United States Department of Agriculture

Somes Bar Integrated Fire 

Management Project

Final Environmental Assessment

Forest 

Service

Pacific Southwest 

Region

Six Rivers 

National Forest

R5-MB-312

April 2018
Cover photo: Low intensity prescribed fire returns to a white oak stand near Orleans, California, during 

the 2014 Klamath River Prescribed Fire Training Exchange (TREX), after over a hundred years of fire 

exclusion. Photo courtesy of Will Harling, Mid Klamath Watershed Council.

In accordance with Federal civil rights law and US Department of Agriculture (USDA) civil rights 

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

or administering USDA programs are prohibited from discriminating based on race, color, national origin, 

religion, sex, gender identity (including gender expression), sexual orientation, disability, age, marital 

status, family/parental status, income derived from a public assistance program, political beliefs, or reprisal 

or retaliation for prior civil rights activity, in any program or activity conducted or funded by USDA (not 

all bases apply to all programs). Remedies and complaint filing deadlines vary by program or incident.

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

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

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

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

other than English.

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

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

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

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

USDA by: (1) mail: US Department of Agriculture Office of the Assistant Secretary for Civil Rights, 

1400 Independence Avenue SW, Washington, DC 20250-9410; (2) fax: (202) 690-7442; or (3) email: 

program.intake@usda.gov.

USDA is an equal opportunity provider, employer, and lender.
Final Environmental Assessment – i

Somes Bar Integrated Fire Management Project

Environmental Assessment

Siskiyou County, California

Responsible Official: Merv George Jr., Forest Supervisor

Six Rivers National Forest

1330 Bayshore Way

Eureka, CA 95501-3834

(707) 441-3534

mgeorge@fs.fed.us

For Information Contact: Nolan C. Colegrove Sr., District Ranger

Lower Trinity, Orleans and Ukonom Ranger Districts

PO Box 410

1 Ishi Pishi Road

Orleans, CA 95556

(530) 627-3291 (Orleans)

ncolegrove@fs.fed.us
ii – Somes Bar Integrated Fire Management Project

This page intentionally left blank.
Final Environmental Assessment – iii

Table of Contents

Chapter 1. Purpose and Need........................................................................................................................1

Changes between Draft and Final Environmental Assessment ................................................................1

Introduction ..............................................................................................................................................2

Project Location........................................................................................................................................3

Wildland-Urban Interface...................................................................................................................4

Karuk Aboriginal Territory ................................................................................................................5

Landscape Character ..........................................................................................................................7

A Welcome Change..................................................................................................................................7

Fire Race... The story of the Karuk or Upstream People ..................................................................8

Purpose and Need for the Proposal...........................................................................................................8

Restoring and Maintaining Resilient Landscapes...............................................................................9

Resilient Communities .....................................................................................................................11

Resilient Economies.........................................................................................................................12

Proposed Action .....................................................................................................................................15

Principle Laws and Regulations that Influence this EAs Scope.............................................................16

Land and Resource Management Plans............................................................................................16

Other Relevant Direction..................................................................................................................17

Decision Framework...............................................................................................................................20

Collaboration, Public Involvement and Tribal Consultation..................................................................20

A Story that needs to be Told ...........................................................................................................20

US Forest Service Fire Management................................................................................................20

Karuk Fire Management...................................................................................................................20

Community Wildfire Management – Orleans/Somes Bar Fire Safe Council...................................21

Western Klamath Restoration Partnership .......................................................................................22

Scoping.............................................................................................................................................22

Comments on the Draft EA ..............................................................................................................23

Chapter 2. The Alternatives........................................................................................................................25

Introduction ............................................................................................................................................25

Early Community Planning ....................................................................................................................25

Identifying Critical Threats to Conservation Values........................................................................26

Defining Goals and Objectives.........................................................................................................27

Alternatives Considered in Detail...........................................................................................................35

Alternative 1 – No Action ................................................................................................................35

Alternative 2 – Proposed Action ......................................................................................................38

Monitoring..............................................................................................................................................94

Alternatives Considered but Eliminated from Detailed Study ...............................................................95

Alternative 3: Consider Northern Spotted Owl as Driving Force in Project Development..............95

Comparison of Alternatives Considered in Detail..................................................................................98

Chapter 3. Environmental Consequences .................................................................................................103

Introduction ..........................................................................................................................................103
iv – Somes Bar Integrated Fire Management Project

Place-based Setting...............................................................................................................................104

Archaeology and Living Environment ...........................................................................................105

Fire, Fuels and Community ............................................................................................................106

Fire Behavior and Fire Effects........................................................................................................107

Vegetation.......................................................................................................................................107

Wildlife and Traditional Ecological Knowledge Species and their Habitats .................................108

Watershed Values...........................................................................................................................109

Soils................................................................................................................................................109

Botany ............................................................................................................................................110

Invasive Species.............................................................................................................................111

Resource Topics by Alternative Considered in Detail..........................................................................111

Cultural Resources..........................................................................................................................111

Fire and Fuels.................................................................................................................................131

Vegetation.......................................................................................................................................155

Wildlife...........................................................................................................................................172

Watershed Values – Water Quality, Geology and Fisheries ..........................................................217

Soil Resources................................................................................................................................235

Botanical Resources – Sensitive Plant and Fungi Species .............................................................246

Invasive Plant Species....................................................................................................................258

Social Environment ........................................................................................................................265

Finding of No Significant Impact .............................................................................................................283

Context .................................................................................................................................................283

Intensity ................................................................................................................................................283

Chapter 4. Consultation and Coordination................................................................................................299

References.................................................................................................................................................301

Appendix A. Collaboration.......................................................................................................................319

Appendix B. Response to Comments .......................................................................................................323

Appendix C. Somes Bar Integrated Fire Management Project Prescriptions...........................................413

Appendix D. National Best Management Practices for Water Quality Management...............................433

Appendix E. Aquatic Conservation Strategy Objectives..........................................................................443

Appendix F. Cumulative Watershed Effects Analysis Using R5 ERA Model .........................................451

List of Tables

Table 1-1. Proposed action treatment summary..........................................................................................15

Table 1-2. Management areas within the Somes Bar Project. ....................................................................16

Table 2-1. Perceived current and future target viability. ............................................................................27

Table 2-2. Recent wildfire starts compared to total acreage burned in the project area vicinity................34

Table 2-3. Recorded wildfires, greater than 200 acres in the project area vicinity.....................................35

Table 2-4. Crown class and fuel-type classes. ............................................................................................46

Table 2-5. Phasing of treatments.................................................................................................................55

Table 2-6. First entry mechanical unit treatments.......................................................................................56
Final Environmental Assessment – v

Table 2-7. First entry manual, mastication and prescribed burning unit treatments...................................59

Table 2-8. Temporary roads necessary for project implementation............................................................67

Table 2-9. Log landings available for expediting timber harvest operations..............................................69

Table 2-10. Maintenance Level 1 (ML 1) system road use. .......................................................................70

Table 2-11. Legacy road sediment source treatments.................................................................................71

Table 2-12. Units with known water-source infrastructure. .......................................................................80

Table 2-13. Site-specific project design features (PDFs) for invasive weed treatments.............................84

Table 2-14. Endlining in riparian reserves..................................................................................................85

Table 2-15. Equipment use in outer riparian reserves.................................................................................86

Table 2-16. Units with 18-inch-dbh cutting limit. ......................................................................................89

Table 2-17. High-quality nesting/roosting habitat polygons that overlap treatment polygons. ..................90

Table 2-18. Northern goshawk limited operating period (LOP) for all entries...........................................90

Table 2-19. Types of monitoring and the components that may be used for the Somes Bar Project. ........95

Table 2-20. Treatment summary for Alternative 3. ....................................................................................96

Table 2-21. Comparison of alternatives – Purpose and Need.....................................................................98

Table 2-22. Comparison of alternatives – Relevant Issues.......................................................................100

Table 3-1. Descriptions of fire regime condition classes (FRCC)............................................................136

Table 3-2. Relationship of surface fire flame length and fireline intensity to suppression interpretations.

..........................................................................................................................................................140

Table 3-3. Environmental inputs used for FVS fire modeling—WKRP fuel modeling parameters 

(FireFamily Plus Output)..................................................................................................................141

Table 3-4. FVS current condition modeling of potential associated fire behavior in plantations—FVS 

output depicting potential flame lengths (No Action Alternative)....................................................144

Table 3-5. FVS current condition modeling of potential associated fire behavior in non-plantations—FVS 

output depicting potential flame lengths (No Action Alternative)....................................................144

Table 3-6. Recent wildfire on the Six Rivers National Forest, lightning ignited compared to other starts.

..........................................................................................................................................................145

Table 3-7. Recent wildfire starts compared to total acreage burned.........................................................145

Table 3-8. FVS output showing impact of the Proposed Action on fire behavior in plantations—FVS 

output depicting potential flame lengths (within plantations, thin, pile, and burn in 2019). ............150

Table 3-9. FVS output showing impact of the Proposed Action on fire behavior in non-plantations—FVS 

output depicting potential flame lengths (within non-plantations, thin, pile, and burn in 2019)......150

Table 3-10. Current fuel conditions in a representative previously managed stand (pre-treatment). .......152

Table 3-11. Future stand condition following thinning and burning treatments (post-treatment)............152

Table 3-12. Acres of managed stands by date of plantation establishment within each project area. ......156

Table 3-13. Acres of managed stands by date of plantation establishment by Proposed Action treatment 

type. ..................................................................................................................................................157

Table 3-14. Year of activities modeled by FVS within each stand group. ...............................................159

Table 3-15. Karuk Tribe focal species short-and long-term response to treatments.................................175

Table 3-16. Units, prescription treatments, and approximate acres of late-successional reserves (LSRs) in 

the Somes Bar Project.......................................................................................................................177

Table 3-17. List of wildlife species analyzed with associated indicators. ................................................178

Table 3-18. Criteria used for northern spotted owl risk to reproduction analysis Indicator. ....................188
vi – Somes Bar Integrated Fire Management Project

Table 3-19. Northern spotted owl activity centers (ACs) within analysis area (pre-treatment). ..............193

Table 3-20. Effects to Northern spotted owl (NSO) activity centers (ACs) from proposed project 

activities............................................................................................................................................195

Table 3-21. Proposed treatments by activity center..................................................................................196

Table 3-22. The number of NSO sites within each level of risk to reproduction (Analysis Indicator 1). 198

Table 3-23. Change in NSO critical habitat analysis Indicator 2..............................................................198

Table 3-24. Summary of the Proposed Action and its effect on each federally listed and Forest Sensitive 

species. ..............................................................................................................................................206

Table 3-25. Summary of harvesting by project area.................................................................................212

Table 3-26. Minimum width of primary shade zone (feet) based on slope and tree height......................222

Table 3-27. Miles of coho habitat by project area. ...................................................................................223

Table 3-28. Percent of project area in the analysis area............................................................................225

Table 3-29. Existing Equivalent Roaded Acres (ERA) values by watershed. ..........................................227

Table 3-30. Summary of ground disturbance within riparian reserves.....................................................232

Table 3-31. Total equivalent roaded acres (ERA) percentages by watershed for Proposed Action. ........233

Table 3-32. Soil-cover guidelines for projects..........................................................................................241

Table 3-33. Sensitive species known or detected in project analysis and their general habitat................247

Table 3-34. Definitions of Roaded-Natural, Rural and Semi-Primitive Motorized ROS classes.............269

Table 3-35. Visual quality objective (VQO) definitions...........................................................................270

Table 3-36. Proposed treatment summary. ...............................................................................................273

Table 4-2. Environmental assessment contributors. .................................................................................299

Table A-1. Western Klamath Restoration Partnership (WKRP) meetings. ..............................................319

Table A-2. Western Klamath Restoration Partnership (WKRP) meeting participants. ............................321

Table B-1. Project scoping comments received during February 21 through March 23, 2017 scoping 

period. ...............................................................................................................................................323

Table B-2. Listing of the names and locations of the commenters, the organization or entity each 

commenter represents, and the type and date of the comment submitted.........................................347

Table B-3. Minimum width of primary shade zone (feet) based on slope and tree height. ......................375

Table B-4. Units, prescription treatments, and approximate acres of late-successional reserves (LSRs) in 

the Somes Bar Project.......................................................................................................................392

Table C-1. Mechanical harvest units (Prescriptions 1a, 1b and 2)............................................................425

Table C-2. Mastication units (Prescription 3)...........................................................................................427

Table C-3. Manual Units (Prescriptions 4a and 4b)..................................................................................427

Table C-4. Prescribed fire units (Prescription 5a).....................................................................................431

Table F-1. Threshold of concern by watershed.........................................................................................451

Table F-2. ERA coefficients and recovery times......................................................................................452

Table F-3. Road ERA coefficient and recovery times. .............................................................................453

Table F-4. Wildfire ERAs.........................................................................................................................454

Table F-5. Current condition percent ERA compared to TOC. ................................................................454

Table F-6. Proposed Action ERA results..................................................................................................455

Table F-7. ERA analysis results................................................................................................................455
Final Environmental Assessment – vii

List of Figures

Figure 1-1. WKRP workshop in Orleans shares planning efforts and gathers input from a diverse group of 

participants............................................................................................................................................2

Figure 1-2. Somes Bar Project vicinity map.................................................................................................3

Figure 1-3. Wildland-urban interface and the project area. ..........................................................................4

Figure 1-4. Project areas relative to Karuk aboriginal territory and project area..........................................5

Figure 1-5. Katimiin Cultural Management Area.........................................................................................6

Figure 1-6. Marble rim from Orleans Mountain. Photo by Will Harling......................................................7

Figure 1-7. Dense vegetation typically found in project area. ......................................................................9

Figure 1-8. Graphic example of building fire resiliency in forests. From top to bottom: lightning fires, 

lightning and indigenous burning, fire suppression. (Anderson and Barbour 2003) ...........................10

Figure 2-1. WKRP utilized a collaborative process to develop overlay assessments to better prioritize 

manual, mechanical and prescribed burning treatment methods and locations..................................25

Figure 2-2. A shaded fuelbreak created in a tanoak forest benefits the landowner who lives just upslope, 

elk that frequent the stand to feed and bed down, and tribal members who gather tanoak acorns for 

subsistence and ceremonial use. .........................................................................................................29

Figure 2-3. The WKRP plan for restoring fire-adapted landscapes identified strategic features (roads, 

mechanical and manual treatments around private property and burn treatments between roads and 

mountain ridgetops) to protect neighborhoods......................................................................................32

Figure 2-4. Fire regime condition class based on departure from fire return interval. ...............................33

Figure 2-5. Fire starts by cause and ignition density. .................................................................................34

Figure 2-6. Fire history from 1900 to 2017 within and surrounding the focal areas. .................................36

Figure 2-7. Prescribed burn in progress......................................................................................................45

Figure 2-8. Mechanical treatment unit in a 50-year-old plantation, featuring multi-stemmed tanoaks intermixed with Douglas-fir.......................................................................................................................47

Figure 2-9. Mature black oaks being outcompeted by younger Douglas-fir. The Douglas-firs are in the 

stem exclusion stage, putting all their resources into growing taller in the competition for light and 

shading out the oaks............................................................................................................................47

Figure 2-10. Manual treatment unit in a 32-year-old plantation, Douglas-firs mixed with multi-stemmed 

tanoaks. ...............................................................................................................................................49

Figure 2-11. Mechanical treatment unit in a non-plantation, high stem density forest resulting from fire 

suppression. These trees, which have grown up in the fire suppression era, are too big to treat 

effectively with a manual treatment....................................................................................................50

Figure 2-12. Young plantation (very high stem density of tanoak, madrone and Douglas-fir) where 

masticators are employed to reduce fuel loading in preparation for prescribed burning....................51

Figure 2-13. Manual treatment unit in a non-plantation, high stem density forest resulting from fire 

suppression. These trees, which have grown up in the fire suppression era, are small enough to be 

treated effectively by hand..................................................................................................................53

Figure 2-14. Prescribed fire treatment unit, low amounts of ladder fuels and ample surface fuels create a 

condition where prescribed fire is an effective treatment...................................................................54

Figure 2-15. Donahue project area proposed action. ..................................................................................72

Figure 2-16. Donahue project area connected actions. ...............................................................................73

Figure 2-17. Patterson project area proposed action...................................................................................74

Figure 2-18. Patterson project area connected actions................................................................................75
viii – Somes Bar Integrated Fire Management Project

Figure 2-19. Rogers Creek project area proposed action............................................................................76

Figure 2-20. Rogers Creek project area connected actions.........................................................................77

Figure 2-21. Ti Bar project area proposed action. ......................................................................................78

Figure 2-22. Ti Bar project area connected actions. ...................................................................................79

Figure 2-23. Water drafting site locations. .................................................................................................88

Figure 2-24. Schematic of multi-party monitoring strategy........................................................................94

Figure 2-25. Alternative 3 – proposed treatment methods and locations....................................................97

Figure 3-1. Recent fire activity (1909-2016) near the project area showing time since last fire (including 

prescribed fire)..................................................................................................................................135

Figure 3-2. Project areas depicting mean pre-settlement fire-return interval departure. ...............................137

Figure 3-3. Project area associated hazard assessment rating (FlamMap wildfire modeling)..................140

Figure 3-4. Recent fire history map of the project areas and surrounding landscapes...............................147

Figure 3-5. Relative sizes of beach sand, flour and a PM 2.5 particle in smoke. .....................................148

Figure 3-6. Current and predicted percent SDI in plantations. .................................................................160

Figure 3-7. Current and predicted percent SDI in natural stands..............................................................161

Figure 3-8. Current and predicted percent SDI in natural stands..............................................................161

Figure 3-9. Current and predicted percent SDI in plantations. .................................................................161

Figure 3-10. Current and predicted percent SDI in natural stands............................................................162

Figure 3-11. Current and predicted percent SDI in plantations. ...............................................................162

Figure 3-12. Current and predicted percent SDI in plantations. ...............................................................162

Figure 3-13. Current and predicted percent SDI in natural stands............................................................163

Figure 3-14. Current and predicted BA mortality in plantations. .............................................................164

Figure 3-15. Current and predicted BA mortality in plantations. .............................................................164

Figure 3-16. Current and predicted BA mortality in natural stands..........................................................164

Figure 3-17. Current and predicted BA mortality in plantations. .............................................................165

Figure 3-18. Current and predicted BA mortality in natural stands..........................................................165

Figure 3-19. Current and predicted BA mortality in plantations. .............................................................165

Figure 3-20. Current and predicted BA mortality in plantations. .............................................................166

Figure 3-21. Current and predicted BA mortality in natural stands..........................................................166

Figure 3-22. Current and predicted QMD (inches) in plantations. ...........................................................168

Figure 3-23. Current and predicted QMD (inches) in plantations. ...........................................................168

Figure 3-24. Current and predicted QMD (inches) in natural stands........................................................168

Figure 3-25. Current and predicted QMD (inches) plantations. ...............................................................169

Figure 3-26. Current and predicted QMD (inches) natural stands............................................................169

Figure 3-27. Current and predicted QMD (inches) plantations. ...............................................................169

Figure 3-28. Current and predicted QMD (inches) plantations. ...............................................................170

Figure 3-29. Current and predicted QMD (inches) in natural stands........................................................170

Figure 3-30. Northern spotted owl (NSO) analysis area...........................................................................187

Figure 3-31. Watershed effects analysis boundaries.................................................................................225

Figure 3-32. Aerial view of steep slopes in the Klamath Mountains........................................................265

Figure 3-33. Map of historic timber harvesting in the project areas.........................................................266
Final Environmental Assessment – ix

Figure 3-34. Post-fire landscape showing charred downed woody material that was once a living forest 

with scenic integrity..........................................................................................................................271

Figure 3-35. Map of example gaps and retention distribution..................................................................272

Figure 3-36. Map of visual quality objectives within the project (or focal) areas. ...................................274

Figure 3-37. Map of the Rogers Creek project area viewshed with proposed treatments. .......................275

Figure 3-38. Map of the Patterson project area viewshed with proposed treatments. ..............................276

Figure 3-39. Map of the Ti Bar project area viewshed with proposed treatments....................................277

Figure 3-40. Map of the Donahue project area viewshed with proposed treatments................................278

Figure 3-41. Prescribed burning during and after. ....................................................................................280

Figure 3-42. Rural residential interface with smoke disturbance..............................................................280
x – Somes Bar Integrated Fire Management Project

This page intentionally left blank.
Chapter 1. Purpose and Need

Final Environmental Assessment – 1

Chapter 1. Purpose and Need

Changes between Draft and Final Environmental Assessment

The US Forest Service (USFS or Forest Service) made minor grammatical changes, corrected inadvertent 

misspellings and technical errors, and added the response to public comments and findings of consulting 

regulatory agencies following the distribution of the Somes Bar Integrated Fire Management Project 

Draft EA (Somes Bar Project draft EA). Specific changes made include:

Chapter 1. Comments on the Draft EA. This new section discloses how the public was notified 

of the start of the comment period, the length of the comment period, and how many individuals 

and organizations were provided the draft environmental assessment (EA) for review.

Chapter 2. Project Design Features and Mitigation Measures. Further description of the 

proposed treatment mitigations were included under the Fisheries, Wildlife and Soils sections 

to improve clarity.

Chapter 3. Wildlife. Updated habitat removal numbers for road and landing construction 

(Table 3-15). Also added clarity about scattered openings in the project area, as well as 

additional information about treatments within late-successional reserves (LSRs). Clarified 

snag and coarse woody debris standards and guidelines (S&Gs) for both the Klamath (KNF) 

and Six Rivers (SRNF) national forests. Updated habitat acres for northern spotted owl 

(NSO) activity centers (ACs) within the action area (Table 3-18). Added a new table (Table 3-

20) further disclosing effects to NSO ACs. Updated the NSO critical habitat analysis for 

Indictor 2 (Table 3-21). Supplemented the cumulative effects analysis. Added information 

regarding proposed monitoring of Roosevelt elk (habitat enhancement and utilization) that 

would be conducted by the Karuk Tribe and other WKRP partners.

Chapter 3. Invasive Plant Species. Further description of the monitoring findings of past 

project design features (PDFs) used to evaluate cumulative effects of Alternative 2 (Proposed 

Action) was incorporated to improve clarity. Additionally, the invasive plant species risk 

assessment includes further description of the methodology used to determine the risk of 

invasive plant introduction or spread under Alternative 2.

References. This section includes citations either inadvertently omitted in the draft EA or new 

citations incorporated in response to public comments, disclosed in Appendix B.

Appendix B. Response to Comments, Comments on the Draft EA. This new section was 

added to Appendix A of this final EA to disclose the US Forest Service (Forest Service or 

USFS) responses to comments on the draft EA.
Chapter 1. Purpose and Need

2 – Somes Bar Integrated Fire Management Project

Introduction

Western Klamath Restoration Partnership (WKRP)1 representatives prepared the Somes Bar I Project final

EA, per the National Environmental Policy Act of 1969 (NEPA), to disclose the effects of a demonstration 

proposal that once again welcomes fire on public lands. This project is the first phase in realizing the goals 

of the National Cohesive Wildland Fire Management Strategy2 (Cohesive Strategy), in accordance with 

traditional ecological knowledge (TEK)3 and customs, as a framework for living with fire in the western 

Klamath Mountains of northern California.

The Somes Bar Project exemplifies participatory planning where all contributors share responsibilities 

for each other’s safety and well-being, and for preserving the nation’s natural resources and our cultural 

legacy for future generations (Harling and Tripp 2014). With this vision in mind, dedicated collaborators 

convened workshops (Figure 1-1) and field trips, coming to agreement in principle and practice on a wide 

range of stewardship treatments across the landscape to begin healing the land (Appendix A).

The proposed land management treatments were designed in alignment with the Klamath and Six 

Rivers national forests’ land and resource management plans (SRNF and KNF LRMPs or forest plans;

USDA Forest Service 1995 and 2010, respectively) and records of decision (ROD(s)), and informed by 

the Karuk Tribe Eco-Cultural Resource Management Plan (Karuk Tribe 2010), Katimiin Memorandum of 

Understanding (MOU; Karuk Tribe and USDA Forest Service 2017), and the Orleans/Somes Bar 

Community Wildfire Protection Plan (CWPP; CWPP 2012).

 1 Western Klamath Restoration Partnership (WKRP): WKRP formed in 2013 to build trust and a shared vision for restoring fire 

resilience at the landscape scale. Members include representatives from the US Forest Service, Karuk Tribe, Mid Klamath Watershed 

Council, Orleans-Somes Bar Fire Safe Council, Salmon River Restoration Council, The Nature Conservancy Fire Learning Network, 

Klamath Forest Alliance, Environmental Protection Information Center, University of California Berkeley, Bureau of Indian Affairs, 

National Oceanic and Atmospheric Administration, Environmental Protection Agency, and US Fish and Wildlife Service. 2 National Cohesive Wildland Fire Management Strategy (Cohesive Strategy): The Federal Land Assistance, Management and 

Enhancement Act of 2009 (FLAME Act) was signed by the President in November 2009. The Act states, in part, “Not later than one 

year after the date of the enactment, the Secretary of the Interior and Secretary of Agriculture shall submit to Congress a report that 

contains a cohesive wildfire management strategy.” The Act directs that a cohesive strategy be developed addressing seven specific 

topic areas ranging from how to allocate fire budgets at the Federal level to assessing threats to communities, and prioritizing 

hazardous fuels project funds. The Act is the catalyst for bringing fire leadership at all levels and agencies together and prompting a 

new approach to how wildland fire is managed (www.forestsandrangelands.gov). 3 Traditional Ecological Knowledge (TEK): cumulative body of knowledge, practice, and belief, evolving by adaptive processes and 

handed down through generations by cultural transmission, about the relationship of living beings (including humans) with one another 

and with their environment (Berkes et al. 2000).

Figure 1-1. WKRP workshop in Orleans shares planning efforts and gathers input from a diverse 

group of participants.
Chapter 1. Purpose and Need

Final Environmental Assessment – 3

Project Location

The Somes Bar Project area (Figure 1-2) encompasses 5,570 acres of National Forest System (NFS) lands 

administered by the Orleans/Ukonom Ranger District (RD) in T11N, R6E, Sec. 5-6; T12N, R6E, Sec. 2-4, 9-

11, 14-16, 19-21, and 29-33; T14N, R6E, Sec. 34-35; and T13N, R6E, Sec. 3, 5, 8-9, 17, 20-21, 27, 29, and 

32-33; Humboldt Base Meridian, California.

Figure 1-2. Somes Bar Project vicinity map.
Chapter 1. Purpose and Need

4 – Somes Bar Integrated Fire Management Project

Wildland-Urban Interface

The Somes Bar Project area is composed of four (4) distinct project areas—Donahue Flat, Patterson, 

Rogers Creek and Ti Bar—that surround isolated private and tribal land parcels (Figure 1-2). The four (4) 

project areas were selected for their strategic value to help protect dispersed private land inholdings and 

the community of Somes Bar that are within the wildland-urban interface (WUI) from wildfire, as 

depicted in Figure 1-3. Road access to these inholdings are narrow and windy US Forest Service (USFS

or Forest Service) roads (classified as Maintenance Levels (ML) 2 to 4) that are open year-round. The 

closest community is Somes Bar, located in northern California’s Siskiyou County.

Figure 1-3. Wildland-urban interface and the project area.
Chapter 1. Purpose and Need

Final Environmental Assessment – 5

Karuk Aboriginal Territory

In 1979, the federal government recognized the Karuk Tribe as a sovereign tribal nation with a 

government-to-government relationship with the United States (73 Fed. Reg. 18553-18557). The Karuk 

people reorganized from an aboriginal to a contemporary Native American form of government to

facilitate more effective government-to-government interaction. The Karuk Aboriginal Territory was 

defined (Figure 1-4) and the Karuk Tribal Constitution developed. This recognition was without a 

conveyance of reservation and/or trust land, but did establish a unique jurisdiction for the Karuk people. 

Today, the Karuk Tribe is the second largest federally recognized tribe in California with 3,744 tribal 

members and 4,110 enrolled descendant tribal members.

Figure 1-4. Project areas relative to Karuk aboriginal territory and project area.
Chapter 1. Purpose and Need

6 – Somes Bar Integrated Fire Management Project

The 11,950-acre Katimiin Cultural Management Area (CMA) 8 lies within the Rogers Creek and 

Donahue project areas (Figure 1-5). The MOU between the Karuk Tribe and the Forest Service provides a 

platform for both parties work together to meet mutually beneficial goals and objectives for management 

of this area that is of indescribable importance to the Karuk people.

On the broader scale, establishing strategic ridge-top fuelbreaks, boundary defensible space buffers, 

and defensible space along associated egress routes and landscape fuels reduction within these project 

areas would set the stage for enabling greater social license to restore the cultural practice of burning 

Offield Mountain, as part of the Pikyavish World Renewal Ceremony at Katimiin held each September. As 

Figure 1-5. Katimiin Cultural Management Area.
Chapter 1. Purpose and Need

Final Environmental Assessment – 7

an integrated focus, there are resource-rich areas utilized by the Karuk who have considerable knowledge 

about the productivity and management of these resources, their uses, and associated human responsibility.

Landscape Character

The project area is positioned in the western Klamath Mountains region, primarily along the Klamath 

River corridor. Wildfire is one of the primary natural disturbances in the landscape. All the natural 

vegetation types have adapted to a fire-disturbance regime, and many are dependent upon fire for their 

persistence. Over the past century, fire suppression along with intensive timber harvest practices 

(clearcutting) have altered vegetation types, favoring Douglas-fir rather than true oak species, Pacific 

madrone, and ponderosa and sugar pine.

The terrain can be steep and rugged, ranging from 20 to 85 percent slopes (Figure 1-6). Elevations 

within the project area range from about 800 to 3,000 feet. The climate is Mediterranean, characterized by 

hot, dry summers, followed by cold, wet winters. Most of the precipitation is rainfall, accumulating an 

average of 60 inches per year in the valley. The project area supports important habitats for resident and 

anadromous fish species, northern spotted owl, Roosevelt elk and black-tailed deer, to name a few.

A Welcome Change

Despite differences in European and Native American cultures, core values, jurisdictional authorities and 

disjointed funding mechanisms respective of fire programs, all participants adamantly agree there are 

commonalities to be recognized in living with fire. The WKRP reached an agreement in principle for 

promoting frequent fire in that, if enough land is treated with prescribed fire more regularly at a lower 

intensity as the Karuk once did, there would be less flammable vegetative fuels to burn when lightning or 

human-caused fires do strike.

The Karuk used fire to regularly consume flammable live and dead forest litter (surface fuels), shrubs 

and small trees (ladder fuels), as a tool to regulate vegetative growth and composition, decrease fuels and 

promote cultural natural resources. The Proposed Action would establish a landscape pre-treatment 

Figure 1-6. Marble rim from Orleans Mountain. Photo by Will Harling.
Chapter 1. Purpose and Need

8 – Somes Bar Integrated Fire Management Project

hazardous fuels reduction strategy alongside well-distributed, strategically placed, ridge-top and roadside 

fuelbreaks that set the stage for living with fire, and allowing for safe and frequent prescribed burning 

operations. In this way, the Somes Bar Project is the first step in the long journey to manage the size and 

intensity of natural and human use of restorative fire across all lands, while concurrently managing 

wildfires threatening people, property, cultural and natural resources in a safe and effective manner.

Fire Race... The story of the Karuk or Upstream People

The time has come to listen to echoes from our land... the wisdom and teachings of Native American 

Indians. Their words are simple and their voices are soft. We have not heard them, because we have not 

taken the time to listen. Perhaps now is the time to open our ears and our hearts to the words of wisdom 

they have to say...

... A long time ago, only the three Yellow Jacket sisters had fire. Even though other animals 

froze, the fire was kept from them. Coyote wanted to steal fire, which had been lost in a bet. 

He collected various animals, and placed them at intervals from the river to the mountains. 

Frog was in the first place—closest to the river. There was forest fire in the mountains, and 

he stole it by diverting the children who were in charge of it, and then pretending to fall 

asleep by the fire, having placed oak bark between his toes. At the right moment, he ran away 

with a piece of burning charcoal. The ember was passed from one animal to the next as each 

got tired. Turtle was able to escape by rolling down from a mountaintop towards the river, 

and then gave it to Frog. Frog hid the fire in his mouth, dived in the river and swam to the 

other side, and spat the fire out under a Willow. Dogs howled as the fire rose up, and mankind 

came into existence.

The story of Coyote stealing fire provides an example of how stories encapsulate aspects of 

traditional ecological knowledge (TEK) and outline the combination of responsibility, respect, and 

reciprocity that links the people to their environment. It demonstrates how teachings from the beginning 

of time help inform current practices—the keystone of the Somes Bar Project.

Purpose and Need for the Proposal

The purpose of the Somes Bar Project is to demonstrate how prescribed fire restores and maintains 

resilient ecosystems, communities, and economies to revitalize balanced human relationships with our 

dynamic landscape. The project would also reinstate the use of TEK fire integrated with emergent 

restorative fire practices at the landscape scale, thereby:
Chapter 1. Purpose and Need

Final Environmental Assessment – 9

o Reestablishing frequent fire cycles, behavior and patterns stimulating resilient, spatially 

heterogeneous forest and riparian habitats and self-sustaining populations of culturally 

important Karuk focal species and traditions.4

o Promote shared values, encourage widespread personal ownership and local technical 

skills leading to healthy communities and economies, capable of well-coordinated land 

stewardship regardless of ownership or administrative boundaries.

This proposal responds to the following needs:

Restoring and Maintaining Resilient Landscapes

There is a need to treat fuels and alter forest structure to enable prescribed fire to do its 

ecological work frequently, at relatively self-limiting small scales, historic topographic 

position, and when seasonally appropriate.

Vegetation within the project area experiences wildfire behavior influenced by the Mediterranean climate

and aspect-driven vegetative patterns, as well as wind currents influenced by steep, rugged topography. 

As an unintentional outcome of shrub and invasive weed encroachment and high stocking reforestation 

forestry practices between 1950 and 1994, along with considerable investment in fire suppression 

technologies effectively excluding this natural disturbance, flammability of overgrown forest vegetation 

(Figure 1-7) now makes the use of prescribed fire more complicated as a safe management tool without 

some fuels reduction pre-treatment.

Prior to fire suppression, indigenous burning and uninhibited lightning-ignited wildfires were an 

inseparable part of this forest ecosystem, consuming flashy fuels on a regular cycle. These wildfire 

 4 In 1911, federal policy (Weeks Act) was enacted with a strict goal to “suppress all fires”. The pressure exerted on tribal and settler 

communities to discontinue fire use was immediate and intense.

Figure 1-7. Dense vegetation typically found in project area.
Chapter 1. Purpose and Need

10 – Somes Bar Integrated Fire Management Project

events, coupled by frequent fire use by the Karuk, were mechanisms for environmental change and 

continuous renewal of healthy, heterogeneous wildlife habitats and plant communities.

Karuk culture is directly reliant and dependent on mixed fire severity regimes (Lake 2007). While fire is 

a central component of Karuk management and culture, increased fire severity and frequency poses particular 

and unique risks to specific Karuk tribal foods and cultural use species on the one hand, and to broader tribal 

programmatic goals and activities on the other (Lake et al. 2010). The process of mixed fire severity5

establishes complex mosaic vegetative patterns, stand structure, and species composition.

This regular consumption of surface fuels6 (duff, litter and down logs), vertical ladder fuels7

(saplings/understory trees and climbing invasive vines), created gaps in the forest canopy from random 

torching of single tree crowns and groups of trees, limited heat residence time and kept most flames close 

to the ground, as displayed in Figure 1-8.

 5 Fire Severity: Degree to which a site has been altered or disrupted by fire; loosely, a product of fire intensity and residence time. 6 Surface Fuels: Leaf and needle litter, dead branch material, downed logs, bark, tree cones, and low stature living plants lying 

horizontally, on or near the surface. 7 Ladder Fuels: Trees growing in the forest understory that provide vertical continuity between strata, thereby allowing fire to carry 

from surface fuels into the crowns of trees or shrubs with relative ease.

Figure 1-8. Graphic example of building fire resiliency in forests. From 

top to bottom: lightning fires, lightning and indigenous burning, fire 

suppression. (Anderson and Barbour 2003)
Chapter 1. Purpose and Need

Final Environmental Assessment – 11

Since the early 1900s, every fire interval removed from this fire-adapted landscape has resulted in a 

fire deficit, compounding threats to values at risk. Today, the amount of vegetative fuels buildup across 

forests, shrub and grasslands are incompatible with using fire as a management tool, as burning of 

overgrown vegetative fuels would likely promote volatile active crown fire behavior, difficult for fire 

crews to contain. The need for manipulating ladder fuel patterns and lowering the amount of flammable 

surface fuels represents an incremental step on the journey to manage this fire deficit that otherwise

would be deferred to set the stage for a more hazardous future.

Desired Condition: Heterogeneity is restored and maintained by fire to recreate patch size as if fire 

was never suppressed, assuming application of anthropogenic fire to establish functioning resilient 

heterogeneous forests at multiple scales, benefiting cultural uses, native flora, wildlife habitats and 

successional complexity (borrowed and adapted from Hessburg et al. 2015).

Indicators and Measures: Risk to landscapes and high-value resources and assets are diminished as 

measured by 1) flame length. Heterogeneity is enhanced as measured by 2) stand density index and 3) 

basal area mortality.

Resilient Communities

There is a need to reduce vegetative fuel hazards around private properties and critical 

ingress/egress routes to safeguard life, health and property, as well as improve the ability 

for safe and effective fire management, including planned and unplanned ignitions.

The Karuk used fire as a way to improve access to resource areas and preserve the well-being of village 

communities from high-intensity flame fronts. “Utilizing former trail systems, many now converted to 

roads, can foster a reconnection to place for tribal communities ..., and allow the incorporation of TEK 

into fire and fuel research and management ... ” (Lake 2013)

“The relatively small percentage of fires that escape initial response are vitally important, as they 

account for a disproportionate percentage of the area burned, degraded air quality, damage to homes and 

communities, and injuries and fatalities. For example, a summary of available data shows that the top 3 

percent of fires in terms of individual fire sizes account for over 90 percent of the total area burned 

nationwide from 2002 to 2011” (Cohesive Strategy 2014).

Departures in forest overstory, understory plant communities and subsequent fuel types have also 

been influenced by the introduction of exotic plants (Brooks et al. 2004), primarily in the lower portions 

of the project areas. Himalayan blackberries have established and quickly colonized disturbed areas along 

roads and old landings. Exotic grasses, star thistle and Scotch broom function as flashy fuel hazards and 

can increase flammability during wildfires (CWPP 2012).

Concerns for human safety and property in the dispersed homesteads in the Rogers Creek, Patterson, 

Ti Bar and Donahue Flat neighborhoods from wildfire are further exacerbated by limited access and 

egress routes. Access may be temporarily blocked along specific routes where there is active fire, 

sometimes enforced by forest closure orders. As flames emit thick smoke and fire embers spread, human 

safety can be threatened, along with air quality and driver visibility. Even structures not immediately 
Chapter 1. Purpose and Need

12 – Somes Bar Integrated Fire Management Project

adjacent to wildland vegetation are at risk from wildfire, as embers can be transported by wind and ignite 

vulnerable homes a mile or more away from the flame front (Cohen 2000).

Desired Condition: Human health and safety, community prosperity and revitalization of our human 

relationships to the natural world are in harmony.

Indicators and Measures: Risk of wildfire impacts to communities is reduced and effectiveness of 

mitigation activities is monitored, collected and shared. This is measured by 1) the potential rate of 

spread and 2) the change in fire type.

Resilient Economies

There is a need to provide traditional and local food sources, forestry and fire 

management training, local living-wage jobs and commercial forest by-products to 

promote local economic vitality.

The isolation of the project area, due in part to rugged terrain and narrow, windy roads, predestines the 

people of the area to be dependent on gathering and extracting local natural resources to supplement their 

diet and as capital to exchange in the market system. In the mid- to late-1900s, the logging and mining 

industries became important to the local economy by providing seasonal jobs for people in the area. The 

boom-and-bust nature of these industries contributed to unemployment and a cycle of poverty, while 

promoting even-age forestry management practices that inadvertently disrupted ecological cycles,

compromising the services provided by industrial and traditional/cultural systems.

With the decline in big game, salmon and other foods from the land, those living in Orleans, Somes 

Bar and other nearby areas are compelled to purchase foods in grocery stores or rely on government 

commodities and subsidies. This financial deficit can make or break a family business or promote poor 

diet and health. Poverty can affect one’s ability to overcome or bounce back from severe weather, forest 

fires and other climatic change impacts, as the lack of financial resources may prevent one from receiving

proper healthcare, have a monetary safety net, or prepare for future changes.

Traditional and local food source-based economies.

The lack of available traditional food sources has not only decreased the Karuk people’s nutritional 

intake, it has resulted in an overall absence of food devastating their aboriginal resource base, leaving 

Karuk people with basic issues of food security. This distinction is both based on the fact that Karuk 

people are denied access to many of their former (first) foods due to federal policy and environmental 

damage, and the fact that the nearest supermarket is a two-hour drive from most parts of Karuk ancestral 

territory. Studies indicate this is directly linked to the disproportionate unemployment and low socioeconomic status of many Karuk people today, resulting in poverty and hunger rates that are among the 

highest in the state and nation (Norgaard et al. 2011).

Once amongst the most plentiful food systems in the world, Karuk ancestral territory now 

falls under the classification of a food desert.
Chapter 1. Purpose and Need

Final Environmental Assessment – 13

Access to abundant and quality hunting, fishing, and gathering areas, as well as traditional, 

ceremonial, or religious fire use, has significantly declined following fire exclusion. Once abundant,

natural resources, including foods supporting wholesome diets, medicines promoting good health, and 

raw materials for making tools, clothing, cordage and structures are in a state of diminishment relative to 

quality and abundance (Western Regional Science-Based Risk Analysis Report 2012).

Depending on the scale and intensity of a particular fire event, a patch of habitat or conditions at a 

landscape scale can be altered, shifting nutrient and energy cycles and other ecological processes that 

favor some species or communities while adversely affecting others (Agee 1998). Changes in 

characteristic fire patterns can have substantial consequences for ecosystems and the species they harbor, 

including wildlife and plant pollinators adapted to specific open canopy vegetative types (Ice et al. 2004, 

Brown et al. 2000, Wilcove et al. 1998, Stein et al. 2013).

The Karuk tribal economy continues to center around formal and informal economic endeavors related 

to natural resources. As the abundance and range of key plant and animal species is affected by climate 

change, subsistence hunting, fishing and gathering activities that provide a significant percentage of food 

for some native families will continue to be compromised, forcing these families to spend more money on 

conventional groceries. This is particularly troubling given that indigenous communities are among the 

most economically impoverished in the United States (Leichenko 2003, Sarche and Spicer 2008).

Tribal communities often have tight social networks, traditions and knowledge that foster 

resilience in the face of climate change and mitigate the vulnerabilities that may arise as a 

result of financial scarcity.

It is important to note that in a traditional cultural paradigm void of Western influence, most tribal 

monetary systems were tied directly to the health and abundance provided by human-natural systems. 

Indigenous communities typically could not generate site-specific excess needed for trade or use for 

specialty items, such as ceremonial regalia, without first fulfilling the human responsibility. In contrast, 

the contemporary regional economy and monetary system is linked to extraction, environmental 

degradation, and profit accumulation. As tribes move into a climate-change era, there is an opportunity 

(albeit challenging) to plan for tribal economic futures that restore former responsibilities and values, and 

prioritize social and ecological health as a key element of economic sustainability.

Forestry and fire management training.

In 2008, the US Fire Learning Network (FLN) designed a novel program to provide training and learning 

opportunities for wildland fire professionals. These one- to three-week events, known as Prescribed Fire 

Training Exchanges (or TREX), provide opportunities to implement prescribed fires (or controlled burns) 

and give trainees high-quality training assignments, as well as exposure to new people, places and 

techniques. The FLN now hosts dozens of TREX events across the country each year. The events are 
Chapter 1. Purpose and Need

14 – Somes Bar Integrated Fire Management Project

deliberately designed to create opportunities for trainees to work with qualified trainers. The host units, 

meanwhile, get qualified workers to help with large or complex burn events.

In October 2013, the WKRP hosted their first two-day TREX event in Orleans. Now, the Klamath 

TREX is an annual two-week training in the use of controlled burning to reduce the danger of wildfires in 

the western Klamath Mountains. With funding and resources from federal, tribal, state, local, and nongovernmental organizations, the TREX events help bring in more participants to deliver good fire to a 

larger landscape. Every year, the Klamath TREX advances the training of firefighters from around the 

region, the nation and even the world to share best practices and knowledge about how to implement 

controlled burns. This training event blends traditional native burning with western science to restore fire 

processes around communities where it is needed most. To date, the Klamath TREX has accomplished 

over 750 acres of prescribed fire on private lands in Orleans and Somes Bar. These efforts compliment 

treatments proposed on public lands in the Somes Bar project.

The Nature Conservancy (TNC), who facilitates the FLN for US Department of Agriculture (USDA) 

and US Department of the Interior (USDI) agencies, worked with local partners and the Forest Service’s 

Region 5 to establish an MOU that provides the framework for cross-boundary burning and sharing of 

resources during TREX events. The SRNF has a current (2016) supplemental agreement that allows forest 

employees to participate in the Klamath TREX, and for TREX resources to be used to implement 

controlled burns on Forest Service lands with forest leadership. This mechanism for combining local, 

tribal, and federal resources would be utilized in scaling up to implement fire management actions as 

described in the Somes Bar Project.

Local living-wage jobs.

The WKRP and this project, not including the Klamath TREX or USFS employees, have already 

contributed over $1.4 million to the local economy. A portion of these funds has gone to local contractors 

and the majority has been invested in the local workforce to accomplish field surveys, environmental 

planning and development of a multi-party monitoring strategy. From 2016 to 2017, the number of fulltime-equivalent (FTE) positions increased over 200 percent. In addition to USFS employees, WKRP now 

contributes almost 10 FTE jobs, all at living-wage8 pay rates. The number of jobs is expected to increase 

at least as much during the implementation of the project. During the implementation of the initial 

treatment entry, it is estimated that WKRP, including contractors, would employ almost 20 FTE local 

living-wage jobs each year.

Desired Conditions: The desire is to provide for tribal and local community subsistence needs and 

access to high quality, abundant food and fiber resources in support of traditional economies dependent on 

food security. Communities are defined as food secure when all members have access to nutritionally 

good, safe and culturally acceptable foods through local sources at all times.

Ecological trends inform the process of intergenerational knowledge transfer and restoration of 

cultural use plants and substance foods, forestry-based training opportunities and local living-wage jobs to 

 8 Based on the Massachusetts Institute of Technology living wage calculator for both Humboldt and Siskiyou Counties 

(http://livingwage.mit.edu/resources/Living-Wage-User-Guide-and-Technical-Notes-2016.pdf).
Chapter 1. Purpose and Need

Final Environmental Assessment – 15

build local capacities and institutionalize a consistent bridge to a resilient landscape capable of producing 

food and traditional resources. The desired trajectory is to scale up to revitalize TEK through integration 

of intergenerational education programs and activities that build upon a cumulative wealth of knowledge, 

repeated practice and long-standing beliefs that can be passed on orally, learning from experience, and 

adaptive to change in perpetuity.

The training and jobs provided and project-generated revenue would be reinvested into the local 

economy through direct and indirect contributions to local county revenues, generated from purchases and 

sales of goods and services produced locally, creating diversified sources of revenue streams.

Indicators and Measures: Cultural use flora and fauna habitat restoration measured by 1) acres 

enhanced; local workforce qualification of training measured by 2) the number of living-wage jobs 

providing environmental planning and hands-on field experience; forestry related employment 

opportunities measured by 3) the number of potential stable, seasonal or full time jobs; and the potential 

for commercial forest products measured by 4) the amount of timber volume in million board feet.

Proposed Action

The Somes Bar Project would establish up to 250,822 linear feet of Strategic Fire Control Features 

(SFCF) and implement up to 5,570 acres of landscape-scale integrated vegetative, fuels reduction and 

restorative prescribed burning alongside roads and interior forests, phased over 15 years. A maximum of 

160 landings (30 would be newly constructed), long-term and incidental temporary hand lines, and 11 

miles of temporary road access (0.6 miles of new construction) may be required to facilitate operations, as 

summarized in Table 1-1.

Table 1-1. Proposed action treatment summary.

Integrated Fire Management Treatments Area and/or Length

Strategic Fire Control Features Feet

Ridgetop Shaded Fuelbreak 105,524

Handline 145,298

Treatments –Total Acres Acres

Manual, Prescribed Burn 2,658

Mastication, Manual, Prescribed Burn 187

Mechanical - cable system, Manual, Prescribed Burn 176

Mechanical - ground-based, Manual, Prescribed Burn 1,058

Prescribed Burn 1,491

Total 5,570

Landings – Mechanical and Mastication units only Number Acres

Existing Landing 130 63

New Landing 30 13

Total 160 76

Temporary Use Road – Access to Mechanical and Mastication units Miles

Existing Mastication Access Road 2.3

Existing Temp Roads 8.1

New Temp Road 0.6

Total 11.0
Chapter 1. Purpose and Need

16 – Somes Bar Integrated Fire Management Project

Integrated Fire Management Treatments Area and/or Length

Level 1 Roads to be Used – Provides access to Mechanical, Manual and Prescribed fire units Miles

13N12A 0.9

13N14A 1.2

13N14C 0.2

13N14D 0.5

13N14E 0.5

13N18A 0.3

13N18E 0.5

14N15 0.5

Total 4.7

Legacy Road Sediment Source Restoration – Route Number Miles

9400 0.09

9100 0.35

9101 0.13

9102 0.22

9103 0.19

9402 0.11

Total 1.09

Principle Laws and Regulations that Influence this EAs Scope

This section describes land management direction and regulations relevant to the Somes Bar Project area, 

which provided the legal framework for opportunities and constraints to achieving desired conditions. It 

also provides the foundation for assessing the environmental effects to the human environment analyzed 

in this final EA.

The Somes Bar Project was developed in alignment with the Aquatic Conservation Strategy (ACS) 

reflected in the ROD and standards and guidelines (S&Gs) of the Northwest Forest Plan (NWFP; USDA 

and USDI 1994a), as incorporated into the SRNF and KNF LRMPs, as described below.

Land and Resource Management Plans

The Proposed Action was developed in alignment with land management direction in the in the SRNF 

and KNF LRMPs and RODs, as follows in Table 1-2.

Table 1-2. Management areas within the Somes Bar Project.

Management Areas Management Goals Acres

Wildland Urban Interface

The wildland urban interface (WUI) zone is an area where human 

habitation is mixed with areas of flammable wildland vegetation. It 

extends out from the edge of developed private land into federal, 

private, and state jurisdictions. The WUI Threat zone boundaries 

generally extend approximately 11⁄4 miles out from the defense zone 

boundary; however, actual extents of threat zones are based on fire 

history, local fuel conditions, weather, topography, existing and 

proposed fuel treatments, and natural barriers to fire. Fuels 

treatments in these zones are spatially placed to reduce wildfire 

intensity and interrupt spread, designed to link to the larger fuelbreak 

network to the north and south and other features, such as roads and 

rocky areas, effective as anchor areas to contain wildfire.

5,570
Chapter 1. Purpose and Need

Final Environmental Assessment – 17

Management Areas Management Goals Acres

Cultural Management Area 8 The integrity of the area for use by the Karuk Tribe is maintained in a 

manner consistent with their customs and culture. 2,306

Visual Quality Objectives (VQOs)

Management treatments are designed to appear natural by retaining 

variable forest structure mimicking healthy forest conditions that 

would not be visually evident and would remain visually subordinate 

within the Retention and Partial Retention VQOs classes.

Retention: 1,337

Partial Retention: 3,781

Modification: 617

General Forest Lands capable, available and suitable for a host of resource 

conditions. Timber outputs are a high priority. 330

Late Successional Reserve Protect and enhance conditions of late-successional and “old-growth” 

forest ecosystems, which serve as habitat for late-successional species. 49

Riparian Reserve

Management treatments within riparian areas are designed to modify 

fuels and vegetation to enhance and reduce threats to riparian 

resources at risk to insects, diseases, encroachment of invasive plants 

and wildfire.

3,605

Other Relevant Direction

This section describes documented assessments that are pertinent to the Proposed Action and the No 

Action Alternative being analyzed in this final EA.

National Cohesive Wildland Fire Management Strategy

Wildland fire management response in the United States has evolved into an increasingly complex and

multifaceted system. Climate change, fuels management, expanding WUI and associated infrastructure, 

budgets, along with mission differences are some of the challenges facing wildland fire managers today. 

The National Cohesive Wildland Fire Management Strategy (Cohesive Strategy 2014) seeks to ensure 

that the values and concerns of the public and all governments are accurately understood and reflected. 

This demands a more comprehensive understanding of the diverse perspectives that underlie this 

situation—encompassing both the social/human and science dimensions.

Managers and natural resource experts recognize that the creation of a truly national cohesive strategy 

will include not only the seven (7) elements identified in the FLAME Act2

, but must also envision a 

broader, overarching and comprehensive consideration of all lands and fire programs. Therein lies the 

primary challenges facing wildfire managers, land managers, and communities in developing a strategy 

that meets local, regional and national needs.

A national cohesive strategy must recognize the differences and tensions that exist among the partners 

and stakeholders and why those differences exist (e.g., different priorities, planning processes, legal 

mandates, values and resources) and seek to resolve them. It must build stronger relationships based on 

the successes of intergovernmental agreements for mutual response; incorporate cost and data sharing; 

include community wildfire protection planning (i.e., CWPPs or their equivalent), regional fire risk 

assessments, state and forest resource assessments and strategies; and encourage increased use of 

partnerships, grants and other funding opportunities. Each of these tools can be used to build stronger 

collaborative processes and move toward shared understandings that resolve conflicts and enhance 

partnerships among multiple landowners across all lands and jurisdictions.
Chapter 1. Purpose and Need

18 – Somes Bar Integrated Fire Management Project

Indian Self-Determination and Education Assistance Act, and Executive Order 13175

The Indian Self-Determination and Education Assistance Act of 1975 (ISDEAA; 25 USC §450 et seq.) 

guides Indian self-determination and is the cornerstone of the federal relationship with sovereign tribal 

governments. Self-determination contracts, grants, cooperative agreements and self-governance compact 

agreements are authorized by the ISDEAA. These agreements between the federal government and Indian 

tribes and tribal organizations allow the tribes, rather than federal employees, to operate the federal programs.

Self-determination agreements generally cover individual programs or sets of interrelated programs. 

The self-governance agreements cover a wider range of federal programs and the tribes have more 

flexibility to redesign the programs and adjust funding to meet changing needs without amending the 

compact agreement. Major amendments include the Tribal Self-Governance Demonstration Act of 1988 

(PL 100-472) that provides tribes control, decision-making authority and funding for federal programs,

services, functions and activities; and the Tribal Self-Governance Act of 1994 (PL 103-413) that 

establishes a demonstration program and authorization for tribes to continue self-governance.

In a similar vein, Executive Order 13175 – Consultation and Coordination with Indian Tribal 

Governments (EO 13175; 65 Fed. Reg. 67249) provides guidance to establish consultation and

collaboration with tribal officials in the development of federal policies with tribal implications. This is 

intended to strengthen the government-to-government relationship with Indian tribes, and to reduce the 

imposition of unfunded mandates upon tribes.

National Historic Preservation Act of 1966 and Section 106 Regulations

The National Historic Preservation Act of 1966 (NHPA; 16 USC §470 et seq.) is intended to preserve the 

cultural and historical legacy of the United States for the benefit of future generations. The NHPA 

requires that federal agencies consult with any Indian tribe that attaches religious and cultural significance 

to historic properties that may be affected by an undertaking. The law, as amended in 1992, clarifies that 

historic properties of religious and cultural importance to Indian tribe may be eligible for listing in the 

National Register. Section 106 (§106; 36 CFR 800) regulations provide that the federal agency and the 

State Historic Preservation Officer (SHPO) must engage Indian tribes in timely and meaningful 

consultation in order to resolve the adverse effects of the undertaking.

The NHPA is important to the Karuk Tribe because it provides the tribe with an opportunity through 

consultation to protect, or mitigate harm to, cultural resources located on federal public lands. In 

conjunction with the Archaeological Resources Protection Act (ARPA), Native American Graves 

Protection and Repatriation Act (NAGPRA), American Indian Religious Freedom Act (AIRFA), Religious 

Freedom Restoration Act (RFRA), Religious Land Use and Institutionalized Persons Act (RLUIPA), and 

Indian Sacred Sites EO 13007, the NHPA provides a method of procedural protection for the tribe’s 

cultural resources. Through meaningful consultation, the Karuk Tribe has led the way in designing the 

WKRP Somes Bar Project in a way that goes well beyond just simple protection of historic properties, with 

a focus on proposing actions that will benefit cultural sites and revitalize traditional practices.
Chapter 1. Purpose and Need

Final Environmental Assessment – 19

Tribal Forest Protection Act of 2004

The Tribal Forest Protection Act (TFPA; 25 USC §§3101 Note and 3115a) provides opportunities to 

complete collaborative stewardship work on federal lands adjacent to tribal trust lands through agreements 

or contracts. It provides for the protection of trust lands and tribal interests from fires, insects, disease and 

other threats that are in need of restoration. The Karuk Tribe believes that this can be implemented through 

tribal/interagency partnerships that provide for an integrated working relationship in the planning and 

implementation of landscape-scale restoration efforts throughout Karuk Aboriginal Territory.

Karuk Tribe Eco-Cultural Resource Management Plan

In 2010, the Karuk Tribe released a draft Eco-Cultural Resources Management Plan (ECRMP; Karuk 

2010) to create a long-term adaptation strategy for the protection, enhancement and utilization of cultural 

and natural resources. The ECRMP establishes a framework for considering a wide range of human and 

environmental stressors to the Karuk Tribe and their cultural practices, including effects of climate change.

The ECRMP ensures that “Karuk Tribal members and Departmental personnel hold information 

critical to the interworking of the natural environment. Natural Resources staff is working with Federal 

and State agency personnel, academia, and the interested public to ensure that the integrity of natural 

ecosystem processes and traditional values are incorporated into current and future management strategies 

within our area of influence” (ECRMP p. 5).

Katimiin Memorandum of Understanding

The intent of the MOU (Karuk Tribe and USDA Forest Service 2017) is to work together to mutually 

coordinate planning and implementation efforts as partners, in and adjacent to the Katimiin CMA, in a 

manner consistent with Karuk customs, culture and federal land management direction.

Orleans/Somes Bar CWPP and Private Lands Fuels Treatment Project

In response to federal and state legislation, the Orleans/Somes Bar community began preparing a CWPP

to strengthen collaboration between landowners, local, state, tribal and federal wildland fire protection 

agencies. The CWPP identified affected communities at risk from wildfire and strategies to promote 

Firewise (www.firewise.org), fire-adapted communities. The 2015 lightning-caused wildfires and 

subsequent neighborhood evacuations, further moved collaborators to recognize the urgency of taking an 

“all lands” approach to address threats to people, property, cultural and natural resources at-risk of highintensity wildfire. Recent fire events show that continued fire exclusion and barriers to managing fire 

within its historic regime perpetuates risk to the public and fire management personnel.

In 2015, the forest fiscally supported members of the WKRP and the Mid Klamath Watershed Council 

(MKWC) to further complementary fuels reduction on private lands, adjacent to and within the interior of

the surrounding Somes Bar Project area on NFS lands. These partners engaged landowners to plan and 

implement fuels reduction work around their homes. Several landowners voluntarily participated in the 

Private Lands Fuels Treatment Project, which was planned and analyzed under a separate federal 
Chapter 1. Purpose and Need

20 – Somes Bar Integrated Fire Management Project

decision. This private lands project provided much of the social license to move forward with the Somes 

Bar Project, located on public lands.

These on-going outreach efforts incorporate active community participation in project planning 

design and implementation to facilitate the creation of fire-adapted communities and change the public 

perception that all fire is bad.

Decision Framework

The Six Rivers National Forest Supervisor, as the Responsible Official, will use his discretionary 

authority to decide whether to implement the Somes Bar Project as proposed, make modifications, or not 

implement the project at this time.

Collaboration, Public Involvement and Tribal Consultation

A Story that needs to be Told

There is a paradigm shift happening in wildfire management in northern California today. The Somes Bar 

Project seamlessly integrates, in practice, principles underlying the Cohesive Strategy and Karuk 

traditions passed down and preserved over generations for millennia.

The challenge for land managers lies in the fundamental dynamic tension between the need for 

periodic fire to sustain healthy wildlands and cultural lifestyles, and interests in suppressing wildfires to 

minimize safety threats to those living in the WUI, where homes and wildlands intermingle. For the 

residents of Orleans and Somes Bar, surrounded by forested public lands susceptible to high-intensity 

wildfire behavior, the question is not if, but when the next event will occur.

US Forest Service Fire Management

In recent years, the USFS philosophy underlying managing wildfire is no longer simply about Smokey 

Bear’s fire prevention campaign. The Cohesive Strategy reflects this shift in philosophy stating, 

“Addressing wildfire is not simply a fire management, fire operations, or wildland-urban interface 

problem—it is a larger, more complex land management and societal issue”.

Gone is the agency’s approach that wildland fire demands control, containment and suppression 

universally throughout the NFS (2012 Planning Rule (77 Fed. Reg. 21162)).

The agency’s vision for the next century is to “Safely and effectively extinguish fire, when needed; 

use fire where allowable; manage our natural resources; and as a Nation, live with wildland fire.”

Karuk Fire Management

Once, over 100 villages were occupied by the Karuk’s ancestral people as masterful stewards of the land, 

where natural resources were abundant and easily accessible alongside the middle course of the Klamath 

and Salmon rivers in northern California (Figure 1-4).
Chapter 1. Purpose and Need

Final Environmental Assessment – 21

The federal government’s primary trust responsibility to Indian tribes was reaffirmed in 2014 by 

Secretarial Order 3335: Federal Trust Responsibility to Federally Recognized Indian Tribes and 

Individual Indian Beneficiaries. The Karuk believe fire is a spirit transformed following a time of 

darkness and cold, one of many spirits that transformed into everything in the natural world, including 

humans. Fire is considered a healing agent capable of producing change to restore balance when 

respected, understood, and utilized in an appropriate natural/cultural context (Lake et al. 2010). As 

cultural resources are synonymous with natural resources, the management, protection, preservation, and 

accessibility to cultural resources by the Karuk are vital to perpetuate traditional practices.

The Karuk skillfully used fire as caretakers of the land, as an instrument in concert with nature to 

expertly cultivate cultural use plants, invigorate forage for wildlife, emit smoke to suppress infestations 

and promote periods of inversion cooling for anadromous fisheries reliant on cold water.

“We share our existence with plants, animals, fish, insects, and the land and waters. We 

are responsible for their well-being. Our ancestral landscapes overflow with stories and 

expressions from the past, which remind us of who we are and direct us to implement sound 

traditional management practices in a traditional and contemporary context.” (Karuk 

DNR Strategic Plan p.4)

Over 80 percent of the plants utilized by the Karuk people depend on restorative fire for germination, 

as well as the quality and quantity of the plant materials (Anderson 2006). For example, basketry 

materials are required to be specific sizes for various types of baskets (Lake 2007). Acorn abundance and 

quality are also dependent on regular burning (Anderson 2005). Specific fire intervals are needed to 

manage these resources, and these intervals vary between different cultural use plant species (Lewis 1993, 

Anderson 2006, Lake 2007). These prescribed fires may or may not have been started in conjunction with 

wildland fires ignited by lightning (Lake 2013).

Community Wildfire Management – Orleans/Somes Bar Fire Safe Council

Since May 2001, the Orleans/Somes Bar Fire Safe Council has been acting on the direction of the 

National Fire Plan (USDA Forest Service 2000a), which instructs federal land managing agencies to work 

closely with communities to protect people and resources in the WUI. In 2001, the Western Governors’

Association published a 10-year comprehensive strategy for reducing wildland fire risks to communities 

and the environment, which further highlighted the role of communities in shaping fire and fuels 

management decisions on private and adjacent public lands (Cohesive Strategy 2001).
Chapter 1. Purpose and Need

22 – Somes Bar Integrated Fire Management Project

“We believe the reintroduction of fire at the landscape level is necessary to protect, promote,

and preserve the cultural and natural resources and ecological processes within the planning 

area. The mission of the OSB FSC is to help plan, implement and monitor the reinstatement 

of historic fire regimes primarily through strategic fuels reduction in a manner that protects 

life, property, improves forest health, and enhances the resources valued by its stakeholders. 

This mission will be accomplished in collaboration with the Karuk Tribe, USFS, and other 

agencies and community organizations.”

Western Klamath Restoration Partnership

Through outreach and involvement of local, state, tribal and federal entities, the Western Klamath Fire 

Learning Network (WKFLN) was formed to address the need for increased education and communication 

around fire and fire management. Momentum grew to surrounding communities after the first meeting in 

May 2013, and stakeholder groups from the Salmon River attended the July 2013 meeting. Based on their 

participation and interest, the partnership settled on a planning scope that included the entire Salmon 

River watershed. The name of the group changed to the Western Klamath Restoration Partnership 

(WKRP) to reflect this increase in geographic scope.

“Establish and maintain resilient ecosystems, communities, and economies guided by

cultural and contemporary knowledge through a truly collaborative process that 

effectuates the revitalization of continual human relationships with our dynamic 

landscape.” –WKRP Vision

Scoping

The interdisciplinary team (IDT) considered comments received during the scoping period to refine the 

Proposed Action and as the basis to explore alternatives (refer to Chapter 2 of this final EA for discussion 

of alternatives considered in detail and those eliminated from detailed study and Appendix B for response 

to comments).

The Council on Environmental Quality (CEQ) defines scoping as an early and open process to 

determine the scope of issues to be addressed and to identify potential significant issues related to a 

project (40 CFR 1501.7). Beginning in February 2017, the Somes Bar Project was listed on the Klamath 

National Forest’s (KNF) Schedule of Proposed Actions (SOPA), as the Ukonom Ranger District is part of 

the KNF that is administered by the SRNF.

The 30-day scoping period for the Somes Bar Project, held from February 21, 2017 through March 

23, 2017, was initiated with the circulation of a scoping letter and map distributed to 114 individuals and 

groups, disclosing information and seeking public comment on the Somes Bar Project, along with an 

invitation to attend a public meeting on March 1, 2017. The notification was distributed to the Karuk 
Chapter 1. Purpose and Need

Final Environmental Assessment – 23

Tribe, federal and state agencies, local government officials, businesses, interest groups, adjacent 

landowners, and interested individuals.

Sixteen (16) commenters submitted 56 comments during the scoping period (Appendix B of the final 

EA). The IDT considered public comments received during the scoping period to refine the Somes Bar 

Project and as the basis to explore another alternative (Alternative 3; final EA pp. 93-95).

Relevant Issues

Relevant issues represent minor and/or non-variable consequences, which could be avoided, partially or 

fully mitigated by design criteria and operating procedures disclosed in Chapter 2 (Alternative 2) and 

throughout Chapter 3 of this final EA.

Threats to Native and Traditional Ecological Knowledge Plants

Prescribed burning in the spring and ground disturbance from log skidding, sorting and loading may 

damage native plant species, while increasing solar radiation favoring the spread of invasive weeds.

Human Disturbance

Operational noise, presence of field crews, and smoke generated from prescribed burning may 

periodically disturb neighbors.

Habitat Disturbance

The removal of select crown fuels (co-dominant conifer trees), along with ladder fuels and surface fuels 

reduction treatments, including prescribed burning, may act to simplify forest stand structure in the short

term, impacting habitat quality and TEK focal species.

Soil Erosion

Tree harvest and associated logging operations (e.g., skidding, temporary road and landing construction), 

coupled with phased initial and maintenance prescribed burning may increase sedimentation downstream.

Non-Significant Issues

Non-significant issues were defined by the IDT as those 1) outside the scope of the Proposed Action; 2) 

already decided by law, regulation, forest plan, or other higher-level decision; 3) irrelevant to the decision 

to be made; 4) conjectural and not supported by scientific or factual evidence; or 5) the comment could 

not be phrased as a cause-effect relationship. The CEQ NEPA regulations explain this delineation in 

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

been covered by prior environmental review... (§1506.3).”

Comments on the Draft EA

On February 22, 2018, the Forest Service initiated the 30-day comment period on the draft EA with the 

publication of the opportunity to comment in the Eureka Times-Standard. Additional notification was 

posted on the KNF’s website and on the SRNF’s social media sites (Facebook and Twitter). The Forest 

Service received comments from 12 individuals or agencies during the comment period, including 
Chapter 1. Purpose and Need

24 – Somes Bar Integrated Fire Management Project

comments from; Klamath Forest Alliance, Environmental Protection Information Center, North Coast 

Regional Water Quality Control Board, Conservation Congress, Klamath Siskiyou Wildlands Center, Mid 

Klamath Watershed Council and California Wilderness Coalition.

A compilation of public comments received during the draft EA comment period and the response to 

these comments is located in Appendix B of this final EA.
Chapter 2. The Alternatives

Final Environmental Assessment – 25

Chapter 2. The Alternatives

Introduction

The National Environmental Policy Act (NEPA) is our country’s basic charter for environmental 

responsibility. The NEPA applies when a federal agency has discretion to choose amongst one or more 

alternative means of accomplishing a particular goal (CEQ 40 CFR 1508.23). In compliance with NEPA 

implementing regulations, the following chapter discloses:

Early community planning, underlying key collaborative principles and rationale influencing 

the scope, temporal and spatial extent of the project area, and proposed treatment methods.

Description of the Alternatives Considered in Detail (Alternative 1 (No Action) and 

Alternative 2 (Proposed Action)), including the methodology applied to develop Alternative 2 

and detailed information on treatment locations, design and disclosure of associated 

mitigation measures.

Comparison of Alternatives Considered in Detail, at the end of this chapter, includes a tabular 

comparative display of the alternatives’ potential effects, further described in narrative later in 

Chapter 3. Environmental Consequences.

Early Community Planning

Out of necessity, communities across the 

country have jump-started local planning 

efforts to protect themselves from intense 

wildfires. History has shown that real 

change occurs when grassroots 

movements connect to larger national 

shifts in policy and opinion. In 2013, the 

Western Klamath Restoration Partnership 

(WKRP) convened workshops and utilized 

an Open Standards process (Figure 2-1) 

for conservation planning for the entire 

Middle Klamath sub-basin. For California, 

scientist Malcolm North recently predicted 

the rise of mega-fires across the state, as 

fuel loading and climate change combine 

to overwhelm the most technologically 

advanced firefighting force in history.

Figure 2-1. WKRP utilized a collaborative process to develop 

overlay assessments to better prioritize manual, mechanical 

and prescribed burning treatment methods and locations.
Chapter 2. The Alternatives

26 – Somes Bar Integrated Fire Management Project

Given current climate predictions, the Klamath region is predicted to have four (4) times more fires 

by 2085. Fire historian Stephen Pyne identifies the lack of prescribed fire as another major factor in the 

current fire situation. “If contemporary fire agencies had the chance to replay the light burning 

controversy, they would almost certainly choose fire lighting over firefighting as a basis for wildland 

stewardship.” This understanding is shared by a majority of residents in the planning area, and the need to 

increase the use of prescribed fire as a tool to protect communities was expressed throughout the WKRP

workshops. To expand the use of controlled burning to the scale needed will require incorporating 

science, policy, public understanding and sentiment, economics, and mechanisms for risk management 

that are just now being developed. There is urgency to create this new vision, for the specter of climate 

change has made historic fire regimes a moving target, given the amount of current departure from the 

fire resilient forests of a century ago.

Shared values emerged through identification of six (6) Conservation Targets or Values. Targets and 

values are interchangeable terms in the Open Standards process. Though they are called targets in some 

places throughout the process and values in others, the intent is to not only consider our actions, but also

aim to achieve improvement of target viability. The Conservation Values/Targets are:

Fire-adapted communities

Restored fire regimes

Healthy river systems

Resilient biodiverse forests, plants and animals

Sustainable local economies, and

Cultural and community vitality.

Identifying Critical Threats to Conservation Values

In identifying critical threats, the WKRP started with a threat mapping exercise. This process was used as 

an aid to consider real world threats to the viability to the values and targets. Some key threats emerged 

from this exercise, including:

Lack of stable jobs

Erosion of community and cultural values, including Karuk traditional practices

Lack of beneficial fire

Altered forest structure and composition (overly dense forests)9

High fuel loading

Lack of defensible space

Habitat degradation (terrestrial and aquatic), and

Impaired fishery.

 9 The group discussed that we may need to move the fire-adapted communities target to very good to enable us to move restored fire 

regimes to good. The status of fire regimes as currently being in fair condition is in question as the argument could be made that it is 

actually poor due to nearly 50 percent of the planning area not seeing fire in the last 100 years.
Chapter 2. The Alternatives

Final Environmental Assessment – 27

Defining Goals and Objectives

The overarching goal of the WKRP is to improve the viability of all conservation targets. The group reflected 

on the status of the target, discussed real world issues affecting the status and the ability to change them, and 

came up with a goal to improve target viability. Though the metric of measurement is subjective, it provides a 

framework for partners to periodically reevaluate targets in light of lessons learned. These targets are long 

term and will likely still be applicable generations from now. Table 2-1 below provides a guide of how 

perceived current target viability moves to potential future target viability through efforts of the WKRP and 

the broader community.

Table 2-1. Perceived current and future target viability.

Target/Value Current Status Potential Future Status

Sustainable Local Economy Poor Fair

Cultural and Community Vitality Poor / Fair Good

Fire-Adapted Communities Fair Good

Restored Fire Regimes Fair Good

Resilient, Biodiverse Forests, Plants and Animals Fair Good

Healthy River Systems Fair Fair

Three big points that emerged throughout the workshops were:

1. The need to develop multi-organizational capacities;

2. The need for on-the-ground demonstration projects to prove we can go from agreement in 

principle to agreement in practice; and

3. The need to plan big, but start small, learn from the outcomes of our work, and have the 

ability to refine our prescriptions/descriptions as we progress.

Another recurring theme was the intent to implement all three (3) primary components of the 

National Cohesive Wildland Fire Management Strategy (Cohesive Strategy 2014):

1. Restoring and Maintaining Resilient Landscapes

2. Creating Fire-Adapted Communities, and

3. Responding to Wildfires.

Refining Strategies

In order to change the viability of targets/values, strategies were discussed and decided upon and logical 

points of insertion in our results chains were identified. These strategies were meant to reverse threats to our 

values into positive results, which would affect other threats to ultimately increase the likelihood of 

achieving our targets. This forced the partnership to identify the root causes of the problems and what could 

be done to strategically address them. The nine (9) strategies that were ultimately settled on are as follows:

1. Develop and implement landscape level strategic fuels reduction treatments;

2. Increase use of fire to restore and maintain pre-European conditions in a contemporary context;
Chapter 2. The Alternatives

28 – Somes Bar Integrated Fire Management Project

3. Increase local restoration capacity;

4. Create sustainable diverse revenue streams to address all threats and values;

5. Accelerate development of fire-adapted communities;

6. Integrate food security into forest management actions;

7. Advocate for and support implementing existing fisheries restoration plans;

8. Develop integrated, inter-generational education programs and activities that complement our 

identified strategies; and

9. Develop inclusive partnerships for implementing zones of agreement.

Overlay Assessment Description

The following overlay assessment description represents the basic zone of agreement for all treatment 

types. It served as a guide to planning and prioritizing projects on the landscape scale for multiple social, 

ecological, and economic factors:

1. Create defensible space around structures and critical infrastructure through manual and 

prescribed burning fuels reduction treatments. Mechanical treatments were considered for the 

500-foot buffer. The structures layer was updated in 2014 for the entire planning area by the 

Karuk Department of Emergency Services:

a. 100-foot buffer: 1 point

b. No buffer: 2 points

2. Safe and reliable access and egress routes will be maintained by manual, mechanical and 

prescribed burning treatments (if implemented, will also provide cost effective linear features 

to stop wildfires and start prescribed fires):

a. Critical access/egress routes (300-foot buffer): 2 points

b. Complete road system layer, public and private (300-foot buffer): 1 point

3. Public/private boundary layers (Green Line – buffer applied from edge of private property 

onto public lands): Revisiting residential properties to create fuelbreaks (Figure 2-2) along the 

public-private boundary allows both federal and private landowners to have more certainty 

that fires, especially prescribed fires, do not inadvertently spread across property lines:

a. 200-foot buffer: 2 points

b. 1⁄4-mile buffer: 1 point
Chapter 2. The Alternatives

Final Environmental Assessment – 29

4. Fuelbreaks along existing firelines, ridges, and trails help tie in roads and streams to establish 

fire sheds—areas where fires (both controlled and wildfires) can be contained or stopped. 

Control features outside the wildland-urban interface (WUI) should also be addressed to slow 

the spread of larger “mega-fires” through the backcountry. These actions could be as simple 

as conducting controlled burns in the fall along significant ridges to break up fuels at the 

landscape level.

a. Existing firelines (300-foot buffer): 2 points

b. Current and historic trails: 1 point

c. Upper third slopes: 1 point

5. Maintain existing fuels treatments on public and private lands to increase fuelbreak 

effectiveness.

a. 0 to 3 years since treatment: 1 points

b. 3 to 10 years since treatment: 2 points

c. 11-plus years since treatment: 1 point

6. Target fuel treatments for cultural and ecological resource benefits to protect tribal practices 

dependent on the use of fire as a land management tool, and to preserve plant and animal 

species that depend on habitats maintained by frequent fires:

a. Wildlife Layers

b. Elk winter range restoration potential layer

i. Low (0.8): 1 point

Figure 2-2. A shaded fuelbreak created in a tanoak forest benefits the landowner 

who lives just upslope, elk that frequent the stand to feed and bed down, and tribal 

members who gather tanoak acorns for subsistence and ceremonial use.
Chapter 2. The Alternatives

30 – Somes Bar Integrated Fire Management Project

ii. High (0.9 or 1.0): 2 points

iii. Spotted owl nest sites buffer (1/2-mile diameter): 1 point

c. Vegetation Layers (Landfire Biophysical Settings (BpS))

i. Klamath Mixed Evergreen BpS (tanoak distribution): 1 point

ii. Klamath Siskiyou Lower Montane Serpentine Woodland: 1 point

iii. Black Oak BpS Layer: 1 point

iv. White Oak BpS Layer: 1 point

v. Baker Cypress Stands: 2 points

vi. Meadow Restoration: 1 point

vii. Willow/Riparian Stands: 1 point

viii. Beargrass Areas: 1 point

ix. Hazel Areas: 1 point

x. Iris Areas: 1 point

xi. Huckleberry Stands: 1 point

d. Native American Cultural Use Areas: 1 point

Separate overlay assessments were done to better prioritize manual, mechanical and prescribed burn 

treatments, based on specific timing, location, access, and other specific needs/factors relating to each 

treatment type. The following changes and assumptions were made to the general overlay assessment and 

point scheme described above:

Manual Fuels Treatment

Only prioritized fuels treatments from 2002 and earlier, assuming they would need further 

thinning to allow for positive re-introduction of prescribed fire: 1 point.

Did not consider insolation or south and southwest facing slopes (included too many 

inaccessible areas and brought focus away from communities).

Did not include managed stands or mid-mature dense stands (these areas need mechanical 

thinning).

Excluded from prioritization all areas with slopes over 80 percent.

Mechanical Fuels Treatment

No points for 100-foot structure buffer. Kept 2 points for 500-foot buffer. Assumed no 

mechanical treatments that close to homes.

Only used quarter-mile community (neighborhoods) buffer, but gave it two (2) points to 

reduce focus directly on the property lines.

Did not include previous manual fuels treatment layers.
Chapter 2. The Alternatives

Final Environmental Assessment – 31

Reduced the weight on the firelines buffer from two (2) to one (1) point. Most mapped 

firelines are not accessible for mechanical harvest.

Did not include historic trails.

Did not include insolation.

Added a point to mid-mature dense stands layer: 2 points.

Added layer for plantations over 40 years old: 2 points.

Did not include crown fire potential.

Excluded serpentine (buck brush) veg type from Landfire BpS veg layer. These areas are 

proposed mid-winter prescribed burns.

Excluded from prioritization: inner gorges, slopes over 40 percent except within 1,500 feet of 

existing roads (allowing for potential skyline treatments), northern spotted owl (NSO) 

activity center (AC) buffers, and existing landslides.

Prescribed Burning Treatments

Critical access egress routes: 1 point (rather than 2).

Recent wildfires (within past 10 years): 2 points (rather than 1).

A new layer showing plantations over 20 years old was added: 1 point.

A new layer showing areas with predicted flame lengths over 8 feet was added: 1 point.

Crown fire potential layer was removed.

Manual fuels treatments (public and private) are one of the strongest areas of agreement in principle 

identified. Prescribed burning was also strongly supported. Additionally, while these treatments will save 

firefighting expenditures in the future, they do not generate funding by themselves and will require a 

significant investment to implement at the scale described.

Mechanical treatments were strongly supported by some participants, but strongly discouraged by 

others unless there was a clear path for collaboration as defined through the Open Standards process to 

allow for meaningful stakeholder involvement. Mechanical treatments have affected the viability of 

traditional food and fiber resources in some areas; however, manual treatments may not be able to restore 

the potential natural vegetation on a site that has undergone a type-level conversion due to lack of fire. In 

some cases, girdling of trees followed by prescribed fire was proposed by participants to restore potential 

natural vegetation in areas where mechanical treatments are not an option. The overlay assessment 

informed the identification of high-priority areas based on the shared values and zones of agreement, as 

depicted in Figure 2-3.
Chapter 2. The Alternatives

32 – Somes Bar Integrated Fire Management Project

Fire Hazard Assessment

Fire hazard assessment is more complicated than can be described by Fire Regime Condition Class (FRCC) 

alone. Fire starts, mid-mature dense stands, and slope-aspect insolation maps are also included to determine 

fire hazard assessment within the planning area. The FRCC helps planners determine how much landscape 

vegetation has changed from the way it was historically to the way it is today. Figure 2-4 represents where the 

contemporary fire return intervals (FRI) have been altered when compared to historic fire return intervals. 

Lands with high fire return departure are shown as red; moderate, yellow; and green, low departure. For fuel 

hazard, low, medium and high rankings were valued as one (1), two (2), or three (3) points respectively. 

Assessing FRCC was used to help guide management objectives and set priorities for treatments.

Figure 2-3. The WKRP plan for restoring fire-adapted landscapes identified 

strategic features (roads, mechanical and manual treatments around private 

property and burn treatments between roads and mountain ridgetops) to 

protect neighborhoods.
Chapter 2. The Alternatives

Final Environmental Assessment – 33

The overlay below (Figure 2-5) displays fire starts from 1922 to 2005, both as points and as a density 

gradient, to show areas within the planning area that historically burned. This overlay, coupled with other 

fire hazard assessments of the location of mid-mature dense stands (concentrated fuels), slope-aspect 

insolation, areas of community importance, emergency access routes, risk of wildland fire, and 

firefighting capability linked to each community asset were considered when determining recommended 

rankings for treatment priority.

Concerning firefighting capability, ranking and value have an inverse relationship. For example, the 

Karuk Medical Clinic and Department of Natural Resources have a fuel hazard ranking of low (1 point), a 

risk of wildland fire occurrence of medium (2 points), and a firefighting capability ranking of high (1 point). 

This point scale has possible total values ranging from three (3) to nine (9), which correlate to overall risk.

Figure 2-4. Fire regime condition class based on departure from fire return interval.
Chapter 2. The Alternatives

34 – Somes Bar Integrated Fire Management Project

Risk of wildland fire occurrence was determined by using a combination of the asset’s position on the 

slope (low, mid, upper) and how frequently the area experienced fire in the past. The risk of wildland fire 

occurrence considered recorded historic fires in near the project area between 1975 and 2015, as 

displayed in Table 2-2. During the early community planning effort, overall risk rankings were defined as 

low (3 to 4 points), medium (5 to 7 points), and high (8 to 9 points).

Table 2-2. Recent wildfire starts compared to total acreage burned in the project area vicinity.

Fire Years # of Fires Total Acreage Burned

2005-2015 693 355,459

1995-2005 800 91,151

1985-1995 826 18,450

1975-1985 691 2,178

Since 1978, recorded wildfires have burned more than 430,000 acres in this same geographic area 

(Table 2-3 and Figure 2-6). In 2017, the Ukonom and Haypress fires burned approximately 25,000 acres 

immediately adjacent to the project areas. The only wildland fire recorded within the project area was the 

Marble Fire, in August 2017, which burned 318 acres in the Patterson project area.

Figure 2-5. Fire starts by cause and ignition density.
Chapter 2. The Alternatives

Final Environmental Assessment – 35

Table 2-3. Recorded wildfires, greater than 200 acres in the project area vicinity.

Year Fire Name Acres

1987 King Titus 68,071

1987 Yellow 51,060

1994 Jack 28,206

1998 UNK 8,797

2006 Hancock 21,866

2006 Somes 15,506

2007 King Creek 10,477

2008 Haypress 13,665

2008 Jake 38,417

2008 Merrill 8,339

2008 Mill 65,882

2008 Panther 44,497

2008 Three 4,923

2013 Butler 22,445

2017 Haypress 21,086

2017 Ukonom 4,237

Figure 2-6 illustrates the absence of fire processes over the last 95 years, the influence of seasonal 

easterly prevailing winds driving rapid moving flame fronts, and large areas affected. The Ukonom Ranger 

District (RD) tends to experience a noticeably higher rate of lightning occurrence compared to other areas 

of the forest over the same period, particularly in the higher elevation terrain in the Marble Mountain 

Wilderness east of the project area. This frequency for lightning is almost twice as much as the rest of the 

forest combined. Fire suppression within the WUI has increased forest density and hazardous surface and 

aerial fuels, increasing the risk for large-scale, high-intensity wildfires, including active crown fires.

Alternatives Considered in Detail

Two (2) alternatives were considered in detail—the No Action Alternative (Alternative 1) as a 

comparative baseline of what could happen if the Proposed Action (Alternative 2) is not implemented.

Alternative 1 – No Action

The No Action Alternative provides a baseline for comparing the Proposed Action. Under this alternative, 

proposed treatments would not occur. Recent fire events show that continued fire exclusion and barriers 

to managing fire within its historic regime perpetuates risk to the public and fire management personnel.

The current conditions of many seasonally dry forests in the western United States, especially those 

that once experienced low- to moderate-intensity fire regimes, leave them uncharacteristically susceptible 

to high-severity wildfire today. Both prescribed fire and its manual and mechanical surrogates are 

generally successful in meeting short-term fuel-reduction objectives, such that treated stands are more 

resilient to high-intensity wildfire” (Stephens et al. 2012).
Chapter 2. The Alternatives

36 – Somes Bar Integrated Fire Management Project

As reflected by the 2014 letter of intent from USDA Chief Tidwell, “We do not accept unnecessary 

risk or transfer it to our partners or future generations.” The Forest Service recognizes every fire interval 

removed from a fire-dependent ecosystem compounds risk and defers it to a more hazardous future.

Enabling fire to be managed at an acceptable level of risk now will mitigate unacceptable consequences 

and reduce risk to future generations. In the past two (2) decades, a rapid escalation of extreme wildfire 

behavior, accompanied by significant increases in risk to responders and citizens, home and property 

losses, costs, and threats to communities and landscapes have been observed (Cohesive Strategy 2014).

Figure 2-6. Fire history from 1900 to 2017 within and surrounding the focal areas.
Chapter 2. The Alternatives

Final Environmental Assessment – 37

Fire Suppression

Within the project area, the appropriate response for a wildland fire on National Forest System (NFS) 

lands would continue to be direct and indirect suppression tactics as described in the Klamath (KNF) and 

Six Rivers national forests’ (SRNF) land and resource management plans (LRMPs or forest plans). The 

US Forest Service (USFS or Forest Service) policy for fire suppression is to conduct fire suppression in a 

timely, effective, and efficient manner with a high regard for public and firefighter safety, followed by

protection of natural resources. It is the objective of the Forest Service to respond to each wildland fire 

ignition in a timely manner with appropriate forces. Firefighting resources would continue to focus 

strategies and tactics to aggressively suppress wildfires near at-risk, isolated parcels of private property in 

the WUI as the highest priority, necessary due to the current and continued accumulation of flammable 

forest vegetation likely to contribute to high-intensity fire behavior that could threaten communities, 

infrastructure and private property amenities.

The probability of a fire burning over a landscape is based on factors such as the chance of ignition, 

potential rate of spread, historical and predicted weather conditions, topography, and length of the fire 

season (Miller and Urban 2000). Consequences regarding these factors are analyzed and based on fire 

computer modeling, and are discussed for the No Action Alternative, as well as the Proposed Action, in 

Chapter 3 of this final EA.

Fire Prevention

Wildland fire prevention activities would continue to occur under the No Action Alternative. Wildland 

fire prevention is the informing, educating, and regulating of human behavior or activities that influence 

the various types of potential ignition sources within flammable vegetation. Analysis of human-caused 

fires indicates that these fires are most likely to occur near inhabited areas or heavily used areas, such as 

campgrounds or along forest roads or trails (USDA Forest Service 1995). Efforts to educate the public on 

safe fire use would continue through personal contacts, interpretive programs, interagency fire prevention 

cooperatives, the use of posters and signs, radio and press releases.

Continuation of public neighborhood fire prevention meetings, discussions of defensible space, fire 

apparatus access, education about home construction materials (flammability) and design, etc., would 

continue to take place periodically. In 2012, the Orleans Somes Bar Fire Safe Council (FSC), with 

assistance from the Orleans Volunteer Fire Department (VFD), USFS, Karuk Tribe, California 

Department of Forestry and Fire Protection (CAL FIRE), Salmon River FSC, Humboldt County FSC, 

FSC of Siskiyou County, Siskiyou County, private landowners, and the community at large completed 

their community wildfire protection plan (CWPP) for northwestern California, in Humboldt and Siskiyou 

counties, and a small portion of Del Norte County. The purpose of the CWPP is to provide the 

communities, agencies and the Karuk Tribe with information that can be used to help protect Orleans and 

Somes Bar from severe wildland fires, while helping to guide the planning and implementation of 

community fire safety projects.
Chapter 2. The Alternatives

38 – Somes Bar Integrated Fire Management Project

Prescribed Fire Training Exchange

Approximately six (6) full-time-equivalent (FTE) jobs are created through the Klamath Prescribed Fire 

Training Exchange (TREX). These exchanges were designed by the US Fire Learning Network (FLN) to 

provide opportunities to implement prescribed fires (or controlled burns) and give trainees high-quality 

training assignments, as well as exposure to new people, places and techniques. Each year, there are 

approximately 50 TREX training opportunities with about 100 participants each.

Prescribed burning reduces fuel loading and wildfire risks to protect communities, homes and lives. 

With proper planning and under the right conditions, prescribed burns are an effective tool. Burning also 

increases the food and fiber resources for subsistence gatherers, contributing to the local economy. This 

effort requires close coordination with multiple organizations and residents to be successful, including the 

Forest Service, Karuk Tribe, Mid Klamath Watershed Council (MKWC), Cultural Fire Management 

Council, FLN, The Nature Conservancy, Salmon River Restoration Council, Northern California 

Prescribed Fire Council, California FSC, CAL FIRE, Firestorm, Orleans VFD, and other partners. The 

TREX organizers work with regulatory agencies and partners to coordinate these burns, which will be 

implemented following strict protocols to ensure safe fuels reduction, capacity building for fire managers, 

and future opportunities for managing wildfires more frequently for resource objectives without increased 

threats to communities.

Alternative 2 – Proposed Action

Function: Bringing Back Fire

Since it has taken nearly 100 years of growth to produce present-day, “non-natural” vegetative structural

conditions, it is predicted that it will likely take several decades of resource management to return the 

cultural environment and balance of ecological cycles.

As designed for this Proposed Action in the short-term, the desired future condition would be to 

sustain a flame length less 4 feet under 90th-percentile weather conditions10. The selection of a desired 

less than 4-foot-flame length is to facilitate restoration of historic fire regimes. Experts also recognize a 

100-percent attainment of the desired future condition within the project area is not probable.

Environmental and legal constraints, such as weather, on-the-ground fuelbed conditions, and application 

of required mitigations to ensure compliance with air quality, down wood, roadless and riparian standards, 

etc., would restrict treatment intensity and duration in some areas.

Alternative 2 represents an effective approach to revitalize the ecosystem and prepare communities to 

live cooperatively with wildfire within the project area and would provide for public and firefighter safety.

 10 “90th percentile” Weather Conditions: The combination of temperature, humidity, wind, and fuel moisture that is warmer, drier, and 

windier than 90 percent of all summer days. Under 90th percentile weather conditions, 10 percent of the summer days are assumed 

hotter, drier and windier. For example, the fire season is described as the 153-day period between May 1 and September 30. Ten 

percent (or 15 days) would be hotter, drier, and windier than the conditions described as 90th percentile.
Chapter 2. The Alternatives

Final Environmental Assessment – 39

The long-term objective is to set the stage for the near future so wildfire can become a 

restorative management tool to promote diversity of native plants, stimulate sprouting of 

deciduous oaks and shrubs and so trees can survive long enough to develop thick, scorch 

and insect-resistant bark and healthy crowns.

The following overarching tactics would be implemented:

Ridge-Top Containment (strategic fuelbreak)

Stop or contain planned prescribed fire during burning operations. During burning, these 

defensible control lines act to hold or confine fire within the burn plan area.

Provide defensible control lines from which firefighters can safely intervene when responding 

to unplanned fire ignitions outside the project area.

Interface Boundary Confinement (defensible space buffers)

Stop or confine planned prescribed burning during operations by providing a defensible space 

between private property and prescribed burning on NFS lands. During burning, these 

defensible control lines act to hold or confine fire within the burn plan area.

Increase the probability of unplanned fire ignited on private land from entering NFS lands

and unplanned fire ignited on NFS lands from entering onto private land.

Interior Confinement Lines (control line, fireline or handlines)

Stop or confine planned prescribed fire during multiple phased burning operations.

Control

Pre-treatment of hazardous fuels across the landscape would establish a mosaic pattern, setting 

the stage for low and moderate intensity prescribed burning and wildfire that can be safely 

contained and controlled without substantial augmentation of suppression reinforcements.

Prescribed burning treatments would occur once associated perimeter containment and 

interior control line fuelbreaks are in place.

Integration of Karuk traditional management philosophy and practices (TEK)

Although Alternative 2 is designed to benefit diverse community interests and reinstate fire processes to 

restore natural and cultural resources holistically, WKRP recognized the aboriginal values were forefront. 

The Karuk philosophy of renewal reaffirms the responsibility of humans as stewards, as well as a critical 

ecosystem component. The tribe believes in renewal of the human-environment relationship that is 

compatible with ecological processes, promotes a sustainable economy, and increases ecosystem resilience.

This paradigm shift was the driving consideration influencing project design, which did not involve 

single-species management; rather, whole landscape improvement—for the collective benefit of people, 

animals and plants. Since involving all aspects of TEK (traditional ecological knowledge) in this initial 
Chapter 2. The Alternatives

40 – Somes Bar Integrated Fire Management Project

project would be too complex, a few focal species were selected to begin to formulate a story of human 

re-emergence in accepting the people’s collective responsibility in a contemporary future.

Focal Species

The focal species selected represent different components of the landscape and are those that are either:

Directly regulated by laws, such as the Endangered Species Act (ESA),

Associated with water-quality regulations, or

Founded in TEK as being foundational in human-fire relationships.

The focal species provided an umbrella framework for the landscape-level analysis. Some of these 

components are regalia species in tribal ceremonies. Regalia species are crucial to tribal people through 

ancestral tradition. If those components are put together, management for the focal species promises to 

provide a realistic and holistic approach to whole landscape management. The following five (5) focal 

species were selected according to these guidelines for the Somes Bar Integrated Fire Management Project

(Somes Bar Project) and the planning efforts of the greater WKRP collaborative:

1. Northern spotted owl (NSO): This regulated species tends to use old growth forest habitats. 

While the interpretation could be made that the NSO is a messenger of a sick forest habitat 

dynamic, that function is traditionally associated with another species—the Pacific fisher—which 

is not only legally regulated, but is a regalia species. In Karuk culture, the Pacific fisher 

represents NSO habitats in the environment. Though owls are known as messengers of sickness 

and death, it is the great horned and screech owls that are told to carry these specific messages. 

These two (2) species are known to have specific names in the Karuk language. The NSO is not 

known to have a specific name, but has been found in practice to be one of the first species to 

decline when the habitat dynamics deteriorate owing to fire exclusion and other contemporary 

management practices.

2. Pacific fisher: This species, which as a regalia species directly ties to TEK principles, is a 

potential surrogate for NSO using the forest and oak woodlands. The fisher, in fact, covers a 

wider array of habitat dynamics, which in turn is more representative of fire process and function. 

The fisher is not just associated with conifer forests, but also with upland oak stands, which are 

traditionally more open and contain bunch grasses. The fisher plays a very central role in 

ceremony and culture—the Pacific fisher is carried through the Karuk World Renewal ceremonies 

holding the arrows used to pierce the earth and wake up the world.

3. Roosevelt elk: This species tends to use open areas, higher elevation grasslands, or passageways 

provided by native serpentine soils, representing a bridge between the human-fire relationship 

(men carry fire in elk horns) and howling dogs (wolf returning to adjacent landscapes). In looking 

to an imminent return of the wolf, elk habitat dynamics are critical in protecting their 

reproductive rights from the wolf, as well as enhancing our ability to see things through the eyes 

of the wolf in teaching the importance of family, togetherness, or collaboration.
Chapter 2. The Alternatives

Final Environmental Assessment – 41

To build upon the open end of the fisher-habitat dynamic, Roosevelt elk was also identified 

as a focal species. Though neither the fisher nor the elk were mentioned explicitly in the 

summarized story, they have a unique place in ceremonial practice, use and management that 

helps to start building a story leading us into a contemporary future, while maintaining the 

traditional foundations of Karuk living culture. With elk specifically, there is the traditional male 

responsibility of taking care of the animals. In fulfilling this male role in fire management, fire is 

carried in an elk horn. In integrating the habitat needs of large ungulates and other species 

needing more open space, we start to enhance the entire spectrum of habitat needs. With fisher 

covering the dense habitats transitioning to the more open habitats, and the elk transitioning from 

the wide-open habitats back to the denser habitats, there is plenty of overlap in habitat use. This 

can help to frame site-specific variation when it comes to formulating a proposed action or need 

for adaptation, moving towards recovering the habitat dynamics and ecosystem processes 

required by the spotted owl.

4. Pacific giant salamander: This species tends to be concentrated in the low gradient riparian 

areas. Riparian areas require special focus in the current regulatory environment. This is not 

unfounded in traditional Karuk practice. The Pacific giant salamander is the traditional focal 

species treated with the utmost respect—it has its own prayer in Karuk World Renewal 

ceremonies and is considered the sacred water purifier. Though water-quality parameters can be 

measured as an indicator of water quality, Karuk culture requires that no harm come upon this 

species, and in turn, riparian habitats receive special focus, and water from the source to the 

ocean and back again is protected as the primary directive.

5. Willow: This species tends to be concentrated around the riverine areas. The story of Coyote 

stealing fire illustrates the crucial place of Willow within human culture. One can correlate the 

human use and responsibility to the plants and animals to a cyclic interaction among all living 

things. This interaction operates among TEK, practice, and belief pathways. The willow grows 

around and at the edge of the river, often close to the sites of traditional villages. Willow is used 

to make fire, and is a crucial basket-weaving resource. It is particularly important in terms of 

female responsibility. Willow also harbors the river mussel, whose shell is used by women to 

carry fire when upholding the traditional female fire use responsibility to the plants.

Traditional Cultural Properties

Traditional cultural properties (TCPs) and their consideration within historic preservation law has allowed 

for a deeper understanding of what needs to be identified and protected through active cultural 

management. Traditional cultural properties are places that tie the practices of a living community with 

ancestral use; vegetation features, landscape features, the setting, and the feeling of a place may all be 

concrete contributory elements in the designation of a TCP.

Cultural vegetation characteristics (CVC) make up a special category of tribal archaeological data. 

They are main constituents of resource areas that provide evidence of human management. They are 

defined as vegetation assemblages indicative of historic human use, management, or occupation. They are 
Chapter 2. The Alternatives

42 – Somes Bar Integrated Fire Management Project

indicators that provide historically relevant information, which may justify their designation as a site, 

property, or as a feature in determining the eligibility of a larger district.

Examples of vegetation that show evidence of management include huckleberry, sugar pine, California 

black oak and tanoak. Tanoak groves require fire and removal of younger trees to ensure the heath, vitality 

and productivity of the main trees. A high-quality grove will have mature, well-spaced trees. Huckleberries 

need to be managed in order to produce useful berries for people and animals. Both of these become 

unproductive if left to grow unchecked. Sugar pines are often found in strategic places on ridges, and would 

have been managed to serve as ignition sources. Accordingly, they are commonly found in conjunction with 

other plants that thrive in areas well managed by fire, such as tanoak, hazel, manzanita, or beargrass.

Treatment Objectives and Considerations

• Focus mechanical and/or manual thinning around hardwood trees that are deficit on the landscape and 

legacy trees of cultural value to retain, enhance, and increase CVCs and resources within existing 

natural stands that have been subject to encroachment by Douglas-fir. These include black oak, white 

oak, madrone, chinquapin, and tanoak species, sugar pine, ponderosa pine, and other species with 

unique structural characteristics. These treatments would also be used to:

Reduce probability of future loss of these trees due to increased encroachment by Douglas-fir 

and due to high severity fire;

Revitalize the Karuk culture by allowing for the reintroduction of fire, while maintaining 

maximum amount of existing cultural vegetation characteristics and resources that are still 

present at these sites after more than a century of fire suppression and lack of cultural 

management; and

Increase overall diversity and heterogeneity of these stands to increase habitat value and use 

by wildlife and other species.

Work towards restoration of the former progeny site within Katimiin Cultural Management 

Area (A-spur treatments in Donahue) by using mechanical, mastication and/or manual 

treatments to work towards restoring more natural conditions.

• Mechanical and/or manual treatment up to 300 feet from roadside to provide safe access/egress and 

ease of prescribed fire implementation.

• Mechanical/manual treatment within 500 feet of private property to protect property and ensure 

limited mortality from prescribed fire adjacent to private land.

• Mastication and/or manual treatment within plantations that cannot be treated mechanically due to 

lack of maturity and/or other concerns to provide safe access/egress and ease of prescribed fire 

implementation.

• Mechanical thinning within plantations, adjacent to access/egress roads and large enough to compensate 

for the cost of treatment, to increase and enhance foraging habitat and provide access/egress.
Chapter 2. The Alternatives

Final Environmental Assessment – 43

• Minimize the need for new infrastructure (temporary roads and landings) when planning mechanical 

treatments.

• Take incremental steps to prepare the landscape for future treatments aimed to revitalize ceremonial 

practice of cultural burning Offield Mountain. This includes treating plantations on the north face of 

Offield Mountain to allow for prescribed fire treatments in this area.

Description of Treatment Methods

A guiding premise for sustaining ecosystems and protecting biodiversity put forth by Kaufmann and 

others (1994) is to manage ecosystems to conserve the structure, composition, and function of all 

elements, including their frequency, distribution, natural loss and revival. Fire effects are woven through 

all aspects of this premise. The dynamic nature of ecosystems and the scale of landscape patterns and 

processes are fundamental characteristics that the interdisciplinary team (IDT) considered in integrating 

TEK and agency knowledge of fire into land management.

Alternative 2 would apply phased, strategically placed manual, mechanical, and prescribed burning 

treatments across the landscape and around private inholdings to establish defensible space, critical 

fuelbreaks and safe access routes to aid fire control and frequent burning to promote TCPs. Refer to Table 

2-5, Table 2-6, and Table 2-7 for more details on phasing of treatments and unit-specific treatments.

Once initial phased entries 1 through 3 are complete, as summarized below in the Treatment 

Prescription Descriptions section and described in Appendix C, repeated, carefully planned prescribed 

burning would continue up to 15 years. As designed, prescribed fire would be ignited from the established 

fuelbreaks, whereby flames creep downslope becoming the primary method to achieve ecological balance 

of key cultural and ecological elements, and WUI property and life protection.

The following treatment methods would be implemented to alter forest fuels structure and fuel loading:

Manual Treatments

Manual treatments are proposed as an initial entry and as a second entry following mechanical entries, to 

select for more fire tolerant species, lower fuels concentrations, and potential for torching to control fire 

behavior during burning operations.

Handheld equipment (e.g., chainsaws, loppers) is utilized to thin (cut), limb, or girdle small-diameter 

ladder fuels and break up the continuity of high concentrations of shrub species. Some conifers cannot be 

removed without seriously damaging oak trees (Harrington and Devine 2006). Girdling removes a strip of 

bark from around the entire circumference of either a branch or trunk of a woody plant.

Slash generated from manual treatments would be handpiled and burned (or scattered where 

concentrations are low) to prepare for understory or jackpot burning. Handpile dimensions are up to 

5x5x5 feet in size, piled on slopes up to 65 percent, and away from the drip line of pre-dominant trees. 

Piles would be covered and ignited during favorable weather conditions.

Manual treatments as an initial entry would occur in areas where there is no opportunity for forest byproducts, such as firewood and commercially valuable sawlogs. This may be due to the topography (not 

conducive to heavy equipment access or safe operations), protection of natural resources vulnerable to 
Chapter 2. The Alternatives

44 – Somes Bar Integrated Fire Management Project

ground disturbance, or in larger more mature stands where only smaller diameter fuel reduction is 

necessary to prepare the ground for follow up prescribed burning.

Manual treatments would be implemented within select riparian areas. Most of the perennial and 

intermittent streams in the project area provide a natural obstacle to the rate of spread and consumption from 

understory/jackpot burning and may not require much treatment as the first entry. Where thinning of smalldiameter ladder fuels is needed to ensure positive prescribed burning effects adjacent to streamcourses, 

thinning would be limited to vegetation less than 6-inch dbh (diameter at breast height). Placement of piles 

would be minimized near stream channels, as well as adjacent large downed woody debris, key habitat 

components for Pacific giant salamanders.

Mechanical Treatments

Ground-, cable- and road-based heavy equipment (e.g., yarders, tractors) are utilized to improve growing 

conditions for trees of interest and reduce ladder fuels. In plantations, the residual average canopy closure 

would be 45 to 50 percent. For example, non-plantations, where larger black and white oak or sugar pine 

are being encroached by other less fire-tolerant conifer species, efforts would be aimed at culturing 

around these more fire-tolerant species to promote their health and vigor and to help ensure these species 

continue to thrive in the project area. This would also aid in efforts to provide meaningful forest industry 

jobs. Activity fuels may also be handpiled and burned.

Ridgetop-Shaded Fuelbreaks

Ridgetop-shaded fuelbreaks are strategic ridges identified as important control features for prescribed 

burning and would assist with wildland fire response tactics. They are similar to the access/egress shaded 

fuelbreaks, but narrower in scope. Manual treatments may include handpile burning or lopping and 

scattering of fuels up to 100 feet off ridge features, supported by two-foot-wide handline construction.

Prescribed Burning

To achieve the desired results of low- to moderate-burning intensity, manual and mechanical treatments 

would be completed to allow for prescribed fire conditions that minimize high-severity fire effects. Some 

of the project area is not accessible due to very steep terrain or is already in the condition (more open 

stands, no ladder fuels) that would achieve the desired effects from burning without any pre-treatments.

Prescribed burning (Figure 2-7) would target the reduction of small-diameter ladder fuels and break up 

the continuity of excessive surface fuel build up. Important cultural and ecological plant and tree species 

would be protected from adverse fire effects, either by installing temporary firelines or by altering ignition

patterns as identified in a burn plan. Riparian areas would not be directly ignited, but fire would not be 

prevented from entering into them. If its determined that the initial fuel loading is too heavy in the riparian 

area to allow prescribed fire to enter, then handlines or “wet lines” would be temporarily employed to reduce 

the potential for adverse impacts to stream temperature and water quality. Follow up understory burn 

treatments would occur approximately every two (2) to seven (7) years according to site-specific objectives.
Chapter 2. The Alternatives

Final Environmental Assessment – 45

Treatment Prescription Descriptions

The WKRP IDT designed a series of phased entry, integrated fuels reduction and ecological restoration 

land management treatments for 15 years, to the degree suppression would no longer be the primary 

choice for fire managers in the near future. These treatments are intended to be a turning point at which a 

full range of response options for using prescribed fire and unplanned wildfire ignitions as a restoration 

tool could be employed to heal the natural world in balance with people, benefiting amenities, TEK and 

natural resources.

During treatment (prescription) development, the IDT rigorously explored rate of change and scale of

adaptive treatment methods, including entry cycles, seasonal timing, and spatial scale and position,

recognizing implications for affecting TEK, water resources, plants, animals, aquatic species and people.

The implementation strategy entails pre-treating select areas where crown and/or ladder fuels would 

hamper safe application of prescribed fire. Where mechanical pre-treatments are necessary, manual 

treatments of understory ladder reduction would occur, followed by prescribed burning. Where crown and 

ladder fuels are not excessive and/or no access exists, initial entry would commence with prescribed burning.

The IDT developed treatments in context of crown class, fuel type and canopy closure. This approach 

was taken to allow for micro-scale specific “best fit” adaptive treatment variations during fieldwork, 

responsive to the collaborative’s recommendation that treatments not be arbitrarily constraining. Crown class 

is defined relative to the tree’s structural vertical position in the forest and horizontal live crown ratio. Fuel 

type is defined as an identifiable association of fuel elements of distinctive species, form, size, arrangement, 

or other characteristics that will cause a predictable rate of spread or resistance to control under specified 

weather conditions. Table 2-4 provides crown class and fuel-type classifications and definitions.

Figure 2-7. Prescribed burn in progress.
Chapter 2. The Alternatives

46 – Somes Bar Integrated Fire Management Project

Table 2-4. Crown class and fuel-type classes.

Crown Class Fuel Type Definition

Pre-dominant (Protected 

during all entries) Crown Larger, older trees that pre-date the current age of the stand and have large limbs, livecrown ratios generally greater than 50 percent.

Dominant (Protected 

during all entries) Crown

Trees with crowns extending above the general level of the crown cover and receiving 

full light from above and partly from the sides; larger than the average trees in the stand 

and with crowns well developed but possibly crowded on the sides. Live crown ratios 

generally greater than 40 percent.

Co-dominant Crown

Trees with crowns forming the general level of the crown cover and receiving full light 

from above but comparatively little from the sides; usually with medium-sized crowns 

more or less crowded on the sides. Live crown ratios generally greater than 30 percent.

Intermediate Ladder

Trees shorter than those in the two preceding classes, but with crowns either below or 

extending into the crown cover framed by the co-dominant and dominant trees, receiving 

a little direct light from above but none from the sides; usually with small crowns 

considerably crowded on the sides. Live crown ratios generally less than 30 percent.

Suppressed Ladder

Trees with crowns entirely below the general level of the crown cover receiving no 

direct light either from above or from the sides. Live crown ratios are generally less than 

20 percent.

Common Design Criteria for Plantations – Mechanical Treatments

• All pre-dominant and dominant tree species would be retained. These trees are considered fire 

resilient due to their thick bark and generally lack of low-lying tree branches.

• A minimum 40 percent canopy closure would be retained, on average, throughout the treatment unit.

Prescription 1a: Plantations (Douglas-fir) and 1b (Pine)

The prescription for 1a and 1b are similar, with one exception. Treatments in plantations with a substantial 

pine tree component (1b) would be thinned to 80 to 100 residual basal area in square feet per acre 

dependent on the size and age of the stand (North 2012, Fettig et al. 2007, Fettig et al. 2010) to minimize 

the potential for increasing unwanted bark beetle populations. Douglas-fir dominated plantations would be 

thinned to 100 to 120 residual basal area in square feet per acre, depending on the size and age of stand.

Ladder and canopy fuels would be thinned to increase spacing between conifers (Douglas-fir) and 

pines (sugar, ponderosa and Jeffrey pines), followed by surface fuels treatments to increase ground-tocrown height distances. Figure 2-8 illustrates a typical plantation in the project area in need of mechanical 

treatment prior to initiating prescribed burning.
Chapter 2. The Alternatives

Final Environmental Assessment – 47

First Entry (1a and 1b). Mechanical fuels treatment (ground based and cable yarding).

At the treatment unit scale, areas of high- and low-stand density (retention patches and openings) would 

be interspersed throughout the unit. The remaining portion of the stand would be thinned retaining an 

average 45 to 50 percent canopy cover. Species variability would be enhanced by thinning around true 

oaks, sugar, ponderosa or Jeffrey pines, madrone, and Pacific yew wherever possible. Figure 2-9

illustrates encroachment of black oaks in a plantation. Thinning around suppressed oak trees is a priority.

Use the upper end of canopy cover range along roadways, around invasive weeds and adjacent to 

retention patches. Use the lower end of canopy cover range along ridges and adjacent to gaps.

Figure 2-8. Mechanical treatment unit in a 50-year-old plantation, featuring multistemmed tanoaks inter-mixed with Douglas-fir.

Figure 2-9. Mature black oaks being outcompeted by younger Douglas-fir. The 

Douglas-firs are in the stem exclusion stage, putting all their resources into 

growing taller in the competition for light and shading out the oaks.
Chapter 2. The Alternatives

48 – Somes Bar Integrated Fire Management Project

Retention patches. The use of ground-based machinery (tractors and masticators) is prohibited 

within retention patches. Retention patches would retain forest canopy from 5 to 10 percent of each unit, 

clumped in 0.25- to 1.0-acre patches, strategically placed where there is evidence of culturally important 

gathering areas or TEK species habitats that would benefit from more forest cover or shade (i.e., 

gathering or elk calving areas).

Where woodrat nests are found, choose 0.25 acres adjacent to retention patch to cut all tanoak sprouts

less than 4-inch dbh to encourage re-sprouting and create future woodrat habitat where appropriate.

Openings. Openings in the forest canopy would be created to increase heterogeneity and promote 

cultural vegetation. Traditional ecological knowledge data and on-site observations are used to locate 

openings in areas where TEK species or cultural vegetation would benefit from increased or filtered light. 

Locate in areas where conditions in the stand may already be less dense (e.g., encroached meadows).

Improve quality foraging habitat for local elk populations and warmer sites by creating 0.5- to 1-acre 

openings. Where non-elk habitat and cooler sites are present, gaps would range from 0.25 to 0.5 acres.

Second Entry (4c). Manual hand cutting, handpiling, grapple or excavator piling, and pile burning.

Small diameter trees and shrubs, 4- to 6-inch dbh and less, would be manually cut from beneath overstory 

trees, and/or aggregations of small-diameter Douglas-fir plantation trees would be thinned. Figure 2-10

illustrates a typical young plantation in the project area. Retain approximately 30 percent of the vegetation 

to be cut in the latter portion (150 to 300 feet) of the access/egress road treatment and inner riparian 

reserves. Enhance species variability by thinning around true oaks, sugar, ponderosa or Jeffrey pines, 

madrone, Chinquapin, and Pacific yew wherever possible. Reduce concentration of tanoak sprouts by 

thinning 25 to 50 percent of live sprouts over 4-inch dbh.

The cut trees and shrubs, and existing slash, would be manually piled, jackpot or lopped and 

scattered, depending on fuel-loading conditions. Low-impact machine piling may be employed to reduce 

costs and increase production. Create piles approximately 5x5x5 feet in size and place away from the 

dripline of pre-dominant trees and sensitive plant buffer areas. Burn piles under appropriate conditions as 

described in the burn plan.

Third Entry (5b). Prescribed fire.

Handlines would be constructed by manual methods prior to ignition. A prescribed burn under an existing 

canopy of trees would be designed to reduce concentrations of excess live and dead vegetation. This type 

of burning would be initiated when fuel moistures are low enough to carry fire and still within 

prescription parameters. Burning would only be initiated on “burn days” or with an approved variance.
Chapter 2. The Alternatives

Final Environmental Assessment – 49

Prescription 2 – Non-Plantation

Commercial thinning would occur to increase the health and vigor of shade-intolerant tree species by 

providing needed light and growing space around these trees, and to reduce crown and ladder fuels by 

increasing spacing between trees and tree crowns. This would be followed by thinning ladder fuels to 

increase ground-to-crown height distances and surface fuel reduction treatments to promote desired 

prescribed fire effects. The creation of gaps and openings described below are designed to improve 

overall stand heterogeneity.

Thinning would focus where shade-tolerate species have tree crowns that are impinging on culturally 

important shade-intolerant species (trees of interest), removing the smallest trees necessary to release trees 

of interest. In areas not containing trees of interest, removal of a portion of the suppressed and 

intermediate-crown class conifer trees would occur to reduce ladder fuel concentrations, while maintaining 

the multi-aged structure of the stand. Figure 2-11 is an example of a non-plantation in the project area.

First Entry (2). Mechanical fuels treatment.

Retain trees of interest, such as black and white oak, sugar pine, madrone, ponderosa and Jeffrey pine, 

chinquapin and tanoak, greater than 8-inch dbh. Mark for cutting all Douglas-fir trees within the dripline 

of the tree of interest. Continue to mark additional Douglas-fir for removal until shade on the crown area 

of the tree of interest has been reduced by 50 percent.

Figure 2-10. Manual treatment unit in a 32-year-old plantation, Douglas-firs mixed 

with multi-stemmed tanoaks.
Chapter 2. The Alternatives

50 – Somes Bar Integrated Fire Management Project

Retention patch clumps of 5 to 10 percent of the unit in 0.25- to 1.0-acre sections would be 

strategically placed where there is evidence of culturally important gathering areas or TEK species 

habitats that would benefit from less solar radiation (i.e., gathering or elk calving areas). Where woodrat 

nests are found, choose 0.25 acres adjacent to retention patch to cut all tanoak sprouts less than 4-inch dbh

to encourage re-sprouting and create future woodrat habitat where appropriate.

Openings in the forest canopy would be applied to ground-based logging systems ranging from 10 to 

20 percent of the unit area, positioned away from system roads where invasive plants are present. Openings

would be located in a manner that would provide benefits to TEK species such as beargrass, iris, 

manzanita, and true oaks or where other TEK focal species would benefit from filtered light.

Locate in areas where conditions in the stand may already be less dense (e.g., existing interior 

landings, skid roads, or encroached meadows). Improve quality foraging habitat for local elk populations 

and warmer sites by allowing for 0.5- to 1.0-acre openings. Where non-elk habitat and cooler sites are 

present, gaps would range from 0.25 to 0.5 acres.

Use the upper end of canopy cover range along roadways, around invasive weeds and adjacent to 

retention patches. Use the lower end of canopy cover range along ridges and adjacent to gaps or openings.

Second Entry (4c). Manual hand cutting, handpiling, grapple or excavator piling, and pile burning.

Small diameter trees and shrubs, 4- to 6-inch dbh and less, would be manually cut from beneath overstory 

trees, and/or aggregations of small-diameter Douglas-fir plantation trees would be thinned. Retain 

approximately 30 percent of the vegetation to be cut in the latter portion (150 to 300 feet) of the access/egress 

road treatment and inner riparian reserves. Enhance species variability by thinning around true oaks, sugar, 

ponderosa or Jeffrey pines, madrone, chinquapin, and Pacific yew wherever possible. Reduce concentration 

of tanoak sprouts by thinning 25 to 50 percent of live sprouts over 4-inch dbh.

The cut trees and shrubs, and existing slash, would be manually piled, jackpot or lopped and scattered 

depending on fuel loading conditions. Low-impact machine piling may be employed to reduce costs and 

increase production. Create piles approximately 5x5x5 feet in size and place away from the dripline of 

Figure 2-11. Mechanical treatment unit in a non-plantation, high stem density forest 

resulting from fire suppression. These trees, which have grown up in the fire 

suppression era, are too big to treat effectively with a manual treatment.
Chapter 2. The Alternatives

Final Environmental Assessment – 51

pre-dominant trees and sensitive plant buffer areas. Burn piles under appropriate conditions as described 

in the burn plan.

Third Entry (5b). Prescribed fire.

Defer prescribed burning in non-plantations for two (2) years post mechanical treatments to allow 

previously encroached trees to respond to improved stand conditions. Handlines would be constructed by 

manual methods prior to ignition. A prescribed burn under an existing canopy of trees would be designed 

to reduce concentrations of excess live and dead vegetation. This type of burning would be initiated when 

fuel moistures are low enough to carry fire and still within prescription parameters. Burning would only 

be initiated on “burn days” or with an approved variance.

Prescription 3 – Plantation Ladder Fuel Mastication

The objective is to break up some of the continuous fuelbed in young Douglas-fir plantations in 

preparation for prescribed burning. Figure 2-12 is a good example of a where masticators would be 

operated to reduce ladder fuel concentrations. Utilizing former skid and logging roads, masticators work 

on reducing fuel loading on and adjacent to these linear features. In essence, they create a path through 

dense plantations where crews can conduct additional manual fuel reduction treatments and planned 

burning operations.

First Entry (3). Mastication.

Masticate small-diameter vegetation, generally less than 4- to 6-inch dbh, across 60 percent of the treatment 

area to minimize the amount of slash material on the ground. Some of these areas would have a follow up 

manual treatment.

Second Entry (4c). Manual hand cutting, handpiling, grapple or excavator piling, and pile burning.

Choose retention patches in clumps of 5 to 10 percent of the unit in 0.25- to 1.0-acre sections where the 

masticator did not enter. Retention patches would be strategically placed where there is evidence of 

culturally important gathering areas or TEK species habitats that would benefit from less solar radiation 

(i.e., gathering or elk calving areas). Where woodrat nests are found, choose 0.25 acres adjacent to the 

Figure 2-12. Young plantation (very high stem density of tanoak, madrone and Douglas-fir) where 

masticators are employed to reduce fuel loading in preparation for prescribed burning.
Chapter 2. The Alternatives

52 – Somes Bar Integrated Fire Management Project

retention patch to cut all tanoak sprouts less than 4 inches dbh to encourage resprouting and create future 

woodrat habitat where appropriate.

The cut trees and shrubs, and existing slash, would be manually piled, jackpot or lopped and scattered 

depending on fuel loading conditions. Low-impact machine piling may be employed to reduce costs and 

increase production. Create piles approximately 5x5x5 feet in size and place away from the dripline of 

pre-dominant trees. Burn piles under appropriate conditions as described in the burn plan.

Third Entry (5d). Prescribed fire.

Handlines would be constructed by manual methods prior to ignition. A prescribed burn in a treated stand 

would be designed to reduce concentrations of excess live and dead vegetation. Defer prescribed burning 

in mastication units for two (2) to five (5) years to allow for adequate decomposition of masticated 

material to promote desired prescribed fire effects. This type of burning would be initiated when fuel 

moistures are low enough to carry fire and still within prescription parameters. Burning would only be 

initiated on “burn days” or with an approved variance.

Prescriptions 4a – Plantation Ladder Fuel Manual Thinning

Reduce ladder fuels by breaking up the continuity of both vertical and horizontal fuels using manual 

methods in preparation for prescribed fire.

First Entry (4a). Plantation ladder fuel manual thinning.

Small-diameter trees and shrubs, generally up to 6-inch dbh, would be manually cut from beneath 

overstory trees, and/or aggregations of small-diameter Douglas-fir plantation trees would be thinned or 

limbed. Spacing for leave trees should be approximately 16 feet apart. Retain approximately 30 percent of 

the vegetation to be cut in the latter portion (150 to 300 feet) of the access/egress road treatment and inner 

riparian reserves. Enhance species variability by thinning around true oaks, sugar, ponderosa or Jeffrey 

pines, madrone, chinquapin, and Pacific yew when present. Reduce concentration of tanoak sprouts by 

thinning 25 to 50 percent of live sprouts under 4-inch dbh. Create or enhance openings approximately 

0.25 to 0.33 acres in size where feasible.

The cut trees, shrubs, and existing slash would be manually piled, jackpot, or lopped and scattered 

depending on fuel-loading conditions. Low-impact machine piling may be employed to reduce costs and 

increase production. Create piles approximately 5x5x5 feet in size and place away from the dripline of 

pre-dominant trees. Burn piles under appropriate conditions as described in the burn plan.

Second Entry (5c). Prescribed fire in manual units.

Handlines would be constructed by manual methods prior to ignition. A prescribed burn in a treated stand 

would be designed to reduce concentrations of excess live and dead vegetation, while maintaining gaps 

created during the first entry. This type of burning would be initiated when fuel moistures are low enough 

to carry fire and still within prescription parameters. Burning would only be initiated on “burn days” or 

with an approved variance.
Chapter 2. The Alternatives

Final Environmental Assessment – 53

Prescriptions 4b – Non-Plantation Ladder-Fuel Manual Thinning

Reduce ladder fuels by breaking up the continuity of both vertical and horizontal fuels using manual 

methods in preparation for prescribed fire. Figure 2-13 is an example of a non-plantation manual thinning 

treatment unit.

First Entry (4b). Non-plantation ladder-fuel manual thinning.

Small diameter conifer trees and shrubs, between 4- and 6-inch dbh, would be manually cut from beneath 

overstory trees, and/or aggregations of small-diameter Douglas-fir trees would be thinned. Spacing for leave 

trees should range from 20 to 24 feet apart to promote stand heterogeneity. Retain approximately 30 percent 

of the vegetation to be cut in the latter portion (150 to 300 feet) of the access/egress road treatment and inner 

riparian reserves. Enhance species variability by thinning around true oaks, sugar, ponderosa or Jeffrey 

pines, madrone, and Pacific yew wherever possible. Reduce concentration of tanoak sprouts by thinning 25 

to 50 percent of live sprouts over 4-inch dbh. Where feasible, reduce contiguous patches of evergreen 

huckleberry, in a mosaic pattern, up to 50 percent of what is present in the unit, especially when adjacent to 

the largest trees.

Create or enhance openings approximately 0.25 to 0.33 acres in size where feasible. Consider girdling 

to enhance openings where feasible. The cut trees, shrubs, and existing slash would be manually piled, 

jackpot, or lopped and scattered depending on fuel loading conditions. Create piles approximately 5x5x5

feet in size and place away from the dripline of pre-dominant trees. Burn piles under appropriate 

conditions as described in the burn plan.

Second Entry (5c). Prescribed fire in manual units.

Handlines would be constructed by manual methods prior to ignition. A prescribed burn in a treated stand 

would be designed to reduce concentrations of excess live and dead vegetation, while maintaining gaps 

created during the first entry. This type of burning would be initiated when fuel moistures are low enough 

to carry fire and still within prescription parameters. Burning would only be initiated on “burn days” or 

with an approved variance.

Figure 2-13. Manual treatment unit in a non-plantation, high stem density forest 

resulting from fire suppression. These trees, which have grown up in the fire 

suppression era, are small enough to be treated effectively by hand.
Chapter 2. The Alternatives

54 – Somes Bar Integrated Fire Management Project

Prescriptions 5a – Prescribed Fire in Plantations and Non-Plantations

Treatment units are located in the interior of the project areas, away from access/egress roads and private 

lands.

First Entry (5a). Prescribed fire in plantations and non-plantations.

It is acknowledged that not every acre of these units would be treated; however, prescribed fire would be 

used to break up the continuity of fuel loading and maintain existing openings where appropriate. Mixed 

severity is anticipated and control features and firing tactics would keep higher severity fire effects to less 

than 10 percent of the units treated, with fire as a first entry. Treatments in these areas would be 

conducted only after the fuelbreaks and other treatment unit work has been completed. Handlines would 

be constructed by manual methods prior to ignition. This type of burning would be initiated when fuel 

moistures are low enough to carry fire and still within prescription parameters. Figure 2-14 is an example 

of a stand where prescribed fire is the first entry.

Figure 2-14. Prescribed fire treatment unit, low amounts of ladder fuels and ample 

surface fuels create a condition where prescribed fire is an effective treatment.
Chapter 2. The Alternatives

Final Environmental Assessment – 55

Maintenance Burning

During the final treatment entries, all units would require varying degrees of maintenance using 

prescribed burning to achieve project treatment objectives. The frequency of maintenance burning would

be two (2) to seven (7) years after the third entry, once mechanical, manual and prescribed treatments 

have been completed.

The maintenance burn cycle would be based on the amount of short-term fuel loading buildup from 

field surveys relative to desired fuel conditions. Burning would be initiated when fuel moistures are low 

enough to carry fire and still within prescription parameters for low to moderate intensity. Burning would 

only be initiated on “burn days” or with an approved variance.

Implementation Strategy

Table 2-5 summarizes the phasing and order of treatments intended to prepare the landscape for 

prescribed burning, achieving the desired fire effects intended to meet the purpose and need for the 

project. The sequencing is designed to ensure safe and efficient application, while minimizing undesirable 

effects to natural and TEK resources.

Table 2-5. Phasing of treatments.

Proposed Treatments Prescription ID Acres

First Entry

Plantations – Mechanical thinning and removal of fuels, handpile and handpile burn. 1a and 1b 660

Non-Plantations – Cultural tree species restoration and ladder-fuel mechanical thinning. 2 573

Plantations – Ladder-fuel mastication. 3 187

Plantation – Ladder-fuel manual thinning. 4a 502

Non-Plantation – Ladder-fuel manual thinning. 4b 2,156

Plantation and Non-Plantation – Ladder-fuel prescribed fire. 5a 1,491

Total 5,570

Second Entry

Manual Thinning Ladder Fuel Post Mechanical and Post Mastication Entries. 4c 1,420

Third Entry (provided associated handlines and control features are in place)

Prescribed Fire – Understory and jackpot burn in all mechanical units, where needed. 5a 1,233

Prescribed Fire – Understory and jackpot burn in all manual units, where needed. 5b 2,658

Prescribed Fire – Understory and jackpot burn in all mastication units, where needed. 5c 187

Total 4,078

Maintenance Entry

Prescribed fire in mechanical and manual treated units. 5,570

Proposed Action – Unit-Specific Treatment Descriptions

The unit-specific information of first entry treatments is presented in Table 2-6 and Table 2-7. Upon 

completion of the first entry prescription (Table 2-6), a second entry (4c) of manual hand cutting, piling 

and burning, followed by a third entry (5b) of prescribed burning would be implemented (see Figure 2-15, 

Figure 2-17, Figure 2-19 and Figure 2-22). All units would then receive maintenance burning every three 

(3) to seven (7) years.
Chapter 2. The Alternatives

56 – Somes Bar Integrated Fire Management Project

Table 2-6. First entry mechanical unit treatments.

Unit ID Treatment 

Category

Harvest 

Method Prescription Acres

Volume 

Estimate 

(MBF)

TEK Resource

Pre-Treatment 

Canopy Cover 

Range (%)

PostTreatment 

Canopy Cover 

Range (%)

2101 Mechanical Ground-based 1b 10 80 Cultural Vegetation 94-99 40-60

2105 Mechanical Ground-based 1a 7 35 Cultural Vegetation, 85-99 40-60

2110 Mechanical Ground-based 1a 6 30 Pacific fisher, Cultural 

Vegetation 75-99 40-50

2111 Mechanical Ground-based 1b 8 45 Cultural Vegetation 94-99 40-50

2112 Mechanical Ground-based 1b 16 100

Pacific fisher, Cultural 

Vegetation, Pacific giant 

salamander

86-99 40-50

2113 Mechanical Ground-based 2 13 50

Elk, Trees of Interest, 

Cultural Vegetation, 

Pacific giant salamander

80-99 40-50

2114 Mechanical Ground-based 2 16 75

Elk, Trees of Interest, 

Cultural Vegetation, 

Pacific giant salamander

78-99 40-50

2116 Mechanical Ground-based 2 20 120

Elk, NSO, Trees of 

Interest, Cultural 

Vegetation, Pacific giant 

salamander

79-99 40-60

2117 Mechanical Ground-based 1b 12 80 Elk, Cultural Vegetation, 

Pacific giant salamander 60-99 40-60

2119 Mechanical Ground-based 2 3 0 Elk, Trees of Interest, 

Cultural Vegetation 73-99 40-60

2120 Mechanical Cable-based 2 6 0 Elk, Trees of Interest, 

Cultural Vegetation 69-99 40-60

2124 Mechanical Cable-based 2 4 20 Elk, Trees of Interest, 

Cultural Vegetation 81-99 40-50

2127 Mechanical Ground-based 2 35 250

Elk, Pacific fisher, Trees 

of Interest, Cultural 

Vegetation

71-99 40-60

2128 Mechanical Ground-based 1a 3 0 Elk, Cultural Vegetation 79-98 40-50

2131 Mechanical Ground-based 1a 8 80 Cultural Vegetation 87-99 40-60

2132 Mechanical Ground-based 2 11 15

Elk, NSO, Trees of 

Interest, Cultural 

Vegetation, Pacific giant 

salamander

82-99 40-60

2142 Mechanical Ground-based 2 9 0 Elk, Pacific fisher, Willow, 

Cultural Vegetation, 0-72 40-50

2145 Mechanical Ground-based 2 20 0

Elk, NSO, Trees of 

Interest, Cultural 

Vegetation

65-99 40-50

2148 Mechanical Ground-based 2 5 18 Trees of Interest, Cultural 

Vegetation 89-99 40-50

2151 Mechanical Ground-based 1a 1 0 Elk, Cultural Vegetation 55-86 40-50

2157 Mechanical Cable-based 2 0 0 Cultural Vegetation 91-92 40-50

2158 Mechanical Cable-based 2 3 0 Elk, Cultural Vegetation 90-98 40-60

2200 Mechanical Ground-based 1a 6 40 Elk, Cultural Vegetation 83-99 40-50

2203 Mechanical Ground-based 1b 13 45 Elk, Pacific fisher, 

Cultural Vegetation 46-99 40-50

2217 Mechanical Ground-based 1a 24 180 Elk, Pacific fisher, 

Cultural Vegetation 80-99 40-50

2218 Mechanical Ground-based 2 10 25 Elk, Trees of Interest, 

Cultural Vegetation 76-99 40-60

2221 Mechanical Ground-based 1a 10 60 Elk, Cultural Vegetation 71-99 40-60

2224 Mechanical Ground-based 2 3 5 Elk, Cultural Vegetation 82-99 40-60
Chapter 2. The Alternatives

Final Environmental Assessment – 57

Unit ID Treatment 

Category

Harvest 

Method Prescription Acres

Volume 

Estimate 

(MBF)

TEK Resource

Pre-Treatment 

Canopy Cover 

Range (%)

PostTreatment 

Canopy Cover 

Range (%)

2225 Mechanical Ground-based 2 7 40 Trees of Interest, Cultural 

Vegetation 87-99 40-60

2226 Mechanical Ground-based 1a 4 12 Cultural Vegetation 97-99 40-60

2227 Mechanical Ground-based 1b 33 180 Elk, Cultural Vegetation 82-99 40-60

2228 Mechanical Cable-based 2 8 0 Elk, Cultural Vegetation 78-99 40-60

2230 Mechanical Ground-based 1a 16 100 Elk, Cultural Vegetation 89-99 40-60

2231 Mechanical Cable-based 2 1 0 Cultural Vegetation 91-99 40-60

2235 Mechanical Ground-based 1b 10 40 Cultural Vegetation 84-99 40-60

2237 Mechanical Ground-based 1a 17 110 Cultural Vegetation, 

Pacific giant salamander 78-99 40-50

2242 Mechanical Ground-based 1a 26 100 Cultural Vegetation, 

Pacific giant salamander 81-99 40-50

2248 Mechanical Ground-based 2 29 0

Pacific fisher, Trees of 

Interest, Cultural 

Vegetation, Pacific giant 

salamander

78-99 40-50

2249 Mechanical Ground-based 2 78 350

Elk, NSO, Trees of 

Interest, Cultural 

Vegetation, Pacific giant 

salamander

84-99 40-60

2260 Mechanical Ground-based 2 6 0 Elk, Trees of Interest, 

Cultural Vegetation 59-98 40-50

2264 Mechanical Ground-based 1b 26 30 Cultural Vegetation, 

Pacific giant salamander 73-99 40-50

2265 Mechanical Ground-based 1b 40 180 Elk, Cultural Vegetation 85-99 40-50

2266 Mechanical Ground-based 2 7 70 Elk, Trees of Interest, 

Cultural Vegetation 81-99 40-50

2272 Mechanical Ground-based 2 3 10 Elk, Trees of Interest, 

Cultural Vegetation 59-97 40-50

2273 Mechanical Ground-based 2 3 10

Elk, Pacific fisher, Trees 

of Interest, Cultural 

Vegetation

66-99 40-50

2320 Mechanical Cable-based 1a 4 100 Cultural Vegetation 29-97 40-60

2321 Mechanical Cable-based 2 9 0 Cultural Vegetation 81-99 40-60

2328 Mechanical Ground-based 1a 12 0 Cultural Vegetation 65-99 40-60

2336 Mechanical Cable-based 2 17 70

Elk, NSO, Trees of 

Interest, Cultural 

Vegetation

76-99 40-60

2400 Mechanical Ground-based 2 34 700

Elk, NSO, Pacific fisher, 

Trees of Interest, Cultural 

Vegetation

83-99 40-60

2401 Mechanical Cable-based 2 2 0 Trees of Interest, Cultural 

Vegetation 48-97 40-60

2402 Mechanical Ground-based 1a 7 18 Elk, Cultural Vegetation, 

Pacific giant salamander 66-99 40-50

2404 Mechanical Ground-based 1a 4 0 Cultural Vegetation 69-99 40-50

2405 Mechanical Ground-based 1a 4 20 Elk, Cultural Vegetation 81-99 40-50

2407 Mechanical Ground-based 1b 26 190 Cultural Vegetation, 

Pacific giant salamander 81-99 40-50

2409 Mechanical Ground-based 1a 9 0 Cultural Vegetation 80-99 40-50

2411 Mechanical Ground-based 1b 23 180 Cultural Vegetation 88-99 40-60

2412 Mechanical Ground-based 1b 19 100 Cultural Vegetation, 

Pacific giant salamander 92-100 40-60

2414 Mechanical Cable-based 1a 7 0 Cultural Vegetation, 

Pacific giant salamander 55-99 40-50
Chapter 2. The Alternatives

58 – Somes Bar Integrated Fire Management Project

Unit ID Treatment 

Category

Harvest 

Method Prescription Acres

Volume 

Estimate 

(MBF)

TEK Resource

Pre-Treatment 

Canopy Cover 

Range (%)

PostTreatment 

Canopy Cover 

Range (%)

2419 Mechanical Ground-based 1a 8 70 Elk, Cultural Vegetation 95-99 40-60

2421 Mechanical Ground-based 1b 19 120 Elk, Cultural Vegetation, 

Pacific giant salamander 86-99 40-60

2422 Mechanical Ground-based 2 5 60 Elk, Trees of Interest, 

Cultural Vegetation 77-99 40-50

2423 Mechanical Cable-based 2 6 0 Cultural Vegetation, 

Pacific giant salamander 83-99 40-50

2425 Mechanical Cable-based 1a 17 0 Cultural Vegetation, 

Pacific giant salamander 87-99 40-60

2426 Mechanical Cable-based 2 6 0 Cultural Vegetation, 

Pacific giant salamander 88-99 40-60

2431 Mechanical Cable-based 2 16 0

Elk, Trees of Interest, 

Cultural Vegetation, 

Pacific giant salamander

30-99 40-60

2433 Mechanical Ground-based 1a 8 40 Elk, Cultural Vegetation 95-99 40-50

2434 Mechanical Cable-based 2 5 0 Cultural Vegetation, 

Pacific giant salamander 84-99 40-60

2452 Mechanical Ground-based 2 6 60 Elk, Trees of Interest, 

Cultural Vegetation 83-99 40-60

2453 Mechanical Ground-based 2 7 60

Elk, Pacific fisher, Trees 

of Interest, Cultural 

Vegetation

91-99 40-60

2454 Mechanical Ground-based 2 31 450

Elk, NSO, Pacific fisher, 

Trees of Interest, Cultural 

Vegetation

83-99 40-60

2456 Mechanical Ground-based 1b 9 70 Elk, Cultural Vegetation 85-99 40-60

2460 Mechanical Cable-based 1b 20 0 Cultural Vegetation, 

Pacific giant salamander 74-99 40-50

2461 Mechanical Ground-based 1a 44 240 Elk, Cultural Vegetation 90-99 40-50

2462 Mechanical Cable-based 2 25 0

NSO, Trees of Interest, 

Cultural Vegetation, 

Pacific giant salamander

82-99 40-60

2463 Mechanical Ground-based 1b 11 80 Elk, Cultural Vegetation 79-99 40-60

2465 Mechanical Cable-based 1a 10 0 Cultural Vegetation 83-99 40-50

2466 Mechanical Ground-based 1a 7 35 Cultural Vegetation 92-99 40-50

2467 Mechanical Ground-based 1a 11 0 Cultural Vegetation 83-99 40-60

2470 Mechanical Ground-based 1b 10 70 Cultural Vegetation 75-99 40-50

2474 Mechanical Ground-based 2 29 0

Elk, NSO, Pacific fisher, 

Trees of Interest, Cultural 

Vegetation, Pacific giant 

salamander

40-99 40-60

2475 Mechanical Ground-based 1a 17 0 Cultural Vegetation 73-99 40-50

2480 Mechanical Ground-based 1a 17 45 Elk, Cultural Vegetation 86-99 40-60

2481 Mechanical Ground-based 1a 26 80 Elk, Cultural Vegetation 78-99 40-50

2492 Mechanical Ground-based 1a 4 27 Cultural Vegetation 86-99 40-50

2493 Mechanical Ground-based 2 29 260

Elk, NSO, Trees of 

Interest, Cultural 

Vegetation

87-99 40-60

2494 Mechanical Cable-based 2 6 80 Elk, Trees of Interest, 

Cultural Vegetation 83-99 40-60

2500 Mechanical Ground-based 2 35 300 Elk, Trees of Interest, 

Cultural Vegetation 82-99 40-50

2505 Mechanical Ground-based 1a 8 20 Cultural Vegetation 65-98 40-50

2508 Mechanical Cable-based 2 2 0 Trees of Interest, Cultural 

Vegetation 82-99 40-60
Chapter 2. The Alternatives

Final Environmental Assessment – 59

Table 2-7. First entry manual, mastication and prescribed burning unit treatments.

Unit ID Treatment Category Prescriptions Acres

Pre-Treatment 

Canopy Cover 

(%)

TEK Resource

Post-Treatment 

Canopy Cover 

(%)

2100 Manual & Prescribed Fire 4b, 5c 84 87-99

Cultural Vegetation, 

NSO, Pacific giant 

salamander

85

2102 Manual & Prescribed Fire 4a, 5c 7 71-99 Cultural Vegetation 84

2103 Manual & Prescribed Fire 4b, 5c 5 83-99 Elk, Cultural Vegetation 84

2107 Manual & Prescribed Fire 4a, 5c 5 62-99 Cultural Vegetation, 

Pacific giant salamander 81

2108 Manual & Prescribed Fire 4a, 5c 5 22-97 Cultural Vegetation 49

2115 Manual & Prescribed Fire 4a, 5c 44 86-99

Elk, Pacific fisher, 

Cultural Vegetation, 

Pacific giant salamander

86

2118 Manual & Prescribed Fire 4b, 5c 14 78-99 Elk, Cultural Vegetation, 

Pacific giant salamander 83

2121 Manual & Prescribed Fire 4b, 5c 15 71-99

Elk, NSO, Cultural 

Vegetation, Pacific giant 

salamander

80

2122 Manual & Prescribed Fire 4b, 5c 8 89-99 NSO, Cultural Vegetation 84

2123 Manual & Prescribed Fire 4b, 5c 12 76-99 Cultural Vegetation 81

2125 Manual & Prescribed Fire 4b, 5c 4 69-98 Elk, Cultural Vegetation 79

2126 Manual & Prescribed Fire 4b, 5c 22 65-99 Elk, Cultural Vegetation, 

Pacific giant salamander 80

2129 Manual & Prescribed Fire 4a, 5c 6 26-76 Cultural Vegetation 41

2133 Manual & Prescribed Fire 4b, 5c 3 60-99 Cultural Vegetation 79

2134 Manual & Prescribed Fire 4b, 5c 12 0-43

Willow, Cultural 

Vegetation, Pacific giant 

salamander

75

2135 Manual & Prescribed Fire 4b, 5c 12 74-99 Elk, Cultural Vegetation, 

Pacific giant salamander 82

2136 Manual & Prescribed Fire 4b, 5c 81 57-99

Elk, NSO, Cultural 

Vegetation, Pacific giant 

salamander

78

2137 Manual & Prescribed Fire 4b, 5c 28 41-99 Elk, Cultural Vegetation, 

Pacific giant salamander 71

2138 Manual & Prescribed Fire 4b, 5c 6 2-97 Elk, Cultural Vegetation, 

Pacific giant salamander 60

2139 Manual & Prescribed Fire 4b, 5c 26 0-99 Cultural Vegetation, 

Pacific giant salamander 60

2140 Manual & Prescribed Fire 4b, 5c 21 0-97 Cultural Vegetation, 

Pacific giant salamander 60

2141 Manual & Prescribed Fire 4b, 5c 20 2-97

Elk, Pacific fisher, 

Cultural Vegetation, 

Pacific giant salamander

60

2143 Manual & Prescribed Fire 4b, 5c 8 61-99 Elk, Cultural Vegetation, 

Pacific giant salamander 78

2146 Manual & Prescribed Fire 4b, 5c 40 68-99 Cultural Vegetation, 

Pacific giant salamander 79

2147 Manual & Prescribed Fire 4b, 5c 17 67-99 Cultural Vegetation 78

2149 Manual & Prescribed Fire 4b, 5c 8 83-99

Trees of Interest, NSO, 

Cultural Vegetation, 

Pacific giant salamander

83

2150 Manual & Prescribed Fire 4a, 5c 3 91-99 Elk, Cultural Vegetation 86

2152 Manual & Prescribed Fire 4b, 5c 11 88-99 Elk, Cultural Vegetation, 

Pacific giant salamander 85
Chapter 2. The Alternatives

60 – Somes Bar Integrated Fire Management Project

Unit ID Treatment Category Prescriptions Acres

Pre-Treatment 

Canopy Cover 

(%)

TEK Resource

Post-Treatment 

Canopy Cover 

(%)

2153 Manual & Prescribed Fire 4b, 5c 14 78-99

Cultural Vegetation, 

NSO, Pacific giant 

salamander

83

2154 Manual & Prescribed Fire 4b, 5c 9 52-99 Cultural Vegetation, NSO 74

2155 Manual & Prescribed Fire 4b, 5c 8 83-99 Cultural Vegetation 84

2156 Manual & Prescribed Fire 4b, 5c 8 82-99 Cultural Vegetation 84

2159 Manual & Prescribed Fire 4b, 5c 8 55-99 Elk, Cultural Vegetation, 

Pacific giant salamander 80

2160 Manual & Prescribed Fire 4b, 5c 10 78-99 Elk, Cultural Vegetation 83

2161 Manual & Prescribed Fire 4b, 5c 9 66-98 Elk, Cultural Vegetation, 

Pacific giant salamander 77

2162 Manual & Prescribed Fire 4b, 5c 9 77-99

Elk, NSO, Trees of 

Interest, Cultural 

Vegetation, Pacific giant 

salamander

81

2163 Manual & Prescribed Fire 4b, 5c 22 30-99

Elk, Trees of Interest, 

Cultural Vegetation, 

Pacific giant salamander

69

2164 Manual & Prescribed Fire 4b, 5c 5 95-99

Trees of Interest, Cultural 

Vegetation, Pacific giant 

salamander

88

2165 Manual & Prescribed Fire 4b, 5c 19 0-26

Elk, Pacific fisher, Willow, 

Cultural Vegetation, 

Pacific giant salamander

25

2166 Manual & Prescribed Fire 4b, 5c 36 71-99 Cultural Vegetation 81

2167 Manual & Prescribed Fire 4b, 5c 1 96-99 Cultural Vegetation 87

2168 Manual & Prescribed Fire 4b, 5c 8 75-99 Cultural Vegetation 82

2169 Manual & Prescribed Fire 4b, 5c 4 88-99 Elk, Cultural Vegetation 85

2202 Manual & Prescribed Fire 4b, 5c 12 50-99 Elk, Trees of Interest, 

Cultural Vegetation 74

2206 Manual & Prescribed Fire 4b, 5c 18 58-99

Elk, NSO, Pacific fisher, 

Cultural Vegetation, 

Pacific giant salamander

77

2207 Manual & Prescribed Fire 4a, 5c 12 66-97 Cultural Vegetation 74

2210 Manual & Prescribed Fire 4a, 5c 14 89-99 Elk, Cultural Vegetation, 

Pacific giant salamander 86

2211 Manual & Prescribed Fire 4b, 5c 11 69-99 Elk, Pacific fisher, 

Cultural Vegetation 79

2213 Manual & Prescribed Fire 4b, 5c 10 82-99 Cultural Vegetation 85

2216 Manual & Prescribed Fire 4b, 5c 4 93-99 Cultural Vegetation, 

Pacific giant salamander 87

2219 Manual & Prescribed Fire 4b, 5c 4 91-99 Cultural Vegetation, 

Pacific giant salamander 87

2220 Manual & Prescribed Fire 4a, 5c 20 40-99 Elk, Cultural Vegetation 63

2222 Manual & Prescribed Fire 4b, 5c 10 90-100 Cultural Vegetation, 

Pacific giant salamander 87

2223 Manual & Prescribed Fire 4b, 5c 7 91-99 Cultural Vegetation 87

2233 Manual & Prescribed Fire 4a, 5c 8 21-85 Elk, Cultural Vegetation, 

Pacific giant salamander 43

2236 Manual & Prescribed Fire 4a, 5c 6 89-99 Cultural Vegetation, 

Pacific giant salamander 86

2239 Manual & Prescribed Fire 4b, 5c 3 83-99 Cultural Vegetation 83

2241 Manual & Prescribed Fire 4b, 5c 2 94-99 Cultural Vegetation, 

Pacific giant salamander 87
Chapter 2. The Alternatives

Final Environmental Assessment – 61

Unit ID Treatment Category Prescriptions Acres

Pre-Treatment 

Canopy Cover 

(%)

TEK Resource

Post-Treatment 

Canopy Cover 

(%)

2243 Manual & Prescribed Fire 4b, 5c 28 89-99

Pacific fisher, Cultural 

Vegetation Pacific giant 

salamander

87

2244 Manual & Prescribed Fire 4a, 5c 6 94-99 Cultural Vegetation 88

2245 Manual & Prescribed Fire 4b, 5c 6 90-99 Cultural Vegetation, 

Pacific giant salamander 86

2246 Manual & Prescribed Fire 4b, 5c 11 80-99 Cultural Vegetation, 

Pacific giant salamander 86

2247 Manual & Prescribed Fire 4b, 5c 14 89-99

Cultural Vegetation,

NSO, Pacific giant 

salamander

87

2250 Manual & Prescribed Fire 4b, 5c 18 80-99

Cultural Vegetation,

NSO, Pacific giant 

salamander

84

2251 Manual & Prescribed Fire 4b, 5c 7 95-99

Cultural Vegetation,

NSO, Pacific giant 

salamander

88

2252 Manual & Prescribed Fire 4b, 5c 25 81-99

Elk, NSO, Cultural 

Vegetation, Pacific giant 

salamander

85

2253 Manual & Prescribed Fire 4b, 5c 59 84-99

Elk, NSO, Cultural 

Vegetation, Pacific giant 

salamander

85

2254 Manual & Prescribed Fire 4b, 5c 12 47-99 Elk, Cultural Vegetation

Pacific giant salamander, 76

2255 Manual & Prescribed Fire 4b, 5c 24 37-99

Elk, NSO, Cultural 

Vegetation, Pacific giant 

salamander

72

2256 Manual & Prescribed Fire 4b, 5c 28 59-99

Elk, NSO, Cultural 

Vegetation Pacific giant 

salamander,

79

2257 Manual & Prescribed Fire 4b, 5c 10 34-99 Cultural Vegetation 71

2258 Manual & Prescribed Fire 4b, 5c 9 3-99 Cultural Vegetation, 

Pacific giant salamander 49

2259 Manual & Prescribed Fire 4b, 5c 104 12-99

Pacific fisher, Cultural 

Vegetation, Pacific giant 

salamander

60

2261 Manual & Prescribed Fire 4a, 5c 6 58-97 Elk, Cultural Vegetation 70

2262 Manual & Prescribed Fire 4b, 5c 2 52-95 Elk, Cultural Vegetation 70

2263 Manual & Prescribed Fire 4b, 5c 21 62-99

Elk, NSO, Trees of 

Interest, Cultural 

Vegetation, Pacific giant 

salamander

78

2267 Manual & Prescribed Fire 4a, 5c 2 46-81 Elk, Cultural Vegetation 58

2271 Manual & Prescribed Fire 4b, 5c 7 25-99

Elk, Trees of Interest, 

Cultural Vegetation, 

Pacific giant salamander

58

2274 Manual & Prescribed Fire 4b, 5c 10 47-99 Cultural Vegetation, 

Pacific giant salamander 78

2275 Manual & Prescribed Fire 4b, 5c 3 64-99 Cultural Vegetation, 

Pacific giant salamander 81

2276 Manual & Prescribed Fire 4a, 5c 4 91-99 Cultural Vegetation 86

2277 Manual & Prescribed Fire 4a, 5c 3 96-99 Cultural Vegetation 87

2278 Manual & Prescribed Fire 4a, 5c 5 41-98 Cultural Vegetation 61

2279 Manual & Prescribed Fire 4a, 5c 4 75-99 Cultural Vegetation, 

Pacific giant salamander 83
Chapter 2. The Alternatives

62 – Somes Bar Integrated Fire Management Project

Unit ID Treatment Category Prescriptions Acres

Pre-Treatment 

Canopy Cover 

(%)

TEK Resource

Post-Treatment 

Canopy Cover 

(%)

2280 Manual & Prescribed Fire 4b, 5c 3 73-99 Cultural Vegetation 82

2281 Manual & Prescribed Fire 4b, 5c 4 78-98 Elk, Cultural Vegetation 79

2282 Manual & Prescribed Fire 4b, 5c 4 84-99 Elk, Cultural Vegetation, 

Pacific giant salamander 84

2283 Manual & Prescribed Fire 4b, 5c 3 88-99 Elk, Cultural Vegetation 86

2284 Manual & Prescribed Fire 4b, 5c 17 46-98 Elk, Cultural Vegetation, 

Pacific giant salamander 66

2285 Manual & Prescribed Fire 4b, 5c 6 20-99 Elk, Cultural Vegetation, 

Pacific giant salamander 67

2286 Manual & Prescribed Fire 4b, 5c 7 94-99 Cultural Vegetation, 

Pacific giant salamander 87

2287 Manual & Prescribed Fire 4a, 5c 5 69-99 Elk, Cultural Vegetation 81

2288 Manual & Prescribed Fire 4b, 5c 12 62-99

Elk, NSO, Pacific fisher, 

Trees of Interest, Cultural 

Vegetation, Pacific giant 

salamander

78

2289 Manual & Prescribed Fire 4b, 5c 2 93-99 Elk, Trees of Interest, 

Cultural Vegetation 87

2290 Manual & Prescribed Fire 4b, 5c 20 85-100

Elk, NSO, Cultural 

Vegetation, Pacific giant 

salamander

85

2291 Manual & Prescribed Fire 4b, 5c 10 88-99

Trees of Interest, NSO,

Cultural Vegetation, 

Pacific giant salamander

86

2292 Manual & Prescribed Fire 4b, 5c 2 83-99 Cultural Vegetation, 

Pacific giant salamander 84

2293 Manual & Prescribed Fire 4b, 5c 13 57-99

Elk, Trees of Interest, 

Cultural Vegetation, 

Pacific giant salamander

75

2294 Manual & Prescribed Fire 4b, 5c 5 71-98 Elk, Trees of Interest, 

Cultural Vegetation 79

2295 Manual & Prescribed Fire 4a, 5c 4 93-99 Cultural Vegetation 86

2300 Manual & Prescribed Fire 4b, 5c 61 84-99 Elk, Cultural Vegetation 84

2301 Manual & Prescribed Fire 4a, 5c 15 66-99 Cultural Vegetation, 

Pacific giant salamander 77

2302 Manual & Prescribed Fire 4a, 5c 4 51-99 Cultural Vegetation 76

2303 Manual & Prescribed Fire 4b, 5c 36 87-99 Cultural Vegetation, NSO 86

2305 Manual & Prescribed Fire 4a, 5c 5 92-99 Cultural Vegetation 87

2307 Manual & Prescribed Fire 4a, 5c 11 76-99 Cultural Vegetation, 

Pacific giant salamander 83

2308 Manual & Prescribed Fire 4a, 5c 22 73-99 Cultural Vegetation, 

Pacific giant salamander 83

2309 Manual & Prescribed Fire 4a, 5c 14 68-99 Cultural Vegetation, 

Pacific giant salamander 80

2311 Manual & Prescribed Fire 4b, 5c 11 75-99 Cultural Vegetation 82

2312 Manual & Prescribed Fire 4b, 5c 6 84-99 Cultural Vegetation, NSO 83

2313 Manual & Prescribed Fire 4a, 5c 5 71-99 Cultural Vegetation 82

2314 Manual & Prescribed Fire 4b, 5c 40 55-99

Cultural Vegetation, 

NSO, Pacific giant 

salamander

77

2316 Manual & Prescribed Fire 4b, 5c 4 40-95 Cultural Vegetation 67

2318 Manual & Prescribed Fire 4a, 5c 7 35-98 Cultural Vegetation, 

Pacific giant salamander 64

2319 Manual & Prescribed Fire 4a, 5c 18 68-99 Cultural Vegetation, 

Pacific giant salamander 79
Chapter 2. The Alternatives

Final Environmental Assessment – 63

Unit ID Treatment Category Prescriptions Acres

Pre-Treatment 

Canopy Cover 

(%)

TEK Resource

Post-Treatment 

Canopy Cover 

(%)

2322 Manual & Prescribed Fire 4b, 5c 33 70-99

Elk, NSO, Pacific fisher, 

Trees of Interest, Cultural 

Vegetation, Pacific giant 

salamander

82

2323 Manual & Prescribed Fire 4b, 5c 47 78-99

Elk, NSO, Cultural 

Vegetation, Pacific giant

salamander

85

2325 Manual & Prescribed Fire 4b, 5c 15 77-99

Cultural Vegetation, 

NSO, Pacific giant 

salamander

85

2326 Manual & Prescribed Fire 4a, 5c 14 93-99 Cultural Vegetation 87

2327 Manual & Prescribed Fire 4a, 5c 5 75-99 Cultural Vegetation 80

2329 Manual & Prescribed Fire 4b, 5c 14 84-99 Trees of Interest, Cultural 

Vegetation 85

2330 Manual & Prescribed Fire 4b, 5c 10 92-99

Pacific fisher, Trees of 

Interest, Cultural 

Vegetation

86

2331 Manual & Prescribed Fire 4a, 5c 6 77-100 Elk, Cultural Vegetation, 

Pacific giant salamander 82

2332 Manual & Prescribed Fire 4a, 5c 6 94-99 Cultural Vegetation 87

2333 Manual & Prescribed Fire 4b, 5c 26 92-99 Elk, Cultural Vegetation, 

Pacific giant salamander 87

2334 Manual & Prescribed Fire 4b, 5c 12 78-99 Elk, NSO, Cultural 

Vegetation 83

2335 Manual & Prescribed Fire 4b, 5c 30 74-99 Elk, Cultural Vegetation 81

2343 Manual & Prescribed Fire 4b, 5c 19 91-99

Cultural Vegetation, 

NSO, Pacific giant 

salamander

86

2345 Manual & Prescribed Fire 4b, 5c 3 87-99 Trees of Interest, Cultural 

Vegetation 86

2346 Manual & Prescribed Fire 4a, 5c 16 88-99 Cultural Vegetation 86

2347 Manual & Prescribed Fire 4a, 5c 2 95-99 Cultural Vegetation 88

2348 Manual & Prescribed Fire 4b, 5c 17 78-99 Elk, NSO, Cultural 

Vegetation 84

2351 Manual & Prescribed Fire 4a, 5c 2 47-90 Cultural Vegetation 60

2352 Manual & Prescribed Fire 4a, 5c 10 0-97 Cultural Vegetation 60

2354 Manual & Prescribed Fire 4b, 5c 20 59-99

Elk, NSO, Pacific fisher, 

Cultural Vegetation, 

Pacific giant salamander

82

2355 Manual & Prescribed Fire 4b, 5c 7 42-99 Cultural Vegetation 72

2356 Manual & Prescribed Fire 4b, 5c 38 63-99

Pacific fisher, NSO,

Cultural Vegetation, 

Pacific giant salamander

82

2357 Manual & Prescribed Fire 4b, 5c 30 41-99 Cultural Vegetation, 

Pacific giant salamander 75

2358 Manual & Prescribed Fire 4b, 5c 25 85-99 Cultural Vegetation, 

Pacific giant salamander 84

2359 Manual & Prescribed Fire 4b, 5c 6 0-16

Willow, Cultural 

Vegetation, Pacific giant 

salamander

15

2360 Manual & Prescribed Fire 4a, 5c 7 58-99 Cultural Vegetation 73

2361 Manual & Prescribed Fire 4b, 5c 21 80-99

Cultural Vegetation, 

NSO, Pacific giant 

salamander

83

2403 Manual & Prescribed Fire 4b, 5c 9 84-99 Cultural Vegetation, 

Pacific giant salamander 85
Chapter 2. The Alternatives

64 – Somes Bar Integrated Fire Management Project

Unit ID Treatment Category Prescriptions Acres

Pre-Treatment 

Canopy Cover 

(%)

TEK Resource

Post-Treatment 

Canopy Cover 

(%)

2406 Manual & Prescribed Fire 4b, 5c 13 81-99

Elk, NSO, Cultural 

Vegetation, Pacific giant 

salamander

83

2408 Manual & Prescribed Fire 4a, 5c 4 67-98 Cultural Vegetation, 

Pacific giant salamander 76

2410 Manual & Prescribed Fire 4b, 5c 9 87-99

Cultural Vegetation, 

NSO, Pacific giant 

salamander

86

2415 Manual & Prescribed Fire 4a, 5c 11 80-98 Cultural Vegetation, 

Pacific giant salamander 80

2416 Manual & Prescribed Fire 4b, 5c 6 56-97 Cultural Vegetation 74

2417 Manual & Prescribed Fire 4b, 5c 29 78-99

Cultural Vegetation,

NSO, Pacific giant 

salamander

83

2418 Manual & Prescribed Fire 4b, 5c 9 79-99 NSO, Cultural Vegetation 83

2420 Manual & Prescribed Fire 4a, 5c 7 89-99 Elk, Cultural Vegetation 86

2424 Manual & Prescribed Fire 4b, 5c 2 75-99 Cultural Vegetation 82

2429 Manual & Prescribed Fire 4a, 5c 1 88-97 Cultural Vegetation 84

2430 Manual & Prescribed Fire 4b, 5c 17 84-99

Trees of Interest, NSO, 

Cultural Vegetation, 

Pacific giant salamander

84

2432 Manual & Prescribed Fire 4b, 5c 13 86-99

Cultural Vegetation,

NSO, Pacific giant 

salamander

85

2435 Manual & Prescribed Fire 4b, 5c 13 86-99

Cultural Vegetation, 

NSO, Pacific giant 

salamander

84

2436 Manual & Prescribed Fire 4b, 5c 5 87-99 Elk, Cultural Vegetation 84

2437 Manual & Prescribed Fire 4a, 5c 12 83-99 Cultural Vegetation 86

2438 Manual & Prescribed Fire 4b, 5c 3 57-96 Cultural Vegetation 68

2439 Manual & Prescribed Fire 4b, 5c 20 86-99 Cultural Vegetation 85

2440 Manual & Prescribed Fire 4b, 5c 22 90-99

Elk, NSO, Cultural 

Vegetation, Pacific giant 

salamander

86

2448 Manual & Prescribed Fire 4b, 5c 16 66-99

Cultural Vegetation, 

NSO, Pacific giant 

salamander

81

2449 Manual & Prescribed Fire 4b, 5c 5 74-99 Cultural Vegetation 81

2450 Manual & Prescribed Fire 4b, 5c 5 80-99 Cultural Vegetation 81

2451 Manual & Prescribed Fire 4b, 5c 2 96-99 Elk, Cultural Vegetation 87

2455 Manual & Prescribed Fire 4b, 5c 6 78-99 Cultural Vegetation 83

2458 Manual & Prescribed Fire 4b, 5c 11 71-99

Cultural Vegetation,

NSO, Pacific giant 

salamander

82

2459 Manual & Prescribed Fire 4a, 5c 20 72-99 Cultural Vegetation 79

2464 Manual & Prescribed Fire 4a, 5c 16 73-99 Elk, Cultural Vegetation 81

2468 Manual & Prescribed Fire 4b, 5c 5 85-99 Cultural Vegetation 85

2469 Manual & Prescribed Fire 4a, 5c 16 82-99 Cultural Vegetation, 

Pacific giant salamander 83

2471 Manual & Prescribed Fire 4b, 5c 5 75-99 Cultural Vegetation, 

Pacific giant salamander 81

2472 Manual & Prescribed Fire 4a, 5c 26 70-99 Cultural Vegetation, 

Pacific giant salamander 79

2473 Manual & Prescribed Fire 4b, 5c 8 78-99 Cultural Vegetation, 

Pacific giant salamander 83
Chapter 2. The Alternatives

Final Environmental Assessment – 65

Unit ID Treatment Category Prescriptions Acres

Pre-Treatment 

Canopy Cover 

(%)

TEK Resource

Post-Treatment 

Canopy Cover 

(%)

2476 Manual & Prescribed Fire 4a, 5c 4 79-98 Cultural Vegetation 83

2478 Manual & Prescribed Fire 4a, 5c 7 76-99 Cultural Vegetation, 

Pacific giant salamander 82

2479 Manual & Prescribed Fire 4b, 5c 31 85-99 Elk, NSO, Cultural 

Vegetation 83

2482 Manual & Prescribed Fire 4a, 5c 3 77-98 Cultural Vegetation 81

2483 Manual & Prescribed Fire 4b, 5c 3 90-99 Cultural Vegetation, 

Pacific giant salamander 86

2485 Manual & Prescribed Fire 4b, 5c 10 80-99

Elk, NSO, Cultural 

Vegetation, Pacific giant 

salamander

83

2488 Manual & Prescribed Fire 4a, 5c 7 64-99 Cultural Vegetation 78

2491 Manual & Prescribed Fire 4b, 5c 9 83-98 Elk, Cultural Vegetation 82

2495 Manual & Prescribed Fire 4b, 5c 17 83-99 NSO, Cultural Vegetation 85

2496 Manual & Prescribed Fire 4b, 5c 15 84-99

NSO, Cultural 

Vegetation, Pacific giant 

salamander

84

2497 Manual & Prescribed Fire 4b, 5c 3 90-99 Cultural Vegetation, 

Pacific giant salamander 86

2498 Manual & Prescribed Fire 4b, 5c 11 31-99 Cultural Vegetation, 

Pacific giant salamander 68

2499 Manual & Prescribed Fire 4b, 5c 19 67-99 NSO, Cultural Vegetation 81

2501 Manual & Prescribed Fire 4a, 5c 5 89-99 Cultural Vegetation 86

2502 Manual & Prescribed Fire 4a, 5c 13 76-99 Cultural Vegetation, 

Pacific giant salamander 83

2503 Manual & Prescribed Fire 4a, 5c 7 53-99 Cultural Vegetation 75

2504 Manual & Prescribed Fire 4a, 5c 4 66-99 Cultural Vegetation 80

2509 Manual & Prescribed Fire 4b, 5c 46 71-99

NSO, Trees of Interest, 

Cultural Vegetation, 

Pacific giant salamander

81

2510 Manual & Prescribed Fire 4b, 5c 15 78-99

NSO, Cultural 

Vegetation, Pacific giant 

salamander

84

2130 Mastication & Prescribed Fire 3, 4c, 5d 7 62-99 Elk, Cultural Vegetation 50

2212 Mastication & Prescribed Fire 3, 4c, 5d 14 86-100 Elk, Cultural Vegetation 84

2214 Mastication & Prescribed Fire 3, 4c, 5d 5 67-96 Elk, Cultural Vegetation 50

2229 Mastication & Prescribed Fire 3, 4c, 5d 12 80-99 Elk, Cultural Vegetation, 

Pacific giant salamander 50

2240 Mastication & Prescribed Fire 3, 4c, 5d 30 38-99 Cultural Vegetation, 

Pacific giant salamander 50

2413 Mastication & Prescribed Fire 3, 4c, 5d 6 90-99 Cultural Vegetation 50

2427 Mastication & Prescribed Fire 3, 4c, 5d 22 74-99 Elk, Cultural Vegetation 60

2428 Mastication & Prescribed Fire 3, 4c, 5d 3 87-99 Cultural Vegetation 50

2441 Mastication & Prescribed Fire 3, 4c, 5d 9 73-99 Elk, Cultural Vegetation 50

2457 Mastication & Prescribed Fire 3, 4c, 5d 7 85-99 Elk, Cultural Vegetation 50

2477 Mastication & Prescribed Fire 3, 4c, 5d 3 46-99 Cultural Vegetation 50

2484 Mastication & Prescribed Fire 3, 4c, 5d 9 82-98 Elk, Cultural Vegetation 50

2486 Mastication & Prescribed Fire 3, 4c, 5d 30 58-99 Elk, Cultural Vegetation 50

2487 Mastication & Prescribed Fire 3, 4c, 5d 7 74-99 Elk, Cultural Vegetation 50

2489 Mastication & Prescribed Fire 3, 4c, 5d 7 63-99 Cultural Vegetation 50

2490 Mastication & Prescribed Fire 3, 4c, 5d 15 85-99 Elk, Cultural Vegetation 50
Chapter 2. The Alternatives

66 – Somes Bar Integrated Fire Management Project

Unit ID Treatment Category Prescriptions Acres

Pre-Treatment 

Canopy Cover 

(%)

TEK Resource

Post-Treatment 

Canopy Cover 

(%)

2144 Prescribed Fire Only 5a 73 84-99

Elk, NSO, Cultural 

Vegetation, Pacific giant 

salamander

84

2201 Prescribed Fire Only 5a 12 87-99 Cultural Vegetation, 

Pacific giant salamander 86

2204 Prescribed Fire Only 5a 20 75-99

Cultural Vegetation, 

NSO, Pacific giant 

salamander

83

2205 Prescribed Fire Only 5a 15 89-99

Elk, NSO, Pacific fisher, 

Cultural Vegetation, 

Pacific giant salamander

86

2208 Prescribed Fire Only 5a 59 82-99

Cultural Vegetation, 

NSO, Pacific giant 

salamander

85

2209 Prescribed Fire Only 5a 31 84-99

Cultural Vegetation,

NSO, Pacific giant 

salamander

85

2215 Prescribed Fire Only 5a 11 88-99 Elk, Cultural Vegetation, 

Pacific giant salamander 86

2232 Prescribed Fire Only 5a 4 87-99 Cultural Vegetation 85

2234 Prescribed Fire Only 5a 7 68-99 Cultural Vegetation, 

Pacific giant salamander 81

2238 Prescribed Fire Only 5a 4 89-99 Cultural Vegetation 85

2268 Prescribed Fire Only 5a 362 61-99

Pacific fisher, NSO, 

Cultural Vegetation, 

Pacific giant salamander

79

2269 Prescribed Fire Only 5a 18 45-99 Cultural Vegetation, 

Pacific giant salamander 74

2270 Prescribed Fire Only 5a 13 0-99 Cultural Vegetation, 

Pacific giant salamander 31

2296 Prescribed Fire Only 5a 6 68-99 Cultural Vegetation 81

2304 Prescribed Fire Only 5a 28 96-99 Cultural Vegetation 88

2306 Prescribed Fire Only 5a 19 96-99 Cultural Vegetation, 

Pacific giant salamander 88

2310 Prescribed Fire Only 5a 25 30-99 Cultural Vegetation 60

2315 Prescribed Fire Only 5a 16 53-99

Cultural Vegetation, 

NSO, Pacific giant 

salamander

76

2317 Prescribed Fire Only 5a 15 71-99 Cultural Vegetation, 

Pacific giant salamander 78

2324 Prescribed Fire Only 5a 19 0-98 Cultural Vegetation, 

Pacific giant salamander 27

2337 Prescribed Fire Only 5a 10 1-99 Cultural Vegetation 51

2338 Prescribed Fire Only 5a 31 87-99 Elk, NSO, Cultural

Vegetation 86

2339 Prescribed Fire Only 5a 172 80-99 NSO, Cultural Vegetation 85

2340 Prescribed Fire Only 5a 129 64-99 Elk, NSO, Cultural 

Vegetation 77

2341 Prescribed Fire Only 5a 30 95-99 Elk, NSO, Cultural 

Vegetation 87

2342 Prescribed Fire Only 5a 72 84-99 NSO, Cultural Vegetation 85

2344 Prescribed Fire Only 5a 19 96-99 Cultural Vegetation 88

2349 Prescribed Fire Only 5a 2 81-99 Cultural Vegetation 85

2350 Prescribed Fire Only 5a 3 66-99 Cultural Vegetation 81

2353 Prescribed Fire Only 5a 9 90-99 NSO, Cultural Vegetation 85
Chapter 2. The Alternatives

Final Environmental Assessment – 67

Unit ID Treatment Category Prescriptions Acres

Pre-Treatment 

Canopy Cover 

(%)

TEK Resource

Post-Treatment 

Canopy Cover 

(%)

2443 Prescribed Fire Only 5a 161 90-99

NSO, Pacific fisher, 

Cultural Vegetation, 

Pacific giant salamander

86

2444 Prescribed Fire Only 5a 3 77-98 Cultural Vegetation, 

Pacific giant salamander 82

2445 Prescribed Fire Only 5a 2 79-99 Cultural Vegetation, 

Pacific giant salamander 84

2446 Prescribed Fire Only 5a 51 83-99

NSO, Cultural 

Vegetation, Pacific giant 

salamander

84

2447 Prescribed Fire Only 5a 11 73-98 Cultural Vegetation, 

Pacific giant salamander 78

2506 Prescribed Fire Only 5a 18 81-99 Cultural Vegetation, 

Pacific giant salamander 83

2507 Prescribed Fire Only 5a 9 85-99 Cultural Vegetation, 

Pacific giant salamander 86

Connected Actions

The following section presents those actions required to access and implement the proposed treatments 

safely and efficiently.

Temporary Roads

Mechanically treated areas where a commercial by-product is anticipated require the use of temporary

roads to facilitate logging and hauling operations. New temporary roads were considered where no 

existing roads and roads are not in the right location. Their locations would be restricted to areas where 

the impact of creating new temporary roads is minor and rehabilitation techniques would effectively 

eliminate the effects of a new linear feature on the landscape. For example, a new temporary road that 

requires minimal clearing and has no stream crossings would be a scenario where this action was

considered. All temporary roads would be winterized and closed to vehicle traffic every rainy season. 

Post project implementation would require that all temporary roads be left in a free draining condition, 

free of berms or obstacles that would concentrate water on the roadbed during storm events. Drainage 

structures would be removed and associated fill stored at stable locations on the roadbed. Roadbeds would 

be decompacted to improve infiltration where necessary. Disturbed areas would be mulched with native 

material found on site and may be seeded with native grasses. All temporary roads listed in Table 2-8

would be blocked to eliminate motor-vehicle access.

Table 2-8. Temporary roads necessary for project implementation.

ID Mileage Treatment Unit Status Treatment Method

7101 0.22 2105 Existing Mechanical

7102 0.16 2112, 2113 Existing Mechanical

7103 0.02 2112 Existing Mechanical

7104 0.03 2110 Existing Mechanical

7105 0.15 2116, 2117 Existing Mechanical

7106 0.03 2117 Existing Mechanical

7109 0.04 2213 Existing Mechanical

7111 0.44 2127, 2129, 2128, 2130, 2132, 2151, 2154 Existing Mechanical
Chapter 2. The Alternatives

68 – Somes Bar Integrated Fire Management Project

ID Mileage Treatment Unit Status Treatment Method

7112 0.07 2101, 2105 New Mechanical

7113 0.12 2131, 2132 Existing Mechanical

7115 0.04 2119 Existing Mechanical

7116 0.33 2127, 2128, 2154 New Mechanical

7117 0.06 2116 Existing Mechanical

7119 0.32 2127 Existing Mastication

7201 0.22 2235, 2237 Existing Mechanical

7202 0.66 2215, 2217, 2218, 2219, 2242, 2265 Existing Mechanical

7203 0.08 2265 Existing Mechanical

7204 0.02 2264 Existing Mechanical

7206 0.13 2225 Existing Mechanical

7207 0.15 2230 Existing Mechanical

7208 0.15 2227, 2281 New Mechanical

7209 0.14 2217, 2218 Existing Mechanical

7210 0.07 2242 Existing Mechanical

7211 0.07 2263, 2264, 2268 Existing Mechanical

7212 0.11 2221 Existing Mechanical

7213 0.03 2242 Existing Mechanical

7214 0.23 2206 Existing Mechanical

7215 0.03 2266 Existing Mechanical

7216 0.09 2265 Existing Mechanical

7217 0.25 2265, 2266, 2294, 2283 Existing Mechanical

7218 0.04 2249 Existing Mechanical

7219 0.03 2203 Existing Mechanical

7220 0.69 2201, 2201, 2229, 2212, 2214, 2228, 2229 Existing Mastication

7221 0.27 2240 Existing Mastication

7222 0.05 2200 New Mechanical

7300 0.03 2328 Existing Mechanical

7401 0.33 2461 Existing Mechanical

7402 0.16 2481 Existing Mechanical

7403 0.12 2481, 2490 Existing Mechanical

7404 0.08 2481 Existing Mechanical

7405 0.28 2461, 2500, 2461 Existing Mechanical

7406 0.21 2493 Existing Mechanical

7407 0.23 2481, 2486 Existing Mechanical

7408 0.10 2467, 2492 Existing Mechanical

7409 1.03 2400, 2443, 2500, 2439, 2500 Existing Mechanical

7410 0.14 2418, 2419 Existing Mechanical

7411 0.11 2411 Existing Mechanical

7412 0.14 2412, 2413 Existing Mechanical

7413 0.10 2411, 2407 Existing Mechanical

7414 0.10 2407 Existing Mechanical

7415 0.26 2409, 2411 Existing Mechanical

7416 0.37 2407, 2409, 2455 Existing Mechanical

7418 0.04 2402 Existing Mechanical

7419 0.10 2400, 2439, 2453 Existing Mechanical

7420 0.09 2400, 2454 Existing Mechanical

7421 0.15 2426, 2505 Existing Mechanical

7423 0.04 2465, 2466 Existing Mechanical

7425 0.07 2500 Existing Mechanical

7426 0.14 2400, 2433, 2453 Existing Mechanical

7427 0.02 2470 Existing Mechanical
Chapter 2. The Alternatives

Final Environmental Assessment – 69

ID Mileage Treatment Unit Status Treatment Method

7432 0.12 2489, 2490 Existing Mastication

7433 0.25 2481, 2490 Existing Mastication

7434 0.19 2403, 2427, 2428, 2441, 2472 Existing Mastication

7435 0.14 2427 Existing Mastication

7436 0.13 2418, 2457 Existing Mastication

7437 0.07 2457 Existing Mastication

7438 0.07 2484 Existing Mastication

7439 0.05 2403, 2427, 2428, 2441, 2472 Existing Mastication

Total Mileage 11.0

Table 2-9 displays log landings available for expediting timber harvest operations.

Table 2-9. Log landings available for expediting timber harvest operations.

Landing ID Acres Status Landing ID Acres Status Landing ID Acres Status

4101 0.50 Existing 4256 0.33 Existing 4440 0.50 Existing

4102 0.50 Existing 4257 0.25 Existing 4441 0.33 Existing

4103 0.50 Existing 4258 0.25 Existing 4442 0.50 Existing

4104 0.50 Existing 4259 0.25 Existing 4443 0.25 Existing

4105 0.50 Existing 4260 0.50 Existing 4444 0.25 Existing

4106 0.50 Existing 4261 0.50 Existing 4445 0.50 Existing

4107 0.33 Existing 4263 0.25 Existing 4446 0.50 Existing

4108 0.50 Existing 4264 0.25 Existing 4447 0.50 Existing

4109 0.50 Existing 4265 0.50 Existing 4448 0.50 Existing

4110 0.50 Existing 4266 0.25 Existing 4449 0.50 Existing

4111 0.50 Existing 4267 0.25 Existing 4450 0.50 Existing

4112 0.50 Existing 4269 0.50 Existing 4451 0.50 Existing

4116 0.75 Existing 4270 0.50 Existing 4453 0.50 Existing

4118 0.50 Existing 4301 0.25 Existing 4454 0.50 Existing

4123 0.50 Existing 4302 0.25 Existing 4457 0.75 Existing

4125 0.75 Existing 4310 0.50 Existing 4458 0.50 Existing

4127 0.25 Existing 4311 0.25 Existing 4459 0.50 Existing

4128 0.25 Existing 4312 0.25 Existing 4460 0.75 Existing

4129 0.50 Existing 4401 0.50 Existing 4461 0.50 Existing

4130 0.50 Existing 4403 0.75 Existing 4467 0.50 Existing

4132 0.33 Existing 4404 0.50 Existing 4468 0.50 Existing

4137 0.25 Existing 4405 0.33 Existing 4471 0.50 Existing

4143 0.5 Existing 4406 0.50 Existing 4472 0.75 Existing

4144 0.75 Existing 4408 0.50 Existing 4119 0.50 New

4201 1.00 Existing 4409 0.50 Existing 4134 0.33 New

4202 0.50 Existing 4410 0.50 Existing 4135 0.33 New

4203 0.50 Existing 4411 0.50 Existing 4136 0.50 New

4204 0.50 Existing 4412 0.50 Existing 4138 0.33 New

4205 0.25 Existing 4413 0.75 Existing 4140 0.75 New

4206 0.50 Existing 4414 0.33 Existing 4141 0.75 New

4208 0.75 Existing 4415 0.50 Existing 4142 0.75 New

4209 0.50 Existing 4416 0.50 Existing 4145 0.25 New

4210 0.50 Existing 4417 0.50 Existing 4146 0.50 New

4211 0.50 Existing 4418 0.50 Existing 4207 0.75 New

4212 0.75 Existing 4419 0.50 Existing 4237 0.50 New

4213 0.75 Existing 4421 0.50 Existing 4242 0.25 New

4214 0.50 Existing 4422 0.50 Existing 4243 0.25 New
Chapter 2. The Alternatives

70 – Somes Bar Integrated Fire Management Project

Landing ID Acres Status Landing ID Acres Status Landing ID Acres Status

4215 0.5 Existing 4423 0.50 Existing 4244 0.33 New

4216 0.75 Existing 4424 0.50 Existing 4245 0.50 New

4217 0.50 Existing 4425 0.50 Existing 4246 0.50 New

4218 0.50 Existing 4426 0.50 Existing 4255 0.33 New

4219 0.50 Existing 4427 0.50 Existing 4271 0.50 New

4220 0.50 Existing 4428 0.75 Existing 4308 0.25 New

4223 0.50 Existing 4429 0.50 Existing 4309 0.25 New

4229 0.50 Existing 4430 0.50 Existing 4420 0.50 New

4230 0.50 Existing 4431 0.50 Existing 4462 0.33 New

4239 0.75 Existing 4432 0.50 Existing 4466 0.33 New

4240 0.25 Existing 4433 0.50 Existing 4469 0.25 New

4241 0.33 Existing 4435 0.50 Existing 4470 0.50 New

4249 0.50 Existing 4436 0.75 Existing 4474 0.33 New

4250 0.75 Existing 4437 0.75 Existing 4475 0.33 New

4251 0.33 Existing 4438 0.50 Existing 4476 0.33 New

4252 0.33 Existing 4439 0.75 Existing 4477 0.33 New

Maintenance Level 1 System Road Use

Maintenance Level (ML) 1 roads to be used during the normal operating period (dry season) are listed in 

Table 2-10. The ML 1 designation indicates a road that is closed to motor-vehicle traffic and is placed in 

“storage” until needed. These roads would be brought up to ML 2 standards when needed to facilitate 

access to treatment units. Bringing an ML 1 road up to ML 2 standards often requires some site-specific

travelway reconditioning using heavy equipment (e.g., graders, excavators, and dump trucks). Road 

13N14A needs a new culvert installed and placed in clean rock fill. The travelway on 13N14E and 

13N14A has accumulated dirt and debris that will be removed and stored at designated locations. All 

roads would be brushed (using hand-held equipment) to improve visibility and travelways cleared of 

debris and vegetation.

Once brought up to ML 2 standards, these roads would receive routine road maintenance to facilitate 

access for equipment and workers for the life of the project in alignment with the Six Rivers Road 

Maintenance Project, authorized in January 2016. Incorporated by reference, all previously authorized 

road maintenance design and mitigation measures would apply. These roads would be closed annually to 

vehicle traffic during the wet weather season.

Table 2-10. Maintenance Level 1 (ML 1) system road use.

ID Mileage ID Mileage

13N12A 0.9 13N14E 0.5

13N14A 1.2 13N18A 0.3

13N14C 0.2 13N18E 0.5

13N14D 0.5 14N15 0.5

Legacy Road Sediment Source Treatments

Restoration actions would occur at existing legacy sediment source sites, scheduled for treatment in 

compliance with the Clean Water Act as a condition of the North Coast Regional Water Quality Control 

Board waiver of waste discharge requirements (Order No. R1-2015-0021). No legacy sites are found 
Chapter 2. The Alternatives

Final Environmental Assessment – 71

adjacent to anadromous salmonid habitat or resident trout habitat. There are six (6) segments, totaling 1.1 

miles of legacy roads found in the project area (Table 2-11) and include the following actions:

• Excavated road fill would be stored on site and in stable locations;

• Construct waterbar drainage features to prevent water from concentrating on the roadbed;

• Cover disturbed ground with native material gathered on sites (tree boughs);

• Install earthen log barrier at locations to effectively block motor-vehicle access; and

• Develop appropriate erosion control plans and incorporate best management practices (BMPs)

into project plans prior to all ground-disturbing work that would occur during the dry season.

Table 2-11. Legacy road sediment source treatments.

Route ID Miles Route ID Miles

9400 0.09 9103 0.19

9100 0.35 9402 0.11

9101 0.13 Total 1.09

9102 0.22

Strategic Fuelbreaks and Handlines

Strategic fuelbreaks and primary handlines have been identified and would be constructed under minimal 

impact guidelines following a path of least resistance. Where feasible, natural features, such as ridges, 

rock screes, riparian areas, game trails, and vegetation breaks will be utilized. Only small-diameter trees 

(6 to 8 inches) would be cut during handline installation. A general description of the fuelbreak activity 

would be a 100-foot-chainsaw brushing cut supported by a 2-foot-wide handline cut down to bare mineral 

soil. For handlines, a 6-foot-chainsaw brushing cut supported by a 2-foot-wide handline cut down to bare 

mineral soil. Waterbars would be added as needed to reduce concentration of water. Refer to Figure 2-15, 

Figure 2-17, Figure 2-19 and Figure 2-21 for approximate locations of fuelbreaks and handlines.

Hazards Trees

Incidental felling would only occur in the event they pose an immediate safety risk to firefighters or a 

containment risk during implementation. Hazards trees posing a risk to loggers or operations would also 

be felled. Felled hazard trees may be reserved for use for fisheries restoration, decked and stored, left on 

site, or sold.

Fireline Maintenance

The 1987 dozer line in Ti Bar, reused during the Ukonom Fire in 2017, is an example of an existing 

fireline that serves as an important strategic fireline for private land dwellings in the vicinity. This fireline 

would be maintained for multiple entries and as more of a “true fuelbreak” where most of the shrubs and 

small-diameter trees are thinned while preserving the larger trees to provide some shade/canopy cover. 

Handlines will be constructed with waterbars and left in a free-draining condition.
Chapter 2. The Alternatives

72 – Somes Bar Integrated Fire Management Project

Figure 2-15. Donahue project area proposed action.
Chapter 2. The Alternatives

Final Environmental Assessment – 73

Figure 2-16. Donahue project area connected actions.
Chapter 2. The Alternatives

74 – Somes Bar Integrated Fire Management Project

Figure 2-17. Patterson project area proposed action.
Chapter 2. The Alternatives

Final Environmental Assessment – 75

Figure 2-18. Patterson project area connected actions.
Chapter 2. The Alternatives

76 – Somes Bar Integrated Fire Management Project

Figure 2-19. Rogers Creek project area proposed action.
Chapter 2. The Alternatives

Final Environmental Assessment – 77

Figure 2-20. Rogers Creek project area connected actions.
Chapter 2. The Alternatives

78 – Somes Bar Integrated Fire Management Project

Figure 2-21. Ti Bar project area proposed action.
Chapter 2. The Alternatives

Final Environmental Assessment – 79

Figure 2-22. Ti Bar project area connected actions.
Chapter 2. The Alternatives

80 – Somes Bar Integrated Fire Management Project

Project Design Features and Mitigation Measures

All activities would incorporate design features aimed at minimizing the potential for adverse effects to 

existing aquatic, semi-aquatic and associated terrestrial organisms and their environments. All applicable 

USFS National BMPs would be implemented for land disturbing activities that may impact water quality 

(Appendix D). Implementing these types of improvements may require the use of heavy equipment (e.g., 

self-propelled yarders, mechanical excavators, backhoes); however, hand labor would be used to 

accomplish manual restoration activities whenever safe and practical.

Landowner Notifications

• Keep landowners informed of the approximate timeline when implementation is planned to occur 

adjacent to private property. Contact landowners, in writing or other agreed to forms of 

communication, at least two (2) weeks prior to when activities are planned. Post tentative schedules 

on the forest’s Facebook page, at local stores and post offices.

• Measures when working adjacent to private property:

All water lines and storage tanks, fences, gates and other private land facilities would be fully 

protected during implementing the proposed actions. Low-lying structures, such as water lines 

that are difficult to see, would be flagged on the ground to ensure handpiles or equipment use 

would not disturb infrastructure. Flammable property would be protected by leaving adequate 

space between burn piles and facilities when working in the private and public land interface 

area. Table 2-12 displays treatment units with known water lines and associated infrastructure.

Portions of Unit 2250 that fall within the 300-foot private and public land interface boundary 

would limit prescribed fire treatments only to handpile construction and handpile burning.

Table 2-12. Units with known water-source infrastructure.

Project Area Initial Entry Method Unit Project Area Initial Entry Method Unit

Donahue Manual 2406 Patterson Mechanical 2228

Donahue Mastication 2427 Patterson Prescribed Fire 2204

Donahue Mastication 2428 Patterson Prescribed Fire 2208

Donahue Mastication 2441 Rogers Creek Manual 2357

Donahue Mechanical 2474 Rogers Creek Prescribed Fire 2337

Patterson Manual 2223 Ti Bar Manual 2108

Patterson Manual 2246 Ti Bar Manual 2118

Patterson Manual 2250 Ti Bar Manual 2122

Patterson Manual 2252 Ti Bar Manual 2143

Patterson Manual 2281 Ti Bar Manual 2146

Patterson Manual 2290 Ti Bar Manual 2152

Patterson Mastication 2240 Ti Bar Manual 2153

Patterson Mechanical 2224 Ti Bar Manual 2156

Patterson Mechanical 2226 Ti Bar Manual 2166

Patterson Mechanical 2227 Ti Bar Manual 2168

Patterson Mechanical 2230 Ti Bar Mechanical 2110

Patterson Mechanical 2248 Ti Bar Mechanical 2113

Patterson Mechanical 2249 Ti Bar Mechanical 2114
Chapter 2. The Alternatives

Final Environmental Assessment – 81

Protect private property with boundary signs, corners, and tree blazes with ribbon flagging 

where needed to insure the delineation between private and public land is clear and obvious. 

Do this no more than two (2) weeks prior to implementation.

Cultural Resources

General – All Treatments

• All sites will be marked on the ground prior to implementation.

• All work within site boundaries shall be monitored by a Forest Service archaeologist or tribal monitor 

to ensure that the work is culturally desirable (i.e., for restoration purposes) and to ensure that ground 

disturbance is minimized and that features and artifacts are protected.

• All treatments within site boundaries will adhere to On-Site Historic Property Protection Measures as 

stipulated in the Region 5 Programmatic Agreement (R5 PA).

• In the event that cultural resources are discovered during implementation, all work in the area shall 

cease and the Forest Heritage Program Manager and Karuk Tribal Historic Preservation Officer 

(THPO) shall be notified immediately.

• Should inadvertent effects to or unanticipated discoveries of human remains be made on Region 5 

lands, the County Coroner (California Health and Safety Code 7050.5(b)) shall be notified 

immediately. If the remains are determined to be Native American or if Native American cultural 

items pursuant to NAGPRA are uncovered, the provisions of NAGPRA and its regulations at 43 CFR 

10 and ARPA at 43 CFR 7 shall be followed on federal lands (R5 PA Stipulation 7.9 (a)).

Prescribed Fire

• All sites in manual or prescribed burn (i.e., non-mechanical) units shall be marked on the ground with 

flagging prior to implementation.

• Construction of fire lines where sites are present will require a Forest Service archaeologist or tribal 

monitor to ensure fire lines avoid all archaeological features. Vegetation may be removed and fire 

lines or breaks may be constructed using hand tools, so long as ground disturbance is minimized and 

features are avoided.

• Vegetation to be burned shall not be piled within site boundaries of historic properties unless the 

location (e.g., a previously disturbed area) has been specifically approved by a Forest Service 

archaeologist. In general, slash piles will be placed at least 50 feet from any archaeological features or 

artifact concentrations.

• All fire-sensitive archaeological features or artifacts will be excluded from prescribed fire utilizing a 

variety of protective methods, such as use of flagging, fire line construction, specific ignition pattern, 

wetting agents, fire shelter fabric, and/or monitoring. Some sites will require hand removal of fuels 

prior to ignition to ensure that artifacts are not in direct contact with excess fuels.
Chapter 2. The Alternatives

82 – Somes Bar Integrated Fire Management Project

Vegetation Management

• All sites in mechanical units shall be marked on the ground as general equipment exclusion zones 

prior to implementation.

• Coordinate marking of restoration by-products in designated equipment exclusion areas with the 

Karuk Tribe.

• Any trees cut near or within site boundaries will be directionally felled away from archaeological 

features or artifacts.

• Full suspension or one-end suspension will be the preferred method of tree extraction when 

conducting tree harvest near sites.

• One-end suspension may be utilized within site boundaries on a case-by-case basis, but only after a 

Forest Service archaeologist or tribal monitor determines that trees can be removed without impacting 

any archaeological features or artifact concentrations.

• For linear sites (e.g., mining ditches, historic trails), equipment may cross in areas where their 

features or characteristics clearly lack historic integrity. Crossings will be designated by a Forest 

Service archaeologist. The remainder of the site will be avoided, and traffic will be clearly routed 

through designated crossings.

• No new landings will be constructed within the boundary of any site.

• Re-utilizing existing landings may be allowable within the boundaries of some post-contact sites (not 

allowable for pre-contact sites), where a Forest Service archaeologist has determined: a) access to and 

from the landing is on a previously established route, b) only the current extent of the existing landing 

will be used, c) the existing landing is devoid of any archaeological features or artifacts, and d) no 

subsurface component is likely to be present.

• All new temporary roads or skid trails shall be constructed outside of site boundaries.

• Previous temporary roads or skid trails may be determined acceptable for re-use if vehicles stay on 

the previously disturbed roadbed.

Invasive Weeds

Treatment #1 – Small sites (Table 2-13).

1. Where Himalayan blackberry (blackberry) exists as a discrete site with few plants (<10 plants) or 

as a small patch (<0.01 acres/est. 435 ft2

),

 Include treatment area in a retention mosaic for mechanical units OR retain an 

estimated 20 feet of native vegetation around treatment site for manual and 

prescribed fire units;

 Avoid operating equipment or yarding logs across retention areas;
Chapter 2. The Alternatives

Final Environmental Assessment – 83

 Manually grub out the plant including root crown, (with Pulaski or similar tool) 

before plant flowers in the spring, taking care not to damage roots of any native 

vegetation at the site;

 Remove pulled plants from site, re-locate to a nearby burn pile;

 Monitor in the fall;

 Repeat treatment annually until eradicated; then,

 Implement prescribed burning activities.

 Based upon monitoring, adapt approach as needed to meet the intent of the 

design feature.

1a. Where tree-of-heaven exists as discrete site with a few stems:

 Include in retention area or retain an estimated 20 feet of native vegetation 

around the site;

 Manually remove trees when ground is moist or workable to best ensure root 

removal (dig or use trailer/towing winch);

 Monitor in the fall;

 Repeat annually until site is eradicated; and

 Implement prescribed burning activities.

Treatment #2 – Moderate sites (Table 2-13).

2. Where blackberry exists as a moderately sized patch (e.g., 0.02 acres/est. 1,152 ft2):

 Include treatment area in a retention mosaic for mechanical units OR retain an 

estimated 20 feet of native vegetation around treatment site for manual, 

prescribed burn units;

 Avoid operating equipment or yarding logs across the retention area for 

mechanical units;

 Remove above-ground blackberry canes (weed whack or similar) before plant 

flowers in the spring;

 Pile blackberry canes where removed;

 Follow up in the fall with a prescribed burn over the removed canes;

 Monitor in the spring;

 Repeat annually (above-ground cane removal and burning or if a few plants, 

manual grubbing) until eradicated; then

 Implement prescribed burning activities.

 Based upon monitoring, adapt approach as needed to meet the intent of the 

design feature.
Chapter 2. The Alternatives

84 – Somes Bar Integrated Fire Management Project

2a. Where blackberry exists as a linear feature along a short stretch of road (0.1 miles):

 Implement items above, but only repeat treatment if monitoring in the spring 

after weed whacking and burning indicates the cover of blackberry is reduced.

Treatment #3 – Landings (Table 2-13).

3. Before using the landing, where blackberry exists as a small site:

 Mechanically remove blackberry by blading down to ground surface, pile on site 

away from operations;

 Subsequently pile burn on landing;

 Follow up with blackberry cane removal (weed whack or similar) or if few 

plants, manually grub out blackberry before plant flowers OR prescribe burn over 

blackberry patch;

 Monitor a year after treatment; then

 Repeat annually until eradicated.

 Based upon monitoring, adapt approach as needed to meet the intent of the 

design feature.

3a. Before using landing, where blackberry exists as a large site:

 Mechanically remove blackberry by blading down to ground surface, pile on site 

away from operations, then

 Pile burn on landing.

Treatment #4 – Other settings (Table 2-13).

4. Where blackberry exists as a large site, along a stretch of road associated with mechanical units or 

manual burn units:

 Include 10 to 15 feet of native vegetation around blackberry on the road edge of 

units in the retention mosaic or for manual units, a 10- to 15-foot native 

vegetation buffer.

Table 2-13. Site-specific project design features (PDFs) for invasive weed treatments.

Project Area Prescription Unit # Treatment

Ti Bar Manual (4a), Prescribed Fire (5c) 2115 #1

Ti Bar Manual (4a), Prescribed Fire (5c) 2115 #2

Ti Bar Mechanical (1b) 2117 #1

Ti Bar Mechanical (2) 2124 #1

Ti Bar Manual (4b), Prescribed Fire (5c) 2162 #2

Ti Bar Mechanical (2) 2116 #2

Patterson Manual (4b), Prescribed Fire (5c) 2291 (3 sites) #1

Patterson Prescribed Fire (5a) 2290 #1

Patterson Mechanical (1a) 2230 #1
Chapter 2. The Alternatives

Final Environmental Assessment – 85

Project Area Prescription Unit # Treatment

Patterson Mechanical (1a) 2230 #3 – landing

Patterson Mechanical (1b) 2227 #3a – landing

Patterson Mastication (3) 2229 #3a – landing

Patterson Mechanical (1a) 2217 #3a – landing

Rogers Manual (4b), Prescribed Fire (5c) 2361 #1

Rogers Manual (4b), Prescribed Fire (5c) 2314 #1

Rogers Mechanical (1a) 2320 #2

Rogers Manual (4b), Prescribed Fire (5c) 2312 #2

Rogers Mechanical (2) 2321 #2

Rogers Manual (4a), Prescribed Fire (5c) 2352 #1

Rogers Manual (4a), Prescribed Fire (5c) 2309 #1

Rogers Manual (4b), Prescribed Fire (5c) 2361 #1

Rogers Manual (4b), Prescribed Fire (5c) 2307/2361 #1 – both sides of road

Rogers Manual (4b), Prescribed Fire (5c) 2322 #1

Rogers Mechanical (2) 2336 (2 sites) #3 – landing

Rogers Mechanical (2) 2336 #2

Rogers Manual (4b), Prescribed Fire (5c) 2358 #1a – tree-of-heaven

Rogers Manual (4a), Prescribed Fire (5c) 2332 #2

Rogers Manual (4a), Prescribed Fire (5c) 2327 #2

Rogers Manual (4b), Prescribed Fire (5c) 2323 #4

Rogers Manual (4b), Prescribed Fire (5c) 2355 #2

Rogers Manual (4b), Prescribed Fire (5c) 2322 #2a

Rogers Mechanical (1a) 2328 #2

Donahue Mechanical (1a) 2425 #1

Donahue Mechanical (1b) 2412 #3

Donahue Mastication (3) 2412 #3

Donahue Mastication (3) 2413 #3

Donahue Mechanical (2) 2434 #1

Donahue Manual (4b), Prescribed Fire (5c) 2471 #1

Donahue Mechanical (1b) 2463 #1

Donahue Manual (4a), Prescribed Fire (5c) 2509 #1

Donahue Mechanical (2) 2452 #3a – landing

Donahue Mechanical (2), Manual (4b), Prescribed Fire (5c) 2452/2431/2458/2430 #4 – stretch of road

Donahue Mechanical (2) 2452/2431 #3a – landing

Donahue Mechanical (2) 2400 #4 – stretch of road

Riparian Reserves

• Endlining within the outer portion of riparian reserves would occur in the following mechanical units 

and as marked on the ground (Table 2-14):

Table 2-14. Endlining in riparian reserves.

Project Area Unit Treatment Method Project Area Unit Treatment Method

Ti Bar 2101 Mechanical Patterson 2273 Mechanical

Ti Bar 2105 Mechanical Donahue 2400 Mechanical

Ti Bar 2111 Mechanical Donahue 2401 Mechanical
Chapter 2. The Alternatives

86 – Somes Bar Integrated Fire Management Project

Project Area Unit Treatment Method Project Area Unit Treatment Method

Ti Bar 2112 Mechanical Donahue 2402 Mechanical

Ti Bar 2113 Mechanical Donahue 2404 Mechanical

Ti Bar 2114 Mechanical Donahue 2405 Mechanical

Ti Bar 2116 Mechanical Donahue 2407 Mechanical

Ti Bar 2117 Mechanical Donahue 2411 Mechanical

Ti Bar 2119 Mechanical Donahue 2412 Mechanical

Ti Bar 2120 Mechanical Donahue 2419 Mechanical

Ti Bar 2127 Mechanical Donahue 2421 Mechanical

Ti Bar 2131 Mechanical Donahue 2422 Mechanical

Ti Bar 2132 Mechanical Donahue 2423 Mechanical

Ti Bar 2142 Mechanical Donahue 2425 Mechanical

Ti Bar 2158 Mechanical Donahue 2431 Mechanical

Patterson 2200 Mechanical Donahue 2434 Mechanical

Patterson 2203 Mechanical Donahue 2452 Mechanical

Patterson 2217 Mechanical Donahue 2454 Mechanical

Patterson 2221 Mechanical Donahue 2456 Mechanical

Patterson 2224 Mechanical Donahue 2461 Mechanical

Patterson 2225 Mechanical Donahue 2465 Mechanical

Patterson 2226 Mechanical Donahue 2466 Mechanical

Patterson 2227 Mechanical Donahue 2467 Mechanical

Patterson 2230 Mechanical Donahue 2470 Mechanical

Patterson 2231 Mechanical Donahue 2474 Mechanical

Patterson 2235 Mechanical Donahue 2475 Mechanical

Patterson 2237 Mechanical Donahue 2480 Mechanical

Patterson 2242 Mechanical Donahue 2481 Mechanical

Patterson 2248 Mechanical Donahue 2492 Mechanical

Patterson 2249 Mechanical Donahue 2505 Mechanical

Patterson 2260 Mechanical Donahue 2508 Mechanical

Patterson 2264 Mechanical Patterson 2265 Mechanical

• When operating heavy equipment in designated riparian reserve buffers (Table 2-15), and as marked 

on the ground, work in linear strips to avoid unnecessary turning and subsequent soil displacement.

Table 2-15. Equipment use in outer riparian reserves.

Project Area Unit Treatment Method Project Area Unit Treatment Method

Ti Bar 2101 Mechanical Patterson 2240 Mechanical

Ti Bar 2105 Mechanical Patterson 2242 Mechanical

Ti Bar 2111 Mechanical Patterson 2248 Mechanical

Ti Bar 2112 Mechanical Patterson 2249 Mechanical

Ti Bar 2113 Mechanical Patterson 2264 Mechanical

Ti Bar 2119 Mechanical Patterson 2265 Mechanical

Ti Bar 2130 Mechanical Donahue 2400 Mechanical

Ti Bar 2131 Mechanical Donahue 2402 Mechanical

Ti Bar 2142 Mechanical Donahue 2404 Mechanical

Patterson 2200 Mechanical Donahue 2405 Mechanical

Patterson 2212 Mechanical Donahue 2407 Mechanical

Patterson 2214 Mechanical Donahue 2411 Mechanical
Chapter 2. The Alternatives

Final Environmental Assessment – 87

Project Area Unit Treatment Method Project Area Unit Treatment Method

Patterson 2217 Mechanical Donahue 2419 Mechanical

Patterson 2221 Mechanical Donahue 2421 Mechanical

Patterson 2226 Mechanical Donahue 2422 Mechanical

Patterson 2230 Mechanical Donahue 2427 Mechanical

Patterson 2235 Mechanical Donahue 2428 Mechanical

Patterson 2237 Mechanical Donahue 2441 Mechanical

Donahue 2456 Mechanical Donahue 2452 Mechanical

Donahue 2467 Mechanical Donahue 2456 Mechanical

Donahue 2477 Mechanical Donahue 2481 Mechanical

Donahue 2480 Mechanical Donahue 2486 Mechanical

Donahue 2487 Mechanical Donahue 2489 Mechanical

Donahue 2505 Mechanical

• Feather manual treatments within the inner riparian reserve buffers by retaining 30 to 40 percent of 

the vegetation available to cut in a mosaic pattern.

• Direct ignition would occur upslope of riparian reserve buffers so fire intensity remains low and 

backs into the riparian reserve buffer.

• Minimize burning of handpiles adjacent to stream channels and seek a balance between number and 

distribution of piles to reduce sedimentation. Place burn piles away from existing coarse woody 

debris to project Pacific giant salamander habitat.

• Utilize stream courses for prescribed fire control features.

• Construct handlines in riparian reserves only where necessary to minimize undesired fire effects.

Fisheries

• Water drafting will occur only at designated sources, away from coho critical habitat, as shown in

Figure 2-23.

• Follow National Core BMPs, Operations in Aquatic Ecosystems (AqEco-2 pp. 21-23) and Water Uses 

Management Activities (WatUses-3 pp. 145-146) – www.fs.fed.us/biology/resources/pubs/watershed/

FS_National_Core_BMPs_April2012.pdf.

• Conduct operations at water source developments in such a manner as to avoid, minimize or mitigate 

adverse effects to aquatic species and habitats from water drafting. Consult with a forest fisheries 

biologist with any questions concerning this water drafting protocol.

• Adhere to National Marine Fisheries Service (NMFS) water-drafting specifications and guidelines at 

designated water sources – www.westcoast.fisheries.noaa.gov/publications/hydropower/

water_drafting_specification_guidelines.pdf.

• Pumping rate will not exceed 350 gallons-per-minute or 10 percent of the flow in anadromous 

reaches. Otherwise pumping rate will not exceed 50 percent of surface flow.
Chapter 2. The Alternatives

88 – Somes Bar Integrated Fire Management Project

Wildlife

• No project activities that modify NSO nesting/roosting and foraging habitat from February 1 to 

September 15, unless protocol surveys determine no nesting activity. If surveys result in determining 

no NSO nesting activity, this restricted project operations time period would be lifted for the year in 

consultation with the US Fish and Wildlife Service (USFWS).

• No project activities that result in creating noise above ambient levels within 0.25 miles of 

nesting/roosting and foraging habitat or within known NSO AC cores from February 1 to July 9 on 

the KNF (Ukonom RD). No project activities that create smoke within 0.25 miles of nesting/roosting 

Figure 2-23. Water drafting site locations.
Chapter 2. The Alternatives

Final Environmental Assessment – 89

and foraging habitat within known NSO ACs from February 1 to July 31 on the KNF (Ukonom RD). 

If surveys result in determining no NSO nesting activity or non-occupancy, this restricted project 

operations time period would be lifted for the year. This project design feature is not intended to be 

applied to motor-vehicle travel on roadways.

• No project activities that result in creating smoke or noise above ambient levels within 0.25 miles of 

nesting/roosting and foraging habitat or within known NSO AC cores from February 1 to July 31 on 

the SRNF (Orleans RD). If surveys result in determining no NSO nesting activity or non-occupancy, 

this restricted project operations time period would be lifted for the year. This project design feature is 

not intended to be applied to motor-vehicle travel on roadways.

• NSO nest groves: No commercial treatments in any NSO nest groves.

• NSO habitat treatments: Maintain an average overstory canopy cover of 60 percent in treatment units 

mapped as nesting/roosting habitat. Maintain an average overstory canopy cover of 40 percent in 

treatment units mapped as foraging habitat.

• During project design with the Level 1 team and the USFWS, it was determined that four (4) NSO 

ACs (1250, 1073, 58 and 53) cores (0 to 0.5 mile) were deficit in habitat. The following units in the 

deficit cores (Table 2-16) would receive an 18-inch-dbh limit. These units would maintain posttreatment average overstory canopy cover of 60 percent in treatment units mapped as nesting/roosting 

habitat and would maintain an average overstory canopy cover of 40 percent in treatment units 

mapped as foraging or dispersal habitat.

Table 2-16. Units with 18-inch-dbh cutting limit.

Project Area Unit NSO Activity Center (AC) Number Treatment Method

Donahue 2421 58 Mechanical

Donahue 2456 58 Mechanical

Donahue 2474 53 Mechanical

Donahue 2480 53 Mechanical

Ti Bar 2105 1250 Mechanical

Ti Bar 2110 1250 Mechanical

Patterson 2225 1073 Mechanical

Patterson 2227 1073 Mechanical

• All high-quality nesting/roosting habitat as mapped within the project area will receive manual fuels 

treatments. The proposed treatment for high-quality nesting/roosting habitat would be cutting, piling, 

burning material less than or equal to 4 inches, and a low-intensity underburn. A high-quality 

nesting/roosting habitat polygon may occur in more than one (1) unit (Table 2-17) and only the 

portion of high-quality nesting/roosting habitat within the unit will be treated with this prescription.
Chapter 2. The Alternatives

90 – Somes Bar Integrated Fire Management Project

Table 2-17. High-quality nesting/roosting habitat polygons that overlap treatment polygons.

Treatment Type Unit # Project Area Treatment Type Unit Project Area

Manual Prescribed Burn 2100 Ti-Bar Manual Prescribed Burn 2103 Ti-Bar

Manual Prescribed Burn 2121 Ti-Bar Manual Prescribed Burn 2122 Ti-Bar

Manual Prescribed Burn 2149 Ti-Bar Manual Prescribed Burn 2153 Ti-Bar

Manual Prescribed Burn 2161 Ti-Bar Manual Prescribed Burn 2162 Ti-Bar

Manual Prescribed Burn 2169 Ti-Bar Manual Prescribed Burn 2250 Patterson

Manual Prescribed Burn 2252 Patterson Manual Prescribed Burn 2288 Patterson

Manual Prescribed Burn 2291 Patterson Manual Prescribed Burn 2410 Donahue

Manual Prescribed Burn 2424 Donahue Manual Prescribed Burn 2430 Donahue

Manual Prescribed Burn 2432 Donahue Manual Prescribed Burn 2440 Donahue

Manual Prescribed Burn 2455 Donahue Manual Prescribed Burn 2509 Donahue

Mechanical Ground-Based/ 

Manual Prescribed Burn 2119 Ti-Bar Mechanical Ground-Based/Manual Prescribed Burn 2225 Patterson

Mechanical Ground-Based/ 

Manual Prescribed Burn 2249 Patterson Mechanical Ground-Based/Manual Prescribed Burn 2493 Donahue

Mechanical Road-Based/

Manual Prescribed Burn 2120 Ti-Bar Prescribed Burn 2144 Ti-Bar

Prescribed Burn 2443 Donahue

• Goshawk surveys in the project area are in progress. During surveys, a nesting pair was detected—the 

units listed in Table 2-18 include the limited operating periods (LOPs) for this site. If nesting 

goshawks are found within 0.25 miles of any treatment unit, no noise- or smoke-generating activities 

(e.g., timber harvest, heavy equipment use, chainsaw use, burning) would occur within 0.25 miles of 

the occupied site between March 1 and August 31.

Table 2-18. Northern goshawk limited operating period (LOP) for all entries.

Project Area Unit Treatment Method

Rogers Creek 2323 Manual & Prescribed Fire

Rogers Creek 2328 Mechanical, Manual & Prescribed Fire

Rogers Creek 2334 Manual & Prescribed Fire

Rogers Creek 2335 Manual & Prescribed Fire

Rogers Creek 2336 Mechanical, Manual & Prescribed Fire

Rogers Creek 2340 Prescribed Fire

Rogers Creek 2341 Prescribed Fire

• Bald eagle nest surveys are in progress. During surveys, a nesting pair was detected—the units listed 

below include the LOPs for this site. If bald eagles are detected in or adjacent to the project area, no 

noise- or smoke-generating activities (e.g., timber harvest, heavy equipment use, chainsaw use, 

burning) would occur within 0.25 miles of the occupied site from January 1 and August 31. This 

applies to Units 2134, 2135 and 2139.

• Fisher, marten and wolverine surveys have been conducted with camera stations. Detections of marten 

and fisher have been documented in the project area. Although no den sites have been located, if a den 

is found, no project activities associated with loud noise above ambient levels and smoke-producing 

activities would occur within 0.25 miles from February 1 to May 31 adjacent to an active den site.
Chapter 2. The Alternatives

Final Environmental Assessment – 91

• Protect other known or discovered raptor nest sites from management activities and human 

disturbance until fledging has been documented. Levels of protection vary by the requirements of the 

species involved. A Forest Service biologist will be notified if a raptor nest is discovered during 

implementation and appropriate steps will be taken.

• Snags and logs would be retained per KNF LRMP standards and guidelines (S&Gs) Table 4-4; KNF 

LRMP FEIS Table I-1 provides standards for snag retention. The KNF LRMP guidelines recommend 

five (5) snags per acre averaged across a 100-acre area. This site-specific recommendation (FEIS 

Table I-1) advises that NSO high-quality habitat would have eight (8) snags per acre on an average 

area basis. Each acre need not meet these standards. Five (5) to eight (8) snags per acre is safe with 

the higher standard being applied to high-quality habitat.

• Maintain five (5) to 20 pieces of coarse woody debris (CWD) per acre in various stages of decay, and 

leave large logs (conifer and hardwood) at least 20 inches in diameter and about 40 cubic feet in 

volume when they are available. Down logs should reflect the mix of species in the stand (KNF 

LRMP p. 4-25 S&G 6-16).

• Snags and logs would be retained as per SRNF LRMP S&G Table IV-8 and Appendix L. Treatments 

within late-successional reserves (LSRs), riparian reserves, critical habitat units (CHU), and suitable 

Northern spotted owl habitat (regardless of land allocation) would maintain snags (20′′ dbh and greater 

or the largest available in younger seral stages) and downed logs (20′′ and greater and at least 10 feet 

long or the largest available) at the 80 to 100 percent level, unless they pose a safety hazard or would 

not meet fuel treatment objectives. Hazard trees are defined as any tree that is dead, dying, or showing 

signs of failure that has the potential to hit the area of operations (leaning toward the site and within 

tree-height distance).

• No snags will be cut during implementation, unless they present a particular safety issue that cannot

be avoided.

• Slash will not be piled against large trees or snags to reduce loss of structural elements during 

prescribed burning.

• All pre-dominant and dominant tree species would be retained. The project would not remove 

potential threatened, endangered, and sensitive species (TES) nest trees or affect the canopy around 

potential nest trees in suitable habitat. Directional falling would be used to protect all pre-dominant 

trees and any tree forming a canopy around the pre-dominant tree.

• Roadside and ingress/egress fuelbreaks (300 feet each side of the road) would retain approximately 

30 percent of uncut understory vegetation to provide cover for other wildlife species. Leave about 30 

percent of existing understory vegetation in a mosaic pattern that feathers more leave patches in the 

latter half (150 feet to 300 feet) of the fuelbreak.

• Shaded fuelbreak construction may occur in suitable TES habitat. No overstory trees or overstory 

canopy would be removed; however, in areas where the existing overstory canopy closure is low (but 
Chapter 2. The Alternatives

92 – Somes Bar Integrated Fire Management Project

greater than 40%) treatments in secondary or understory canopy layers should maintain a minimum 

overall canopy closure of 60 percent.

Visual Resources

• Created gaps or forest openings shall be placed a minimum of 75 feet from open public roads (ML 2 

and 3) and private properties.

• Avoid painting trees along open, public roads where visible from the road, river, or residence.

Temporary Roads

• Minimize proposing new temporary use roads.

• All temporary roads shall be winterized and closed to vehicle traffic every rainy season, typically 

October 30 to June 1, for the life of the project.

• When no longer needed for operations, remove culverts and associated fill. Rehabilitate roads and 

landings by decompacting, outsloping, and mulching with slash or seeding with native grasses. 

Physically close to vehicle access.

Sensitive Plants – Vascular Plants

• Cypripedium fasciculatum

Ti Bar Unit 2162 (manual and prescribed fire treatment), 30-foot treatment buffer:

 Conduct prescribed burning when plant is dormant (fall-winter seasons).

 Locate handpiles outside of buffer.

• Thermopsis robusta

Donahue Units 2431, 2459, 2461, 2463, 2454 and 2500:

 Equipment exclusion buffer marked on the ground, typically along the edge of 

the units listed above.

• Lichen (Sulcaria badia)

Patterson Unit 2249, two (2) equipment exclusion buffers marked on the ground, less than 0.1 

miles apart:

 Maintain existing overstory canopy cover.

 Consider incorporating sites within retention patches.

 For follow up treatments, manual/prescribed burn treatments are recommended

within equipment exclusion buffer.

 Locate burn piles outside of buffers.

Patterson Unit 2268 (prescribed fire), one (1) site:
Chapter 2. The Alternatives

Final Environmental Assessment – 93

 Manual treatments are conducted within the buffer prior to reintroducing fire to 

ensure a low-intensity understory burn.

 Avoid direct ignition within buffer area. Allow low-intensity prescribed fire to 

back or flank buffer.

 Conduct prescribed burning maintenance at intervals no less than five (5) years.

• Bryophyte (Buxbaumia viridis)

Patterson Unit 2247 (manual and prescribed fire treatments):

 Locate handpiles outside of buffer marked on the ground.

 Within the buffer, implement prescribed burning maintenance at intervals no less 

than five (5) years.

Donahue Unit 2457 (manual and prescribed fire treatments), riparian area:

 Given the moderate ladder fuels and moderate to high stems per acre in the area 

corresponding to this species, manually thin small-diameter trees/shrubs within 

the stretch of a riparian area buffer, which has been demarcated in the field.

 Locate burn piles outside of the buffer.

 Within the buffer, implement prescribed burning maintenance at intervals no less 

than five (5) years.

Soils

• Heavy-equipment operations shall occur when soils are dry enough to avoid deep rutting or puddling; 

operate over a duff and slash “mattress” if possible.

• Maintain 50 to 70 percent soil cover in units with low EHR, as prescribed on unit cards; duff and fine 

litter less than 3-inch diameter are the most desired soil cover components, but rock and larger wood 

also technically count as cover.

• The following units require 70 to 80 percent soil cover where units overlap with Hugo soils:

o Donahue: 2449, 2498, 2503, 2506 and 2509

• Limit temporary roads and landings, and skid trails to less than 15 percent of the unit area.

• Existing utilized skid trails would require ripping to mitigate compaction in the following units:

Ti Bar: 2117, 2119 and 2127

Patterson: 2242

Rogers: none

Donahue: 2409, 2467, 2493 and 2500.
Chapter 2. The Alternatives

94 – Somes Bar Integrated Fire Management Project

• Single-pass feller-buncher and masticator routes are generally not restricted to 15% area, however 

these are limited to dry soil conditions as with skidding equipment, and effort should be made to 

minimize turning-related (skid-steer) soil displacement.

Monitoring

The overarching goal of monitoring the Somes 

Bar Project is to evaluate the effectiveness of 

treatments in achieving desired condition and 

function, including reintroduction of fire as a 

step towards restoring and maintaining 

resilient ecosystems, communities, and 

economies in the interest of revitalizing 

balanced human relationships with our 

dynamic landscape.

Because the WKRP is dedicated to sharedlearning, the Somes Bar Project’s multi-party 

monitoring (MPM) strategy is the primary way 

for the partnership and the community to learn 

about—and from—the project. The monitoring 

effort will be led by the MPM team comprised 

of diverse participants that may include 

representatives from the Karuk Tribe, Forest 

Service, Klamath Forest Alliance/Environmental Protection Information Center (KFS/EPIC), Salmon 

River Restoration Council, MKWC, local K-12 students, Humboldt State University or other university 

students, and community volunteers (Figure 2-24).

The partnership has identified two (2) types of monitoring that will take place throughout the project: 

1) implementation and 2) effectiveness. Although validation monitoring is beyond the scope of this 

project, the partnership will pursue this type of monitoring with the help of researchers. The MPM team 

will meet annually to determine monitoring priorities. Based on team capacity, there are several 

components within each monitoring type that may be included. This capacity is largely dependent on 

funding availability. The question(s) related to each component link to the Purpose and Need, as well as 

the three (3) goals of the Cohesive Strategy. The data for monitoring will be housed by the WKRP data 

steward and available upon request.

Table 2-19 lists the types of monitoring and the components that may be monitored.

Figure 2-24. Schematic of multi-party monitoring strategy.

Multiparty 

Monitoring 

Team 

Karuk 

Tribe

U.S. 

Forest 

Service

Students 

and 

Universities

Mid 

Klamath 

Watershed 

Council

Community 

Volunteers

Salmon 

River 

Restoration 

Council

Klamath 

Forest 

Alliance,

EPIC
Chapter 2. The Alternatives

Final Environmental Assessment – 95

Table 2-19. Types of monitoring and the components that may be used for the Somes Bar Project.

Monitoring Type Component Component

Implementation: Did we do what 

we said we were going to do?

Prescribed burning Invasive weeds

Temporary roads Collaborative process

Landings Implementation mechanism(s)

Equipment exclusion zones Workforce

Canopy cover Project protocols and contract specifications

Skyline corridors Riparian Reserves

Ground disturbance Aquatic Conservation Strategy objectives

Accomplishments (e.g., acres)

Effectiveness: Did our treatments 

meet the purpose and need?

Prescribed burn effects Canopy cover

Oak enhancement Ingress/egress

Food species Youth Involvement

Basket materials Collaboration

Heterogeneity Social acceptance of fire

Invasive weeds Notifications for work

Fire Function Fuels reduction on private land

Fuel hazards (private properties, 

ingress/egress, ladder)

Public satisfaction

Northern spotted owl habitat Access to food and materials

Elk habitat Restoration byproduct revenue

Fisher habitat Demographics of workforce

Salamander habitat Jobs created

Willow habitat Jobs retained/sustained

Snags Training opportunities

Ladder fuels Avoided costs

Tree-size composition

Validation: Larger questions that 

are outside the scope of this 

project, but may be pursued 

concurrently.

Tree growth/basal area Sustained cultural practices

Structural heterogeneity Fisher as spotted owl surrogate

Wildlife habitat connectivity Elk population viability

Bird assemblages New resource areas

Adverse effects

Alternatives Considered but Eliminated from Detailed Study

Federal agencies are required to rigorously explore and objectively evaluate all reasonable alternatives 

and to briefly discuss the reasons for eliminating alternatives that were not developed in detail (40 CFR 

1502.14). Public written comments received during the scoping period on the Proposed Action included 

suggestions for alternative methods to achieve the Purpose and Need.

Alternative 3: Consider Northern Spotted Owl as Driving Force in Project 

Development

The purpose of the Somes Bar Project is to demonstrate how fire restores and maintains resilient 

ecosystems, communities, and economies to revitalize balanced human relationships with our dynamic 

landscape. Alternative 2 (Proposed Action) was developed to reinstate the use of TEK fire integrated with 

emergent restorative fire practices at the landscape scale. The commenter’s proposal to consider 

preserving Northern spotted owl NSO habitats as the driving force in project development does not align 

with the early WKRP community planning efforts, which underpin the purpose for the project. The 

WKRP selected various focal species representing different components of the landscape, rather than 
Chapter 2. The Alternatives

96 – Somes Bar Integrated Fire Management Project

managing with preference for a single species, such as NSO. The WKRP approached management from a 

broader landscape scale. Alternative 2 was designed so as components are put together, management for 

the focal species would provide a realistic and holistic approach to whole landscape management.

Although not the driving force in project development, NSO was identified as a TEK focal species 

integral to treatment design and season of implementation. Recognizing the NSO as regulated species 

under ESA, its decline from a cultural perspective serves as an indicator of a sick or dying environment. 

The Pacific fisher was identified as a potential surrogate, for which the NSO could serve as an indicator 

regarding varying components of its habitat dynamic. The Pacific fisher was also identified as a regalia 

species tied directly to TEK principles. During preliminary analysis, it was found that Pacific fisher 

habitat closely aligns with the habitat characteristics critical to the NSO food web.

As suggested, consideration was given to limiting removal of 18-inch dbh or greater size crown fuels 

(intermediate and dominant trees) in natural stands, and avoiding all mechanical treatments in cable units 

and within riparian reserves, proposed under Alternative 2 (Proposed Action). As considered under 

Alternative 3, to allow for safe ignition as an initial entry, prescribed burning would be limited to areas 

where pre-treatments would occur and a 133-acre area with low amounts of ladder and crown fuels. Table 

2-20 presents a treatment summary of Alternative 3.

Table 2-20. Treatment summary for Alternative 3.

Treatment Methods Sum of Acres

Manual, Prescribed Burn 502

Mastication / Manual, Prescribed Burn 154

Mechanical – Ground-based / Manual, Prescribed Burn 496

Prescribed Burn 133

Grand Total 1,286

Under Alternative 3 as illustrated in Figure 2-25, the 2,658 acres of manual treatments, followed by 

prescribed burning units and additional 1,491 acres of prescribed burning only units proposed under 

Alternative 2 were not considered. Although these treatments are within the framework of consideration 

for Alternative 3, implementation would not be feasible and would require a high cost investment (manual 

treatments) with flame lengths exceeding the desired 4 feet. Landscape-scale prescribed burning may only 

occur once perimeter containment and interior control line fuelbreaks are in place. Without this pretreatment of hazardous fuels across the landscape proposed under Alternative 2, application of introducing 

fire under Alternative 3 could not be safely contained and controlled without substantial augmentation of 

suppression reinforcements. As Alternative 3 does not respond to fundamental elements of the Purpose 

and Need to revitalize balanced human relationships within our dynamic landscapes and would only 

reduce vegetative fuel hazards along roughly 50 percent of the critical ingress/egress routes to private 

land inholdings, this alternative was considered but eliminated from detailed study.
Chapter 2. The Alternatives

Final Environmental Assessment – 97

Figure 2-25. Alternative 3 – proposed treatment methods and locations.
Chapter 2. The Alternatives

98

– Somes Bar Integrated Fire Managmenet Project

Comparison of Alternatives Considered in Detail

Table 2-21 provides a comparison of No Action Alternative (Alternative 1) and the Proposed Action (Alternative 2) displayed by measurement 

indicators, organized by elements of the purpose and needs to provide a clear basis for the decision to be made by the Responsible Official.

Table 2-21. Comparison of alternatives – Purpose and Need.

Purpose Needs Measurement Indicators Alternative 1

(No Action)

Alternative 2

(Proposed Action)

Demonstrate how fire restores 

and maintains resilient 

ecosystems, communities, and 

economies to revitalize 

balanced human relationships 

with our dynamic landscape.

Restoring and 

Maintaining Resilient 

Landscapes

Flame length

Model results of current fuel conditions 

indicate flame lengths would be 18.3 feet in 

plantations (Table 3-4) and 7.3 in nonplantations (Table 3-5).

Model results of future stand condition 

following thinning and prescribed fire

treatments flame lengths would range from 

4.7-5.3 feet in plantations (Table 3-8) and 

5.4-6.1 in non-plantations (Table 3-9) over 

the life of the project.

Modeling of flame length in plantations 

(Table 3-4) and non-plantations (Table 3-5) 

over 50 years show an increase in the 

average flame length from the current 

condition to highs of 22.9 and 10.8 

respectively. At the end of the 50 years, 

average flame lengths would be around 9-

11 feet in both.

Modeling of flame length post treatments 

over 50 years show a decrease in average 

flame length from 18.3 to 4.2 in plantations 

(3-8) and in non-plantations from 7.3 to 

3.7(Table 3-9) over the life of the project. At 

the end of the 50 years, average flame 

lengths would be 6 to 7 feet in both.

Stand density index (SDI)

SDI is a measure of inter-tree competition. 

Current condition of SDI (See Vegetation

section) is estimated at 80% in plantations 

and non-plantations. At this level, trees in the 

stand compete heavily for light and 

resources, resulting in stressed trees and 

increased rates of mortality, which also 

results in increased surface fuel loading. This 

stage of stand development often lasts a 

century or longer (Oliver and Larson 1996).

SDI would be reduced to about 40% 

through the life of the project (See 

Vegetation section). Decreasing stand 

densities would result in increased health 

and resilience as there would be less intertree competition for water, and light, and 

other resources. The resultant increase in 

tree vigor would allow for trees and stands

to be more resistant to disturbance agents 

such as insects, disease, and drought 

(Fettig et al. 2007, Vernon 2017). Western 

pine beetles already present in the project 

area, they would continue to attack potential 

host trees, but healthier more vigorous 

trees have a far better chance of surviving 

an attack than those that are stressed 

(Fettig et al. 2010, 2007).
Chapter 2. The Alternatives

Draft Environmental Assessment 

– 99

Purpose Needs Measurement Indicators Alternative 1

(No Action)

Alternative 2

(Proposed Action)

Basal area mortality

High rates of average basal area mortality 

is predicted to be 81% to 92% (Table 3-4)

mortality in plantations and 49% to 70%

(Table 3-5) in non-plantations.

The average percent of basal area mortality 

would be reduced to approximately 40%-

50% in plantations (Table 3-8) and nonplantations (Table 3-9) through the life of 

the project.

Resilient Communities

Potential rate of spread (chains 

per hour)

Modeled output under wildfire scenarios in 

previously managed strands is 6.7 chains 

per hour (Table 3-10).

Future stand condition following thinning and 

burning treatments and under a wildfire 

scenario increases slightly to 7.3 chains per 

hour (Table 3-11).

Change in fire type Torching

Surface: The model predicted that flame 

lengths would be reduced by half and that the 

associated fire type would change “torching 

with a potential transition to crown fire” to 

“surface fire with no crown fire transition”.

Resilient Economies

Cultural use flora and fauna 

habitat restoration acres 

enhanced

Karuk identity, and cultural use flora and 

fauna remain at risk due to growing risk of 

uncharacteristic high intensity wildfire and 

lack of a human interacted fire regime 

based on TEK principles.

Treating the landscape with fire achieved 

twin goals: protection against wildfire and 

promotion of cultural use species. This 

report sets out in detail how the Somes Bar 

IFMP will bring back cultural burning to 

revitalize and preserve Karuk culture.

Local workforce qualification 

training number of wage grade 

jobs providing environmental 

planning and hands-on field 

experience

The Klamath TREX is an annual two-week 

training in the use of controlled burning in 

the western Klamath Mountains to reduce 

the future danger of wildfires. Currently 50

training opportunities.

Combining local, tribal, and federal 

resources would be utilized in scaling up to 

implement fire management actions as 

described in the Somes Bar Project. 75 to 

100 training opportunities.

Fire management and forestry 

related employment number of 

potential living wage seasonal 

or full time jobs

Approximately six (6) full-time-equivalent 

(FTE) jobs have been created through the 

Klamath TREX

During the initial project period, it is 

estimated that WKRP, including 

contractors, would employ almost 20 FTE 

local living-wage employees each year. 

When the projects moves into maintenance 

and monitoring, that number may decrease 

again to 10 FTEs.

Commercial forest products in 

million board feet 0 MMBF 6 MMBF

Table 2-22 provides a comparative presentation between the No Action Alternative and the Proposed Action concerning the potential effects 

and outcomes relative to the Relevant Issues.
Chapter 2. The Alternatives

100

– Somes Bar Integrated Fire Managmenet Project

Table 2-22. Comparison of alternatives – Relevant Issues.

Relevant Issues Measurement Indicator Alternative 1

(No Action)

Alternative 2

(Proposed Action)

Threat to Native and Cultural Use

Plants: Ground disturbance from 

prescribed fire and timber harvest, 

may damage native plant species, 

while increasing solar radiation 

favoring the spread of invasive weeds.

Quality and quantity of 

cultural use plant species

No change to current conditions. Lack of frequent fire 

processes would continue to compromise the quality 

and quantity of cultural use plant species within and 

adjacent to the Katimiin CMA.

Elements to the larger cultural landscape would be 

enhanced by reinstatement of cultural burning to

improve the state of certain sites, objects, features or 

properties.

Over eighty percent of the plants utilized by Karuk 

people depend on restorative fire for germination, as 

well as the use quality and quantity of the plant 

materials (Anderson 2006). For example, basketry 

materials are required to be specific sizes for various 

types of baskets (Lake 2007). Acorn abundance and 

quality are also dependent on regular burning 

(Anderson 2005). 

Risk of introduction or 

spread No change

Implementation of invasive plant control measures 

would reduce the risk of introduction and spread in 

relation to the proposed actions.

Satellite occurrences with relatively few individuals 

(e.g., Himalayan blackberry and Dyer’s woad) would 

be eradicated.

Human Disturbance: Operational 

noise, presence of field crews and 

smoke generated from prescribed 

burning may periodically disturb 

neighbors.

Recreational Opportunity 

Spectrum (ROS)

ROS social setting would continue to provide for 

moderate to high frequency of user contact on roads 

and low to moderate frequency of backcountry use, 

away from roads in ROS Roaded-Natural and SemiPrimitive Motorized classes.

ROS social setting would continue to provide for 

moderate to high frequency of user contact on roads 

and low to moderate frequency of backcountry use, 

away from roads in ROS Roaded-Natural and SemiPrimitive Motorized classes.

Road access may be temporarily restricted during 

active logging operations (decking and hauling) for 

short durations to ensure public safety.

Visual Quality Objectives 

(VQOs) Retention and 

Partial Retention classes

No change to landscape character

Moderate and dominant alterations would occur from 

mechanical and manual treatments The alteration to 

landscape character, designed to mimic healthy forest 

conditions, would remain visually subordinate within 

the Retention and Partial Retention VQO classes.

Scenic Stability and Integrity

Scenic stability and integrity would continue to be atrisk, as current hazard and risk ratings for wildfire 

would remain status-quo.

Loss and/or degradation of natural resources from 

wildlife would likely affect other natural resource 

amenities.

Scenic integrity in these areas, along with the 

presence of field crews during and immediately after 

prescribed burning, operational slash, reflective tree 

stumps and smoldering debris would likely draw the 

attention of motorized observers in the short term.
Chapter 2. The Alternatives

Draft Environmental Assessment 

– 101

Relevant Issues Measurement Indicator Alternative 1

(No Action)

Alternative 2

(Proposed Action)

Noise (dBA) No change in ambient noise level.

Operational noise from equipment and presence of field 

crews may periodically disturb neighbors. The extent of 

noise disturbances from phased timber harvesting and 

use of equipment would be seasonal, concentrated ns 

along transport or log truck haul routes.

The initial phase involving tree felling (65 dBA) within 

line of sight noise measurement distance of 150 feet, 

skidding and stacking logs (65 dBA) and loading (58 

to 65 dBA).

Smoke (Air quality)

In the event of a wildfire, recreational use would likely 

disperse to alternate unburned areas and areas void 

of smoke, until vegetative recovery and the air quality 

and visibility is restored post control.

As each entry may be implemented over several 

seasons, smoke disturbance may impact nearby 

residents and visitors by lowering visibility and from 

the burning smell.

Habitat Disturbance: The removal of 

select crown fuels along with ladder 

fuels and surface reduction treatments 

including prescribed burning, may act to 

simplify forest stand structure in the 

short-term, impacting habitat quality and 

TEK focal species.

Stand density index (SDI)

SDI is a measure of inter-tree competition. Current 

condition of SDI (see Vegetation section) is estimated 

at 80% in plantations and non-plantations. At this 

level, trees in the stand compete heavily for light and 

resources, resulting in stressed trees and increased 

rates of mortality, which also results in increased 

surface fuel loading. This stage of stand development 

often lasts a century or longer (Oliver and Larson, 

1996). Stands would remain in overstocked conditions 

with a lack of structural diversity and decreased prey 

base for NSO foraging.

SDI would be reduced to about 40% through the life of 

the project (see Vegetation section). Reducing SDI 

helps to promote a mosaic of habitat types across the 

landscape and re-introduction of wildfire back on the 

landscape would reduce conifer encroachment in 

hardwoods, increase perennial grass diversity and 

increase structural diversity providing cover for calving 

and calves. In the long-term late successional habitat 

would be more resilient to large-scale disturbances. 

The trees of interest would have the necessary 

resources to increase the size of their crowns, 

allowing them to produce more carbohydrates, which 

will lead to increased quality and quantity of acorns.

Important structural elements would be maintained 

within the stand (large snags, trees and hardwoods) 

post-treatment. This would enhance resiliency of oak 

woodlands, and establish resilient heterogeneous 

forests at multiple scales. In addition, the Proposed 

Action provides mosaics of interior habitats and edges 

to provide for the diversity of prey for NSO.

Soil Erosion: Ground disturbance 

associated with tree harvest and 

associated logging operations 

(skidding, temporary road and landing 

construction) in riparian reserves may 

increase sedimentation downstream.

Risk to quality of streamflow

(Sedimentation through 

acres of ground disturbance 

in riparian reserves)

No change to current sediment regime.

0 acres of new ground disturbance in riparian reserves.

172 acres of ground disturbance would occur within 

riparian reserves.

Very low to no risk of sediment delivery based on 

integration of minimization design and mitigation 

measures.
Chapter 2. The Alternatives

102 – Somes Bar Integrated Fire Management Project

This page intentionally left blank.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 103

Chapter 3. Environmental Consequences

Introduction

This chapter describes the best available science, legal framework and analytical basis for comparing 

potential biological, social (cultural) and economic effects and outcomes associated with the No Action 

Alternative (Alternative 1) and the Proposed Action (Alternative 2), presented in Chapter 2. The 

Alternatives. The National Environmental Policy Act (NEPA) requires the agency to take a “hard look” at 

the potential effects of alternatives. Each of the following resource topic sections provides a summary of 

the project-specific reports, assessments, consultation and input prepared by US Forest Service (USFS or 

Forest Service) specialists. Information from these “specialist reports” (i.e., cultural resources inventory 

report, fisheries biological assessment, botanical biological evaluations, noxious weed risk assessment, 

wildlife biological assessment/biological evaluations (BA/BE), survey and manage reports, management 

indicator species, neo-tropical migratory bird species, soils, geology and fire and fuels resource reports 

are incorporated by reference into this final environmental assessment (EA). These reports or memoranda 

are part of the project record on file at the Six Rivers National Forest (SRNF or forest), in Eureka, 

California.

No Action (Alternative 1): What if we did nothing at all?

According to ancestral practice, treating the landscape with fire would achieve twin goals: protection 

against wildfire and promotion of cultural use species. If the status quo were to continue and a wildfire 

runs across the land, an uncharacteristically high-intensity wildfire is certain to happen, and is very likely 

to happen in the near future.

Given the Proposed Action was collaboratively developed in response to concerns about the 

ecosystem health, risks to the communities and the desire to bring restorative and cultural fire processes 

back to the landscape, the No Action Alternative was developed in detail.

Proposed Action (Alternative 2): What if we reinstate fire process beginning with pre-treatment of the land?

Tribal knowledge is driving the planning of the Somes Bar Integrated Fire Management Project (Somes 

Bar Project) using traditional ecological knowledge (TEK) on par with tenets of western science. Within 

Karuk aboriginal territory, people still follow the same practices for which evidence exists on and in the

ground. Archaeology is conventionally practiced as though the information sought pertains to a dead 

culture. In the Karuk worldview, there is a deeper meaning that has to do with the relationship with those 

that came before. Archaeology is practiced in conjunction with talking to people, and in conformity with 

those deeper meanings.

This chapter is organized into the following sections:
Chapter 3. Environmental Consequences

104 – Somes Bar Integrated Fire Management Project

o Place-based Setting: The first section summarizes a compilation of resource topic 

highlights of the place-based setting in light of the current living and physical environment 

holistically. This section is unique from the presentation of the alternatives that follows as it 

highlights patterns that would continue without implementing change.

o Resource Topics by Alternative Considered in Detail: This section presents individual 

resource topic summarizing project-specific reports, assessments, consultation and input 

prepared by the Western Klamath Restoration Partnership (WKRP). Information from these 

“specialist reports” (botanical biological evaluation and noxious weed risk assessment, 

biological assessment/biological evaluation (BA/BE) for fish and wildlife, geology report, 

soils report, and heritage resources report) pertinent to the analysis are incorporated by 

reference into this EA. The full reports or memoranda are part of the project record on file at 

the Six Rivers National Forest (SRNF or forest), in Eureka, California (see References section 

for those resources with specialist reports).

The disclosure of the No Action and Proposed Action alternatives described in separate resource topic 

sections, begins with a disclosure of the legal framework, description of analysis methodology, a 

comprehensive presentation of the affected environment, followed by a description of environmental 

consequences. The presentation of the environmental consequences address the potential for direct, 

indirect, and cumulative effects as defined below:

o Direct effects are caused by the action and occur at the same place and time as the action.

o Indirect effects are caused by the action and are later in time, or further removed in distance, 

but are still reasonably foreseeable.

o Cumulative effects are those that result from the incremental impact of the action when added 

to other past, present, and reasonably foreseeable future actions. According to the Council on 

Environmental Quality (CEQ) NEPA regulations, “cumulative impact” is the impact on the 

environment which results from the incremental impact of the action when added to other past, 

present, and reasonably foreseeable future actions regardless of what agency (federal or nonfederal) or person undertakes such actions (40 CFR 1508.7). The cumulative effects analysis 

area is described under each resource, and in most cases includes the private and other public 

lands that lie within the analysis area. This cumulative effects analysis does not attempt to 

quantify the effects of past human actions by adding up all prior actions on an action-by-action 

basis. Past activities are considered part of the existing condition.

Place-based Setting

The WKRP developed the Proposed Action through the Open Standards for the Practice of Conservation 

process based on shared values and identification of six (6) conservation targets, values and threats (see 

Chapter 2). Through a collaborative IDT process, measurement indicators were analyzed to provide the 

cultural, biological and physical components of the affected environment for this final EA.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 105

Archaeology and Living Environment

Stories are the primary means for passing down TEK, and govern its interpretation and use. They are told 

in winter and require complete attention when they are told. They also function as medicine in 

themselves. Stories have positive, healing properties. They recite the origins of medicine, and link the 

people today to Ikxareyavs, the Spirit People. Everything in the world—the mountains, the trees, the 

animals, came from the Spirit People. Only some of them became modern-day people. The stories link 

people of today to the ancestral ties of duty towards the whole environment and to the practices that 

sustain the bonds that tie all pieces of the environment together. Karuk ceremonies are for Fixing the 

World—the people, the animals, the plants, and the air and water. In that sense, everything is a cultural 

resource. Accounts of the prayers offered by people in land management or hunting roles—not just priests 

of sacred ceremonies—demonstrate the way all resources are unified.

The Karuk living culture is expressed not only in people’s beliefs and practices, or in the plants and 

animals that make up the landscape, but also in the things that have been touched and used by people in 

the past. For these reasons, excavation goes against Karuk beliefs and traditions. What is in the soil

should stay there. The Tribe does implement archaeological survey, documenting features, artifacts, 

cultural vegetation characteristics and associated wildlife habitats. Cultural resources still have a life, as 

do the people using them, all of which have a link with spirits of old. If you find an old artifact out in the 

field, you touch it with a stick: it still has something of the people who have touched it before. You need 

to get rid of any bad feeling in that rock. It has an intention: it wants to lie where it is and it should be left 

alone. Similarly, regalia items have a spirit too. They are made to be danced: they do not want to languish 

in museums and archives, but want to dance. You should let them be used, and be worn. Taking a longer

view than most archaeologists do, one can see how these resources have come to rest in the place they lie.

The focal and indicator species provide direct and culturally specific information about the overall 

health of the landscape. The policy of fire exclusion has resulted in great damage to the landscape: many 

resources have been left to grow unmanaged, with the result that they are being overtopped with conifers, 

primarily Douglas-fir and are choked with brush. Because of these factors, the overall landscape is on a 

trajectory that leads to uncharacteristically high-intensity wildfires, loss of local focal species populations, 

and ecosystem collapse. A key component of the landscape that is in dire threat are the black oak 

woodlands, which are easily overtopped and out-competed by Douglas-fir. This reduces habitat for focal 

species such as Roosevelt elk. As was seen with the loss of salamander in 201411, these focal species can 

serve as a warning that the bonds holding people, animals, and plants together that we all depend on are 

loosening, and the loss of one element is likely to result in the loss of significant parts of the ecosystem. 

Just as surely as the loss of salmon in the rivers and creeks, the loss of key regalia species would lead to the 

devastation of the people and all the other species that depend on them.

 11 In 2014, over 800 dead Pacific giant salamanders were counted in the Salmon River watershed during snorkel surveys.
Chapter 3. Environmental Consequences

106 – Somes Bar Integrated Fire Management Project

Fire, Fuels and Community

In the Happy Camp Complex fires of 2014, as in the fires of 2008, several areas were noticed that burned 

at sufficient temperatures to kill all the plants and to prevent any significant regeneration. This danger is 

especially acute because of the overall lack of fire across the WKRP planning area. Few areas have seen 

five (5) fires in the last century, and large areas have seen none at all (Harling and Tripp 2014).

The pattern has been set for infrequent, uncharacteristically high-intensity fires, instead of the 

traditional practice of introducing frequent, designed, and regular fires at low intensity. By not taking 

action on the project landscapes, the continued lack of fire would drive stands further and further from 

their historic conditions:

o Forest resiliency to wildfire in the project area would continue to decline and accordingly, 

through the coming years, mortality of large hardwoods would generally increase in stands, 

which would in turn increase the fuel loading.

o Fire return intervals could continue to become more and more departed.

o Most importantly, the process of fire would not be restored back onto landscapes, which have 

been missing that as an ecological component.

o This in turn would impact their ability to build resiliency function such as encouraging the 

development of fire prone species, which can shade out native fire adapted species.

o Natural fuel accumulations would continue to increase as more trees begin to succumb to 

overcrowding, drought, insect and pathogens thereby increasing the rate of mortality.

o This additional accumulation in ground and surface fuels would gradually begin to shift the 

potential fire behavior to a more severe stature including increased smoke production.

o Communities would continue to be at risk, as the extremely valuable strategic fuelbreaks 

would not be constructed. This in conjunction with the increased fuel loading, firefighting 

resources would continue to focus strategies and tactics on reducing the threat to life and 

property impacts of the communities, protecting infrastructure and private property as the 

highest priority followed by protection of natural resources.

o Suppression efforts would gradually become more difficult as wildfires could grow to larger,

unmanageable sizes more quickly. Therefore, direct attack in most cases could no longer be 

used as an initial tactic in suppressing a fire, and have to be changed to more indirect tactics, 

where more area has the potential to be affected by fire, in some cases high intensity and 

more severe fire.

o With the increases in fire behavior generated by these surface fuel changes, fire suppression 

forces would have higher resistance to control due to fuel loading and by more intensive fire 

behavior.

o Aerial retardants would be less effective due to closed continuous canopies. If a fire were to 

start in or burn into the project area, ground and aerial initial attack operations as well as 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 107

extended attack would become less effective and firefighter and public safety would be more 

difficult to ensure.

Fire Behavior and Fire Effects

Without the restoration of fire, forest health would continue on its current trajectory:

o Fire-adapted species would continue to flourish on the landscapes outcompeting more fireresilient species and native species, which are vital to many cultural perspectives.

o Historically, non-native flora species would continue to present higher levels of stand 

densities and associated fire behavior potential representing higher fire hazards on the 

landscapes (Taylor and Skinner 2003).

o If a wildfire ignites in the project area without action on the landscape, the ecosystem and 

communities would be subject to potentially stand-replacing results as seen in recent years in 

the Klamath Mountains region.

o Without frequent fire to clean the understory of stands, excessively dense stands lead to 

drought stress and bark beetle outbreaks, resulting in wide spread mortality of trees in many 

areas and the potential for extensive mortality. This leads to a large increase in the amount 

and continuity of both live and dead forest fuels, resulting in a substantial increase in the 

probability of large, severe wildfires (Weatherspoon 1996).

Vegetation

o With currently high stand densities throughout the project area comes increased susceptibility to 

damage and mortality resulting from such stressors as insects, disease, fire, and drought diseases.

o Many trees are currently experiencing high levels of competition for soil moisture, nutrients, 

and available light.

o Natural thinning is occurring to some degree in almost every stand of the proposed project, 

and additional stressors can trigger pulses of significantly increased mortality.

o Once a stand reaches 55 percent of the maximum stand density index (SDI), the stand is in 

the zone of self-thinning. At that level, the trees in the stand compete for light and resources, 

and the stand thins itself, resulting in increased fuel loading and stressed trees. All of the 

treatment groups presented in start in 2017 with an SDI around 80 percent of the maximum, 

and do not change much through the 50-year modeling period.

o The No Action Alternative keeps stands along their current trajectory of being vulnerable to 

significant mortality during a wildland fire under severe conditions

o Some stands would suffer stand replacing wildland fire under severe conditions; however, 

when taken into consideration and averaged across the proposed project area, those figures 

show that we are not looking at an entirely high severity affected landscape after a wildland 
Chapter 3. Environmental Consequences

108 – Somes Bar Integrated Fire Management Project

event under severe conditions. No landscape is completely dead post-fire, in fact high 

severity patches are often the most biodiverse post-fire compared to unburned areas.

o Non-plantation stands that are proposed for commercial thinning under the action alternative

shows the lowest potential basal area loss under severe conditions as almost all been 

previously thinned from below, have a dense canopy and very high canopy base height. The 

dense overstory has kept the ingrowth of brush to a minimum. However, planned treatments 

in these stands are aimed at maintaining and enhancing trees of interest that are critical TEK 

resources requiring less shade a more growing space.

o Young plantations are highly vulnerable to significant basal area loss in a wildland fire under 

severe conditions, and continue along that trajectory through time until stand densities are 

altered through some sort of disturbance.

Wildlife and Traditional Ecological Knowledge Species and their Habitats

Under current conditions, forested stands in the area of proposed treatments, which can be 

generally described as uniform and heavily stocked, are not meeting desired condition for 

structural heterogeneity, nor the desired number of large trees, snags, or hardwood basal area. 

These conditions are expected to remain as such without the proposed treatment.

o Fire behavior modeling (at 90th percentile of weather conditions) predicts about half of the 

project area would experience low intensity fires and half would be considered as very high, 

likely resulting in a significant loss or degradation of late successional habitats. The lack of 

natural mixed-severity fires in the landscape retains a continuum of stand homogeneity and 

limits a primary process, which results in the formation of unique habitat features (e.g., basal 

hollows, snags) and stand diversity.

o Habitat suitability for late successional species (or lack thereof) would remain the same; 

however, stands would trend toward increased homogenization due to declining tree growth 

and continued stand density.

o This, in turn, would prolong the time required to attain or retain the desired large tree and 

complex stand components and there would be a gradual loss of important features (such as 

large California black oak) due to competition and stress.

o This continued decline in ecological diversity would affect habitat suitability for many 

species including late-successional species in the long term. In addition, early-seral habitats 

would continue to decline as a result of lack of management and fire suppression.

o Overall, the No Action Alternative increases the potential for fire to shift to more of a high 

intensity fire regime rather than a mixed fire regime and remove more of the desired 

structural components within the project area, while areas that do not experience fire would 

continue to provide lower quality wildlife habitats with low structural and species diversity.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 109

Watershed Values

o Under the No Action Alternative, no fuel reduction treatments or associated connected actions 

would be implemented. There would be no direct effects to water quality or coho salmon 

under the No Action Alternative, as it maintains the current condition in riparian reserves.

o Short-term indirect effects to fire-excluded landscapes would likely increase vegetation cover 

and woody debris inputs to riparian reserves, decrease stream temperatures, and delay and 

reduce peak flow runoff.

o In the event of a large storm event, there is the risk that the stream crossings in the legacy roads 

could fail and deliver up to 1,100 cubic yards of sediment. Threatened and sensitive fish species 

occupy habitat between 1.0 and 1.7 miles downstream of these legacy road treatment sites.

o Forest density, and surface and ladder fuels, are expected to increase, and forest health within 

Riparian reserves is expected to continue to decline. The project area would remain 

vulnerable to having a stand replacement wildfire, especially on upper and mid slopes, and 

east and southeast facing aspects.

o The predicted fire behavior indicators related to rate of spread, flame length and intensity are 

expected to increase if this landscape were left untreated, with the potential for wildfire to 

spread across multiple drainages causing additional impacts to more riparian reserves and 

aquatic habitats.

o Under this No Action Alternative, Southern Oregon Northern California Coast (SONCC)

Coho Recovery Plan restoration actions identified as MKR.7.1.9 and 8.1.2, which were 

prioritized to conserve and recover this species, would not occur. Therefore, the elevated high 

severity fire threat to this Middle Klamath coho population is expected to increase over time.

Soils

o Direct effects of the No Action Alternative would be of no immediate effect at all on the soils, 

as soil disturbing project activities would not take place. Soil cover for erosion protection 

would not change. Present compaction levels would remain the same in the short-term, with 

very slow long-term natural recovery. Surface organic matter components would continue to 

accumulate faster than decomposition. Soil organic matter would be unaffected. Soil 

hydrologic function would be unaffected.

o Indirect effects of the No Action Alternative would be the increased accumulation of organic 

matter in terms of surface and ladder fuels, with a corresponding continual increase in fire 

hazard. Fire hazard is not the probability of a fire ignition, but that a fire ignition (human or 

lightning caused) would result in a successful fire start and spread, and fire behavior would 

be more severe. Fire hazard already represents an unacceptable threat to specified values at 

risk within the project area due to present vegetation composition.
Chapter 3. Environmental Consequences

110 – Somes Bar Integrated Fire Management Project

o The No Action Alternative would do nothing to alleviate the hazard, or manage risks 

associated with watershed values.

o The threat of wildfire to the soil resource should not be underestimated. As fire intensity 

increases, the potential for soil organic matter destruction, nitrogen volatilization, microbial 

mortality, structure and porosity destruction, inducement of water-repellency, and erosion are 

greatly elevated. High soil burn severity can severely damage soils and cause long-term 

declines in soil productivity and hydrologic function. Post-fire erosion is probably the single 

greatest risk to long-term productivity of soils in this Region. In extreme cases, soils cannot 

be revegetated without management intervention, or type conversion of vegetation 

communities may occur. Low to moderate severity fire is not usually considered a serious 

threat to soil resources, so to the extent that management activities can reduce the occurrence 

of high severity fire, soil resources benefit in the long term. High severity fire does have 

resource benefits, but high severity fire resulting in hydrophobic soil conditions harm this 

essentially non-renewable and irreplaceable resource.

Botany

o The ecology of all native plants and fungi in the Mid-Klamath bioregion (and beyond) 

includes wildfire as a natural disturbance. Even the Sensitive species in the project area 

associated with mature forests, including Buxbaumia viridis which is found within riparian 

settings, have evolved with fire at some intensity and interval. Historical cultural burning also 

played a role by enhancing conditions for growth and reproduction of an array of focal plant 

species—indicators of forest health.

o Where fuels have accumulated beyond their natural range of variability; the risk of losing 

occurrences of Sensitive species with very limited dispersal capability, requirements for 

shade and specific heat/humidity conditions, requirements for large coarse woody debris 

(CWD) as well as forest floor organics, is real when faced with potentially extensive high 

intensity wildfire.

o Fire intensity is also a factor for Cypripedium fasciculatum, but damage to a given occurrence 

is affected by fire scale as well as the number of plants present at the time of fire. Localized, 

intense fire may only affect a portion of an occurrence with a relatively large number of 

plants. Dispersal is less limiting for Cypripedium than for Buxbaumia as the former can 

disperse through asexual means (rhizomes) and air dispersed seeds.

o For Thermopsis robusta, an early successional species, while this species may expand to 

occupy post-wildfire settings and thus possibly benefit from the No Action Alternative, 

human-caused disturbance (i.e., roads and road maintenance) appears to serve as a surrogate 

to the effects of wildfire to stimulate the seed bank and clear competing vegetation; therefore; 

indirect effects of the No Action Alternative are not considered in relation to this species.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 111

o While the lack of fire leading to potential for high intensity burn is identified above as having 

a negative indirect effect to those species associated with mature and older stands under the 

No Action Alternative, it is also related to cumulative effects as past land management 

practices involving clear cutting, with little to no management (thinning) after logging has led 

to excessive fuel loading within sections of the project areas.

Invasive Species

o Road use and road maintenance activities, private land activities and development, as well as 

the potential for high intensity wildfire are ongoing activities that could affect the 

introduction and spread of invasive plants beyond their current distribution.

o Invasive species are tolerant of disturbance, most of the species shade intolerant (e.g., yellow star 

thistle, Dyer’s woad, Scotch broom) and easily disturbed, high intensity wildfire—a situation the 

Proposed Action is attempting to ameliorate—would create a setting conducive to the spread and 

establishment of invasive species beyond their current location. Relative to the growth habit of 

Himalayan blackberry in particular, removal of woody native species by wildfire, followed by 

relatively rapid growth of blackberry could result in its spread from road edges down or upslope 

into the forest interior and serve as a ladder fuel for subsequent wildfires.

o High intensity wildfire that removes the canopy and understory cover would create an 

environment conducive to spread of invasive plants, especially Himalayan blackberry, from 

its current location, into forest interior environments.

Resource Topics by Alternative Considered in Detail

This section presents the potential effects and outcomes for Alternatives 1 and 2, discussed by resource 

topic. The Environmental Consequences section summarizes in narrative format the scientific and 

analytical basis for comparing alternatives, summarized at the end of Chapter 2.

Cultural Resources

Introduction

The Somes Bar Project is a demonstration project for the WKRP. The WKRP is a combined agency–local 

organization–tribal initiative designed to promote cultural environmental management practices in the 

project area. The Somes Bar Project is the first concrete step towards restoration along those principles. 

The treatment of the project areas would allow the reintroduction of prescribed burning. The 

accomplishment of this goal would in turn revitalize TEK, practice, and belief systems. The 

reintroduction of fire as a cultural environmental management practice promises to mitigate if not 

remediate the era of wildland fire exclusion and past management or clearcut logging practices, as well as 

to promote the cultural use species traditionally utilized across the landscape.
Chapter 3. Environmental Consequences

112 – Somes Bar Integrated Fire Management Project

This section is based on the Somes Bar Project Cultural Resources Specialist Report, which describes 

the archaeological/cultural resource surveys done as part of the NEPA regulatory process. These surveys 

have been co-directed by the SRNF and the Karuk Tribe (Tribe / “we”), and have been designed 

collaboratively by the SRNF and the Karuk Resources Advisory Board in order to identify the cultural use 

values to be promoted by the project, and to assess any potential environmental impacts or adverse effects 

to potential historic properties. The Tribe and the SRNF are key partners in the WKRP. The report 

explains the survey methodology, the affected environment, and outlines the environmental considerations 

and potential effects of the proposed actions. It considers two (2) alternatives: the No Action Alternative 

and the Proposed Action. The latter part of the report reviews the potential impacts of the project actions; 

the first part of the report sets out in some detail how the cultural resource considerations link to the 

proposed actions and the purpose and need of this project.

A Karuk – Six Rivers National Forest Collaborative Approach

The archaeological/cultural resource surveys conducted by the Karuk and US Forest Service (USFS or 

Forest Service) archaeological crew were rather different from those practiced elsewhere in the state. The 

National Historic Preservation Act (NHPA) §106, as conventionally interpreted, tends to make the 

assumption the archaeological resources represent a dead culture. The surveys employed for this project 

aim toward the goal of preserving a living culture. They are designed around cultural revitalization and 

landscape restoration objectives, rather than the minimum requirements of historic preservation law. The 

identification phase included cultural resources areas that may benefit from the actions of this project.

The survey strategy has been formed jointly by the Karuk Tribe and the Forest Service to meet the 

fundamental goals of the project, while working within the framework of historic preservation law—in 

particular, analyzing whether or not any adverse effects would occur to known historic or pre-contact 

(prehistoric) sites. Historic preservation law is premised on protecting resources from federal actions. A 

primary assumption behind historic preservation laws is that a project has the potential to cause harm to 

archaeological resources. Our approach in the Somes Bar Project calls for actions that would benefit 

rather than harm the cultural and natural resources.

The surveys were designed to identify cultural resources that may end up being considered elements 

of a potential future TCP that may be larger than the areas covered within the project areas. Broadening 

the scope of the archaeological surveys to cultural vegetation characteristics and resources that may 

become elements of a future TCP is more effective in meeting the intent of the NHPA.

The concept of Traditional Cultural Properties (TCPs) and their consideration within historic 

preservation law has allowed for a deeper understanding of what needs to be identified and protected. 

TCPs are places that tie the practices of a living community with ancestral use; vegetation features, 

landscape features, the setting, and the feeling of a place may all be concrete contributory elements in the 

designation of a TCP. This brings to the fore a broader understanding of Historic Preservation law that 

allows consideration of historic activities within a given area that link to contemporary practices. Those 

contemporary practices would include the active management of sites that have been used for countless 

generations and are still used by people today. The purpose and need of this project opens up the 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 113

possibility that the management actions would benefit and revitalize those sites. In this way, the NHPA 

can be employed to preserve the living culture of the Karuk people.

The assessment factors below open up the possibility that certain projects, such as fuels reductions and 

the reintroduction of cultural burning, would in fact improve the state of certain sites, objects, features or 

properties. It is important to consider traditional principles, practices, use factors, and associated wildlife 

habitats that link the action to the spiritual, living environment, and human responsibility through respect 

and reciprocity, especially concerning food, fiber, medicinal and regalia species.

These practices include management by fire, spiritual uses, gathering uses, hunting, and evidence of 

temporary or long-term habitation. Thus, the survey crew assessed cultural resources that may not fit the 

strict definition of an historic property, but with a more holistic look may in the future become elements 

of a landscape-scale TCP, cultural landscape, or cultural district. This information was gathered to be

correlated with TEK and is incorporated into the design of the Somes Bar planning effort.

The broader vision for the WKRP planning area is to enable restoration of cultural burning practices 

on Offield Mountain and in the adjacent landscape, utilizing tenets of TEK as an indigenous science that 

works together with Euro-American models of science, hence revitalizing our cultural responsibilities to 

this place, and protecting the Karuk people from the loss of our cultural identity.

Cultural resources are recorded in a manner that reflects Tribal values and perspectives. In addition to 

identifying historic properties, the archaeological/cultural resources crew identified evidence for how the 

land was used and managed in the past, with a view to revitalizing those practices in their traditional places.

The cultural resources identified and TEK expressed through this project provide a living memory of 

human use and responsibility in context of place and can help us realize the stories of the past in the 

formulation of our contemporary future. By reconnecting the human role to the whole landscape, we can 

strengthen the spiritual, subsistence and management practices that the place calls the people to perform.

Affected Environment

The affected environment is being considered in the light of the cultural practices that produce it and 

sustain it. The surveys provide a window into the current conditions of the landscape. The incorporation 

of tribal participation in the surveys, with extensive experience in ceremonial and gathering practices and 

TEK, has enabled the consideration of broader range of cultural resources and associations that deepen 

our understanding of present and past use of the landscape. The survey results would be utilized in the 

project prescriptions and project design features (PDFs) to benefit and enhance culturally utilized plants, 

promote gathering and other cultural practices, and re-establish cultural burning.

Traditional ecological knowledge considerations should be given at least equal weight to the findings 

of Western science in designing projects. The principles of TEK arise from the fact that the Tribe is a 

place-based culture. The Karuk Tribe has occupied the same land for countless generations, and Tribal 

tradition includes a remarkable continuity of environmental management knowledge. While western 

science findings may be found in standard references, many of the key principles of TEK are 

encapsulated in the responsibility to the land, passed down and learned in contact with the environment.
Chapter 3. Environmental Consequences

114 – Somes Bar Integrated Fire Management Project

These considerations would express themselves as automatic, instinctive, and intuitive ideas the mind of 

an indigenous person when thinking about land management.

Cultural Context

The Karuk Tribe has practiced World Renewal Ceremonies around Panamnik and Katimiin since time 

immemorial. These ceremonial centers are located respectively near the modern Orleans and Somes Bar. 

The ceremonies themselves have been passed down intact since the beginning of time, and make up a key 

part of the social fabric of those communities. They link up families and guide spiritual, hunting, and 

gathering, and land management activities. The whole landscape needs to be considered to understand the 

links between village sites, gathering places, spiritual trails, and places that have been managed in 

accordance with ancestral principles, use and responsibility. Tribal people continue to practice a close 

relationship with the land and value many resources throughout the landscape as sacred. The relationship 

between the people and the land, as well as the sacred duty to take care of it for all animals and plants, has 

endured through countless generations. People still gather, hunt, fish, prune, burn, and coppice, and carry 

on their cultural practices throughout the Karuk Aboriginal Territory. In many cases, locational 

information and other sensitive information needs to be kept confidential in order to protect this 

relationship. However, in order to preserve this relationship, it must be enabled to thrive as a continual 

living culture in place through traditional knowledge, practice, and belief systems.

Traditional Ecological Knowledge and Landscape Character

Stories are the primary means for passing down TEK, and govern its interpretation and use. They are told 

in winter, and require complete attention when they are told. They also function as medicine in themselves. 

Stories have positive, healing properties. They recite the origins of medicine, and link the people today to 

Ikxareyavs—the Spirit People. Everything in the world—the mountains, the trees, the animals, came from 

the Spirit People. Only some of them became modern-day people. The stories link people of today to the 

ancestral ties of duty towards the whole environment and to the practices that sustain the bonds that tie all 

pieces of the environment together. Karuk ceremonies are for Fixing the World—the people, the animals, 

the plants, and the air and water. In that sense, everything is a cultural resource.

Accounts of the prayers offered by people in land management or hunting roles—not just priests of 

sacred ceremonies—demonstrate the way all resources are unified. The prayer to the mountains links the 

uplands with the water and the fish. As the stories tell, the prayer is based on the presence or absence of the 

Pacific giant salamander. This species indicates the health of the environment and revered as the water 

purifier. It is said that when the Pacific giant salamander is in peril, the entire system is on the verge of 

collapse. According to the stories that prayer is carried on: from the salamander to the frog, from the frog to 

the Pacific garter snake; from the snake to the springs and the salmon; from the salmon down the river and 

out to the sea. Then the sea will produce fog and clouds, and make rain in the mountains to restore balance 

in the world. The salamander is a key part in the cycle of rejuvenation covering the whole landscape.

Recent observations demonstrate the crucial ongoing part the salamander plays in indicating the health of 

the landscape. In 2014, over 800 dead Pacific giant salamanders were counted in the Salmon River watershed 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 115

at the same time as mortality exceeded 15 percent in the spring Chinook salmon run. It was ultimately fire, 

and correlating smoke shading of the river corridor that cooled the river and halted this die-off.

Below is an example of a story connecting the time of the Spirit People or Ikxareyavs to 

contemporary times. What we could learn from it in current conditions, is that we may need to increase 

our use of fire in order to protect salmon stocks using the smoke to maintain water conditions to below 

the temperature threshold for Pacific giant salamander mortality.

The Story of how Coyote Stole Fire

Karuk stories commonly tell of the relationship of people today to the Ikxareyavs, and on the role of 

Coyote in establishing that transition. Coyote is a trickster figure and helper of mankind. This story tells 

of how Coyote stole fire. In the Western tradition, a similar essential premise may be noticed in the story 

of Prometheus stealing fire from the gods, inside a fennel stalk. But the very significant differences in this 

story demonstrate its cultural significance. The Spirit People were the original beings in the world, before 

people existed. They changed into the beings in the world—the animals, the fish, the trees, and the rocks, 

as well as people. Coyote’s trickery represents the essential inventiveness and resourcefulness of people. 

Mankind has something of the quality of those Spirit People. But people also inherited a sense of duty. 

Only some of the Spirit People chose to become humans, and part of that choice was to make the promise 

to care for the land, the plants, and the animals within it. All those beings were siblings in the time of 

Spirit People, and the familial bonds persist to this day.

Coyote wanted to steal fire, which had been lost in a bet. He collected various animals, and placed 

them at intervals from the river to the mountains. Frog was in the first place—closest to the river. There 

was forest fire in the mountains, and he stole it by diverting the children who were in charge of it, and 

then pretending to fall asleep by the fire, having placed oak bark between his toes. At the right moment, 

he ran away with a piece of burning charcoal. The ember was passed from one animal to the next as each 

got tired. Turtle was able to escape by rolling down from a mountaintop towards the river, and then gave 

it to Frog. Frog hid the fire in his mouth, dived in the river and swam to the other side, and spat the fire 

out under a Willow. Dogs howled as the fire rose up, and mankind came into existence.

In this story, several key themes emerge. The story represents the transition from the time of Spirit 

People to the time of people, and it defines their relationship to the world. This transition is marked by the 

howling of dogs. Three things happen simultaneously: the appearance of fire by the river, the 

transformation of the Spirit People, and the emergence of mankind. They are linked. Fire is crucial to who 

people are, and what they do. It enables them to live. It is a central component of that duty of care for the 

whole world, which is inherited from their common ancestry as Spirit People. People need to work with 

all the animals, and to manage the landscape from the lowest points to the highest. Care of the 

environment covers all the plants and animals, and is an obligation for the humans who live there.

These interconnected threads of landscape management and duty are articulated in the stories that 

elders tell their children. Utmost attention is required, because they represent the cultural inheritance of 

wisdom and values. In the story of Coyote stealing fire, it is very significant that willow is the species in 

which fire comes to reside. The story emblematizes good management practices that are carried down to 
Chapter 3. Environmental Consequences

116 – Somes Bar Integrated Fire Management Project

this day. There are two (2) broad aspects to this management: enhancing positives and minimizing 

negatives. On the positive side is the use of fire. In this story, Frog ultimately hides fire at the base—in 

the roots—of the Willow plant. Willow is the plant used for fire making: rubbing sticks together, and later, 

using a bow. It is used for cooking and heating, and many other uses. Willow is to be found down by the 

river, and grows with the rhythms of the river. But in order to be useful, Willow needs to be managed by 

people. Willow is also a key resource in itself: it is a key species for basketmaking. The new stalks are 

harvested early in the year, are stripped of bark, dried for keeping, and then wetted for weaving purposes. 

The roots are also used for this purpose. As with Hazel, another basketmaking resource, the use of fire 

changes the cellular structure and makes it grow straighter and stronger. On the negative side, trees and 

shrubs can grow out of control, and inhibit access and contribute to risks of wildfire. Down by the river, 

village sites, gathering sites, fishing places, and dance grounds need to be protected from fire by reducing 

excess fuels, making fuelbreaks, and promoting buffer species such as live Manzanita. Up in the 

mountains too, fire has traditionally been used to manage the complete landscape, drainage by drainage. 

While the fire that Coyote found in the mountains was natural wildfire, management involves human 

intervention to ensure that fire burns though at regular enough intervals to promote cultural use species 

and to lessen the danger of wildfire. When Frog hid fire in Willow root that provided access to humans 

and enabled the responsibility to be upheld while providing clues leading to identification of additional 

indicators that would trend the balance of nature toward abundance without triggering unsupported 

population explosions, followed by species starvation and decline.

Stories in many cases revolve around Coyote as the one who helped bring humans into being. It is 

told that Coyote had seven wives whom at the time of the great transformation turned into the 

constellation Pleiades. It is said that when this constellation is not visible (April through June) their spirits 

come back to earth to help all things through their reproductive cycle. At this time, people were to have 

the utmost respect for this process by using fire only for the purposes of heating and cooking. In addition 

to this, place based indicators with some degree of spatial variability extended this time earlier into spring 

in respect for the reproductive rights of individual species.

This worldview establishes a belief system that protects the balance in nature, while remaining rooted 

in practice and enabling observational knowledge accumulation through intergenerational change.

Traditional Ecological Knowledge and Focal Species

The story of Coyote stealing fire provides an example of how stories encapsulate aspects of TEK and 

outline the combination of responsibility, respect, and reciprocity that links the people to their 

environment. It demonstrates how teachings from the beginning of time inform current practice.

The main efforts in the cultural resource surveys focus on these cultural use species. In the present 

context, it needs to be borne in mind how the indicator species link the cultural uses to the focal species 

and the whole landscape. What follows is a top-level analysis of how the focal species play a key role in 

the health of landscape segments. Awareness of this interconnectivity lies at the heart of TEK. It is also 

crucial for the revitalization of traditional knowledge, practice, and belief pathways through the adaptive 

management framework adopted by the WKRP.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 117

The story of Coyote stealing fire also illustrates the crucial place of Willow within human culture. 

One can correlate the human use and responsibility to the plants and animals to a cyclic interaction among 

all living things. This interaction operates among TEK, practice, and belief pathways. The willow grows 

around and at the edge of the river, often close to the sites of traditional villages. Willow is used to make 

fire, and is a crucial basket-weaving resource. It is particularly important in terms of female responsibility. 

Willow also harbors the river mussel. The mussel shell is used by women to carry fire when upholding the 

traditional female fire use responsibility to the plants.

Legal regulatory frameworks mandate that the northern spotted owl (NSO) must be considered in the 

NEPA process in planning projects. In Karuk culture, the Pacific fisher represents NSO habitats in the 

environment. Though owls are known as messengers of sickness and death, it is the great horned and 

screech owls that are told to carry these specific messages. These two (2) species are known to have 

specific names in the Karuk language. The NSO is not known to have a specific name, but has been found 

in practice to be one of the first species to decline when the habitat dynamics deteriorate owing to fire 

exclusion and other contemporary management practices.

While the interpretation could be made that the NSO is a messenger of a sick forest habitat dynamic, 

that function is traditionally associated with another species, the Pacific fisher, which is not only legally 

regulated but is also a regalia species. The fisher in fact covers a wider array of habitat dynamics, which 

in turn are more representative of fire process and function. The fisher is not just associated with the 

conifer forests, but also with the upland oak stands, which are traditionally more open and contain bunch 

grasses. The fisher plays a very central role in ceremony and culture—it is carried through the World 

Renewal Ceremonies by way of holding the arrows used to pierce the earth and wake up the world.

To build upon the open end of the fisher habitat dynamic, Roosevelt elk was also identified as a focal 

species. Though neither the fisher nor the elk were mentioned explicitly in the summarized story, they have 

a unique place in ceremonial practice, use and management that helps to start building a story leading us 

into a contemporary future while maintaining the traditional foundations of Karuk living culture. With elk 

specifically, we get into the traditional male responsibility of taking care of the animals. In fulfilling this 

male role in fire management, fire is carried in an elk horn. In integrating the habitat needs of large 

ungulates and other species needing more open space, we start to enhance the entire spectrum of habitat 

needs. With fisher covering the dense habitats transitioning to the more open and the elk transitioning from 

the wide open back to the more dense, there is plenty of overlap in habitat use that can help to frame sitespecific variation when it comes to formulating a proposed action or need for adaptation and we start to 

recover the habitat dynamics and ecosystem processes required by the spotted owl.

This leaves an additional component of regulatory consideration without complete coverage under 

our focal species. Riparian areas require special focus in the current regulatory environment. This is not 

unfounded in traditional Karuk practice. The Pacific giant salamander is the traditional focal species that 

is to be treated with the utmost respect. This species has its own prayer in Karuk World Renewal 

Ceremonies, and is the sacred water purifier. Though water quality parameters can be measured as an 

indicator of water quality, Karuk culture requires that no harm come upon this species and in turn, 
Chapter 3. Environmental Consequences

118 – Somes Bar Integrated Fire Management Project

riparian habitats receive special focus, and water from the source to the ocean and back again is protected 

as the primary directive.

As per the 2012 planning rule, focal species and specific questions that we would use in our 

monitoring efforts should be identified in the planning process. In consideration of these initial five (5)

focal species, the following questions may help to formulate a monitoring plan:

1. Can we treat enough willow and other basketry materials to supply basket weavers with enough 

gathering opportunity and materials to sustain this cultural practice?

2. How often and to what extent should willow be cut, burned or washed down the river to ensure 

quality basket materials are being produced while associated species habitat components are 

maintained or enhanced?

3. Can the Pacific fisher become a surrogate species for NSO in landscape scale planning efforts 

while allowing oak woodland maintenance/recovery efforts to take place?

4. Can elk winter range and calving habitat restoration increase the population viability for elk and 

other large ungulates?

5. What additional focal species and indicators should be integrated into site-specific prescription 

adaptations (lesser effect than analyzed) and future planning efforts?

Additional biological information about the focal species and how the Proposed Action may affect 

populations and their habitats can be found in the Wildlife Resources discussion further in this chapter. Some 

species, like the NSO, have legal disclosure requirements that focus on the individual species, however, this 

disclosure and potential impacts does not negate the overall intent of the focal species goals and objectives.

Human Practices across the Landscape

The Tribe takes account of the relationships between various phenomena that tie together all earthly and 

astronomical spirits. A landscape perspective is crucial for interpreting the information cultural resources 

may hold in the context of the culture itself. Broadly speaking, the cultural surveys initially focus on five

(5) main uses of the landscape by people: habitation, gathering, management, hunting, and spiritual.

Habitation means houses and villages. Houses are usually found on terraces elevated above the river. 

They would be indicated by pit houses, porch stones, midden soil, and graves. Other resources such as 

white and blue clay deposits and Port-Orford-cedar (POC) stands are also associated with these houses 

and ceremonial structures. Houses at higher elevations for the most part have historically been 

constructed with bark and poles.

Gathering refers principally to basketmaking materials, food and medicine. Many gathering activities 

would take place close to the houses in the watersheds above the rivers and creeks. The favored gathered 

foods are acorns from tanoaks. Acorns from black oaks are also used, as are mushrooms, nuts, berries and 

teas of many kinds. Grinding stones, mortars, pestles, etc., are often found in or near to these 

environments. Traditional archaeological site definitions, if applied strictly, would have limited scope for 

identifying and documenting these areas. However, when considered in the context of their relationship 

with the other four (4) factors, the story of a living culture begins to emerge. Families largely manage 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 119

their own gathering areas, and these are generally respected by others. Tools historically left in place can 

still be found today, though different tools are used today. Fire is integral to an active gathering culture.

Hunting resources include trails, blazes, arrowheads, hunting camps and cultural species associated 

with hunting practices. These include yew, mock orange, Douglas-fir, Ironwood, as well as birds and 

furbearers. Fishing and fish processing sites would also be included in this category. The habitats of the 

creatures that are hunted, or used for tools and ceremonial regalia, are in themselves integral to the 

associated management practices and to the spiritual human responsibility. Fire used in the context of the 

male responsibility was carried in an elk horn. The use of fire as a tool in Karuk culture provides for both 

protection and for enhancement of resources.

Management by fire, is in practice integral to the other four (4) factors, but is worthy of a special 

category. The landscape is managed principally by burning, and the frequency of those interventions 

depends on the intended purpose and whether it is a male or a female responsibility. Fire management 

provides one of the more abundant kinds of evidence that can be found on the landscape today. In 

ancestral practice, Sugar pines were the most prized ignition source, especially because of their yield of 

pitch and needles. Black pitch was indeed one of the most prized monetary resources available. Pine trees 

in general bridge both the male and female responsibility. Pine roots and needles are also used in basket 

making and are represented in ceremony as the tree of life. The presence of pines in specific landscape 

situations shows human management. In many cases, these remnant pine stands are located in areas 

central to landscape/resource specific ignition patterns. It takes hundreds of years to manage the lifecycle 

of pine to assure you always have an adequate pitch supply. If these places were not managed for this 

resource, they would not be found in this pattern on the landscape today. Indicators such as this are 

prevalent upon the landscape. They can be assessed through the identification of different species that 

correlate to products of fire management, and through the distinct human responsibility associated with a 

given piece of knowledge around a particular practice and/or belief.

Spiritual sites would include sweathouses, dance grounds, ceremonial structures, sacred places, sacred 

landscapes, spiritual trails, fireplaces and prayer seats. Setting, location, and feeling are crucial elements 

when interpreting the teachings that have been handed down, and are therefore very firmly tied to specific 

places. Stories and expressions handed down for millennia are often not completely realized by an 

individual until put into practice. You can tell a person to carry out a task, and why they should do it, but 

then they may not notice when a new variable comes into play. If the action one is asked to do is rooted in 

a purpose for which one has been exposed to a profound respect for the indicators through their entire life, 

they are more likely to come to realize the smallest of nuance on their own. While spiritual factors may be 

interpreted in a physical/locational sense, it needs to be borne in mind that there are intangible factors, as 

they are also founded in the responsibility under which one should or should not perform any action. A 

good example of this is burn timing and responsibility toward reproductive cycles as founded in an 

utmost respect for only using fire for heating and cooking during the time Pleiades is not visible in the sky 

(April to June). As explained above, the Pleiades are associated with a regenerative function within the 

universe, and represent Coyote’s wives. Such restrictions are applicable on a broad level. Site-specific 

indicators expand this responsibility to particular situations.
Chapter 3. Environmental Consequences

120 – Somes Bar Integrated Fire Management Project

Cultural Resource Recording Procedures

The Karuk Tribe and the Forest Service are partners in the planning and implementation of the cultural 

resource surveys. Because of this, the surveys fit the requirements for archaeological survey on public 

land administered by USFS, and meet the principles of cultural resources survey outlined above. The 

USFS guiding document for archaeological survey is the Region 5 Programmatic Agreement (R5 PA) 

with State Historic Preservation Officer (SHPO) and ACHP. All documented archaeological sites are

treated as historic properties potentially eligible for listing on the National Register of Historic Places

(NRHP), unless determined otherwise; consequently, sites were recorded on standard California DPR 

forms with discrete site boundaries.

Archaeological sites are defined as “A location of purposeful prehistoric or historic human activity. 

An activity is considered to have been purposeful if it resulted in a deposit of cultural materials beyond 

the level of one or a few accidentally lost artifacts.” Natural resources with signs of human manipulation 

are considered as ecological artifacts or features. An example would be a site that includes vegetation 

associated with past fire management practices (e.g., sugar pine) and other fire-dependent resources (e.g., 

tanoak, hazel, and beargrass) in association with artifacts. Traditional ecological knowledge forms were 

created for every pre-contact archaeological site to provide a broader context for the artifacts found across 

the landscape. Our understanding of past management practices is deepened by combining analysis of 

documenting artifacts with TEK considerations. This wider analysis allows consideration as sites of single 

artifacts, conventionally called “isolates”, if they are found within a wider context of ecological or 

landscape setting, and cultural use species that indicates purposeful human activity in that location. All 

archaeological sites documented in the project area are considered historic properties that are potentially 

eligible for listing on the NRHP.

In addition to recording sites, resource areas were recorded on TEK forms, developed and field-tested 

by the Tribe and the Forest Service to articulate TEK considerations necessary to inform management 

decisions. The TEK forms provide information on the natural resources showing signs of past or 

contemporary use/management (i.e., cultural vegetation characteristics), associations with the broader 

landscape (known villages, trails, hunting grounds, old camp sites, spiritual trails, springs, ridgetops, view 

sheds, ceremonial areas), and management recommendations to enhance cultural use quality.

Resource areas are locations that provide evidence about past human use or management. They may 

or may not have artifacts present. Resource areas may or may not qualify as archaeological sites. Their 

boundaries frequently overlap with archaeological sites, and in some cases are coextensive with them. 

Resources areas would often be tied to the five (5) types of human use listed, and they may include 

landscape features, vegetation, or artifacts in significant and agreed concentrations or combinations. The 

cultural use vegetation elements are called cultural vegetation characteristics, as defined below.

Cultural vegetation characteristics make up a special category of Tribal archaeological data. They are 

main constituents of resources areas that provide evidence of human management. They are defined as 

vegetation assemblages that are indicative of historic human use, management, or occupation. They are 

indicators that provide historically relevant information, which may justify their designation as a site, 

property, or as a feature in determining the eligibility of a larger district.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 121

Examples of vegetation that show evidence of management include huckleberry, sugar pine, and tanoak. 

Tanoak groves require fire and removal of younger trees to ensure the heath, vitality and productivity of the 

main trees. A high-quality grove would have mature, well-spaced trees. Huckleberries need to be managed 

in order to produce useful berries for people and animals. Both of these become unproductive if left to grow 

unchecked. Sugar pines, as stated above, are often found in strategic places on ridges, and would have been 

managed to serve as ignition sources. Accordingly, they are commonly found in conjunction with other 

plants that thrive in areas well managed by fire, such as tanoak, hazel, or beargrass.

The resource areas were given boundaries for this project to define a discrete grouping of cultural 

vegetation as verified by ground surveys. These areas are considered to be contributing elements to the 

larger cultural landscape. The broader management context for these resource areas would inevitably turn 

out to be larger than this project area. The surveys provide valuable information for a future designation 

of a much larger TCP, Historic District, or Cultural Management Area (CMA). Because of the potential 

for confusion of the project areas with the already-established Katimiin CMA, the preferred aim for the 

resource areas is for a future TCP and or cultural landscape designation.

Regulatory Framework

The WKRP aims at transforming the fire exclusion paradigm to one of holistic landscape management 

practice in alignment with the National Cohesive Wildland Fire Management Strategy (Cohesive Strategy)12. 

Archaeological surveys for the Somes Bar Project have been implemented in accordance with the 

requirements of the NEPA and NHPA §106. Compliance with these laws is required to gain the agency 

environmental approvals for implementation of this project, which calls for manual, mechanical, and 

prescribed fire treatments. NHPA §106 requires that 1) any adverse effects to historic properties be 

considered, analyzed, mitigated, and disclosed before initiating an undertaking, and 2) the Advisory Council 

on Historic Preservation (ACHP) be given the opportunity to comment on any such potential adverse effects.

For the Somes Bar Project, standard protection measures would be applied to sites in and near the 

area of potential effect in accordance with Appendix E of the R5 PA. If all measures are completed, it is 

anticipated that no historic properties would be adversely affected by this project.

For the purposes of NHPA §106 analysis (outlined at 36 CFR 800), the area of potential effects (APE) 

of the project were identified as the external boundaries of our four (4) project areas at Ti Bar, Patterson, 

Rodgers Creek, and Donahue Flat. This APE also corresponds in NEPA terms to the area of direct effects. 

It is more productive to consider the APE of the project in NEPA terms as the area of direct effects. This is 

because NHPA §106 regulations are premised on the assumption that “potential effects to historic 

properties” are negative in nature, and need to be mitigated or avoided. This project aims at enhancing 

these areas. The analysis in this section documents that there would be no significant impacts to cultural 

resources in the NEPA framework, and no adverse effects in the NHPA framework.

This analysis (also found in the Cultural Resources Specialist Report for Somes Bar Project, 2017)

does not address site-specific effects from the perspective of the NHPA. Site-specific effects would be 

addressed in compliance documentation completed for the inventory, evaluation and resolution of effects 

 12 www.forestsandrangelands.gov/strategy/thestrategy.shtm
Chapter 3. Environmental Consequences

122 – Somes Bar Integrated Fire Management Project

on cultural resources to meet the requirements of NHPA §106. Therefore, this specialist report does not 

meet the requirements of NHPA §106 for approving cultural resource clearance.

An archaeological survey was conducted on the project area and recorded in a Cultural Resources 

Inventory Report (CRIR R2015051000018), which is on file in the Heritage Department of the SRNF

Supervisor’s Office and at the Tribal Historic Preservation Office (THPO) of the Karuk Tribe. 

Archaeological surveys were conducted in accordance with the requirements set forth in Appendix H 

(Region 5 Hazardous Fuel Protocol) of the R5 PA, as well as the survey protocol developed by the Karuk 

Resources Advisory Board in collaboration with the SRNF. Since the project aims at the revitalization of 

community and cultural values, the surveys were designed to identify resource areas with high potential 

for improving the viability of cultural resources and tribal uses impacted by a century of fire exclusion 

and related past management practices.

Much of the land in the Somes Bar Project is administered by the Forest Service, and all of it is 

within Karuk Aboriginal Territory. There is a statutory obligation to engage in NHPA §106 and tribal 

consultation processes for projects on this land. Government-to-government tribal consultation has been 

on going between the Tribe and SRNF since the project’s inception in 2013. The Karuk Resources 

Advisory Board and Department of Natural Resources has been fully involved and has led all aspects of 

project design and planning.

Information regarding sensitive cultural resources and all locational data will be protected from public 

disclosure and will not be subject to FOIA. Relevant federal statutes include the 2008 Farm Bill, the 

FOIA identification of exemptions (5 USC §552 (b) (3)), and NHPA confidentiality (16 USC §470 hh).

The project was designed in concert with the Katimiin Memorandum of Understanding (MOU) 

between the Karuk Tribe, Six Rivers and Klamath (KNF) national forests, which establishes a working 

partnership between those entities with respect to management activities and opportunities within and 

adjacent to the Katimiin CMA. This document recognizes the central importance of the Katimiin CMA in 

the Tribe’s culture and beliefs. The project also puts into practice some of the principles from the Karuk 

Tribe’s draft Eco-Cultural Resources Management Plan (ECRMP), which is an over-arching planning 

document that aims at establishing a unified approach to managing the human, cultural/natural resources, 

and interests of the Karuk Tribe. The ECRMP specifies resource concerns, goals, objectives, current 

conditions, and future desired conditions, in a variety of environmental areas including cultural resources.

A TCP “... can be defined generally as one that is eligible for inclusion in the National Register 

because of its association with cultural practices or beliefs of a living community that (a) are rooted in 

that community’s history, and (b) are important in maintaining the continuing cultural identity of the 

community” (Parker and King 1998). Being eligible for the NRHP is the way federal agencies evaluate 

the significance of cultural resources on a national scale. In a more common sense, TCPs are places that 

are culturally significant to living communities.

An historic property is any prehistoric or historic district, site, building, structure, or object included 

in, or eligible for inclusion on the National Register, including artifacts, records, and material remains 

related to such a property or resource (NHPA Title III §301).
Chapter 3. Environmental Consequences

Final Environmental Assessment – 123

To be considered eligible for the National Register, a property must meet the National Register 

Criteria for Evaluation. This involves examining the property’s age, integrity, and significance:

o Age and Integrity. Is the property old enough to be considered historic (generally at least 50 

years old) and does it still look much the way it did in the past?

o Significance. Is the property associated with events, activities, or developments that were 

important in the past? With the lives of people who were important in the past? With 

significant architectural history, landscape history, or engineering achievements? Does it have 

the potential to yield information through archaeological investigation about our past?

Historic properties can include archaeological sites and TCPs. Federal agencies determine the 

significance of cultural resources on a national scale by determining their eligibility for the NRHP. Being 

eligible for the National Register means a property has acquired significance in light of its contribution to 

the past, and meets one of the criteria of eligibility for the National Register.

Criteria of eligibility refers to the quality of significance in American history, architecture, 

archaeology, engineering, and culture present in districts, sites, buildings, structures, and objects that 

possess integrity of location, design, setting, materials, workmanship, feeling, and association, and:

o Are associated with events that have made a significant contribution to the broad patterns of 

our history;

o Are associated with the lives of persons significant in our past;

o Embody the distinctive characteristics of a type, period, or method of construction, or that 

represent the work of a master, or that possess high artistic values, or that represent a 

significant and distinguishable entity whose components may lack individual distinction; or

o Has yielded, or may be likely to yield, information important in prehistory or history (36 CFR 

60.4).

Environmental Considerations

The project areas cover approximately 5,570 acres across the locations designated at Donahue Flat, Rogers 

Creek, Patterson, and Ti Bar. Of those locations, a large portion has been designated as prescribed burn as 

some things, such as girdling, pull back and firelines, etc., may be needed to contain the cultural burning 

within set areas. No potentially ground-disturbing work would be projected for those areas. The surveys were 

conducted on the firelines and those designated for mechanical thinning, which total 2,475 acres. Together 

with roadside, hand thin and mechanical cable areas, and additional fireline prep in burn only areas, the total 

comes to 3,900 acres. The 2015 field season surveys concentrated on roadside locations and covered 

approximately 1,900 acres. In 2016, an additional 2,000 acres were surveyed, including all units proposed for 

mechanical timber harvest. All the previously known archaeological sites within the project area were 

identified and updated as part of this project. The majority of these were historic mining sites. All identified 

resource areas were assessed using TEK forms. In addition, the most intact resource areas identified during 

the survey process were also surveyed. The 3,900 acres includes approximately 700 additional acres that were 

surveyed within resource areas in the event heavier management treatments were proposed.
Chapter 3. Environmental Consequences

124 – Somes Bar Integrated Fire Management Project

Resource areas are locations where a significant concentration or combination of resources, including 

cultural vegetation characteristics, artifacts, and features such as trails and ridges justifies an assessment 

of past human use and management. These assessments are made with a view to treating them for future 

use due to their short-term resource potential through the introduction of fire and other ancestral 

management practices. As typical in traditional knowledge, practice and belief systems, it would be 

through post-fire monitoring and reassessment of ecosystem response to treatment that additional resource 

areas might be identified or adjusted according to the site-specific situation.

There are 90 documented archaeological sites in the project areas. These sites are discussed in the 

restricted CRIR.

Direct Effects

As described above in the Collaborative Approach section, the primary intent of the project’s Proposed 

Action is to benefit cultural resources. Fuels reduction treatments and the reintroduction of cultural 

burning would in fact improve the state of certain sites, objects, features or properties. It is important to 

consider traditional principles, practices, use factors, and associated wildlife habitats that link the action 

to the spiritual, living environment, and human responsibility through respect and reciprocity, especially 

concerning food, fiber, medicinal and regalia species.

The proposed activities in the Somes Bar Project include prescribed burning, hand thinning with 

chainsaws, mastication, and several types of ground-disturbing activities, such as ground and cable-based 

tree harvesting. These activities have the potential to affect cultural resources, including historic 

properties, archaeological sites, TCPs, sacred sites, and traditional use areas. However, with the 

application of PDFs and Standard Protection Measures, it is anticipated that none of the proposed 

activities would adversely affect cultural resources.

How does this all tie together to frame the direct and indirect effects to the human environment? In 

accordance with the regulatory environment, one typically begins by defining the direct and indirect APE. 

In this case, the APE has been determined to be the four (4) project areas. There is a direct connection 

between the planned activities and the Purpose and Need of the project. The cultural resource surveys have 

been designed in such a way as to assess current conditions and to design management prescriptions that 

would lead towards a desired future condition more considerate of perpetuation of living Karuk culture.

Indirect Effects

In taking the approach of TEK integration, we are preserving a living culture while enabling expansion of 

fire-adapted community concepts. The management practices achieved in the currently proposed Somes 

Bar Project would lead to the introduction of fire, and would start the process of landscape recovery from 

years of neglect, fire exclusion, road building, use of chemical/biological agents, logging practices and 

spread of invasive plant, tree and shrub species. The reintroduction of management by fire may have 

indirect beneficial effects over a much wider area than the direct APE covered by this analysis. Since the 

project takes a holistic landscape approach and employs five (5) focal species that together cover the main 

landscape components, it is appropriate to realize that we may have indirect beneficial effects in the 

context of the entire WKRP planning area and beyond. These actions have the potential to enhance the 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 125

focal species and integrate other TEK considerations across that whole area as well as in building 

relationships with additional tribal groups. Indirect effects beyond the scope of the WKRP effort are also 

underway as many people at regional, national, and international scales are expressing interest in the 

processes and considerations being established and undertaken in this demonstration project. A key 

indirect effect of this project is the potential for enabling the restoration of important ceremonial burning 

practices on Offield Mountain. By treating large areas around residential structures, and building social 

license for increasing the scope and scale of fire use, ceremonial burning can be restored, as well as 

managed wildfire decisions enabled on adjacent landscapes.

Alternatives

This analysis considers two (2) alternatives: the No Action and the Proposed Action. It is worth noting 

that the cultural resources surveys have been designed to cover the most intensive treatments, or those 

that are most likely to produce significant impacts. Any other actions outlined in the final EA, therefore, 

would involve less treatment and would already have cultural resources survey coverage and meet 

analysis requirements by assessment of these two (2) alternatives.

No Action Alternative

The project actions need to be viewed in the context of, and in comparison to, wildfire. One of the main 

objectives of the project is to make the land more fire resilient (“resilient communities”). If the neglect 

continues and a wildfire runs across the land, uncharacteristically high intensity wildfire is very likely to 

happen in the future. In the Happy Camp complex fires of 2014, as in the fires of 2008, several areas were 

noticed that burned at sufficient temperatures to kill all the plants and to prevent any significant 

regeneration. This danger is especially acute because of the overall lack of fire across the WKRP planning 

area. Few areas have seen five (5) fires in the last century, and large areas have seen none at all (Harling 

and Tripp 2014). The pattern has been set for infrequent, uncharacteristic high intensity fires, instead of 

the traditional practice of introducing frequent, designed, and regular fires at low intensity. As is well 

established, both the costs and the direct effects to cultural resources from wildfire suppression are far 

higher than those of prescribed fires in the same area.

The focal species and the indicator species provide direct and culturally specific information about 

the overall health of the landscape. The policy of fire exclusion has resulted in great damage to the 

landscape: many resources have been left to grow unmanaged, with the result that they are choked with 

brush. Black oak woodlands, a key component of the landscape in dire threat, are easily overtopped and 

out-competed by Douglas-fir. This reduces habitat for focal species such as Roosevelt elk.

Because of these factors, the overall landscape is on a trajectory that leads to uncharacteristic high 

intensity wildfire, loss of local focal species populations, and ecosystem collapse. The focal species have 

been selected because they are regulated or as regalia species, and because they are important in discrete 

segments of the landscape. As was seen with the loss of salamander in 2015, these focal species serve as a 

warning to people that the bonds holding together people and animals, and plants that we all depend on 

are loosening, and the loss of one element is likely to result in the loss of significant parts of the 
Chapter 3. Environmental Consequences

126 – Somes Bar Integrated Fire Management Project

ecosystem. Just as surely as the loss of salmon in the rivers and creeks, the loss of key regalia species 

would lead to the devastation of the people and all the other species that depend on them.

While it is difficult to associate a project with any specific climate change effects, some well-accepted 

climate change considerations can be outlined. A great increase in the frequency and intensity of wildfires

has been observed in the last three (3) decades, concomitant with increased riparian and riverine erosion. 

The landscape and all of its rich cultural resources are at great risk.

The Somes Bar Project is a pro-active and holistic approach to restoring cultural fire to a landscape

preparing communities and neighborhoods for fire readiness. This section documents the central 

importance of the Somes Bar area, which is the center of the Karuk universe. According to ancestral 

practice, treating the landscape with fire achieved twin goals: protection against wildfire and promotion of 

cultural use species. This section sets out in detail how the Somes Bar Project would bring back cultural 

burning to revitalize and preserve Karuk culture.

Proposed Action Alternative

Direct effects for the preservation of Karuk living culture aim at whole landscape enhancement. The 

identification of the focal species and indicator species served to show interconnections of mutual 

dependency between one species and another. They provide a rational, coherent explanation of how 

saving or enhancing one value would contribute to the environment as a whole. Traditional ecological 

knowledge does not focus, as modern regulations tend to, on single species management, but on the 

health and productivity of the whole.

The immediate aim of the treatment and burning of the Somes Bar Project is to enhance the diversity 

and productivity of the vegetative species. These values tie directly to the identified Purpose and Need of the 

project as a whole. It has been observed that the landscape is so heavily vegetated that the reintroduction of 

burning cannot be accomplished in all places without prior treatment work. Moreover, there is an 

overabundance of Douglas-fir on the landscape, whereas in the past, evidence shows that there was a much 

more significant variety of hardwoods on the landscape. These can still be seen in certain places.

One of the most threatened species is the California black oak (Quercus Kelloggii), which is 

vulnerable to being overtopped and crowded out by Douglas-fir. All the same, the oaks that remain are old 

and serve as indicators of an ancestral state. One of the biggest deficits on the landscape is the old upland 

oak woodland. The development of the TEK forms has helped summarize most of the characteristics of 

these remnant stands. As has been demonstrated by Jeffrey N. Crawford in a University of Nevada, Reno 

dissertation, the evidence from sediment, charcoal and pollen records demonstrate the development of 

these oak uplands just after the end of the last Ice Age, and—crucially—that this development was of

anthropogenic origin (Crawford 2012). Additionally Taylor et al. (2016) further identifies the level of fire 

activity in the Pacific Northwest to be anthropogenic in nature vs driver by climate. Therefore, in 

founding our reference condition as pre-condition landscape condition pre-historic fire vs practice would 

be considered of natural origin.

These woodlands would usually be southeast to southwest facing, on relatively gentle slope, have 

relatively open canopy conditions, and would have grasses, forbs, foods, medicines, and fibers among 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 127

them. These stands are sometimes found on northerly aspects with higher insolation values and make for 

good fire management features when restored and burned frequently. The people would manage this and 

adjacent habitats by introducing fire prior to bud set in spring triggering immediate response in ground 

resources that provide high quality food for animals and people alike. While most other burning is done in 

early summer though fall, this late winter/early spring practice also provides a valuable teaching 

component in and near areas of permanent habitation through bringing together elders and youth to teach 

and learn about the dynamics of fire practice in a low fire risk setting. The conditions in early spring are 

just right to run fire at low intensity through open canopies covering cured grasses and leaf litter and to 

enhance the habitat for other animals while reducing vulnerability to overstory trees during in-season fire 

events. In particular, this habitat is crucial for elk and for the Pacific fisher, two (2) of the focal species. 

These oak uplands provide crucial connections for the elk between their calving habitat in the woods and 

their upland summer range. Elk horns are often found in these areas, and they in turn are crucial for 

management by fire. These habitats provide both browse and the necessary open conditions for elk to 

thrive. More research is ongoing about their migration patterns across the landscape. The fisher, while it 

burrows in the hardwood and conifer forest, often comes out to forage and rest in or adjacent to the more 

open conditions provided by oak woodlands. These habitats provide rodents and other prey for the fisher. 

In several cases, management decision should take into account providing food for prey for focal species. 

Such considerations have assisted in designing prescriptions that benefit the ecosystem as a whole.

The black oak woodland is just one component of the landscape that is in deficit. As can be observed in 

various places, when clear-cut logging has occurred, certain species would grow back naturally. Tanoak, a 

crucial cultural species, can grow thick and unchecked, and would produce a hillside with many thin stems. 

This is unproductive for humans and animals alike. Tanoak groves, such as those identified in the cultural 

surveys, have mature trees, which are well spaced. Management by fire would usually be low intensity 

because ground cover is generally quite low apart from the litter and duff on the ground. Fire should run 

through these stands and not harm the trees. The groves would also have been managed by cutting trees to 

favor others. As has been set out in the previous sections, pine and manzanita spines have a crucial role to 

play in the management by fire, for introducing controlled burning, and for community protection.

The discussion above provides an account of the positive effects of the management work and some 

of the aims of reintroducing fire. One should also discuss some potential negative effects.

In some cases, there is the potential for direct effects to archaeological values. Wooden features such 

as cabins would be protected according to the processes outlined in the R5 PA. Standard Protection 

Measures are designed to avoid adverse effects to these kinds of resources. Moreover, PDFs and Standard 

Protection Measures call for the exclusion of heavy equipment in certain zones, for instance where 

mushrooms grow. These are important gathering resources and would be harmed through damage to the 

mycelium layer from heavy equipment use. Hand treatment would be recommended in many of those 

equipment exclusion zones. If hand treatment is practiced sensitively, and burn piles are located at a safe 

distance from sensitive resources, hand treatment would not produce significant direct effects.

Many areas within the APE were designated as prescribed burn and were surveyed only along 

proposed fireline routes. They were so designated because they were steep and inaccessible—both for 
Chapter 3. Environmental Consequences

128 – Somes Bar Integrated Fire Management Project

cultural surveys and for project implementation activities. This does not mean to say that they were 

inaccessible to people who came before: there may be resources in these areas. Although all areas planned 

for other potentially ground-disturbing treatment have been surveyed, there would likely be inadvertent 

discoveries through project implementation. Previously unrecorded properties that are encountered during 

implementation shall be documented and protected in the same manner as other properties.

It is worth considering potential effects from fire to a pre-contact archaeological site that contains 

stone artifacts. High-intensity fire may be sufficient to crack rock. Most archaeologists would take the 

viewpoint that when an artifact is present it must not be disturbed or the planned action may cause 

damage. In this project, a new approach is being taken. Stone artifacts are linked to cultural vegetation 

characteristics, which this project means to enhance. In general, the intensity of prescribed burning would 

be low to moderate, while the intensity of wildfire can reach high intensity and can cause severely 

negative effects. By contrast, cultural indicator species, beargrass and hazel, grow back particularly 

strongly after low to moderate-intensity fire.

When fire occurs via a lightning ignition, it would burn in conditions that are likely to crack rock. 

Through recovering fire process, function and resource use, including the human use of fire, resources 

traditionally enhanced by fire can be once again and the tools of the past that are left behind can be more 

easily located, even though they may have some fire effect relevant information in fact remains. The

potential impacts need to be viewed in comparison with the potential effects of wildfire, and in the 

context of the overall enhancement of the surrounding resource area as a whole. This kind of impact to an 

artifact, while not necessarily desirable in itself, does not in NHPA §106 terms mean “adverse effects” to 

a historic property, and still less in NEPA terms does it mean “significant impacts” to cultural resources. 

Any potential for damage done by fire reintroduction would be lessened by burning in selective climatic 

conditions. Mitigations such as survey coverage during fireline construction and following burning may 

be good practice.

Manual Treatments

Important cultural and ecological plant species would be targeted for enhancement wherever feasible. 

Manual treatments involve minimal ground disturbance, and usually have low likelihood of causing

significant impacts to archaeological sites. Intensive surveys were conducted along all roadside units and 

any areas where it is high probability for archaeological sites to be present. Subsequent treatments 

utilizing prescribed fire do have the potential to affect archaeological sites. Therefore, no slash piles shall 

be allowed within site boundaries.

Mechanical Treatments

Mechanical treatments involve varying levels of ground-disturbance and can cause the following effects 

on cultural resources, including compaction, movement, breakage, or total destruction of artifacts, 

features, site stratigraphy (subsurface cultural deposits), or the entire site. These effects can range in 

intensity and, in some instances, can lead to significant loss of data potential and diminishment of the 

characteristics that make historic properties eligible to the NRHP. Timber harvesting activities, for 

instance, have the potential to disturb cultural resources when logs are dragged across the ground, skid 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 129

trails are created, and logs are piled at landings. Additionally, heavy equipment used for timber harvesting 

operations can cause rutting and compaction, resulting in increased erosion, creating both direct and 

indirect effects on cultural resources.

Intensive surveys were conducted in all units where mechanical treatments were proposed. Site 

avoidance strategies and/or site protection measures would be used to address all of these potential 

effects. Specifically, site boundaries would be flagged as equipment exclusion zones. If it is determined 

that removing some trees would be beneficial to a site (e.g., restoring an acorn processing site where 

conifers have encroached upon a mature oak stand), timber harvest may be allowable where the forest 

heritage program manager has determined that work can be conducted without causing significant 

impacts to the site, utilizing On-Site Historic Property Protection Measures (specified in the R5 PA). All 

work within site boundaries would be monitored and directed by Forest Service archaeologists and/or 

Tribal representatives. Therefore, the potential effects are not considered adverse.

Prescribed Burning

Prescribed burning has the potential to damage archaeological sites directly and indirectly. Intensive 

surveys were conducted along all primary fire control lines and other areas where there was high 

probability for archaeological sites to be present. Fire-sensitive sites (i.e., sites that contain organic 

materials, exposed wooden architecture, etc.) are at the greatest threat from fire, and can be completely 

consumed even at low intensities. Sites without flammable features (i.e., prehistoric and historic sites with 

deeply buried cultural deposits; prehistoric and historic artifact scatters; and prehistoric and historic sites 

with non-flammable surface features) are less vulnerable to fire, but can be damaged when exposed to 

high-intensity fire. Fire effects on less fire vulnerable sites include, but are not limited to, cracking of 

stones, spalling (peeling or separating of outer layer of rock), and sooting.

Fire-sensitive sites with flammable features, such as culturally modified trees, dendroglyphs, blazed 

trees, cabins, and homesteads, would be protected from fire. Fire-sensitive sites would be protected using 

a variety of methods, including but not limited to: removing fuels, foaming wooden structures, 

constructing firelines around structures, backfiring, and avoiding burning near sites if no other means of 

protection can be accomplished. Fire control lines (handlines) would be located such that they do not 

disturb archaeological features.

Sites with non-flammable resources, including those with stone or metal artifacts, would be 

considered for prescribed burns. It is not anticipated that significant fire effects would occur to sites with 

non-flammable resources during a low-intensity prescribed fire. These sites would be included in 

prescribed burning where the forest heritage program manager anticipates that work can be conducted 

without causing significant impacts to the site, utilizing On-Site Historic Property Protection Measures 

(specified in the R5 PA). All work within site boundaries would be monitored by Forest Service 

archaeologists and/or tribal representatives.

Burning could indirectly create a higher susceptibility to erosion if a substantial amount of plant cover 

(i.e., grasses, forbs, pine duff) is burned off the archaeological sites. However, reducing fuel loads and 

implementing low- to moderate-intensity prescribed burns does not cause soil sterilization or hydrophobic 
Chapter 3. Environmental Consequences

130 – Somes Bar Integrated Fire Management Project

soils (as do high-intensity wildfires). Low-intensity prescribed fires leave some vegetation in place and 

re-vegetation occurs soon afterwards if soils are not sterilized. The overall effect to the archaeological 

sites from loss of plant cover is expected to be minor and short term because vegetation would be 

expected to regrow across the sites quickly and in a way that enhances their cultural uses.

Temporary roads and landings

Every effort would be made to utilize existing temporary roads, skid trails and landings to minimize new 

ground disturbance. Intensive surveys were conducted for all proposed temporary roads and landings. No 

new temporary roads or landings shall be allowed within site boundaries.

Road repair

Road maintenance has the potential to affect cultural resources similar to those mentioned above for grounddisturbing activities in general. Intensive surveys were conducted along all major roadways, especially on 

egress/ingress routes. All of these potential effects are addressed through site avoidance strategies and 

implementing site protection measures. As such, the potential effects are not considered adverse.

Legacy road sediment source treatments in project area

Several previously used temporary logging roads in the project area have been identified as active/chronic 

sediment sources in the Ti Bar and Donahue project areas. These locations would be treated with heavy 

equipment to promote positive drainage of the old roadbed and to physically block motor-vehicle use. No 

heavy equipment shall be allowed within site boundaries.

Water Drafting

In support of fuel reduction treatments, drafting would be not occur in occupied coho streams segments 

with required fish screens at appropriate drafting sites. No heavy equipment shall be allowed within site 

boundaries.

Handlines

Fire control lines (hand lines) shall be located such that they do not disturb archaeological features. All 

fire control lines along ridges, and other high probability areas for sites, were intensively surveyed. If 

additional fire control lines are necessary, fire personnel would work closely with the heritage program 

manager to determine whether field verification is needed prior to implementation.

Cumulative Effects

When considering past, present, and foreseeable future actions (e.g., mechanical cutting, prescribed 

burning, etc.), all of the action alternatives have the potential to increase the amount of ground-disturbing 

activities and prescribed fire across the landscape. Past and present projects that are in and around the 

current project footprint include Roots and Shoots Cultural Burn Project (Roots and Shoots Project)), 

Orleans Community Fuels Reduction Project (OCFR), and Katimiin Thin Project. The only known future 

project is the Six Rivers Aquatic Restoration Project (Aquatic Restoration Project), which is under 

development. Within the project area, most actions are within the active stream channel and or surveys 

would be done to prevent effects to cultural resources. All past, present, or foreseeable future 

undertakings that have the potential to affect cultural resources and TCPs have gone (or would go) 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 131

through the NHPA §106 process. Mitigation measures have been or would be implemented to keep 

ground-disturbing activities out of site boundaries; fuels reduction treatments have been or would be 

implemented to minimize fire effects on archaeological sites and TCPs during prescribed burns. As such, 

the potential cumulative effects on cultural resources and TCPs are not considered adverse. In fact, ongoing and future collaborative-based ecological restoration projects would benefit the cultural resources 

across the larger landscape.

Fire and Fuels

Overview

The purpose of this section is to explain the effects of the Proposed Action from a fuel management 

perspective, while equally addressing effects of a “no action” alternative. Both the affected environment and 

the results of the proposed actions would be examined through qualitative as well as quantitative descriptions.

The project area encompasses four (4) project areas, which would be referred to as Ti Bar, Patterson, 

Rogers Creek, and Donahue. All of the project areas are within lands designated in the KNF LRMP as 

Wildland Urban Interface (WUI). These areas range in elevation from approximately 2,618 feet at the top 

of the ridges down to around 984 feet at the bottom of the lowest proposed units. The different elevational 

gradients, aspects and past management activities, are generally all the conditions which have developed a 

variety of species compositions. Existing vegetation can be described as diverse depending on a 

combination of site conditions (biophysical settings) and past management history. One commonality that 

all areas share is their lack of wildfire occurrence and absence of fire process in individual ecosystems.

The diversity of stands in the project area can lead to a variety of fire behavior effects (elevated potential 

fire hazard) but overall they are dense in conifer species and represent high levels of competition (see 

Vegetation section for more information). Each stand type promotes different fire behavior characteristics, 

which would be examined in detail in the following Existing Condition section. One goal for the project 

areas would be the development of strategic control features, in addition to key ridge features and 

established road systems, in order to reintroduce fire on the landscapes and achieve desired effects.

Fire modeling of current conditions for the project areas show the potential of high fire hazard (the 

hazard ranges from low to high but there is a significant percentage of moderate to high). Recent fire 

history, in areas with conditions similar to those within the project area, has resulted in 

uncharacteristically large wildfires that demonstrate negative stand replacing fire effects. Therefore, 

management action must be taken to alter the potential fire effects by thinning and burning in order to 

reduce fuel loading and improve the growing condition of the residual stands. Small steps are being taken 

on private land working with landowners and The Nature Conservancy to reintroduce prescribed fire 

using the model of the Prescribed Fire Training Exchange (TREX) program but these efforts stop at the 

jurisdictional property boundaries. The Somes Bar Project would aim to blend treatments on federal land 

with treatments conducted on private lands through TREX efforts or others in an effort to build resiliency 

at local as well as landscape scales.
Chapter 3. Environmental Consequences

132 – Somes Bar Integrated Fire Management Project

Introduction

Across the project area landscapes, there is a variety of conditions present. Some stands are densely 

stocked plantation stands where other areas have large dominant hardwoods, which have a thick 

component of conifer in the understory. Douglas-fir, in some cases, has become the co-dominant species 

to the large hardwoods, outcompeting native species, which in turn affects their ability to survive and 

reproduce. In many instances, one can observe large hardwood CWD scattered on the forest floor, which 

has succumbed to death as it was outcompeted for sunlight or nutrients by fast growing species. The 

common factor that all areas share is that they have not seen fire as a process in the ecosystem for nearly a 

century and the buildup of fuel (both living and dead) has created dangerous conditions pertaining to 

potential wildfire ignitions.

Existing Condition

The project area lies in the heart of the Klamath Mountain region. The Klamath region is noted for its 

high diversity of conifers and unique mixtures of taxonomic species (Whitlock et al. 2003). Fire is 

recognized as a keystone process that has influenced the composition, structure, and heterogeneity of 

forested landscapes in the western North America for millennia (Swetnam 1993, Whitlock et al. 2003, 

Scholl and Taylor 2010). While fire represents one of the greatest threats to public safety due to the 

excessive amount of burnable materials available for ignition, it also represents one of the strongest allies 

in efforts to protect and sustain human and natural resources in California (Taylor and Skinner 2003).

Residents and visitors alike are well aware of the threats posed by both natural and human ignited 

wildfires and any ignition in the forest today poses a threat to a multitude of values at risk.

Historically, wildfire and cultural burning have played major roles in the development and 

maintenance of our local ecosystems. Wildfire is often the primary natural disturbance influencing 

vegetation structure, species composition, soil properties, nutrient cycling, and ecosystem processes 

(Odion et al. 2004). Most native plants evolved with fire and many are adapted to or dependent on fire’s 

periodic occurrence. However through the exclusion of fire (cultural burning), more fire prone species 

have become established encroaching in on more fire adapted native species or the sheer abundance of 

individuals have created a situation where there is no longer a process regulated by natural disturbance 

events that maintain historic pre-European conditions (Hessburg et al. 2015).

On the Ukonom and Orleans ranger districts (RD), lightning along with cultural burning has shaped 

the mixed coniferous, hardwood forests and woodlands present today. However, the lack of fire as an 

ecological process within the project area boundaries has created high tree densities, elevated fire hazard 

risk and potentially high rates of mortality.

Fire Suppression

Fire’s role in shaping forest structure and composition changed in the mid-to-late 19th century with EuroAmerican settlement and then implementation of a federal policy of suppressing fire in 1905 (Agee 1993). 

Following the new fire suppression policy, the “10 a.m. rule” became the mantra of the Forest Service in that 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 133

any fire detected should be extinguished by 10 a.m. the following day. The elimination of fire in the wildland, 

especially the suppression of lightning ignitions, allowed the forest to become “unnaturally dense”.

Natural wildfires may have shaped the landscapes in western United States for millennia; however, the 

importance of utilizing and manipulating fire is one that seems to be just coming into a broader countrywide 

state of acceptance. Within the project area, this concept of restoring beneficial fire is one of the main goals 

of the WKRP collaborative group. However, before prescribed fire can play its natural/ecological role in 

shaping a more fire resilient landscape, many areas need to be thinned and ladder fuels reduced, utilizing 

tested fuel management techniques, before the reintroduction of beneficial fire can begin.

Analysis of the project areas indicate potentially hazardous conditions pertaining to anticipated fire 

behavior therefore steps need to be taken to minimize fuel loading and decrease the frequency of ladder 

fuels (small diameter trees and shrubs) before elements of resiliency can be restored on the landscapes.

Individual areas which have had various management actions in the past (i.e., extensive timber 

management versus no timber management) would be assessed for thinning treatment needs prior to 

understory burning so that desired fire effects may be achieved. An area’s current condition may also be a 

factor of growing conditions, aspect and elevation, how long fire has been excluded in its stand or the 

length of time since the last fire has occurred in the area.

The effects of reduced fire frequency have been greatest in forests with surface fires that had burned 

frequently. Excluding fires has increased forest densities, surface and aerial fuels, increasing the risk of 

large high-intensity wildfires, including crown fire (Scott and Reinhardt 2001). In recent years, some 

national forests across the nation have experienced more frequent fires exhibiting extreme fire behavior 

than ever before, in recent history. These large uncharacteristic high intensity fires demonstrate the need 

to take action quickly with a variety of mechanisms (mechanical, manual and prescribed fire) and develop 

landscapes and communities, which can become more fire resilient.

Within the project area boundaries, fuel buildups have become so great that many stands are 

unnaturally dense, as wildfires have been missing from the ecological equation for an extended period. 

This perspective is also a key component as to the selection of these areas for project developments since 

all factors point to the reality that a majority of ignitions occur in close proximity to urban areas, so it is 

just a matter of time and circumstance before an ignition within the landscape occurs. Prior to the recent 

history described, little information is available by the forest to describe what fire history was like in the 

Klamath Mountains. Large-scale wildfires prior the early 1900s are not well documented and much of the 

land was being managed with fire by Native Americans who inhabited the area.

Through incorporating information other than “western scientific studies” such as those gathered 

from TEK, we are able to better understand historic conditions from those whose families are 

practitioners of fire. Traditional ecological knowledge provides personal accounts of how landscapes were 

managed by fire through generational teachings, which passes the knowledge providing guidance on fire 

application. Cultural burning has long been a part of forest ecosystems in the Klamath Mountains and 

should be considered an embedded process in the historic fire regimes.
Chapter 3. Environmental Consequences

134 – Somes Bar Integrated Fire Management Project

Fire Regime

The fire regimes within the project area are extremely departed from their historic range. Fire exclusion 

and management activities have altered these fire regimes in many areas across the forest. During the 

period before significant European influence, natural fires and cultural burning in the Klamath Mountain 

region were generally low intensity, roughly between 10 and 35 years (USDA Forest Service 2003). A fire 

frequency study of the SRNF (Adams and Sawyer 1980) showed an average recurrence of lightning caused 

fires to be 16.2 years in mixed evergreen forests just south of the project area, on the Lower Trinity RD.

Local TEK indicates that more frequent burning occurred at lower elevations, where people inhabited 

areas manipulating the ground for multiple purposes, in order to control more of the annual fuels and 

higher elevations burned less frequently in order to maintain the landscapes. Lower elevations may have 

burned perhaps every 2 to 5 years where higher elevations may have been burned at a slightly longer 

interval such as every 10 to 35 years.

However, depending on site-specific considerations more frequent burning could have occurred to 

address needs on the landscape such as food, medicinal or basketry gathering sites or perhaps to address a 

different condition on a landscape. Pre-Columbian (indigenous) peoples fired along routes of travel, and 

they burned patches where flame could help them extract some resource—camas, deer, huckleberries, 

maize. The outcome was a kind of fire foraging, even fire cultivating, such that strips and patches burned 

as fuel became available. Places that escaped anthropogenic fire likely escaped fire altogether (Pyne 

2000). These types of fires produced fire effects of low to moderate severity throughout the ecosystem.

Figure 3-1 depicts recent fire activity across the project area according to ranges of time since last 

fire. It also shows that nearly no lands in the project areas have experienced a wildfire in over 95 years. 

There has been some recent prescribed fire activity, as noted, however this has been small scale and 

generally limited to private property. A large landscape surrounding the project area exists in the same 

condition. These areas, which have missed regular intervals of fire, are described as departed from their 

historic fire regime. Figure 3-1 further depicts these landscapes as an associated departure from their 

historic fire-return intervals.

When forests or stands do not undergo burning (either naturally or through prescribed fire), they 

develop characteristics such as the growth of more fire prone species or the forest fuel just continues to 

build and build. In determination of fire regime alignment with known historical ranges, areas are 

categorized by being of a specific condition class (Table 3-1). When an area misses a fire intervals, stands 

transition from those associated with their historic range (Condition Class 1) to those that are outside of 

their historic range and represent stands prone to larger fire growth potential (Condition Class 3). This 

concept is also referred to as the fire-return interval departure (FRID). The FRID analysis is a method for 

quantifying the difference between current and pre-settlement fire frequencies on a management 

landscape (Caprio et al. 1997).

The cessation of indigenous burning and the increase of fire suppression activities are thought to have 

affected the number of beneficial acres burned on the forest in the past 100-plus years, which infers that 

nearly all land in the project area are associated with Condition Class 3. By performing analyses of FRID 

conditions on the landscapes, land managers can determine specific areas of need to conduct fuels related 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 135

activities in order to mitigate associated fire hazards and provide ecological benefits to areas that may be 

at-risk of losing ecosystems components due to large-scale disturbances.

Another concept commonly used by the Forest Service especially in Northern California where 

weather precipitation can be more variable is the percent FRID or PFRID. Results utilizing the PFRID 

concept can help refine understandings of departures from pre-settlement fire regimes across large 

landscapes in a fire-prone region. PFRID metrics quantify the extent in percent to which contemporary 

fires (i.e., since 1908) are burning at frequencies similar to the frequencies that occurred prior to EuroAmerican settlement (Safford and Van de Water 2014). These PFRID metrics are associated with positive 

and negative condition classes, which show a range of departure based on the fire return interval (Figure 

Figure 3-1. Recent fire activity (1909-2016) near the project area showing time 

since last fire (including prescribed fire).
Chapter 3. Environmental Consequences

136 – Somes Bar Integrated Fire Management Project

3-2). These percentage-based measures are less sensitive to the incidence of a single fire, and are more 

suitable to comparisons of fire frequencies over time between the current and pre-Euro-American 

settlement periods (Safford and Van de Water 2014).

Both FRID and PFRID are determination assessments, which pertain to an areas alignment with their 

known historical or measured fire regime. Accordingly, a goal of this project is to work to restore 

landscapes to condition classes, which mirror their historic fire regimes. Fire regime condition classes 

(FRCC) are described in Table 3-1.

Table 3-1. Descriptions of fire regime condition classes (FRCC).

Condition Class Fire Regime

1 Fire regime is within historical range and the risk of losing key ecosystem components is low.

2 Fire regimes have been moderately altered from their historical range. The risk of losing key ecosystem 

components is moderate. Fire frequencies have departed from historical frequencies by one or more 

return intervals.

3 Fire regimes have been significantly altered from their historical frequencies by multiple return intervals.

Across the SRNF (including Ukonom RD as part of the KNF), the fire regime is historically described 

as one of frequent fires and mixed severity as recent tree-ring data indicate median fire intervals of 

generally less than 35 years (Adams and Sawyer 1980). Typical burns have been generally frequent, 

occasionally large, and generally low or moderate-intensity surface burns (Whitlock et al. 2003). Highest 

severity fires have historically occurred on the upper slopes and ridges, whereas less intense fires have 

occurred in the lower to mid ranges. Generally speaking, fire frequency and occurrences in northwestern 

California increases from west to east and from higher to lower elevation but this is also a factor of causal 

ignitions as high frequency lightning years like 2008 alter this concept dramatically.

Occasional patches of high severity most likely occurred, but these would have mainly been limited 

to the upper ridges, where the conditions of fuel loading and arrangement aligned with other favorable 

conditions such as wind and aspect. Douglas-fir/tanoak stands generally exhibit a moderate-severity fire 

regime with periods of high-severity fires. This is evident by examining areas of recent wildfire 

occurrence throughout the Orleans and Ukonom RDs as well as adjacent forests with similar fuel types in 

the Klamath Mountains. Tanoak have adapted to low-moderate severity fire with epicormic sprouting and 

basal sprouting following high intensity fire (Jimerson et al. 1996). The frequency of multiple stem 

tanoaks are high to extremely high throughout the project area and this has led to some widespread 

continuous fuel ladders. Research indicates that hardwood management is needed to address this by 

thinning less dominant stems in order to reduce the individual stem competition and promote mature 

stems for acorn production.

The role fire plays in an ecosystem is characterized by the fire regime attributes that describe the 

pattern of fire occurrence, behavior, and effects. Desired conditions for these attributes would be further 

discussed in this document. Variation in fire severity has an important influence on forest heterogeneity 

because fires may kill all trees in some stands and few in others. Stand development after high-severity fire 

leads to even-aged or several-aged stands, while forests that experience low- or moderate severity fires 

have trees in many age classes because few trees are killed in a stand (Agee 1993, Scholl and Taylor 2010).
Chapter 3. Environmental Consequences

Final Environmental Assessment – 137

Figure 3-2 depicts the existing conditions for the project area in regards to their alignment or 

departure from the associated fire return intervals. When natural ignitions (or ignitions in general) are 

suppressed and the role of fire is not allowed to interact with the landscape, fuels buildup until some 

action is taken to decrease their density such as prescribed fire or mechanical treatments. A primary goal 

in this project’s vegetation management strategies is to reintroduce fire on the landscape to allow areas to 

burn more frequently so that their conditions can resemble those with closer historical regimes.

Figure 3-2 displays positive condition classes apply where contemporary fire frequencies are less than 

pre-settlement frequencies (Hann and Strohm 2003); negative condition classes apply where 

contemporary fire frequencies are greater than pre-settlement frequencies (Safford et al. 2011). Therefore, 

Figure 3-2. Project areas depicting mean pre-settlement fire-return interval departure.
Chapter 3. Environmental Consequences

138 – Somes Bar Integrated Fire Management Project

areas that have seen recent fire activity can be seen in yellow hues and areas, which are more departed 

from pre-settlement frequencies, are seen in more of a red hue. One should note that areas indicated in 

green also depict those that are associated with a high departure from known historic pre-settlement 

frequencies as there have been frequent overlapping wildfires in the recent past. The mapping base was 

the Forest Service existing vegetation (EVEG) geodatabase, which uses the CALVEG13 classification. 

Most of the data used came from composite dendrochronological fire histories including records from 

multiple trees in a defined area (Safford and Van de Water 2014).

Comparisons between historical and current fire regimes provide information to managers in 

prioritizing areas for ecological restoration and other management actions. This type of FRID analysis 

quantifies the difference between current and pre-settlement fire frequencies (prior to Euro-American 

settlement), allowing managers to target areas at high risk of threshold-type responses owing to altered 

fire regimes and interactions with other factors (Safford and Van de Water 2014). This information could 

also be used to identify places, which may be more prone to vegetation type conversions in areas, which 

have burned recently at higher fire severities.

As you can see from the figure above, there is a clear illustration that the process of fire has been 

absent on the landscape for a long time. One can observe this by looking at the area in the southeastern 

corner of the map where recent wildfires have occurred just outside of the project boundary. These 

wildfires, some overlapping as can be seen in the green color, have brought the frequency of the fires to 

align with the historic fire regime of the area according to the associated fire regime condition class.

Methodology

The following subsections discuss the scope of analysis, methodology, and indicators to assess the 

environmental consequences of the alternative on fire and fuels for the project area.

Modeling for Potential Fire Behavior Risk and Fire Effects

Modeling of potential fire behavior and the resulting intensity/severity of such fire behavior requires 

several inputs for calculation. These include, but are not limited to, fuel, weather and topographical 

conditions of the area being analyzed. Fuel and weather conditions can change slowly over time and 

space or can change rapidly. For this analysis, conditions were held constant and were based on what are 

considered the 90th-percentile wildfire weather and fuels conditions for the project area. While these 

conditions represent a high percentile observation, it is important to note that the conditions are defined in 

this fashion because they are only observed up to 10 percent of the time. For weather, it pertains to hot, 

dry conditions and for fuels, it pertains to a low level of fuel moisture.

The program Fire Family Plus (version 4.2) was also utilized to examine weather in order to show 

local wind and weather observations. Ninetieth-percentile fuel moisture variables were derived from Fire 

Family Plus, which described the conditions represented on a hot summer day. Weather variables such as 

temperature, relative humidity and wind were derived from a nearby Remote Automated Weather Station 

 13 CALVEG classification is a provisional system that meet regional and nation vegetation mapping standards that further categorize 

existing vegetation (EVEG) boundaries for ecological tile units by incorporating Ecological Units of California into the database layer.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 139

(RAWS) located in Somes Bar, which analyzed hourly weather data from 1993 through 2016 and a single 

day was chosen to utilize weather observations. For this analysis, a weather and wind file was developed 

from August 1 to August 31, 2008 with a date of August 31, 200814 chosen to depict the outputs.

Fire behavior modeling was done utilizing the program FlamMap 515 and ArcMap 10.3 in order to 

analyze and estimate the current fire hazard condition potential (in relation to predicted fire behavior) if a 

fire were to occur in certain areas during a specified set of weather conditions. The fire modeling process 

was performed in order to depict potential burning conditions incorporating existing vegetation data from 

the program Landfire16. The combination of these programs is commonly used to derive a landscape 

perspective of potential fire conditions.

The following 90th-percentile weather conditions were used to describe fuel conditions:

o 1-hour fuel moisture: 3

o 10-hour fuel moisture: 4

o 100-hour fuel moisture: 8

o Herbaceous fuel moisture: 30

o Live woody fuel moisture: 70

A variety of other factors (which would be later discussed in detail) would also be considered prior to 

unit implementation, however by first considering risk on the landscape, we should have a solid starting 

point to which we can apply other pre-implementation prioritization criteria.

The analysis of weather and fuels inputs generated files, which were integrated into FlamMap to 

analyze the associated characteristics of wildfire, which were simulated on the landscape. The fire 

behavior conditions, known as indicators, relate fire behavior aspects as a certain type of fire hazard, 

which would be present. These indicators assist in planning efforts to appropriately determine the types of 

suppression resources needed to safely manage an ignition under the given circumstances. In order to 

assist with planning implementation factors, fire modeling of the project areas was buffered by a half mile 

distance to identify where treatments could potentially provide better initial effectiveness and also to 

provide for some unit prioritization by first considering current risks on the landscapes (Figure 3-3).

Fire hazard indicators were modeled (Table 3-2) in terms of rates of spread (ROS) and flame length 

(FL), which were calculated based on inputs of fire behavior fuel models, canopy characteristics (for wind 

reduction), topography (elevation, slope and aspect), fuel moisture conditions, and weather. Flame length 

and rates of spread are known critical factors in determining the effectiveness of suppression resources.

These fire behavior outputs are related to suppression effectiveness in terms of whether hand crews, 

equipment, or aerial attack can successfully suppress the wildfire. Figure 3-3 demonstrates the potential of 

fire suppression as it relates to the existing condition within the project area in terms of fire behavior 

potential (or fire hazard rating on the associated maps).

 14 This date coincides with a recent fire run on a local wildfire, the Mill Fire, on the Six Rivers National Forest. 15 FlamMap 5 simulates thousands of wildfires on the landscape given vegetation and environmental inputs. 16 Landfire is a program that provides over 20 national geo-spatial layers (e.g., vegetation, fuel, disturbance), databases, and ecological 

models that are available to the public for the US and insular areas. Available at www.landfire.gov.
Chapter 3. Environmental Consequences

140 – Somes Bar Integrated Fire Management Project

Table 3-2. Relationship of surface fire flame length and fireline intensity to suppression interpretations17.

Fire Behavior 

Potential ROS (ft/min) ROS (m/min) FL (ft) FL (m) Suppression Effectiveness

Low 0-11 0-3.3528 0-4 0-1.2192 Handcrews (Direct attack)

Moderate 11-22 3.3529-6.7056 4.1-6 1.2093-1.8288 +Engines/Watertenders (Direct with 

equipment)

High 22-33 6.7056-10.0584 6.1-8 1.8288-2.4284 +Aerial Support/Dozers (Direct/Indirect 

with equipment including aerial support)

Very High 33+ 10.0584+ 8.1-11 2.4284 +Aerial Support/Dozers (Indirect only)

 17 Fire characteristics charts such as this are intended to illustrate fire behavior characteristics from values calculated by computer 

programs such as the BehavePlus fire modeling system.

Figure 3-3. Project area associated hazard assessment rating (FlamMap 

wildfire modeling).
Chapter 3. Environmental Consequences

Final Environmental Assessment – 141

Predicted fire behavior was variable across the landscape from low to high, however analyzing the 

graphic depiction of the modeling showed pockets of potential high fire behavior in concentrated areas. 

Roger’s Creek had the highest rate of high fire hazard within the project area, but Donahue depicted the 

highest amount of high fire hazard potential just outside of the project area boundary. Additionally in the 

Ti Bar area, a pocket of very high fire hazard is shown just outside of the project area boundary to the 

south. These assessments of fire hazard areas would be taken into account during project priority area 

determinations.

Assessment of Fuel and Forest Structure

Stand exam data taken across the project area was uploaded into the model program FS Veg where an 

analysis of forest stand characteristics could be determined by utilizing the Forest Vegetation Simulator 

(FVS) as well as the Fire and Fuels Extension (FFE). The FVS provides analysis based on stand inputs to 

determine structure across large areas; however, these outputs homogenize large areas and do not necessarily 

take into account individual unique characteristics. The outputs tend to be limited by the quantity of gathered 

data; however, the program also serves as a platform for performing stand growth determinations.

Another aspect FVS provides is a determination of potential stand mortality18 on a percentage of 

basal area basis. One note to make here is that a large percentage of basal area can be represented by 

either one (1) large tree or many smaller trees. The expected change in basal area mortality following the 

various treatments can be seen in the analysis below.

The environmental variables depicted in Table 3-3 were input into fire modeling programs to 

determine effects of the Proposed Action (prescribed fire only inputs) and the No Action Alternative 

(wildfire 90th percentile).

Table 3-3. Environmental inputs used for FVS fire modeling—WKRP fuel modeling parameters (FireFamily

Plus Output).19

Environmental Factor Wildfire (All Months)

90th Percentile

Prescribed Fire Only (10/1 to 6/30)

90th Percentile

Temp Max 95 85

RH 19 22

Wind 8 8

1-hour fuel 4 4

10-hour fuel 5 5

100-hour fuel 8 12

1000-hour fuel 10 10

Herb Fuel Moisture 4 30

Woody Fuel Moisture 70 70

Environmental Consequences

Current fuel loading conditions and associated (or anticipated) fire behavior within the project area is 

unacceptably high. This condition is due to multiple factors but the main factor is a lack of fire process on 

 18 Stand basal area mortality is an indicator of forest health. 19 Model outputs are compiled from 20 years of data from the Somes Bar RAWS.
Chapter 3. Environmental Consequences

142 – Somes Bar Integrated Fire Management Project

the landscapes for an extended period. The current conditions can lead to high severity wildfires could 

result in high rates of stand mortality. However, since there has been a lack of fire process for so long, 

dominant hardwoods have been succumbing to mortality and their numbers would continue to decline. By 

applying an adaptive management of prescribed burning and thinning actions on landscapes, conditions 

should change over time as the trajectory of the stand is altered. The adjustment of restoring the 

ecological balance by utilizing fire on the landscape may have short-term negative visual effects within 1

to 3 years, but over a long-term basis of perhaps 3 to 7 years, the response in individual stands should be a 

positive gain.

Restoring the process of fire as an ecological tool is key to the success of landscape treatment for this 

project and performing this action in combination with strategically placed treatments should provide 

acceptable levels of effects from the application of prescribed fire. Controlling the intensity and severity of 

prescribed fire application can be an extremely difficult task but through a detailed plan of action and analysis 

of fuels and weather conditions, successful results should be attained over time. Applying fire at differing 

intervals should achieve a variety of beneficial results and developing recurrence intervals should build 

resiliency to future wildfires while mutually benefiting multiple culturally and ecologically important species.

Alternative 1 – No action

Direct and Indirect Effects

Under the No Action Alternative, no initial or follow up fuel treatments would occur, thereby continuing 

to defer risk of wildfire into the future. The No Action Alternative would not change the current 

conditions in the project area and therefore would not support the project’s purpose and need. There 

would be no direct effects on fire behavior specifically to the fire intensities and potential flame lengths or 

improvement on the growing conditions of dominant hardwoods. Additionally, there would also be no 

direct effect to address the existing fuel loading conditions especially those immediately adjacent to 

private property, as resiliency would not be built on the landscapes.

Forest resiliency to wildfire in the project area would continue to decline and accordingly, through the 

coming years, mortality of large hardwoods would generally increase in stands, which would in turn 

increase the fuel loading. No fuels treatments would occur under the No Action Alternative including the 

extremely valuable strategic fuelbreak construction intended to surround the communities. Most 

importantly, the process of fire would not be restored back onto landscapes, which have been missing that 

as an ecological component. Fire return intervals could continue to become more and more departed. As 

Figure 3-2 shows, a large area is already in Condition Class 3 and these areas are at risk of losing key 

ecological components as Table 3-1 describes. By not taking action on the project landscapes, continuing 

a lack of fire process would drive stands further and further from their historic conditions. This in turn 

would impact their ability to build resiliency function such as encouraging the development of fire prone 

species, which can shade out native fire adapted species.

Natural fuel accumulations would continue to increase as more trees begin to succumb to overcrowding, 

drought, insect and pathogens thereby increasing the rate of mortality. These natural processes that would 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 143

eventually occur instead of the controlled processes of thinning and prescribed fire application, which would 

lead to an increase in the amount of ground and surface fuels within the area. This additional accumulation in 

ground and surface fuels would gradually begin to shift the potential fire behavior in the area, to a more 

severe stature if a wildfire was to start. This increase could promote a more severe surface fire as the type of 

fuels changed from branches and needles (0- to 1-inch material) to the larger size material (3-plus inches) 

causing higher residence burning times20 and increased amounts of smoke production.

Fire Suppression

Due to the continued and potential increased threat to life and property, under Alternative 1, firefighting 

resources would continue to focus strategies and tactics on reducing the impacts of the communities, 

protecting infrastructure and private property as the highest priority followed by protection of natural 

resources. In fact, one could also argue that the threats would increase, as fuel loading would continue to 

build over time as forests continued to grow increasingly dense due to the continual lack of process to 

change stand dynamics.

As surface fuels continue to accumulate, with no additional management actions, suppression efforts 

would gradually become more difficult as wildfires could grow to larger unmanageable sizes more 

quickly. Therefore, direct attack in most cases could no longer be used as an initial tactic in suppressing a 

fire, and have to be changed to more indirect tactics, whereby more area has the potential to be affected 

by fire—in some cases, high intensity and more severe fire. With the increases in fire behavior generated 

by these surface fuel changes, fire suppression forces would have higher resistance to control due to fuel 

loading and by more intensive fire behavior. Aerial retardants would be less effective due to closed 

continuous canopies. If a fire were to start in or burn into the project area, ground and aerial initial attack 

operations as well as extended attack would become less effective and firefighter and public safety would 

be more difficult to ensure.

Fire Behavior and Fire Effects

Without the restoration of fire, forest health would continue on the current trajectory. Fire-adapted species 

would continue to flourish on the landscapes outcompeting more fire resilient species and native species, 

which are vital to many cultural perspectives. Historically non-native flora species would continue to 

present higher levels of stand densities and associated fire behavior potential representing higher fire 

hazards on the landscapes (Taylor and Skinner 2003). If a wildfire ignites in the project areas without 

action on the landscape, the ecosystem and communities would be subject to potentially stand replacing 

results as we have seen in recent years in the Klamath Mountains region.

Without frequent fire to clean the understory of stands, excessively dense stands lead to drought stress 

and bark beetle outbreaks, resulting in wide spread mortality of trees in many areas and the potential for 

extensive mortality. This leads to a large increase in the amount and continuity of both live and dead forest 

fuels, resulting in a substantial increase in the probability of large, severe wildfires (Weatherspoon 1996).

Table 3-4 and Table 3-5 from FVS depict the potential flame lengths and associated mortality 

depending on whether the stand was previously managed (plantation) or non-plantation.

 20 This term refers to the amount of time fire will burn in an area based on the amount of available fuel loading.
Chapter 3. Environmental Consequences

144 – Somes Bar Integrated Fire Management Project

Table 3-4. FVS current condition modeling of potential associated fire behavior in plantations—FVS output 

depicting potential flame lengths (No Action Alternative).

Year Average Flame Length (ft.) Average of BA Mortality (%)

2017 18.3 81

2022 17.8 86

2027 19.6 88

2032 19.3 91

2037 22.9 93

2042 16.5 92

2047 17.5 93

2052 17.7 94

2057 12.1 94

2062 11.5 93

2067 11.2 92

Table 3-5. FVS current condition modeling of potential associated fire behavior in non-plantations—FVS 

output depicting potential flame lengths (No Action Alternative).

Year Average Flame Length (ft.) Average of BA Mortality (%)

2017 7.3 49

2022 6.4 55

2027 7.2 60

2032 8.5 64

2037 9.5 67

2042 10.1 69

2047 10.3 69

2052 10.6 70

2057 10.8 70

2062 10.8 70

2067 9.9 69

As seen in the tables above, under the No Action Alternative, stand health would continue to decline 

as modeling shows gradual increases in basal area mortality through the next 50 years. The increase in 

mortality is a valuable indicator in terms of stand resiliency as it can directly pertain to multiple other 

conditions such as the potential fire behavior or the susceptibility to other disturbances such as insects, 

pathogens and disease. This course of stand trajectory could eventually lead to widespread stand 

replacement of most native species.

Additionally under Alternative 1, there would be no alteration/reduction in surface and ladder fuels, 

raising canopy heights and/or promoting fire resilient species or individuals, which would create more fire 

resilient stands. The associated fire behavior is already extremely high and over the course of continued 

no action, high severity stand replacing wildfires would dominate on the landscapes. Vertical continuity of 

fuels from the forest floor to the crowns of overstory trees would remain and under the right conditions 

could produce crown fire events. Fire hazard of late summer scenarios would also continue to present 

situations of high severity fires with potentially high rates of spread leading to high tree mortality rates 

and threats to rural communities.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 145

Recent Fire History Considerations

In the last 45 years, there have been over 2,900 fires on the forest. A large number of these wildfires 

occurred within about a mile from communities or next to major roads. Although most fire starts occur 

near human populations and thoroughfares, this is mainly due to the high rate of ignition occurrence. 

During this same timeframe, Ukonom RD has had a noticeably higher rate of lightning occurrence when 

compared to the Orleans RD (Table 3-6). The project area also seems to have a noticeably higher rate of 

lightning occurrence over the same period and this frequency is almost twice as much as the rest of the 

forest combined. Although the occurrence of human ignitions is of a higher rate, those ignitions have 

started wildfires outside of the project area of focus.

Table 3-6. Recent wildfire on the Six Rivers National Forest, lightning ignited compared to other starts.

District Fire Year Total # of Fires Lightning Fires % of Total

Orleans RD 1970-2015 558 139 25

Ukonom RD 1970-2015 340 206 61

All Districts 1970-2015 2,925 1,011 35

Lightning ignition occurrence has become more frequent across the forest in recent years. Lightning 

generally occurs in the “high country” far away from populated areas; however, in recent years (2006, 

2008, 2009, 2013 and 2015), lightning-ignited fires on ridges in some locations close to rural residents. 

These fires are difficult for land managers to handle since they have the ability to become larger fires due 

to factors, such as the fuel loading present and low values at risk, and since lightning is usually 

widespread and starts fires in a variety of locations.

Wilderness fires account for a large percentage of all acres burned on the forest lands over the last 45 

years and the amount of acres that have burned on the forest has been increasing dramatically in recent

years (Table 3-7). Wilderness fires can pose a risk to the nearby rural communities, as they grow 

uncharacteristically large due to the large amount of available fuel accumulations from years of fire 

suppression. These scenarios have presented strategic and tactical hazards for land managers due in part 

to limitations provided to firefighters by the terrain accessibility.

Table 3-7. Recent wildfire starts compared to total acreage burned.

Fire Years # of Fires Total Acreage Burned

2005-2015 693 355,459

1995-2005 800 91,151

1985-2005 826 18,450

1975-1985 691 2,178

Fire severity data is only available since 1984. Previous research does not show an increase in the 

percentage of high-severity fire between 1984 and 2008 (Miller et al. 2012). However, we do have 

evidence that the average size of fires is increasing over this same period (Miller et al. 2012, Odion et al. 

2004). This and other research has shown that severity trends correlate well with winter and spring 

precipitation amounts and temperature inversions during smoky conditions (Miller et al. 2012, Estes et al. 
Chapter 3. Environmental Consequences

146 – Somes Bar Integrated Fire Management Project

2017). The 2014 fires on the Klamath National Forest resulted in exceptionally large high severity patches 

and an elevated percent of high severity due to drought conditions and a general lack of inversion 

conditions that are characteristic of the Klamath Mountains (Ebert 2015).

Cumulative Effects

The fire danger is considerable and spreads throughout surrounding ridges of the Klamath Mountains. So 

due to the large scale of the present fire hazard and the potential spread of wildfire from outside the 

project area, the landscape or watershed scale within the project areas are used as the geographic 

boundary for cumulative effects analysis. Under the No Action Alternative, cumulative effects of the 

present and potential fire danger from both within the project area boundary and outside the boundary 

would continue to put human lives and property at a high risk of loss or damage from wildfire.

Tree densities across the project area range from those representative of historic frequencies to areas 

showing extremely dense conditions as seen in the Light Detection and Ranging (LiDAR map) products. 

These conditions are a vast departure from stand conditions of the past and can succumb quickly to largescale disturbances such as fire, insects, or disease. Forest debris accumulates more rapidly and species 

compositions have departed from historic conditions. As these landscapes have changed over time due to 

the absence of fire, the behavior of fire would also change accordingly hence the increased fire hazard. 

Smoke production from wildfires can emit extremely large concentrations of carbon into the atmosphere 

especially in areas with high fuel loading which have missed several fire return intervals (Figure 3-4).

During recent years, smoke from large wildfires became trapped in river valleys and remained for 

long periods. Smoke can impact different resources in various ways. For the effects of smoke on different 

resources see the following sections: Wildlife Resources (effects of smoke on NSO); Watershed Values

(effects of smoke on fisheries); Botany (effects of smoke on sensitive plants); and Social Environment

(effects of smoke on communities). Many environmental factors can contribute to the conditions when 

smoke inundates and subsists for long periods in drainages; however, there is a direct correlation between 

high levels of smoke production and high concentrations of fuel loading. This condition is observed 

during any year when wildfires burn for extended periods. In fact, smoke production can be so excessive 

that it lingers for months on end, which has been observed in many recent years.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 147

Figure 3-4. Recent fire history map of the project areas and surrounding landscapes.
Chapter 3. Environmental Consequences

148 – Somes Bar Integrated Fire Management Project

Particulate matter produced from wildland fires 

limits visibility and absorbs harmful gases. Over 90 

percent of the mass of particulate matter21 produced 

by wildland fires is less than 10 microns in diameter 

and over 80 to 90 percent is less than 2.5 microns in 

diameter (Figure 3-5). Under the No Action 

Alternative, smoke production from wildfire events 

would also continue to be excessive and river valleys 

would continue to become inundated with wildfire 

smoke. Local wind inversions can cause this dense 

smoke to become trapped for extended periods. This 

smoke can also heavily impact coastal communities 

when winds develop out of the east in an off shore 

pattern development.

Alternative 2 – Proposed Action

Direct and Indirect Effects

Under this alternative, preparing landscapes to allow for the return of fire back onto the landscapes for 

recurring intervals and restoring fire back on the landscapes should revive aspects of health and diversity 

that have been missing for decades. Through the careful, methodical application of combinations of 

thinning and prescribed burning, the health and function of forest ecosystems across the landscapes 

should be improved both directly and indirectly. Modeling shows that treatments would reduce overall 

basal area mortality (see Table 3-8 and Table 3-9) within stands. Creating species preference lists 

pertaining to increasing diversity on landscapes would also ensure a successful outcome pertaining to the 

implementation of thinning prescriptions.

Restoration efforts to reintroduce fire back on the landscape should increase the abundance of 

understory forbs, which in turn would have a positive reproductive effect response of many of the 

identified TEK fauna species. By focusing treatments on improving conditions of culturally significant 

flora species (hardwood restoration elements) and retaining larger trees, we should simultaneously see 

improved conditions for the identified focal species as well as reduced risks on the landscapes close to 

communities. A management strategy that includes methods for increasing forest heterogeneity at 

multiple scales would improve habitat quality and landscape connectivity (North et al. 2009).

In addition to promoting more fire resilient trees, prescriptive treatments would be accomplished to 

treat activity fuels from thinning by either hand pile burning, understory burning or a combination of 

both. Understory burning treatments would also occur in areas identified as culturally important for 

collection of other forest products such as for traditional foods or medicines. By applying recurrent fire 

 21 Particulate matter refers to any liquid or solid particle. They generally range in size from 0.1 to 100 microns. PM 2.5 is a measure of 

fine particles of particulate matter that come from fuel combustion. Often called respirable particles, as they are more efficient at 

penetrating lungs and causing damage.

Figure 3-5. Relative sizes of beach sand, flour and a 

PM 2.5 particle in smoke.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 149

back into the ecosystem, creating greater ecosystem and community resiliency to wildfire, hopefully in 

the years following treatment, incident commanders of future wildfire occurrences both in and adjacent to 

the project area may allow naturally ignited fires to play more of an ecological role and burn to 

established strategic fire control features22 for the project.

Fire Behavior and Effects (Forest Vegetation Simulator and Behave Models)

Under the Proposed Action Alternative, fire effects both prescribed fire as well as wildfire would change 

through the years following thinning and burning treatments. In the short term of 1 to 3 years, we should 

see an immediate reduction in hazard risk. Over the course of the longer term (5 to 10 years), we would 

potentially see a decrease in fire behavior, especially pertaining to any wildfire ignition. Depending on 

time of year during ignition (weather and fuels conditions), prescribed fire effects would be variable on the 

landscapes and would ultimately align with objectives associated with the identified TEK focal species.

Allowable ranges for associated fire effects would have to be developed during the life of the project 

and should be adaptable to change based on the refinement of monitoring criteria to be developed in the 

years following initial treatments. An example of “acceptable fire effects” to be determined may be the 

effective percentage of consumption pertaining to a specific vegetation component or an 

acceptable/desired range of severity from low to moderate. Following initial treatment monitoring, it may 

be indicated that an alteration to a firing pattern or seasonal component may achieve a higher level of 

desired effect in order to reach better outcomes. There may be a need to adaptively manage the usage of 

fire in future instances and this should be recognized as needed change to achieve the desired effect for 

the associated TEK species habitat elements.

The Forest Vegetation Simulator (FVS) program was utilized to perform modeling of stand effects from 

the project thinning and burning actions. This program uses environmental inputs as well as thinning 

parameters to apply a prescription to a homogenous stand and simulates the resulting change over time. The 

environmental inputs utilized for modeling fire effects are listed in the Methodology section. Thinning of trees 

under 6 inches in diameter was assumed to occur in 2018 with pile burning to occur in 2019. Understory 

prescribed fire was also factored into the model in years 2020 and 2027.

The FVS modeling (using the FFE) of the Proposed Action demonstrated dramatic changes in 

potential fire behavior over time in terms of flame lengths and anticipated basal mortality. The outputs in 

Table 3-8 and Table 3-9 should be compared with the outputs in the No Action Alternative. While the 

model tends to depict values higher than actual circumstances, the trends of a reduction in fire behavior 

and associated mortality are noticeable. The following tables depict the associated changes according to 

thinning and burning at various intervals.

 22Strategic fire control features are defined as areas, which can be utilized for control line purposes. Specifically: handlines built 

adjacent to private property or those that are designated to be a unit boundary, handlines built on ridge systems that may have a shaded 

fuelbreak component, handlines on previously disturbed ground (such as old skid trails or game trail), road systems that may or may 

not have associated fuels reduction and wet riparian areas that could halt the progression of fire.
Chapter 3. Environmental Consequences

150 – Somes Bar Integrated Fire Management Project

Table 3-8. FVS output showing impact of the Proposed Action on fire behavior in plantations—FVS output 

depicting potential flame lengths (within plantations, thin, pile, and burn in 2019).

Year Average Flame Length (feet) Average of BA Mortality (%)

2017 18.3 81

2018 8.3 68.8

2019 6.2 46.2

2020 6.3 50

2022 7.4 58.2

2027 4.2 48.7

2032 4.7 49.9

2037 5.3 56.2

2042 5.5 55.6

2047 5.7 54.7

2052 5.9 53.4

2057 6.3 53.6

2062 6.7 56.7

2067 7.2 60.8

Table 3-9. FVS output showing impact of the Proposed Action on fire behavior in non-plantations—FVS 

output depicting potential flame lengths (within non-plantations, thin, pile, and burn in 2019).

Year Average Flame Height (feet) Average of BA Mortality (%)

2017 7.3 49

2018 6.5 39.1

2019 3.7 29.9

2020 3.9 29.9

2022 4.4 35.2

2027 5.0 39.0

2032 5.4 41.5

2037 6.1 47.5

2042 6.4 49.2

2047 6.6 49.3

2052 6.6 48.9

2057 6.7 48.7

2062 6.8 48.6

2067 6.9 48.9

The effects within burn units should achieve patch-style dynamics according to burn plan prescription 

constraints. As mentioned previously, some mortality is anticipated to occur in regards to prescribed fire 

application but through preemptive actions such as thinning and pile burning, fuels pullback or other burn 

plan prescriptive elements, prescribed fire mortality levels should not reach unacceptable levels. By 

comparing the tables above with those included in the previous section under the No Action Alternative, 

you can see a clear improvement (reduction) in stand mortality as a result of the proposed actions. This 

reduction in mortality is a direct result of the change in growing conditions. Improving the growing 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 151

condition for dominant and co-dominant hardwoods, as well as increasing spacing between residual trees, 

is the overall goal for fuels reduction and fire effects.

Following initial thinning treatments of strategic features and priority treatment areas, an improved, 

reduced fuel load dynamic should allow for a reduction in potential negative fire effects. Lower flame 

lengths, lower fire intensities and shorter residence burning time should lead to a reduction in dominant tree 

mortality. Although a main objective is to create a patch-style landscape in order to increase heterogeneity, 

this condition would be dictated by site-specific conditions as well as associated harvest actions.

Various research supports this restorative type treatment by summarizing: a reasonable start is to put 

forest and woodland landscapes on a path to successional patterns and disturbance dynamics that reflect 

the natural disturbance regimes of regional and local landscapes (Swetnam et al. 1999, Keane et al. 2009,

Wiens et al. 2012), and allow the future climate to adapt them. To place landscapes on this path, pattern 

modifications across scales would be needed in areas where past management alterations are greatest 

(Hessburg et al. 2015).

Treatment units in this project can be generally described as a timber-understory fuel type model (TU) 

or a timber litter fuel type model (TL) with mixtures of a timber shrub (SH) component. These are fuel 

type model descriptions used in the Behave fire-modeling program. The primary carrier of fire in the TU 

fuel models is forest litter in combination with herbaceous or shrub fuels. The primary carrier of fire in 

the TL fuel models is dead and down woody fuel. Live fuel, if present, has little effect on fire behavior.

The effect of live herbaceous moisture content on spread rate and intensity is strong and depends on the 

relative amount of grass and shrub load in the fuel model (Scott and Burgan 2005).

The following fuel models were chosen to represent the project areas:

o TU5 (165) – Very high Load, Dry Climate Timber-Shrub

o TL3 (183) – Moderate Load Conifer Litter

Fuel model TU5 is probably most common currently on the project area landscapes; however, some 

stands represent fuel models TL3 as they have larger trees on the landscape. A note should be made 

however, in that a percentage of stands depicting TL fuel models also have a percentage of TU fuel model 

since they have not been maintained in quite a long time. This assumption would go into the fire behavior 

modeling and would change in time with pre and post treatments.

In general, a fuel model of TU3 has less fuel than fuel model TU5. This numerical relationship of fuel 

loading exists throughout the different fuel model classes. For the project area, TU5 was chosen for its

representation of understory fuels while TL3 was chosen for its representation of timber characteristics. As 

treatments occur over time, these fuel models are anticipated to transition to lower fuel model representations 

but for initial treatment modeling, a reduction in understory fuels was the only depicted change.

The following tables (Table 3-10 and Table 3-11) demonstrate the potential changes in fire behavior 

potential in stands as compared to current fire behavior shown in Table 3-4 and Table 3-5. Stands in the 

project area were shown to have a combination of fuel models (both TU and TL). For the initial pretreatment model, it was estimated that 60 percent of the stand represented TU5 and 40 percent of the 

stand represented TL3. This assumption remained for the post treatment model but the shrub fuel model 
Chapter 3. Environmental Consequences

152 – Somes Bar Integrated Fire Management Project

was changed from TU5 to TU2 as it is expected that there would be a reduction in fuel loading following 

initial treatment. The fuel model changes in composition predicted to occur through thinning and burning 

treatments (pre- and post-treatments are shown) were developed utilizing the program BehavePlus 5.0.4.

Table 3-10. Current fuel conditions in a representative previously managed stand (pre-treatment).

TU5 (60% of unit) and TL3 Fuel Model – Modeled Under 90th Percentile Conditions

Model Criteria Model Output

Surface Rate of Spread (chains/hour) 6.7

Flame Length (ft.) 7.6

Surface Intensity (Btu/ft./sec) 84

Transition to Crown Fire? Yes

Fire Type Torching

Table 3-11. Future stand condition following thinning and burning treatments (post-treatment).

TU2 (60% of unit) and TL3 Fuel Model – Modeled Under 90th Percentile Conditions

Model Criteria Model Output

Surface Rate of Spread (chains/hour) 7.3

Flame Length (ft.) 3.4

Surface Intensity (Btu/ft./sec) 84

Transition to Crown Fire? No

Fire Type Surface

As described previously, the fuel models are anticipated to transition from higher fuel loading (TU5) 

to lower fuel loading (TU2) and a reduction in potential fire behavior can be seen in the associated tables. 

The model predicted that flame lengths would be reduced by half and that the associated fire type would 

change “torching with a potential transition to crown fire” to “surface fire with no crown fire transition”. 

The potential surface rate of spread is depicted to be slightly higher than the current fuel model depiction 

(possibly due to a small shift in ground fuels) but the overall point to capture is the predicted reduction in 

associated potential flame lengths.

Treatment units adjacent to private property would be assessed for needs on the landscape and would 

receive acceptable levels of fuel reduction through either hand piling and burning of fuels, understory 

burning or both. These communities would become more fire resilient through years of thinning and 

prescribed burning treatments. Additionally, the roadside access/egress conditions would improve site 

visibility allowing safer passage as well as minimizing the potential for accidental roadside ignitions. 

Ridgetop connected treatments should also reduce the risk of wildfire crossing readily over those features 

and modify fire behavior over the broader landscape.

Overall, large areas would be treated to provide “modified” shaded fuelbreaks23 and defensible fuels 

profiles near key transportation corridors and within the zones of the WUI/intermix. By decreasing fuel 

ladders and reducing surface fuels, forest floors would be converted from ones that produce moderatehigh fire behavior to ones that produce moderate-low fire behavior.

 23 .A modified shaded fuelbreak is defined as a defensible location, where ground and ladder fuels have been modified, that can be 

used by fire suppression resources to suppress oncoming wildfires.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 153

Fire Suppression

The Proposed Action aims to reduce ladder fuels, which in turn increases canopy base heights. Canopy 

densities would be decreased through thinning activities and to a potentially noticeable extent, a reduction 

in fuel ladders would also occur through the same activities. These, in combination, would help to reduce 

rates of spread, flame length, fireline intensity, resistance to control and the potential for a ground fire to 

transition into a crown fire. The reduction in fire behavior indicators would occur over time and through 

multiple entries as the fuel models transition following thinning and burning by improving the resiliency 

of stands to large-scale crown fires (North et al. 2012).

If full fire suppression continues as the management strategy for unplanned ignitions within the 

project area, fire suppression resources would have an increased ability to control fires at initial attack 

with minimal risk to their safety and the public. Through the assignment of treatment activities, reduced 

fire severities should occur in the project areas increasing abilities to keep fires small with the use of 

direct attack or fire managers should be able to allow the fires to burn under appropriate conditions to 

strategic control areas. Decisions on how to manage a wildfire scenario are always made by determining 

the associated values at risk. The values at risk in an area associated with the protection of life, property 

and natural resources. A component that this project integrates is the assignment of thinning actions in 

order to develop strategic control features associated with values at risk.

By developing strategic control features, an additional level of consideration should be given to 

incident commanders when it comes to their decision process regarding suppression. Although there is 

widespread recognition to restore fire process on the landscapes, this concept is always a condition of 

associated values at risk such as private property infrastructure or other sensitive features that may dictate 

some form of suppression. Depending on the local values at risk, full suppression may always be the 

needed tactic when it comes to wildfire adjacent to private property.

Under this alternative, treatments are targeted to break up the horizontal and vertical continuity of live 

fuels to reduce the abundance of ladder fuels. By altering fuel continuity, elements intended to build 

resiliency to large-scale uncharacteristic wildfires can become restored on the landscapes. Through time 

as stands are manipulated to represent different characteristics, concepts of modified suppression tactics 

could more safely be employed by fire managers. These tactics could include utilizing a wildfire 

confinement strategy more often in times of unplanned ignitions. This strategy is widely utilized as a 

management option in certain areas (sometimes including the KNF and SRNF), however following 

treatments included in the Proposed Action, landscapes would be better prepared to show lower amounts 

of uncharacteristically high intensity fire effects during unplanned ignitions. In effect, treating stands on 

the landscape would more readily allow wildfire to burn to control features with minimal suppression 

activities utilizing more of a confinement strategy and allowing wildfire to act as an ecological process 

should not defer risk in the future, which often occurs under full fire suppression management.

Cumulative Effects

When considering the potential cumulative effects of the project, it would be most beneficial to think in 

terms of net value change. Actions associated with proposed treatments may pose a few temporary risks 
Chapter 3. Environmental Consequences

154 – Somes Bar Integrated Fire Management Project

in the short term, however these short term risks are far offset by the anticipated long-term gains 

following implementation. While the main anticipated direct effect is a positive in terms of aiming to 

reduce fire hazard risk by performing strategic fuel reduction activities and lowering fire behavior 

characteristics, some of the potential short-term indirect effects could be seen as negative effects. 

However, by conducting multiple treatments on landscapes and providing for a recurrence of prescribed 

fire, indications are that there would be a positive net value change over time. Another measure of success 

for recognizing positive change in the reduction of basal area mortality would be the observation of 

increased growth for dominant hardwoods or developing hardwoods as well as the increase in habitat 

elements for multiple species.

Small diameter basal mortality is the main negative cumulative effect pertaining to prescribed 

burning. This may be most evident along roadways and near private property. Although through 

conducting thinning actions prior to understory burning, we should be able to limit the frequency of these 

and create a better visual product. Thinning actions after prescribed fire entries may also be able to 

mitigate this visual effect. Fire-killed leaves and needles are a short-term visual indicator of mortality; 

however, in a one-year period following the entry, these fall to the ground lessening the visual effect.

Thinning action prescriptions that were developed focused on the improvement of living and breeding 

conditions for multiple species. The main goal is to reduce the fire hazard threat that currently exists while 

recognizing multiple habitats of species to improve. Limited operating periods for several endangered, 

threatened, or sensitive species should ensure that thinning and prescribed burning operations do not 

negatively impact reproductive seasons. Additionally, burn plan language would give clear resource and 

prescribed fire objectives to ensure that implementation actions would minimize resource concern elements.

Although smoke production from prescribed fires is very temporary in nature and light in duration 

compared to wildfire smoke (lasting a period of hours or days), it still can be a nuisance to those in close 

proximity. Prior to and during the implementation of burning, it is anticipated that smoke management 

techniques would be utilized in order to minimize emissions as much as possible. These techniques may 

include only burning concentrations of fuels in an area as an initial action, isolating fuels that may 

smolder for long periods, mosaic burning in areas of non-continuous fuels and/or mechanical removal of 

fuels (USDA Forest Service 2001).

Smoke production can become a limiting factor to achieve project accomplishment as air quality 

regulations exist which limit the amount of smoke that can be produced daily, however this may be more of 

a factor when multiple projects are going on simultaneously throughout the air basin. Long-term success for 

this project may lie in our ability to scale up during times of implementation and following initial entries, we 

should be able to achieve larger scale burning according to our strategic feature location designations.

Additionally, burn plan development would also include language on how to reduce smoke emissions, 

identify sensitive smoke receptors for notification purposes or indicate favorable wind directions for 

smoke transport. While this effect can be a localized impact, it would be very important to consider its

cumulative nature and address all potential impacts accordingly. Prior to the implementation of thinning 

activities, adjacent landowners should also be notified prior to activity and an implementation plan would

be developed to address this process.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 155

In consideration of additional projects within the project area boundaries, as well as those just outside of 

the project boundaries, this project is a direct compliment to other efforts. There is a recognition that fire 

danger exists well beyond the project boundaries (as well as on private inholdings) and providing for a 

connectivity of fuels reduction treatments aims to address that issue. Working across jurisdictional boundaries 

achieves the greater goal of the WKRP as well as aiming to achieve goals within the Cohesive Strategy.

By initially developing strategic fire control features of private property thinning, ridgeline fuelbreak 

construction and careful assessment of high fuel loading condition, we should be able to return fire 

successfully to the project areas. Once first-entry treatments of fire have occurred, second and third entry 

treatments may occur at larger scales due to previous reductions in fuel loading and decreased tree 

densities as well as the multiple established control line placement.

A key component to the success of this project would be monitoring effectiveness of actions following 

treatments. There can be a fine balance between too much action on the land and too little. Adapting our 

actions and learning to control the intensities of our actions should lead us to be able to better interpret 

long-range effects and outcomes. Through recognizing our need to have adaptive management on certain 

landscapes, we should be successful in finding an appropriate balance of cumulative effects for the project.

Lastly, one potential hurdle for this project may be the ability to accomplish large acreages of burning 

and the amount of smoke production, which may ensue. Landscapes in the project areas have not burned 

in roughly 100 years and returning the fire process must be well planned and thought out to ensure desired 

effects are achieved. Project treatment areas were developed to be of the smaller scale (averaging around 

40 acres in size) but the scale of the project may make it difficult to accomplish in a reasonable timeframe 

unless some larger acreage is accomplished annually.

Compliance with Forest Plan and Other Relevant Laws, Regulations, Policies and Plans

Project related fuels activities would adhere to all applicable relevant state and federal laws and 

associated provisions such as the Clean Air Act24 and Clean Water Act25.

All project related fuels activities would adhere to management direction standards and guidelines 

(S&Gs) provided within the KNF LRMP26 including actions associated within specific management areas.

All prescribed fire activities would be conducted in accordance under federal policy direction 

provided within the Forest Service Manual (FSM)27.

Vegetation

Introduction

The Proposed Action plans to increase landscape heterogeneity by management of topographically-driven 

treatment units and stand-level heterogeneity by integrating openings and retention patches into 

 24 Including provisions of the Clean Air Act, California’s Title 17. 25 In accordance with requirements of the Regional Water Quality Control Board, North Coast Region. 26 Klamath LRMP Forestwide Management Direction Chapter 4 (22-10 through 22-24). 27 FSM 5100, Chapter 5140.
Chapter 3. Environmental Consequences

156 – Somes Bar Integrated Fire Management Project

commercial thinning operations, in a way that would mimic patterns created by wildland fires (Hessburg 

et al. 2016; North and Sherlock 2012; Sherlock 2007). In addition, the Proposed Action calls for thinning 

from below (thinning smallest trees in a stand), both manually and mechanically; thinning throughout the 

diameter classes (with the exception of pre-dominant and dominant trees), mainly mechanically, but also 

using mastication in young plantations; pile burning and the use of prescribed fire.

Thinning from below increases the residual size of trees left in a stand (Agee and Skinner 2005; 

Smith et al. 1997). In general, larger trees have thicker bark, and are therefore more fire resilient than 

smaller trees. Thinning, whether from below or throughout the diameter classes (with the exception of 

pre-dominant and dominant trees), increases spacing and reduces stand densities, resulting in less intertree competition, which increases individual tree vigor, resulting in stands that are more resilient to

insects, disease, wildland fire, and drought (Agee and Skinner 2005, Fettig et al. 2007, Hessburg et al. 

2016, van Mantgem et al. 2009, Vernon 2017).

From a silvicultural standpoint, the Proposed Action would have many benefits to project area and 

human environment. These include 1) reducing stand densities and increasing the average tree size of 

residual trees, which, 2) increases tree health and vigor as well as insect, disease, drought and wildland 

fire resiliency; 3) maintaining and enhancing existing structural and compositional diversity; 4) increasing 

heterogeneity at the stand scale as well as at the landscape scale; and 5) increasing availability of a widevariety of forest resources for humans, plants, and wildlife.

The No Action Alternative would leave the project area in a continued state of overstocking and 

generally stagnant stand conditions in which the landscape is highly vulnerable to disturbance agents such 

as insects, disease, wildland fire, and drought. Fire suppression has resulted in uncharacteristically dense 

stands of continuous of conifer dominated forests across the landscape that are not commonly talked 

about in the oral histories of the area. Therefore, the No Action Alternative is not within the guidance and 

direction of the KNF LRMP or the Katimiin MOU.

Affected Environment

Approximately 26 percent (1,467 acres) of the project area consists of stands that were established after a 

previous regeneration harvest (clearcut) (Table 3-12). The Proposed Action proposal calls for commercial 

thinning of just under half (652 acres) of these stands, otherwise known as plantations (Table 3-13).

Table 3-12. Acres of managed stands by date of plantation establishment within each project area.

Project Area 1960-1969 1970-1979 1980-1989 1990-1999 Total Acres

Rogers 36 135 104 – 274

Ti Bar 81 35 14 8 137

Patterson 154 71 143 31 399

Donahue 345 44 267 – 656

Totals 616 284 528 39 1,467
Chapter 3. Environmental Consequences

Final Environmental Assessment – 157

Table 3-13. Acres of managed stands by date of plantation establishment by Proposed Action treatment type.

Treatment 1960-1969 1970-1979 1980-1989 1990-1999 Total Acres

Mechanical, Manual, Prescribed Burn 380 113 158 1 652

Mastication, Manual, Prescribed Burn 30 – 126 31 187

Manual, Prescribed Burn 162 126 199 6 495

Prescribed Burn 44 45 44 – 133

Totals 616 284 528 39 1,467

An additional 797 acres (14 percent) of the project area has had some previous silviculture activity 

(usually commercial or pre-commercial thinning). Approximately half (416 acres) of this area is proposed 

for commercial thinning (followed by manual fuels reduction and prescribed burning), and the remaining 

would be treated by manual fuels reduction followed by prescribed fire (379 acres) or prescribed fire only 

(2 acres). The remaining project area (59 percent) has no previous silvicultural activity, of which 157 

acres are considered for commercial thinning (followed by manual fuels reduction and prescribed 

burning) under the Proposed Action. The majority (1,778 acres) would be treated with manual fuels 

reduction followed by prescribed fire, or prescribed fire only (1,356 acres).

Certain species of trees are of particular interest to the WKRP collaborative and the Karuk Tribe, 

including deciduous hardwoods such as Oregon white oak, California black oak, certain evergreen 

hardwoods such as large acorn-producing tanoaks, large nut-producing giant golden chinquapin, large 

madrones, sugar pines, and the few scattered ponderosa pine. The majority of these tree species are 

considered early seral trees that are either fire-dependent or enhanced by fire. This is also reflected in their 

lower tolerance for dense stand conditions compared to Douglas-fir and white fir, which quickly crowd, 

overtop, and eventually kill many of these tree species in the absence of disturbance (Hunter and Barbour 

2001). There is extensive cultural, archeological, and scientific evidence that healthy, mature individuals of 

these tree species were present in much higher numbers within the project area than they are today prior to 

the occupation of these lands by Europeans and the subsequent establishment of the National Forest System 

(NFS) and fire suppression policy (Taylor and Skinner 2003, North et al. 2007, Crawford et al. 2015).

The collaborators in WKRP are committed at a basic level towards moving this landscape towards a 

condition where fire can be reintroduced as a management tool and a process, and restoring ecosystem 

function, among other goals. To accomplish these goals, stand densities need to be reduced to allow 

prescribed fire to move through plantations under desired conditions; the size of residual trees need to be 

enhanced to increase resilience in the case of moderate to high intensity wildfire; and the proportion of 

ecologically functional hardwoods need to be enhanced because of their unique adaptations to fire, 

including ability to re-sprout following severe wildfire (Cocking et al. 2012). To support total ecosystem 

function, a variety of stand conditions are needed, including patches of early-seral-like/open conditions as 

well as dense patches of conifers, conditions that support a wide-array of conifer and hardwood species. 

Given current conditions, silvicultural tools are critical to achieving collaborator goals of stand-level and 

landscape level heterogeneity and fire resilience, especially considering the length of time since the 

establishment of fire suppression (shade-tolerant encroaching conifers have now reached sizes that are not 
Chapter 3. Environmental Consequences

158 – Somes Bar Integrated Fire Management Project

possible to thin using manual fuels reduction and/or prescribed fire) and level of surface and ladder fuels 

that has accumulated over this time period.

Stand density index (SDI) is an established (Reineke 1933) measure of stand-level inner tree 

competition. Designed to measure competition in even-aged, single-species conditions, it is used widely 

by forest growth models to describe how stand density affects stand development and growth even in 

uneven aged and mixed stand conditions. The average size of trees in a stand can be looked at and 

assessed in terms of quadratic mean diameter (QMD) and how it changes through time. Looking at the 

percentage of basal area (BA) that is predicted to die as a result of a wildland fire under severe conditions, 

is a good direct indicator of forest resiliency. Therefore, reducing SDI, increasing the QMD, and 

decreasing the proportion of BA that is predicted to die in a severe wildland fire scenario in and across 

stands, are cause and effect indicators necessary to inform the decision.

Environmental Consequences

Methodology

Stand level data was collected during the summers of 2015 and 2016, in partnership with the Mid Klamath 

Watershed Council (MKWC) and the Karuk Tribe. Because of the large scale of the project, it was not 

feasible to collect stand level data for every stand in the project. The project area was stratified into 10 stand 

types based on management history, age/size class, and solar insulation. Representative stands from each 

strata were sampled. The larger the proportion of the area in a strata, the more plots were measured, with 

more preference given to those strata which contained stands that were most likely to receive mechanical 

treatment. No one strata had less than four (4) stands or more than 10 stands sampled. In total, 71 stands 

were selected for individual examinations, approximately 25 percent of the total stands identified.

All stand exams were conducted using the Common Stand Exam protocol. Both the Proposed Action 

and the No Action alternatives were analyzed using the Forest Vegetation Simulator (FVS), with the 

“Klamath Mountain Variant,” were used to evaluate the effects of time and treatments on vegetation over 

the next 50 years, starting in 2017. The Fire and Fuels Extension (FFE) of this model was used to predict 

potential fire behavior and fire effects to vegetation over the next 50 years, starting in 2017.

As with any model, FVS/FFE needs to be used with caution and an understanding of its limitations

and modeling assumptions. This model is not intended to provide absolute values for a particular set of 

circumstances, but is intended to provide valuable information for meaningful comparisons of 

alternatives. To simplify the display of analysis outputs, proposed treatment units have been broadly 

grouped according to their management history, proposed treatment type, and whether or not they involve 

commercial thinning. There are eight (8) general groupings presented and the corresponding initial entry 

identification as shown on the Proposed Action maps:

1. Managed stands with commercial timber and no significant pine component (1a)

2. Managed stands with commercial timber and a significant pine component (1b)

3. Natural stands with commercial timber (2)
Chapter 3. Environmental Consequences

Final Environmental Assessment – 159

4. Managed stands with manual treatment (4a)

5. Natural stands with manual treatment (4b)

6. Managed stands with mastication (3)

7. Managed stands with prescribed fire only (5a)

8. Natural stands with prescribed fire only (5a)

It is important to point out that there is considerable variation between the individual stands/units in 

each grouping specified above. Stands that were regenerated (clear-cut) are called managed stands, and even 

those natural stands that have had previous thinning, are called natural stands. A previously thinned natural 

stand has more in common with the structural characteristics of a natural stand with no management, than 

with a managed stand, sometimes also called a plantation. Therefore, when reviewing the analysis outputs 

for any of these groupings, one should realize that the numbers are averages for the entire grouping.

For the No Action Alternative, stand development and changes through time were modeled with no 

vegetative manipulations during the entire modeling period (2017-2067). For the Proposed Action, stand 

development and changes through time were modeled with the called for vegetative manipulations during 

the modeling period (2017-2067). For all groupings of stands, two (2) prescribed fires were simulated, in 

2027 and 2037; 2020 and 2027; or 2022 and 2030, depending on the prescription category (Table 3-14). 

Prescribed fires were modeled using 50th-percentile conditions (fuel moisture values, temperature, and 

wind speed) from nearby weather stations. Basal area mortality was also modeled from a severe wildfire 

event that could occur in any year. The basal area mortality graphs shown below display the result if a 

severe wildfire were to occur in any of the years displayed. Ninety-seventh (97th) percentile conditions 

(fuel moisture values, temperature, and wind speed) from nearby weather stations were used in the wildfire 

simulations. See Table 3-14 for the complete set of dates of simulated treatments used in the FVS runs.

Table 3-14. Year of activities modeled by FVS within each stand group.

Stand Grouping Commercial 

Thinning Mastication Manual Fuels Reduction Pile Burning Understory Burning

Managed stands with commercial timber,

no significant pine 2020 NA NA NA 2027 & 2037

Managed stands with commercial timber,

with significant pine 2020 NA NA NA 2027 & 2037

Managed stands with mastication NA 2018 2019 2023 2027 & 2037

Managed stands with manual treatment NA NA 2018 2019 2020 & 2027

Managed stands with prescribed fire only NA NA NA NA 2022 & 2030

Natural stands with commercial timber 2020 NA NA NA 2022 & 2030

Natural stands with manual treatment NA NA 2018 2019 2022 & 2030

Natural stands with prescribed fire only NA NA NA NA 2022 & 2030
Chapter 3. Environmental Consequences

160 – Somes Bar Integrated Fire Management Project

Alternative 1 – No Action

Direct and Indirect Effects

No direct effects would occur in choosing the No Action Alternative. All of the treatment groups presented 

start in 2017 with an SDI around 80 percent of the maximum for the site species, which is most commonly 

dominated by Douglas-fir, and do not change much through the 50-year modeling period (Figure 3-6

through Figure 3-13). Once a stand reaches 55 percent of the maximum SDI, the stand enters the ‘zone of 

self-thinning’ (Reineke 1933, Smith et al. 1997). At this level of inter-tree competition, trees in the stand 

compete heavily for light and resources, resulting in stressed trees and increased rates of mortality, which 

also results in increased surface fuel loading. This stage of stand development often lasts a century or 

longer (Oliver and Larson 1996). In mixed-severity fire regime ecosystems such as the Klamath 

Mountains, regular fire occurrence plays a role in maintaining appropriate forest densities and patch sizes 

during this period (Hessburg et al. 2016). However, little to no fire has occurred within our project area in 

the last century or longer, leading to the uniformly dense conditions present in these stands today.

Figure 3-6. Current and predicted percent SDI in plantations.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 161

Figure 3-7. Current and predicted percent SDI in natural stands.

Figure 3-8. Current and predicted percent SDI in natural stands.

Figure 3-9. Current and predicted percent SDI in plantations.

.
Chapter 3. Environmental Consequences

162 – Somes Bar Integrated Fire Management Project

Figure 3-10. Current and predicted percent SDI in natural stands.

Figure 3-11. Current and predicted percent SDI in plantations.

Figure 3-12. Current and predicted percent SDI in plantations.

.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 163

With currently high stand densities throughout the project area comes increased susceptibility to 

damage and mortality resulting from such stressors as insects, disease, fire, and drought (Agee and 

Skinner 2005, Condeso and Meentemeyer 2007, Fettig et al. 2007, Vernon 2017). Many trees are 

currently experiencing high levels of competition for soil moisture, nutrients, and available light. Natural 

self-thinning is occurring to some degree in almost every stand of the proposed project, and additional 

stressors can trigger pulses of significantly increased mortality. The SDI graphs illustrate the high levels 

of stand density and inter tree competition that is present in all of the treatment groups. Note these graphs 

show the maximum SDI in relation to species present, which is most often dominated by Douglas-fir. 

Species such as Ponderosa pine, sugar pine, and especially black oak and white oak, have even lower 

tolerance for stand density than Douglas-fir.

The No Action Alternative keeps stands along their current trajectory of being vulnerable to 

significant mortality during a wildland fire under severe conditions (Figure 3-14 through Figure 3-21). 

The fact that few of the graphs show a complete loss of basal area if wildfire occurs at any of the shown 

dates is because the model runs are based on averages across groups of stands, as opposed to individual 

stands themselves. Some stands would suffer stand replacing wildland fire under severe conditions; 

however, when taken into consideration and averaged across the proposed project area, these figures show 

that we do not expect uniform high severity fire effects across the landscape after a wildland event under 

severe, 97th-percentile conditions. Perhaps unsurprisingly, the brushiest managed stands are currently at 

the highest risk of significant mortality in these conditions (Figure 3-19). When evaluating the results of 

these fire simulations, it is also important to note that the project takes place on some of the more gentle 

slopes in the Klamath Mountains, as the project is centered on communities along the lower middle 

Klamath. More severe fire effects would be expected on steeper slopes typical of the Klamath Mountains, 

including in areas adjacent to the project area.

Figure 3-13. Current and predicted percent SDI in natural stands.
Chapter 3. Environmental Consequences

164 – Somes Bar Integrated Fire Management Project

Figure 3-14. Current and predicted BA mortality in plantations.

Figure 3-15. Current and predicted BA mortality in plantations.

Figure 3-16. Current and predicted BA mortality in natural stands.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 165

Figure 3-17. Current and predicted BA mortality in plantations.

Figure 3-18. Current and predicted BA mortality in natural stands.

Figure 3-19. Current and predicted BA mortality in plantations.
Chapter 3. Environmental Consequences

166 – Somes Bar Integrated Fire Management Project

It is noteworthy to point out that natural stands planned for commercial treatment show the lowest 

potential basal area loss under severe conditions (Figure 3-16). Those stands that are proposed for 

commercial thinning under the action alternative, have almost all been previously thinned from below, 

and therefore have a dense overstory canopy and very high canopy base height. The dense overstory has 

kept the ingrowth of brush to a minimum. However, these units are planned for site-specific treatment 

aimed at maintaining and enhancing trees of interest that are critical TEK resources and require less shade 

and more growing space. To no one’s surprise, young plantations are highly vulnerable to significant basal 

area loss in a wildland fire under severe conditions, and continue along that trajectory through time until 

stand densities are altered through some sort of disturbance (Figure 3-17, Figure 3-19 and Figure 3-20).

Cumulative Effects

Under the No Action Alternative, the only way that stand density would be affected is though disturbance 

such as insects, disease, wildland fire, snow down events, or drought. These disturbance events are 

Figure 3-20. Current and predicted BA mortality in plantations.

Figure 3-21. Current and predicted BA mortality in natural stands.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 167

inevitable, though management actions can lower the probability of widespread severe impacts from these 

events. Fire is a natural part of the ecosystem in the Klamath Mountains, and one look at the fire history 

of the area shows that it is just a matter of when a wildland fire would occur, not if. Under the no action 

alternative, a wildland fire under severe conditions could significantly alter the project area in terms of 

structure and composition, with stand replacing fire in many stands being a real possibility, as has 

occurred in recent years during wildfires in August.

Within the project area, there is already evidence of bark beetle activity. Western pine beetles 

(Dendroctonus brevicomis) were observed in plantations with a significant pine component in both Ti Bar 

and Donahue. Given current and future SDI predictions under the no action alternative (Figure 3-7) it is 

highly likely, if not inevitable, that we would see significant mortality associated with a bark beetle 

outbreak similar to what recently occurred in the Sierra Nevada Mountains.

Due to the high stand densities within managed stands and several recent years of lower than normal 

spring precipitation, conditions have been ideal for the spread and intensification of black stain root 

disease (Leptographium wageneri) by stressing the Douglas-fir trees and increasing insect vector 

abundance and activity (Angwin 2003). Increasing levels of black stain activity have been observed in 

plantations over the last 10 years. Under the No Action Alternative, the levels of moisture stress in 

Douglas-fir trees would continue to be high and this disease would continue to kill Douglas-fir trees on 

the edges of existing and newly established root disease centers. Because the local variety of this disease 

only affects Douglas-fir trees, and because there are many hardwood trees and occasionally other conifer 

species present, the cumulative effects from this disease in terms of future canopy cover, relative stand 

density, opening sizes, etc., would be insignificant.

Alternative 2 – Proposed Action

Direct Effects

The Proposed Action would directly affect the size and density of stands throughout the project area by 

lowering the SDI (Figure 3-6 through Figure 3-13) and increasing the QMD (Figure 3-22 through Figure 

3-29). The only treatment groups with a lower QMD overtime under the Proposed Action compared with 

No Action are managed stands that are to only be treated with prescribed fire and managed stands that are 

to be treated with mastication (Figure 3-27 and Figure 3-28). This is due to fact that in such small, dense 

stands, prescribed fire would kill trees in all diameter classes. If manual treatments were to be applied 

before the prescribed burning, those numbers would more closely resemble those seen in the managed 

manual stand group (Figure 3-25). Mastication also eliminates some larger trees; though none of the 

existing trees in these stands are very large (these are very young, brushy plantations). Although only the 

initial sequence of treatments proposed under this project were modeled, these figures illustrate the need 

for future management activities to maintain healthy stand densities and to continue to increase the 

residual size of trees through time, especially in managed stands.
Chapter 3. Environmental Consequences

168 – Somes Bar Integrated Fire Management Project

Figure 3-22. Current and predicted QMD (inches) in plantations.

Figure 3-23. Current and predicted QMD (inches) in plantations.

Figure 3-24. Current and predicted QMD (inches) in natural stands.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 169

Figure 3-25. Current and predicted QMD (inches) plantations.

Figure 3-26. Current and predicted QMD (inches) natural stands.

Figure 3-27. Current and predicted QMD (inches) plantations.
Chapter 3. Environmental Consequences

170 – Somes Bar Integrated Fire Management Project

The Proposed Action would also directly benefit the trees of interest to the collaborative (California 

black oak, Oregon white oak, golden chinquapin, large tanoaks, etc.). In plantations, larger hardwoods, 

both single-stemmed and larger stems in clumps, would be favored for retention and conifers thinned out 

around them to enhance hardwood growth while reducing stand densities. In natural stands, hardwoods 

over 24 inches in diameter at breast height (dbh) are usually the oldest trees in the stand. These trees were 

once the dominant or co-dominant trees in the stands before fire exclusion, but are now being 

outcompeted by conifers. Thinning around these remnant trees, many of which are being over-topped and 

shaded-out by faster growing Douglas-fir, would enable them to receive more light and grow fuller 

crowns, which would allow them to continue to persist in these stands (and thus continue to provide 

valuable structural habitat and diversity and maintain and support a healthy mixed-severity fire regime), 

increase their health and resistance to disturbance, as well as increase acorn production in true oaks, 

tanoak, and chinquapin (Devine and Harrington 2006, Engber et al. 2011).

Figure 3-28. Current and predicted QMD (inches) plantations.

Figure 3-29. Current and predicted QMD (inches) in natural stands.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 171

Indirect Effects

There are several beneficial indirect effects of implementing the Proposed Action. Decreasing stand 

densities would result in increased health and resilience as there would be less inter-tree competition for 

water, and light, and other resources (Smith et al. 1997). The resultant increase in tree vigor would allow 

for trees and stands to be more resistant to disturbance agents such as insects, disease, and drought (Fettig 

et al. 2007, Vernon 2017). Western pine beetles already present in the project area , they would continue 

to attack potential host trees, but healthier more vigorous trees have a far better chance of surviving an 

attack than those that are stressed (Fettig et al. 2010, 2007).

Similarly, decreased stand densities would allow for more airflow through stands, potentially leading 

to lower relative humidity and faster drying, which could help to limit the spread of sudden oak death 

(Phytophthora ramorum), should it make its way into the project area. Increasing heterogeneity may also 

decrease disease severity in the case of infection (Condeso and Meentemeyer 2007). In addition, it’s 

possible that prescribed fire treatments help to prevent the spread of sudden oak disease (Moritz and 

Odion, 2005). Regardless of the treatment method, a reduction in host density, especially young tanoak, 

would likely reduce spread of the disease in the case of infection.

With an increase in QMD after treatments (Figure 3-22 through Figure 3-26 and Figure 3-29), stands 

throughout the project area would, on average, have thicker bark than if left untreated. Thicker bark 

coupled with reduced ladder fuels, and reduced surface fuels, would result in more fire resilient stands as 

illustrated by reductions in predicted basal area mortality under severe wildfire conditions (Figure 3-14

through Figure 3-21; Agee and Skinner 2005).

Thinning the stands throughout the project area, both from below and throughout the diameter classes 

around trees of interest (with the exception of pre-dominant and dominant trees), while also creating gaps 

and leaving small portions of the stands untreated, would increase heterogeneity both within stands and 

throughout the project area at the landscape level and also advance stand structures towards those found 

in active mixed-conifer fire regimes (Churchill et al. 2013, Hessburg et al. 2016, North et al. 2007). Field 

crews combed the project area looking through the TEK lens for species of cultural significance so that 

through the Proposed Action we could culture and enhance species such as hazel, huckleberry, iris and 

various trees. The varying intensity of our thinning prescriptions allow us to mimic patterns created by 

fire, which support and enhance the unique ecology of this area, including rich conifer and hardwood 

diversity and diverse and abundant TEK resources. In addition, these varying stand density patterns may 

be effective at reducing the spread of crown fire in the event of wildfire (Sherlock 2007).

By implementing the Proposed Action, the trees of interest, particularity the true oaks, tanoaks and 

chinquapins, would in time have the necessary resources to increase the size of their crowns, allowing 

them to produce more carbohydrates, which would lead to increased growth and production of acorns and 

nuts (Devine and Harrington 2006). Increased acorn and nut production would have many benefits, both 

ecologically and on the human environment. The Karuk and other local tribes rely heavily on these oaks 

for acorns as a significant portion of their diets. As availability and quality increase, younger generations 

are more likely to continue to utilize these important resources. Having places that are easy to access for 
Chapter 3. Environmental Consequences

172 – Somes Bar Integrated Fire Management Project

acorn gathering would be very positive on a physiological, cultural, and spiritual level. Acorns and 

chinquapin nuts are also an important food source for local wildlife.

Other understory vegetation would also be enhanced through time with thinning and the creation of 

gaps in the canopy. Willow (Salix spp.) and hazel (Corylus cornuta), would have reduced competition for 

water and light; and understory burning would enhance these species for local cultural use. In many 

places, hazel exists in the understory where it is not receiving much light, and therefore is not producing 

hazel nuts. Currently hazel nuts can be found alongside roads where plants receive more light. These 

highly prized hazel nuts should be more abundant throughout the project area after canopy level 

treatments have been implemented and the plants have had time to respond to more favorable conditions. 

Here again, this increases production of nuts would benefit wildlife as well as local indigenous peoples 

who wish to gather traditional resources.

Cumulative Effects

For silviculture, the indirect effects and the cumulative effects are much the same. Of particular 

importance is that if the Proposed Action is implemented, we would be shifting the landscape towards an 

ecological condition where wildland fire, both planned and unplanned, would not pose as high of a risk to 

existing resources, infrastructure, and the ecocultural balance of these forests as it does today. Fire is a 

vital, natural, ecological disturbance agent that is critical to the ecosystem dynamics of the Klamath 

Mountains. The flora and fauna of the bioregion have lived with and evolved with fire for millennia, as 

well as the inhabitants and their culture.

The Proposed Action would help the local communities to be more resilient, and would constitute a 

huge step towards restoring and maintaining a resilient landscape along the Klamath River. Beginning 

around the communities is a logical place to start. By virtue of implementing the Proposed Action, there 

would be many jobs created at the local level that would have effects on the surrounding rural and urban 

communities. All of the thinning, whether manual or mechanical, would require many people to 

implement over a long period, such is the case with prescribed fire as well.

Compliance with Forest Plan and Other Relevant Laws, Regulations, Policies and Plans

The project would meet all timber and vegetation standards and guidelines described in the KNF and 

SRNF forest plans (or LRMPs). The forest plans incorporate all applicable provisions of the Northwest 

Forest Plan of 1994 (NWFP). In addition, the forest plans incorporate provisions of the National Forest 

Management Act of 1976 (NFMA), its implementing regulations, and other guidance documents.

Wildlife

Introduction

The objective of the proposal is both short- and long-term in its aim for wildlife species and the habitats 

on which they rely. The short-term aspect is to manage for protection from stand-replacing fire, this 

would help prevent further habitat fragmentation and loss of habitat connectivity. The long-term aspect is 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 173

to restore and improve the function of habitat for late-successional and old growth associated species such 

as the fisher, and NSO. In addition by reintroducing wildfire and creating a landscape mosiac this would 

improve conditions for the Karuk Tribe traditonal ecological knowledge (TEK) focal species.

Traditional Ecological Knowledge Focal Species

Chapter 2 describes the rationale for the following five (5) focal species selected according to the 

guidelines for the initiation of the Somes Bar Project and inform the planning efforts of the greater 

WKRP collaborative. Each TEK focal species (Table 3-15) comes with a set of habitats, which serve as 

indicators of the health of a habitat segment for the applicable focal species:

o Pacific fisher is a Forest Service Sensitive species, important for cultural use and an indicator 

for forests and oak woodlands.

o Northern spotted owl is listed as threatened and is an indicator for old growth forest.

o Roosevelt elk is an indicator for open areas and high elevation grasslands with associated 

cultural use vegetation.

o Pacific giant salamander are found in low-gradient riparian areas, and are indicators for the 

health of the environment and revered as the water purifier.

o Willow is important for cultural use and an indicator for riverine areas.

Awareness of the interconnectivity between the focal species and cultural use species lies at the heart 

of TEK. It is also crucial for the revitalization of traditional knowledge, practice, and belief pathways 

through the adaptive management framework adopted by the WKRP. In this section, Pacific fisher, 

northern spotted owl, Roosevelt elk, Pacific giant salamander and willow are discussed in context of both 

the No Action Alternative, with associated risks with doing nothing, and the Proposed Action of 

reestablishing fire on the landscape for both the potential for short term impacts to the species as well as 

long-term benefits to their individual habitat conditions. In addition, the direct and indirect effects of the 

no action and the Proposed Action also analyzed for NSO and Pacific fisher in the context of legal 

requirements of the Endangered Species Act (ESA) and FSM direction (FSM 2670).

Legal Compliance and Mandatory Disclosure

Using the following three (3) lists, a determination is made of whether the species range overlaps the 

project area and whether habitat is likely to exist in the project area (if both are true, then the species is 

analyzed for the project): 1) Threatened, Endangered, Proposed and Candidate terrestrial species in the 

project area are identified using the USDI Fish and Wildlife Service (USFWS) list of Threatened, 

Endangered, Proposed or Candidate Species list website (IPaC) dated November 01, 2017 (Consultation 

Code: 08EACT00-2018-SLI-0028 – AFWO; see biological assessment (BA) in the project record, Yost 

and Bettaso 2018); 2) the Forest Service (Pacific Southwest Region (Region 5)) Sensitive Species list 

(revised July 3, 2013) identifies the species to consider for this analysis; and 3) Survey and Manage (S&M) 

species list as identified in Record of Decision (ROD; 2001) as adjusted in 2014 and interpreted by Forest 
Chapter 3. Environmental Consequences

174 – Somes Bar Integrated Fire Management Project

Service, Region 5 guidance (2014). The project record contains the following reports: BA for ESA-listed 

wildlife species (Yost and Bettaso 2018), BE for Forest Service Sensitive wildlife species (Yost and 

Bettaso 2017a) management indicator species (Yost and Bettaso 2017b), survey and manage species 

(Bettaso, Yost and Hoover 2017), and migratory bird species ((MBS; Bettaso 2017) that document these 

conclusions. These reports contain additional details of the project including site history, Recovery Plan 

guidance, and unit by unit treatments, etc.

Forest Plan Guidance

One of the primary purposes of a forest plan is to guide land management through the adherence to the 

Forest-wide and management area S&Gs. The desired condition represents the general goal for which the 

project would strive. Forest plan S&Gs (both forest-wide and specific to management areas) were 

developed to assure compliance with law, regulation and policy and to minimize impacts during forest 

plan implementation.

Information from both forests plans pertinent to Forest Sensitive species occurring in the Somes Bar 

Project is displayed below; this information was used in developing analysis indicators. The Proposed 

Action and the Somes Bar Project is in accordance with guidance and direction from the KNF and SRNF 

LRMPs, and the Katimiin MOU between the Karuk Tribe and the KNF for the management of the 

Katimiin CMA.

Special Habitat KNF Management Area 5

This management area consists of special provisions for peregrine falcon, bald eagle and Late 

Successional Reserves. The KNF LRMP includes a provision for the Special Habitat Management Area

around peregrine falcon eyries. The project proposes fuels reduction treatment that occurs within the 

Special Habitat area. However, no known peregrine falcon eyries are located within 0.5 miles of the 

project areas. Therefore, the proposed treatment is consistent with the management of this area and would

not be analyzed further for this project.

Bald eagles were also delisted under ESA but the eagle is included in the Forest Service Sensitive 

species list. Forest plan provisions for the Special Habitat Management Area around bald eagle nests 

would be followed. Effects of the project on bald eagles are disclosed under discussions of Forest Service 

Sensitive species.
Final Environmental Assessment 

– 175

Chapter 3. Environmental Consequences

Table 3-15. Karuk Tribe focal species short-and long-term response to treatments.

Focal Species

Habitat Components No Action Short-Term Habitat(0 to 5 years)

Long-Term Habitat

(5 to 15 years)

Pacific Fisher: conifer 

forests, upland oak 

stands

The Klamath National Forest Forest-Wide LSR 

Assessment (LSRA 1999) and the Ishi-Pishi 

Ecosystem Analysis determined that the project 

area and the Ten-Bear LSR was deficient in latesuccessional habitat. Fire modeling predicts 

increased losses or degradation of late 

successional habitats. Stands would remain in 

overstocked conditions with a lack of structural 

diversity and decreased heterogeneity. The lack of 

treatment would result in increased fragmentation 

of habitat, lack of connectivity between suitable 

habitat patches, increased stand densities, 

increased fire severity, overstocking and potential 

loss of hardwoods due to competition with conifer.

In the short-term, canopy cover would be reduced. 

Nesting, roosting and foraging habitat (11 acres) 

and movement habitat (58 acres) would be 

removed. This will be from landing and temporary 

road construction and will not occur in one area. 

Scattered openings across the project area can be 

beneficial in stands lacking structural diversity to 

“maximize individual tree development, encourage 

some understory vegetation development, and 

encourage the initiation of structural diversity” 

(Interagency Regional Ecosystem Office 

memorandum 1996). Treatment design features 

would enhance hardwood stands within and 

adjacent to suitable habitat for fisher.

In the long-term, late successional habitat would 

be more resistant to large-scale disturbance. This 

would increase the probability of maintaining 

connectivity for late-successional species and 

reducing potential fragmentation of habitat. 

Important structural elements would be maintained 

within the stand (large snags, trees and 

hardwoods) post-treatment. This would enhance 

resiliency of oak woodlands, and establish resilient 

heterogeneous forests at multiple scales.

NSO: latesuccessional habitat 

and old growth

The Klamath National Forest Forest-Wide LSR 

Assessment (LSRA 1999) and the Ishi-Pishi 

Ecosystem Analysis determined that the project 

area and the Ten-Bear LSR was deficient in latesuccessional habitat. Fire modeling predicts 

increased losses or degradation of late 

successional habitats. Stands would remain in 

overstocked conditions with a lack of structural 

diversity and decreased prey base for NSO 

foraging. The lack of treatment would result in 

increased stand densities, increased fire severity, 

overstocking and potential loss of hardwoods due 

to competition with conifer.

In the short-term, canopy cover would be reduced. 

Nesting, roosting and foraging habitat (11 acres) 

and dispersal habitat (58 acres) would be 

removed. This will be from landing and temporary 

road construction and will not occur in one area. 

Scattered openings across the project area can be 

beneficial in stands lacking structural diversity to 

“maximize individual tree development, encourage

some understory vegetation development, and 

encourage the initiation of structural diversity” 

(Interagency Regional Ecosystem Office 

memorandum 1996).

Treatment design features protect woodrat habitat, 

a prey species for NSO where wood-rat habitat is 

found, choose 0.25 acres adjacent to retention 

patch to treat small diameter vegetation (4 inches 

or less) to encourage re-sprouting and create 

future woodrat habitat.

In the long-term, late-successional habitat would be 

more resistant to large-scale disturbance. This 

would increase the probability of maintaining 

connectivity for late-successional species and 

reducing potential fragmentation of habitat. 

Important structural elements would be maintained 

within the stand (large snags, trees and hardwoods) 

post-treatment. This would enhance resiliency of 

oak woodlands, and establish resilient 

heterogeneous forests at multiple scales. In 

addition, the Proposed Action provides mosaics of 

interior habitats and edges to provide for the 

diversity of prey for NSO.

Roosevelt Elk: open 

space, transition 

between wide open to 

more dense habitat

As the local elk population continues to increase, 

fire suppression and lack of management has 

created conditions with limited early seral habitats. 

This leads to continued simplification of critical 

winter foraging habitats and may ultimately limit 

population size and distribution.

Hiding cover maybe reduced in the short-term, but 

this is not a limiting factor for this population. 

Provisions to improve quality winter foraging habitat 

that would support a stable elk herd population as 

described in the KNF Elk Management Plan.

Promote a mosaic of habitat types across the 

landscape; re-introduction of wildfire back on the 

landscape would reduce conifer encroachment in 

hardwoods, increase perennial grass diversity and 

increase structural diversity providing cover for 

calving and calves.
176

– Somes Bar Integrated Fire Management Project

Chapter 3. Environmental Consequences

Focal Species

Habitat Components No Action Short-Term Habitat(0 to 5 years)

Long-Term Habitat

(5 to 15 years)

Pacific Giant 

Salamander: riparian, 

clean water

No action would set riparian zones up for high 

severity fire and reduce the variable stages of 

decay in large logs throughout the range of Pacific 

giant salamanders. More trees fall after fire, but it 

takes a long time to get the variability back in the 

stages of decay.

Burning in favorable conditions would scorch these 

large logs but would not totally consume them all. 

Having backing fire into riparian areas and not 

using drip torch fuel in them would reduce the 

potential for impact to this species. This species as 

a focal species also gets to the human 

responsibility. If a person sees one and it would be 

harmed we are supposed to move it to a safe 

place. Smoke shading in restored fire regimes can 

help benefit this species by reducing insolation 

factors and river temperatures.

Riparian areas are part of the landscape and may 

need fuel treatments based on fuel loading within 

and in surrounding uplands. Reducing the risk of 

uncharacteristically high severity fire in riparian 

areas can limit the effects to riparian dependent 

species such as TEK focal species willow and 

Pacific giant salamander as well as limit the spread 

of invasive species.

Post implementation of all planned entries, the 

riparian areas that support Pacific giant 

salamanders and willows would be more resilient 

to the risk of uncharacteristic high intensity fires.

Willows treated over time would provide material 

for weaving baskets.

Willow: Klamath River 

and lower parts of 

tributaries

Sand bar willow is infested with bugs, which would 

continue with no treatment. Weavers cannot use 

willow infested with bugs.

Cutting and burning would improve willow stands 

in four units along Klamath River. More light to 

mountain willow is also important. Many bird 

species are also associated with different willow 

species. Avoiding use of prescribed fire during 

nesting season is intrinsically linked to this focal 

species. Use of monitoring and adapting based on 

implementation would reduce impacts. If for 

example the willow flycatcher comes to nest earlier 

that when Pleiades is no longer visible (April) then 

early season burns would need to stop sooner.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 177

Treatment within Late-Successional Reserves

The Somes Bar Project occurs partially within Late-Successional Reserve (LSR) RC 349 (Ten Bear) and 

the 100-acre LSR KL0058. Under the 1994 NWFP, S&Gs were developed for silvicultural treatments in 

LSRs in order to maintain or improve habitat conditions for late-successional species. The KNF Forestwide Late-successional Reserve Assessment (LSRA; 1999) sets the objective that fuels management 

treatment effects in LSRs must be neutral and should have a long-term positive effect on late-successional 

habitat. Proposed project treatments should not diminish suitable habitat now or in the future. The KNF 

LSRA (1999) determined that this area of the LSR was deficient in late-successional habitat. Portions of 

the LSR prior to its designation were harvested; therefore, extensive stands of dense plantations exist that 

not only create a fuels hazard, they also do not provide suitable habitat for late-successional species such as 

the NSO. Plantations and young natural stands are even-aged and lack the horizontal and vertical diversity 

components associated with late-mature stands. Young stands have the potential to achieve rapid diameter 

and height growth with thinning treatments. Silvicultural prescriptions can be applied to younger stands in

order to accelerate their development toward late seral conditions. These treatments could increase the 

amount of late seral vegetation sooner than would occur naturally. The LSRA indicated the proposed area 

needs extensive fuels treatments to protect the LSR as well as extensive habitat restoration. Planned 

treatments outside but adjacent to the Ten Bear LSR and KL0058 would reduce fuel loading risk and 

provide additional protection to late-seral stands.

Late-successional reserve treatment will include approximately 49 acres, specifically in LSR Ten 

Bear and the 100-acre LSR KL0058. The Ten Bear LSR would include 14 acres of manual, prescribed 

burn treatments (Units 2247 and 2252), and 11.9 acres of mechanical treatment with a 20-inch dbh limit 

(Unit 2249) in the Patterson project area. The Ti Bar project area would treat 9.6 acres with manual, 

prescribed burning (Units 2107 and 2108). Treatment in the Donahue project area would include 13.5 

acres of manual, prescribed burning (Unit 2440) in LSR KL0058 (Table 3-16).

Table 3-16. Units, prescription treatments, and approximate acres of late-successional reserves (LSRs) in the 

Somes Bar Project.

Unit Acres in Unit Prescription Treatments Approximate LSR Acres

2440 22.2 Manual, Prescribed Burn 13.5

2252 25.3 Manual, Prescribed Burn 12.8

2249 78.4 Mechanical, ground-based / Manual, Prescribed Burn 11.9

2107 4.8 Manual, Prescribed Burn 4.8

2108 5.0 Manual, Rx Burn 4.8

2247 14.0 Manual, Rx Burn 1.2

Total Acres 49.0

One (1) S&G required that all 20-inch dbh and above trees be maintained within the treated stands 

unless reviewed by the Regional Ecosystem Office (REO). In a July 9, 1999 letter, the REO allows 

“Individual trees ... exceeding 20-inches dbh in any province, shall not be harvested except for the 

purpose of creating openings, providing other habitat structure such as downed logs, elimination of a 

hazard from a standing danger tree, or cutting minimal yarding corridors.” The Somes Bar Project meets 
Chapter 3. Environmental Consequences

178 – Somes Bar Integrated Fire Management Project

LSR objectives for habitat protection and restoration, and will not need the exemption. The project would

not cut trees over 20-inch dbh within LSR and would retain pre-dominant and dominant trees.

Methodology

The analyses are based on the bestscientific28 and commercial data available at the time this document 

was written. Information such as data collected from Forest databases, remote sensing vegetation analysis, 

the Forest existing vegetation (EVEG), direct field assessments, California Natural Diversity Database, 

and the most recent and appropriate scientific research and species information, was all used for the 

consideration of direct, indirect and cumulative effects.

Spatial and Temporal Bounds

The treatment area (project areas) boundaries reflect the physical footprint, where proposed vegeatation and 

prescribed fire, and therefore potential direct effects would occur. The analysis area varies by species and 

reflects the area within which the species could be directly and indirectly affected by the Proposed Action.

Temporal bounding for the analysis is both short term and long term. Short term consists of the 

project implementation and the time in which vegetation begins to respond to treatments. These are

normally the commercial treatments that occur within five (5) to 10 years. Long-term boundaries to 

habitat changes are limited to vegetation and fuels modeling, which extends to approximately five (5) to 

15 years following project implementation of fuels treatments.

Analysis Indicators

Table 3-17 lists species, analysis areas and indicators that were developed using the forest plan S&Gs and 

the best available science to estimate direct, indirect, and cumulative effects for Forest Sensitive species.

Table 3-17. List of wildlife species analyzed with associated indicators.

Species Analysis Area Analysis Indicator

Northern spotted owl 1.3 miles out from a proposed treatment unit and the 

homerange of any NSO ACs that intersects a project area.

Risk to reproduction.

Change in critical habitat.

Bald eagle

The project area and the analysis area include the 

Klamath and Salmon Rivers and within these areas of the 

river, two eagle nest sites are known to occur.

Level of disturbance to nest sites.

Northern goshawk

The project area was surveyed for goshawk. One (1) 

goshawk nest was detected near the Rogers project area 

and the site produced offspring in 2015. No other sites are 

known to occur within the project area.

Level of disturbance to nest sites.

Risk to reproduction.

Fisher, marten, and wolverine 

(Fisher is a TEK Focal species)

Ten 7th-field watersheds that contain project areas.

Fisher and marten have been detected within the project

areas. No detections of wolverine.

Since the fisher, marten, and wolverine have an overlap in 

general habitat use, one (1) habitat layer would be used for 

this analysis. The desired condition maintains all potential 

suitable habitat for these species within a 7th-field watershed.

Level of habitat alteration (NSO 

habitat is used as a proxy for 

suitable fisher, marten, and 

wolverine habitat).

Change in fisher home range

Pallid bat, Townsend’s big 

eared bat, and fringed myotis

The project area has no known bat hibernaculum or 

maternity sites.

Risk of disturbance of potential 

hibernaculum or maternity sites

 28 Best available science is defined as scientific literature that is relevant to the project and available to the reader and decision-maker.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 179

Species Analysis Area Analysis Indicator

Willow flycatcher

Surveys have not been conducted within the project area. 

No nest-site locations are known within or adjacent to the 

project area however were found on the Klamath National 

Forest. Reproduction is most likely to occur in riparian 

areas primarily in the low gradient and larger waterways. 

The remaining waterways within the project area would be 

high gradient and less suitable

Level of habitat alteration in the inner 

riparian reserves.

Western bumblebee

Ten 7th-field watersheds that contain project areas.

The actual location and distribution of bumblebee colonies 

is not known. This analysis is assuming that each 

meadow could contain a colony.

Level of habitat disturbance in 

meadows.

Foothill yellow-legged frog

The project area has not been thoroughly surveyed for 

foothill yellow-legged frogs since measures to protect 

riparian reserves should not directly affect habitat.

Risk of disturbance in inner riparian 

reserves.

Southern torrent salamander

Ten 7th-field watersheds that contain project areas.

The project has not been surveyed although one (1) 

salamander was found in the Ti Bar project area.

Risk of disturbance of 

seep/spring/riparian habitat disturbed 

per 7th-field watershed.

Western pond turtle Ten 7th-field watersheds that contain activities within 100 

to 500 meters of the Klamath River.

Risk of disturbance of nesting 

bench/hibernation habitat disturbed.

Federally Listed Terrestrial Species

Based on the BA prepared (Yost and Bettaso 2018), NSO, with associated designated critical habitat, is 

the only federally listed terrestrial species known to occur within the project area.

Northern Spotted Owl (Strix occidentalis caurina)

NSO Recovery Plan

On June 28, 2011, the USFWS released the Revised Recovery Plan for the NSO. The purpose of recovery 

plans is to describe reasonable actions and criteria that are considered necessary to recover a listed 

species. The 2011 Revised Recovery Plan (Recovery Plan) for NSO represents the “best available 

science.” The Recovery Plan recognizes the importance of maintaining, and restoring, habitat for the 

recovery and long-term survival of the spotted owl. The Recovery Plan also relies on federal lands to 

provide the major contribution for recovery (USDI Fish and Wildlife Service 2011).

The Recovery Plan describes reasonable recovery criteria and recovery actions that are considered 

necessary to recover a listed species. Recovery criteria serve as objective, measurable guidelines to assist 

in determining when an endangered species has recovered to the point that it may be downlisted to 

threatened, or that the protections afforded by the ESA are no longer necessary and the species may be 

delisted. Recovery actions are the Service’s recommendations to guide the activities needed to accomplish 

the recovery criteria.

The Recovery Plan states due to “The continued decline of the spotted owl populations and low 

occupancy rates in large habitat reserves, and the growing negative impact from barred owl invasions of 

spotted owl habitats (Forsman et al. 2011, Dugger et al. 2011 and 2016), which is greater than anticipated 

in the NWFP. We recommend increased conservation and restoration of spotted owl sites and high-value 

spotted owl habitat to help ameliorate this impact”.

The Somes Bar Project was designed to meet the objectives of the Recovery Plan as follows:

o Recovery Action 10 (RA 10) requires that agencies:
Chapter 3. Environmental Consequences

180 – Somes Bar Integrated Fire Management Project

 “Conserve spotted owl sites and high value spotted owl habitat to provide additional 

demographic support to the spotted owl population”.

 “When planning management activities, Federal and non-federal land managers 

should work with the Service to prioritize known and historic spotted owl sites for 

conservation and/or maintenance of existing levels of habitat.”

Because the SRNF strives towards recovery of the spotted owl, all NSO ACs receive the 

highest level of protection. This goes beyond the requirement of RA 10. There are 10 known 

NSO ACs included in the analysis area for the Somes Bar Project. Care was taken to avoid 

habitat downgrade or removal within deficit NSO ACs, and no NSO ACs would be taken 

(indirect or direct) as a result of habitat treatments. Commercial and fuel treatments would 

not remove or downgrade suitable nesting/roosting or foraging habitat. In addition, the 

USFWS requires a 70-acre nest grove protection zone. This project exceeds the 70 acres 

around each known AC, which was incorporated into the project design (see the project BA 

for specific information relating to nest groves). No commercial treatment would occur 

within the nest groves.

o Recovery Action 32 (RA 32) states:

 “Maintaining or restoring forests with high-quality habitat will provide additional 

support for reducing key threats faced by spotted owls” and “Protecting these forests 

should provide spotted owls high-quality refugia habitat from the negative 

competitive interactions with barred owls that are likely occurring where the two 

species’ home ranges overlap. Maintaining or restoring these forests should allow 

time to determine both the competitive effects of barred owls on spotted owls and the 

effectiveness of barred owl removal measures.”

Forsman et al. (2011) recommended that all potential NSO habitats should be considered, not 

just old growth. The Six Rivers definition of suitable nesting/roosting NSO habitat includes 

mid-mature (starting at 21-inch dbh), late-mature and old-growth seral stages. All potential 

habitat was considered during project evaluation, and all high quality habitat (no matter what 

seral stage) was considered during project design. Low-quality habitats were evaluated for 

habitat improvements measures. If the habitat could benefit from a silvicultural or fuels 

treatment, then it was considered for the project.

The definition of NSO habitat used for this project was based on the definition found in the 

SRNF LRMP, Recovery Plan and field verified by biologists with extensive experience with 

the species. The LRMP and Recovery Plan definitions were based on extensive amounts of 

published literature and represent the best available science for the Six Rivers’ habitat types.

All high-quality NSO nesting/roosting habitat and nest groves were dropped from 

commercial treatment on this project. Commercial and fuels treatments within and adjacent to 

these areas would help protect existing high-quality nesting/roosting/foraging (NRF) habitat 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 181

from human-caused and wildfires. This project meets the intent of RA 32 and the need to 

reduce inter-specific competition between spotted and barred owls.

o Recovery Action 6 (RA 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.”

The Somes Bar Project is designed to restore and accelerate development of important habitat 

characteristic for the spotted owl. This includes plantations and overstocked stands that, if 

treated, would increase the available habitats for the spotted owl and help reduce interspecific competition between the barred owl and the spotted owl. Treatment of these stands 

would have an immediate benefit to the spotted owl. This project meets the intent of RA 6 by 

reducing fuel loading in dense plantations and by increasing development of important 

habitat components for the NSO.

The proposed project treatments would meet or exceed the KNF LRMP guidelines recommend 

five (5) snags per acre averaged across a 100-acre area (Table 4-4 of the KNF LRMP, Table I-1 

of the LRMP FEIS provide standards for snag retention). The project would meet or exceed the 

KNF Forest Plan S&G 6-16 (p. 4-25) for CWD. The proposed project will maintain 5 to 20 

pieces of CWD per acre in various stages of decay. Leave large logs, conifer and hardwood, at 

least 20 inches in diameter and about 40 cubic feet in volume when they are available. Down 

logs should reflect the mix of species in the stand. Snags and logs would be retained as per 

SRNF LRMP S&Gs Table IV-8 and Appendix L. Treatments within LSRs, riparian reserves, 

critical habitat units (CHU), and suitable NSO habitat (regardless of land allocation) would 

maintain snags (20′′-dbh and greater or the largest available in younger seral stages) and 

downed logs (20′′ and greater and at least 10′ long or the largest available) at the 80- to 100-

percent level, unless they pose a safety hazard or would not meet fuel treatment objectives. 

Hazard trees are defined as any tree that is dead, dying, or showing signs of failure that has the 

potential to hit the area of operations (leaning toward the site and is within tree-height distance).

The Somes Bar Project has protected all high quality habitat (not just old growth, but also late-mature 

and some mid-mature stands (RA 32)), all spotted owl territories (not just high priority sites (RA 10)) and 

is designed to restore and accelerate important habitat characteristic for the spotted owl (RA 6) in young 

overstocked stands. Such long-term protection of owl habitat is consistent with the recommendations in 

the Recovery Plan.

The Recovery Plan states, “Dugger et al. (2016) found an inverse relationship between the amount of 

old forest within the core area and spotted owl extinction rates from territories” when barred owls were 

present. The Recovery Plan also states due to the “growing negative impact from barred owl invasions of 

spotted owl habitats (Forsman et al. 2011, Dugger et al. 2016)..., We recommend increased conservation 

and restoration of spotted owl sites and high-value spotted owl habitat to help ameliorate this impact” 
Chapter 3. Environmental Consequences

182 – Somes Bar Integrated Fire Management Project

(emphasis added). Barred owls have been documented using a wider range of forest types (younger seral 

stages with more fragmentation) than spotted owls (Hamer 1988, Herter and Hicks 2000, Kelly et al. 2003, 

Hamer et al. 2007, and Irwin et al. 2018). Consequently, the loss of late-successional old-growth forest and 

increased fragmentation of these forests would decrease the amount of suitable habitat for spotted owls. In 

other words, without treatment of non- or poor-quality habitats in deficit core areas we may lose these sites 

to barred owls. The Recovery Strategy of Recovery Plan supports “active forest management” and states 

that “In addition to describing specific actions to address the barred owl threat, this Revised Recovery Plan 

continues to recognize the importance of maintaining and restoring high value habitat for the recovery and 

long-term survival of the spotted owl” (emphasis added).

The Somes Bar Project treatments within owl territories, including core areas, are designed to accelerate 

the development of old forest characteristics, and increase structural diversity which would improve habitat 

conditions within spotted owl territories. The project meets the objectives of the Recovery Plan.

Barred Owl

Barred owls are recognized as a significant threat to the recovery of the NSO (USFWS 2011). The 

Recovery Plan addresses barred owls under RA 32 and RA 10, which are found under the “Barred Owl 

Recovery Actions”. The barred owl recovery actions were developed under the assumption that barred 

owls now occur at some level in all areas used now or in the past by spotted owls. This is true for the 

Somes Bar Project area as well. Northern spotted owl surveys within the project area have shown barred 

owl occupancy within the project area. The Recovery Plan addresses the threat to the NSO from the 

barred owl through the preservation of existing high-quality habitat (RA 32) and preservation of high 

priority NSO territories (RA 10). The Recovery Plan also addresses the need to restore additional habitat 

for the owl in order to ameliorate the impact of the barred owl. Implementation of RA 10 and RA 32 

standards fully meets the best available barred owl mitigation measures by protecting, maintaining and 

restoring spotted owl habitat.

The Recovery Plan was informed by Forsman et al. (2011) and Dugger et al. (2011). The Recovery 

Plan states due to “The continued decline of the spotted owl populations and low occupancy rates in large 

habitat reserves, and the growing negative impact from barred owl invasions of spotted owl habitats 

(Forsman et al. 2011, Dugger et al. 2016, Holm et al 2016, and Irwin et al. 2018), which is greater than 

anticipated in the NWFP. We recommend increased conservation and restoration of spotted owl sites and 

high-value spotted owl habitat to help ameliorate this impact”.

Recovery Action 32 specifically states “Maintaining or restoring forests with high-quality habitat 

would provide additional support for reducing key threats faced by spotted owls” and “Protecting these 

forests should provide spotted owls high-quality refugia habitat from the negative competitive interactions 

with barred owls that are likely occurring where the two species” home ranges overlap. Maintaining or 

restoring these forests should allow time to determine both the competitive effects of barred owls on 

spotted owls and the effectiveness of barred owl removal measures”. High-quality nesting/roosting NSO 

stands and nest groves were dropped from commercial treatment on the Somes Bar Project due to this 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 183

recovery action and the need to reduce inter-specific completion of the owls and restoration activities are 

proposed for non-habitat or low-quality habitat stands.

Recovery Action 10 requires that agencies “Conserve spotted owl sites and high value spotted owl 

habitat to provide additional demographic support to the spotted owl population”. Maintaining all historic 

ACs is a standard SRNF and KNF protection measure. The SRNF and KNF database includes NSO ACs 

that predates the 1990 listing of the NSO. All historic ACs (currently occupied or not) that meet the criteria 

of an AC (described in the USFWS survey protocol) are considered during project evaluation. Within the 

NSO Analysis area for NSO, the area has 14 historical ACs mapped. Ten of these ACs were included in the 

analysis for this project. The other four (4) NSO ACs were dropped from analysis due to location and 

review by the Level 1 team. All 14 ACs were found to be active at some point in time from as early as the 

1990s. To date the project area has had three (3) years of surveys to protocol (2015 to 2017). No NSO were 

detected at any of these sites in 2017. All high quality nesting/roosting habitat, regardless if it was located 

within an active AC, was dropped from commercial consideration during project design. In addition, the 

USFWS requires a nest grove protection zone of a minimum of 70-acres around each known AC, which 

was exceeded for this project and incorporated into the project design. No commercial activities would

occur within the nest groves. The Somes Bar Project meets RA 10.

The Somes Bar Project has protected all high-quality habitats (not just old growth), all spotted owl 

territories (not just high priority sites) and is designed to restore, maintain, and accelerate important habitat 

characteristic for the spotted owl. “Maintaining or restoring these forests should allow time to determine 

both the competitive effects of barred owls on spotted owls and the effectiveness of barred owl removal 

measures” (II-67 of the 2011 Plan). Protecting these forests should provide spotted owls high-quality 

refugia habitat from the negative interactions with barred owls that are likely occurring where the two (2) 

species’ home ranges overlap. The project would not exacerbate competitive interactions between the two 

(2) species. Without the implementing the additional protection measures and recovery actions of the 

Recovery Plan, the barred owl may be successful in out-competing the spotted owl. It is imperative to the 

spotted owl’s recovery to take such actions. The project is meeting the objectives of the Recovery Plan.

Fire

Another threat to the NSO addressed by the Recovery Plan is wildfire. The Recovery Plan identifies 

stand-replacing wildfire as one of the three (3) top threats to the recovery of species stating, “currently the 

primary source of habitat loss is catastrophic wildfire...” The Recovery Plan further notes that wildfire 

size and frequency have been increasing in the western United States and that acres burned are expected 

to continue to increase due to climate changes and past land management practices. This overall increase 

in acres burned translates to a corresponding increase in the acres of spotted owl habitat lost to fire. While 

the risk of habitat loss to wildfire varies by location, the Recovery Plan emphasized that the Klamath 

region is one of the main areas at risk:

o “Fire-prone provinces and critical habitat subunits, including Klamath West, scored high on 

threats from ongoing habitat loss as a result of wildfire and the effects of fire exclusion on 

vegetation change.”
Chapter 3. Environmental Consequences

184 – Somes Bar Integrated Fire Management Project

o “In view of the increasing risk posed to northern spotted owl habitat by wildland fire in the 

dry forests of the California Klamath Province (Klamath West), the Recovery Plan calls for 

management actions that result in forests that are more fire resilient and fire-resistant.”

However, the area’s dry, hot summers and extreme departure from its historic fire return interval mean 

that owl habitat within many areas of the Forests is at risk of being lost to, or significantly degraded by, 

severe uncharacteristic fire. The 1999 Megram Fire (120,000 acres), 2002 Biscuit Fire (500,000 acres), 

the 2008 Lightning Complex (45,000), 2013 Butler (22,932 acres), 2013 Salmon Complex (15,004 acres), 

2014 Beaver Fire (32,307 acres), 2014 Happy Camp Complex (131,389 acres), 2014 Man Fire (15,645 

acres), 2014 July Complex (3,362 acres), 2014 Little Deer (5,503 acres), 2015 Saddle Fire (1,541 acres), 

2015 Fork Complex (36,562 acres), 2015 Mad River Complex (5,746 acres), 2015 River Complex 

(71,493 acres), 2015 Route Complex (17,095 acres), 2015 South Complex (28,724 acres), 2017 Orleans 

Complex, and the 2017 Marble Fire (319 acres) and many other fires within the range of the species that 

has removed or downgraded suitable NSO habitat demonstrates that fire risk on the Forests and within the 

range of the species is genuine (Davis et al. 2015, Davis 2015). Active management to reduce the fire 

hazard and increase resilience, as well as to accelerate the development of higher quality NSO habitat, 

should contribute to the spotted owl’s persistence and recovery. Such long-term protection of owl habitat 

is consistent with the recommendations in Forsman et al. (2011) as well as the Recovery Plan and 2012 

Revised NSO Critical Habitat Rule.

Impacts to Pacific Northwest forests from wildfire appear to be increasing along with fire occurrence, 

size, and intensity. Although some researchers disagree on the magnitude of these changes and what to do 

about them (e.g., Hanson et al. 2009, Hanson et al. 2018, Jones et al. 2016, and Rockweit et al. 2017), 

most researchers believe, as does the USFWS (USDI 2012b), that these changes are happening, and that 

active management should be considered (e.g., Hessburg et al. 2007, Healy et al. 2008, Heyerdahl et al. 

2008, Kennedy and Wimberly 2009, Latta et al. 2010, Littell et al. 2009, 2010, Spies et al. 2010, Perry et 

al. 2011, Syphard et al. 2011, Waring et al. 2011, Jenkins et al. 2012, Marlon et al. 2012, Miller et al. 

2009, 2012). Thus, this project takes the active management intervention approach rather than a passive 

approach to restoring NSO habitat. This approach is what was envisioned by the NWFP, the Recovery 

Plan, and the 2012 Revised NSO Critical Habitat Rule.

Prey Species

In this portion of the northern spotted owls range (below about 4,100 feet in southern Oregon and 

northern California), dusky-footed wood rats (Neotoma fuscipes), are the most important prey species of 

spotted owls, both in frequency and biomass (Forsman 1975, Barrows 1980, Solis 1983, Forsman et al. 

1984, Ward 1990, Carey et al. 1992, Zabel et al. 1995, Ward et al. 1998, Forsman et al. 2004, and Hansen 

and Mazurek 2010).

In a study conducted on the SRNF, Sakai and Noon (1993) found the highest abundance of woodrats 

occurred in 15- to 30-year-old plantations resulting from past clearcut timber harvest. The study used 

radio telemetry to track the movement of woodrats and found that although the woodrats inhabited 

younger stands, woodrats would often cross distinct ecotonal boundaries between forest types. Woodrats 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 185

tracked during evening telemetry sessions made intermittent, short distance movements into adjacent oldgrowth forests occupied by spotted owls. A substantial number of radio tagged woodrats were killed by 

predators, with carcasses most often found in adjacent old forest. This is presumably because younger, 

dense plantations are difficult if not impossible for the owl to forage in and must wait until the prey leave 

these refugia to be preyed upon.

Ward et al. (1998) found that owls foraged along late-seral forest edges where dusky-footed woodrats 

were more abundant. Woodrats living in or dispersing from adjacent shrub lands may be more available for 

owls hunting along the ecotonal edges between habitat types. Edge or transitional habitats appear to be more 

important to foraging spotted owls when woodrats dominate the diet (Zabel et al. 1995, Ward et al. 1998). 

Edges may provide cover to conceal owls from predators while making them inconspicuous to wood rats.

These results suggest that the infrequent use of younger stands by foraging spotted owls is not due to 

low abundance of prey. Simply increasing prey densities within a stand may not result in an increase in 

prey available to spotted owls if their foraging efficiency is low in these stands (Rosenberg et al. 1994). 

High tree densities and homogeneous canopies in second-growth forests may reduce flight 

maneuverability and the ability of owls to capture prey (Rosenberg and Anthony 1992). However, 

silvicultural procedures that maintain or enhance woodrat populations adjacent to spotted owl habitat may 

benefit spotted owls (Sakai and Noon 1993, Irwin et al. 2007).

Stands occupied by woodrats gradually decline in suitability. Data from Sakai and Noon (1993) 

suggest that this occurs when the dominant trees (usually Douglas-fir) begin to over top and eventually 

suppress the low-to-mid-canopy level vegetation (less than 3 to 6 meters). In the inland forests of 

northwestern California, the decline in habitat quality occurs in regenerated stands at about 40 to 50 years 

after harvest. To enhance dusky-footed woodrat populations, Sakai and Noon proposed retaining brush 

patches during precommercial thinning and creating brush patches in younger stands. The existence of 

shrub fields or younger stands adjacent to older forest may increase the availability of woodrats to spotted 

owls that exploit prey from a variety of habitats but spend the majority of their time hunting in late seral 

stage forests (Sakai and Noon 1993).

The northern flying squirrel (Glaucomys oregonensis; Arbogast et al. 2017) is a smaller component of 

the biomass collected by the spotted owl in this portion of the province. In northwestern California, flying 

squirrels constitute only 9.3 percent of the biomass of NSO diet, while dusky-footed woodrats constitute 

70.9 percent of the biomass of NSO diet (Ward et al. 1998).

Forsman et al. (1984) described potential negative impacts to flying squirrels through the timber 

harvest; however, the conditions described by Forsman occurred in heavily thinned mature and old 

growth stands. No high-quality nesting/roosting habitat is being commercially treated during 

implementation of the Somes Bar Project. Thinning might also affect flying squirrels through reduction or 

development of other important resources, such as shrubs, hardwoods, arboreal lichens, or deformed trees 

and snags (Williams et al. 1992, Carey 1995). The project would protect these important habitat 

components. Hansen and Mazurek (2010) found “mixed” results in relation to the flying squirrel, with 

some studies showing no effect at all from thinning compared to unharvested stands.
Chapter 3. Environmental Consequences

186 – Somes Bar Integrated Fire Management Project

Northern Spotted Owl Habitat Types

Suitable NSO habitat is commonly separated into nesting/roosting, foraging, and dispersal habitat; these 

habitat types are described in detail in the NSO Recovery Plan (USDI Fish and Wildlife Service 2011). 

Nesting/roosting is generally described as mid- to late-seral forests that contain stands of large trees with 

high canopy cover, multilayered canopies, and nesting platforms. Foraging habitat can be described as 

slightly reduced canopy cover, fewer large trees, and enough space for NSO to maneuver through the 

trees for hunting prey when compared to nesting/roosting habitat. Dispersal habitat contains a moderate 

level of canopy closure and trees large enough to provide shelter and potential foraging opportunities for 

traveling NSO, but does not contain adequate amounts of other essential habitat components for longterm NSO occupation, reproduction or survival. Determination of NSO habitat suitability also considers 

many factors including size of stand and adjacency to other habitat types, which owls may use. For this 

analysis, suitable habitat is defined as stated above in this paragraph and is generally referencing 

nesting/roosting and foraging habitat unless otherwise specified.

Spatial Bounds

For known NSO territories, NSO habitat would be evaluated at two (2) spatial scales 1) home range and 2) 

core areas (Figure 3-30). Based on the median home range estimate for NSO pairs in the California Coast 

Range (Douglas-fir/mixed conifer zone), 1.3 miles is the home range radius and 0.5 miles is the core radius 

for evaluating habitat conditions of and potential impacts to home ranges and core around the nest location 

(Thomas et al. 1990, USDI Fish and Wildlife Service 1992, 2009, 2012). The core and home range analysis 

would be limited to the home ranges that overlap the Somes Bar Project perimeter. Therefore, the spatial 

boundary is the home ranges that intersect the project perimeter plus the entire project area.

Analysis Indicator 1 – Risk to Reproduction

Reproduction is one of the primary elements of a species existence and effects to reproduction can have a 

significant effect on any population. The amount of suitable habitat within both the home range and core 

has been shown to influence NSO productivity and survivorship (Bart 1995, Franklin et al. 2000, Dugger 

et al. 2005). Based on results of these studies, the USFWS has concluded that significant effects to 

reproduction are not likely to occur if management activities retain a higher proportion (at least half or 

250 acres) of the core area’s high quality habitat and 1,086 acres of suitable habitat in the home range 

(outside the core) (USDI Fish and Wildlife Service 2009). Core areas falling below these habitat acre 

levels may affect the productivity and survival of NSO. Older forest is more likely than other vegetation 

classes to provide NSO with suitable structures for perching and nesting, a stable, moderate microclimate 

at nest and roost sites, and visual screening from both predators and prey.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 187

This analysis would calculate the change in NSO habitat (nesting/roosting, foraging, or dispersal 

habitat) within the core and home range resulting from the action alternative. The changes in NSO habitat 

would be analyzed and compared to the suggested levels of habitat as described by the USDI Fish and 

Wildlife Service (2009), published research, and professional judgement.

Assumptions for Risk to Reproduction

o Occupancy and reproductive success is based on the amount and quality of habitat in the 

activity center (AC).

Figure 3-30. Northern spotted owl (NSO) analysis area.
Chapter 3. Environmental Consequences

188 – Somes Bar Integrated Fire Management Project

o Roadside treatments in existing NSO habitat would result in maintaining habitat thus habitat 

would remain functioning at the current habitat type after treatment.

o Project treatments would maintain nesting/roosting habitat at 60 percent canopy closure and 

foraging habitat at 40 percent canopy closure.

o Habitat burned during the 2017 fires at low (<50 percent basal area removed per RAVG data) 

severity in the analysis area would still function as it did pre-fire.

o New landing and new temporary road construction would result in loss of habitat for the 

footprint of the landing and road prism if the landing construction occurs within suitable habitat.

Criteria for Assessing Risk to Northern Spotted Owl Reproduction

The desired condition for this analysis indicator is to minimize the amount of NSO habitat affected by the 

project actions. The amount of NSO habitat would be assessed for all known ACs and these acres of 

habitat would be interpreted into four (4) categories based on the criteria below (Table 3-18).

Table 3-18. Criteria used for northern spotted owl risk to reproduction analysis Indicator.

Risk to Reproduction Criteria29

Very Low In the core, >400 acres of NRF (>250 NR must occur in the core), AND

In the home range, >935 acres of NRF.

Low In the core, >250 acres being NRF, AND

In the home range, >1,086 acres NRF.

Moderate In home range, 665 to 1,336 acres of NRF (>500 acres NRF must occur in core and home 

range combined).

High In home range, <665 acres of NRF.

Risk to reproduction is split into four categories representing the relative level of effect resulting from 

the action alternative. Using the existing quality and amount of habitat within the AC (composed of core 

and home range), the acres of nesting/roosting and foraging habitat would be calculated as the existing 

condition and the AC would be placed into one of the four (4) categories. Then the action alternative 

effect on habitat would be calculated and compared to the existing condition. Note that an AC cannot 

have a reduction in risk. For example, an AC that meets the conditions of moderate given the existing 

habitat condition can only remain as moderate or increase to high risk based on the action alternative. 

However, an AC currently at high risk would continue to be a high risk regardless of the level of effects 

from the action alternative.

A high risk means that reproduction is not likely to occur in the AC because the low number of habitat 

acres occurring in the core and home range. Moderate level represents the ACs likely to have difficulty in 

finding resources and would likely need to traverse openings (areas without overstory tree canopy) or use 

areas of low-habitat quality to find enough resources. These challenges may result in lower survival or 

reproduction potential for the pair occupying moderate level ACs. Low-level ACs have enough habitat in 

the core and home range to support reproduction, but the habitat may not be distributed in large patches. 

 29 Core is 0.5-mile radius from the center of the activity center. Home range is 0.5- to 1.3-mile radius from the center of the activity 

center. NRF = nesting/roosting/foraging habitat
Chapter 3. Environmental Consequences

Final Environmental Assessment – 189

Generally, many of the active ACs on both forests can be described as containing similar amount of 

habitat as described for the “low” level category. The final category, very low, represents the quality and 

distribution habitat that has been associated with successful reproduction over the species range, but these 

conditions are not common on either Forest typically because the patches of NR are relatively small and 

are spatially separated.

Analysis Indicator 2 – Changes to Critical Habitat

The California Coast Range (Klamath West) is considered a “fireprone” area because of its frequent fire 

return intervals and existing vegetation condition that likely elevates the potential of fire (USDI Fish and 

Wildlife Service 2012). Within fire-prone areas, resource agencies planning vegetation management in 

critical habitat for the NSO are encouraged to ameliorate current threats of on-going habitat loss from 

uncharacteristic fires and vegetation change that are largely related to past fire exclusion (USDI Fish and 

Wildlife Service 2012). Resource agencies are also encouraged to work toward maintaining or enhancing 

the characteristics of older forest and providing large habitat blocks and associated interior forest 

conditions. Regional variations should be taken into account. In the area of the California Coast Range,

this means providing mosaics of interior habitats and edges to provide for the diversity of prey for NSO.

Critical habitat is generally described as the specific geographic area occupied by the species at the 

time of listing plus areas that contain the physical and biological features that are essential to the 

conservation of endangered and threatened species and may need special management or protection. 

Instead of providing general recommendations that cover the entire critical habitat area, critical habitat 

was split into units and subunits to provide specific recommendations because units or subunits may 

provide different functions to aid in the recovery of the species. For the spotted owl, the Somes Bar 

Project overlaps a portion of the Klamath units KLW6 and KLW7. These units are intended to enhance or 

protect existing essential biological or physical features, reduce the loss of habitat to wildfire, reduce 

change in habitat as a result of fire exclusion, and buffer competition with barred owls, but the primary 

function for these subunits is to support the survival, reproduction, and dispersal of NSO (USDI Fish and 

Wildlife Service 2012).

Primary constituent elements (PCEs) are the physical and biological features that provide the essential 

life history requirements of the species. The 2011 CHU designation identifies the primary constituent 

elements for NSO as those physical and biological features that support nesting, roosting, foraging, and 

dispersal. These PCEs are quoted from the critical habitat rule (USDI Fish and Wildlife Service 2012):

PCE 1, Forest Type

Forest types that support the NSO across its geographic range. Within the California Coastal Range 

(Klamath West), these include mixed conifer/mixed conifer-hardwood, mixed evergreen, Douglas-fir, 

white fir, and Shasta red fir. These forest types may be in early-, mid- or late-seral stages

These activities can occur in early-, mid-, or late-seral forest types identified in the PCEs in the final 

rule. On the Forest, PCE 1 includes the mixed conifer and mixed evergreen type, the Douglas-fir type, the 

Shasta red fir type and a small amount of the moist end of the ponderosa pine, coniferous forest zones.
Chapter 3. Environmental Consequences

190 – Somes Bar Integrated Fire Management Project

PCE 2, Nesting and Roosting habitat California Coast Range (Klamath West)

Stands for nesting and roosting are generally characterized by:

o Moderate to high canopy closure (60 to over 80 percent);

o Multilayered, multispecies canopies with large (20 to 30 inches or greater dbh) overstory trees;

o High basal area (greater than 240 square feet/acre);

o High diversity of different diameters of trees;

o High incidence of large live trees with various deformities (e.g., large cavities, broken tops, 

mistletoe infections, and other evidence of decadence);

o Large snags and large accumulations of fallen trees and other woody debris on the ground; and

o Sufficient open space below the canopy for NSOs to fly.

PCE 3, Foraging habitat in the California Coast Range (Klamath West)

Foraging habitat is generally characterized by:

o Stands of nesting and roosting habitat; in addition, other forest types with mature and oldforest characteristics;

o Presence of the conifer species, incense-cedar, sugar pine, Douglas-fir, and hardwood species 

such as big leaf maple, black oak, live oaks, and madrone, as well as shrubs;

o Forest patches within riparian zones of low-order streams and edges between conifer and 

hardwood forest stands;

o Brushy openings and dense young stands or low-density forest patches within a mosaic of 

mature and older forest habitat;

o High canopy cover (87 percent at frequently used sites);

o Multiple canopy layers;

o Mean stand diameter greater than 21 inches;

o Increasing mean stand diameter and densities of trees greater than 26 inches increases 

foraging habitat quality;

o Large accumulations of fallen trees and other woody debris on the ground; and

o Sufficient open space below the canopy for NSOs to fly.

PCE 4, Dispersal habitat in the California Coast Range (Klamath West)

Dispersal (i.e., transience and colonization) habitat is generally characterized by:

o Stands with adequate tree size and canopy cover to provide protection from avian predators 

and minimal foraging opportunities; in general this may include, but is not limited to, trees 

with at least 11-inch dbh and a minimum 40 percent canopy cover;
Chapter 3. Environmental Consequences

Final Environmental Assessment – 191

o Younger and less diverse forest stands than foraging habitat, such as even-aged, pole-sized 

stands, if such stands contain some roosting structures and foraging habitat to allow for 

temporary resting and feeding during the transience phase; and

o Habitat supporting the colonization phase of dispersal, which is generally equivalent to 

nesting, roosting, and foraging habitat as described in PCEs (2) and (3), but may be smaller in 

area than that needed to support nesting pairs.

Assumptions for Changes to Critical Habitat

o Roadside treatments in existing NSO habitat would result in maintaining habitat thus habitat 

would remain functioning at the current habitat type post-treatment.

o Commercial and fuels treatments would maintain nesting/roosting habitat at 60 percent 

canopy closure and foraging habitat at 40 percent canopy closure.

o New landing and new temporary road construction would result in the loss of habitat for the 

footprint of the landing and road prism if the landing construction occurs within suitable habitat.

Criteria for assessing NSO Critical Habitat analysis

The desired condition for this analysis indicator is to minimize the effects to NSO critical habitat. The 

analysis estimates the number of critical habitat acres affected by the action alternative. Given the types 

of treatment proposed for this project, we focus the reporting of effects on habitat as degrade, downgrade, 

or remove. Degrade means the effects on the habitat are minimal and the habitat remains functional at the 

same level prior to treatment. Downgrade means the habitat has been affected to the point where it would

not continue to function at its initial level and it would drop down one level in habitat type. For example, 

foraging habitat receives treatments that results in removing canopy cover and structure to the point that 

the foraging habitat functions as dispersal habitat. Removal means the once functional habitat is not 

habitat after treatment.

The acres of critical habitat downgraded or removed by the action alternative would be presented 

along with the proportion of the change in critical habitat within the portion of critical habitat subunit 

within the analysis area.

Affected Environment for Northern Spotted Owl

The area proposed for treatment (5,570 acres) occurs within Subunit KLW7 of the NSO CHU 09 

(Klamath West; USDI Fish and Wildlife Service 2012). The analysis area for NSO is 46,243 acres of 

which 37,447 acres occurs within two (2) critical habitat subunits. A small portion of Subunit KLW6

(2,867 acres) of CHU 09 (Klamath West) occurs within the analysis area. No proposed treatment would 

occur in Subunit KLW6. The remaining 34,580 acres is KLW7 and proposed treatment would occur in 

this subunit. Treatment of LSR is proposed for 49.4 acres, specifically in LSR Ten Bear RC349 and 

LSR100-KL0058. This treatment would be manual prescribed fuels and 11.9 acres of mechanical 

treatment removing trees less than 20-inch dbh. The Somes Bar Project area is dominated by dense earlyand mid-successional habitats (53 percent), with late-successional habitats comprising about 24 percent of 

the area. An estimated 1,369 acres of late-successional habitat and about 2,969 acres of mid-successional 
Chapter 3. Environmental Consequences

192 – Somes Bar Integrated Fire Management Project

habitat occurs within the project area. Within the treatment area, the primary objectives are treating dense 

early and mid-seral stands, enhancing resiliency of oak woodlands, reintroducing fire, and establishing

functioning resilient heterogeneous forests at multiple scales.

The forest conditions of the Somes Bar Project area is representative forested conditions resulting 

from natural ecological processes (i.e., fires), past management, and fire suppression. Approximately 

3,079 acres of federal and non-federal timber harvest have occurred in the watersheds since 1966. These 

projects were implemented prior to the 2012 Critical Habitat Rule and the habitat has been reevaluated. 

Most plantation and natural stands identified for thinning are uniformly dense and lack horizontal and 

vertical diversity. Natural (“minimally-managed”) stands commonly have scattered trees exceeding 30-

inch dbh, contain a mix of size classes, large logs and snags, and contain conifer and hardwood species 

diversity. Identified plantation stands contain densely spaced trees with interlocking crowns; therefore, the 

growth potential under current conditions is limited.

The ecological diversity found throughout the Western Klamath Mountains is reflected in diversity of 

vegetation types and terrain in the Somes Bar Project area. Forest stands occur as a result of soil type, 

aspect, disturbance history, and slope position. Currently vegetation diversity is high but the structural 

diversity is lacking in many areas. This lack of structural diversity is primarily due to the absence of 

naturally occurring mixed severity fires and the stand complexity resulting from this type of disturbance. 

Large residual conifer and hardwood trees are scattered through the stands that are dominated by midsuccessional trees throughout the project area, the majority of which are surrounded by small and midsized Douglas-firs. Young dense conifer plantations (1960s through early 1990s) have not yet been 

thinned and are scattered throughout the project area. In addition, without the influence of naturally 

occurring mixed severity fire oak woodlands have become encroached with conifer.

Action Area for Northern Spotted Owl

The action area includes 10 NSO ACs that have been active at some point since the early 1980s (Table 3-

19). The numbers in this table reflect pre-treatment conditions. The analysis area is about 46,243 acres in 

size; the analysis area contains approximately 15,369 acres of nesting/roosting, 12,615 acres of foraging, 

and 8,047 acres of dispersal habitat. Within the analysis area, an additional four (4) NSO ACs were 

dropped from consideration. Three (3) of the ACs are located on the west side of the Klamath River (307, 

308 and 4082) and the fourth AC (1075) had minimal acres overlap (1.89) and therefore was dropped 

(BA; Yost and Bettaso 2018).

Many of the ACs within the analysis area have not been active for many years typically related to a 

change in habitat conditions (e.g., fire or previous management), but in most cases, the reason for no 

activity is unknown. These sites maybe occupied by barred owls or have a lack of continuous survey 

effort. In addition, there are a few ACs with questionable origin and appear to have been established 

based on a single observation with no evidence of reproduction. Although a single observation does not 

necessarily warrant an ACs designation, we are analyzing all possible ACs based on data from the forest 

and California Department of Fish and Wildlife (CDFW) databases.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 193

Table 3-19. Northern spotted owl activity centers (ACs) within analysis area (pre-treatment).

AC

Number AC Name

0-0.5 mi Radius 0-1.3 mi Radius Total NRF

Acres (0-1.3 

miles)

Most Recent 

Detection Year

SPOW

NR F NR F Detection(s)

1250 201 125 1,330 911 2,241 2015 Male

53 Donahue Flat 150 150 986 815 1,801 2014 Pair

58 Scorpion 269 125 1,383 717 2,100 1995 Male

1073 271 85 1,340 699 2,039 1992 Male

1076 127 109 1,439 784 2,223 2015 Male

1089 259 106 1,228 883 2,117 1996 Pair

52 Wilder Creek 251 60 1,498 659 2,157 2014 Male

1260 376 26 1,762 503 2,265 1993 Male

SIS111 319 43 1,433 498 1,931 2015 Unknown Sex

4059 263 117 1,473 935 2,408 1996 Pair

Totals 13,872 7404 21,282

Analysis Indicator 1 – Risk to Reproduction

Based on habitat in known cores and home ranges, about 80 percent of the ACs analyzed in the project 

area are at a “low” risk to reproduction. One of the ACs has a very low risk to reproduction while the 

other ACs has a moderate risk to reproduction. In other words, the NSO ACs in the project area would 

likely have a high likelihood of being reproductively successful and contain enough suitable habitat to 

reproduce successfully if occupied.

Analysis Indicator 2 – Change in NSO Critical Habitat

The project areas and the analysis area overlap with the NSO critical habitat Subunit KLW7 (34,580 

acres) and a small portion of KLW6 (2,867). Critical habitat Subunit KLW7 contains 12,662 acres of 

nesting/roosting, 8,679 acres of foraging and 6,013 acres of dispersal habitat. No treatment would occur 

within KLW6 but it does fall within the analysis area for the project.

Environmental Consequences to Northern Spotted Owl

Direct and Indirect Effects of Alternative 1 (No Action)

No action would have no “direct effects” to NSO habitat or individuals. The Somes Bar Project area 

would remain in the existing condition for an undetermined amount of time. The lack of treatment would

retain all the remaining habitat and important legacy structures (e.g., large trees/snags and woody debris) 

to aid in the development of NSO habitat by providing physical structure as the stand regenerates. Fire 

modeling predicts increased losses or degradation of late-successional habitats. Stands would remain in 

overstocked conditions with a lack of structural diversity and decreased prey base for NSO foraging. 

Since NSO and their prey are associated with large trees/snags and logs, Alternative 1 would maintain all 

large trees/snags and large woody debris. However, the lack of treatment would not aid in reducing fuels 

that would likely increase the potential of the project area experiencing fire levels that may interrupt 

habitat regeneration and maintenance of these features on the landscape. The lack of treatment would

result in increased stand densities, increased fire severity, overstocking and potential loss of hardwoods 

due to competition with conifer.
Chapter 3. Environmental Consequences

194 – Somes Bar Integrated Fire Management Project

The lack of treatment would however, affect the rate of habitat development (overstocking and 

competition), stand complexity, and risk of future high severity fire consuming suitable habitat thus 

risking reproduction of NSO as well as to critical habitat.

Direct and Indirect Effects of Alternative 2 (Action Alternative)

All of the known NSO ACs within the analysis area would have some type of treatment in the home range 

and four (4) would have treatment in the core, but the level of affects would vary. For Analysis Indicator 

1, a “very low” risk is desired—one (1) of the ACs met this criterion before treatment and Alternative 2 

would not affect this AC’s risk level. None of the eight (8) ACs in the “low category” would increase in 

risk level. The ACs in the “moderate category” remained at the same risk level. None of the NSO ACs 

within the project area was ranked at the high-risk category.

Alternative 2 would result in the removal of critical habitat and nesting/roosting, foraging and dispersal 

(NRFD) habitat within the KLW7 subunit. The removal of habitat is due to new road and landing 

construction within the project area (Table 3-21). During project design, the group ensured that suitable 

habitat removal (NRFD) did not occur within NSO ACs cores (0 to 0.5 miles) that were deficit in habitat

with the exception of 0.1 acres in AC 1073. Landing or road construction would remove less than 0.25 

acres of habitat in any one area. All of the habitat removal would occur within the homerange of nondeficit NSO sites. The majority of landings and roads that would be used for this project are existing 

openings that would only need minor expansion and brushing for safe operations. Small, scattered 

openings across the project area can be beneficial in stands lacking structural diversity to “maximize 

individual tree development, encourage some understory vegetation development, and encourage the 

initiation of structural diversity” (Interagency REO memorandum 1996). In addition, the USFWS has 

considered this amount of habitat loss to be insignificant when considered with the project design features. 

The USFWS considers that effects to spotted owl habitats around ACs will be minimized if: there are no 

treatments or removal in the 70-plus acre nest groves; no high-quality habitat is being commercially 

treated; post-treatment canopy closure will be maintained at 60 percent or greater in nesting/roosting 

habitats, and 40 percent or greater in foraging and dispersal habitats in all treated areas; no pre-dominant or 

dominant trees will be removed; and all large logs and snags 20-inch dbh or greater will be retained (unless 

they pose a safety hazard). Northern spotted owl habitat will be maintained with the proposed vegetation 

management prescriptions and fuels management treatments (Table 3-20). The Somes Bar Project is not 

likely to affect the NSO or Critical habitat.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 195

Table 3-20. Effects to Northern spotted owl (NSO) activity centers (ACs) from proposed project activities.

NSO Activity 

Center 

Number & 

(Name)

Pre-implementation 

NSO Habitat within 

Core

Pre-Implementation NSO 

Habitat within Homerange

Post-implementation 

NSO Habitat within 

Core

Post-Implementation NSO 

Habitat within Homerange

0-0.5 Mile (Core) 0-1.3 Mile (Homerange) 0-0.5 Mile (Core) 0-1.3 Mile (Homerange)

F NR F NR NRF Total F NR F NR NRF Total

1250 125 201 911 1,330 2,241 125 201 908.3 1,328.9 2,237.2

1073 85 271 699 1,340 2,039 84.9 271 698 1,339.9 2,037.9

58 125 269 717 1,383 2,100 125 269 715.2 1,380.9 2,096.1

53 150 150 815 986 1,801 150 150 815 986 1,801

1089 106 259 883 1,228 2,111 106 259 883 1,228 2,111

1076 109 127 784 1,439 2,223 109 127 784 1,438.8 2,222.8

1260 26 376 503 1,762 2,265 26 376 502.9 1,762 2,264.9

SIS 111 43 319 498 1,433 1,931 43 319 498 1,433 1,931

4059 117 263 935 1,473 2,408 117 263 934.9 1473 2,407.9

52 60 251 659 1,498 2,157 60 251 659 1,498 2,157

Roadside hazard tree treatment would remove trees that pose a risk to human safety including trees 

that meet the tree hazard guidelines. In addition, fuels treatments would remove some understory in 

portions of the roadside treatment resulting in degrading but maintaining the understory habitat. These 

treatments are not expected to downgrade or remove suitable habitat and habitat should function at pretreatment levels. Commercial and fuels treatments would maintain NSO nesting/roosting habitat at 60 

percent canopy closure and foraging and dispersal habitat at 40 percent canopy closure post-treatment. 

The proposed commercial treatments would maintain habitat suitability and function post-treatment. 

Smoke disturbance would be mitigated by survey efforts prior to implementation.

Overall, the amount of NSO habitat across the range of the species has been on the decline primarily 

because of large fire events that resulted in removing many acres of habitat (Davis et al. 2015, Davis 

2015). The 2017 fires added to this negative trend in the amount and quality of NSO critical habitat on the 

SRNF. However, the 2017 fires within the NSO analysis area for the Somes Bar Project burned at lower 

intensities and did not remove large areas of suitable habitat. Previous research shows that fire severity 

trends correlate well with winter and spring precipitation amounts and temperature inversions during 

smoky conditions (Miller et al. 2012, Estes et al. 2017). The fact that 2017 was one of the wettest years in 

recent history explains why the 2017 fires burned at lower intensities. The NSO habitat baseline for the 

analysis area was adjusted after the 2017 fires and a new baseline was established for the project area.
196

– Somes Bar Integrated Fire Management Project

Chapter 3. Environmental Consequences

Table 3-21. Proposed treatments by activity center.

Activity 

Centers

Habitat 

type

Thinning (comm, 

pct, or biomass)

Fuels 

Treatments

Temporary Roads & 

New Construction

Landing 

Construction

Total 

Treatment 

Acres

% Total 

Treatment

Total 

Treatment 

Acres

% Total 

Treatment

0.5 mi 

acres

1.3 mi 

acres

0.5 mi 

acres

1.3 mi 

acres

0.5 mi 

acres

1.3 mi 

acres

0.5 mi 

acres

1.3 mi 

acres 0.5 mi acres 0.5 mi 1.3 mi acres 1.3 mi

1250

F 5 84 37 71 0 0 0 2.7 42 34 158 17

N/R 0 26 8 74 0 0.1 0 1.0 8 4 101 8

Non 13 65 33 92 0.3 1.3 1.8 5.7 48 27 164 14

Total 18 174 78 238 .3 1.4 1.8 9.4 98 20 423 12

53 

Donahue 

Flat

F 17 19 27 74 0 0 0 0 44 29 93 11

N/R 7 12 31 162 0 0 0 0 38 25 175 18

Non 41 197 53 287 0.8 4.1 2.9 12.1 97 48 500 31

Total 65 228 111 523 0.8 4.1 2.9 12.1 179 36 767 23

58

F 2 100 12 101 0 0.6 0 1.2 14 11 203 28

N/R 2 86 42 261 0 0.8 0 1.3 45 17 349 25

Non 15 200 9 129 0.6 3.2 1.5 17.3 26 24 350 27

Total 20 386 63 492 0.6 4.6 1.5 19.8 84 17 902 27

1073

F 4 21 0 73 0 0.1 0.1 0.8 4 5 95 14

N/R 1.4 8.3 5 50.3 0.07 0.11 0 0 6.4 2 58.71 4

Non 8.1 96.7 0.2 158.7 0 2.88 0.5 7.08 8.8 6 265.36 20

Total 14 126 5 282 0 3.1 0.6 7.9 20 4 419 12

1076

F 0 1 0 3 0 0 0 0 0 0 4 0

N/R 0 5 0 61 0 0 0 0.2 0 0 66 5

Non 0 0 0 2 0 2.9 0 0 0 0 5 0

Total 0 6 0 66 0 2.9 0 0.2 0 0 75 2

1089

F 0 0 0 5 0 0 0 0 0 0 5 1

N/R 0 0 0 5 0 0 0 0 0 0 5 0

Non 0 1 0 9 0 0 0 0 0 0 10 1

Total 0 1 0 20 0 0 0 0 0 0 21 1
Final Environmental Assessment 

– 197

Chapter 3. Environmental Consequences

Activity 

Centers

Habitat 

type

Thinning (comm, 

pct, or biomass)

Fuels 

Treatments

Temporary Roads & 

New Construction

Landing 

Construction

Total 

Treatment 

Acres

% Total 

Treatment

Total 

Treatment 

Acres

% Total 

Treatment

0.5 mi 

acres

1.3 mi 

acres

0.5 mi 

acres

1.3 mi 

acres

0.5 mi 

acres

1.3 mi 

acres

0.5 mi 

acres

1.3 mi 

acres 0.5 mi acres 0.5 mi 1.3 mi acres 1.3 mi

52

F 0 0 0 11 0 0 0 0 0 0 11 2

N/R 0 0 0 26 0 0 0 0 0 0 26 2

Non 0 15 0 99 0 0.6 0 0.5 0 0 115 9

Total 0 15 0 136 0 0.6 0 0.5 0 0 153 4

1260

F 0 6 0 102 0 0.1 0 0 0 0 108 21

N/R 0 7 0 56 0 0 0 0 0 0 63 4

Non 0 4 0 115 0 0 0 1 0 0 120 11

Total 0 16 0 273 0 0.1 0 1 0 0 290 9

SIS 111

F 0 0 0 127 0 0 0 0 0 0 127 26

N/R 0 0 0 131 0 0 0 0 0 0 131 9

Non 0 4 0 145 0 0 0 0.5 0 0 149 10

Total 0 4 0 403 0 0 0 0.5 0 0 407 12

4059

F 0 4 0 45 0 0.1 0 0 0 0 49 5

N/R 0 0 0 31 0 0 0 0 0 0 31 2

Non 0 11 0 51 0 0.1 0 0.5 0 0 63 6

Total 0 15 0 127 0 0.2 0 0.5 0 0 142 4
Chapter 3. Environmental Consequences

198 – Somes Bar Integrated Fire Management Project

Cumulative Effects

Future actions are included in the Aquatic Restoration Project, which is under development. California 

Department of Forestry and Fire Protection’s (CAL FIRE) website does not indicate if there are any 

additional timber harvest plans currently planned on private lands. The direct and indirect effects of 

Alternative 2 plus cumulative effects resulting from other actions within the analysis area did not change the 

risk level for any of the ACs (Table 3-22 and Table 3-23).

For Analysis Indicator 2, the cumulative effects would not result in any additional acres of critical 

habitat being removed. The direct and indirect effects of the Proposed Action would remove 

approximately 67 acres of NRFD habitat. The cumulative effects (about 0 acres of NRFD habitat) from

other projects would not contribute to this total. No critical habitat will be treated within KLW6. The 67 

acres (approximate) of critical habitat removed (NRFD habitat) represents about 0.2 percent of the NRFD

habitat (27,354 acres) within KLW7 in the action area.

Summary of Effects by Analysis Indicators (NSO)

Table 3-22. The number of NSO sites within each level of risk to reproduction (Analysis Indicator 1).

Risk to Reproduction Current Condition Alterative 2

Very Low 1 1

Low 8 8

Moderate 1 1

High 0 0

Table 3-23. Change in NSO critical habitat analysis Indicator 2.

Critical Habitat 

Subunit within 

Analysis Area

Critical Habitat 

Acres in 

Analysis Area

Nesting/ Roosting Foraging Dispersal

Current Alternative 2 

Acres Current Alternative 2 Acres Current Alternative 2 Acres

KLW6 2,867 1,495 0 470 0 532 0

KLW7 34,580 12,662 -3.3 (0.02%) 8,679 -5.9 (0.06%) 6,013 -58 (0.9%)

Forest Service Sensitive Wildlife Species

Analysis of project impacts to Forest Service Sensitive species is required by FSM 2670 through the 

preparation of a biological evaluation (BE). All Forest Service Sensitive wildlife species known or 

thought to occur in the project area (based on habitat and range), were evaluated for this project. It was 

determined that the project would have no impact on certain Forest Service Sensitive species, based on 

either the lack of habitat, lack of detections during surveys, or the fact that habitat would not be impacted.

In additon, surveys and limited operating periods (LOPs) could be used as a mitigation to reduce the risk 

that project actions would impair a species reproduction.

Species that would not be affected by this project include the greater sandhill crane (Grus canadensis 

tabida), great gray owl (Strix nebulosa), Siskiyou Mountains salamander (Plethodon stormi), cascade frog 

(Rana cascadae), northern red-legged frog (Rana aurora aurora), Tehama chaparral snail (Trilobopsis 

tehamana) and mardon skipper (Polites mardon mardon).
Chapter 3. Environmental Consequences

Final Environmental Assessment – 199

The following summarizes the effects analysis of those Forest Service Sensitive species and/or habitat 

that may be affected by this project (Table 3-24). The BE prepared for this project contains the affected 

environment for each species, description of indicators to base effects on as well as the assumptions upon 

which the analysis was done.

Bald Eagle

The two (2) known sites along the Klamath corridor are Green Riffle and Soldier’s Creek bald eagle nest 

sites. The Green Riffle bald eagle nest is 0.55 miles from the Rodgers project area. The Soldiers Creek 

bald eagle nest is 0.17 miles from the Ti Bar project area.

Indicator: Level of Disturbance

Disturbance of eagle nest sites can affect eaglet survival. The most common activities likely to occur in 

this project that may disturb eagles is noise created by equipment.

Alternative 1 (No Action)

The lack of treatment would have no effect on disturbing nesting eagles in the short- or long-term. The 

lack of treatment would result in increased stand densities, increased fire severity, overstocking and 

potential loss of habitat and nest trees within or adjacent to the nest stand.

Alternative 2 (Action Alternative)

In order to mitigate this concern, a PDF would minimize the risk of creating noise that may result in noise 

disturbance. Smoke disturbance would be mitigated by survey efforts prior to implementation.

Northern Goshawk

The Somes Bar Project area was surveyed for goshawk. One (1) goshawk nest was detected and the site 

produced offspring in 2015. No other sites are known to occur within the project area.

Indicator – Level of Disturbance

Little information is available about the direct effects of disturbance on nesting goshawks. However, 

goshawks generally exhibit a high level of vulnerability during the incubation stage. The KNF LRMP

S&Gs recommend a noise-disturbance distance buffer of 0.25 miles around nest sites (p. 4-29).

Indictor – Risk to reproduction

The amount and quality of nesting habitat can affect the success of a nest. The LRMP recommends that 

management in the goshawk primary nest zone (0.5 mile radius around nest site) maintain at least 60

percent canopy cover over 300 acres (primary nest zone equals 504 acres; KNF LRMP p. 4-29).

Alternative 1 (No Action)

One goshawk site was located during survey efforts for the Somes Bar Project. This site has sufficient 

habitat to reproduce and the site produced two (2) young in 2015. Without treatment, it would be 

expected that this site would continue to be active. The No Action Alternative would not disturb this

goshawk nest site. In the long term, the lack of disturbance is expected to continue without action.
Chapter 3. Environmental Consequences

200 – Somes Bar Integrated Fire Management Project

Alternative 2 (Action Alternative)

Alternative 2 would have treatment within 0.25 miles of the nest site (Rudy’s Nest). However, a PDF

would be used to avoid disturbance of this nest location during the sensitive part of nesting. Therefore, 

Alternative 2 would have a low risk of disturbing the known goshawk nest site. Smoke disturbance would

be mitigated by survey efforts prior to implementation.

Fisher, Marten, and Wolverine

Fisher

Fisher appear to be common within the project and analysis area. There have been many observations of 

fisher near or within the project area over the last 20 years. Baited camera station surveys have been 

conducted within the project area: positive detections have been made at many of the stations within the 

project areas in the two (2) years of sampling from 2016 to 2017. No den sites have been found.

Marten

The distribution of marten on the east side of the Forest along the Klamath River corridor is not well 

known due to the lack of consistent and reliable observations. Surveys for forest carnivores have been 

described above (see fisher) within the Somes Bar Project, and during fisher survey efforts a marten was 

detected in 2016. This marten was most likely a dispersing individual. No den sites have been found.

Wolverine

There are no verified records of wolverine on the SRNF: however, incidental sightings of wolverines have 

been reported on the northern part of the Forest. Most of the sightings occurred in the 1970s and 1980s.

Surveys were conducted in the Somes Bar Project area in 2016 and 2017 using baited camera stations. No 

wolverine were detected. We are assuming the wolverine could be present in the project area and would 

use the same basic habitat as the fisher.

Indicator – Level of Habitat Alteration

Fisher, marten, and wolverine occupy similar habitat of late-successional, dense conifer forest. These 

species are commonly found at different elevations with some overlap. All three (3) of these species move 

across the landscape using higher or lower elevation conifer forests even though the elevation may be 

outside the average elevation range for the particular species.

Indicator – Change in Fisher Home Range

Fisher home range selection is important because the home range must provide sufficient resources for 

survival and reproduction. Some of the basic characteristics of home range selection appear to be related 

to tree canopy closure, tree size class, percentage of conifer, and openness (area with little overhead 

cover; Carroll et al. 1999, Weir and Corbould 2010). However, the amount and distribution of these 

habitat characteristics can affect a fisher home range. Fisher can be split into three (3) habitat categories: 

denning/resting, foraging, and movement. Denning/resting habitat is typically the least common on the 

landscape followed by foraging. Movement habitat, which provides overhead cover for fisher to move 

from one (1) patch of denning/resting habitat to another and avoid predation, is more common.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 201

The loss of overhead cover creates openings that may affect the function of a fisher home range. 

Fishers avoid crossing large openings and moving around large openings while staying within habitat may 

not be feasible for a home range to function. A fisher home range needs about half of the home range with 

at least 50 percent canopy cover and 30 percent of the home range with 20 percent overhead cover.

Alternative 1 (No Action)

Fisher, marten, and wolverine are forest dependent species that are strongly associated with older forests 

with dense canopy cover. The project area is currently in an overstocked dense condition with canopy 

closure typically above 90 percent. The No Action Alternative would have no “direct effects” to fisher, 

marten, or wolverine habitat or individuals. Unfortunately, Alternative 1 would not help to protect 

existing habitat. The overstocked stands and increased competition would increase the likelihood of future 

high severity fire possibly threatening more denning/resting habitat and increasing fragmentation of home 

ranges. Therefore, Alternative 1 would not affect the level of habitat alteration or the amount of habitat 

needed for a fisher home range.

Alternative 2 (Action Alternative)

Alternative 2 would most notably affect seven (7) of the watersheds. The proposed treatments would

result in seven (7) of the watersheds changing in level of habitat alteration from low to moderate. Three 

(3) of the watersheds remained at the same level of habitat alteration given the effects of Alternative 2.

Of the watersheds analyzed for impacts one (1) of the watersheds is above 20 percent habitat 

alteration (Natuket-Klamath). Two (2) are above 15 percent, but below 20 percent habitat alteration 

(Ogaromtoc-Klamath, and Rodgers Creek). The other four (4) are below 15 percent, but above the 10

percent criteria for a low level of habitat alteration.

Ten (10) of the watersheds met the criteria of possibly containing or contributing to a fisher home 

range. These 10 watersheds are likely to contain enough habitat and could contribute to a fisher home 

range after proposed treatments.

Pallid Bat, Townsend’s Big-eared Bat, and Fringed Myotis

Pallid bats

Surveys have not been conducted within the project area, but because suitable large tree roost sites are 

fairly common and it is reasonable to conclude that pallid bats are present within the project area. Suitable 

roost sites for pallid bats in the form of large trees and snags do occur in the project area. Other structures, 

including buildings and bridges, also occur within or adjacent to project area, but are much more limited.

Townsend’s big-eared bats

Surveys have not been conducted and no known locations occur within the project area. Caves or open 

mines are not known to occur within the project area; however, suitable roost sites for Townsend’s bigeared bats in the form of large diameter trees are scattered throughout the project area. Thus, it is 

reasonable to assume that Townsend’s big-eared bats are present in the project area. Surveys would not be 

conducted for this species.
Chapter 3. Environmental Consequences

202 – Somes Bar Integrated Fire Management Project

Fringed myotis

Little is known on the species abundance and distribution, although potentially suitable roost sites exist 

within the SRNF. This species is known to roost in caves, mineshafts and abandoned buildings. There are 

no detections of this species in the project area and no known roost sites within the project area.

Indicator – Risk of disturbance

The KNF LRMP recommends no timber harvest within 250 feet of a roost site (S&G pg. 4-32; i.e., 

hibernacula or maternity).

Alternative 1 (No Action)

Three potential sites were identified within the project area. For Alternative 1, the lack of action would

not affect bats. The lack of disturbance created by treatment and fuels treatments would maintain any 

hibernaculum or maternity sites. Therefore, for Analysis Indicator 1, the risk of disturbance is no effect.

Alternative 2 (Action Alternative)

The action alternative would have direct and indirect effects for Analysis Indicator 1. All of the known 

sites within the project area would have a low or moderate risk of disturbing a possible bat maternity or 

hibernacula. Given the period when treatment is most likely to occur (summer and fall months), treatment 

is not likely to disturb a possible hibernacula. The treatments may disturb a maternity because maternities 

are active from April to August, but are most sensitive during the early spring when the offspring are not 

capable of flight. Although unlikely, the two (2) sites with a moderate risk of disturbance could affect a 

maternity, but more realistically, treatment greater than 250 feet is only likely to disrupt foraging bats. 

The site identified as a historic cave is ranked as low because of the site is over 0.5 miles from proposed 

treatment units. Although caves can possess features that are desirable for bats this site has not been 

checked in the field for occupancy. Maternities are not common because bats need specific cave 

environment conditions and although this site maybe a historic mine it may not have the criteria to be 

suitable as a site.

Willow Flycatcher

Surveys have not been conducted within the project area. No nest site locations are known within or 

adjacent to the project area. Willow flycatchers have been detected upriver on the KNF. The distribution 

and amount of willow flycatcher reproduction is not well known on the Forest, but reproduction is 

possible. We are assuming that flycatchers are present on the Forest and reproduction is most likely to 

occur in riparian areas primarily in the low gradient and larger waterways. The remaining waterways 

within the project area would be high gradient and less suitable or would not contain suitable vegetation 

for willow flycatcher reproduction.

Indicator – Habitat alteration

It is difficult to translate the number of territories actually affected by the proposed activities, but it can 

assume based on the average size of territories that even 1 acre of riparian habitat could affect willow 

flycatchers. Therefore, small changes in habitat associated with reproduction could have large effects on 

the willow flycatcher, if present.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 203

Alternative 1 (No Action)

The flycatcher would continue to use available habitat within the project area. In the long-term, the 

habitat could be lost due to due lack of proposed treatments. For Analysis Indicator 1, the lack of action 

would have no effect on risk to habitat alteration.

Alternative 2 (Action Alternative)

The direct and indirect effects on willow flycatcher habitat is low for (100 percent) of the 7th-field 

watersheds in the analysis area. Most of the effects are the result of fuels treatments in riparian reserves. 

The primary habitat identified in the watersheds is along the Klamath River corridor. This habitat falls 

within the treatment polygons but the river corridor has isolated pockets of suitable willow habitat. The 

fuels treatments in these areas would be difficult because nothing would carry fire over sand and rock bars.

Western Bumblebee

In general, bumblebees prefer open meadow like areas with a high diversity of plant structure with an 

abundant amount of flowering plants (Hatfield et al. 2012). Habitat can also extend into agricultural fields 

or orchards where flowering agricultural plants can provide similar food resources (Hatfield et al. 2012). 

There is little information regarding the western bumblebee on the SRNF. The nearest confirmed 

detections were of two (2) bumblebees in 1997 in the Marble Mountain Wilderness on KNF. Within the 

project area, most of the large openings occur on private property.

Indicator – Habitat disturbance

The desired condition for bumblebee is a low level of disturbance. The western bumblebee like other 

species of bumblebees is sensitive to habitat disturbance. In the project area, high quality wet meadow 

habitat and large openings are difficult to find.

Alternative 1 (No Action)

There is almost no suitable habitat for the western bumblebee in the project area. Alternative 1 would

have no direct effect to the western bumblebee or its habitat. Any existing habitat within the project area 

would provide nesting and foraging opportunity for bumblebees.

Alternative 2 (Action Alternative)

The action alternative would have low levels of effects on the disturbance level on the western 

bumblebee. Treatments are not likely to occur in wet meadow habitats over 5 acres in size. The majority 

of large opening and wet meadows in the project area occur on private property or east of the project area 

in the Marble Mountain Wilderness.

Foothill Yellow-legged Frog

Surveys for the foothill yellow-legged frog have not been conducted in the project area. The majority of 

in-stream environments within the treatment area are not suitable for the foothill yellow-legged frog as 

they are characterized by steeper gradients and/or fast currents. However, along the Klamath River 

corridor and the lower tributaries it is reasonable to assume that this species is present. We are assuming 

that the frogs occur in the area and that the Klamath River has appropriate oviposition habitats along the 
Chapter 3. Environmental Consequences

204 – Somes Bar Integrated Fire Management Project

river and in the lower reaches of stream confluences to the Klamath. Foothill yellow-legged frogs have 

been located in higher reaches of tributaries in the post-breeding and over-wintering seasons.

Indicator – Risk of disturbance

Alternative 1 (No Action)

Under the No Action Alternative, the scenario of a large, uncontrolled wildlife fire with high intensity 

burn coverage could devastate both upland and riparian habitats. In the case of a wildfire burning through 

riparian habitat, direct take of individuals would likely occur in areas of intense burn. Indirect take from 

fire may occur with the increase in sediment loading associated with fires (Sankey et al. 2017), that would 

be transported down tributaries and into the Klamath River, exacerbating the coverage of egg masses or 

filling interstitial spaces used by tadpoles.

Alternative 2 (Action Alternative)

The total amount of stream riparian reserves within the project area is approximately 2,122 acres, with 

mechanical treatments occurring in 147 acres in the outer 80 feet of the riparian reserves. Since adults are 

reported to rarely move outside of the 39-foot distance from the stream line, the level of impact to the 

species should be nominal. Manual fuels treatments to reduce ladder fuels occur within the 2,122 acres

and prescribed fire would be allowed to back in from outside the riparian reserve buffer. Within the 

riparian reserves, actions are designed to minimize ground disturbance and maintain canopy cover while 

reduction the risk of a higher intensity wildfire.

Southern Torrent Salamander

Suitable habitat can be found throughout the SRNF, particularly on the western coastal ranges. This 

species is associated with seeps, small streams, and waterfalls in wet or mesic coastal-forested habitats 

(Welsh and Lind 1996, Diller and Wallace 1996). Changes to forest canopied and the hydrology of seeps 

and streams can affect southern torrent salamanders. Surveys have not been conducted for Southern 

torrent salamanders in the Somes Bar Project area but potentially suitable habitat is present within the 

project area along the upper-most reaches of perennial creeks. A southern torrent was found during 

spotted owl survey efforts in 2017 in the Ti Bar project area. Habitat for this species is present in the 

planning area. Pre-project surveys for this species would not be conducted.

Indicator – Risk of disturbance

Alternative 1 (No Action)

Under the No Action Alternative, the scenario of a large, uncontrolled wildlife fire with high intensity 

burn coverage could devastate both upland and riparian habitats. In the case of a wildfire burning through 

riparian habitat, direct take of individuals would likely occur in areas of intense burn. Indirect take from 

fire may occur with the increase in sediment loading associated with fires (Sankey et al. 2017), that would 

be transported down into riparian habitats, exacerbating the filling of interstitial spaces used by southern 

torrent salamanders for all life stages
Chapter 3. Environmental Consequences

Final Environmental Assessment – 205

Alternative 2 (Action Alternative)

The total amount of stream riparian reserves within the project area is approximately 2,122 acres, with 

mechanical treatments occurring in 147 acres in the outer 80 feet of the riparian reserves. Since adults are 

reported to rarely move outside of the wetted channel of the stream, the level of impact to the species should 

be very small as no actions occur within the stream channel. Manual fuels treatments to reduce ladder fuels 

occur within the 2,122 acres and prescribed fire would be allowed to back in from outside the riparian 

reserve buffer. Within the riparian reserves, actions are designed to minimize ground disturbance and 

maintain canopy cover while reduction the risk of a higher intensity wildlife.

Western Pond Turtle

There have been no surveys conducted specifically for turtles, however, there is little suitable habitat for 

the species on the Somes Bar Project, due to the geology and geomorphology occurring upslope of the 

main stem of the Klamath River.

Indicator – Risk of disturbance

Alternative 1 (No Action)

Under the No Action Alternative, the scenario of a large, uncontrolled wildlife fire with high intensity 

burn coverage could devastate both upland and riparian habitats, to include both nesting benches and 

over-wintering habitats. In the case of a wildfire burning through nest benches or over-wintering habitat, 

direct take of individuals would likely occur in areas of intense burn if occurring when turtles have moved 

up from the Klamath River to over-wintering site in late September and fires occurring at that time or 

later. Indirect take from fire may occur with the increase in sediment loading associated with fires that 

could change subsequent nutrient sources leading to a trophic cascade event not suitable to turtle prey 

species (Emeko et al. 2016).

Alternative 2 (Action Alternative)

Within the 7th-field watershed with a buffer zone from 330 feet (100 meters) to 1,640 feet (500 meters), 

there is 5,261 acres of potential habitat, with 778 acres of habitat being treated by mechanical, manuals or 

prescribed burn treatments, or 15 percent of the analysis area being treated. With either mechanical or 

manual treatments, all 778 acres would have a prescribed burn treatment, and affect the 15 percent of 

potential nest sites or over-wintering habitats. The heat from fire could have direct impact on any stage of 

the turtles in the treatment areas, but would likely be of a lower intensity burn than an uncontrolled wildfire. 

Turtles may escape effects of fire by residing under soil in a low-intensity scenario, permitting perpetual 

existing in the area.
Chapter 3. Environmental Consequences

206 – Somes Bar Integrated Fire Management Project

Cumulative Effects for Forest Service Species

Table 3-24. Summary of the Proposed Action and its effect on each federally listed and Forest Sensitive species.

Species Determination

Federally Listed Species

Northern spotted owl (NSO) May affect, not likely to adversely affect.

NSO Critical Habitat May affect, not likely to adversely affect.

Forest Sensitive Species

Bald eagle, northern goshawk, fisher, marten, wolverine, 

pallid bat, Townsend’s big-eared bat, fringed myotis, willow 

flycatcher, western bumblebee, foothill yellow-legged frog, 

southern torrent salamander, western pond turtle

May impact individuals, but is not likely to result in a trend 

towards federal listing.

Summary of Effects to TEK Focal Species

Fisher

In general, fisher dispersal is affected by the reduction in fisher habitat and the distance between patches 

of habitat (Weir and Corbould 2010). The desired condition is to maintain all potential suitable habitat for 

these species within a 7th-field watershed. Ten of the watersheds met the criteria of possibly containing or 

contributing to a fisher home range. These 10 watersheds are likely to contain enough habitat and could 

contribute to a fisher home range after proposed treatments.

Northern Spotted Owl

See above for discussion of northern spotted owl.

Roosevelt Elk

The proposed treatments and the level of habitat alteration would have beneficial effects in the watersheds 

for Roosevelt elk. The goal of the proposed treatments is to promote a mosaic of habitat types across the 

landscape. Fire suppression over the last 100 years has simplified calving and wintering habitats. 

Encouraging mixed severity fire on the landscape would reduce conifer encroachment in hardwoods, 

increase perennial grass diversity and increase structural diversity providing hiding cover for calving and 

calves during the reproductive period. In addition, without the influence of naturally occurring mixed 

severity fire oak woodlands have become encroached with conifer. The Proposed Action would benefit 

calving and wintering habitats, and reduce conifer encroachment within the project area. The proposed 

treatments would also reduce the risk of hiding cover loss by high severity fires in the watershed.

In addition, during project design the interdisciplinary team (IDT) identified areas for calving, suitable 

foraging, and wintering habitat enhancement opportunities. Components of these habitat dynamics were 

built into the selection process for identifying opening and retention areas during treatment layout.

A grant application with California Department of Fish and Wildlife, titled “Marble Mountain Elk 

Ecology and Management Collaborative Research Initiative,” has been funded. The Karuk Department of 

Natural Resources, in partnership with California Department of Fish and Wildlife and academic 

researchers, is developing strategies to restore elk habitat in Karuk Aboriginal Territory through 

prescribed fire and fuels treatments in coordination with the WKRP. The goals of this agreement are to 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 207

provide a better understanding of elk population dynamics, migrations, and habitat utilization, which is 

needed to assist in directing management decisions. The proposed monitoring will include collaring, 

monitoring and tracking elk around the WKRP planning area. The goals of this agreement are to:

1. Gather data to estimate elk population dynamics, migrations, and habitat utilization; and

2. Develop best management practices for prescribed fire and fuels treatment to restore elk 

winter range within the project area.

Data collection from GPS collars, trail cameras, and fecal transects will help determine population 

dynamics, movement, and habitat use of elk utilizing the study area in the Marble Mountain portion of 

Siskiyou County. The data will be gathered in collaboration with subcontractors from the University of 

California Berkeley and Humboldt State University.

New temporary roads total 0.6 miles and use on existing temporary roads is 8.1 miles. The temporary 

roads would be closed once implementation on project activities is complete. Road densities open to 

vehicular traffic are not expected to increase within the project area.

In addition, within the riparian reserves (2,122 acres), only 147 acres would be commercially treated. 

These riparian reserves serve as corridors and networks within the project areas providing connectivity to 

patches of security cover and calving habitats. Implementing this project would provide adequate security

cover for elk and improve wintering habitat for this species.

Pacific Giant Salamander

The risk of disturbance to the Pacific giant salamander would be low following the criterion developed for 

the species and the amount of habitat used being treated by the Proposed Action. The reported available 

research on movement and habitat use has the species highly associated with use of the inner 80-foot 

buffer that would have no mechanical treatment in the stream tributaries occurring in the four (4) project

areas. Within fish bearing stream reaches (320 foot riparian reserve widths), no mechanical treatment 

would occur within 240 feet. The impacts of fall prescribed fires that would be allowed to back-down into 

the inner 80-foot riparian reserves would occur at a temporal and spatial extent that would be minimal for 

any given single season. For prescribed fire down within the Klamath River floodplain, and associated 

riparian habitat along the Klamath River, fall burns would not likely impact species, as most of the larvae 

would have achieved metamorphic climax and begun dispersal up associated tributaries, as would that 

adults have moved earlier in the summer post-breeding activities. For adult Pacific giant salamanders 

moving or dispersing during winter rains, habitat modifications may be at a moderate risk in areas where 

large woody material (LWM) has not be retained on the landscape.

Willow

Willow is a TEK focal species and is being managed for basket making material. The direct and indirect 

effects on willow (Salix spp.) habitat is low for (100 percent) of the 7th-field watersheds in the analysis 

area. Most of the effects are the result of fuels treatments in the riparian reserves. The primary habitat 

identified in the watersheds is along the Klamath River corridor. This habitat falls within the treatment 

polygons but the river corridor has isolated pockets of suitable willow habitat. The fuels treatments in this 
Chapter 3. Environmental Consequences

208 – Somes Bar Integrated Fire Management Project

area would be difficult because nothing would carry fire over sand and rock bars. Suitable habitat was not 

identified in the interior of the project area because the stream channels became incised and alder was 

more prevalent in these areas. Therefore, the number of watersheds within each of the levels of habitat 

alteration did not change with the effects of Alternative 2. The direct and indirect effects on willow (Salix

spp.) habitat is low for (100 percent) of the 7th-field watersheds in the analysis area.

Management Indicator Species

Under the NFMA, the Forest Service is directed to “provide for diversity of plant and animal 

communities based on the suitability and capability of the specific land area in order to meet overall 

multiple-use objectives” (PL 94-588, §6(g)(3)(B)). The 1982 regulations implementing NFMA require 

that “Fish and wildlife habitat shall be managed to maintain viable populations of existing native and 

desired non-native vertebrate species in the planning area” (36 CFR 219.19). Management indicator 

species (MIS) is a concept used by the agency to serve as a barometer for species viability at the forest 

level. Population changes of MIS are believed to indicate the effects of management activities.

The SRNF and KNF LRMPs use MIS to assess potential effects of project activities on the various 

habitats and habitat assemblages with which these species are associated. Forty-one fish and wildlife 

species have been selected as MIS or assemblages for a variety of habitats that are potentially affected by 

resource management activities on the forest (LRMP IV-97). The potential impacts to MIS were analyzed 

and the results are summarized here. The full report is located in the project file (Yost and Bettaso 2017b).

Seral stages in the project area range from shrub to mid-mature stands with smaller patches of latemature and old growth. The project is designed to improve habitat conditions through the acceleration of 

late-successional habitat characteristics, while still maintaining current functional habitat. Canopy closure 

would be maintained in late-successional habitats, vegetation species diversity and composition would be 

maintained, and retention of snags and downed logs would be retained at 80 to 100 percent of the average 

numbers found within mature and old growth stands within the forest.

This project would degrade but maintain a approximately1,836 acres of early seral stage habitat due 

to shaded fuelbreaks, commercial and pre-commercial thinning in early seral stands (shrub through early 

mature). For species that utilize early seral habitat (such as the lazuli bunting) this represents 32 percent

of the early seral stage habitat in the project area.

No commercial harvest would occur in high quality late-successional habitat; however, shaded 

fuelbreak construction would occur in late-successional habitat along the main roads. Ridgetop shaded 

fuelbreak treatments would degrade but maintain habitat that are considered suitable for late successional 

associated species. These fuel treatments would degrade but maintain approximately 0.08 percent of the 

suitable habitat for these species available in the project area. In two (2) locations, the shaded fuelbreak 

would be approximately 150-feet wide on either side of the road. Only brush and small diameter trees 

(less than 4′′ dbh) would be handpiled and burned. No overstory trees would be removed. All exiting 

snags and downed wood would be retained, unless the former poses a safety hazard. There would be 

minor habitat degradation for understory species such as the Pacific wren and ruffed grouse within the 

project areas through the removal of brush and small diameter (less than 8′′ dbh) trees; however,in the 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 209

long term, reduction of fuel ladders in these areas would improve adjacent habitat areas resilience to fire 

disturbance. Overstory canopy closure would be maintained, ground disturbance would be limited to 

existing roads and skid trails, vegetation species diversity and composition would be maintained, and 

retention of snags and downed logs would be retained at 80 to 100 percent of the average numbers found 

within mature and old growth stands within the Forest.

All riparian reserves have a no-commercial treatment established within 80 feet of the stream channel 

(inner 80 feet) and limited commercial treatment based within the outer 80 feet, with equipment exclusion 

requirements in the remaining riparian reserves (approximately 160 feet total riparian reserves width). 

Fuels treatments would be allowed to back down into the riparian reserves. In addition, handpiling of 

material less than 4 to 6 inches would be allowed within the riparian corridor. This would reduce “flashy 

fuel” accumulation in the riparian reserves. Adjaenct to perrnial streams, willow, a TEK focal species, is 

found and is being managed for suitable basket making material. Little to no true riparian habitat exists 

within the units given the lack of riparian vegetation associated ephemeral and intermittent stream courses 

within the project area. However, in the long-term project implementation has the potential to improve 

riparian habitat conditions through the release of conifer and hardwoods/shrubs from thinning, generating 

a secondary canopy. The project would maintain high levels of coniferous canopy closure within the 

project area adjacent to riparian reservess. Implementation of the project would maintain and improve 

riparian habitat conditions.

Understory burning may also cause short-term habitat degradation through the loss of small woody 

debris; however, burning would occur under specific weather and moisture condition designed to 

minimize damage to the residual stand, maintain large woody debris, and maintain at least 50 percent of 

the duff layer. Some minor local increases in fuels may occur from project generated slash, but due to 

proposed post-harvest fuel treatments, fuel loading would not be a threat to the treated areas. In the long 

term, reduction of fuel ladders would improve stand resilience to fire disturbance.

Understory burning the black oak/white oak assemblage would reduce conifer encroachment and 

protect and enhance the habitat in the long-term. MIS species such as the black-tailed deer and Roosevelt 

elk (TEK focal species) would benefit from burning these areas.

The Somes Bar Project would not adversely impact MIS. Although shaded fuelbreak construction 

would degrade habitat for species such as the Pacific wren and ruffed grouse, the majority of the project 

would improve/restore habitat conditions for all MIS by thinning (both commercial and precommercial) 

young, homogenous stands, culturing and releasing hardwoods, accelerating the development of multistoried conditions, and other late-successional habitat characteristics. In addition, development of 

strategic fuelbreaks would help protect existing habitat from stand replacing fire.

Survey and Manage

One S&M species occurs in the project area. No known sites for the red tree vole are known to occur in the 

project area. The Oregon red tree vole (Arborimus longicaudus) is a Category C species, which require predisturbance surveys. Red tree vole strategic surveys were conducted on the KNF in 2000. In 2002, random 

grid strategic surveys were conducted on the KNF. In 2015, random line transects were conducted in 
Chapter 3. Environmental Consequences

210 – Somes Bar Integrated Fire Management Project

suitable habitat in all four (4) project areas for the Somes Bar Project. Recent research has defined the 

distribution of the red tree vole north of the Klamath River corridor. Only one (1) of the project areas 

(Donahue) is in the described range of Arborimus longicaudus (Forsman et al. 2016). In 2015, random line 

transects were conducted in all four (4) project areas (Ti Bar, Patterson, Rodgers, and Donahue). No red tree 

vole nests were documented in or adjacent to the project area in 2000, 2002, or 2015. These surveys serve to 

comply with the NWFP ROD for all species that may occur in the project area (Moore and Connaughton 

2014; Bettaso, Yost and Hoover 2017). The red tree vole is not be analyzed further in this document.

The blue-gray taildropper (Prophysaon coeruleum) occurs on the Orleans RD (Survey and Manage 

Protocol 2003). The blue-gray taildropper is a Category A species that typically has pre-disturbance 

surveys and is listed to occur on the Orleans RD. The Somes Bar Project occurs primarily on the Ukonom 

RD (97 percent) which is outside of the range of this species. Three (3) percent of the project area occurs 

on the Orleans RD. This portion of the project is located in the Donahue project area. Review of the NRIS 

database and numerous surveys for SRNF projects has not detected the species on the Orleans RD or the 

Ukonom RD. Species collected during survey efforts include other species of Prophysaon, including P. 

dubium) and other undescribed Prophysaon species by taxon expert Dr. Barry Roth. There were and no 

detections of Prophysaon coeruleum. Of the 183.9 acres in the Donahue project area occurring on the 

Orleans RD, 34 acres (18 percent) are proposed for mechanical treatment, 68.2 acres (37 percent) are 

proposed for manual prescribed fuels treatment units, and the remaining 17.3 acres (9 percent) of 

mastication treatment that would be followed by manual treatments and prescribed burns. This would be a 

total of 119.5 acres (65 percent) of the 183.9 acres within the Donahue project area proposed for treatment 

on the Orleans RD. The remaining 64.4 acres would be excluded from commercial treatment because of 

mitigation (FWS) including the designated northern spotted owl nest grove, and private land. The 

Pechman Rule also provides exemption for fuels treatments and in commercial stands less than 80 years 

of age. This species would not be discussed further in this document.

The Somes Bar Project would not adversely impact S&M species. Although the treatments may

degrade/modify habitat, overall the project would improve/restore habitat conditions for all S&M species

by thinning (both commercial and precommercial) young, homogenous stands, culturing and releasing 

hardwoods, accelerating the development of multi-storied conditions, and other late-successional habitat 

characteristics. In addition, development of strategic fuelbreaks would help protect existing habitat from 

stand replacing fire.

Migratory Birds

Diverse natural communities are highly dependent upon the disturbance factors (such as fire regimes) that 

develop the structure and function of ecosystems. Communities can undergo negative changes in species 

composition and richness without these disturbance regimes or from the changes that result from a history 

of active management (reviewed in Atwilla 1994). In the Pacific northwest, Kennedy and Spies (2004) 

cite declines of diversified early-seral forests and broadleaf (hardwood) components of conifer-dominated 

landscapes federal lands resulting from years of fire suppression and the focus of old-growth 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 211

conservation. Under current management policies, similar trends have in the same area on federal and 

non-federal lands have been modeled for the future (Spies et al. 2007).

Negative impacts to songbird populations have been observed to occur as a response to large-scale 

vegetation changes (Drapeau et al. 2000). Specific to hardwood associated bird communities, Betts et al. 

(2010) also hypothesized that declines of songbirds in species in the Pacific Northwest were due to the 

combination of forest succession and increased intensified forestry. This study found positive associations 

of many songbird species with the amount of broadleaf and young broad leaf forests at broad spatial scales.

Understanding the type and extent of disturbance and other ecological mechanisms in landscapes of 

interest are critical when considering management approaches (ibid). The North American Bird 

Conservation Initiative (2011) has identified the restoration of fire regimes as one of the most important 

challenges for forest managers nationwide. That synopsis details some successes and challenges to 

restoration projects including successful prescribed fire treatments and silvicultural practices that promote 

hardwood regeneration. The Somes Bar Project proposes management that attempts to recreate conditions 

and reintroduces ecological processes conducive to migratory songbirds.

On December 12, 2008, an MOU was signed by the Forest Service and the USFWS to promote the 

conservation of migratory birds. This MOU directs agencies to evaluate the effects of proposed actions on 

migratory birds, focusing first on species of management concern along with their priority habitats and 

key risk factors. Mechanical treatment of forested habitats do have the ability to mimic the effects of fire, 

but efficacy of these treatments may depend whether or not they replicate food availability or predation 

conditions that are created by natural fire. As fuels reduction activities are implemented in the Western 

Klamath region, these activities should be closely monitored with respect to their effect on bird 

abundance and demography. For the Six Rivers and Klamath national forests, the MBS of management 

concern include species listed under the ESA as Threatened or Endangered, species designated by the 

Regional Forester as Sensitive species and species listed under S&Gs 8-21 through 8-34 of the KNF 

LRMP as MIS for project level assessment (Yost and Bettaso 2017b). There have been no site-specific 

surveys for migratory birds within the project area.

Cumulative Effects to TES, MIS, NTM, and other Wildlife Species

Regarding all the past impacts from land uses (mining, timber harvest, and road constructions), the Somes 

Bar Project will facilitate restoration by thinning plantations, non-plantation stands and introducing fire 

on the landscape. The beneficial cumulative effects include the reduction of habitat fragmentation and the 

development of late-seral conditions.

For an in depth description of the Ukonom and Orleans ranger districts and its history, see Ishi-Pishi 

Ecosystem Analysis (1998) and the Forest-wide LSRA (USDA Forest Service 1999).

Timber Harvest

Timber harvest activities and the suppression of wildfire in the Klamath Watersheds has led to changes in 

seral stages and increases in fuel loading. This shift in seral stage distribution is highest in the tanoak and 

Douglas-fir series, due to harvest of commercially valuable old-growth Douglas-fir stands that began in 
Chapter 3. Environmental Consequences

212 – Somes Bar Integrated Fire Management Project

the late 1950s. There has been a reduction in old-growth forests and an increase in shrub, pole, and early 

mature forests.

Most of this harvest activity was concentrated on the lower one-third slope in the Douglas-fir and 

tanoak series. Within the 46,243-acre action area, approximately 8,047 acres (17%) was harvested and are 

now in younger seral stages. Within the project areas (Ti-Bar, Rodgers, Patterson and Donahue), there 

was an estimated 3,079 acres of plantation, and clear-cut logging prior to the 1980s. Past, present and 

foreseeable projects that are in and around the current project footprint include Roots and Shoots Cultural 

Burn Project (Roots and Shoots Project), Orleans Community Fuels Reduction Project (OCFR), Katimiin 

Thin Project, and the Six Rivers Aquatic Restoration Project.

This section provides a summary of past and present and foreseeable actions that have occurred within 

the Somes Bar Project area boundaries, with the exception of the 319-acre 2017 Marble Fire that burned 

within a portion of the Patterson project area. Past timber harvesting includes 3,079 acres of various 

treatments (Table 3-25) that has occurred in the project areas. The majority of these past actions affected 

suitable habitat for threatened, Forest Sensitive, MIS, S&M, and MBS addressed in this document.

Table 3-25. Summary of harvesting by project area.

Project Area Acres

Donahue

Commercial Thin 155

Improvement Cut 14

Patch Clearcut (EA/RH/FH) 273

Sanitation Cut 185

Stand Clearcut (EA/RH/FH) 486

Total 1,113

Patterson

Commercial Thin 78

Overstory Removal Cut (from advanced regeneration) (EA/RH/FH) 125

Patch Clearcut (EA/RH/FH) 101

Salvage Cut (intermediate treatment, not regeneration) 3

Sanitation Cut 35

Stand Clearcut (EA/RH/FH) 362

Thinning for Hazardous Fuels Reduction 292

Total 996

Rodgers

Improvement Cut 19

Patch Clearcut (EA/RH/FH) 38

Stand Clearcut (EA/RH/FH) 195

Thinning for Hazardous Fuels Reduction 80

Total 332

Ti-Bar

Patch Clearcut (EA/RH/FH) 126

Stand Clearcut (EA/RH/FH) 88

Thinning for Hazardous Fuels Reduction 424

Total 638

Grand Total 3,079
Chapter 3. Environmental Consequences

Final Environmental Assessment – 213

Since the late-1990s, vegetation management projects on these districts (Ukonom and Orleans) have 

involved thinning plantations and natural stands to accelerate the development of late-successional 

characteristics for the benefit of fish and wildlife, as well as to reduce fuel loading to protect existing latesuccessional habitats. Ecological restoration of upland and riparian habitats and processes can be 

accelerated with active management.

Ongoing Forest Projects

The intent of OCFR was to reduce hazardous fuels along ridges at key locations, reduce surface and 

ladder fuels, and allow cultural burning and maintenance through prescribed fire. The intent of vegetation 

treatment was to reduce the density of understory vegetation, low- to mid-canopy-level and co-dominant 

trees, while promoting the development of large trees. Approximately 2,587 acres of treatment occurred,

of which 1,183 acres was commercial treatment and 1,404 acres was hand treatment. All the treatments 

within suitable NSO habitat maintained and did not downgrade or remove habitat.

The Roots and Shoots Project was a fuels reduction project. The project will treat 176 acres of phased 

(about every 2 to 4 years), low-intensity prescribed fire botanical restoration treatments and 

complimentary non-commercial hand thinning, pruning, chipping, lop and scatter and/or handpile, and 

pile burn units. Given the nature of the project with its focus a) on prescribed burning designed for lowintensity fire to promote culturally significant plant species (e.g., hazel, Corylus cornuta) and if present, 

Thermopsis robusta; b) a burning interval associated with the Phaeocollybia of no less than 2 years; c) the 

project’s use of manual techniques for thinning fuels; and d) application of soil S&Gs pertaining to 

retention of CWD and ground cover, it was expected that this project would not result in any negative 

effects to Sensitive species. Details relative to the analysis of Sensitive species can be found in the BA/BE 

for the Roots and Shoots Project.

The Katimiin Thin Project was a pre-commercial thinning project implemented by the Karuk Tribe 

with the Katimiin MOU agreement. The project pruned and thinned the understory vegetation to improve 

basketry and food gathering opportunities for the Karuk Tribe.

Based on the CalFire website review on February 5, 2018, there are currently no known private 

timber harvesting plans requesting approval on private ownerships in the action area.

Mining

Past hydraulic mining, primarily for gold, altered certain stream channels, including many tributaries of 

the Klamath River. Hydraulic mining altered channels and riparian areas significantly. Huge volumes of 

hillslope sediment were washed down to riparian and streamside areas and large woody debris (LWD) 

was removed from the channel to mine alluvial gold deposits within the substrate and near the channel. 

The removal of LWD reduced habitat complexity, LWD recruitment potential, and the ability of the 

channel to store and route the introduced sediment. Much of the landscape where hydraulic mining 

occurred is recovering, and previously altered riparian stands in these areas are approaching 70 to 80 

years and are beginning to provide riparian reserve functions.
Chapter 3. Environmental Consequences

214 – Somes Bar Integrated Fire Management Project

Fire

Historical records and fire evidence show that fires regularly occurred in this area with a variety of fire 

frequencies and intensities. Both wildfires and their exclusion through aggressive suppression affect plant 

and animal habitat, including stand structure, number of standing snags, amount of large woody debris, 

soil organic matter content, nutrient availability, and erosion hazard.

The dramatic reduction in wildfire burn acreages over the last 80 years appears to have resulted in 

fuel profiles that are more continuous, both horizontally and vertically. Given this increased conifer 

density, future wildfires could become larger and more destructive than in the past.

In the prolonged absence of fire, and aggravated by other disturbance factors, these fire-adapted 

forests and grasslands have undergone significant changes in species composition and structure. 

Intermediate canopy layers and higher ground fuel loadings have developed, which allow ground fires to 

reach the crown more easily, making fires more difficult to control. Young plantations now occupy most 

of the harvested old-growth sites within the project area. Early- and mid-seral stages of Douglas-fir are 

more susceptible to mortality by wildfire than older late-seral stands. Thick, corky bark on the lower bole 

and roots of older trees protects the cambium from heat damage. In addition, the tall trees have their 

foliage concentrated on the upper bole, which makes it difficult for fire to reach the crown; however, trees 

are typically not free of lower branches until they are more than 100 years old.

The high stem densities in plantations and younger stands also results in greater fire risk. Fire 

suppression activities have significantly reduced the amount of fire over the past 50 years leaving high 

fuel loads in places, which threaten the resiliency of the upland and riparian habitats in the event of a 

wildfire. In addition to these past activities, road building has cut across numerous riparian reserves and 

fragmented habitat in multiple locations throughout the project area, which has the potential to alter the 

sediment routing within the riparian reserve.

Only the Patterson project area was affected by the 2017 Marble Wildfire, which burned 318 acres. 

The majority of the acres burned at relatively low intensity; the high-intensity areas burned were 

primarily comprised of vegetation in the early mature or shrub seral stages.

Foreseeable Future Actions

Foreseeable future actions would include those associated with continued implementation of OCFR and 

Roots and Shoots projects, implementation of the current project (effects addressed in this analysis), as 

well as the anticipated Six Rivers Aquatic Restoration Project. The latter is a forest-wide programmatic 

planning effort that includes actions such as instream habitat management and riparian vegetation 

restoration. Prior to design and on-the-ground implementation, the programmatic project requires the 

involvement of resource specialists to determine if PDFs are needed to reduce negative effects. In the case 

of Sensitive wildlife species, wildlife staff would review the project relative to the potential to effect 

Sensitive wildlife species or their equivalent, implement surveys during the appropriate season as 

necessary and determine if alterations to the Proposed Action are needed.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 215

Habitats

Within the 46,243-acre action area, approximately 8,047 acres (17%) have been harvested or burned 

during previous fires and currently listed as dispersal habitat (regenerating conifer). Approximately 

10,212 acres occurs in vegetation types (pine stand, grasslands, oak woodlands and rock outcrops, etc.) 

categorized as habitat not currently suitable for spotted owl. There are approximately 12,615 acres of 

foraging habitat for NSO and suitable habitat for species, such as the northern goshawk and fisher. There 

are approximately 15,369 acres of habitat that is potentially suitable for nesting for species, such as the 

NSO and denning habitat for fisher.

The trend for wildlife habitats on the Orleans and Ukonom RDs is moving towards recovery. Since 

the 1990s, timber harvest on the Districts has been geared towards habitat restoration (thinning and 

reducing fuel loading). Fuel and vegetation management treatments have been developed to help restore 

natural fire regimes and to protect existing habitats. The OCFR Project is currently being implemented 

and will improve habitat conditions with approximately 2,587 acres of treatment occurring within project 

boundaries, of which 1,183 acres was commercial and 1,404 acres was hand treatments. All the treatments 

within suitable NSO habitat maintain and will not downgrade or remove suitable habitat. The Roots and 

Shoots Project will treat 176 acres of phased entry (about every 2 to 4 years), low-intensity prescribed fire 

botanical restoration treatments, and complimentary non-commercial hand thinning, pruning, chipping, 

lop and scatter and/or handpile, and pile burn units. The Katimiin Thin Project was geared toward pruning 

and thinning understory vegetation to improve basketry and food gathering opportunities for the Karuk 

Tribe. These projects will accelerating the development of late-successional characteristics, and protecting 

existing habitat, and will move the area toward the historic range of variability of seral stages and reduce 

fragmentation of habitat, which will improve habitat conditions for TESP species.

In addition, the Somes Bar Project is designed to improve habitat conditions through the acceleration 

and development of late-successional habitat characteristics, while still maintaining current functional 

habitat. Potential impacts to species would be minimized through PDFs listed in Chapter 2 and adherence 

of LRMP S&Gs, including:

1. Retention of snags and downed logs at 80 to 100 percent of the average numbers found 

within mature and old-growth stands within the forest. In stands other than mature or oldgrowth, five (5) snags per acres and five (5) to 20 pieces of CWD would be left following 

KNF and SRNF LRMP guidelines.

2. There are approximately 2,122 acres of riparian reserves in the project area, with 147 of these 

acres proposed for mechanical treatments in the outer 80 feet of those reserves; therefore,

there is limited landscape level change in riparian reserves.

3. Limited ground disturbance.

4. Canopy closure will be maintained at 60 percent in nesting/roosting habitat and 40 percent in 

foraging and dispersal habitats.

5. Vegetation species diversity and composition will be maintained.
Chapter 3. Environmental Consequences

216 – Somes Bar Integrated Fire Management Project

Reduction in canopy density in early seral stage stands may result in small local changes in 

microclimate in the short term prior to remaining tree crown improvement, but the changes will not 

increase overall stream and ambient air temperatures. Removal of a portion of the conifer stand is 

expected to result in the establishment of hardwoods and a multi-story canopy in the even-aged conifer 

stands, improving the canopy density and shade for various species. These indirect effects will lead to 

improved habitat function in the riparian and upland habitat areas.

Understory burning may also cause short-term habitat degradation through the loss of small woody 

debris; however, burning will occur under specific weather and moisture condition designed to minimize 

damage to the residual stand, maintain large woody debris, and maintain at least an average of 50 percent 

of the duff layer. Some minor local increases in fuels may occur from slash, but due to the low level of 

harvest and proposed post-harvest fuel treatments, fuel loading will not be a threat to riparian reserves or 

upland areas.

All treatment areas in all vegetation management projects in the action area will remain suitable 

immediately post project. Treatments were designed to maintain and restore habitat function in habitat in 

all project areas.

Illegal Marijuana Cultivation

A current issues arising in the scientific community is the effect of illegal marijuana gardens on public 

and private lands. The use of rodenticide has been linked to death in the Pacific fisher and the NSO. The 

project area has had gardens in the past, and some may exist on private lands. It is uncertain how much 

cumulative impact this will have on the species within the project area at this time, but ongoing research 

has shown that there is greater risk to foraging Pacific fisher because of its scavenging activities during 

parts of the year. The data on these impacts is just starting to be generated. Whether rodenticide use is 

impacting the population of fisher, owls, or other forest species is still to be determined.

Marijuana cultivation on Forest Service land is an illegal activity, and therefore, is beyond the Forest 

Service control. The Forest Service law enforcement actively searches for and removes any grow-sites 

found; however, it is unknown how many sites exist in the forest. It is hoped that by treating these low 

quality stands and plantations that are not currently habitat that owls, fisher, and other species will have 

increased areas for foraging, and possibly help limit their exposure to the toxins that may be found in the 

forest from illegal activities.

Due to the scope, size, and intent of this project, there are no concerns of negative cumulative effects 

for TES, MIS, neo-tropical migratory (NTM) birds, or other wildlife species. This proposed project is 

designed to attain 2011 Recovery NSO Plan, 2012 NSO Critical Habitat Rule, and LSR objectives and 

contains implicit measures to reverse cumulative watershed effects over the long term in the proposed 

treatment area.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 217

Watershed Values – Water Quality, Geology and Fisheries

Introduction

The protection of water quality and quantity is an important part of the mission of the Forest Service 

(Forest Service Strategic Plan for FY 2015-2020, June 2015). Management activities on NFS lands must 

be planned and implemented to protect the hydrologic functions of forest watersheds, including the 

volume, timing, and quality of streamflow. All management actions must be consistent with the Aquatic 

Conservation Strategy (ACS) objectives including riparian reserve S&Gs (see Appendix E). Riparian 

reserve widths of two-site potential tree-heights on fish-bearing streams and one site-potential tree-height 

on non-fish-bearing streams were established when the NWFP was adopted. Riparian areas provide the 

ecological functions and processes necessary protect water quality and to create and maintain habitat for 

aquatic and riparian-dependent organisms over time, dispersal corridors for a variety of terrestrial 

organisms and connectivity of streams within a watershed (FEMAT 1993). After 15 years under the 

riparian reserves system, 70 percent of the watersheds had improved and 18 declined (Lanigan et al. 

2012). The primary factors for improvement were an increase in the number of large trees (>20 inches 

dbh) in riparian areas and reduction in road densities in watersheds. Watersheds in which conditions 

declined have recently experienced high intensity wildfires (Reeves et al. 2016).

This section discloses the analysis of direct, indirect and cumulative effects associated with proposed 

actions, while preventing adverse impacts to water quality and quantity, and fisheries resources (KNF 

LRMP (4-18-20, 25, 107-114) and SRNF LRMP (pp. IV-46-49, 70-71), Clean Water Act, ESA). 

Beneficial uses most sensitive to water quality and quantity impairments in the project area are cold 

freshwater salmonid fishery, Native American cultural use and subsistence fishery. Residences in the 

project area depend on these tributaries as their lone source for domestic use.

Southern Oregon Northern California Coast coho are listed as threatened under ESA. The Middle 

Klamath River Coho Salmon Population reflects a moderate extinction risk under the SONCC Coho 

Salmon Recovery Plan (NMFS 2014). High-severity fires are identified as a key threat under the 

Recovery plan as they can torch, and damage vegetation and tree roots, decrease soil porosity, and cause 

chronic erosion (see Fire and Fuels section). High severity fires can also introduce large quantities of 

sediment (along with large wood) into streams via post fire landslides with the sediment posing a high 

threat to all life stages of coho within the Middle Klamath. Chinook and steelhead, Forest Service

Sensitive species are located in the project area as well.

The forest plans require geologic investigations for ground or vegetation-disturbing activities on 

potentially unstable land, where potential geologic hazards exist, before the development of any new or 

existing rock or earth material quarries, and where there exist potential impacts to cave and groundwater 

resources (USDA Forest Service pp. 4-18, 19-20). Geologic investigations must include identification of 

geologically unstable lands, distribution of rock types and relevant structural features, geomorphic terrain 

with landslide potential, known special interest areas, caves, groundwater developments, and rock 

material quarries by use of existing databases, and include recommendations for additions or exclusions. 
Chapter 3. Environmental Consequences

218 – Somes Bar Integrated Fire Management Project

Each geologic resource is addressed where applicable, and additional attention is given to unstable lands 

and treatments within unstable lands (Cabrera 2017).

Affected Environment

Risk of Wildfire

When wildfire eventually occurs, high rates of fire intensity can significantly reduce vegetative cover. With 

the exception of the 160 acres that burned in the 2017 Marble Fire in the Patterson project area, the rest of 

the area has not had a wildfire in the vicinity in at least 100 years. At present, the majority of the project 

area is at risk for active or passive crown fire (see the Fire and Fuels section for more details). In the event 

of an uncharacteristically high severity wildfire, water quality would be detrimentally affected by removal 

of vegetation and re-activation of landslides (Mikulovsky et al. 2012), all of which increase the potential 

for erosion. The potential loss of vegetative cover in riparian reserves would result in reduced streamside 

shading and increased stream temperatures. Fire-excluded landscapes are especially vulnerable to adverse 

changes in forest hydrology when stand-replacement wildfires inevitably occur (Keane et al. 2002). Peak 

flows usually increase substantially after large, intense wildfires, which presumably increases surface and 

mass erosion, resulting in substantial increases in sedimentation rates, ultimately lending to poor water 

quality until suitable vegetative cover is reestablished (Dwire et al. 2016).

Riparian Reserves

Ecologically diverse riparian corridors are maintained by active natural disturbance regimes, including 

fires that operate over a range of spatial and temporal scales. However, the role of fire, the streamside 

factors that influence fire properties and the response of riparian and aquatic communities to fire can differ 

widely, depending on characteristic of both e the fire and the riparian area (Dwire et al. 2016). Fire regimes 

in riparian areas relative to adjacent uplands vary depending on the physical features of the watershed, 

location within a given watershed, vegetation type and fuel characteristics, and disturbance and land use 

history (Olson and Agee 2005, Van de Water and North 2011). In the Klamath Mountains of Northern 

California, Skinner (2003) found that the median fire return intervals were approximately twice as long in 

riparian reserves as in upland sites, indicating that fires occurred less frequently in riparian areas. However, 

fires can be less severe or as severe as in adjacent uplands, depending on the local topography, vegetation 

characteristics (especially fuel moisture and loading), and fire weather (Dwire et al. 2016).

Headwater streams are among the most dynamic portions of aquatic ecosystems (Naiman et al. 1992). 

Tributary junctions between headwater streams and larger channels are important nodes for regulating 

material flows in a watershed (Benda et al. 2004).

Scientific Considerations for riparian conservation areas along non-fish bearing streams (Reeves et al. 2016)

• Effect on microclimate and water temperature: Relative to temperature effects, non-fish-bearing 

streams tend to be narrow channels in steeper constrained valleys (Moore et al. 2005). Nearstream vegetation and topographic features often shade the entire channel in such settings 

(Janische et al. 2012). In addition, water temperatures in headwater streams are strongly 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 219

influenced by in-channel substrate (ibid). Neither of these factors would be affected managing 

vegetation within riparian reserves.

• Effect on amphibians: Olson et al. (2007) reviewed studies of the effects of harvest inside and 

outside of riparian reserves on microclimate conditions and amphibians. They concluded that the 

relatively narrow buffers can be effective in maintaining microclimates 33 to 66 feet from the 

stream center. Headwater streams may also serve as connection corridors within and between 

watersheds (Olson and Burton 2014). Most amphibians moved along the stream within 45 feet of 

the channel (Olson and Kluber 2014). Maintaining for downed wood in the riparian areas would

further reduce potential impacts on terrestrial salamanders.

• Effects on wood recruitment: Since the publication of FEMAT (1993) report, new examinations of 

studies on the sources of wood (Spies et al. 2013) and information in Gregory et al. (2003) 

suggest that about 95 percent of the total instream wood inputs from the adjacent riparian area 

came from distances that ranged between 0.46 to 0.82 of a site potential tree height (82 to 148 

feet) from the stream which is less than FEMAT’s 0.95 of a site potential tree height (Reeves et al. 

2016) Thus more wood recruitment comes from the inner half of a site potential tree-height than 

assumed in FEMAT; therefore, managing the outer half of the riparian reserves should maintain 

wood recruitment process in non-fish-bearing streams (ibid).

Fuel Treatments in Riparian Reserves

The immediate goal of most fuel-reduction treatments is to change vegetative structure and reduce fuel 

continuity to reduce crown fire behavior and potential wildfire size and intensity. Results of the study by 

Arkle and Pilliod (2010) indicate that the effects of prescribed fires are much smaller and shorter-lived to 

the effects of wildfire, especially uncharacteristically high severity wildfires. The effects of mechanical 

treatments on riparian species composition are more complex, and could result in longer-term changes, 

depending on magnitude of environmental impacts, such as soil compaction.

A recent publication, Riparian Fuel treatments in the Western USA: Challenges and Considerations

(Dwire et al. 2016) described the following considerations for managing fuels in riparian areas:

o Riparian areas are part of the landscape and may need fuel treatments based on fuel loading 

within and in surrounding uplands. Reducing the risk of uncharacteristically high severity fire 

in riparian areas can limit the effects to riparian dependent species such as TEK focal species 

willow and Pacific giant salamander as well as limit the spread of invasive species.

o Fuel reduction treatments can potentially assist in riparian and stream restoration by returning 

fuel loads and vegetation, and result in more spatially diverse range of habitat components with 

long-term benefits for multiple wildlife species, including TEK focal species Roosevelt elk.

Riparian zones in the Somes Bar Project area were delineated by forest hydrologists, geologists, and 

fisheries biologists and totaled 3,072 acres. Unstable and potentially unstable geologic landforms were 

assessed and buffered. Stream riparian areas consisted of perennial, intermittent, or ephemeral streams,

and the area on each side of these channels between 160-foot-slope distances for “non-fish bearing” 
Chapter 3. Environmental Consequences

220 – Somes Bar Integrated Fire Management Project

streams up to 320-foot slope distances for “fish bearing” streams. These “fish bearing” streams include 

the mainstem Klamath (20 miles) and the lower portion of Burns, Kennedy, Ti, Sandy Bar, Stanshaw, 

Rogers, Teneyk, Natuket and Donahue Flat creeks for a combined additional 9 miles of the wider riparian 

reserve boundaries. All streams have a definable channel and evidence of annual scour or deposition in 

order to be included in the riparian reserve system. Forested ponds, wetland features and associated 

aquatic vegetation have designated equipment exclusion zones.

Riparian reserves are represented in the lower elevations of the watersheds by the TEK focal species 

Willow (primarily located along the mainstem Klamath River) and the Pacific giant salamander. The 

riparian reserve system provides travel corridors for wildlife species, including Roosevelt elk and Pacific 

fisher, two (2) more TEK focal species. Before the NWFP, timber harvest occurred in what are now 

designated riparian reserves. Much of the riparian areas would burn like adjacent uplands, as the riparian 

vegetation terrain and topography are similar to surrounding uplands. Fuel abundance/accumulation is 

likely to be similar to the uplands.

Forest plan direction allows for silviculture and fuels treatments within riparian reserves when needed 

to meet ACS objectives. Fuel reduction treatments can potentially assist in riparian and stream restoration 

when actions include the return to fuel loads and vegetation that supports ecosystem processes and natural 

disturbance regimes, including restoring fire to the landscape (Dwire et al. 2016).

Geology

The project area lies in the west central area of the Klamath Mountains, which are comprised of sets of 

roughly parallel, north-south trending, arcing concave eastward belts extending from northwestern 

California through southwestern Oregon (Irwin 1989). The deep inner gorge canyon of the Klamath River 

bisecting the steep upland topography of the project area, as well as the disrupted and sheared nature of 

much of the bedrock, combined with high rainfall-runoff effects in the wet Mediterranean climate, 

combine to effect high rates of mass movement (landsliding) and sediment delivery. The major floods in 

1955, 1964, the 1970s, 1986, 1995 and 1998, to name a few, have resulted in extensive landslide delivery 

to the Klamath River, often damaging or removing Highway 96. Large prehistoric landslides are evident 

in all four (4) project areas. Of these, the Ti Bar earthflow has by far the greatest contemporary activity 

and concerns for project-related effects. Deep-seated landsliding in the Ti and Rogers Creek project areas 

is largely associated with shearing along faults and inner gorge activity. The Donahue Flat and Patterson 

project areas are occupied by a large prehistoric landslide that are mostly dormant now though exhibit 

characteristics of dormant earthflow terrain such as frequent springs, hummocky terrain, and broad, steep 

concavities with well rounded, deeply weathered breaks in slope but no abrupt scarps. All active shallow 

landslides, inner gorges, and areas within earthflows that have evidence of activity within the past 400 

years (USDA and USDI 1994b) such as toe zones, bowed and leaning trees, abrupt scarps, tension cracks, 

disorganized and incised stream networks, and sag ponds, and that impact watercourses were mapped and 

included in riparian reserves as is required by the KNF and SRNF LRMPs (USDA Forest Service 1995 

pp. 44-50, USDA Forest Service 2010 p. IV-44).
Chapter 3. Environmental Consequences

Final Environmental Assessment – 221

Unstable Lands

There are no geologic special interest areas, or caves in project area. No groundwater or rock quarry 

developments are proposed. The SRNF has no samples or tests for presence of naturally occurring 

asbestos within or near the project area. No mechanical treatments would be applied and no temporary 

roads used within ultramafic and serpentine bedrock. Strategic firelines are planned on serpentenite soils 

within the Patterson Project area, but they are fuelbreaks—not handlines—and would not disturb the soil. 

The geologic resource addressed in this analysis is related to proposed ground disturbing treatments 

within unstable lands.

Unstable lands have been mapped as riparian reserves in the project area. The forest plans prohibit 

timber harvest on extremely unstable lands defined as active landslides, inner gorges, toe zones of 

dormant landslides and severely dissected granitic terrain (USDA Forest Service 1995, glossary p. 7).

No commercial harvesting would occur within extremely unstable lands. Ground disturbing activities 

are proposed on approximately 15 acres (1 percent of all mechanical timber harvest units) of riparian 

reserves associated with unstable lands on nearly dormant sections within large, deep-seated earthflows. 

The activities proposed are significantly distant from extremely unstable lands in order to prevent any 

triggering of mass movement, and pose low risk of sedimentation because sites are low gradient and slope 

away from stream channels.

Water Quality

The hydrologic function most vulnerable to the Proposed Action is quality of streamflow. Proximity of 

ground disturbance to riparian reserves in an important factor controlling sediment delivery (Rashin et al. 

2006). When compared to the other proposed actions, mechanical fuel-reduction treatment methods and 

associated connected actions within riparian reserves have potential to cause measurable ground 

disturbance, which could impact water quality by altering background sedimentation rates in the short term.

Because the project is spread across three 6th-field watersheds, and at most encompasses roughly 13 

percent of the Reynolds-Klamath River watershed, it is very unlikely that enough vegetation would be 

removed to cause detectable changes in peak flows in the analysis area. For rain-dominated zones (below 

2,500 feet in elevation in the project area), changes in peak flow can only be detected where 29 percent of 

the area is harvested (Grant et al. 2008). For areas where rain-on-snow events can occur (above 2,500 feet 

in elevation in the project area), the detection level for peak flow increases is 19 percent, including 

harvested acres and the area in roads. The magnitude of observed changes in peak flows from 

management activities diminished with increased watershed area (ibid).

Temperature

In 1996, the Klamath River was listed for nutrient and temperature impairment under §303(d) of the 

Clean Water Act. The basis for the listing was associated with aquatic habitat degradation in the mainstem due to excessively warm temperatures and algae blooms associated with high nutrients, water 

impoundments (reservoirs) and agriculture diversions. While the main-stem Klamath is listed as impaired, 

its smaller tributaries within the project area provide year-round excellent cold freshwater quality and 

have no agriculture diversions, impoundments, or significant water withdrawals that would alter water 
Chapter 3. Environmental Consequences

222 – Somes Bar Integrated Fire Management Project

quality or quantity (Ishi Pishi Ecosystem Analysis 1998). Throughout the Klamath River watershed in 

California, the 303(d) listing has prompted many individuals, groups, Indian Tribes, and agencies to 

actively work together to enhance and restore water quality. Their past and present efforts have improved 

water quality conditions in the Klamath River and its tributaries (Action Plan for the Klamath River 

TMDL, California State Water Resources Control Board 2010). The North Coast Regional Water Quality 

Board has adopted a waiver of waste discharge (The Waiver) that includes conditions to implement the 

Klamath TMDL Action Plan for activities on USFS land. This project would meet all requirements 

associated with The Waiver.

Elevated water temperatures are common water quality concerns in the Klamath River basin. Solar 

radiation is the most important source of radiant energy affecting stream temperatures. Shading from 

overstory vegetation along the stream channel has a significant effect on temperature. A study conducted 

in western Oregon (comparable vegetation types and geology as in the project area) of thinning treatments 

and the effects on stream temperature showed that thinning in primary shade zones (area adjacent to 

stream channels that provides stream shade during periods of greatest solar loading) along 6 miles of 

stream led to a 4 degree (F) increase in temperature (NWFP Temperature TMDL Implementation Strategy 

2010). In dense riparian areas such as in the project area, optimum shade can be provided by the primary 

shade zone alone (ibid). Near-stream vegetation and topographic features often shade the entire channel in 

such settings (Janische et al. 2012). Water temperatures in headwater streams are also strongly influenced 

by in-channel substrate (ibid). Neither of these factors would be affected managing vegetation within 

riparian reserves. The table below displays findings relative to minimum widths of primary shade zones 

needed maintain suitable shade. All proposed buffer widths are greater than the widths recommended in 

Table 3-26 below. Canopy cover would not be affected in the inner riparian reserve and the 147 acres 

treated mechanically would not significantly change canopy. Given the project conservative protection of 

the primary shade zone, increase in stream temperature is unlikely. In the long term, a more fire-resilient 

stand would promote and maintain appropriate shade over time, provide for larger trees and a diversity of 

desired species in the riparian area.

Table 3-26. Minimum width of primary shade zone (feet) based on slope and tree height.30

Tree height Hill Slope Percent

<30 30 to 60 >60

<20 feet 12 14 15

20 to 60 feet 28 33 55

>60 to 100 feet 50 55 60

>100-140 feet 70 75 85

Chemical Contamination

Project operations would adhere to all best management practices (BMPs) pertaining to containment and 

prevention of all petroleum product spills from reaching water bodies. Heavy equipment fueling would 

only occur on roads and landings. Chainsaw fueling or storing of fuel would not occur adjacent to stream 

 30 Source: Northwest Forest Plan Temperature TMDL Implementation Strategy 2010.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 223

courses. Spill trays and absorbent padding would always accompany fueling or storage of fuel and oil 

during operations. Containers of fuel and oil are removed daily off-site. Chemical contamination would 

not occur.

Water Quantity

Water drafting to support prescribed burns and dust abatement for watering roads could occur from 

developed water sources near the project area. It is unlikely that flows would be affected from the drafting 

as relatively small amounts would be removed and the area would be continually recharged from upstream. 

Best management practices require less than 10 percent of base flow be drafted at any given time. For these 

reasons, implementation of the project would not adversely impact the volume or timing of streamflow.

Fisheries

Within most miscellaneous mid-Klamath tributaries of the project, anadromous and resident fish habitat is 

very limited due to channel steepness and existing gradient barriers (e.g., slopes >8 percent over a >200 

foot distance). In general, suitable tributary fisheries habitat mostly occurs within lowermost reaches, 

within low-to-moderate stream gradients, found near their confluence with the Klamath River mainstem. 

Anadromous fish streams potentially affected by project activities (Table 3-27). Critical habitat is defined 

as all potentially accessible streams and adjacent riparian zones.

Table 3-27. Miles of coho habitat by project area.

Project Area Tributaries to Klamath River Miles of Coho Habitat Fish Bearing (Steelhead/ 

Rainbow Trout) Miles

Ti Bar

Burns Creek

Kennedy Creek 1.4 3.4

Ti Creek

Patterson Sandy Bar Creek 0.6 4.6

Stanshaw Creek

Rogers Rogers Creek 0.9 2.7

Donahue

Teneyck

0.63 1.9 Unnamed tributary (North of Teneyck Creek)

Natuket

Donahue Flat Creeks

Project wide Klamath mainstem 16.4 16.4

The SONCC Coho Recovery Plan identified one of the key limiting threats is related to risk of high 

severity fire. High-severity fires can torch and damage vegetation and tree roots, decrease soil porosity, 

and cause chronic erosion. High severity fires can also introduce large quantities of sediment into streams 

posing a high threat to all life stages of coho. This project addresses specific recovery actions including 

developing a plan for firebreak stewardship and defensible space, implementing fire-safe community 

action plans in identified areas and reducing stand densities through prescribed burning and thinning to 

reduce high severity fire. Reducing the risk of wildfire would also benefit Chinook, steelhead and other 

aquatic organisms, including TEK focal species.
Chapter 3. Environmental Consequences

224 – Somes Bar Integrated Fire Management Project

Environmental Consequences

Methodology

This section describes methods used to evaluate proposed treatments within and adjacent to riparian 

reserves, including unstable areas, and the effects of the proposed actions to water quality and fisheries. 

Analyzing the effects to coho salmon serves as a surrogate for other aquatic resources including Chinook, 

steelhead, and Pacific lamprey.31 In addition, cumulative effects from the Proposed Action, as well as 

ongoing, future and past actions in the last 30 years, are quantified using the Equivalent Roaded Acres 

(ERA) method.

LiDAR imagery recently acquired in the project area provided a digital elevation model (DEM), and 

from this, a stream delineation model was utilized to reveal precise locations of stream channels and 

extent of unstable terrain in the project area. Stream-delineation model results, along with unstable terrain 

were validated on the ground by qualified earth scientists and fisheries biologists in 2016 and 2017. 

Subsequently, riparian reserves layers were created to assist with project planning efforts, quantify 

proposed treatment acres and refinement of PDFs for riparian reserves, including unstable lands.

Additional analysis for fisheries effects is based upon Forest Service, Karuk Tribe and CDFW

available fisheries data; fisheries surveys and assessments of aquatic habitat suitability; a review of best 

available information related to existing aquatic resources and potential impacts, and professional 

judgment (Cyr, Forest Service fisheries biologist). A BA/BE was prepared for consultation with National 

Marine Fisheries Service (NMFS; Cyr 2018) and analyzed the potential effects to fish and their habitat 

based on the effects to seventeen indicators (water quality, barriers, stream habitat complexity, etc.) of 

anadromous fish habitat conditions. Effects of the project to an indicator may be neutral (no effect), 

discountable (extremely unlikely to occur), insignificant (effects cannot be meaningfully measured, 

detected, or evaluated), or significant (effects able to be measured). Furthermore, effects may be either 

positive or negative.

Spatial and Temporal Context for Effects Analysis

The extent of watershed effects is dependent on the watershed size and the issues of concern (MacDonald 

2000). The 5,570-acre planning area where these effects would occur is the scale used for assessing direct 

and indirect effects from individual proposed actions. For cumulative watershed effects (CWE), the 

analysis area is the 6th-field watersheds containing proposed treatment acres (Figure 1-1). Most of the 

treatment units are located in the Ti Creek-Klamath River and Reynolds Creek-Klamath River watersheds. 

Approximately 120 acres are located in the Boise Creek-Klamath River watershed (Table 3-28).

 31 See Biological Assessment/Biological Evaluation for aquatic threatened, endangered and Forest Service Sensitive aquatic species in 

the project record for a complete analysis (Cyr 2018).
Chapter 3. Environmental Consequences

Final Environmental Assessment – 225

Table 3-28. Percent of project area in the analysis area.

6th-Field HUC Watershed Watershed Acres Project Area Acres

in Watershed

Percent Project Area in 

Watershed

Boise Creek-Klamath River 31,343 120 0.4

Reynolds Creek-Klamath River 34,611 4,487 13

Ti Creek-Klamath River 13,623 1,045 8

Using the entire 5th-field watershed with the ERA model would dilute the effects of all projects that 

are occurring or planned in the foreseeable future. Hence, the ERA model to assess cumulative effects 

would be run for the three 6th-field watershed where the proposed actions are planned (Figure 3-31).

Figure 3-31. Watershed effects analysis boundaries.
Chapter 3. Environmental Consequences

226 – Somes Bar Integrated Fire Management Project

Alternative 1 – No Action

Direct and Indirect Effects to Water Quality and Coho Salmon

Indicator – Mechanical treatments within riparian reserves, high severity wildfire effects risk reduction.

Unit of measure – Acres

Duration – Long Term

Under the No Action Alternative, no fuel reduction treatments or associated connected actions would be 

implemented. There would be no direct effects to water quality or coho salmon under the No Action 

Alternative, as it maintains the current condition in riparian reserves.

Short-term indirect effects to fire-excluded landscapes would likely increase vegetation cover and woody 

debris inputs to riparian reserves, decrease stream temperatures, and delay and reduce peak flow runoff.

In the event of a large storm event, there is the risk that the stream crossings in the legacy roads could 

fail and deliver up to 1,100 cubic yards of sediment. Threatened and sensitive fish species occupy habitat 

ranging between 1.0 and 1.7 miles downstream of these legacy road treatment sites. Any of these road 

failures may cause effects at the site, but the potential for effects to resident and anadromous fish found 

downstream is negligible, and the expected response would be insignificant.

Direct and Indirect Effects to Water Quality and Coho Salmon

Indicator – Reducing the risk of high-severity fire

Unit of measure – Acres

Duration – Long term

A summary of fire occurrence for this portion of the Klamath Mountains bioregion is described in the Fire 

in California’s Ecosystems (Skinner 2006) and the Project Fire and Fuels Report (Spain 2017). Fire 

exclusion and past management activities have altered the fire regime within the Somes Bar Project area. 

Under Alternative 1, there would be no fuel reduction treatments and therefore no direct and indirect 

management related sediment delivery. No thinning or placement of strategic fuelbreaks would occur. 

Forest density, and surface and ladder fuels, are expected to increase, and forest health within riparian 

reserves is expected to continue to decline. This project area would remain vulnerable to having a stand 

replacement wildfire, especially on upper and mid slopes, and east and southeast facing aspects (see Fire 

and Fuels section). The predicted fire behavior indicators related to rate of spread, flame length and 

intensity are expected to increase if this landscape were left untreated, with the potential for wildfire to 

spread across multiple drainages causing additional impacts to more riparian reserves and aquatic habitats.

Under this No Action Alternative, SONCC Coho Recovery Plan restoration actions identified as 

MKR.7.1.9 and 8.1.2, which were prioritized to conserve and recover this species, would not occur. 

Therefore, the elevated high severity fire threat to this Middle Klamath coho population is expected to 

increase over time.

Cumulative Effects

Unit of measure – Equivalent Roaded Acres
Chapter 3. Environmental Consequences

Final Environmental Assessment – 227

Duration – Long term (5 to 15 years post treatment)

In assessing CWEs, all past, current and reasonably foreseeable actions on both private and public lands 

were assessed within all affected watersheds and related to beneficial uses and sensitivities within these 

watersheds (KNF LRMP EIS Appendix G, SRNF LRMP pp. IV-71, 1-10 and 11; FSH 2509.22 Ch. 20). 

The KNF and SRNF LRMPs incorporated S&Gs from the ROD for Management of Habitat for LateSuccessional and Old-Growth Forest Related Species within the Range of the NSO—also referred to as 

the NWFP. Methodology incorporates an Equivalent Roaded Acres (ERA) model used by the Pacific 

Southwest Region. The ERA model is a measure of hydrologic disturbance of a watershed. Disturbances, 

such as roads, timber harvest and wildfire, are converted into ERAs, approximating the amount of 

disturbance associated with 1 acre of road. The total ERAs are divided by the watershed area (acres) and 

multiplied by 100 to obtain the percent ERA for affected watersheds. This percentage is then compared to 

the Threshold of Concern (TOC) that is established in the LRMPs. Where ERAs approach or exceed a 

given watershed’s TOC, further fieldwork would be necessary to ascertain whether CWE are present and 

if land management activities would adversely add to those effects and result in detrimental impacts to 

beneficial uses.

Results of the ERA model indicate that current conditions of the watersheds in the project area are 

well below the TOC for adverse CWEs. The current conditions of Ti Creek and Reynolds Creek 

watersheds are due in a large part to the NWFP revisions in 1995, of which both the KNF and SRNF 

LRMPs were updated to align with this new direction. Aquatic Conservation Strategy objectives were 

established, paving the way for extensive watershed analyses and subsequent restoration of sediment 

sources. In response to this new direction, the SRNF completed the East Ishi Pishi Road Restoration 

Environmental Assessment (2001). As a result, approximately 156 miles of road were stormproofed and 

62 miles of road decommissioned. Additionally, the bulk of past timber harvest areas are well over 30 

years old and much of the hydrologic processes impacted by past timber harvest activities have since 

recovered, and there have been limited timber harvesting (primarily commercial thinning for hazardous 

fuels reduction) in the Ti and Reynolds creek watersheds.

The No Action Alternative represents the current baseline for the project area. The most recent 

additions to the ERA calculations are the Marble, Ukonom and Haypress wildfires in 2017. Table 3-

26Table 3-29 shows the existing ERA, representing the No Action Alternative.

Table 3-29. Existing Equivalent Roaded Acres (ERA) values by watershed.

6th-Field HUC Watershed Watershed Acres Total Existing ERA Total Existing ERA 

(%)

Threshold of 

Concern (%)

Boise Creek-Klamath River 31,343 241 0.8 13.7

Reynolds Creek-Klamath River 34,611 1,680 4.9 8

Ti Creek-Klamath River 13,623 579 4.3 8

A likely potential adverse impact to cumulative effects could come from a high severity wildland fire. 

The effects of high severity fire in this area include an increase in erosion and creation of hydrophobic 

soils. In addition, there could be adverse effects to water quality by increased nutrients from ash, sediment 
Chapter 3. Environmental Consequences

228 – Somes Bar Integrated Fire Management Project

bulking due to accelerated erosion, and loss of vegetative control of watercourses creating scouring of 

stream-banks. If the wildland fire was large in acreage it could lead to increased erosion rates and 

subsequent detrimental cumulative effects to the watershed in which it occurred. In 1999, the lightning 

caused Megram Fire (located in the Trinity River watershed, a major tributary to the Klamath River) 

eventually grew to almost 50,000 acres. More than half of these acres burned at high or moderate severity. 

It was estimated that short-term surface erosion rates could increase by 80-fold as a result of the wildfire 

(Horse Linto, Mill, and Tish Tang Watershed Analysis, USDA Forest Service 2000b).

Alternative 2 – Proposed Action

Direct and Indirect Effects to Water Quality and Coho Salmon

Indicator – Mechanical treatments within riparian reserves

Unit of measure – Acres

Duration – Short term (1 to5 years post treatment)

As discussed previously under the Affected Environment section, quality of streamflow (increased 

sedimentation) is the primary water quality factor that can be adversely impacted when ground-disturbing 

actions occur within riparian reserves.

Sediment movement can be episodic or chronic. In the Klamath Mountains region, the most common

of sediment movement happens in response to large storm events. Ground disturbing activity within and 

adjacent to riparian reserves can potentially add to sediment delivery. Proximity of ground disturbance to 

streams is an important factor for controlling sediment delivery.

Effects to coho salmon (and other aquatic biota) are based on the proximity of the sediment to 

occupied habitat, the probability of the sediment affecting any life stage or habitat components and the 

magnitude of the effect (Cyr 2018).

Sediment Delivery from Fuels Reduction

Fuels reduction methods are categorized as manual, mechanical, and prescribed burning. Manual and 

mechanical methods are employed in preparation for prescribed burning, including follow up 

maintenance burning cycle to maintain desired condition.

Manual fuel reduction treatments are aimed at cutting small-diameter ladder fuel vegetation, followed 

by and handpiling of cut material, in preparation for follow up prescribed burning. Manual fuel reduction 

methods are conducted with only with hand carried mechanized tools (e.g., chainsaws and loppers). 

Manual treatments are limited to cutting and stacking vegetation, without disruption to the ground 

surface, thereby maintaining suitable ground cover and posing very low to no risk of sediment delivery 

regardless of the proximity of the activity to riparian reserves. For these reasons, proposed manual 

treatments would not pose a threat to water quality from sedimentation.

Mechanical fuel reduction treatments include conventional timber harvesting techniques, such as 

ground or cable based yarding systems. Mechanical methods are used to thin and remove ladder fuels and 

reduce competition between Douglas-fir species and other more fire resilient hardwood and conifer 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 229

species (e.g., black oak and sugar pine). Because all of the units identified for mechanical treatments are 

in previously managed stands that were either high graded or clearcut, there are ample existing skid roads 

and old logging roads with which to operate on, thereby decreasing the need for new skids or temporary 

roads. There were no riparian reserve designations when these units were logged in the early 1960s. Much 

of the riparian reserve areas within the units are now dense thickets, dominated by Douglas-fir species. 

Consequently, much of the riparian reserve areas in the plantations within the project area would benefit 

from fuel reduction actions, and some mechanical treatments within the outer 80 feet of riparian reserves 

are warranted. Management within riparian reserves must demonstrate how activities would maintain

riparian reserves and meet the ACS objectives. The NWFP recognized the need to manage within riparian

reserves to address legacy issues of old silvicultural practices that encroached or even eliminated large

trees within riparian areas and adjacent stream channels such as in plantations (LRMP pp. IV-49, IV-110).

Project design features require any heavy equipment that operates within the riparian reserve do so in 

such a manner (linear passes and no turning of machinery) that does not displace or adversely compact 

soils. The use of modern equipment (e.g., feller bunchers or excavators) reduces, or avoids soil 

displacement and compaction during implementation (Poff 1996). Equipment exclusion areas around 

springs and wet areas would be buffered 25 feet from the edges of the riparian vegetation and delineated 

on the ground. All efforts would be made to stay on existing roads and skid trails wherever possible or 

necessary to minimize soil compaction.

Interdisciplinary team (IDT) members representing disciplines of hydrology, soils, geology, forestry 

and fisheries carefully evaluated potential impacts from heavy equipment use within riparian reserves and 

ground based cable harvesting (endlining) outside of riparian reserve buffers. Because this is a fuel 

reduction project, the intent is to remove smaller diameter trees, while retaining the larger, more fire 

resilient trees in the stand. Canopy cover would not change, as over story trees would not be removed. No 

equipment or other ground disturbing activities would occur within the inner 80 feet of the riparian 

reserve (immediately adjacent to the stream channel) or within active landslides, providing for adequate 

buffers and filtering of soil that may have become displaced in the outer riparian reserve, thus posing a 

low risk to sedimentation. Kreutzweiser and Capell (2001) found no significant input of sediment when 

machine travel was greater than 10 feet from streams and harvesting equipment did not create channeled 

flow paths. Manual and mechanical would not result in significant expose of disturbed soil (See Soils 

Resource section) with the implementation of BMPs (see Appendix D) In the outer 80 feet of riparian 

reserves approximately 45 acres of mechanical treatments are recommended for endlining and 101 acres 

for ground based equipment, which includes 18 acres of mastication. Mastication includes using low 

impact type equipment, which typically is a small to medium size excavator with a rotary head operated 

to shred small diameter vegetation in dense stands. In general, masticator use would be limited and used 

along existing skid roads, logging spurs or firelines. Masticators would primarily be utilized only to 

maintain enough open space for hand pile placement and to break up the fuel profile to better insure 

desired prescribe burning effects.

Prescribed fire actions include handpile burning, understory and jackpot burning. Prescribed burning 

would generally occur as follow up actions for manual and mechanical treatments, but also can be the sole 
Chapter 3. Environmental Consequences

230 – Somes Bar Integrated Fire Management Project

treatment prescribed. In many cases, it is important to break up the horizontal and vertical fuel 

composition prior to prescribe burning to meet project objectives of low to moderate severity fire effects, 

flame lengths up to 6 feet with minimal torching (less than 10 to 15 percent of the treatment area). Low to 

moderate severity fire effects would maintain a minimum of 60 percent canopy cover and 50 percent 

ground cover retention. Multiple entries of prescribed burning, ranging approximately from 2- to 7-year 

cycle, are included in the proposed actions. No direct ignition is planned to occur with riparian reserves. 

Ignition Prescribed fire would be permitted to back or flank into a riparian area, with the condition that 

fire effects would be of low to moderate severity. Ignition may occur within riparian reserves to insure 

desired fire effects.

No mechanical fuel reduction units are found adjacent to occupied coho salmon habitat or within the 

inner 80 to 160 feet of all riparian reserves. The 18 treatment units (13 manual only units and 5 prescribed 

burn only units) are found near tributaries or the Klamath River mainstem where coho occupy habitat 

however, based on the lack of ground disturbance and adherence to project objectives of low to moderate 

severity fire effects sediment production over time is expected to be negligible.

Sediment Delivery from Connected Actions

New temporary road construction is limited to approximately 1⁄2 mile of road and is not located within 

riparian reserves. All pre-exiting temporary road and landing footprints proposed for use and within the 

outer 80 feet of riparian reserve were analyzed by the ID Team in the field. The hydrologist and fisheries 

biologist carefully reviewed all proposed use of temporary roads and landings in or adjacent to riparian 

reserves. All existing road and landing footprints brought forward for use within riparian reserves have a

low risk of delivering sediment to waterways. Low risk for sediment delivery is best characterized as 

having gentle travelway gradients, minimal earthwork needed to make useable for vehicles, and no roadstream crossings. All temporary roads needed for more than one (1) field season, would be physically 

closed to vehicle traffic and left in a free draining condition throughout the rainy season. When no longer 

needed for project work, all temporary roads would be decommissioned. Decommissioning includes 

installing water bars, installing a physical barrier to prevent motor vehicle access, and seeding with native 

grasses where appropriate.

Proposed strategic fuelbreaks and handlines would be constructed using hand-held tools (such as,

chainsaws, loppers, shovels, and McLeods), have limited impact on canopy closure and do not create 

significant ground disturbance near riparian reserves that could lead to off-site sedimentation. These 

actions are limited in scope, primarily located on ridgetops away from inner riparian reserves. Strategic 

fuelbreaks are designed to facilitate planned and unplanned ignitions, and as such would be maintained 

throughout the life of the project. Fuelbreaks require minimal soil disturbance. An approximately 2-footwide scrape (supported with 100-foot thinning of ladder fuels) is the actual ground disturbance associated 

with these features. As mentioned before under manual treatments, thinning of small diameter trees is not 

a ground disturbing action. Fuelbreaks would have waterbars installed at the appropriate spacing, 

dependent on slope steepness, to prevent erosion and subsequent sedimentation during the rainy season. 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 231

Handlines also have a 2-foot-wide scrape, but are supported with only a 6-foot-wide brush cut and are 

more of a temporary feature designed and located to support planned ignitions.

Approximately five (5) miles of Maintenance Level (ML) 1 roads would be brought into service for 

the life of the project. Most of these roads require routine maintenance to be useable. Routine 

maintenance includes brushing for visibility and grading for drainage control. All ML 1 roads used for 

this project would be closed during the rainy season and left in a free draining condition. The travelway 

on road 13N14A does require one (1) crossing fill to be reconstructed, which is approximately 1.2 miles 

above coho habitat. This work entails installing a properly sized culvert (to meet the predicted 100-year 

flood flows) and importing clean rock and fill to bring it up to standard. The roadbed would be outsloped 

at the crossing to minimize diversion potential. This work would only occur during the dry season and 

would not require any dewatering prior to installation. When employed, these design features insure that 

the proposed activities would have a low risk of sediment delivery downstream of the work area.

Also included in the proposed actions is the restoration of six (6) segments, 1.1 miles total of legacy 

roads discovered in the project area. All of these legacy site treatments are found greater than 1.2 miles 

upstream of occupied coho habitat. Restoration of legacy sediment sources in the project area is a 

requirement to receive a Waiver of Waste Discharge (Order No. R1-2015-0021) from the North Coast 

Regional Water Quality Control Board. Restoration of legacy roads includes removing one (1) culvert and 

associated fill, storing fill in stable locations, covering of excavation sites and storage areas with suitable 

material to minimize surface erosion until native vegetation is reestablished, seed with native grass where 

needed, placing waterbars or dips to prevent water from concentrating on the roadbed, and decompacting 

the travelway. Earthen log barriers are installed at locations that would effectively block motor vehicle 

access. All restoration work would occur during the dry season, have appropriate erosion control plans 

developed, and be closely monitored by qualified personnel experience in road restoration activities. In 

the short term, there is a slight possibility of off-site sedimentation during the first few winters until 

suitable ground cover is reestablished. In the long term, hydrologic function would be restored and 

actually reduce the cumulative effects from roads in the watershed.

None of the connected actions occur within coho habitat; therefore, there are no direct effects. Due to 

the project location, which is mostly found within mid-to-upper slopes (upstream of coho salmon 

distribution and critical habitat), proposed PDFs, BMPs, and minimization measures for reducing 

sediment, only very negligible amounts of sediment may be delivered to stream channels. Thus, the 

potential for exposing coho salmon (all life stages) and other previously described fish species located 

downstream to increased suspended sediment and turbidity caused by project activities is negligible, and 

the expected response to a negligible increase would be insignificant.

Summary of Ground Disturbing Actions within Riparian Reserves

Table 3-30 shows the extent of actions that are planned to occur within riparian reserves and have the 

potential to impact water quality by increasing background sedimentation rates in the short term. No 

mechanical treatments occur adjacent to coho habitat; however, 18 treatment units over 10 watersheds (13 

manual only units and 5 prescribed burn only units) are found near tributaries or the Klamath River 
Chapter 3. Environmental Consequences

232 – Somes Bar Integrated Fire Management Project

mainstem where coho occupy habitat. As part of these treatments, handlines in riparian reserves would

occur only where necessary to minimize undesired fire effects and would not create significant ground 

disturbance near riparian reserves that could lead to off-site sedimentation.

Table 3-30. Summary of ground disturbance within riparian reserves.

Water Quality Indicators No Action (acres) Proposed Action (acres)

Fuel reduction treatments 0 147

Temporary roads 0 12

Level 1 road refurbishing 0 4

Landings 0 7

Legacy road restoration 0 2

Totals 0 172

Analysis of the proposed actions reveals that less than 172 acres of ground disturbance would occur 

within riparian reserves upstream of fish bearing portions of the stream. The vast majority of these actions 

occur within the outer 80 feet of the riparian reserves, leaving the inner riparian reserve (80 feet for non-fish 

bearing streams) function as a filter to sediment movement. Project design features, wet weather operating 

standards and BMPs are incorporated into the Proposed Action specifically to further insure a low risk to 

water quality as a result of implementing this project. While the No Action Alternative would have no 

ground disturbing action in riparian reserves, hence no effect to water quality, the Proposed Action is the 

alternative that would, in the long term, protect water quality by greatly reducing the chance of high severity 

wildfire in project area. Fuel reduction treatments can influence wildfire severity. Fuel reduction treatments 

conducted on the neighboring district (Lower Trinity RD) a few years prior to the Megram fire in 1999, 

reduced high burn severity to 3 percent of the acres treated (USDA Forest Service 2000b).

Cumulative Effects

Unit of measure – Equivalent Roaded Acres

Duration – Long term (5 to 15 years post treatment)

To assess the potential for the project to add to cumulative effects, the extent all proposed and connected 

action within the analysis watersheds were examined. In addition, effects of past projects and wildfires in 

the watersheds were also examined. The ERA model is designed to determine whether past and present 

land management activities in a given watershed approach or exceed a TOC whereby changes in peak 

flows and hence sedimentation might occur.

The ERA methodology has both strengths and weaknesses. Strength of the ERA methodology is the 

ease with which the analysis can be duplicated and understood. It is also a CWEs model that incorporates 

acres of land management disturbance and recovery times associated with those disturbances, an attribute,

which is missing in many other CWE analysis models. A weakness of the ERA model is that it is mostly a 

computer analysis that is primarily based on management-related hill-slope disturbance. It does not 

directly assess physical or biological processes in stream channels, nor does it account for the time lag 

associated with routing sediment delivered from a given activity. Recovery times in the ERA model apply 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 233

only to the site of a given treatment, not to the recovery of downstream impacts. In predicting post project 

ERAs, the model assumes all proposed actions happen at the same time, and does not account for the 

phasing and time between each entry.

Results from the ERA model (Table 3-31 and Appendix F) indicates that implementation of the project 

would not push the affected watersheds near or beyond the TOC, indicating that implementation of the 

Proposed Action would not result in added detrimental CWE. Field investigations within the affected 

watersheds corroborate the ERA model estimation of low risk of CWE and indicate that past management 

actions have few legacy impacts. Approximately 1 mile of legacy road sediment sources discovered in the 

project area would be rehabilitated, further reducing impacts from past management actions.

Low impact and limited in scope, treatments within riparian reserves are designed to reduce ladder 

fuel concentrations and promote long1term heterogeneity.

Table 3-31. Total equivalent roaded acres (ERA) percentages by watershed for Proposed Action.

Name of 6th-Field HUC Watershed Total Existing ERA (%) Threshold of Concern (%) Total Predicted ERA (%)

Boise Creek-Klamath River 0.8 13.7 0.8

Reynolds Creek-Klamath River 4.2 8 6.4

Ti Creek-Klamath River 4.1 8 5.2

Based upon the analysis of direct, indirect and cumulative effects, the risk to water quality and 

fisheries habitats is low. The Proposed Action would not result in adverse added cumulative effects that 

threaten the long-term water quality and ACS objectives. Proposed new temporary road construction is 

extremely limited (approximately 0.6 miles) and are not hydrologically connected (no stream crossings). 

Implementation of forest plan S&Gs, BMPs, utilization of erosion control plans, adherence to wet 

weather operating plans, as well as the extensive PDFs, when combined provide a solid foundation to 

protect water quality while still achieving fuel reduction objectives in the project area.

Compliance with Forest Plan and Other Relevant Laws, Regulations, Policies and Plans

All alternatives comply with the KNF and SRNF LRMPs, originally published in 1995.

Aquatic Conservation Strategy

The Aquatic Conservation Strategy (ACS) outlines specific objectives regarding forest goals in the 

management of aquatic and riparian resources (KNF 4-25 and SRNF IV-107). Project NEPA decisions 

must be consistent with the wording regarding ACS consistency, including consistency with the nine (9) 

ACS objectives described in the 1994 NWFP ROD (p. B-10) and in the May 22, 2007 Memorandum.

Project implementation does not prevent attainment of ACS objectives at the HUC 6 and larger scales 

in the short-term, and promotes attainment of ACS objectives in the long-term. Fuel treatments are in 

accord with recommendations in the Ishi Pishi Ecosystem Analysis (1998). Cumulative watershed effects

would remain below threshold for adverse watershed effects. Minimal disturbances are not expected to 

adversely affect anadromous fish and habitat because PDFs would contain effects to the project site and 

the effects are negligible in the action area. The project would maintain and help restore many of the 
Chapter 3. Environmental Consequences

234 – Somes Bar Integrated Fire Management Project

Indicators of the HUC 6 sub-watersheds in the short term and are expected to improve aquatic habitats 

and watershed conditions for fish populations in the Kennedy-Ti Creek and Irving-Reynolds Creek 

composite sub-watersheds, and in the lower mid-Klamath River in the long term.

Clean Water Act

The alternatives, as proposed, would comply with the Clean Water Act, Porter-Cologne Water Quality

Control Act, applicable water quality control plans, and the North Coast Regional Water Quality Control 

Board waiver of waste discharge requirements. A waiver application would be filed after the Decision 

Notice is signed.

The Basin Plan for the North Coast contains water quality objectives, implementation plans for meeting 

those objectives, and other policies of the State Water Quality Control Board and the federal government, 

which are applicable to timber and fuel treatment projects. The water quality standards in the Basin Plan that 

most closely apply to this project are sediment, turbidity, temperature and dissolved oxygen.

The standard for sediment states that sediment load and suspended sediment discharge rate of surface 

waters shall not be altered in such a manner as to cause nuisance or adversely affect beneficial uses. The 

standard for turbidity states, “turbidity shall not be increased more than 20 percent above naturally occurring 

background levels”. Relative to water temperature, the Basin Plan states that water temperature of receiving 

water bodies shall not be altered, and at no time shall the temperature of any cold water be increased by 

more than 5°F. Similarly, dissolved oxygen concentrations shall not fall below 6.0 mg/l.

Stream temperature and dissolved oxygen would not be altered as a result of the Proposed Action.

Extensive riparian reserve buffers and maintaining canopy cover at approximately 60 percent in 147 acres 

mechanically treated in the outer 80 feet would protect stream temperatures. Current dissolved oxygen 

concentrations are in the range of natural concentrations and would not be altered. Effort was made to

reduce the risk of sedimentation and turbidity relative to the Proposed Action. The Basin Plan states that

controllable water quality factors shall not cause further degradation of water quality when it has already

been established as degraded, and efforts to restore the impaired beneficial uses of these watersheds must

be made. The water quality analysis of this project has focused on minimizing delivery of managementrelated sediment and improving the long-term sediment regime for the project area.

Endangered Species Act

The Fish BA/BE for the Somes Bar Project (Cyr 2018) contains a detailed analysis of effects and 

determinations on SONCC coho salmon and its designated critical habitat, essential fish habitat (EFH) for 

coho and Chinook, and Forest Service Sensitive species as further summarized below.

The Fish BA/BE analysis resulted in the determination of “may affect, not likely to adversely affect” 

coho salmon and its critical habitat due to a negligible potential for sediment to reach occupied habitat 

through a combination of all actions. More importantly, the BA/BE documented the Proposed Action

would result in key recovery actions being implemented on 5,570 acres of the Mid-Klamath population of 

coho salmon to reduce the risk of high severity fire.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 235

Magnuson-Stevens Fishery Conservation and Management Act

The Magnuson-Stevens Fishery Conservation and Management Act (MSA), as amended by the 

Sustainable Fisheries Act of 1996 (PL 104-267), requires federal agencies to consult with National 

Oceanic and Atmospheric Administration (NOAA) Fisheries on all actions and proposed actions 

authorized, funded or undertaken by the agency that may adversely affect EFH.

All EFH assessments must include: 1) a description of the Proposed Action; 2) an analysis of the 

effects, including cumulative effects of the Proposed Action on EFH, the managed species and associated 

species, including life history stages potentially affected; 3) the federal agency’s views regarding the 

effects of the action on the EFH; and 4) proposed mitigation, where applicable (50 CFR 600.920(g)(2)). 

The information prepared under a BA for formal or informal consultation under the ESA (50 CFR 402.12) 

may serve as the EFH assessment curtailing the need for separate analysis.

Effects to EFH related to the project were analyzed using habitat data derived from available 

historical fish species inventories and habitat assessments on record at the Orleans/Ukonom RD. The 

project may affect Chinook or coho salmon EFH; however, fuel reduction treatments would reduce the 

long-term risk of uncharacteristically high-intensity wildfire.

Forest Service Sensitive Aquatic Species

A BE was prepared for the Forest Service aquatic sensitive species that are located in the analysis area 

(see Region 5 list by Forest dated July 2015; Cyr 2018). The analysis resulted in a “may impact 

individuals but would not lead to a trend towards federal listing” for Upper Klamath Trinity River

Chinook salmon, Klamath Mountain Province steelhead trout, as well as, Pacific and Klamath River 

lampreys. Again, the slight risk of an insignificant amount of sediment reaching these species habitat is 

far outweighed by reducing the risk of high severity wildfire and the potential impacts that would bring. 

The project would have no effect on western brook lamprey, California floater, pristine springsnail, and 

chace juga, as they are not located within the project boundaries.

Soil Resources

Introduction

Soil management objectives with this project 1) keep soil in place: minimize erosion and sedimentation 

by adhering to BMPs and maintaining effective soil cover at or above minimum levels specified herein; 2) 

minimize and/or mitigate secondary soil quality impacts (compaction, displacement, severe burning) by 

applying PDFs specified herein, which mainly aim to limit severity and aerial extent of such impacts; and 

3) monitor project activities as they occur, particularly mechanical treatments and prescribed burning, to 

ensure acceptable soil cover levels are maintained.

The following analysis summarizes the key points from the Soils specialist report (Young 2017). That 

report describes the soils in the project area, provides an assessment of current soil conditions, and 

analyzes the potential effects that treatments under the Proposed Action are expected to have on the soil 

resource. Operational restrictions and mitigations that would help minimize adverse effects on soil quality 
Chapter 3. Environmental Consequences

236 – Somes Bar Integrated Fire Management Project

and productivity are included in the form of PDFs as outlined in Chapter 2. The report includes the 

regulatory framework and applicable S&Gs that were used to evaluate soil condition and potential 

impacts of proposed treatments; a description of the methods used to assess the effects of the project on 

soils; a description of the affected environment, and assessment of the current condition of soils, 

including effects of past management activities; an assessment of the direct, indirect, and cumulative 

effects of the Proposed Action on the soil resource; and appendices containing soil and slope maps, an 

activity unit by soil map unit crosswalk table (used to identify units with “sensitive” soils for priority 

attention in field review), and erosion hazard rating (EHR) calculations.

The Proposed Action is in compliance with FSM direction and all S&Gs that are intended to prevent 

substantial and permanent damage or degradation that affects inherent ecosystem processes. Substantial 

and permanent soil impairment is defined as detrimental changes in soil properties (physical, chemical, 

biological) that result in the loss of the inherent ecological capacity or hydrologic function of the soil 

resource, over the mid-term (substantial, beyond the duration of the project) to long-term (permanent, 

beyond a land management planning period), respectively (FSM 2250). Soil management direction is 

applied to lands dedicated to growing vegetation; it is not applied to areas dedicated to other uses, such as 

roads, trails, administrative and recreation sites, etc.

Both severity and extent of detrimental disturbance are important considerations that must be 

evaluated together to assess potential adverse impacts on soils of the activity area. As such, detrimental 

disturbance can be allowed on a small portion of a unit—this does not constitute adverse impacts; 

conversely, minor disturbance can be allowed in most of a unit, this likewise does not necessarily 

constitute adverse impacts. Detrimental disturbance in greater than 15 percent of the area is used to 

constitute adverse impacts. The indicators for this analysis include soil stability, soil porosity, soil organic 

matter, and soil hydrologic function.

Affected Environment

There have been past entries into the project area to harvest timber, implement prescribed burns, construct 

firebreaks, and respond to wildfire with suppression activities. Portions of the project area remain 

detrimentally disturbed, most commonly in plantations. Persistent disturbance is primarily compaction 

located in old landings, old temporary roads, and some primary skid trails near landings; some old 

temporary roads also have significant displacement. The assessment of current soil condition and past 

disturbance extent is based upon ocular estimates of disturbance collected when field reviewed. Severity 

of persistent past disturbance was assessed qualitatively (i.e., for compaction, inspecting soil for platy 

structure, and presence and distribution of fine to medium roots to estimate whether root growth pattern 

was affected (excluded or restricted)).

Soil Cover (Soil Stability)

Bare soil was occasionally noted during field investigations, but was rarely observed in most units, and 

when noted was always small isolated patches (such as windthrow mounds) without significant sediment 

movement. The only exception was a few segments of old temporary roads, which were identified as 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 237

legacy sites for repair actions. All mechanical and other units surveyed had ample ground cover (>95

percent cover) to prevent soil loss from erosion. This is quite typical in a forested setting with good site 

quality, both for units with no management history and those not entered for a decade or more. The 

average depth of fine organic matter, focused on duff, was 1 to 4 inches thick.

Soil Porosity (Compaction)

Attention given to assessing the soil condition, particularly for proposed mechanical ground-based units.

Detrimental compaction was visually assessed during unit field reviews and using LiDAR imagery. Many of 

the old temporary roads and landings could be seen with the LiDAR. The majority of the plantations and 

some of the non-plantations on slopes generally less than 40 percent still exhibit signs of detrimental 

compaction. Most of the detrimental compaction appeared to occur on old roads and landings, and some (but 

not all) primary skid trails in proximity of landings. Secondary skid trails further out from landings were 

observed to have little to no compaction that would qualify as detrimental. It was also observed on fine-loamy 

soils, notably Goldridge, the well-used old skid trails, landings and temporary roads persist on the landscape, 

and naturally recover very slowly (as in several decades). Less-frequented old skids (with fewer passes) are 

assumed to be okay, since the more heavily trafficked ones are so very close to the threshold.

Field investigations conclude that historic temporary roads and landings may all be assumed to be 

over the detrimental threshold in terms of severity. Only a subset of old main skid trails have detrimental 

compaction. However, old skid trails were universally assessed as occupying less than 15 percent areal 

extent in proposed units, so all units currently meet applicable compaction standards.

Organic Matter

Organic matter currently exists in kinds and amounts sufficient to prevent significant nutrient cycle 

deficits, and to avoid detrimental physical and biological soil conditions, as described below. Kinds and 

amounts based on ocular surveys in units were universally consistent.

Soil Organic Matter (Displacement, Severe Burning)

Evidence of severe burning (from past pile burning or underburns) was not found in any of the proposed 

units. Old piles that had been burned were seen and inspected in a few units, which presumably burned 

hot, but sufficient time has passed such that effects of burning have apparently recovered, with no heavily 

oxidized or charred surface soils found. These piles were also acceptably “clean” or free of topsoil, so it 

was reckoned that brush rakes had been used in previous machine piling operations, with favorable 

results. Other soil displacement was only viewed as significant on a few segments of old temporary roads, 

the same segments having compaction and evidence of erosion, as discussed.

Fine Organic Matter (Nutrient Cycling)

Fine organic matter, including litter, duff, and woody material less than 3 inches in diameter, currently occurs 

on about 95 percent of the area (visually estimated), and on average is 1 to 4 inches deep. This is considered 

sufficient for nutrient cycling purposes, and all proposed units currently meet applicable standards.
Chapter 3. Environmental Consequences

238 – Somes Bar Integrated Fire Management Project

Large Woody Material / Coarse Woody Debris

Large woody material (LWD) and coarse woody debris (CWD), terms used in the KNF and SRNF

LRMPs, are interchangeable and specifications for retention are virtually the same—five (5) to 20 logs 

per acre, greater than 20 inches diameter and at least 10 feet long or 40 cubic feet in volume, and 

spanning a range of decomposition classes, as available on site. Coarse woody debris levels were visually 

assessed during surveys by the soil scientists and/or wildlife biology crews. Non-plantation stands all 

currently meet or exceed this level of CWD. Plantations generally do not, and would not in the 

foreseeable future, lack trees that large in the living stand for recruitment. In accordance with standards, 

where currently existing CWD is deficient, five (5) logs per acre is not required post-activity, but existing 

logs greater than 12 inches diameter should be conserved to meet the intent of the standard.

Infiltration and Permeability (Soil Hydrologic Function)

Water infiltration is reduced in areas of units that were previously managed with mechanical groundbased entry, specifically on the old main skid trails, landings and temporary roads that are considered 

detrimentally compacted. This is generally estimated to be about 5 to 10 percent aerial extent of these 

units, and not exceeding 15 percent in any units. Soil water movement in other units without intensive 

management history is essentially unaffected.

Subsurface permeability is naturally slower in soils with clay loam subsoil (i.e., Clallam deep, 

Goldridge, Aiken), which is generally unaffected by surficial impacts unless exposed by displacement.

Complete topsoil displacement was not observed in any substantial portions of any of the proposed units, 

except for some segments of a few of the old temporary roads. Erosion hazard rating infiltrationpermeability ratings are currently 1 to 4, well below the 6 to 8 that the forest plan uses as a standard.

Besides the EHR water-movement rating standard, impaired hydrologic function is conventionally 

indicated by signs of erosion. In ocular surveys, minor sheet erosion was only noted on a select few of the 

old temporary roads. Also noted was that re-deposition of fines generally occurred over short distances 

(<10 to 20 feet), so the eroded soil materials and nutrient capital remains on site. There were no larger 

contiguous areas (>100 square feet) with signs of erosion to be of concern. Current soil hydrologic 

function of soils is judged as acceptable and meeting applicable standards in greater than 95 percent of the 

project area, with the exception as noted on a select few of the old temporary roads.

Environmental Effects

The proposed project involves multiple purposes and needs, primarily alteration of fuels and forest 

structure as a prerequisite for reintroduction of fire as a more frequent and active element upon the 

landscape, in a more culturally traditional manner to restore cultural vegetation characteristics. Past 

management activities have occurred in a large portion of the project area, with some portion of a 

“footprint” persisting and observable today. The No Action Alternative incorporates these past effects, 

and is analyzed as a baseline or yardstick to compare the end result of new and additive effects from the 

Proposed Action, if implemented.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 239

Methodology

In addition to information obtained from the KNF and SRNF LRMPs and the NRCS Web Soil Survey

(publicly available soil information). Soil resource information was field-verified to 1) validate the soil 

mapping coverage; 2) gather information on site-specific soil properties; 3) assess current soil conditions 

as affected by past management activities; and 4) develop predictions on soil response to the proposed 

treatments within the units (Young 2017).

A LiDAR bare earth DEM was available for the project area. This was highly valuable for mapping 

old temporary roads, as well as creating high-resolution slope gradient maps; these maps were prepared 

and carried in the field during site visits, which made field review much more efficient. Steep inclusions 

within mechanical ground based units could be easily identified spatially in GIS, and this was very 

accurate in the field. Ocular estimates, aided by LiDAR, were made for the overall detrimental soil 

conditions for each of the ground-based treatment units.

The Region 5 Soil Erosion Hazard Rating System (USDA Forest Service 1990) was used to rate the 

risk of soil erosion for all soils in the project area. This system uses various physical soil properties along 

with climate and site-specific factors to rate soils for hazard of sheet and rill erosion. This system can also 

be used to determine the amount of surface cover necessary post-activity to avoid raising the erosion 

hazard rating to a higher risk level, and to determine the slope gradient at which EHR becomes higher 

with other site factors held constant. Hazards of gully erosion or mass wasting are not addressed with this 

procedure; these are evaluated on site during site visits.

Spatial and Temporal Bounding of the Effects Analysis

For soil resource analysis, the analysis area for direct effects is bounded spatially by the entire “footprint” 

of the project activity units, as this is the full extent of direct soil disturbing activities. For indirect and 

cumulative effects, the analysis area is likewise the same as the proposed project area (unit areas only).

Although surface runoff egressing the project units has a potential to indirectly affect adjacent downhill 

slopes, it is only relevant where 1) runoff may be expected to occur, and 2) site-specific topography 

indicates runoff could pose additional off-site scouring, erosion, or water quality concerns. It is an 

assumption that runoff and erosion concerns are expected to be controlled on-site through effective BMPs 

and drainage controls. Thus, the analysis area for soils equals the proposed project area.

The analysis is further bounded in time by the foreseeable future period during which effects of this 

project could persist as detectable, significant effects. Some soil impacts, such as cover reductions, can 

naturally recover quite quickly from needlecast and other organic debris deposited on the forest floor. 

Others, such as compaction and effects of displacement, can persist for decades. In general, expectation 

for temporal longevity of effects is discussed as short-term (<5 years), mid-term (5 to 20 years), or longterm (>20 years) effects. For cumulative effects, the analysis is bounded in time by past, present, and 

reasonably foreseeable future projects.

Analysis Indicators

Four indicators were chosen that best address relevant soil issues in the project area and measure 

compliance with forest plan S&Gs. The indicators include:
Chapter 3. Environmental Consequences

240 – Somes Bar Integrated Fire Management Project

1. Soil stability (soil cover for erosion prevention),

2. Soil porosity (limiting aerial extent of compaction),

3. Soil organic matter (displacement, severe burning and CWD), and

4. Soil hydrologic function (infiltration and permeability)

The unit measure for each indictor is percentage area (acres) not meeting desired conditions, as set 

forth from applicable Forest Plan Soil Quality Standards (SQS) and/or S&Gs.

Alternative 1 – No Action

Direct Effects of No Action

Direct effects of the No Action Alternative would be of no immediate effect at all on the soils, as soil 

disturbing project activities would not take place. Soil cover for erosion protection would not change. 

Present compaction levels would remain the same in the short-term, with very slow long-term natural 

recovery. Surface organic matter components would continue to accumulate faster than decomposition. 

Soil organic matter would be unaffected. Soil hydrologic function would be unaffected.

Indirect Effects of No Action

Indirect effects of the No Action Alternative would be the increased accumulation of organic matter in 

terms of surface and ladder fuels, with a corresponding continual increase in fire hazard. Fire hazard is 

not the probability of a fire ignition, but that a fire ignition (human or lightning caused) would result in a 

successful fire start and spread, and fire behavior would be more severe. Fire hazard already represents an 

unacceptable threat to specified values at risk within the project area, due to present vegetation 

composition. The No Action Alternative would do nothing to alleviate the hazard, or manage risks 

associated with watershed values.

The threat of wildfire to the soil resource should not be underestimated. As fire intensity increases, 

the potential for soil organic matter destruction, nitrogen volatilization, microbial mortality, structure and 

porosity destruction, inducement of water-repellency, and erosion are greatly elevated. High soil burn 

severity can severely damage soils and cause long-term declines in soil productivity and hydrologic 

function. Post-fire erosion is probably the single greatest risk to long-term productivity of soils in this 

Region. In extreme cases, soils cannot be revegetated without management intervention, or type 

conversion of vegetation communities may occur. Low to moderate severity fire is not usually considered 

a serious threat to soil resources, so to the extent that management activities can reduce the occurrence of 

high severity fire, soil resources benefit in the long term. High severity fire may have other resource 

benefits, depending on scale, but not for soils as an essentially non-renewable and irreplaceable resource.

Cumulative Effects of No Action

There would be no additional impacts to soils with the No Action Alternative, so there would be no 

additive effects of other past, present and reasonably foreseeable future actions, and therefore by 

definition no cumulative effects. Soils would continue to have natural ecological function and soil 

productivity would be unaffected relative to the current existing condition.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 241

Alternative 2 – Proposed Action

Direct Effects of the Proposed Action

Direct effects are generally analyzed in the context of activity types and where they are expected to occur 

(i.e., what “footprint features” would be left behind and what are the soil impacts). The direct effects of 

these activities are very largely predictable based upon expected methods of operations and location of 

activities in terms of topography and soils and vegetation composition, the latter indicating types and 

amounts of removals or general treatment intensity.

Indicator: Soil cover for erosion prevention

Reduction of soil cover to varying degrees is a given by-product of proposed activities. This is acceptable 

given that residual soil cover still meets requirements for erosion prevention, generally 50 to 80 percent 

cover depending on activity type (tractor or burning) and soil surface texture (loam or sandy loam) per the 

KNF LRMP (p. 4-20, Table 4-2, copied below as Table 3-32).

The only sandy loams where the higher cover levels are specified are Clallam very deep (Map Unit 110) 

and Lithic Xerorthents (MU 300sr). These are guidelines, not standards. Site-specific EHR development (Soil 

Report Appendix C) indicates that greater than 50 percent cover is adequate to avoid a high erosion hazard, 

except only for Hugo soil, which occupies about 21 acres in the Donahue project area, most of which is 

riparian reserve and all of which is proposed for manual/prescribed burn only. Donahue Units 2449, 2498, 

2503, 2506 and 2509 require 70 to 80 percent cover maintained post-activity to avoid a high EHR, 

specifically in portions of the units mapped with these soils, and there upon slopes steeper than 55 percent.

All other areas have loam surface textures, and greater than 50 percent soil cover in the form of duff 

and litter is estimated as sufficient to avoid a high erosion hazard. Only prescribed (broadcast) burning 

activities have potential to exceed 50 percent cover losses, and then only if the burns are much hotter than 

planned. It is expected that burns would be conducted with target residual cover levels in the prescription, 

and all units should accordingly meet this requirement at unit-scale post-activity.

Table 3-32. Soil-cover guidelines for projects.

Soil Texture Class Slope (%) Minimum Total Soil Cover32 (%)

Guidelines for Projects Using Tractors:

Sandy loam or coarser

0-25 70

26-35 80

Loam or Finer 0-35 70

Guidelines for Prescribed Burning Projects:

Sandy loam or coarser

0-25 60

26-45 70

46 80

Loam or Finer

0-35 50

36-60 60

60 70

 32 Soil cover consists of low growing live vegetation (12 inches high), rock fragments (greater than 1/2 inch in diameter), slash (any 

size) and fine organic matter (charred or not) that is in contact with the soil surface. Fine organic matter refers to the duff, litter, and 

twigs less than 3 inches in diameter.
Chapter 3. Environmental Consequences

242 – Somes Bar Integrated Fire Management Project

Indicator: Soil porosity (compaction)

The KNF has no compaction standard in its LRMP, but that forest has historically used the same standard 

as in the SRNF LRMP: detrimental compaction is a 10 percent reduction in total soil porosity, and this 

condition cannot occupy greater than 15 percent area of an activity unit. All units surveyed currently meet 

this standard. For proposed activities, this would practically apply only to units with mechanical groundbased activities. One PDF specifies limiting temporary roads and landings and skid trails to less than 15

percent unit area, and this is a conventional standard that the forest’s sale administration staff is 

accustomed to implementing and achieving.

A handful of units are close to exceeding this standard currently with legacy tractor impacts, and these 

would require unit-specific measures to ensure compliance with the 15 percent area and avoidance of 

cumulative impacts. The following units require particular attention to reutilizing existing skid trails and 

landings (PDF) followed by subsoiling or at a minimum rock-ripping of main skid trails and landings 

when mechanical operations are complete; this is needed to ensure compliance with LRMPs.

o Donahue: Units 2409, 2467, 2493, 2500.

o Patterson: Unit 2242.

o Ti Bar: Units 2117, 2119, 2127.

It is thus expected that all units would meet this standard post-activity.

Indicator: Soil Organic Matter (SOM)

Soil organic matter (SOM) is organic matter and humus within the topsoil, which is crucial for nutrient and 

water holding capacity and long-term soil productivity. In Mediterranean climates, it is produced mainly 

from annual fine-root turnover, and to a lesser extent from fine surface organic matter additions; these are 

long-term processes, and long timeframes are necessary to accumulate SOM. The SOM is then vulnerable 

to loss from erosion (export), severe burning effects (volatilization), and displacement (redistribution, but 

still generally on-site). Erosion is explicitly part of the project design to prevent and avoid. Therefore, 

severe burning has the greatest potential to cause some loss of SOM and nutrients in the top several inches 

of soil, precisely where they are most concentrated (Wells et al. 1979, McNabb and Cromack Jr. 1990). 

This is a concern with the extent and frequency of burning being proposed with this project.

That said, burns that aim to preserve greater than 50 percent duff cover for erosion prevention should 

likewise not be hot enough to significantly degrade SOM in the surface soil, except perhaps in small 

patches, as with pile burning. Broadcast burning prescriptions as practiced usually produce low to 

moderate soil burn severity (SBS), as opposed to 5 to 15 percent high SBS plus 30 to 40 percent moderate 

SBS typical for wildfires in this vicinity (BAER records, on file with author).

Both forest plans have a SOM standard of retaining 85 percent of total SOM in the top 12 inches of 

soil. Though not stated, this standard is aimed at avoiding excessive soil displacement; notably it is nonimplementable because even an experienced soil scientist cannot objectively determine compliance, or 

lack of. That said, soil displacement effects are a lesser concern for SOM loss, because the displaced soil 

is still on-site unless eroded, so the nutrient capital is still accessible by plant roots. This was a much 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 243

greater concern historically when large brushfields were “reclaimed” for conifer plantations by “topsoil 

windrowing” to remove root-crowns of sprouting species that would be aggressive competition for 

resources, along with removing nutrient and SOM rich topsoil. It became known that this practice was 

degrading to long-term soil productivity, particularly when windrows were spaced far apart and then 

many tree roots could not reach the enriched soil; such practices have not been conducted for several 

decades now.

Proposed activities, including burning activities, are expected to result in all units meeting applicable 

standards for SOM post-activity.

Surface organic matter (duff and fine litter)

Surface organic matter here is for nutrient cycling, as opposed to erosion prevention, which may or may 

not coincide as the same cover levels. Both forest plans specify at least 50 percent cover of duff and fine 

litter for soil productivity (with perhaps more needed for erosion prevention, as determined for the 

project). As already stated, it is expected that this level of soil cover would be met for all project units

post-activity.

Furthermore, these are not clearcuts. A living forest canopy that continually adds litterfall to the forest 

floor would compensate in the short-term to cover small areas that may have burned hot or otherwise 

inadvertently removed more cover than desired. A healthy productive forest is the best case for selfmaintaining favorable nutrient cycling, particularly on the more developed soils (Ultisols and Alfisols).

Coarse Woody Debris

Coarse woody debris is generally sufficient in non-plantations and deficient in plantations currently. 

Coarse woody debris contributes to SOM and habitat for arthropods that masticate fine organic matter 

into smaller particles that soil microbes can then utilize as food. Coarse woody debris becoming SOM is 

an even longer-term process than for duff and litter; and in a fire prone setting, most CWD probably never 

makes it to this state, but is consumed by fire sometime at higher levels of decomposition class. That said, 

the habitat value of CWD for arthropods, bacteria, and fungi is ecologically important. Furthermore, 

CWD requirements are explicitly waived in strategic fuelbreak areas.

As with duff and fine litter, the extent and frequency of burning activities, specifically broadcast 

burns, have a real potential of consuming existing CWD and reducing overall levels of this resource. 

Since plantations do not have adequate size class of trees for CWD recruitment, the only practical 

management option is to protect existing CWD in non-plantations from mechanical disturbance and more 

importantly prescribed burning. Burn plans would need specific provisions to protect this resource. This is 

accomplished by providing for low intensity prescribed fire. It is thus estimated in good faith that CWD 

would be protected to the extent practical, and CWD levels would increase over time, on average projectwide and eventually within plantations in the long term.

Infiltration and permeability (soil hydrologic function)

The Klamath has no soil hydrologic function standard in its LRMP; the SRNF LRMP specifies that 

infiltration and permeability would not be reduced to a rating of 6 or 8 under the EHR system. The 

primary impact to soil hydrologic function is compaction by ground-based equipment, which usually only 
Chapter 3. Environmental Consequences

244 – Somes Bar Integrated Fire Management Project

affects surface infiltration, not permeability as this is based upon subsurface water movement that is 

typically below compaction depth. The water movement rating becomes a 6 if infiltration is reduced from 

rapid to moderate on a shallow soil (e.g., Deadwood), or an 8 if infiltration is reduced to slow (<0.6 in/hr.) 

on any soil. Of note, the EHR system was developed primarily for agricultural soils; forest soils nearly 

always have rapid to moderate infiltration rates, being naturally more porous than equivalent Ag soils. 

Reduction of infiltration to 0.6 inches per hour would be unusually severe levels of compaction, such as 

with a temporary road or winter-utilized landing (not frozen).

Soil hydrologic function is in good condition except in limited areas, namely segments of old 

temporary roads comprising less than 5 percent area in previous ground-based units. This function is 

potentially compromised where severe compaction from ground-based equipment is expected, 

specifically temporary roads and some landings if not rehabilitated. Project design features would limit 

heavy equipment traffic (including temporary roads, landings, and skid trails) to less than 15 percent area, 

which would satisfy the standard in all units, not just the SRNF where the standard applies. Project design 

features also specify rehabilitation of temporary roads and landings, including some legacy temp roads, so 

this condition is expected to be similar or improved on net-balance post-activity.

Indirect Effects of the Proposed Action

Indirect effects relative to soils include changes to the soil environment, reallocation of soil resources 

(water and nutrients) to fewer plants, changes in the distribution of organic matter upon and within the 

soil, and changes in potential soil damage from future wildfires.

The Proposed Action would create a short- to mid-term change in soil environment. Soil temperatures 

would be elevated due to opening the canopy and increased solar exposure of the soils. This would 

stimulate soil microbial and fungal activity and increase decomposition of soil organic matter and CO2

efflux from the soils. This would also synergistically stimulate root activity of vegetation, also increasing 

CO2 efflux but as importantly, increasing annual fine-root turnover, which is a primary input to soil C and 

organic matter. On balance, soil C attrition in CO2 efflux would probably exceed accrual in root turnover 

for the first several years, then stabilize once revegetation and canopy expansion proceeds to shade the 

soil, then perhaps becoming a C sink from increased tree growth and vigor. This is all largely speculative, 

as current science has not yet formed reliable principles on effects of such practices, particularly 

belowground. Regardless, these effects would be temporary as the overstory canopy closes, understory 

fills in, and forest floor layers increase in depth over several years. Thus, such effects are expected to be 

short- to mid-term, minor, and not relevant to long-term soil productivity. The scale of the proposed 

activities is not large enough to make net carbon sink or source estimates relevant to local or larger scale 

climate effects.

With thinning as a silvicultural practice, residual stocking of trees is supposed to be high enough to 

fully occupy the site, so finite soil moisture and nutrient resources are still fully utilized, just reallocated 

to fewer individual trees. Therefore thinning should have little effect on soil moisture or nutrient status. 

Trees would increase growth rates, expand crown and root systems, and would generally be healthier and 

more resistant to drought and insect attack with more available water and xylem flow.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 245

Increased organic matter mineralization rates, as mentioned above, can provide short term benefits to 

microbial activity and soil nutrient status, but as that nutrient capital is ‘used up’ more rapidly, it can also 

possibly lead to nutrient deficits later. Conservation of surface organic matter as proposed with these 

activities is intended to maintain adequate nutrient cycling and prevent nutrient deficits. Often 

overlooked, the root systems of trees and vegetation that are removed remain in the soil, and slowly 

decompose to provide organic matter inputs directly within the soil, as well as provide readily available 

growth pathways for new roots through compacted soil. This is currently thought by investigators to be 

the probable explanation for a general lack of negative effects on tree growth with extremely severe 

experimental compaction in the long-term soil productivity study (Powers et al. 2005, Ponder Jr. et al. 

2012, Zhang et al. 2017, Busse et al. 2017). This experiment also tested effects of complete organic matter 

removals on soil nutrient status and tree growth, with no negative effects overall in the first 20 years to 

date. Thus, short-term pulse changes in organic matter presence and distribution upon the soil are not 

expected to significantly affect soil productivity.

Given direct localized impacts described above, mainly associated with ground-based operations, this 

should be balanced against a reduced potential for future wildfires to damage the soil in a more harmful 

fashion. On a regional basis, fire is considered a much larger threat to soil productivity than active 

management activities, because the cumulative annual ‘footprint’ of fire is dramatically larger, and it 

causes much more erosion, which represents the most irreversible and irretrievable kind of soil damage.

However, it is also unknown with what severity a future wildfire would burn on these particular areas, 

depending not just on fuels, but topography and weather conditions at the time as they influence fire 

behavior. It is reasonable to assume that fuel reduction activities should help moderate future fire 

behavior, and therefore benefit soil resources, at a cost of management impacts today. This is considered 

acceptable, as long as management related impacts are minor in scale. Soil impacts associated with 

proposed activities are expected to be mostly minor in severity, and ultimately minor in scale.

In summary, indirect effects of proposed activities upon the soil resource are generally neutral or 

beneficial, are short-term in nature, and no adverse indirect effects are foreseen.

Cumulative Effects of the Proposed Action

Past timber harvest activities have occurred in a large portion (55 percent) of the project area. Several past 

projects are listed in the final EA and are not repeated here. Most relevant for soils, regardless of past 

methods the remaining footprint of past activities can be observed in the field, and current condition 

assessed accordingly. Where past impacts cannot be observed today, they were likely minor impacts that 

have naturally recovered and are not significant today, or else they would still be apparent. This is 

bolstered by the finding that almost all of the lasting past impacts that were observed are not judged to be 

detrimental severity or significant in aerial extent today.

The only foreseen future project is the Aquatic Restoration Project. This project involves various 

activities aimed at instream habitat improvements and reconnection of side channels. Within these project 

areas, work would involve heavy equipment, but access to instream work sites would utilize only existing 

roads and trails and no new or temporary access routes. Considering use of existing access and work 
Chapter 3. Environmental Consequences

246 – Somes Bar Integrated Fire Management Project

focused on instream, this project is viewed as having negligible effects on terrestrial areas where this 

current project is to occur.

The Proposed Action by itself would not produce significant amounts of adverse direct or indirect soil 

impacts, using 15 percent area in detrimental soil conditions collectively as the threshold used to 

determine if soil impacts are significant, as per current management direction. Effects of reasonably 

foreseeable future actions are not expected to produce significant impairment of soil quality or 

productivity, because soil impacts are very limited to where soil standards do not apply. Thus there are no 

additive significant effects of past, present, and foreseeable future actions expected, and therefore by 

definition no significant cumulative effects for soil resources.

Statutory and Regulatory Consistency

All alternatives are consistent with the regulatory framework outlined above. Forest plan S&Gs and/or 

SQS are intended to comply with NFMA toward the end result of protecting soil productivity. Standards 

and guidelines and SQS indicators were used as the context to describe and analyze the extent and 

magnitude of expected soil impacts, spatially and temporally. In complying with these forest plan 

provisions, it is assumed that long-term soil productivity is maintained.

Mandatory Disclosures (NEPA)

The Proposed Action involves adverse environmental effects to soil resources that cannot be wholly 

avoided or mitigated. There would be measurable negative effects in specific areas (new temporary roads, 

landings, some skid trails); however, these are not expected to be long term or extensive enough to be 

significant at unit-scale. The aerial extent of these impacts is expected to comply with applicable 

standards (less than 15% area), and thus impacts are not considered to constitute a “substantial and 

permanent impairment” of soil productivity with respect to NFMA and R5 SQS. Project design features 

are developed in site-specific fashion and are intended to ensure compliance with the various elements of 

soil management direction. Physical soil impacts would be limited in aerial extent, and thus are 

considered acceptable for this project, in accordance with soil management direction.

Botanical Resources – Sensitive Plant and Fungi Species

Introduction

Sensitive species are those for which there is a concern for viability of the species based upon population 

trends or loss of habitat that would reduce the species existing distribution (USDA Forest Service 2005, 

FSM 2670.5). Forest Service actions are to be designed and implemented in such a way as to not lead 

toward a loss of viability or a trend toward federal listing. In keeping with this direction, S&Gs from the 

SRNF LRMP (USDA Forest Service 1995) state that:

Before the NEPA process is completed, projects will be assessed through a biological 

evaluation to determine if management activities are likely to adversely affect sensitive 

plant resources. After completion of .the evaluation, proposed actions will be prohibited if 

they are found likely to jeopardize the continued existence of the species or the 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 247

maintenance of the viable populations throughout their existing range. Appropriate 

mitigation measures will be required if activities are not prohibited (pg. 83).

The KNF LRMP (USDA-USFS 2010) for Sensitive species considers that:

... management activities should imitate the natural ecological processes that created 

Sensitive habitat. The guidelines further state that fire and timber management can be 

used as tools for meeting this intent (pg. 27).

This section summarizes the Sensitive species associated with the project area—their distribution and 

ecology—and the potential effects of the Proposed Action and the No Action Alternative on these species 

and their habitat. Information referenced below is drawn from the botanical BE for this project, which is a 

part of the project record (Hoover 2017a).

Affected Environment

Based upon a pre-field analysis which included a) review of the Forest Sensitive species database and 

associated spatial layers of known occurrences relative to the project area, b) assessment of the vegetative 

sub-series and stand age in which the project occurs and c) professional knowledge of Sensitive species 

habitat and distribution on the forest, the project area was stratified to target field surveys. Synthesis of 

this information resulted in survey efforts focusing upon units, or portions thereof, that coincided with 

mature forest types, specifically stands in the mid-mature to late-mature in the Douglas-fir or tanoak

vegetative series. Within these stands, riparian areas were also surveyed. The exception to the mature 

forest affiliation was associated with one (1) species, Thermopsis robusta, which is endemic to the middle 

Klamath bioregion; this species is associated with relatively frequently disturbed settings such as road 

edges or setting subject to frequent wildfire.

Table 3-33 lists the Sensitive species known or detected as a result of project surveys, as well as 

species considered in the analysis. The latter refers to the fungi species that are on the Sensitive species 

list. The reasons for not undertaking surveys for this project are related to the biology of fungal 

organisms, specifically a) the “body” of the fungus is underground consisting of threads called mycelia 

that can extend several meters; b) the stage of the fungus that is observable above ground—the fruit—

may not emerge annually or over consecutive years, thereby making project surveys infeasible; and lastly, 

c) the nature of the project, which is designed to retain habitat components for fungi.

Table 3-33. Sensitive species known or detected in project analysis and their general habitat.

Common Name Scientific Name Taxonomic 

Group General Habitat Number of Occurrences

Bug-on-a-stick Buxbaumia viridis Bryophyte Mature forest-moist, riparian 2

Fascicled lady’s 

slipper

Cypripedium 

fasciculatum Vascular plant Mature forest 1

Sulcaria lichen Sulcaria badia Lichen Mature forests locally, conifer or hardwood 

substrate; also woodlands or open forest 3

False yellow lupine Thermopsis robusta Vascular plant Early-seral, disturbed settings 3

Fungi
Chapter 3. Environmental Consequences

248 – Somes Bar Integrated Fire Management Project

Common Name Scientific Name Taxonomic 

Group General Habitat Number of Occurrences

None Dendrocollybia 

racemosa Fungus Mature forest None known

None Boletus 

pulcherrimus Fungus Mature forest None known

None Phaeocollybia 

olivaceae Fungus Mature forest 1

None Sowerbyella 

rhenana Fungus Mature forest None known

Buxbaumia viridis (BUVI) occurs in mesic to moist settings and occupies well-rotted (decay class 4 and 

5) logs or other forms of CWD of high water content. Relative persistence at an occurrence is dependent 

upon retention of suitable microclimate conditions, available substrate, and the extent of competition from 

other bryophytes or lichens that also occupy advanced decay class logs. It is fair to say that BUVI’s 

persistence is ephemeral if not fragile at a given occurrence, making retention of habitat components for the 

species throughout a forested stand important to the conservation of this species.

In the project area, BUVI was located on advanced decay class logs associated with riparian settings. 

The Proposed Action associated with the respective units in which the species was detected is manual 

thinning and clearing of small diameter ladder fuels and shrub species where shrubs are highly concentrated 

to prepare the unit for subsequent prescribed burning. Burning would occur every two (2) to seven (7) years 

depending on the objective for the given unit and during the moist time of the year. The prescription also 

aims to maintain a minimum residual canopy cover of 60 percent in the 147 acres treated mechanically.

Sulcaria badia’s (SUBA) habitat varies across its range. In the project area, SUBA occurs in mature 

forest yet it prone to those settings in the plant community that are well lit, which is consistent with this 

species occurrence in oak woodlands in other parts of its range. Given its habitat description ranging from 

well-lit plant communities and oak woodlands representing the dry end of the moisture gradient to conifer 

stand types representing the mesic end; it appears that this species is tolerant of a variation in moisture 

conditions. SUBA is geographically situated toward the middle of its range on the SRNF and here the 

species is documented in mixed hardwood-Douglas-fir forests, with the hardwood component comprised of 

madrone, tanoak, black oak, canyon live oak and big-leaf maple, and sugar pine as an associating conifer.

Lichens exchange water and gases through their “skin” and thus are influenced by changes in 

atmospheric moisture. In general, lichens are most susceptible to changes in their environment when the 

thallus (the body of the lichen) is hydrated. In this condition, lichens are most photosynthetically active, 

contrarily, no gas exchange occurs in air-dried lichens (Nash 1996). Reproduction is primarily from 

fragmentation, the breaking of the body of the lichen by wind, animals, or fallen limbs or branches; 

therefore, the dispersal of this species is limited to the extent of a given occurrence—the extent of thalli in 

the canopy of the trees. From the canopy, fragments can become entangled in the leaves, needles, twigs or 

branches of understory trees or shrubs or fall onto the forest floor as litter.

In the project area, SUBA was detected as litterfall and on small branches of understory Douglas-fir. 

It is presumed that the source of the understory material is located in the canopy of nearby mature trees. 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 249

Mature trees serve as a relatively stable substrate over time that would allow for the establishment of this 

species, which is limited in its capacity to disperse.

SUBA is located in units where ground-based mechanical thinning via yarders or tractors, is 

proposed, followed by prescribed burns (two (2) occurrences) and where understory burning alone is 

proposed (one (1) occurrence). Mechanical thinning would retain a minimum of 40 to 60 percent canopy 

cover and all pre-dominant trees; the latter considered “parent” substrate for SUBA. Retention patches are 

a part of the prescription where 0.25- to 1-acre areas would be retained to meet such objectives as 

reducing effects to inner riparian reserves and unstable areas, to occurrences of Forest Sensitive plant 

species. The prescription for understory burning associated with the other occurrence of SUBA aims for 

low-to moderate fire effects (average 4-foot flame lengths) yet there is potential for high fire effects to 

occur in pockets of units where this prescription is proposed. Season of burning would likely occur during 

the time when the thallus of SUBA is hydrated (fall to spring) and thus, most susceptible to changes in 

atmospheric condition associated with fires (i.e., smoke, heat).

Cypripedium fasciculatum’s (CYFA) range is relatively wide, occurring in eight (8) western states. 

More than half of the occurrences documented have fewer than 10 plants (Kaye and Cramer 2005). 

Besides the one (1) occurrence found in the project (with a single non-reproductive plant), there are an 

estimated six (6) occurrences on the Orleans and Ukonom RD. The last monitoring of most of the CYFA 

occurrences on the SRNF was in 2010; therefore, the current condition of the population on the within 

and proximal to the project areas is unknown.

Cypripedium fasciculatum’s existence and persistence in an area is related to its mycorrhizal 

relationships with associating plant species whereby nutrient exchange occurs. Reproduction is primarily 

through underground rhizome development. Dispersal beyond the local area hinges upon aerial dispersal 

of seed, which is less common. Dormancy is a part of the species’ life history as well, whereby a plant 

may not emerge above ground for two (2) or three (3) years. Due to the relatively complicated 

reproductive history (e.g., dormancy phases), impacts to plants during the spring of the year when plants 

are emerging result in set-backs to flowering/fruiting that could extend over the following few years. For 

occurrences with few plants, this set back could result in loss of the occurrence.

Cypripedium fasciculatum is associated with mature forests under relatively high canopy cover (e.g., 

60 percent). Sufficient forest canopy cover and structure to provide shade and filtered light is important to 

the ecology of this species: adequate forest floor moisture and forest floor organics, including logs, are 

needed to sustain their mycorrhizal associates; adequate understory temperatures and humidity are needed 

for plant establishment and growth (Kaye and Cramer 2005). The one (1) occurrence in the project area 

was under greater than 60 percent canopy cover of tanoak and Douglas-fir, the latter, including subcanopy trees and what appeared to be old-growth Douglas-fir trees (4-foot dbh) nearby. The habitat was 

also characterized by a high litter/duff layer that included a large log.

Cypripedium fasciculatum is located in a unit that is proposed for manual thinning and clearing of 

small diameter ladder fuels and shrub species, applying similar prescription designs associated with the 

units where SUBA was located, including size of trees to be removed, retention of minimum residual 

canopy cover of 60 percent and hand piling of slash for subsequent burning.
Chapter 3. Environmental Consequences

250 – Somes Bar Integrated Fire Management Project

Thermopsis robusta (THRO) is endemic to the Mid Klamath River region, yet within that region, it is 

abundant with an estimated 20 occurrences on the Orleans RD and 19 on the Ukonom RD. Unlike the 

other species, which are associated with mature forest, THRO is associated with early successional 

habitats with little to no canopy cover and few associating species. Its long-lived seed bank and hard seed 

coat are adaptations to a habitat subject to disturbance, specifically wildfire, yet human-caused 

disturbances also create settings conducive to establishment of this species including road banks, 

landings/clearings.

In the project area, of the occurrences of THRO, two (2) were associated with an existing landing and 

the other along a road edge intermixed with Himalayan blackberry. There are patches of THRO along a 

road edge adjacent to private property as well.

Sensitive fungi potentially affected by this project include Sowerbyella rhenana, Boletus 

pulcherrimus, Phaeocollybia olivaceae, and Dendrocollybia racemosa. The ecology of these species 

range from decomposers thriving on forest floor litter and duff, to mycorrhizal species that establish and 

interdependent relationship with host trees to exchange nutrients and water, and a species that is parasite 

on decaying fungi. Only Phaeocollybia olivaceae has been documented in the project area in association 

with a manual/prescribed burn unit, but there is the potential for others to be present in the mature stands.

Common to all of these species are habitat conditions characterized by shady, mature stands with 

conifer or hardwood hosts and ample organic material on the forest floor. Management that retains living 

trees (the host) and the important underground linkages for mycorrhizal fungi via the myceliel network 

would maintain habitat parameters for mycorrhizal species (Amaranthus and Perry 1994). Likewise, 

management that retains overstory canopy and the litter and CWD of the forest floor would maintain 

habitat parameters for saprobes (decomposers; Norden et al. 2004). Germane to fire, the interval of 

burning can affect those fungi associated with late-successional forests in the short and long-term.

Frequent fires (i.e., every 2 to 5 years) do not allow for accumulation of organic material on the forest 

floor and therefore, can significantly reduce below ground EMC fungal biomass (Hart et al. 2005, 

Tuininga and Dighton 2004, Wiensczyk 2002).

Environmental Consequences

Methodology

The spatial context for analyzing direct, indirect and in particular, cumulative effects, on rare species is at 

the local scale where the effects at the occurrence level of the population are most readily detected.

Analysis of effects for rare taxa beyond the local scale is not often biologically meaningful due to 

variables associated with plant and fungal species dispersal capabilities (typically short-range), specificity 

in habitat requirements (e.g., presence/availability of CWD), variables associated with a given activity 

(e.g., variable density thinning versus clearcutting) and varying (and often unknown) thresholds of a 

species to disturbance. In the case of this project, the local scale spatially incorporates past, present, and 

foreseeable activities or events on public and private land that are within or adjacent to the respective 

project area boundaries.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 251

In keeping with the spatial scale, the temporal context for assessing past activities would coincide 

generally with those actions that occurred prior to development of land management plans for national 

forests (pre-1990s) which included management of rare species and those activities that were subject to 

rare species management under respective LRMPs. Documentation of Sensitive species such as 

Cypripedium fasciculatum date to the 1980s, whereas information on Sulcaria badia on the forest was in 

2004 at the earliest. Forest planning efforts came along in the early 1990s. Given the affiliation with mature 

forest, it can be assumed that prior to the knowledge of rare taxa and Forest plan development, past logging 

on public lands, involving clearcuts or related prescriptions, negatively affected the rare plant species 

covered in this document. On private land, conversion of forests via clearcutting also occurred and likewise 

negatively affected these rare species. The other activity that might affect Sensitive species and their 

habitats is wildfire of high intensity; however, records on past wildfire indicate that within the project 

areas, wildfires have been more or less absent since the early 1900s (thus the impetus for this project).

The foreseeable future activities are associated with continued implementation of OCFR, Roots and 

Shoots Project, implementation phases of the current project (Somes Bar Project), and implementing the 

Aquatic Restoration Project that is in the planning stages. While not foreseeable, in the fall of 2017, the 

Patterson Project area was affected by the Marble Wildfire and is addressed below under cumulative 

effects.

Indicators used to compare effects of the alternatives vary by species, but in general, include the 

degree or extent of:

o Canopy removal, forest floor shading,

o Disturbance of forest floor litter, duff and CWD due to mechanical operations,

o Burn severity of the soil related to intense wildfire, pile burning,

o Sustained periods of smoke (for the lichen, Sulcaria badia only),

o Narrow prescribed burn fire return intervals (e.g., <5 years).

Alternative 1 – No Action

Direct Effects

There are no direct effects of choosing the No Action Alternative.

Indirect Effects

The ecology of all native plants and fungi in the Mid-Klamath bioregion (and beyond) includes wildfire 

as a natural disturbance. Even the Sensitive species in the project area associated with mature forests, 

including Buxbaumia viridis which is found within riparian settings, have evolved with wildfire at some 

intensity and interval. Where fuels have accumulated beyond their natural range of variability; the risk of 

losing occurrences of Sensitive species with very limited dispersal capability, requirements for shade and 

specific heat/humidity conditions, requirements for large CWD as well as forest floor organics, is real 

when faced with potentially extensive high intensity wildfire. Fire intensity is also a factor for 

Cypripedium fasciculatum, but damage to a given occurrence is affected by fire scale as well as the 
Chapter 3. Environmental Consequences

252 – Somes Bar Integrated Fire Management Project

number of plants present at the time of fire. Localized, intense fire may only affect a portion of an 

occurrence with a relatively large number of plants. Dispersal is less limiting for Cypripedium than for 

Buxbaumia as the former can disperse through asexual means (rhizomes) and air dispersed seeds.

For Thermopsis robusta, an early successional species, while this species may expand to occupy postwildfire settings and thus possibly benefit from the No Action Alternative, human-caused disturbance 

(i.e., roads and road maintenance) appears to serve as a surrogate to the effects of wildfire to stimulate the 

seed bank and clear competing vegetation; therefore; indirect effects of the No Action Alternative are not 

considered in relation to this species.

Cumulative Effects

Across the project areas, there are an estimated 1,482 acres of plantation, clear-cut prior to the 1980s. It 

can be assumed that any of the target species associated with these clearcut areas are no longer extant.

Private land constitutes approximately 800 acres. While not applicable to all private lands, it is assumed 

that developments associated with private property whether it included logging, building construction, or 

other clearings likewise altered habitat conditions to the detriment of the Sensitive plant species, 

Buxbaumia viridis, Cypripedium fasciculatum, and Sulcaria badia and Sensitive fungi species 

Phaeocollybia olivaceae. The extent and intensity of habitat alteration and clearing may also have 

affected the early successional species Thermopsis robusta.

While the lack of fire leading to potential for high intensity burn is identified above as having a 

negative indirect effect to those species associated with mature and older stands under the No Action 

Alternative, it is also related to cumulative effects as past land management practices involving clear 

cutting, with little to no management (thinning) after logging has led to excessive fuel loading within 

sections of the project areas. Past land management practices have exacerbated the cumulative risk 

associated with the No Action Alternative.

Alternative 2 – Proposed Action

Direct Effects

The environmental consequences of the Proposed Action pertain to the alteration of habitat associated 

with mature and older stands as presented in the previous sections pertaining to the individual species or 

species group. Of the 1,420 acres of mechanical treatment (ground and cable) and mastication treatments, 

approximately 15 percent of those acres are in mid-mature and older stands. Of the manual and prescribed 

burn units, 34 percent are in mature stands and 48 percent of the understory burn units are in mature 

stands. Due to the limited extent and influence on mature and older stands, previously disturbed settings 

(i.e., existing landings), construction of new landings along roads (13 acres) and new temporary roads 

(0.6 miles) are not considered to pose a risk to the all target species associated with mature stands; 

therefore, these developments would not be considered further. An exception pertains to an occurrence of 

the early successional species Thermopsis robusta, which is located in association existing landings.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 253

Overall, it is the desired future condition of the Proposed Action to restore the natural process of fire 

to the landscape to create heterogeneous forests and habitats therein, and at different scales, which would 

ultimately benefit native species that depend on periodic disturbance by fire.

The prescriptions associated with mechanical treatments include specific design features listed below 

that would reduce both direct and indirect effects to the Sensitive species associated with mid mature and 

older forests:

o Maintenance of 40 to 60 percent residual canopy cover,

o Retention of all pre-dominant and dominant trees,

o Establishment of retention areas through a given unit covering 5 to 10 percent of unit in 0.25-

to 1.0 acre sections that could include those associated with Sensitive species, and

Likewise, prescriptions for manual treatments and understory burns, in mid-mature and older forests 

where most of the Sensitive species occur, include the following features that, as incorporated, would 

reduce effects to Sensitive species:

o Maintenance of 60 percent residual canopy cover,

o Establishment of retention areas,

o An option to thin and hand pile or scatter fuels prior to reintroducing managed fire to reduce 

the risk of negative prescribed fire effects and,

o Adjustment of prescribed burn intervals to a 5 to 7 year interval in units coinciding with late 

successional forests to allow for accumulation of organic material on the forest floor.

Manual removal and prescribed burning are proposed in units supporting occurrences of Buxbaumia 

viridis, Cypripedium fasciculatum, and Phaeocollybia olivaceae. In addition to features of the 

prescription itemized above, buffers or retention areas were established for Buxbaumia and Cypripedium

due to evaluation of ladder fuels and stems per acre—indicators of fire intensity—where these species 

occurred. Given the moderate to high rating for one variable at a Buxbaumia occurrence and a low to 

moderate rating, for another variable at the Cypripedium occurrence, as well as limitations to dispersal for 

both species, buffers were established. These buffers would allow for thinning of potential fuels within 

the buffer, but no pile burning. Treated material would be located outside the buffer for subsequent 

burning. In association with the Cypripedium buffer, fuels maintenance with prescribed burning could 

only occur during the fall/winter season of the year, before the plant emerges and at interval no less than 5 

to 7 years. A buffer/retention area was also established for the known site of Phaeocollybia olivaceae for 

similar reasons associated with Cypripedium. The buffer is intended to reduce burn intensity that might 

result from pile burning. For ectomycorrizal fungi, such as Phaeocollybia, soil heating has been shown to 

affect fungi species when the temperature reaches 60 to 70 degrees; yet some fungi species survived 

heating at this level (Kipfer et al. 2010). In light of the variables and uncertainties associated with specific 

fungal response—fungal tolerance to soil heating, pile burning would not occur in the buffer but fuels 

removed in the buffer could, alternatively, be lopped and scattered.
Chapter 3. Environmental Consequences

254 – Somes Bar Integrated Fire Management Project

Mechanical treatments followed by manual fuel removal and prescribed burning are proposed for 

units with Sulcaria badia and Thermopsis robusta. A buffer was established for Sulcaria badia only, for 

reasons akin to those associated with Buxbaumia and Cypripedium, reducing the risk of moderate- to 

high-intensity prescribed fire associated with post-mechanical treatment, and alleviating direct impacts 

from commercial thinning of likely “parent” trees of Sulcaria badia. The buffer/retention area would 

exclude all commercial activities and pile burning, but would include thinning of fuels—fuels to be 

located outside the buffer for subsequent burning.

One detection of Sulcaria badia was found within a unit prescribed for understory burning as the 

primary activity. To ensure that understory burning would be of low severity, a buffer/retention area was 

established around the detection that encompasses mature Douglas-fir trees, the likely host for the litter 

fall detection. Within the buffer, trees and shrubs (as applicable) would be thinned and thinned material 

would be located outside of the buffer for subsequent pile burning as applicable. Implementation of PDFs 

would result in no direct effects to Sulcaria badia at this occurrence.

For Thermopsis robusta, ground disturbance associated with commercial thinning, and even 

redevelopment of existing landings where there are some plants maintained proximal to the disturbed 

area, may benefit the species. Thermopsis is a disturbance “follower”; however, thresholds of certain 

disturbance intensities are not know. An example might be the amount of ground surface removed during 

redevelopment of a landing, which may also remove the seed bank for this species. A PDF for 

occurrences corresponding to existing landings next to Units 2454 and 2461 in the Donahue Project area, 

is the buffering or retention of Thermopsis plants that occur on the edge of the existing opening. These 

retained plants would provide a seed source that could germinate on the newly disturbed ground. For the 

other occurrences of this species, the nature of the disturbance proposed is not expected to result in 

negative direct effects to the species.

Furthermore, for all proposed actions, there are S&Gs from the KNF and SRNF LRMPs (USDA 

Forest Service 2010, USDA Forest Service 1995) that pertain to CWD and soil productivity, habitat 

components that are critical to Sensitive fungi, Buxbaumia viridis and Cypripedium fasciculatum,

specifically from the KNF LRMP:

o Biological Environment (6-16): protect CWD from burning and yarding... and other 

activities that might otherwise destroy the substrate, retain CWD in forest patches...

o Soil Productivity (3-4): a minimum of 50 percent of the soil surface should be covered by 

fine organic matter following project implementation, if it is available on the site.

Indirect Effects

Indirect effects pertain to actions that impact (i.e., remove) host species for Sensitive fungi, sever 

mycorrhizal linkages for fungi and Cypripedium, (i.e., through intense burning and frequent burning), 

notably alter shading adjacent to occurrences of Cypripedium or Buxbaumia, or generate smoke that 

affects Sulcaria badia within the tree canopy. The extent of the indirect effect is related to the scale of 

disturbance and frequency. Example, retention of 60 percent canopy and pre-dominant and dominant trees 

as a prescription feature for the manual treatments would lessen indirect effects related to alteration of 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 255

habitat compared to clearcutting adjacent to the occurrence. Relative to atmospheric conditions, 

prescribed and understory burning in mature stands at intervals greater than five (5) years might give 

“breathing” room, literally, to Sulcaria badia in the canopy. In addition to the prescription features, 

specifically listed above under “Direct Effects”, the buffers established for these species are also intended 

to mitigate indirect effects that may occur associated with this project.

The potential indirect effect of the Proposed Action on Thermopsis robusta is associated with the 

potential for expansion of Himalayan blackberry along the road and border of a mechanical unit. Cable 

yarding activities including ground disturbance and removal of competing native vegetation may favor the 

spread of the blackberry. To reduce potential indirect effects to Thermopsis, a buffer was established that 

would exclude removal of trees adjacent to the Thermopsis/blackberry site and cable yarding related 

activities but would allow for manual burn related activities (i.e., removal of blackberry, pile where removed 

and burn) that might reduce the vigor of the blackberry and give advantage to Thermopsis robusta.

Cumulative Effects

The effects discussed above under direct and indirect effects for the target species associated with this 

project pertain to extent and severity of change to mature and older forest stands in particular changes in 

canopy cover, forest structure, quantity and composition of forest floor organics, large CWD, associating 

species and natural disturbance regimes. How the land corresponding to the occurrences of Sensitive 

species was managed in the past has a direct influence on the ability of forested stands to support these 

species today, so cumulative effects have and would influence viability of occurrences over time.

For this project, the spatial context for cumulative effects analysis is at the local scale since this is the 

appropriate scale of a population (plant and fungal). A population is the fundamental biological unit for a 

species. It is at this unit that effects are most readily detected. Local for this project spans the landscape 

within the project areas.

In keeping with the spatial scale, the temporal context for assessing past activities would coincide 

generally with those actions that occurred prior to development of land management plans for National 

Forests which included management of rare species and those activities that were subject to rare species 

management under respective LRMPs. The foreseeable future activities are associated with 

implementation of OCFR, Roots and Shoots Project and the Aquatic Restoration Project.

Prior to land management plans, an estimated 1,482 acres of forest was clear-cut within the project 

areas of this project. It can be assumed that any of the target species associated with these clearcut areas 

are no longer extant. Private land constitutes approximately 800 acres within the project areas. While not 

applicable to all private lands, it is assumed that developments associated with private property whether it 

included logging, building construction, or other clearings likewise altered habitat conditions to the 

detriment of the Sensitive plant species, Buxbaumia viridis, Cypripedium fasciculatum, and Sulcaria 

badia and Sensitive fungi species Phaeocollybia olivaceae. The extent and intensity of habitat alteration 

and clearing may also have affected the early successional species Thermopsis robusta by complete 

removal of occurrences in the wake of logging, but given the variation of disturbance intensity, type of 
Chapter 3. Environmental Consequences

256 – Somes Bar Integrated Fire Management Project

disturbance (mechanical versus fire) and proximity of disturbance to an occurrence, the variables are too 

broad to comment on past actions to this species.

Past projects in the project areas that coincide with the introduction of land management plans and the 

NWFP—the latter bringing light to non-vascular and fungi species—include OCFR (2008) and Roots and 

Shoots Project (2015). For both of these projects, analysis was conducted for the Sensitive species that were 

on the respective Regional Forester Sensitive plant lists dated 2006 and superseded by a revised list in 2013. 

Both of these projects had features similar to the Proposed Action with an emphasis on thinning and 

prescribed burning to reduce wildfire effects. The Roots and Shoots Project only involved manual treatments 

and prescribed burning to promote the development and growth of cultural significant species. Of the target 

species for this project, Buxbaumia viridis, Sulcaria badia and Thermopsis robusta were all detected in 

OCFR as a result of project surveys. The former was located in the inner riparian reserve and thus grounddisturbing activities were restricted and for the other two (2) species, no disturbance buffers were established 

as PDFs. Given the Proposed Action and prescriptions, activities associated with the Roots and Shoots 

Project were not expected to negatively affect any Sensitive species so, no surveys were conducted.

Foreseeable future actions would be associated with continued implementation of OCFR and the 

Roots and Shoots Project, implementation of the current project (effects addressed in this analysis) and it 

is anticipated that the Aquatics Restoration Project would also be in place. The latter is a programmatic 

document including instream habitat management and riparian vegetation restoration. Prior to design and 

on-the-ground implementation, the programmatic requires the involvement of resource specialists to 

determine if PDFs are needed to reduce negative effects. In the case of Sensitive plants and fungi species, 

botanical staff would review the project relative to potential to effect Sensitive plants and fungi species or 

their equivalent, implement surveys during the appropriate season as necessary and determine if 

alterations to the Proposed Action are needed.

In regards to the Marble Wildfire, of the project areas within the project, only Patterson was affected 

by this fire, which burned 318 acres. The majority of the 318 acres burned at relatively low intensity and 

of the high-intensity areas, they were primarily comprised of vegetation in the early mature or shrub seral 

stages. Surveys of those mid-mature and older stands within the fire perimeter in 2015, prior to the 

wildfire, did not result in any detections of Sensitive species; therefore, the effects of this wildfire event 

on the target species is considered minimal to non-existent.

In summary, actions that resulted in the clear-cutting of mature and older forests during the 1950s1980s likely negatively affected those rare plant and fungi species associated with this habitat.

Thermopsis robusta, the only early successional species among those considered in this project, is an 

exception given its requirement for some level and types of disturbance as indicated by its presence is 

clearings, road edges and burned settings.

Recent past actions (1995 and later) and foreseeable future actions are guided by the respective 

LRMPs and associated S&Gs that address Sensitive species (or their equivalent, Species of Special 

Concern, in future Forest planning efforts). For Thermopsis robusta, implementation of the Proposed 

Action with the PDFs is not expected to have any negative direct or indirect effects to this species. For the 

other species considered, prescriptions that provide for retention of mature forest and their structure (i.e., 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 257

partial canopy, CWD, pre-dominant trees, forest floor vegetation mosaics) coupled with PDFs associated 

with recent past, present and future projects are intended to reduce the possibility of direct effects to 

Sensitive species and mitigate significant indirect effects. In light of the inherent uncertainties about some 

Sensitive species, such as the extent of the underground network of fungal mycelia of Phaeocollybia 

olivaceae, the distribution of Sulcaria badia in the forest canopy, and the dormancy and dispersal of 

Cypripedium fasciculatum, the Proposed Action may affect individuals of a given sub-population, but is 

not likely to result in a trend toward federal listing or loss of viability for these species.

Botanical Resources – Survey and Manage Species – Plants and Fungi

Introduction

Survey and Manage (S&M) is a category of species within the NWFP that are closely associated with latesuccessional or old-growth forests and where there is a concern for long-term persistence (USDA and 

USDI 2001). For certain categories of species, if an activity may is considered “habitat disturbing”, then 

pre-disturbance surveys are required. In keeping with the most recent settlement related to S&M standards 

and guidelines (and the associated court order) exemptions to the S&Gs requiring pre-disturbance surveys 

are projects involving “hazardous fuel treatments where prescribed fire is applied and where commercial 

logging is not involved (except in stands younger than 80 years old)” (USDA Forest Service 2014).

Affected Environment

Habitat for S&M species is late-successional (mature) or old growth forests generally defined as forests 

with structural attributes associated with the later stages of stand development and include relatively large 

tree size, accumulations of LWM and logs, multi-layered and multi-species canopy, and moderate to high 

canopy closure. A plant or fungal species associated with late-successional forests have such ecological 

characteristics as stages or long periods of dormancy, limited dispersal capability, ectomycorrhizal 

relationships (that are related to certain species, spacing of host trees...), and substrate requirements only 

found in old forests (e.g., large advanced decay class logs).

The major proposed action for this project is hazardous fuels treatments—manual thinning of small 

trees, pile burning, and prescribed burning. This action would occur in late-successional forests. 

Mechanical treatments are planned to occur primarily in plantations and to a lesser degree, in nonplantations. Of the non-plantations, only an estimated 61 acres across three (3) project areas overlap with 

mid-mature and older stands. The intent of the mechanical treatments is to reduce ladder fuels or in the 

case of non-plantations, enhance the setting for cultural tree species of interest (i.e., thinning trees within 

the drip line and around such tree species true oaks, madrone and sugar pine and reducing the canopy 

cover around these species that prefer settings of relatively higher solar radiation) and creating canopy 

gaps for those cultural use species like iris and beargrass that benefit from solar radiation.

Prior to the surveys there was a known site of the S&M bryophyte Buxbaumia viridis in a riparian area 

that corresponds to the Donahue Project area, Unit 2403 and the S&M fungus Phaeocollybia olivacea in the 

Ti Bar Project area, Unit 2161. Both units are proposed for manual removal of less than 8-inch diameter 

ladder fuels and limbs, pile burning followed by prescribed burning at five (5) to seven (7) year intervals. In 
Chapter 3. Environmental Consequences

258 – Somes Bar Integrated Fire Management Project

2015, surveys were conducted for potential S&M plant species. Survey efforts focused on potentially 

suitable habitat for these species, specifically stands in the mid-mature and older seral stages with the 

structure and canopy cover that defines the habitat. As a result of the surveys, a new site of Buxbaumia 

viridis and Cypripedium fasciculatum were respectively detected in the Patterson Project area, Unit 2247, in 

association with a riparian area and in the Ti Bar Project area, Unit 2162. Activities planned for both of these 

units are the same as the previously known sites—manual removal of fuels followed by prescribed burning.

Surveys were not undertaken for S&M fungi species. The prescriptions associated with the proposed 

actions in late-successional forests, emphasize manual thinning of ladder fuels and prescribed burning or 

understory burning. An estimated 80 percent of the treatment is planned to occur in late successional 

forests). Prescriptions include canopy cover retention of 60 percent (except around culturally significant 

trees or plant species) and retention of pre-dominant and dominant trees. Standards and guidelines 

pertaining to protection of CWD and fine organic matter also address habitat components that are critical 

to fungi (USDA Forest Service 2010). While mechanical treatments may occur in late-successional stands 

to enhance culturally significant species, the proportion of the project area slated for this type of treatment 

is very limited (i.e., 61 acres).

Additional information on S&M species can be found in the specialist report covering faunal, plant 

and fungi species (Bettaso, Yost and Hoover 2017) with more detail on the ecology of the respective 

species or species group (i.e., fungi) in the BA/BE (Hoover 2017a) for this project, since the species 

associated with known sites and those newly detected are also Forest Sensitive.

Environmental Consequences

The indicators for evaluating environmental effects of the No Action and Proposed Action and the effects 

by species are addressed under the Environmental Consequences section for Sensitive plant and fungi 

species above.

The PDFs (i.e., species buffers), in association with the prescriptions and S&Gs, which retain predominant trees and retention areas in mechanical units, aim for low-intensity burning, retain a percentage 

of CWD and duff/litter on the forest floor, and implement prescribed burning at 5- to 7-year intervals, 

would provide for persistence at a site relative to S&M species.

Invasive Plant Species

Introduction

The policy that guides the management of invasive species on national forest lands requires that land 

management activities not foster the introduction and spread of invasive species. Germane to the 

Proposed Action, the following policies from FSM 2900, Invasive Species Management apply:

o Determine the risk of introducing, establishing, or spreading invasive species associated with 

any proposed action, as an integral component of project planning and analysis, and where 

necessary provide for alternatives or mitigation measures to reduce or eliminate that risk prior 

to project approval, and,
Chapter 3. Environmental Consequences

Final Environmental Assessment – 259

o Ensure that all Forest Service management activities are designed to minimize or eliminate 

the possibility of establishment or spread of invasive species on the NFS, or to adjacent areas.

The SRNF LRMP includes the following applicable S&Gs (USDA Forest Service 1995):

o Sites for which ground-disturbing activities are planned shall be evaluated for the presence of 

invasive exotic plant species. (20-16)

o Practices that prevent the introduction or spread of invasive exotic plant species shall be 

incorporated into planning and analysis for all management activities that have the potential 

to introduce or spread these species. (20-18)

o Off-site material (i.e., mulch, imported soil) shall be screened for the presence of invasive 

exotic plant materials. (20-19)

o Sites treated to eradicate invasive exotic plant species shall receive follow-up monitoring. 

(20-20)

The SRNF also developed Invasive Species BMPs that are to be incorporated as standard operating 

procedures Forest wide (USDA Forest Service 2014).

The KNF LRMP includes the following standard and guideline related to introducing invasive plants 

in the context of vegetation management:

o All silvicultural practices shall consider how to best prevent introducing noxious or alien weeds, 

insects, and disease. Certify, by the County Agricultural Department, all straw, hay, and seeds 

used in mulching activities as free of noxious weeds (USDA Forest Service 2010). (21-53)

In keeping with the aforementioned FSM direction, and S&Gs, an Invasive Plant Risk Assessment 

(Hoover 2017b) was developed for this project. Risk is evaluated based upon five (5) indicators: 1) 

presence of known invasive plant species in the project area, 2) habitat vulnerability, 3) non-projectdependent vectors such as existing roads or trails, adjacent private property, 4) habitat alteration expected 

as a result of project implementation, and 5) increased vectors as a result of project implementation. This 

section addresses these factors in relation to the Proposed Action.

Affected Environment

As a result of surveys conducted by MKWC, a partner in this project, six (6) species of invasive plants 

were mapped. The project areas with the highest diversity of invasive plants and cover were those in the 

north of the project area: Ti Bar, Patterson, and Rogers. In contrast, Donahue Project area was relatively 

clear likely due to its distance from State Highway 96 and the Klamath River, both majors vectors for 

invasive species. Himalayan blackberry was the most widespread species, associated with stretches of 

road, within riparian areas adjacent to roads and within unit interiors. Blackberry in the northern-most 

project areas was almost continuous within the first 1.5 to 2.0 miles on roads accessing the respective 

areas and along State Highway 96, which dissects the western-most edge of the northern project area.

Other species, specifically yellow star thistle, Dyer’s woad, Dalmatian toadflax, Scotch broom, 

butterfly bush and tree-of-heaven, were primarily associated with portions of the project areas adjacent to 
Chapter 3. Environmental Consequences

260 – Somes Bar Integrated Fire Management Project

State Highway 96 and associated with the Klamath River bars—those portions dominated by invasive 

plants—and road edges or clearings (e.g., turn-outs, existing landings, disposal sites) along lower sections 

of Forest Service routes that intersect with State Highway 96. The preponderance and diversity of 

invasive plants associated with a state highway demonstrates the role vehicles play in dispersal of 

invasive plants and the suitability of the highway edge setting (i.e., exposed, regularly disturbed) for 

invasive plant establishment (Christen and Matlack 2006, Der Lippe and Kowarik 2007).

In areas further away from State Highway 96 and Klamath River, on less travelled roads, these other 

species listed above were only sporadically observed in the project areas. With the exception of the site 

with a few small tree-of-heaven stems, all satellite (i.e., discrete, isolated) sites with relatively few plants 

were manually treated (hand pulled) upon detection in 2015 and 2017. Invasive annual grasses were not 

targeted for surveys due to the preponderance of forested habitats, however, they do exist in the area in 

association with the river bar and road edges. Annual grasses are very likely present in natural openings 

that exist in those mixed conifer-hardwood forest types (e.g., with oak and pine).

Invasive species have in common high dispersal capabilities, relatively long-lived seed banks, high 

tolerance for disturbance, few herbivores, an ability to reproduce both sexually via seed and asexually 

(via rhizomes). These attributes provide a competitive advantage that leads to displacement of native 

plant communities. Himalayan blackberry is distinguished from the other invasive plant species in the 

project areas in that it tolerates both shady and exposed settings (Caplan and Yeakley 2006), has the 

ability to reproduce by cane sprouting that can produce a thicket up to 15 feet in diameter in less than two 

(2) years (Soll 2004), and the abundant fruits/seeds are readily dispersed by mammals and birds 

(Hoshovsky 2015). Most problematic was the occurrence of Himalayan blackberry in continuous thickets 

along the relatively lower sections of Forest Service routes intersecting with State Highway 96. Within 

this area, Himalayan blackberry was also in forested stands associated with riparian settings. Its presence 

in this setting can act as a barrier to water sources for large mammals such as Roosevelt elk (a focal 

species). Habitat for the riparian associated Woodwardia fern, a cultural use species, is also compromised 

by Himalayan blackberry that out-competes the fern and reduces accessibility for gathering. Likewise for 

hazel, another cultural use species, where Himalayan blackberry was encroaching into the patch of hazel.

Environmental Consequences

Methodology

Invasive species introduction and spread are a by-product of activities occurring within and outside the 

jurisdiction of Forest Service, and as such, the geographic scope associated with invasive plant 

introduction is broad and beyond the scope of this analysis. For this project, due to the relative ease of 

dispersal, the geographic scope is not a fixed landscape or watershed, but related to the Mid-Klamath 

watershed where the invasive plant species associated with this project are documented. What the 

landscape in the project area has in common is the Klamath River, State Highway 96, county or Forest 

Service roads, and private property. Roadside settings are vectors for the spread of invasive plant species 

and if invasive plants make their way to the chronically disturbed river bars, the river also serves as a 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 261

vector of spread. Depending on the extent of clearing and other activities, private property may also 

provide suitable settings for spread of invasive plants.

Temporally, Forest management activities prior to the mid-1990s did not even address invasive plant 

species; presence of species and their distribution were not documented. In addition, definitions and risk 

rankings of invasive plant species is a relatively recent development; therefore, cumulative effects of 

invasive plant species in the current project would focus on recent past and future activities.

In the context described above and given the array of species, their ecology and their geographic 

distribution within the project areas, the activities associated with implementation of this project—the 

indicators of risk—include:

o Operating equipment in areas with a high cover of invasive species and then using that same 

equipment where invasive species do not currently exist,

o Use of heavy equipment or staging equipment at sites with invasive plants or where invasive 

plants are nearby,

o Reducing canopy cover proximal to occurrences of invasive plants,

o Mechanical thinning that removes native vegetation which functions as a barrier to movement 

of invasives from the road edge down into the unit, and

o Manual fuels treatment (thinning and prescribed burning) or understory burning that removes 

native shrubs and trees (competitive vegetation) proximal to existing invasive plant sites.

Alternative 1 – No Action

Direct Effects

There are no direct effects of choosing the No Action Alternative.

Indirect Effects

Road use and road maintenance activities, private land activities and development, as well as the potential 

for high intensity wildfire are ongoing activities that could affect the introduction and spread of invasive 

plants beyond their current distribution, regardless of implementing the Proposed Action. As described 

above, roads and their use are vectors of spread (Christen and Matlack 2006) and certain activities on 

private lands increase risk of introduction and spread. Lastly, given that invasive species are tolerant of 

disturbance, most of the species shade intolerant (e.g., yellow star thistle, Dyer’s woad, Scotch broom) and 

easily disturbed, high intensity wildfire—a situation the Proposed Action is attempting to ameliorate—

would create a setting conducive to the spread and establishment of invasive species beyond their current 

location. Relative to the growth habit of Himalayan blackberry in particular, removal of woody native 

species by wildfire, followed by relatively rapid growth of blackberry could result in its spread from road 

edges down or upslope into the forest interior and serve as a ladder fuel for subsequent wildfires.
Chapter 3. Environmental Consequences

262 – Somes Bar Integrated Fire Management Project

Cumulative Effects

Prior to current forest LRMPs that addressed invasive plant species, invasive species could have been 

introduced on equipment used to build roads, to remove timber, or to stabilize slopes. Private road building 

into forested landscapes also created vectors for the spread of invasive plants, as did some of the activities 

on private lands. Cumulatively, without active management and monitoring, invasive plant species would 

spread both with and without the Proposed Action in association with currently disturbed settings (e.g., 

road edges, clearings, river bars) but as presented under indirect effects, high intensity wildfire that 

removes the canopy and understory cover would create an environment conducive to spread of invasive 

plants, especially Himalayan blackberry, from its current location, into forest interior environments.

Alternative 2 – Proposed Action

Direct Effects

The direct effects pertaining to invasive plant species are primarily associated with introduction and 

spread of invasive plants associated with equipment used for road maintenance, landing developing and 

thinning. Project design features for this project that aim to reduce the risk of invasive plant introduction 

and spread are:

o Equipment cleaning prior to operating in the four (4) respective project areas,

o Avoid development of landings and staging equipment where there is a risk of contact with 

invasive plants, and

o Progression of work which prioritizes road maintenance and mechanical treatments 

(including mastication) first to those units in settings that are relatively “invasive-plant free” 

such as upper reaches of the project areas, before operating in the units/setting where invasive 

plant cover and diversity is high such as along State Highway 96 and on Forest Service routes 

within one (1) mile of the highway.

Indirect Effects

Indirect effects are those associated with the consequences of mechanical thinning, manual treatments, 

mastication, and understory burning relative to the spread of invasive plants. For example, staging 

equipment to be used in a mechanical unit at a turnout that contains patches of Dyer’s woad with seed 

heads could result in the export of plants to another section of road that is currently uninfected. Another 

example relates to opening of the canopy or removing native shrubs (i.e., related to manual treatments) in 

settings proximal to invasive plants. As discussed above, with the exception of Himalayan blackberry, the 

other species are primarily intolerant of shade so exposing the forest floor or reducing cover of competing 

native plants, increases the risk of invasive plant seed, or canes, spreading beyond its current setting.

The PDFs developed for the Proposed Action would aim to reduce the risk of introduction and spread 

of invasive plants associated with these actions. Given its widespread distribution, abilities to spread, and 

tolerance for exposed or shaded settings (including riparian areas), the features below emphasize 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 263

management of Himalayan blackberry but include management of other invasive plants as well. Project 

design features include:

o Management of satellite occurrences with relatively few individuals (i.e., manually 

remove/grub plants until eradicated, before implementing prescribed burning), and manually 

treat other invasive plants (e.g., yellow star thistle, Dyer’s woad) that co-exist with the 

Himalayan blackberry,

o Management of a satellite occurrence of the invasive tree-of-heaven by manual removal of 

the root crown,

o If avoidance is not an option, mechanically blade invasive plants present on existing landings 

away from where equipment would be operating; removed plants would be piled away from 

operations, subsequently burned, and managed with prescribed fire, as applicable,

o Exclude road and roadside openings occupied by Himalayan blackberry from operations 

associated with mastication, mechanical treatments, and road maintenance, and

o Where associated with riparian areas or settings of moderate cover, site prep by manual 

removal (e.g., weed whacking) and piling blackberry where removed, followed by pile 

burning and prescribed fire, with subsequent re-treatments.

o Option: where invasive plants (yellow star thistle, Dyer’s woad) occur as discrete, small 

occurrences manually treat.

o Option related to riparian areas: where Himalayan blackberry has been contained or cover 

reduced, consider active revegetation with relatively fast-growing native trees to provide 

competition and canopy cover (Bennett 2007).

Adaptive management relative to the efficacy of treatment for Himalayan blackberry in particular is a 

key component of the PDFs. If, through monitoring, it is determined that PDFs are not meeting the 

objective of eradicating, maintaining or reducing the spread of Himalayan blackberry, actions pertaining 

to frequency of aboveground treatment or prescribed fire intervals may need to be altered.

Implementation of invasive plant control measures would aim to reduce the risk of introduction and 

spread in relation to the proposed actions identified above under Methodology where invasive plant sites 

are discrete and of relatively few plants. It should be noted that given the invasive plant distribution and 

cover associated with units adjacent to State Highway 96 and lower sections of forest roads that connect 

with the highway, and river bars, are areas that are currently dominated by a diversity of invasive plant 

species. The risk of spread would remain high regardless of the proposed action; therefore, PDFs are 

focused on reducing the potential for spreading invasive plants by utilizing equipment cleaning and 

progression of work methods in these areas.

Cumulative Effects

As imparted above under the header Environmental Consequences, establishing the geographic scope for 

analysis of cumulative effects is difficult for species that disperse readily and long-distances on vehicles, 
Chapter 3. Environmental Consequences

264 – Somes Bar Integrated Fire Management Project

equipment and via river transport. In general, the scope is associated with the project areas and the 

highway and river corridors that run through these areas. In keeping with the temporal context for 

analysis described above, recent past projects include OCFR and the Roots and Shoots Project. The 

foreseeable future activities are associated with implementation of OCFR, Roots and Shoots Project and 

the Aquatic Restoration Project.

For the recent past projects, invasive plant risk assessments were developed using similar criteria 

outlined above (e.g., presence of known invasive plant species in the project area, habitat vulnerability). 

As an example, for the Roots and Shoots Project, yellow star thistle, Dyer’s woad, spurge species, 

Dalmatian toadflax and spotted knapweed were documented in the area associated with State Highway 

96, Forest Service routes and the river bar. Four (4) units (26 acres) associated with the Roots and Shoots 

Project overlap with the Ti Bar project area. The assessment indicated a moderate risk to high risk for 

introduction and spread associated with project implementation without PDFs. The project design features 

to reduce risk were oriented toward management where invasive plant species were limited in distribution 

and activity avoidance where the existing habitat conditions were already compromised by invasive 

plants. Specific to the units in the Roots and Shoots Project that overlap the Somes Bar Project, a PDF to 

reduce risk of direct effects was needed for Unit 1 (9 acres) only: flag and avoid activities proximal to 

concentrations of invasive plant species. The PDFs incorporated into the project reduces the risk of 

introduction and spread as result of project activities was reduced to a moderate level. For indirect effects, 

given the nature of invasive plants and a setting such as that associated with the Roots and Shoots Project

that includes documented invasive plants, a river bar, a highway and roads, and the non-project related 

vectors, a moderate risk of introduction and spread due to indirect effects (e.g., prescribed burning that 

stimulates an unknown invasive plant seed bank) was determined.

Of the seven (7) units of the OCFR project that overlap with the Donahue project area; no detections 

of yellow star thistle or Scotch broom were detected. At the time of field surveys for OCFR (2006), 

inventory and mapping of invasives did not include Himalayan blackberry, likely due to its limited 

distribution at that time.

On-going implementation of past projects (Roots and Shoots, OCFR), as well as implementation of 

the Somes Bar Project, provides for continued treatments to reduce the introduction and spread of 

invasive weeds in the project area. The future foreseeable project to occur in the Somes Bar Project area 

(i.e., Six Rivers Aquatic Restoration Project) would also include a risk assessment for invasive plants, as 

well as site-specific PDFs.

From a cumulative effects perspective past, present and foreseeable future Forest Service activities 

include design features aimed to reduce the risk of introduction and spread of invasive plant species to at 

least a moderate level, or is some settings were invasive treatments are of small, discrete locations, a low 

level of risk. Non-project related vectors and vulnerable habitat settings are factors beyond the scope of 

Forest Service management that will continue (e.g., State Highway 96 road maintenance, potential 

introductions of invasive species on private lands that border public lands) and thus may compromise the 

proposed risk reduction efforts.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 265

Critical to the Somes Bar Project would be timely implementation of design features and adapted as 

applicable. The objective of containment if not eradication is a distinct opportunity where invasive plant 

sites are discrete and consist of a small number of plants. The objective of prevention is associated with 

heavy equipment use in a manner that avoids contact with invasive plants so that invasive plant material 

is not spread into previously uninfected areas within or between project areas.

Social Environment

Introduction

This section presents the predicted effects of Alternative 2 (Proposed Action) compared to Alternative 1 

(No Action) associated with human disturbances (operational noise and smoke), and to recreational and 

visual resource values. Most homesteads were purchased between 1913 and 1940 (Land Status Atlas). 

Transportation development built to meet national demands for timber resources abundant on national 

forests, particularly in 1950s when extraction escalated, improved road access to private land inholdings.

During collaborative events, residents expressed they choose to live in these isolated private land 

parcels surrounded by forestlands, because they highly value and cherish solitude, quiet, outdoor 

recreation, the scenic beauty and bounty provided by nature. For them, the ripple effects to family 

traditions, scenic quality and recreational opportunities from one (1) high-severity fire event becomes a 

moment in time that lasts in the memories for generations... stories not forgotten. Although some 

activities such as gathering and hunting are necessary activities to supplement food sources, they also 

represent family-oriented recreation and cultural traditions.

The second part of the social environment at the end of the analysis displays the economic outcomes 

of the project benefiting local economies.

Affected Environment

Localized environmental conditions are influenced by topographic, slope gradient and aspect, promoting 

forest vegetative species diversity and complexity in pattern and texture (see Fire/Fuels and Vegetation

sections).

The Ti Bar, Patterson, and Rogers Creek project area landscape features on the eastern side of the 

Klamath River are steep slopes, dissected by numerous seasonally running and perennial streams, as 

illustrated in Figure 3-32. In contrast, the Donahue Project area located on the west side of the Klamath 

River is characterized by more gentle slopes.

Figure 3-32. Aerial view of steep slopes in the Klamath Mountains.
Chapter 3. Environmental Consequences

266 – Somes Bar Integrated Fire Management Project

Scenic integrity (quality) has been altered by historic land management activities on national forest 

and private lands. The private land inholdings experienced land development for agriculture, hobby farms 

and residential construction, involving clearing of forest vegetation and road development as displayed in 

Figure 3-33.

On national forest land, even-aged timber harvesting practices were implemented. The intensity 

occurring in the Donahue Project areas was more extensive compared to the other project areas, due to the 

more gentle slopes, where operations were most cost effective. The most extensive timber extraction 

occurred in the 1950s, 60s and 70s. During that time, the transportation network was expanded for access 

and hauling timber to mill sites; now used by the public as access to national forestlands and inholdings.

The outcome of tree removal, intensive timber harvest practices (i.e., clearcut, seed tree, shelterwood

methods), along with road construction drastically altered the scenic quality. On national forest lands, 

Figure 3-33. Map of historic timber harvesting in the project areas.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 267

there has been some recovery of the forest clearings with ingrowth of planted trees, natural regeneration 

and sprouting shrubs. However, resource modifications and utilization practices are still visually evident

from open public roads, private land and select distance viewpoints from State Highway 96.

These same historic forest vegetative conditions also inadvertently promote moderate and highintensity severe fire behavior, as combustible plantations are overstocked with low-lying limbs and 

continuous surface fuel debris. This potential for combustible forested vegetative and woody debris to 

fuel flames is a potential threat to scenic stability, which impacts scenic and recreational quality. Refer to 

Fire/Fuels and Vegetation sections for more information.

The social recreational setting provides for moderate to high frequency of contact on open public 

roads and low- to moderate-frequency use away from roads, allowable under Semi-Primitive Motorized

and Roaded-Natural Recreation Opportunity Spectrum (ROS) visitor-use opportunities (see Methodology

section below). There are no national forest system trails (OHV or hiking) or dispersed camping sites

within the project areas. Creeks tend to be shallow, incised and are not favored public swimming sites.

Most recreational activities are concentrated along the Klamath River or are associated with the Marble 

Mountain Wilderness to the east, outside the project area.

The Klamath River, flowing north-south, is designated a Recreational River within the National Wild 

and Scenic Rivers System in 1981; classified as a designated and recommended recreational river (KNF 

LRMP 4-156). Three (3) designated segments have been identified for potential reclassification per the 

1986 amendment to the Wild and Scenic River Act (WSRA); closest segment is from Ti Bar to the mouth 

of the Salmon River. The Recreational River designation overlaps portions of the project areas and all 

project activities are consistent with the Reactional River standards and guidelines in the KNF LRMP.

Environmental Consequences

Methodology

The methodology applies to assessing the effects linked to 1) human disturbance from operational noise

due to the presence of field crews and smoke generated from prescribed burning may periodically disturb 

neighbors and 2) compliance with federal land management S&Gs for recreation and scenic management,

disclosed in the KNF and SRNF LRMPs.

Human Disturbance Indicators

The analysis indicators include noise levels from timber harvesting activities and smoke generated from 

prescribed burning in proximity to private land.

Noise.

For purposes of this analysis, machinery noise associated with timber harvest and manual tree cutting is 

targeted, discussed in terms of equivalent sound level, accounting for chainsaws, back-up beepers, 

yarding engines and tooters, diesel motors, cable yarders, landing construction, temporary road building 

and grading roads associated with maintenance. The area of influence is one-half mile from open roads.

Noise is often described as unwanted sound. Sound is defined as any pressure variation in air that the 

ear can detect. If the pressure variations occur frequently enough (at least 20 times per second), they can 
Chapter 3. Environmental Consequences

268 – Somes Bar Integrated Fire Management Project

be heard by the human ear and called sound. The number of pressure variations per second is called the 

frequency of sound, and is expressed as cycles per second, called Hertz (Hz). The relative loudness or 

intensity of sound energy is measured in decibels (dB). A decibel is a logarithmic unit of sound energy 

that represents the smallest variance in sound that the human ear can detect.

Ambient (background) sources of natural noise range from short-term soft sounds, as in the sound of 

the wind in the trees (30 to 50db), to short-term loud cracks and rumbles, as in the sound of falling rocks 

(60 to 80db). Environmental noise is usually measured in A-weighted decibels (dBA) and typically 

fluctuates over time. An “A-weighted” decibel (dBA) is a decibel corrected for the variation in frequency 

response of the typical human ear at commonly encountered noise levels. Noise exceeding 85 decibels 

(dBA), regardless of duration, warrant protective devises to protect hearing.

The presence of field crews is recognized for the potential to disrupt the experience of remoteness and 

isolation. The analysis indicator addressing noise is used as a proxy to reflect disruption to these quietdependent experiences.

o Spatial parameters. The spatial bounds for analyzing indirect and cumulative effects of 

noise disturbance is defined as within 150 feet of private land.

o Temporal parameters. The temporal scale for noise disturbances for analyzing direct, 

indirect and cumulative effects is based upon the 15-year implementation timeframe.

Smoke/Dust.

For purposes of this analysis, altered air quality from prescribed burning is targeted, discussed in terms 

relative to visibility and smell. Although prescribed burning activities must adhere to the Clean Air Act33

and all relevant state and federal associated provisions; there is allowance for temporary production of air 

borne particulates (ash fall-out) during specified weather conditions and dust from use of heavy 

equipment (log and transport trucks) on native (dirt) roads

o Spatial parameters. The spatial bounds for analyzing indirect smoke effects from prescribed 

burning in the project area.

o Temporal parameters. The temporal scale for smoke disturbances for analyzing direct, 

indirect and cumulative effects is based upon the 15-year-implementation timeframe.

Scenic and Recreational Quality Indicators

The KNF LRMP describes land management direction with unique S&Gs to fulfill this vision, based on 

designated spatially explicit management area (MA) prescriptions. Standards and guidelines are the rules 

and limits governing actions and the principles specifying the environmental conditions or levels to be 

achieved and maintained. The land management direction is to achieve landscape objectives for visual 

quality influencing recreational experience, so actions, “would appear to be primarily shaped by 

ecological processes, rather than management activities. Openings in the forest canopy created by 

vegetation management would not be readily evident. Existing clearcut units that are apparent today 

 33 Including provisions of the Clean Air Act, California’s Title 17.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 269

would blend into the surrounding vegetation in the future, as planted trees mature and visual restoration 

projects soften sharp contrasts in line, form and color” (KNF LRMP p. 4-15).

Each MA allows for an integrated set of management activities and practices conducted on 

geographically locatable areas in alignment with the designated ROS, place-based setting prescription and 

S&Gs. In some cases, management areas can overlap, in which case, the more restrictive standards apply. 

This analysis of predicted effects to recreational and scenic resource values is founded upon ensuring 

prescribed ROS classes as defined in the ROS Users Guide (USDA Forest Service 1982), described in 

Table 3-34; and visual quality objectives (VQOs) are fulfilled, described in Table 3-35.

The ROS classes are based on the premise that recreational opportunities exist in a continuum of time, 

and with a variety of social motivations and place-based settings, ranging from completely undeveloped 

with Retention VQO prescriptions, to highly developed allowing for Modification VQO prescriptions. For 

management and conceptual convenience, possible mixes or combinations of activities, settings, and 

probable experience opportunities have been arranged along a spectrum, or continuum (USDA Forest 

Service 1982). This continuum is the ROS, which accounts for alterations to visual (scenic) quality.

Table 3-34. Definitions of Roaded-Natural, Rural and Semi-Primitive Motorized ROS classes.

ROS Class LRMP FEIS Appendix E-1 1982 ROS User’s Guide

RoadedNatural

Characterized by predominantly 

natural-appearing settings with 

moderate sights and sounds of 

human activities and structures.

The area is 1/2 mile or less from roads and trails open to motorized use. 

Resource modifications and utilization practices are evident but are harmonious 

with the natural environment. The social setting provides for moderate to high

frequency of contact on roads and low to moderate frequency on trails away 

from roads. Capacity ranges from 10 to 20 RVDs/acre/year. On-site use 

controls are noticeable, but are harmonious with the natural environment. 

Typical activities include, but are not limited to hiking, horseback riding, crosscountry skiing, snowmobiling, OHV touring, trailer camping, hunting and fishing. 

The compatible VQOs are Modification, Partial Retention and Retention.

Rural

The sights and sounds of human

activity are readily evident while 

the landscape is often dominated 

by human-caused geometric 

patterns.

The natural environment is substantially modified to the point that 

developments are dominant to the sensitive observer. Structures are readily 

evident and may range from scattered to small dominant clusters.

Pedestrian or other slow moving observers are constantly within view of 

culturally changed landscapes. The social setting provides for moderate to high 

visitor contact. Typical activities or facilities include, but are not limited to

camping, fishing, information centers, convenience stores and resorts. The 

compatible VQOs are Modification, Partial retention and Retention.

SemiPrimitive 

Motorized

Characterized by predominantly 

natural or natural-appearing 

landscapes and the presence of 

motorized vehicles. The size gives 

a strong feeling of remoteness. 

The natural setting may have 

moderately dominant alterations, 

but would not draw the attention of 

motorized observers. Structures 

are rare and isolated.

The area is generally 2,500 acres to 5,000 acres in size, and 1/2 mile from 

Level 3 or better roads. There is strong evidence of roads and motorized use of 

roads and trails. Access roads are usually Level 1 or 2 roads. An area 

designated within 1⁄2 mile of primitive roads or trails used by motor vehicles, but 

not closer than 1⁄2 mile from better than primitive roads.

Area is characterized by a predominantly natural or natural-appearing 

environment of moderate-to-large size. Concentration of users is low, but there 

is often evidence of other users. The area is managed in such a way that 

minimum on-site controls and restrictions may be present, but are subtle. 

Motorized use is permitted.
Chapter 3. Environmental Consequences

270 – Somes Bar Integrated Fire Management Project

Table 3-35. Visual quality objective (VQO) definitions.

VQO Class LRMP FEIS Standards and Guidelines

Retention: 1,337 (MA 11) Management treatments are designed to 

appear natural by retaining variable forest 

structure mimicking healthy forest conditions 

that would not be visually evident and would 

remain visually subordinate within the 

Retention and Partial Retention VQO classes.

Manage recreational settings to generally 

achieve semi-primitive motorized or roadednatural ROS conditions.

Partial Retention: 3,781 (MA 15)

Manage recreational settings to generally 

achieve semi-primitive motorized or roadednatural ROS conditions.

The analysis indicator is consistency with ROS and VQO classification S&Gs. Only ROS classes 

Semi-Primitive Motorized, Roaded-Natural, and Rural were considered for this analysis and VQO classes

Retention and Partial Retention, as the remaining classes are either not relevant to this project area or so 

limited in extent as not to provide a comparison to Alternative 1 (No Action) to inform the Responsible 

Official. The scenic integrity VQO is considered within the framework of scenic integrity (quality) and 

scenic stability (threat to being altered by disturbance).

o Spatial parameters. The spatial bounds for analyzing direct, indirect and cumulative effects 

for recreation and scenic resources are the project area.

o Temporal parameters. Since the ROS S&Gs are closely tied to visual quality objectives 

(VQO) for scenery, the same temporal bounds apply. The temporal scale for direct and 

indirect effects is three (3) years for short-term effects, as defined by the Forest Plan, where 

projects are required to meet defined VQO thresholds (retention, partial retention, and 

modification), by meeting VQOs immediately upon completion of the project where ever 

possible and, at the maximum, within 3 years of project completion per MA 11-6 (LRMP p. 

4-116). The temporal scale for cumulative effects accounts for past landscape alterations 

since 1960 relative to land allocation, along with foreseeable actions on private land 

inholdings within the four (4) project areas defining the project area.

Alternative 1 – No Action

Direct Effects

There would be no direct effects for human disturbance from machinery noise, dust and smoke production 

or to ROS recreational opportunities or scenic VQO Retention and Partial Retention classes from 

choosing the No Action Alternative, as no mechanical pre-treatment vegetative fuels modification or 

associated timber harvest/hauling, decking or required temporary access improvements, manual cutting or 

prescribed fire would be implemented. There would be no modification to the natural environment to 

further affect scenic integrity along public roads and private land boundary lines. Historic land 

management and development is visually dominant to the sensitive observer. The project areas would 

continue to be characterized by a predominantly natural or natural-appearing environment of moderate-tolarge size. The ROS social setting would continue to provide for moderate to high frequency of user 

contact on roads and low to moderate frequency of backcountry use, away from roads in ROS RoadedNatural and Semi-Primitive Motorized classes.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 271

Indirect Effects

Under the No Action Alternative, there would be no indirect effects from increased human disturbances 

resultant of machinery noise, presence of field crews, dust or smoke production. As forest vegetation would 

not be altered and operations would not be implemented, there would be no increase of human disturbances, 

and no change to ROS recreational opportunities or scenic integrity linked to VQO Retention and Partial 

Retention classes.

Scenic stability would continue to be at-risk, as current hazard and risk ratings for wildfire would 

remain status-quo (see Fire and Fuels and Vegetation sections). Scenic integrity may be compromised in the 

event of a landscape-scale wildfire, featuring mixed moderate to high fire severity. Charring and conversion 

of forested mid- and late-seral stage stands to early seral shrubs and forbs would be evident, most visible 

immediately after the disturbance. In the long-term, partial recovery of scenic integrity would occur as 

blackened woody material decomposes and vegetative re-growth occurs (Figure 3-34). Smoke generated 

from wildfires would likely be of a higher concentration and longer duration (see Fire and Fuels section).

Loss and/or degradation of natural resources from wildfire would affect other natural resource 

amenities such as water quality (see Water Quality section), wildlife habitats (see Wildlife section), and air 

quality, would act to indirectly compromise recreational and special use activities.

Cumulative Effects

Historic land management and development activities on private and public lands have already altered the 

VQO scenic integrity and quality of ROS natural resource dependent recreational opportunities for the 

short and long-term. Although under Alternative 1 (No Action) there would be no machinery noise or 

Figure 3-34. Post-fire landscape showing charred downed woody material that was 

once a living forest with scenic integrity.
Chapter 3. Environmental Consequences

272 – Somes Bar Integrated Fire Management Project

smoke from prescribed burning, these past land management actions combined with the low scenic 

stability have inadvertently set the stage for moderate and high intensity future fire behavior, which could 

degrade scenic integrity and recreational opportunities associated with Roaded Natural, Rural and SemiPrimitive Motorized ROS classifications in the long term. In the event of a wildfire, recreational use 

would likely disperse to alternate unburned areas, areas void of smoke, and noise from fire suppression, 

until vegetative recovery and the air quality and visibility is restored.

Alternative 2 – Proposed Action

Direct Effects

Scenic and Recreational Quality

Proposed mechanical and manual treatments are designed to appear natural by retaining variable forest 

structure and complex mosaic patterns by maintaining retention patches and creating small gaps, as 

portrayed in Figure 3-35. The alteration, mimicking healthy forest conditions that would not be visually 

evident and would remain visually subordinate within the Retention and Partial Retention VQO classes.

The natural setting would experience moderate, dominant alterations from mechanical and manual 

treatments listed in Table 3-36 and displayed on Figure 3-36, which illustrates where managed areas 

spatially overlap VQO Partial Retention and Retention classifications. This change to scenic integrity in 

these areas, along with the presence of field crews during and immediately after prescribed burning, 

operational slash, reflective tree stumps and smoldering debris would likely draw the attention of 

motorized observers in the short term.

Figure 3-35. Map of example gaps and retention distribution.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 273

Table 3-36. Proposed treatment summary.

Integrated Fire Management Treatments Area and/or Length

Strategic Fire Control Feature Actions Feet

Ridgetop Shaded Fuelbreak 105,524

Handline 145,298

First, Second, Third Treatments Acres

Manual, Prescribed Fire 2,658

Mastication, Manual, Prescribed Fire 187

Mechanical – Cable System, Manual, Prescribed Fire 176

Mechanical – Ground-Based, Manual, Prescribed Fire 1,058

Prescribed Fire 1,491

Total 5,570

Although there is concentrated mechanical treatments in the Ti Bar, Patterson and Rogers Creek

project areas around private land, mitigation measures such as not painting trees boles on the side where 

immediately visible to landowners and coordinating tree marking to accommodate personal preferences 

within the 500-foot buffer would minimize visual impacts.

The series of viewshed maps (Figure 3-37 through Figure 3-40) display the unique spatial extent 

where treatments could be seen from select locations on the Klamath River and private property for each 

project area. The patterns suggest topographic screening associated with mountain ridges and incised 

stream channels. From select viewpoints such as in Ti Bar, the viewing distance extends for almost a mile 

up Kennedy Creek. Similarly, steep slope pitches that rise from the main Klamath River channel are also 

visible in the forefront.

Indirect Effects

Human Disturbances

Noise.

Operational noise from equipment and presence of field crews may periodically disturb neighbors. 

“People do not become accustomed to noise” (Brauer 1990). Noises in the rural settings characterized 

within the project areas can seem amplified, where there are no barriers to the source, such as segments 

along Highway 96. However, noise levels are reduced by increasing distance, air density, wind, and 

obstructions (trees, rock outcrops and natural landscape features). On windy days under the forest canopy 

or near streams, ambient noise tends to screen noise from machinery and traffic.
Chapter 3. Environmental Consequences

274 – Somes Bar Integrated Fire Management Project

Figure 3-36. Map of visual quality objectives within the project (or focal) areas.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 275

Figure 3-37. Map of the Rogers Creek project area viewshed with proposed treatments.
Chapter 3. Environmental Consequences

276 – Somes Bar Integrated Fire Management Project

Figure 3-38. Map of the Patterson project area viewshed with proposed treatments.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 277

Figure 3-39. Map of the Ti Bar project area viewshed with proposed treatments.
Chapter 3. Environmental Consequences

278 – Somes Bar Integrated Fire Management Project

Figure 3-40. Map of the Donahue project area viewshed with proposed treatments.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 279

The extent of noise disturbances from timber harvesting and use of chainsaws would be seasonal, 

with operations phased along transport or log-truck haul routes. Traditional tractor logging generates 

sounds from many sources throughout the harvest area, and usually for the duration of the harvest period. 

However, the sounds from heavy equipment operating on the ground in the forest are often dampened or 

attenuated by the surrounding trees and soft ground surface. Generally, on even terrain, noise level is 

reduced by one-half with a doubling of distance between the noise source and the receptor. The Leq 

measurements reported herein include tree falling, limbing, skidding, stacking, sorting, and loading logs 

onto log trucks to the mill. The initial phase would involve tree felling (65 dBA) within line of sight noise 

measurement distance of 150 feet, skidding and stacking logs (65 dBA), and loading (58 to 65 dBA). The 

dBA would vary depending on the size of logs, if heel boom or loader equipped with log forks is used, 

and other equipment (typically equipment similar to the Caterpillar D6 or D7 bulldozer or a log skidder) 

needed for operations.

Cable yarding by itself is a fairly quiet operation; however, communication from the logging area up 

to the landing is necessary. Loggers do this with pre-designated signals from a device on the belt of the 

choker setter/hook tender that emits sounds on the yarder called a “talkie tooter”. This enables the person 

in the woods to give instructions to the yarder operator to slack on the cable, tighten the slack, haul the

logs, stop for emergencies, etc. The talkie tooter horn generally emits repeated short blasts (documented 

blast of 135 to 140 db at the source). These sounds can carry across small ravines and increased distances 

with wind, generally 1 to 3 kilometers (0.6 to 1.9 miles).

All substantial noise levels resulting from operations would be temporary and infrequent. No 

permanent increases in ambient noise levels in the project vicinity above existing levels are expected to 

result from operations. With the exception of Rogers Creek Project area, where only manual use of 

chainsaws are proposed, noise production would be associated with tractor and cable yarding machinery 

to remove crown and ladder fuels (trees ranging in size) up to the property boundary.

The level of human disturbance depends upon the individual (receptor) sensitivity and life preferences. 

Although noise production would be temporary, limited to daylight hours and weekdays only, those living 

within two (2) miles of operations would hear machinery noise during phased entries over 15 years.

Smoke.

Prescribed burning as seen in Figure 3-41 would be implemented seasonally, phased over 15 years. As 

each entry may be implemented over several seasons, smoke disturbance may impact nearby residents

and visitors by lowering visibility and from the burning smell. While these impacts may occur, mitigation 

elements would address public concerns such including contract language to maintain roadway openings 

or providing road monitors to address safety concerns. Additionally, burn plan development would also 

include language on how to reduce smoke emissions, identify sensitive smoke receptors or indicate 

favorable wind directions for smoke transport.
Chapter 3. Environmental Consequences

280 – Somes Bar Integrated Fire Management Project

Cumulative Effects

Man-made noise-generating activities within the project areas including vehicle traffic (access roads), 

recreation (people, wood cutters and hunters), and activities on inholding residences, combined with tree 

harvesting (machines), manual (crews and chain saws) and prescribed burning disturbances would occur 

close enough to the surrounding rural residential interface for homeowners to hear and be bothered by the 

sound and smoke during implementation, as depicted in Figure 3-42.

Local Economy

WKRP and this project, not including the Klamath TREX or USFS employees, have already contributed 

over $1.4 million to the local economy. Portions of these funds have gone to local contractors and the 

majority has been invested in the local workforce. From 2016 to 2017, the number of full-time-equivalent 

(FTE) positions increased over 200 percent. In addition to USFS employees, WKRP now contributes to 

almost 10 FTE jobs that are all living wage. That number is expected to increase at least as much during 

the implementation of the project. During the initial project period, it is estimated that WKRP, including 

contractors, would employ almost 20 FTE local living-wage employees each year. When the project

moves into maintenance and monitoring, that number may decrease again to 10 FTEs.

Figure 3-42. Rural residential interface with smoke disturbance.

Figure 3-41. Prescribed burning during and after.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 281

The areas being treated through this project have food, medicine and fiber materials that embedded 

within Karuk cultural, social, spiritual, economic and political systems, and daily life (Lake 2010, 

Norgaard 2014).While the Karuk people’s connection to the project area is more than economic, there are 

economic implications for the management. The Karuk Tribe, like other tribes, is disproportionately 

affected by forest management practices because they are heavily dependent on natural resources for both 

economic and cultural identity. The absence of food and cultural use species in this overgrown forest 

undermines the subsistence economy. Multiple social, economic, and health benefits that come to the

Karuk community from participation in the process of traditional knowledge generation and its 

application through management.

Timber Receipts

This project may potentially generate six (6) mmbf (million board feet) of timber as part of the fuels 

reduction objectives.

Prescribed Fire Training Exchanges

In 2008, The Nature Conservancy Fire Learning Network (FLN) designed a novel program to provide 

training and learning opportunities for wildland fire professionals while at the same time furthering the 

long-term objectives of FLN landscapes. These two- to three-week events, known as Prescribed Fire 

Training Exchanges (TREXs), include daily burning and give trainees a concentrated dose of prescribed 

fire experience as well as exposure to new people, places and techniques. The FLN now hosts dozens of 

TREX events across the country each year. The events are deliberately designed to create opportunities 

for trainees to work with qualified trainers. The host units, meanwhile, get qualified workers to help with 

large or complex burn events.

The WKRP partners hosted their first TREX event in Orleans for two (2) days in October 2013. Now, 

the Klamath TREX is an annual two-week training in the use of controlled burning in the Western 

Klamath Mountains to reduce the future danger of wildfires. With combined funding and resources from 

tribal, local, and federal partners, the TREX events help bring in more participants to deliver good fire to 

a larger landscape. Every year, the Klamath TREX advances the training of firefighters from around the 

region, the nation and even the world to share best practices and knowledge about how to implement 

controlled burns. This training event blends traditional native burning with western science to restore fire 

processes directly around communities where it is needed most.

Each year there are approximately 50 training opportunities, with about 100 people participating. 

Approximately six (6) full-time-equivalent (FTE) jobs are created through the Klamath TREX. This 

number is expected to increase slightly during implementation of the Somes Bar Project. The burning also 

increases the food and fiber resources for subsistence gatherers—greatly contributing to the local 

economy. The TREX event builds local capacity, while providing high quality training opportunities for 

local, state, private and federal fire professionals, students, and managers from around the country and 

from other countries.

Prescribed burning reduces fuel loading and wildfire risks in order to protect communities, homes and 

lives. With proper planning, in the right conditions during a safe burn window at strategic locations, 
Chapter 3. Environmental Consequences

282 – Somes Bar Integrated Fire Management Project

prescribed burns are an effective tool. This effort requires close coordination with multiple organizations 

and residents to be successful, including the Forest Service, Karuk Tribe, MKWC, Cultural Fire 

Management Council, Nature Conservancy Fire Learning Network, Salmon River Restoration Council, 

Northern California Prescribed Fire Council, California Fire Safe Council, CAL FIRE, Firestorm, Orleans 

Volunteer Fire Department, and other partners. Prescribed Fire Training Exchange organizers work with 

regulatory agencies and partners to coordinate these burns, which would be implemented following strict 

protocols to ensure safe fuels reduction and capacity building for fire management.
Finding of No Significant Impact

Final Environmental Assessment – 283

Finding of No Significant Impact

Council on Environmental Quality (CEQ) regulations define a Finding of No Significant Impact (FONSI) 

as a document by a federal agency briefly presenting the reasons why an action, not otherwise excluded 

(§1508.4), would not have a significant effect on the human environment and for which an environmental 

impact statement therefore would not be prepared. It shall include the environmental assessment (EA) or a 

summary of it and shall note any other environmental documents related to it (§1501.7(a)(5)).34

Combining the FONSI with the EA avoids having to summarize the effects analysis in the FONSI, 

thereby allowing you to cite in the same document the respective pages where the significance factor is 

discussed in the analysis (40 CFR 1508.13). Although the FONSI has often been combined with a 

decision notice, it is not in itself a decision document. Rather, consider the FONSI the outcome of the EA 

process, documenting findings for the Proposed Action and alternatives. In accordance with the projectlevel objections process, the EA, draft FONSI, and draft decision notice are made available to the public 

at the start of the objection period. If the selected alternative after resolution of objections is a 

modification of what was analyzed in the EA, update the FONSI document to reflect the change.

As the Responsible Official, I am responsible for evaluating the effects of the Proposed Action

relative to the definition of significance established by the CEQ regulations (40 CFR 1508.13). I have 

reviewed and considered the EA and documentation included in the project record, and I have determined 

that the Proposed Action would not have a significant effect on the quality of the human environment. As

a result, no environmental impact statement would be prepared. My rationale for this finding is as 

follows, organized by sub-section of the CEQ definition of significance cited above.

Context

For the Proposed Action, the context of the environmental effects is based on the environmental analysis 

in this EA. This discussion of the Proposed Action’s context provides meaning to the intensity of effects 

described below to support the rationale for a finding of no significant impact related to each factor.

Intensity

Intensity is a measure of the severity, extent, or quantity of effects, and is based on information from the 

effects analysis of this EA and the references in the project record. The effects of this Proposed Action

have been appropriately and thoroughly considered with an analysis that is responsive to concerns and 

issues raised by the public. The agency has taken a hard look at the environmental effects using relevant 

scientific information and knowledge of site-specific conditions gained from field visits. My finding of no 

significant impact is based on the context of the project and intensity of effects using the 10 factors 

identified in 40 CFR 1508.27(b):

 34 Refer to CEQ’s 40 Most Asked Questions #37-39 (https://energy.gov/sites/prod/files/G-CEQ-40Questions.pdf), for more information 

about the FONSI including expected level of detail, providing to the public for review (default when combined with the EA), and

mitigation measures imposed in FONSIs.
Finding of No Significant Impact

284 – Somes Bar Integrated Fire Management Project

1. Impacts that may be both beneficial and adverse. A significant effect may exist even if the Federal 

agency believes that on balance the effect will be beneficial.

The Western Klamath Restoration Partnership (WKRP) aims at transforming the fire exclusion paradigm 

to one of holistic landscape management practice in alignment with the National Cohesive Wildland Fire 

Management Strategy (Cohesive Strategy). The Somes Bar Project seamlessly integrates, in practice, 

principles underlying the Cohesive Strategy and Karuk traditions passed down and preserved over 

generations for millennia.

The Proposed Action would reduce ladder fuels, which in turn increases canopy base heights. Canopy 

densities would be decreased through thinning activities and to a potentially noticeable extent a reduction 

in fuel ladders would also occur through the same activities. These, in combination, would help to reduce 

rates of spread, flame length, fireline intensity, resistance to control and the potential for a ground fire to 

transition into a crown fire (final EA p. 152). The reduction in fire behavior indicators would occur over 

time and multiple entries as the fuel models transitioned following thinning and burning by improving the 

resiliency of stands to large-scale crown fires (North et al. 2012) (final EA pp. 160-166).

One of the most threatened species is the California black oak (Quercus Kelloggii), which is vulnerable 

to being overtopped and crowded out by Douglas-fir. All the same, the oaks that remain are old and serve 

as indicators of an ancestral state. One of the biggest deficits on the landscape is the old upland oak 

woodland (CR). The Proposed Action would directly benefit these traditional ecological knowledge (TEK)

species of interest (California black oak, Oregon white oak, golden chinquapin, hazel, large tanoaks, etc.). 

In plantations, larger hardwoods, both single stemmed and larger stems in clumps, would be favored for 

retention and conifers thinned out around them to enhance hardwood growth while reducing stand 

densities. In natural stands, hardwoods over 24-inch dbh are usually the oldest trees in the stand, although 

they may no longer be dominant or co-dominant in the canopy, these trees were once the dominant or codominant trees in the stands before fire exclusion. Thinning around these remnant trees, many of which are 

being over topped and shaded out by faster growing Douglas-fir, would enable the remnant trees of interest 

to receive more light and grow fuller crowns, which would increase their health and resistance to 

disturbance, as well as enhance accord production in true oaks, tanoaks, and chinquapins (final EA pp. 42, 

47, 105, 126-127, 157, 163, 170).

Small-diameter tree basal mortality is the main negative effect pertaining to incidental torching during 

prescribed burning. These dead trees may be most visibly evident along roadways and near private 

property. Fire-killed leaves and needles are a short-term visual indicator of mortality; however, in a oneyear period following the entry, these fall to the ground lessening the visual effect (final EA p. 154). The 

Proposed Action would implement pre-treatment thinning activities prior to understory burning to limit 

incidental basal mortality of preferred retention leave trees (final EA p. 148). This would minimize 

unintended impacts to soils and visual integrity as well.

The Basin Plan of the North Coast states controllable water quality factors shall not cause further 

degradation of water quality when it has already been established as degraded, and efforts to restore the 

impaired beneficial uses of these watersheds must be made. The project design and mitigation measures 

would act to minimize delivery of management-related sediment and improve the long-term sediment 
Finding of No Significant Impact

Final Environmental Assessment – 285

regime for the project area to protect water quality. The water quality analysis indicates stream 

temperature and dissolved oxygen would not be altered as a result of implementing the Proposed Action. 

The project design delineates extensive riparian reserve buffers and residual canopy cover at 60 percent in 

the outer 80 feet of the acres treated mechanically (147 acres) to protect stream temperatures and reduce 

the risk of sedimentation and turbidity. Current dissolved oxygen concentrations are within the range of 

natural concentration levels and would not be altered by the proposed activities (final EA p. 234).

The policy, which guides the management of invasive species on National Forest System (NFS) lands 

requires that land management activities not foster the introduction and spread of invasive species. 

Germane to the Proposed Action, the following policies from FSM 2900 (Invasive Species Management) 

apply. The direct effects of the Proposed Action pertaining to invasive plant species are primarily 

associated with introduction and spread of invasive plants from equipment used for road maintenance, 

landing developing and thinning (final EA p.216). Project design features (PDFs) for this Proposed Action

would reduce the risk of invasive plant introduction and spread via 1) equipment cleaning prior to 

operating in the four (4) respective project areas; 2) avoiding development of landings and staging 

equipment where there is a risk of contact with invasive plants; and 3) employing progression of work 

which prioritizes road maintenance and mechanical treatments (including mastication) first to those units 

in settings that are relatively “invasive-plant free” such as upper reaches of the project areas, before 

operating in the units/setting where invasive plant cover and diversity is high such as along State 

Highway 96 and on US Forest Service (Forest Service) routes within one (1) mile of the highway (final 

EA pp. 262-263).

Indirect effects of the Proposed Action pertain to the types of actions occurring adjacent to invasive 

plant occurrences, such as reducing canopy or shrub cover by mechanical thinning or manual fuels 

treatments, thereby enhancing the growing conditions of relatively shade-intolerant invasive species and 

reducing competition. These indirect effects could result in invasive species like Himalayan blackberry 

expanding from the road edge into the forest. Project design features to reduce the risk of indirect effects 

and thus substantiate the FONSI for this element, include treatment of relatively small and discrete 

occurrences of invasive species, maintenance of a native vegetation around invasive plant occurrences to 

reduce down or upslope spread, and in certain riparian area reaches, focal treatment of blackberry by 

manual removal, piling and burning (final EA pp. 264-265).

2. Degree to which the Proposed Action affects public health or safety.

Clean Air Act of 1970

The Clean Air Act of 1970 and its amendments provide for the protection and enhancement of the 

nation’s air resources. The implementation of the Proposed Action would not exceed the federal and state 

ambient air quality standards to protect public health. Prescribed burning would be implemented 

seasonally, phased over 15 years. As each entry may be implemented over several seasons, smoke 

disturbance may impact nearby residents and visitors by lowering visibility and from the burning smell in 

the short-term. While these impacts are unavoidable, mitigation elements would address public health and 

safety concerns. The project design incorporates operational provisions to maintain roadway openings, 
Finding of No Significant Impact

286 – Somes Bar Integrated Fire Management Project

along with requiring road monitors, to ensure safe motorized access to private land inholdings during 

operations. Additionally, burn plan would be developed identifying specific tactics to reduce smoke 

emissions, including identifying sensitive smoke receptors and when favorable wind directions would 

promote smoke dispersal prior to scheduling burn ignition (final EA pp. 154, 268, 279).

Clean Water Act

The protection of water quality and quantity is an important part of the mission of the Forest Service 

(USDA Forest Service 2015). Management activities on NFS lands must be planned and implemented to 

protect the hydrologic functions of forest watersheds, including the volume, timing, and quality of 

streamflow. The alternatives, as proposed, would comply with the Clean Water Act, Porter-Cologne 

Water Quality Control Act, applicable water quality control plans, and the North Coast Regional Water 

Quality Control Board waiver of waste discharge requirements. A waiver application will be filed after 

the Decision Notice is signed (final EA p. 234).

The Basin Plan contains water quality objectives, implementation plans for meeting those objectives, 

and other policies of the State Water Quality Control Board and the Federal Government, which are 

applicable to timber and fuel treatment projects. The water quality standards in the Basin Plan that most 

closely apply to this Proposed Action are sediment, turbidity, temperature and dissolved oxygen (final EA p. 

234).

The standard for sediment states that sediment load and suspended sediment discharge rate of surface 

waters shall not be altered in such a manner as to cause nuisance or adversely affect beneficial uses. The 

standard for turbidity states, “turbidity shall not be increased more than 20 percent above naturally 

occurring background levels.” Relative to water temperature, the Basin Plan states that water temperature 

of receiving water bodies shall not be altered and at no time shall the temperature of any cold water be 

increased by more than 5°F. Similarly, dissolved oxygen concentrations shall not fall below 6.0 mg/l.

Stream temperature and dissolved oxygen would not be altered as a result of the Proposed Action. 

Extensive riparian reserve buffers and residual canopy cover at 60 percent in the outer 80 feet of 

mechanically treated units (147 acres total) would protect stream temperatures (final EA p. 222). Current 

dissolved oxygen concentrations are in the range of natural concentrations and would not be altered (final 

EA p. 234). Effort was made to reduce the risk of sedimentation and turbidity relative to the Proposed 

Action. The Basin Plan states that controllable water quality factors shall not cause further degradation of 

water quality when it has already been established as degraded, and efforts to restore the impaired 

beneficial uses of these watersheds must be made. The water quality analysis of this Proposed Action has 

focused on minimizing delivery of management-related sediment and improving the long-term sediment 

regime for the project area (final EA pp. 228, 230, 231, 233, 444).

Because the Proposed Action is spread across three 6th-field watersheds, and at most encompasses 

roughly 13 percent of the Reynolds-Klamath River watershed, it is very unlikely that enough vegetation 

would be removed to cause detectable changes in peak flows in the analysis area. For rain-dominated 

zones (below 2,500 feet in elevation in the project area), changes in peak flow can only be detected where 

29 percent of the area is harvested (Grant et al. 2008). For areas where rain-on-snow events can occur 
Finding of No Significant Impact

Final Environmental Assessment – 287

(above 2,500 feet in elevation in the project area), the detection level for peak flow increases is 19 

percent, including harvested acres and the area in roads. The magnitude of observed changes in peak 

flows from management activities diminished with increased watershed area (ibid) (final EA p. 221).

Wildland-urban interface

The reduction in fire hazards would enhance public safety for those living within the WUI, as the 

Proposed Action is designed to allowing for efficient wildfire containment and control (final EA pp. 16, 

19-20). Between 2006 and 2011, about 600 assessments were completed by the Forest Service on 

wildfires that burned into areas where hazardous fuels reduction treatments had previously been 

conducted (Stein et al. 2013). These assessments evaluated the effects of prescribed fire as well as 

mechanical and chemical treatments on fire behavior and fire suppression actions. The data indicate that 

90 percent of treatments reported in the database have helped to reduce wildfire intensity, allowing better 

control by firefighters. In most of these cases, as fires moved from untreated locations to areas treated by 

thinning, mowing, or prescribed burning, the fire behavior changed from active crown fires (burning an 

entire upper story of the forest) to passive crown fires (where only a single tree or small group of trees 

burned), or from passive crown fires to surface fires (burning only dry grass, shrubs, pine needles, and 

other flammable materials on the ground) (DellaSala and others 2004, Stein et al. 2013).

3. Unique characteristics of the geographic area such as the proximity to historical or cultural 

resources, parklands, prime farmlands, wetlands, wild and scenic rivers, or ecologically critical 

areas.

Katimiin Cultural Management Area

The Katimiin Cultural Management Area (CMA) lies within Rogers Creek and Donahue project areas, 

encompassing 2,306 acres within the project area. A memorandum of understanding (MOU; Karuk Tribe, 

SRNF and KNF 2017) provided a platform for both parties to collaboratively develop the Somes Bar 

Project to achieve mutually beneficial goals and objectives for land management, recognizing the 

indescribable importance to the Karuk people (final EA p. 6). The Proposed Action fulfills the intent of the 

MOU to work together to mutually coordinate planning and implementation efforts as partners, in and 

adjacent to the Katimiin CMA in a manner consistent with Karuk customs, culture and federal land 

management direction (final EA pp. 122, 156, 174).

Wetlands and Floodplains

No floodplains associated with Executive Order 11988 or wetlands per Executive Order 11990 exist 

within the project area. Therefore, the Proposed Action would constitute a “no effect” undertaking, as 

none exist or would be affected (final EA p. 287, 434).

Parklands and Prime Farmlands

There are no parklands or prime farmlands within or immediately adjacent to the project area. The Forest 

Service would notify and coordinate with a local grape grower to coordinate the timing of prescribed 

burning to mitigate smoke tainting of commercial grape products (final EA p. 80).
Finding of No Significant Impact

288 – Somes Bar Integrated Fire Management Project

Wild and Scenic Rivers

The Klamath River lies adjacent to the project areas, flowing north-south, designated a Recreational River 

within the National Wild and Scenic Rivers System in 1981; classified as a designated and recommended 

Recreational River (KNF LRMP 4-156). Three (3) designated segments have been identified for potential 

reclassification per the 1986 amendment to the Wild and Scenic River Act (WSRA). The closest segment 

is from Ti Bar to the mouth of the Salmon River. Portions of the designation overlap the project areas near 

the Klamath River. All Proposed Action activities are consistent with the KNF standards and guidelines 

(S&Gs) for Recreational River management (final EA p. 267). Most recreational activities are 

concentrated along the Klamath River or are associated with the Marble Mountain Wilderness to the east, 

outside the project area (final EA p. 288).

Northern Spotted Owl Critical Habitat

The California Coast Range (Klamath West) is considered a “fire prone” area because of its frequent fire 

return intervals and existing vegetation condition that likely elevates the potential of fire (USDI Fish and 

Wildlife Service 2012). Within fire-prone areas, resource agencies planning vegetation management in 

critical habitat for the northern spotted owl (NSO) are encouraged to ameliorate current threats of ongoing habitat loss from uncharacteristic fires and vegetation change that are largely related to past fire 

exclusion (USDI Fish and Wildlife Service 2012). The Somes Bar Project is designed collaboratively 

aimed at maintaining and enhancing the characteristics of older forest and providing large habitat blocks 

and associated interior forest conditions providing mosaics of interior habitats and edges to provide for 

the diversity of prey for NSO (final EA pp. 181, 184, 191, 194-195, 198).

Special Habitat KNF Management Area 5

This management area consists of special provisions for peregrine falcon, bald eagle and late successional 

reserves (LSR). The Klamath National Forest Land and Resource Management Plan (KNF LRMP)

includes a provision for the Special Habitat Management Area around peregrine falcon eyries. The 

Proposed Action proposes fuels reduction treatment that occurs within the Special Habitat area. However, 

no known peregrine falcon eyries are located within 0.5 miles of the project areas (final EA p. 174). 

Therefore, the proposed treatment is consistent with the management of this area and will not be analyzed 

further for this project.

Bald eagles were also delisted under the Endangered Species Act (ESA) but the eagle is included in 

the Forest Service Sensitive species list. Forest plan provisions for the Special Habitat Management Area 

around bald eagle nests would be followed. Effects of the Proposed Action on bald eagles are disclosed 

under discussions of Forest Service Sensitive species (final EA pp. 90, 174, 178, 199, 206).

Late-Successional Reserves (LSRs)

Approximately 49 acres of the Proposed Action is proposed for treatment within LSRs, specifically in LSR 

Ten Bear RC349 and 100-acre LSR KL0058. The KNF Forest-Wide LSR Assessment (LSRA 1999) 

determined that this area of the LSR was deficient in late-successional habitat. Portions of the LSR prior to 

its designation were harvested, therefore, extensive stands of dense plantations exist that not only create a 

fuels hazard, they also do not provide suitable habitat for late-successional species such as the NSO. 
Finding of No Significant Impact

Final Environmental Assessment – 289

Plantations and young natural stands are even-aged and lack the horizontal and vertical diversity 

components associated with late-mature stands. Young stands have the potential to achieve rapid diameter 

and height growth with thinning treatments. Silvicultural prescriptions can be applied to younger stands in 

order to accelerate their development toward late seral conditions. These treatments could increase the 

amount of late seral vegetation sooner than would occur naturally. The LSRA indicated the proposed area 

needs extensive fuels treatments to protect the LSR as well as extensive habitat restoration. Planned 

treatments outside but adjacent to the Ten Bear LSR would reduce fuel loading risk and provide additional 

protection to late-seral stands (final EA pp. 177-178).

4. Degree to which the effects on the quality of the human environment are likely to be highly 

controversial.

The term “controversial” in this context refers to cases where substantial scientific dispute exits as to the 

size, nature, or effects of a major federal action on some human environmental factor, rather than to public 

opposition of a proposed action. The Conservation Congress refers to a study conducted by fire ecologists at 

the Missoula Fire Lab indicating, “Even extensive fuel treatments may not reduce the amount of area burned 

over the long-term and furthermore, reduction of area burned may actually be an undesirable outcome.” The 

commenter shares a new study soon to be published based a review of 1,500 wildfires occurring between 

1984 and 2014, indicating actively managed forests had the highest level of fire severity.

The premise underlying the Proposed Action is to prepare land for the return of frequent, restorative 

lower intensity fire as the Karuk once did, so there would be less flammable vegetative fuels to burn when 

lightning or human-caused fires do strike. Unlike the aforementioned fuel treatment studies, the 

underlying premise of the purpose and need is if enough land is treated with prescribed fire more 

regularly as a tool to regulate vegetative growth and composition, the outcome would be a decrease in 

fuel concentrations and cultural natural resources would be revitalized (final EA pp. 15, 18, 38-42, 45, 

111-112, 126, 148). WKRP recognizes an individual action is not sufficient to alter fire behavior, 

particular those wind-driven events during under 90th percentile weather conditions (final EA p. 153).

However, there are numerous scientific publications supporting findings that, “Maintaining managed 

ecosystems within the bounds of the “historical range of variation” for key ecosystem patterns or 

processes has traditionally been seen as the best hope for preserving species and landscapes and ensuring 

long-term ecological sustainability” (Egan and Howell 2001, Landres et al. 1999; see Scoping Comment 

46). A management strategy that includes methods for increasing forest heterogeneity at multiple scales 

will improve habitat quality and landscape connectivity (North et al. 2009). Some studies and models 

suggest a crown fire entering a stand is rarely sustained (i.e., sustained only under extreme weather 

conditions), if understory fuels are too sparse to generate sufficient radiant and convective heat (Agee and 

Skinner 2005, Stephens and Moghaddas 2005). Various research supports this restorative type treatment, 

including putting forest and woodland landscapes on a path to successional patterns and disturbance 

dynamics that reflect the natural disturbance regimes of regional and local landscapes (Swetnam et al. 

1999, Keane et al. 2009, Wiens et al. 2012), and allow the future climate to adapt them. To place 
Finding of No Significant Impact

290 – Somes Bar Integrated Fire Management Project

landscapes on this path, pattern modifications across scales will be needed in areas where past 

management alterations are greatest (Hessburg et al. 2015).

5. Degree to which the possible effects on the human environment are highly uncertain or involve 

unique or unknown risks.

The Proposed Action applies low-intensity mechanical, manual and prescribed burning treatment methods. 

The treatment prescriptions and mitigation measures incorporated have been applied on numerous projects 

across the SRNF with predictable effects and outcomes.

Executive Order 12898, Environmental Justice

This federal order requires an assessment of whether there would be disproportionate effects to minority 

or low-income populations. Although there are minorities and low-income populations living in the North 

Coast California area, they would benefit from the proposal (final EA pp. 80-94).

Environmental Justice means that, to the greatest extent practicable and permitted by law, all 

populations are provided the opportunity to comment before decisions are rendered on, are allowed to 

share in the benefits of, are not excluded from, and are not affected in a disproportionately high and 

adverse manner, by government programs and activities affecting human health or the environment. There 

would be no discernable differences between the Proposed Action and No Action alternatives regarding 

effects on minorities or the Civil Rights of any American Citizen.

The Proposed Action does not have a disproportionately high and adverse human health effects, high 

or adverse environmental effects, substantial environmental hazard, or affects to differential patterns of 

consumption of natural resources. Extensive scoping did not reveal any issues or concerns associated with 

the principles of Environmental Justice. No mitigation measures to offset or ameliorate adverse effects to 

these populations have been identified (final EA p. 98-101).

Relationships between Local, Short-Term Uses of the Human Environment and Maintenance or 

Enhancement of Long-Term Productivity

Short-term uses are expected to change the human environment during mechanical, manual, prescribed 

burning and logging/hauling operations. Long-term effects should not appreciably change the human 

environment after final entry fuel reduction operations have concluded, as proposal treatment 

prescriptions are low-intensity, and planned for phased entries to minimize disturbance to nearby 

neighbors and natural resources (final EA p. 100).

The availability of natural resources contributes to the quality of life for many county residents. Many 

community members rely on natural resources for substance food gathering and jobs. These communities 

are directly influenced by forest-management job opportunities and supply of natural resources from 

forest ecosystems. Implementation of the Proposed Action would cause no unavoidable or other indirect 

social/economic adverse effects (final EA p. 99).

The Klamath Prescribed Fire Training Exchange (TREX) is an annual two-week training in the use of 

controlled burning in the Western Klamath Mountains to reduce the future danger of wildfires. The TREX 

event builds local capacity, while providing high quality training opportunities for local, state, private and 
Finding of No Significant Impact

Final Environmental Assessment – 291

federal fire professionals, students, and managers from around the country and from other countries. With 

combined funding and resources from tribal, local, and federal partners, the TREX events help bring in 

more participants to deliver good fire to a larger landscape. Every year, the Klamath TREX advances the 

training of firefighters from around the region, the nation and even the world to share best practices and 

knowledge about how to implement controlled burns. This training event blends traditional native burning 

with western science to restore fire processes directly around communities where it is needed most (final 

EA p. 131).

Each year there are approximately 50 training opportunities, with about 100 people participating. 

Approximately six (6) full-time-equivalent (FTE) jobs are created through the Klamath TREX annually. 

The implementation of the Somes Bar Project over a 15-year period would potentially increase paid 

training job opportunities equivalent up to 20 full-time positions. The burning activities would promote 

production of food and fiber resources for subsistence gatherers contributing to the local economy (final 

EA pp. 99, 281-282).

6. Degree to which the action may establish precedent for future actions with significant effects or 

represents a decision in principle about a future consideration.

Irreversible or Irretrievable Commitments of Resources

Irreversible commitment of resources refers to a loss of non-renewable resources, such as mineral 

extraction, heritage (cultural) resources, or to those factors, which are renewable only over long time 

spans, such as soil productivity. Under the No Action Alternative, there would be no irreversible or 

irretrievable commitment of resources.

Irretrievable commitment applies to losses that are temporary, such as use of renewable natural 

resources. The production lost would be irretrievable, but the action would not be irreversible. Vegetation 

removed as commodity byproducts under the Proposed Action, is considered an irretrievable impact. 

Forest conditions would return, as tree growth over one (1) or more decades would feature increased 

canopy closure and development of healthy, sustainable stand densities resilient to natural processes 

serving TEK focal and indicator species, ESA wildlife habitat, and human and cultural values (final EA 

pp. 26, 122, 175).

Adverse Environmental Effects that cannot be Avoided

The Proposed Action involves adverse environmental effects to soil resources that cannot be wholly 

avoided or mitigated. There would be measurable negative effects in specific areas (temporary roads, 

landings, some skid trails); however, these are not expected to be long term or extensive enough to be 

significant at unit-scale. The aerial extent of these impacts is expected to comply with applicable 

standards (less than 15 percent area), and thus impacts are not considered to constitute a “substantial and 

permanent impairment” of soil productivity with respect to National Forest Management Act of 1976

(NFMA) and Forest Service Region 5 Soil Quality Standards (R5 SQS). Project design features are 

developed in site-specific fashion and are intended to ensure compliance with the various elements of soil 
Finding of No Significant Impact

292 – Somes Bar Integrated Fire Management Project

management direction. Physical soil impacts would be limited in aerial extent, and thus are considered 

acceptable for this Proposed Action, in accordance with soil management direction.

Implementation of the Proposed Action would cause no other known unavoidable or other indirect 

adverse effects, other than the effects already stated (final EA pp. 67, 92-93, 230, 232, 242, 244, 246).

Energy Requirements of Alternatives

Under the Proposed Action, various amounts of fossil fuels, and human labor would be expended. Fossil 

fuel energy would not be retrievable. None of them are in short supply and their use would not have an 

adverse effect upon continued availability of these resources.

7. Whether the action is related to other actions with individually insignificant but cumulatively 

significant impacts. Significance exists if it is reasonable to anticipate a cumulatively significant 

impact on the environment. Significance cannot be avoided by terming an action temporary or by 

breaking it down into small component parts.

When considering past, present, and foreseeable future actions (e.g., mechanical and manual cutting, 

prescribed burning, etc.), both the No Action Alternative and the Proposed Action have the potential to 

increase the amount of ground-disturbing activities and prescribed fire across the landscape. Past and 

present projects that are in and around the current project footprint include the Roots and Shoots Cultural 

Burn (Roots and Shoots), Orleans Community Fuels Reduction (OCFR), and Katimiin Thin projects. The 

only known future project is the Six Rivers Aquatic Restoration Project (Aquatic Restoration Project), 

which is under development.

Cultural Resources

For the purposes of NHPA §106 analysis (outlined at 36 CFR 800), the area of potential effects (APE) of 

the project were identified as the external boundaries of our four (4) project areas at Ti Bar, Patterson, 

Rodgers Creek, and Donahue Flat. This APE also corresponds in NEPA terms to the area of direct effects. 

It is more productive to consider the APE of the project in NEPA terms as the area of direct effects. This 

is because NHPA §106 regulations are premised on the assumption that “potential effects to historic 

properties” are negative in nature, and need to be mitigated or avoided. This project aims at enhancing 

these areas. The final EA documents that there would be no significant impacts to cultural resources in the 

NEPA framework, and no adverse effects in the NHPA framework (final EA p. 121). Information 

regarding sensitive cultural resources and all locational data will be protected from public disclosure and 

will not be subject to FOIA. Relevant federal statutes include the 2008 Farm Bill, the FOIA identification 

of exemptions (5 USC §552 (b) (3)), and NHPA confidentiality (16 USC §470 hh) (final EA p. 122).

Mitigation measures have been or would be implemented to keep ground-disturbing activities out of 

cultural resource site boundaries. Fuels reduction pre-treatments have been or would be implemented to 

minimize fire effects on archaeological sites and traditional cultural properties during prescribed burns

(final EA pp. 81-82). As such, the potential cumulative effects on cultural resources and TCPs are not 

considered adverse. In fact, on-going and future collaborative-based ecological restoration projects would

benefit the cultural resources across the larger landscape (final EA p. 130-131).
Finding of No Significant Impact

Final Environmental Assessment – 293

Fire and Fuels

In consideration of additional projects within the project area boundaries, as well as those just outside of the 

project boundaries, this project is a direct compliment to other efforts. There is a recognition that fire danger 

exists well beyond the project boundaries (as well as on private inholdings) and providing for a connectivity 

of fuels reduction treatments aims to address that issue (final EA pp. 32-35). Working across jurisdictional 

boundaries achieves the greater goal of the WKRP as well as aiming to achieve goals within the Cohesive 

Strategy (final EA p. 155).

By initially developing strategic fire control features of private property thinning, ridgeline fuelbreak

construction and careful assessment of high fuel loading condition, we should be able to return fire 

successfully to the project areas. Once first-entry treatments of fire have occurred, second and third entry 

treatments may occur at larger scales due to previous reductions in fuel loading and decreased tree 

densities as well as the multiple established control line placement (final EA pp. 38-39, 131, 153).

Soils

The Proposed Action involves adverse environmental effects to soil resources that cannot be wholly 

avoided or mitigated. There would be measurable negative effects in specific areas (new temporary roads, 

landings, some skid trails); however, these are not expected to be long term or extensive enough to be 

significant at unit-scale. The aerial extent of these impacts is expected to comply with applicable 

standards (less than 15 percent area), and thus impacts are not considered to constitute a “substantial and 

permanent impairment” of soil productivity with respect to NFMA and R5 SQS. Project design features 

are developed in site-specific fashion and are intended to ensure compliance with the various elements of 

soil management direction. Physical soil impacts would be limited in aerial extent, and thus are 

considered acceptable for this Proposed Action, in accordance with soil management direction (final EA 

p. 246).

Invasive Plants

The proposed actions have the potential to increase the risk of invasive plant introduction and spread. 

Actions that increase the risk include; the use of heavy equipment and staging equipment at sites with 

invasive plants, reducing canopy cover proximal to occurrences of invasive plants, creation of landings 

and use of existing landings where invasive plants are already exist, prescribed burning that removes 

native vegetation (i.e., forbs, shrubs, small trees) which provides competition and functions as a barrier to 

movement of invasive plants. There are settings within the project areas specifically associated with State

Highway 96 and the Klamath River, as well as along the lower stretches of access roads closest to State 

Highway 96, that are already very compromised in terms of invasive plant cover and the array of species 

present. Without aggressive actions, such as the use of herbicides, the proposed actions in these settings 

are not likely to change the current condition and the risk of spread is considered high, even if no actions 

were proposed in these areas.

The Proposed Action incorporates prescriptions and design features to reduce the introduction and 

spread of invasive plant species from a high risk to low risk, where occurrences are small and discrete; and 

moderate risk, where occurrences are modest in size or located in riparian areas. Examples of risk reduction 
Finding of No Significant Impact

294 – Somes Bar Integrated Fire Management Project

actions include; establishing a progression of work for implementation that treats areas not infested with 

invasive plants prior to moving to infested areas, equipment cleaning, use of weed-free rock material and 

erosion control material, clearing invasive plants from landings prior to use, and targeted removal of isolated 

plants. Implementation of these prescriptions and design features, along with effectiveness monitoring will 

reduce the risk of introduction and spread of invasive plant species in the project areas (final EA pp. 262-

263).

8. Degree to which the action may adversely affect districts, sites, highways, structures, or objects 

listed in or eligible for listing in the National Register of Historic Places or may cause loss or 

destruction of significant scientific, cultural, or historical resources.

The primary intent of the Somes Bar Project is to benefit cultural resources. Fuels reduction treatments 

and the reintroduction of cultural burning would in fact improve the state of certain sites, objects, features 

or properties. It is important to consider traditional principles, practices, use factors, and associated 

wildlife habitats that link the action to the spiritual, living environment, and human responsibility through 

respect and reciprocity, especially concerning food, fiber, medicinal and regalia species. The proposed 

activities in the Somes Bar Project include prescribed burning, hand thinning with chainsaws, 

mastication, and several types of ground-disturbing activities, such as ground and cable-based tree 

harvesting. These activities have the potential to affect cultural resources, including historic properties, 

archaeological sites, traditional cultural properties (TCPs), sacred sites, and traditional use areas. 

However, with the application of PDFs and standard protection measures, it is anticipated that none of the 

proposed activities would adversely affect cultural resources. The cultural resource surveys have been 

designed in such a way as to assess current conditions in the area of potential effect (APE) to design 

management prescriptions that would lead towards a desired future condition more considerate of 

perpetuation of living Karuk culture (final EA p. 124-125).

In taking the approach of TEK integration and in considering that we are preserving a living culture 

while enabling expansion of fire adapted community concepts. The management practices achieved in the 

currently proposed Somes Bar Project would lead to the introduction of fire, and would start the process 

of landscape recovery from years of neglect, fire exclusion, road building, use of chemical/biological 

agents and logging practices. The reintroduction of management by fire may have indirect beneficial 

effects over a much wider area than the direct APE covered by this analysis. Since the Proposed Action

takes a holistic landscape approach and employs five (5) focal species that together cover the main 

landscape components, it is appropriate to realize that we may have indirect beneficial effects in the 

context of the entire WKRP planning area and beyond. These actions have the potential to enhance the 

focal species and integrate other TEK considerations across that whole area as well as in building 

relationships with additional tribal groups. Indirect effects beyond the scope of the WKRP effort are also 

underway as many people at regional, national, and international scales are expressing interest in the 

processes and considerations being established and undertaken in this demonstration project. A key 

indirect effect of this Proposed Action is the potential for enabling the restoration of important ceremonial 

burning practices on Offield Mountain. By treating large areas around residential structures, and building 
Finding of No Significant Impact

Final Environmental Assessment – 295

social license for increasing the scope and scale of fire use, ceremonial burning can be restored, as well as 

managed wildfire decisions enabled on adjacent landscapes. The Somes Bar Project has been 

implemented in accordance with the requirements of National Environmental Policy Act (NEPA) and 

National Historic Preservation Act (NHPA) §106. The implementation of this Proposed Action would 

avoid and improve cultural resources in TCPs (final EA p. 126-131).

9. Degree to which the action may adversely affect an endangered or threatened species or its habitat 

that has been determined to be critical under the Endangered Species Act of 1973.

The Endangered Species Act (ESA) of 1973 (16 USC 1531 et seq.) requires any action authorized by a 

federal agency to not jeopardize the continued existence of a threatened or endangered species, or result 

in the destruction or adverse modification of the critical habitat of such species. Section 7 of the ESA, as 

amended, requires the responsible federal agency to consult with the US Fish and Wildlife Service 

(USFWS) and the National Marine Fisheries Service (NMFS) concerning endangered and threatened 

species under their jurisdiction as follows:

Wildlife

The draft wildlife BA for the Somes Bar Project (Bettaso and Yost 2017/2018) contains a detailed 

analysis of effects and determinations on the following ESA listed species. No gray wolf den or 

rendezvous sites are known to occur within the project area. No critical habitat has been designated for 

the gray wolf. The nearest known den or rendezvous site is located greater than 70 miles from the project 

area. Therefore it was determined the Proposed Action would have “no effect” on this species (wildlife 

final BA p. 4). Surveys were conducted for the marbled murrelet with no detections. In addition, the 

project is not located within marbled murrelet critical habitat. Therefore, the Proposed Action would have 

“no effect” on marbled murrelet or its Critical habitat (wildlife final BA p. 3).

During discussions with the Level 1 team, draft data presented to the USFWS has resulted in a 

tentative agreement on the determination of “may affect, not likely to adversely affect” NSO and its 

critical habitat due to the removal of 3.4 acres of low- to moderate-quality nesting/roosting habitat and 

removal of 7.5 acres of foraging habitat during construction of temporary roads and new landings. 

Temporary roads and landings would remove scattered pockets of nesting, roosting and foraging habitat 

typically less than 0.25 acres in size of suitable NSO habitat (wildlife final BA p. 69) . No commercial 

treatment would occur within 70-plus-acre nest groves or high-quality nesting/roosting habitat (wildlife 

final BA p. 73). All current NSO habitat function would be maintained in the remaining treated areas and 

ample alternative (non-treated) habitat exists in all areas. In the long term, this Proposed Action is 

expected to have beneficial effects through restoration and protection of higher quality habitats. The 

Proposed Action is consistent with the 2011 NSO Recovery Plan. Limited operating periods (LOPs) 

would be imposed to prevent noise and smoke disturbance during the peak breeding season.

The Somes Bar Project “may affect but is not likely to adversely affect” Critical habitat for the northern 

spotted owl due to removal and modification of primary constituent elements, although current functionality 

of the primary constituent elements would be maintained in the proposed treatment units. Temporary roads 
Finding of No Significant Impact

296 – Somes Bar Integrated Fire Management Project

and landings would remove scattered pockets of nesting, roosting and foraging habitat. In the long term, this 

Proposed Action is expected to have a beneficial effect on Critical habitat through restoration and protection 

of higher quality habitats. The Proposed Action is consistent with the 2012 NSO Critical Habitat Rule

(wildlife final BA pp. 82-83, final EA p. 206).

Botany

There are no occurrences of the federally listed endangered species within the project area (botany final 

BE/BA p.3). Hence, there would be no effects (direct or indirect) from the Proposed Action to this 

species. Under §7 of the ESA, consultation with the USFWS is not required for no effect determinations.

Fisheries

A Fish BA/BE (biological evaluation) for the Somes Bar Project (Cyr 2017) contains a detailed analysis 

of effects and determinations on the following ESA-listed species, Essential Fish Habitat, and Sensitive 

species. The Fish BA/BE analysis resulted in a Level 1 agreement on the determination of “may affect, 

not likely to adversely affect” coho salmon and its critical habitat due to a negligible potential for 

sediment to reach occupied habitat through a combination of all actions. More importantly, the Fish 

BA/BE documenting the Proposed Action, would result in key recovery actions being implemented on 

5,570 acres of the Mid-Klamath population of coho salmon to reduce the risk of high-severity fire.

10. Whether the action threatens a violation of federal, state, or local law or requirements imposed for 

the protection of the environment.

Aquatic Conservation Strategy

The Somes Bar Project was developed in alignment with the Aquatic Conservation Strategy (ACS)

reflected in the Record of Decision (ROD), and S&Gs of the Northwest Forest Plan (NWFP; USDA and 

USDI 1994) as incorporated into the Six Rivers National Forest (SRNF) LRMP (USDA Forest Service 

1995) and the KNF LRMP (USDA Forest Service 2010). The ACS outlines specific objectives regarding 

the forest goals in the management of aquatic and riparian resources (KNF 4-25and SRNF IV-107). 

Project NEPA decisions must be consistent with the wording regarding ACS consistency, including 

consistency with the nine (9) ACS objectives, as ACS consistency is described in the 1994 NWFP ROD 

on page B-10 and in the May 22, 2007 Memorandum.

Project implementation does not prevent attainment of ACS objectives at the HUC 6th and larger 

scales in the short-term, and promotes attainment of ACS objectives in the long-term. Fuel treatments are 

in accord with recommendations in the Ishi Pishi Ecosystem Analysis (1998). Cumulative watershed 

effects (CWE) would remain below threshold for adverse watershed effects. Minimal disturbances are not 

expected to adversely affect anadromous fish and habitat because PDFs would contain effects to the 

project site and the effects are negligible in the action area. The Proposed Action would maintain and help 

restore many of the Indicators of the HUC 6 sub-watersheds in the short term and are expected to improve 

aquatic habitats and watershed conditions for fish populations in the Kennedy-Ti Creek and IrvingReynolds Creek composite sub-watersheds, and in the lower mid-Klamath River in the long term (final 

EA pp. 227, 444).
Finding of No Significant Impact

Final Environmental Assessment – 297

Forest Service Sensitive Wildlife Species

Analysis of Proposed Action impacts to Forest Service Sensitive species is required by FSM 2670 

through the preparation of a BE. All Forest Service Sensitive wildlife species known or thought to occur 

in the project area (based on habitat and range), were evaluated for this Proposed Action. It was 

determined that the Proposed Action would have no impact on certain Forest Service Sensitive species, 

based on either the lack of habitat, lack of detections during surveys, or the fact that habitat would not be 

impacted. In addition, surveys and limited operating periods (LOPs) could be used as a mitigation to 

reduce the risk that the Proposed Action would impair a species reproduction (wildlife final BA p.80, 

final EA pp. 199-206).

Species that would not be affected by this Proposed Action include greater sandhill crane, great gray 

owl, Siskiyou Mountains salamander, cascade frog, northern red-legged frog, Tehama chaparral snail and 

mardon skipper (final EA p.198).

The Somes Bar Project may impact individuals, but is not likely to result in a trend towards federal 

listing for the following Forest Service sensitive species and/or habitat: bald eagle, northern goshawk, 

fisher, marten, wolverine, pallid bat, Townsend’s big-eared bat, fringed myotis, willow flycatcher, western 

bumblebee, foothill yellow-legged frog, southern torrent salamander, and western pond turtle. The BE

prepared for this Proposed Action contains the affected environment for each species, description of 

indicators to base effects on as well as the assumptions upon which the analysis was done (wildlife final 

BE pp. 82-83, final EA pp. 178-179).

Forest Service Sensitive Botanical Species

Sensitive species are those for which there is a concern for viability of the species based upon population 

trends or loss of habitat that would reduce the species existing distribution (USDA Forest Service 2005, 

FSM 2670.5). The Proposed Action was designed to not lead toward a loss of viability or a trend toward 

federal listing in compliance with KNF and SRNF forests plans direction; disclosed in the BE (Hoover 

2017a). For Thermopsis robusta, implementation of the Proposed Action with the PDFs is not expected to 

have any negative direct or indirect effects to this species. For the other species considered, prescriptions 

that provide for retention of mature forest and their structure (i.e., partial canopy, coarse woody debris 

(CWD), pre-dominant trees, forest floor vegetation mosaics) coupled with PDFs associated with recent 

past, present and future projects are intended to reduce the possibility of direct effects to Sensitive species 

and mitigate significant indirect effects. In light of the inherent uncertainties about some Sensitive 

species, such as the extent of the underground network of fungal mycelia of Phaeocollybia olivaceae, the 

distribution of Sulcaria badia in the forest canopy, and the dormancy and dispersal of Cypripedium 

fasciculatum, the Proposed Action may affect individuals of a given sub-population but is not likely to 

result in a trend toward Federal listing or loss of viability for these species (botany final BE p. 20).

Forest Service Sensitive Aquatic Species

A BE was prepared for the Forest Service aquatic sensitive species that are located in the analysis area 

(see Region 5 list by Forest dated July 2015; Cyr 2018). The analysis resulted in a “may impact 

individuals but would not lead to a trend towards federal listing” for Upper Klamath Trinity River 
Finding of No Significant Impact

298 – Somes Bar Integrated Fire Management Project

Chinook salmon, Klamath Mountain Province steelhead trout, as well as, Pacific and Klamath River 

lampreys. The slight risk of an insignificant amount of sediment reaching these species habitat is far 

outweighed by reducing the risk of high severity wildfire and the potential impacts that would bring. The 

Proposed Action would have no effect on western brook lamprey, California floater, pristine springsnail, 

and chace juga, as they are not located within the project boundaries (final EA p. 235).

Magnuson-Stevens Fishery Conservation and Management Act

The Magnuson-Stevens Fishery Conservation and Management Act (MSA), as amended by the 

Sustainable Fisheries Act of 1996 (PL 104-267), requires federal agencies to consult with NOAA 

Fisheries on all actions and proposed actions authorized, funded or undertaken by the agency that may 

adversely affect essential fish habitat (EFH). All EFH assessments must include 1) a description of the 

Proposed Action; 2) an analysis of the effects, including cumulative effects of the Proposed Action on 

EFH, the managed species and associated species, including life history stages potentially affected; 3) the 

federal agency’s views regarding the effects of the action on the EFH; and 4) proposed mitigation, where 

applicable (50 CFR 600.920(g)(2)). The information prepared under a BA for formal or informal 

consultation under the ESA (50 CFR 402.12) may serve as the EFH assessment curtailing the need for 

separate analysis. The effects to EFH related to the Proposed Action were analyzed using habitat data 

derived from available historical fish species inventories and habitat assessments on record at the 

Orleans/Ukonom RD. The Proposed Action would have no effect on Chinook or coho salmon EFH (final 

EA p. 235).
Chapter 4. Consultation and Coordination

Final Environmental Assessment – 299

Chapter 4. Consultation and Coordination

The Forest Service consulted the individuals, federal, state and local agencies, tribal governments and 

non-Forest Service individuals during the development of this environmental assessment. Appendix A

contains additional information on the collaborative efforts in the project development.

Table 4-1. Environmental assessment interdisciplinary team (IDT) members.

Interdisciplinary Team Members Affiliation

Merv George Jr. Forest Supervisor, Six Rivers National Forest

Nolan C Colegrove Sr. Project Leader/District Ranger, Six Rivers National Forest

Carol Spinos Environmental Planner, Six Rivers National Forest

Corrine Black Interdisciplinary Team Leader/Hydrologist, Six Rivers National Forest

Jill Beckmann GIS Specialist/Data Steward, Karuk Tribe

Roberto Beltran Supervisory Forester, Six Rivers National Forest

James Bettaso Wildlife Biologist, Six Rivers National Forest

Natalie Cabrera Geologist/Hydrologist, Six Rivers National Forest

LeRoy Cyr Fisheries Biologist, Six Rivers National Forest

Jennifer Dyer Heritage Program Manager, Six Rivers National Forest

Lisa Hoover Forest Botanist, Six Rivers National Forest

Kenny Sauve GIS Technician II , Karuk Tribe

Andrew Spain Fuels Planner, Six Rivers National Forest

Bill Tripp Deputy Director Eco-Cultural Revitalization, Karuk Tribe

Alex Watts-Tobin Tribal Heritage Protection Officer, Karuk Tribe

Kurt Werner Engineering Technician, Six Rivers National Forest

Bryan Yost Forest Wildlife Biologist/Level 1 Consultation, Six Rivers National Forest

Dave Young Northern CA Zone Soils Scientist, Pacific Southwest Region

Table 4-2. Environmental assessment contributors.

Contributors Affiliation

Kimberly Baker Klamath Forest Alliance, Environmental Protection Information Center

Brandy Clark Archaeologist – Pathways Intern, Six Rivers National Forest

Max Creasy Ecologist (Retired), Klamath National Forest

Earl Crosby Deputy Director Watershed Restoration, Karuk Tribe

Brenda Devlin Wildlife Biologist, Six Rivers National Forest

Eamon Engber Interagency Fire Ecology, Redwood National Park and Six Rivers National Forest

Karuna Greenburg Restoration Director, Salmon River Restoration Council

Scott Haggerty Soils Scientist (Retired), Six Rivers National Forest

Will Harling Director, Mid Klamath Watershed Council

Leaf Hillman Director, Department of Natural Resources, Karuk Tribe

Lisa Hillman Department of Natural Resources, Karuk Tribe

John Hunter US Fish and Wildlife, Arcata Field Office

Jeff Jones Forest Silviculturist, Six Rivers National Forest

Karen Kenfield Fisheries Level 1 Consultation/Editor, Six Rivers National Forest

Frank Lake Research Ecologist, PSW Research Station

Kristen Lark Forester, Six Rivers National Forest
Chapter 4. Consultation and Coordination

300 – Somes Bar Integrated Fire Management Project

Contributors Affiliation

Luna Latimer Director, Mid Klamath Watershed Council

Fred Levitan Geologist, Six Rivers National Forest

Bridget Litten Public Affairs Officer and Editor, Six Rivers National Forest

Cassandra Marszal Wildlife Biologist, Six Rivers National Forest

Cathy Meinart Happy Camp Fire Safe Council, Happy Camp, CA

Jeni Peterson GIS, Six Rivers National Forest

Vicki Prescott Cultural Specialist, Karuk Tribe

Carol Sharp Happy Camp Fire Safe Council, Happy Camp, CA 

Zack Taylor Fuels Specialist, Six Rivers National Forest

Brendan Twieg Ecologist/Data Analyst, Mid Klamath Watershed Council

Leslie Wolff National Marine Fisheries Service, Arcata Field Office

Federal and State Agencies Consulted

• USDI Fish and Wildlife Service

• USDOC National Marine Fisheries Service

• California Regional Water Quality Control Board

• State Historic Preservation Office

Tribal Governments

• Karuk Tribe
References

Final Environmental Assessment – 301

References

Reports Prepared for Somes Bar Integrated Fire Management Project.

Bettaso, J. 2017. Somes Bar Migratory Birds. On file at Six Rivers National Forest, Eureka, CA.

Bettaso, J., B. Yost and L.D. Hoover. 2017. Survey and Manage Species Analysis Somes Bar Integrated 

Fire Management Project/Western Klamath Restoration Partnership (WKRP), Orleans and Ukonom 

Ranger Districts, Six Rivers National Forest, December 4, 2017. On file Six Rivers National Forest, 

Eureka, CA.

Cabrera, N. 2017. Somes Bar Integrated Fire Management Project Geology Report. December 27, 2017. 

On file Six Rivers National Forest, Eureka, CA.

Cyr, L. 2018. Fisheries Biological Assessment and Evaluation for TES Species, Somes Bar Integrated 

Fire Project. On file Six Rivers National Forest, Eureka, CA.

Hoover, L.D. 2017a. Biological Assessment/Biological Evaluation for Threatened, Endangered, Sensitive 

Plant and Fungi Species. Somes Bar Integrated Fuels Management Project, Orleans/Ukonom Ranger 

Districts, Six Rivers National Forest, September 12, 2017. On file Six Rivers National Forest.

Hoover, L.D. 2017b. Invasive Plant Risk Assessment and Project Design Features. Somes Bar Integrated

Fire Management Projects. Orleans/Ukonom Ranger Districts. Six Rivers National Forest. December 

12, 2017.

Yost, B. and J. Bettaso. 2018. Somes Bar Biological Assessment for Wildlife Species – TEP. On file Six 

Rivers National Forest, Eureka, CA.

Yost, B. and J. Bettaso. 2017a. Somes Bar Biological Evaluation for Wildlife Sensitive Species. On file 

Six Rivers National Forest, Eureka, CA.

Yost, B. and J. Bettaso. 2017b. Management Indicator Species Report. On file Six Rivers National Forest,

Eureka, CA.

Young, D. 2017. Soils Specialist Report for Somes Bar. Somes Bar Integrated Fire Management Project. 

Six Rivers and Klamath National Forests. Orleans/Ukonom Ranger Districts. On file Six Rivers 

National Forest, Eureka, CA. Draft December 7, 2017.

Literature Cited

Adams, S. and J. Sawyer. 1980. Past fire incidence in mixed evergreen forests of northwest California. 

Report on file Six Rivers National Forest. 22pp.

Agee, J.K. 1993. Fire Ecology of Pacific Northwest Forest, Island Press, Washington, DC.

Agee, J.K. and C.N. Skinner. 2005. Basic principles of forest fuel reduction treatments. For. Ecol. Manag. 

211, 83-96. https://doi.org/10.1016/j.foreco.2005.01.034.
References

302 – Somes Bar Integrated Fire Management Project

Agee, J.K. 1998. The landscape ecology of western forest fire regimes. Northwest Science, 72:24.

Amaranthus, M.P. and D.A. Perry. 1994. The functioning of ectomycorrhizal fungi in the field: linkages in 

space and time. Plant and soil 159: 133-140.

Anderson, M.K. 2005. Tending the Wild: Native American Knowledge and the Management of 

California's Natural Resources. University of California Press.

Anderson, M.K. 2006. The use of fire by Native Americans in California. Fire in California’s ecosystems. 

University of California Press, Berkeley, CA, pp. 417-430.

Anderson, M.K. and M.G. Barbour. 2003. Simulated indigenous management: a new model for ecological 

restoration in national parks. Ecological Restoration, 21(4):269-277.

Angwin, P. September 25, 2007. Internal FS memo, File Code 3420 Biological Evaluation of Orleans 

Community Fire Reduction Thinning Project (FHP Report No N07-09).

Arbogast, B.S., K.I. Schumacher, N.J. Kerhoulas, A.L. Bidlack, J.A. Cook and G.J. Kenagy. 2017. 

Genetic data reveal a cryptic species of New World flying squirrel: Glaucomys oregonensis. Journal 

of Mammalogy 1-15.

Arkle, R.S. and D.S. Pilliod. 2010. Prescribed fires as ecological surrogates for wildfires: a stream and 

riparian perspective. Forest Ecology and Management, 259(5):893-903.

Atwilla, P.M. 1994. The disturbance of forest ecosystems: The ecological basis for conservation 

management. Forest Ecology and Management 63:2-3:247-300. Abstract.

Barrows, C. 1980. Feeding ecology of the spotted owl in California. Raptor Research 14:73-78.

Bart, J. 1995. Amount of suitable habitat and viability of northern spotted owls. Conservation Biology, 

9(4):943-946.

Benda, L., D. Miller, J. Sias, D. Martin, R. Bilby, C. Veldhuisen and T. Dunne. 2003a. Wood recruitment 

processes and wood budgeting. In: Gregory, S.V.; K.L. Boyer and A.M. Gurnell, A.M. eds. The 

ecology and management of wood in world rivers. Symposium 37. Bethesda, MD: American 

Fisheries Society: 49-73.

Bennett, M. 2007. Managing Himalayan blackberries in southwest Oregon riparian areas. Oregon State 

University. http://extension.oregonstate.edu/catalog/.

Berkes, F., C. Folke and M. Gadgil. 1995. Traditional ecological knowledge, biodiversity, resilience and 

sustainability. In Biodiversity conservation. Springer, Dordrecht. pp. 281-299.

Betts, M. G., J.C. Hagar, J.W. Rivers, J.D. Alexander, K. McGarigal and B.C. McComb. 2010. Thresholds 

in forest birds occurrence as a function of the amount of early-seral broadleaf forest at landscape 

scales. Ecological Applications.

Brauer, Roger L. 1990. Safety and Health for Engineers. Van Nostrand Reinhold, NY, p. 337.
References

Final Environmental Assessment – 303

Brooks, M.L., C.M. D’Antonio, D.M. Richardson, J.B. Grace, J.E. Keeley, J.M. DiTomaso, R.J. Hobbs, 

M. Pellant and D. Pyke. 2004. Effects of invasive alien plants on fire regimes. BioScience, 

54(7):677-688.

Brown, J.K. and J.K. Smith. 2000. Wildland fire in ecosystems: effects of fire on flora. Gen. Tech. Rep. 

RMRS-GTR-42-vol. 2. Ogden, UT: USDA Forest Service, Rocky Mountain Research Station, p. 42.

Busse, M.D., G.O. Fiddler and C.J. Shestak. 2017. Conifer root proliferation after 20 years of soil 

compaction. Forest Science 63(2):147-150.

California State Water Resources Control Board. 2010. Action Plan for the Klamath River Total 

Maximum Daily Loads Addressing Temperature, Dissolved Oxygen, Nutrient, and Microcystin 

Impairments in the Klamath River in California and Lost River Implementation Plan.

Caplan, J.S. and J.A. Yeakley. 2006. Rubus armeniacus (Himalayan blackberry) occurrence and growth in 

relation to soil and light conditions in Western Oregon. Northwest Science 80(1), 17pp.

Caprio, A.C. and D.M. Graber. 2000. Returning fire to the mountains: Can we successfully restore the 

ecological role of pre-Euro-American fire regimes to the Sierra Nevada? In: Cole, D.N., S.F. 

McCool, W.T. Borrie, J. O’Loughlin eds. Wilderness science in a time of change: Wilderness 

ecosystems, threats, and management. Conference proceedings RMRS-P-15-VOL-5. Ogden, UT: 

USDA Forest Service, Rocky Mountain Research Station, pp. 233-241.

Carey, A.B. 1995. Sciurids in Pacific Northwest Managed and Old-Growth Forests. Ecological 

Applications 5(3):648-661.

Carey, A.B., S.P. Horton and B.L. Biswell. 1992. Northern spotted owls: influence of prey base and 

landscape character. Ecological Monographs 62(2):223-250.

Carroll, C., W. Zielinski and R. Noss. 1999. Using presence–absence data to build and test spatial habitat 

models for the fisher in the Klamath Region, Conservation Biology 13:1344-1359.

Christen, D. and G. Matlack. 2006. The role of roadsides in plant invasions: a demographic approach. 

Conservation Biology 20(2)385-391.

Churchill, D.J., A.J. Larson, M.C. Dahlgreen, J.F. Franklin, P.F. Hessburg and J.A. Lutz. 2013. Restoring 

forest resilience: From reference spatial patterns to silvicultural prescriptions and monitoring. For. 

Ecol. Manag. 291:442-457. https://doi.org/10.1016/j.foreco.2012.11.007.

Cocking, M.I., J.M. Varner and R.L. Sherriff. 2012. California black oak responses to fire severity and 

native conifer encroachment in the Klamath Mountains. For. Ecol. Manag. 270:25-34. 

https://doi.org/10.1016/j.foreco.2011.12.039.

Cohen, J.D. 2000. What is the wildland fire threat to homes? School of Forestry, Northern Arizona 

University.

Community Wildfire Protection Plan. 2012. Orleans, Somes Bar Fire Safe Council.
References

304 – Somes Bar Integrated Fire Management Project

Condeso, T.E. and R.K. Meentemeyer. 2007. Effects of landscape heterogeneity on the emerging forest 

disease sudden oak death. J. Ecol. 95:364-375.

Crawford, J.N. 2012. Evidence for Native American land-use impacts on forest structure and fire regimes 

in the Lower Klamath River Region of California. Ph. D. Dissertation, University of Nevada, Reno, 

Department of Geography, May 2012. pp. 142-151.

Crawford, J.N., S.A. Mensing, F.K. Lake and S.R. Zimmerman. 2015. Late Holocene fire and vegetation 

reconstruction from the western Klamath Mountains, California, USA: A multi-disciplinary approach 

for examining potential human land-use impacts. The Holocene 25:1341-1357.

Davis, R.J. 2015. Northwest Forest Plan (NWFP) Interagency Regional Monitoring, 20-year report Status 

and Trends of Northern Spotted Owl Habitat. Raymond Davis, module lead, May 13, 2015.

Davis, R.J., B. Hollen, J. Hobson, J. Gower and D. Keenum. 2015. Northwest Forest Plan – The First 20 

years (1994-2013): Status and Trends of Northern Spotted Owl Habitats.

DellaSala, D.A., J.E. Williams, C.D. Williams and J.F. Franklin. 2004. Beyond smoke and mirrors: a 

synthesis of fire policy and science. Conservation Biology 18:976-986.

Der Lippe, M.V and I. Kowarik. 2007. Long-distance dispersal of plants by vehicles as a driver of plant 

invasions. Conservation Biology 21(4):986-996.

Devine, W.D. and C.A. Harrington. 2006. Changes in Oregon white oak (Quercus garryana Dougl. ex 

Hook.) following release from overtopping conifers. Trees 20:747-756. 

https://doi.org/10.1007/s00468-006-0089-8.

Diller, L.V. and R.L. Wallace. 1996. Distribution and habitat of Rhyacotriton variegatus in managed, 

young growth forest in north coastal California. Journal of Herpetology 30(2):184-191.

Drapeau, P., A. Leduc, J.F. Giroux, J.P. Savard, Y. Bergeron and W.L. Vickery. 2000. Landscape-scale 

disturbances and changes in bird communities of boreal mixed-wood forests.

Dugger, K.M., E.D. Forsman, A.B. Franklin, R.J. Davis, G.C. White, C.J. Schwarz, K.P. Burnham, J.D. 

Nichols, J.E. Hines, C.B. Yackulic, P.F. Doherty Jr., L. Bailey, D.A. Clark, S.H. Ackers, L.S. 

Andrews, B. Augustine, B.L. Biswell, J. Blakesley, P.C. Carlson, M.J. Clement, L.V. Diller, E.M. 

Glenn, A. Green, S.A. Gremel, D.R. Herter, J.M. Higley, J. Hobson, R.B. Horn, K.P. Huyvaert, C. 

McCafferty, T. McDonald, K. McDonnell, G.S. Olson, J.A. Reid, J. Rockweit, V. Ruiz, J. Saenz and 

S.G. Sovern. 2016. The effects of habitat, climate, and barred owls on long-term demography of 

northern spotted owls. Condor 18:57-116.

Dugger, K.M., F. Wagner, R.G. Anthony and G.S. Olson. 2005. The relationship between habitat 

characteristics and demographic performance of northern spotted owls in southern Oregon. The 

Condor, 107(4):863-878.
References

Final Environmental Assessment – 305

Dugger, K.M., R.G. Anthony and L.S. Andrews. 2011. Transient dynamics of invasive competition: 

Barred Owls, Spotted Owls, habitat, and the demons of competition present. Ecological Applications, 

21(7):2459-2468.

Dwire, K.A, K.E. Meyer, G. Riegel and T. Burton. 2016. Riparian fuel treatments in the western USA: 

Challenges and considerations. Gen. Tech. Rep. RMRS-GTR-352. Fort Collins, CO: USDA, Forest 

Service, Rochy Mountain Research Station. 156pp.

Ebert, B. 2015. Westside Fire Recovery Project: Fire and Fuels Resource Report. USDA Forest Service, 

Klamath National Forest, Yreka, CA.

Egan, D. and E.A. Howell. eds. 2001. The historical ecology handbook: a restorationist’s guide to 

reference ecosystems. Washington, DC: Island Press. 488pp.

Emeko, M.B., M. Stone, U. Silins, D. Allin, A.L. Collins, C.H.S. Williams, A.M. Martens and K.D. 

Bladon. 2016. Sediment-phosphorus dynamics can shift aquatic ecology and cause downstream 

legacy effects after wildfire in large river systems. Global Change Biology 22:1168-1184.

Engber E.A., J.M. Varner III, L.A. Arguello and N.G. Sugihara. 2011. The effects of conifer 

encroachment and overstory structure on fuels and fire in an oak woodland landscape. Fire Ecology 

7:32-50.

Estes, B.L., E.E. Knapp, C.N. Skinner, J.D. Miller and H.K. Preisler. 2017. Factors influencing fire 

severity under moderate burning conditions in the Klamath Mountains, Northern California, 

Ecosphere 8(5).

Fettig, C., R. Borys and C. Dabney. 2010. Effects of fire and fire surrogate treatments on bark beetlecaused tree mortality in the Southern Cascades, California. For. Sci. 56:60-73.

Fettig, C.J., K.D. Klepzig, R.F. Billings, A.S. Munson, T.E. Nebeker, J.F. Negrón and J.T. Nowak. 2007. 

The effectiveness of vegetation management practices for prevention and control of bark beetle 

infestations in coniferous forests of the western and southern United States. For. Ecol. Manag. 

238:24-53.

Forsman, E.D. 1975. A preliminary investigation of the spotted owl in Oregon. Thesis, Oregon State 

University, Corvallis, OR. 145pp.

Forsman, E.D., E.C. Meslow and H.M. Wight. 1984. Distribution and biology of the spotted owl in 

Oregon. Wildlife Monographs 87:1-64.

Forsman, E.D., R.G. Anthony, E.C. Meslow and C.J. Zabel. 2004. Diets and foraging behavior of northern 

spotted owls in Oregon. Journal of Raptor Research 38:214-230.
References

306 – Somes Bar Integrated Fire Management Project

Forsman, E.D., R.G. Anthony, K.M. Dugger, E.M. Glenn, A.B. Franklin, G.C. White, C.J. Schwarz, K.P. 

Burnham, D.R. Anderson, J.D. Nichols, J.E. Hines, J.B. Lint, R.J. Davis, S.H. Ackers, L.S. Andrews, 

B.L. Biswell, P.C. Carlson, L.V. Diller, S.A. Gremel, D.R. Herter, J.M. Higley, R.B. Horn, J.A. Reid, 

J. Rockweit, J. Schaberl, T.J. Snetsinger and S.G. Sovern. 2011. Population demography of northern 

spotted owls: 1985-2008. Studies in Avian Biology. Cooper Ornithological Society.

Franklin, A.B., D.R. Anderson, R.J. Gutierrez and K.P. Burnham. 2000. Climate change, habitat quality,

and fitness in northern spotted owl populations in northwestern California. Ecological Monographs 

70:539-590.

Grant, G.E., S.L. Lewis, F.J. Swanson, J.H. Cissel and J.J. McDonnell. 2008. Effect of Forest Practices on 

Peak Flows and Consequent Channel Response: A State-of-Science Report for Western Oregon and 

Washington. Gen. Tech. Rep. PNW-GTR-760. Portland, OR, USDA Forest Service, Pacific 

Northwest Research Station. pp. 34-36.

Gregory, S.V., K.L. Boyer and A.M. Gurnell. eds. 2003. The ecology and management of wood in world 

rivers. Symposium 37. Bethesda, MD: American Fisheries Society. USDA Forest Service RMRSGTR-352. 431:122.

Hamer, T.E. 1988. Home range size of the Northern Barred Owl and Northern Spotted Owl in western 

Washington. M.Sc. thesis, Western Washington University, Bellingham, WA.

Hamer, T.E., E.D. Forsman and E.M. Glenn. 2007. Home range attributes and habitat selection of barred 

owls and spotted owls in an area of sympatry. Condor 109:750-768.

Hann, W.J. and D.J. Strohm. 2003. Fire regime condition class and associated data for fire and fuels 

planning: methods and applications. In: Omi, P.N.; Joyce, L.A. ed. Fire, fuel treatments, and 

ecological restoration. Conference proceedings RMRS-P-29. Fort Collins, CO, USDA Forest 

Service, Rocky Mountain Research Station: 397-434.

Hansen, D.L. and M.J. Mazurek. 2010. Effects of forest thinning on northern spotted owls. Unpublished 

white paper.

Hanson, C.T., D.C. Odion, D.A. DellaSala and W.L. Baker. 2009. Overestimation of fire risk in the 

Northern Spotted Owl Recovery Plan. Conservation Biology 23:1314-1319.

Hanson, C.T., M.L. Bond and D.E. Lee. 2018. Effects of post-fire logging on California Spotted Owl 

Occupancy. Nature Conservation 24:93-105.

Harling, W. and B. Tripp. 2014. Western Klamath Restoration Partnership: A Plan for Restoring Fire 

Adapted Landscapes. Including Descriptions of the Somes Bar Integrated Fire Management Project, 

June 2014.

Harrington, C.A. and W.D. Devine. 2006. A practical guide to oak release. Gen. Tech. Rep. PNW-GTR666. Portland, OR: USDA Forest Service, Pacific Northwest Research Station. 24pp.
References

Final Environmental Assessment – 307

Hart, S.C., A.T. Classen and R.J. Wright. 2005. Long-term interval burning alters fine root and 

mycorrhizal dynamics in a ponderosa pine forest. Journal of Applied Ecology 42(4):752-761.

Hatfield, R., S. Jespsen, E. Mader, S.H. Black and M. Shepard. 2012. Conserving bumble bees. 

Guidelines for creating and managing habitat for America’s declining pollinators. The Xerces 

Society for Invertebrate Conservation. Portland, OR, 32pp.

Healey, S.P., W.B. Cohen, T.A. Spies, M. Moeur, D. Pflugmacher, M.G. Whitley and M. Lefsky. 2008. 

The Relative Impact of Harvest and Fire upon Landscape-Level Dynamics of Older Forests: Lessons 

from the Northwest Forest Plan. Ecosystems 11:1106-1119.

Herter, D.R. and L.L. Hicks. 2000. Barred Owl and Spotted Owl populations and habitat in the central 

Cascade Range of Washington. Journal of Raptor Research 34:279-286.

Hessburg, P., D. Churchill, A. Larson, et al. 2015. Restoring fire-prone Inland Pacific landscapes: seven 

core principles. Online publication at Springerlink.com © The Author(s) 2015.

Hessburg, P.F., R.B. Salter and K.M. James. 2007. Re-examining fire severity relations in premanagement era mixed conifer forests: inferences from landscape patterns of forest structure. 

Landscape Ecology 22(1):5-24.

Hessburg, P.F., T.A. Spies, D.A. Perry, C.N. Skinner, A.H. Taylor, P.M. Brown, S.L. Stephens, A.J. 

Larson, D.J. Churchill, N.A. Povak, P.H. Singleton, B. McComb, W.J. Zielinski, B.M. Collins, R.B. 

Salter, J.J. Keane, J.F. Franklin and G. Riegel. 2016. Tamm Review: Management of mixed-severity 

fire regime forests in Oregon, Washington, and Northern California. For. Ecol. Manag. 366:221-250. 

https://doi.org/10.1016/j.foreco.2016.01.034.

Heyerdahl, E.K, A.G. McKenzie, L.D. Daniels, A.E. Hessl, J.S. Littell and N.J. Mantua. 2008. Climate 

drivers of regionally synchronous fires in the inland Northwest (1651-1900). International Journal of 

Wildland Fire 17:40-49.

Holm, S.R., B.R. Noon, J.D. Wiens and W.J. Ripple. 2016. Potential trophic cascades triggered by the 

barred owl range expansion. Wildlife Society Bulletin 40(4):615-624.

Hoshovsky, M. 2015. Invasive Plants of California’s Wildlands. California Invasive Plant Council. 

Himalayan blackberry, Rubus discolor, R. armeniacus. www.cal-ipc.org/ip/management/ipcw.

Hunter, J.C. and M.G. Barbour. 2001. Through-growth by Pseudotsuga menziesii: A mechanism for 

change in forest composition without canopy gaps. J. Veg. Sci. 12:445-452. 

https://doi.org/10.2307/3236996.

Ice, G.G., D.G. Neary and P.W. Adams. 2004. Effects of wildfire on soils and watershed processes. 

Journal of Forestry 102(6):16-20.

Irwin, L.L., D.F. Rock and S.C. Rock. 2012. Habitat Selection by Northern Spotted Owls in MixedConiferous Forests. The Journal of Wildlife Management 76(1):200-213.
References

308 – Somes Bar Integrated Fire Management Project

Irwin, L.L., L.A. Clark, D.F. Rock and S.L. Rock. 2007. Modeling Foraging Habitat of California Spotted 

Owls. Journal of Wildlife Management 71(4):1183-1191.

Irwin, W.P. 1989. Terranes of the Klamath Mountains, California and Oregon. In Blake, M.C., D.S. 

Harwood, R.J. McLaughlin, A.S. Jayko, W.P. Irwin, F.C.W. Dodge, D.L. Jones, M.M. Miller and T. 

Bullen. Terranes of the Klamath Mountains, California and Oregon, in Tectonic Evolution of 

Northern California: Sausalito to Yosemite National Park, California, June 28-July 7, 1989, 

American Geophysical Union, Washington, DC.

Iverson, R.M. 2000. Landslide triggering by rain infiltration. Water Resources Research 36(7):1897-1910.

Janisch, J.E., S.M. Wondzell and W.J. Ehinger,. 2012. Headwater stream temperature: interpreting 

response after logging, with and without riparian buffers, Washington. Forest Ecology and 

Management 270:302-313.

Jenkins, M.J, W.G. Page, E.G. Hebertson and M.E. Alexander. 2012. Fuels and fire behavior dynamics in 

bark beetle-attacked forests in Western North America and implications for fire management. Forest 

Ecology and Management 275:23-34.

Jimerson, T.M. 1996. BEOR Field Search. USDA, Six Rivers National Forest. Eureka, CA.

Jones, G. M., R. J. Gutierrez, D. J. Tempel, S. A. Whitmore, W. J. Berigan, and M. Z. Peery. 2016. 

Megafires: An Emerging Threat to Old-Forest Species. Frontiers Ecology Environment 14(6):300-

306, doi: 10.1002/fee 1298.

Karuk Tribe. 2010. Karuk Tribe Eco-Cultural Resource Management Plan.

Karuk Tribe and USDA Forest Service. 2017. Memorandum of Understanding Between the Karuk Tribe 

and the US Forest Service, Six Rivers National Forest and Klamath National Forest: Katimiin 

Cultural Management Area.

Kaye, T.N. and J.R. Cramer, Institute for Applied Ecology. 2005 Conservation Assessment for 

Cypripedium fasciculatum and Cypripedium montanum, Region 5, USDA Forest Service. On file Six 

Rivers National Forest.

Keane R.E., P.F. Hessburg, P.B. Landres and F.J. Swanson. 2009. The use of historical range and 

variability (HRV) in landscape management. For Ecol. Manag. 258:1025-1037.

Keane, R.E., K.C. Ryan, T.T. Veblen, C.D. Allen, J. Logan and B. Hawkes. 2002. Cascading effects of fire 

exclusion in the Rocky Mountain ecosystems: a literature review. General Technical Report. RMRS 

GTR-91. Fort Collins, CO, USDA Forest Service, Rocky Mountain Research Station. 24pp.

Kelly, E.G., E.D. Forsman and R.G. Anthony. 2003. Are barred owls displacing spotted owls? Condor 

105:45-53.
References

Final Environmental Assessment – 309

Kennedy, R.S.H. and M.C. Wimberley. 2009. Historical fire and vegetation dynamics in dry forests of the 

interior Pacific Northwest, and relationships to Northern Spotted Owl (Strix occidentalis caurina)

habitat conservation. USDA Forest Service, Pacific Northwest Research Station, Forestry Sciences 

Laboratory, 3200 Forest Ecology and Management 258:554-566.

Kennedy, R.S.H. and T.A. Spies. 2004. Dynamics of hardwood patches in a conifer matrix: 54 years of 

change in a forested landscape in Coastal Oregon. Biological Conservation 122:363-374.

Kipfer, T., S. Egli, J. Ghazoul, B. Moser and T. Wohlgemuth. 2010. Susceptibility of ectomycorrhizal 

fungi to soil heating. Fungal Biology. 114(5-6):467-472.

Kreutzweiser, D.P. and S.S. Capell. 2001. Fine sediment deposition in streams after selective forest 

harvesting without riparian buffers. Canadian Journal of Forest Research 31(12):2134-2142.

Lake, F.K. 2013. Historical and Cultural Fires, Tribal Management and Research Issue in Northern 

California: Trails, Fires and Tribulations. Occasion: Interdisciplinary Studies in the Humanities v. 5 

(March 1, 2013), http://occasion.stanford.edu/node/121.

Lake, F.K. 2007. Traditional ecological knowledge to develop and maintain fire regimes in northwestern 

California, Klamath-Siskiyou bioregion: management and restoration of culturally significant 

habitats. Oregon State University. 771pp.

Lake, F.K., W. Tripp and R. Reed. 2010. The Karuk Tribe, planetary stewardship, and world renewal on 

the middle Klamath River, California. In Power, M.E. and F.S. Chapin. 2010. Planetary Stewardship, 

with an Introduction from the Editor�in�Chief. The Bulletin of the Ecological Society of America

91(2):143-175.

Landres, P.B., P. Morgan and F.J. Swanson. 1999. Overview of the use of natural variability concepts in 

managing ecological systems. Ecological Applications. 9:1179-1188.

Lanigan, S.H., S.N. Gordon, P. Eldred, M. Isley and H. Anderson. 2012. Northwest Forest Plan: The First 

15 Years (1994-2008): Watershed Condition Status and Trend.

Latta, G., H. Temesgen, D. Adams and T. Barrett. 2010. Analysis of potential impacts of climate change 

on forests of the United States Pacific Northwest. Forest Ecology and Management 259:720-729.

Leichenko, R. 2011. Climate change and urban resilience. Current opinion in environmental 

sustainability, 3(3):164-168.

Lewis, H.T. 1993. Patterns of Indian Burning in California: Ecology and Ethnohistory in Before the 

Wilderness, Blackburn and Anderson, Ballena Press, pp. 55-116.

MacDonald, L.H. 2000. Evaluating and Managing Cumulative Effects: Process and Constraints. 

Environmental Management 26(3):219-315.
References

310 – Somes Bar Integrated Fire Management Project

Marlon, J.R., P.J. Bartlein, D.G. Gavin, C.J. Long, R.S. Anderson, C.E. Briles, K.J. Brown, D. 

Colombaroli, D.J. Hallett, M.J. Power, E.A. Scharf and M.K. Walsh. 2012. Long-term perspective on 

wildfires in the western USA. Published online February 14, 2012 

www.pnas.org/cgi/doi/10.1073/pnas.1112839109.

McLaughlin, R.J., S.D. Ellen, M.C. Blake, A.S. Jayko, W.P. Irwin, K.R. Aalto, G.A. Carver and S.H. 

Clarke. 2000. Geology of the Cape Mendocino, Eureka, Garberville, and southwestern part of the 

Hayfork 30 x 60 minute quadrangles and adjacent offshore area, northern California. US Geological 

Survey, Miscellaneous Field Studies Map MF-2336. Retrieved from 

https://pubs.usgs.gov/mf/2000/2336/.

McNabb, D.H. and K. Cromack Jr. 1990. Effects of prescribed fire on nutrients and soil productivity. In 

J.D. Walstad, S.R. Radosevich and D.V. Sandberg, editors, Natural and prescribed fire in Pacific 

Northwest forests. Oregon State University Press, Corvallis, OR, Pp. 125-141.

Mikulovsky, R.P., J.A. De la Fuente, A. Bell, M. Stevens and F. Levitan. 2012. Reactivation of DeepSeated Landslides in Northwestern California after Wildfires. In 2006 and 2008. American 

Geophysical Union, fall 2012 meeting, San Francisco, CA.

Miller, C. and D.L. Urban. 2000. Modeling the effects of fire management alternatives on Sierra Nevada 

mixed-conifer forests. Ecol. Appl. 10:85-94.

Miller, J.D., C.N. Skinner, H.D. Safford, E.E. Knapp and C.M. Ramirez. 2012. Trends and causes of 

severity, size, and number of fires in northwestern California, USA. Ecological Applications

22(1):184-203.

Miller, J.D., H.D. Safford, M. Crimmins and A.E. Thode. 2009. Quantitative Evidence for Increasing 

Forest Fire Severity in the Sierra Nevada and Southern Cascade Mountains, California and Nevada, 

USA Ecosystems 12:16-32.

Moore, R. and K.P. Connaughton. 2014. Direction regarding the survey and manage standards and 

guidelines. US Forest Service Regional Guidance, May 13, 2014.

Moore, R.D., D.L. Spittlehouse and A. Story. 2005. Riparian microclimate and stream temperature 

response to forest harvesting: A review. Journal of the American Water Resources Association. 

41:813:834.

Moritz, M.A. and D.C. Odion. 2005. Examining the strength and possible causes of the relationship 

between fire history and Sudden Oak Death. Oecologia 144:106-114.

Naiman, R.J., H. Décamps and M. Pollock. 1992. The role of riparian corridors in maintaining regional 

biodiversity. Ecological Applications 3:209-212.

Nash III, T.H. 1996. Lichen Biology. Cambridge University Press, Cambridge, UK, 303pp.
References

Final Environmental Assessment – 311

National Marine Fisheries Service. 2014. Final Recovery Plan for the Southern Oregon/Northern 

California Coast Evolutionarily Significant Unit of Coho Salmon (Oncorhynchus kisutch). National 

Marine Fisheries Service. Arcata, CA.

Norden, B., M. Fyberg, F. Gotmark and B. Olausson. 2004. Relative importance of coarse and fine woody 

debris for the diversity of wood-inhabiting fungi in temperate broadleaf forests. Biological 

Conservation 117:1-10.

Norgaard, K.M. 2014. Retaining Knowledge Sovereignty: Expanding the Application of Tribal 

Traditional Knowledge on Forest Lands in the Face of Climate Change. Prepared for the Karuk Tribe 

Department of Natural Resources.

Norgaard, K.M., R. Reed and C. Van Horn. 2011. A continuing legacy: Institutional racism, hunger, and 

nutritional justice on the Klamath. MIT Press.

North, M. and J. Sherlock. 2012. Marking and assessing forest heterogeneity. Manag. Sierra Nev. For. 

Gen. Tech. Rep. PSW-GTR-237, USDA Forest Service, Pacific Southwest Research Station, Albany,

CA, pp. 95-105.

North, M. ed. 2012. Managing Sierra Nevada forests. Gen. Tech. Rep. PSW-GTR-237, USDA Forest 

Service, Pacific Southwest Research Station, Albany, CA, 184pp.

North, M., J. Innes and H. Zald. 2007. Comparison of thinning and prescribed fire restoration treatments 

to Sierran mixed-conifer historic conditions. Can. J. For. Res. 37:331-342.

North, M., P. Stine, K. O’Hara, W. Zielinski and S. Stephens. 2009. An ecosystem Management Strategy 

for Mixed Conifer Forests. Gen. Tech. Rep. PSW-GTR-220, USDA Forest Service. Pacific 

Southwest Research Station, March 2009 (w/addendum Feb. 2010).

Odion, D., E. Frost, J. Stritthold, H. Jiang, D. DellaSala and M. Moritz. 2004. Patterns of fire severity and 

forest conditions in the Western Klamath Mountains, California. Conservation Biology 18(4):927-

936.

Oliver, C.D. and B.C. Larson. 1996. Forest stand dynamics: updated edition. John Wiley and sons.

Olson, D.H., J.B. Leirness, P.G. Cunningham and E.A. Steel. 2014. Riparian buffers and forest thinning: 

Effects on headwater invertebrates 10 years after thinning. Forest Ecology and Management. 321:81-

93.

Olson, D.L. 2000. Fire in riparian zones: A comparison of historical fire occurrence in riparian and 

upslope forests in the Blue Mountains and southern Cascades of Oregon. Thesis. Seattle, WA: 

University of Washington. 274pp.

Olson, D.L. and J.K. Agee. 2005. Historical fires in Douglas-fir dominated riparian forests of the southern 

Cascades, Oregon. Fire Ecology. 1:50-74.

Orleans/Somes Bar Community Wildfire Protection Plan. 2012.
References

312 – Somes Bar Integrated Fire Management Project

Parker, P.L. T.F. and King. 1990. National Register Bulletin 38: Guidelines for the Evaluation and 

Documentation of Traditional Cultural Properties.

Perry, D.A., P.F. Hessburg, C.N. Skinner, T.A. Spies, S.L. Stephens, A.H. Taylor, J.F. Franklin, B. 

McComb and G. Riegel. 2011. The ecology of mixed severity fire regimes in Washington, Oregon, 

and Northern California. Forest Ecology and Management 262:703-717.

Poff, R.J. 1996. Chapter 16, Effects of Silvicultural Practices and Wildfire on Productivity of Forest Soils. 

Sierra Nevada Ecosystem Project: Final report to Congress, vol. II, Assessments and scientific basis 

for management options. Davis: University of California, Centers for Water and Wildland Resources.

Ponder Jr., Felix, R.L. Fleming, S. Berch, M.D. Busse, J.D. Elioff, P.W. Hazlett, R.D. Kabzems, J.M. 

Kranabetter, D.M. Morris, D. Page-Dumroese, R.F. Powers, F.G. Sanchez, D.A. Scott, R.H. Stagg, 

D. Young, J. Zhang, D.W. McKenney, D.S. Mossa, P.T. Sanborn, D.M. Stone and R.A. Voldseth. 

2012. Effects of organic matter removal, soil compaction, and vegetation control on 10th year 

biomass and foliar nutrition: LTSP continent-wide comparisons. Forest Ecology and Management 

278:35-54.

Powers, R.F.D., A. Scott, F.G. Sanchez, R.A. Voldseth, D. Page-Dumroese, J.D. Elioff and D.M. Stone. 

2005. The North American Long-Term Soil Productivity Experiment: Findings from the first decade 

of research. Forest Ecology and Management 220:31-50.

Pyne, S.J. 2000. Where have all the fires gone? USDA Forest Service. Fire Management Today 60(3), 

52pp.

Rashin, E.B., C.J. Clishe, A.T. Loch and J.M. Bell. 2006. Effectiveness of timber harvest practices for 

controlling sediment related water quality impacts. J. Am. Water Resource. Assoc. 42:1307-1327.

Reeves, G.H., B.R. Pickard and K.N. Johnson. 2016. An initial evaluation of potential options for 

managing riparian reserves of the Aquatic Conservation Strategy of the Northwest Forest Plan. 

USDA Forest Service, Pacific Northwest Research Station.

Reineke, L.H. 1933. Perfecting a stand-density index for even-aged forests. J. Agric. Res. 46:627-638.

Rockweit, J.T., A.B. Franklin and P.C. Carlson. 2017. Differential impacts of wildfire on the population 

dynamics of an old�forest species. Ecology 98(6):1574-1582.

Rosenberg, D.K., C.J. Zabel, B.R. Noon and E.C. Meslow. 1994. Northern spotted owls: influence of prey 

base: A comment. Ecology 75(5):1512-1515.

Safford, H.D. and K.M. Van de Water. 2014. Using fire return interval departure (FRID) analysis to map 

spatial and temporal changes in fire frequency on national forest lands in California. Res. Pap. PSWRP-266. USDA Forest Service, Pacific Southwest Research Station, Albany, CA, 59pp.
References

Final Environmental Assessment – 313

Safford, H.D., K.M. Van de Water and D. Schmidt. 2011. California Fire Return Interval Departure 

(FRID) map, 2010 version. USDA Forest Service, Pacific Southwest Region, and The Nature 

Conservancy-California. www.fs.usda.gov/main/r5/landmanagement/gis/. (8 August 2011).

Sakai, H.F. and B.R. Noon. 1993. Dusky-footed woodrat abundance in different-aged forests in 

northwestern California. Journal of Wildlife Management 57:373-382.

Sankey, J.B., J. Kreitler, T.J. Hawbaker, J.L. McVay, M.E. Miller, E.R. Mueller, N.M. Vaillant, S.E. Lowe 

and T.T. Sankey. 2017. Climate, wildfire, and erosion ensemble foretells more sediment in western 

USA watersheds, Geophys. Res. Lett 44:8884-8892, doi:10.1002/2017GL073979.

Sarche, M. and P. Spicer. 2008. Poverty and Health Disparities for American Indian and Alaska Native 

Children: Current Knowledge and Future Prospects. Annals of the New York Academy of Sciences

1136:126-136. http://doi.org/10.1196/annals.1425.017.

Scholl, A.E. and A.H. Taylor. 2010. Fire Regimes, Forest Change, and Self-Organization in an Old –

Growth Mixed-Conifer Forest, Yosemite National Park, USA, Ecological Society of America.

Scott, J.H. and E.D. Reinhardt. 2001. Assessing Crown Fire Potential by Linking Models of Surface and 

Crown Fire Behavior. USDA Forest Service, Rocky Mountain Research Station RP-29.

Scott, J.H. and R.E. Burgan. 2005. Standard fire behavior fuel models: a comprehensive set for use with 

Rothermel’s surface fire spread model. Gen. Tech. Rep. RMRS-GTR-153, Fort Collins, CO, USDA

Forest Service, Rocky Mountain Research Station, 72pp.

Sherlock, J.W. 2007. Integrating stand density management with fuel reduction.

Skinner, C.N. 2003. A tree-ring based fire history of riparian reserves in the Klamath Mountains. In: 

Faber, P.M. ed. Proceedings, California riparian systems: Processes and floodplains management, 

ecology, and restoration, March 12-15, 2001, Sacramento, CA: Riparian Habitat Joint Venture pp. 

116-119.

Skinner, C.N., A.H. Taylor and J.K. Agee. 2006. Klamath Mountains Bioregion. In: Sugihara, N.G., J.W. 

Van Wagtendonk, K.E. Shaffer, J. Fites-Kaufman and A.E. Thode. eds. Fire in California’s 

Ecosystems. University of California Press, Berkeley, Ca. Chapter 9, pp. 170-194.

Smith, D.M., B.C. Larson, M.J. Kelty and P.M.S. Ashton. 1997. The practice of silviculture: Applied 

forest ecology. John Wiley and Sons, Inc.

Solis, D.M. 1983. Summer habitat ecology of spotted owls in Northwestern California. Thesis, Humboldt 

State University, Arcata, CA.

Soll, J. 2004. Controlling Himalayan Blackberry (Rubus armeniacus [R. discolor, R. procerus]) in the 

Pacific Northwest. Brian Lipinski. ed. The Nature Conservancy. 

www.invasive.org/gist/moredocs/rubarm01.pdf.
References

314 – Somes Bar Integrated Fire Management Project

Spies T., M. Pollock, G. Reeves and T. Beechie. 2013 Effects of riparian thinning on wood recruitment: a 

scientific synthesis. Science Review Team Wood Recruitment Subgroup, USDA Forest Service, 

PNW Research Station, Portland, OR.

Spies, T.A., B.C. McComb, R.S.H. Kennedy, M.T. McGrath, K. Olsen and R.J. Pabst. 2007. Potential 

effects of forest policies on terrestrial biodiversity in a multi-ownership province. Ecological 

Applications. 17(1):48-65.

Spies, T.A., J.D. Miller, J.B. Buchanan, J.F. Lehmkuhl, J.F. Franklin, S.P. Healey, P.F. Hessburg, H.D. 

Safford, W.B. Cohen, R.S.H. Kennedy, E.E. Knapp, J.K. Agee and M. Moeur. 2010. Underestimating 

risks to the northern spotted owl in fire-prone forests: response to Hanson et al. Conservation 

Biology 24:330-333.

Stein, S.M., J. Menakis, M.A. Carr, S.J. Comas, S.I. Stewart, H. Cleveland, L. Bramwell and V.C. 

Radeloff. 2013. Wildfire, wildlands, and people: understanding and preparing for wildfire in the 

wildland-urban interface – A Forests on the Edge report. Gen. Tech. Rep. RMRS-GTR-299. Fort 

Collins, CO, USDA Forest Service, Rocky Mountain Research Station. 36pp.

Stephens, S.L. and J.J. Moghaddas. 2005. Experimental fuel treatment impacts on forest structure, 

potential fire behavior, and predicted tree mortality in a mixed conifer forest. Forest Ecology and 

Management 215:21-36.

Swetnam, T.W. 1993. Fire History and Climate Change in Giant Sequoia Groves, Science 262:885-889.

Swetnam, T.W., C.D. Allen and J.L. Betancourt. 1999. Applied historical ecology: using the past to 

manage for the future. Ecological Applications 9:1189-1206.

Syphard, A.D., R.M. Scheller, B.C. Ward, W.D. Spencer and J.R. Strittholt. 2011. Simulating landscapescale effects of fuels treatments in the Sierra Nevada, CA. International Journal of Wildland Fire 

20:364-383.

Taylor A.H., V. Trouet, C.N. Skinner and S. Stephens. 2016. Socioecological transitions trigger fire 

regime shifts and modulate fire-climate interactions in the Sierra Nevada, USA, 1600-2015 CE. 

Proceedings of the National Academy of Sciences of the United States of America, 133(48):13684-

13689.

Taylor, A.H. and C.N. Skinner. 2003. Spatial and temporal patterns of historic fire regimes and forest 

structure as a reference for restoration of fire in the Klamath Mountains. Journal of Arid Land 

Studies 13:704-719.

The National Cohesive Wildland Fire Management Strategy: Phase III Western Regional Science-Based 

Risk Analysis Report. 2012. Final Report of the Western Regional Strategy Committee. November 

2012. 102pp.
References

Final Environmental Assessment – 315

Thomas J.W, E.D. Forsman, J.B. Lint, E.C. Meslow, B.R. Noon and J. Verner. 1990. A Conservation 

Strategy for the Northern Spotted Owl. Portland (OR): Interagency Scientific Committee to address 

the conservation of the northern spotted owl. USDA Forest Service and USDI Bureau of Land 

Management, National Park Service, and Fish and Wildlife Service.

Tuininga A.R. and J. Dighton. 2004. Changes in ectomycorrhizal communities and nutrient availability 

following prescribed burns in two upland pine–oak forests in the New Jersey pine barrens. Can. J. 

For. Res. 34:1755-1765.

USDA and USDI. 1994a. Record of Decision for Management of Habitat for Late-Successional and OldGrowth Forest Related Species within the Range of the Northern Spotted Owl.

USDA and USDI. 1994b. Final Supplemental Environmental Impact Statement on Management of 

Habitat for Late-Successional and Old-Growth Forest Related Species Within the Range of the 

Northern Spotted Owl, Volume I.

USDA and USDI. 2001. Record of Decision for amendments to the survey and manage, protection buffer, 

and other mitigations measures standards and guidelines in Forest Service and Bureau of Land 

Management planning documents within the range of the northern spotted owl, 160pp.

USDA and USDI. 2010. Northwest Forest Plan Temperature TMDL Implementation Strategy. January 14, 

2010 Revision.

USDA Forest Service. 1995. Six Rivers National Forest Land and Resource Management Plan. Six Rivers 

National Forest, Pacific Southwest Region, USDA Forest Service.

USDA Forest Service. 1998. Ishi Pishi Ecosystem Analysis. Klamath National Forest. Yreka, CA.

USDA Forest Service. 1999. Klamath National Forest Forest-Wide Late Successional Reserve 

Assessment. Klamath National Forest. Yreka, CA.

USDA Forest Service. 2000. Horse Linto, Mill, and Tish Tang Watershed Analysis. Six Rivers National 

Forest. Eureka., CA.

USDA Forest Service. 2001. Smoke Management Guide for Prescribed and Wildland Fire 2001 Edition. 

PMS 420-2. 226pp.

USDA Forest Service. 2003. Mainstem Trinity Watershed Analysis. Six Rivers National Forest. Eureka, 

CA.

USDA Forest Service. 2005. Sensitive Species Transition Project, Region 5 (fungi). 2005. Unpublished 

database.

USDA Forest Service. 2010. FS-990a: National Best Management Practices for Water Quality 

Management on National Forest System Lands.
References

316 – Somes Bar Integrated Fire Management Project

USDA Forest Service. 2010. Klamath National Forest Land and Resources Management Plan. Klamath 

National Forest, Pacific Southwest Region, USDA, Forest Service, 1995 (including amendments as 

of 7/29/2010).

USDA Forest Service. 2014. Six Rivers Best Management Practices: Invasive Plant and Aquatic 

Organisms. Signed April 18, 2014, Tyrone Kelley, Forest Supervisor. On file Six Rivers National 

Forest.

USDA Forest Service. 2015. Strategic Plan FY2015-2020. June 2015. FS-1045.

USDI Fish and Wildlife Service. 1992. Designation of Critical Habitat for the Northern Spotted Owl. 

Final Rule. Federal Register: January 15, 1992, 57(10):1796-1838.

USDI Fish and Wildlife Service. 2009. Regulatory and scientific basis for US Fish and Wildlife Service 

guidance for evaluation of take for northern spotted owls on private timberlands in California’s 

northern interior region. 78pp.

USDI Fish and Wildlife Service. 2011. Revised recovery plan for the northern spotted owl (Strix 

occidentalis caurina). US Department of the Interior, Portland, OR.

USDI Fish and Wildlife Service. 2012. Protocol for surveying proposed management activities that may 

impact northern spotted owls.

Van de Water, K. and M. North. 2011. Stand structure, fuel loads, and fire behavior in riparian and upland 

forests, Sierra Nevada Mountains, USA: A comparison of current and reconstructed conditions. 

Forest Ecology and Management. 262:215-228.

van Mantgem, P.J., N.L. Stephenson, J.C. Byrne, L.D. Daniels, J.F. Franklin, P.Z. Fule, M.E. Harmon, 

A.J. Larson, J.M. Smith, A.H. Taylor and T.T. Veblen. 2009. Widespread Increase of Tree Mortality 

Rates in the Western United States. Science 323:521-524. https://doi.org/10.1126/science.1165000.

Vernon, M.J. 2017. In the face of drought: Do fuel treatments promote drought resistance in Whiskeytown 

National Recreation Area? Humboldt State University, Arcata, CA.

Ward Jr., J.P. 1990. Spotted owl reproduction, diet and prey abundance in northwest California. M.S. 

Thesis, Humboldt State Univ., Arcata, CA, 70pp.

Ward Jr., J.P., R.J. Gutierrez and B.R. Noon. 1998. Habitat selection by Northern Spotted Owls: the 

consequences of prey selection and distribution. Condor 100:79-92.

Waring R.H., N.C. Coops and S.W. Running. 2011. Predicting satellite-derived patterns of large-scale 

disturbances in forests of the Pacific Northwest Region in response to recent climatic variation. 

Remote Sensing of Environment 115:3554-3566.

Weatherspoon, C.P. 1996. Sierra Nevada Ecosystem Project; Chapter 44, Fire-Silviculture Relationships 

in Sierra Forests, pp. 1167-1175.
References

Final Environmental Assessment – 317

Weir, R.D. and F.B. Corbould. 2010. Factors affecting landscape occupancy by fishers in north�central 

British Columbia. The Journal of Wildlife Management, 74(3):405-410.

Wells, C.G., R.E. Campbell, L.F. DeBano, C.E. Lewis, R.L. Fredriksen, E.C. Franklin, R.C. Froelich and 

R.H. Dunn. 1979. Effects of fire on soil. USDA Forest Service, US Gov’t Printing Office, 

Washington, DC, 34pp.

Welsh, H.H. and A.J. Lind. 1992. Population ecology of two relictual salamanders from the Klamath 

Mountains of northwestern California. In D. McCullough and R. Barrett (eds.), Wildlife 2001: 

Populations, Elsevier Science Publishers, Ltd., London, pp. 419-437.

Western Regional Strategy Committee. 2011. A National Cohesive Wildland Fire Strategy: Western 

Regional Assessment. September 30, 2011. 61pp.

Whitlock, C., S.H. Shafer and J. Marlon. 2003. The role of climate and vegetation change in shaping past 

and future fire regimes in the northwestern U.S., and the implications for ecosystem management. 

For. Ecol. Manage. 178:5-21.

Wiens JA, G.D. Hayward, H.D. Safford and C. Giffen. 2012. Historical environmental variation in 

conservation and natural resource management. Wiley, Hoboken, p. 352.

Wiensczyk, A.M., S. Gamiet, D.M. Durall, M.D. Jones and S.W. Simard. 2002. Ectomycorrhizae and 

forestry in British Columbia: A summary of current research and conservation strategies. B.C. 

Journal of Ecosystems and Management 2(1), 20pp.

Wilcove, D.S., D. Rothstein, J. Dubow, A. Phillips and E. Losos. 1998. Quantifying threats to imperiled 

species in the United States. BioScience, 48(8):607-615.

Williams, D.F., J. Verner, H.F. Sakai and J.R. Waters. 1992. General biology of the major prey species of 

the California spotted owl.in J. Verner, editor. The California Spotted Owl: A Technical Assessment 

of its Current Status. General Technical Report PSW-GTR-133. USDA Forest Service, Pacific 

Southwest Research Station, Albany, CA.

Zabel, C.J., K. McKelvey and J.P. Ward Jr. 1995. Influence of primary prey on home-ranges size and 

habitat-use patterns of Northern Spotted Owls (Strix occidentalis caurina). Can. J. Zool. 73:433-439.

Zhang, J., M.D. Busse, D.H. Young, G.O. Fiddler, J.W. Sherlock and J.D. TenPas. 2017. Aboveground 

biomass responses to organic matter removal, soil compaction, and competing vegetation control on 

20-year mixed conifer plantations in California. Forest Ecology and Management 401:341-353.
References

318 – Somes Bar Integrated Fire Management Project

This page intentionally left blank.
Appendix A. Collaboration

Final Environmental Assessment – 319

Appendix A. Collaboration

The Western Klamath Restoration Partnership (WKRP) and the project arose because members of the 

community, including the Karuk Tribe, Mid Klamath Watershed Council (MKWC), US Forest Service 

(USFS or Forest Service), area fire safe councils, environmental groups and other community-based 

stakeholders, came together (Table A-1 and Table A-2) from a desire to reintroduce prescribed fire in the 

Klamath Mountains. Ultimately, the goal of this coordinated effort is to utilize an all hands, all lands

approach to ecological restoration that includes landowners and a diverse group of partners to modify 

prescribed fire and wildfire behavior at the larger landscape-scale.

Table A-1. Western Klamath Restoration Partnership (WKRP) meetings.

Date Location Summary

2/25/2016 Somes Bar Work

Station Community Meeting with Landowners and Public

07/7/2016 Orleans Community Meeting with Landowners and Public

12/17/2012 Happy Camp

Middle Klamath Restoration Partnership activities since 2007. Initially began as the Instream 

working group with the intention of creating a common vision for Coho salmon restoration and 

decision was made to branch off into Upslope and Instream working groups.

2/19/2013 Happy Camp

Upslope Working Group Meeting. General ideas on collaborative opportunities, possibilities,

and resources available for a dedicated upslope multi-party collaboration. Ideas taken from 

the Instream working group on developing a candidate action table for restoration priorities

and vetting it through various organizations. US Fire Learning Network (FLN) was interested

in facilitating and providing guidance.

5/30/2013 Happy Camp

Public Workshop #1: Vision and Scope of the entire project. FLN present for facilitating and 

guiding. What will the project boundary encompass? Group work on project vision statements 

and outlining describing values. Defining next steps and agreeing to a workshop every 1.5 to 2 

months. Develop working groups to address the scope and vision.

7/29/2013 Orleans Public Workshop #2. Draft vision statement proposed received comments. Review work done

by the scoping working group thus far. Review of the project targets.

1/29/2014 Happy Camp

Public Workshop #3. Group identified key ecological attributes of the targets and assessed 

their current viability; identified and marked on maps the threats related to each target; and 

developed a series of situation diagrams, exploring linkages among identified targets of: FireAdapted Communities; Restored Fire Regimes; Resilient Biodiverse Forests, Plants, and 

Animals; Sustainable Local Economies; Cultural and Community Vitality, and Key Attributes 

associated with these as well as threats and opportunities. Group discussed and became 

familiar with the Open Standards Process; applied identified targets and threats to community 

related areas within the general landscape; began to work on strategies; and continued to 

build shared knowledge among stakeholders participating in the network.

2/24/2014 –

2/26/2014 Orleans Public Workshop #4: Prioritization model presented (previously from KFES and CWPP) to identify areas where efforts should be concentrated. Discussion of which layers to include for GIS.

3/17/2014 –

3/19/2014 Happy Camp

Public Workshop #5: Continued development of the treatment prioritization model (overlay) 

and its relationships to what exists. Scenario building in the three geographic areas that 

center in community areas. Find zones of agreement and understanding the commonalities 

and differences behind the scenarios. Development of overlays based on need for different 

communities and real world issues that affect these areas. Developed case studies based on 

geographic areas and associated needs, priorities, and challenges and resources associated 

with each of these case studies. Finalized the last two results chains. Set goals and 

objectives related to each target and results chain. Referring to the strategies, developed an 

action plan to accomplish the goals and objectives. Developed a monitoring plan related to 

the action plan to create the adaptive management loop.

4/28/2014 –

4/30/2014 Orleans

Public Workshop #6. Finalize the last two results chains; set goals and objectives related to 

each target and results chain; referring to the strategies, develop an action plan to accomplish 

the goals and objectives; develop a monitoring plan related to the action plan; and 

stakeholder mini-assessment.
Appendix A. Collaboration

320 – Somes Bar Integrated Fire Management Project

Date Location Summary

5/20/2014 –

5/21/2014 Happy Camp Public Workshop #7. Refine the project lifecycle. Updates on the pilot project proposals.

11/3/2014 –

11/5/2014 Happy Camp

Public Workshop #8: Plan for the upcoming year, including funding. Coordinate activities in 

order to maximize use of funding and accomplish funding deliverables. Visit burn areas for 

insights into fire effects and possible landscape treatment options. Discuss post-fire treatment 

prescriptions, level of WKRP engagement on proposed projects, and zones of agreement. 

Introduce Fire Adapted Communities Self-Assessment Tool provided by the Fire Adapted 

Communities Learning Network. Discuss research and monitoring needs, relative to university 

scholarships and PSW involvement.

2/17/2015 –

2/19/2015 Orleans Public Workshop #9: Field review of Donahue Flat area potential treatments, presentations on prescription development and treatment options.

5/19/2015 –

5/21/2015 Orleans

Public Workshop #10: Shared learning about differing perspectives on treatment options in 

the Somes Bar pilot project area. Discover zones of agreement in practice that can inform 

prescription development in the Somes Bar pilot project area. Collaboratively develop 

Purpose and Need statements. Use field trip exercises and indoor work regarding potential 

treatment prescriptions, including some that involve desired future conditions and dynamics in 

natural stands. Continue to build durable relationships by discovering zones of agreement in 

practice. Continue to build muscle for complex problem solving, while maintaining 

fundamental regard for one another.

7/21/2015 –

7/23/2015 Orleans

Public Workshop #11: Get landscape perspective of Rodgers Creek treatment focus area. 

Build consensus and shared understanding of the prescription development process, and how 

this is applied to stand delineation and marking through group marking exercises. Review 

Purpose and Need for the Somes Bar Pilot Project. Discuss integration of Instream Working 

Group and instream restoration into WKRP.

10/27/2015 –

10/29/2015 Happy Camp

Public Workshop #12: WKRP as a whole continues to stay informed, synergistic and 

coordinated. Happy Camp subgroup receives input from whole group on the emerging project 

area project. WKRP strategies are further developed, per the Open Standards. WKRP and 

scientists from PSW and USFWS exchange information, strengthen their working relationships.

3/1/2016 –

3/2/2016 Orleans

Public Workshop #13: Field trip to the Simms Gulch burn area. Participants continue to share 

learning and build skills in collaborative problem solving. The Orleans/Somes Bar subgroup 

received helpful feedback on the Purpose and Need statement for its pilot project. 

Participants find a path for working with diverse treatment philosophies, such as treatment 

options associated with linear treatments in the Orleans/Somes Bar project. WKRP strategies 

are reviewed and participant input on next steps is gathered.

5/11/2016 –

5/12/2016 Sawyers Bar

Public Workshop #14: Update the large group on subgroup and working group progress and 

important announcements, and reflect on WKRP’s work to date. Through a field learning 

exchange, build a common understanding of the Eddy LSR Project as an example of a 

collaboratively designed project that aligns with the shared values of WKRP. See first-hand 

how written prescriptions translate into on-the-ground treatments. Dig deeper into a “project 

lifecycle” and, especially, into the available mechanisms for implementation of projects. We 

will address specific project related questions through a discussion with practitioners 

experienced in various mechanisms. Familiarize the large group with the Yellow Jacket Ridge 

Project, and see how the project represents the group’s shared values.

8/23/2016 –

8/24/2016 Happy Camp

Public Workshop #15: Understand what is happening in each of the geographic subgroups of 

WKRP (Orleans/Somes Bar (OSB), Salmon River and Happy Camp/Seiad). Understand the 

objectives of the 2016 Prescribed Fire Training Exchange (TREX) and how they relate to the 

WKRP vision. Understand the next steps for the research and monitoring in the WKRP 

planning area. Agree to how we should move forward with WKRP-wide objectives and actions 

(based on strategies).

2/15/2017 –

2/16/2017 Orleans

Public Workshop #16: Understand what is happening in each of the geographic subgroups of 

WKRP (Orleans/Somes Bar, Salmon River and Happy Camp/Seiad). Review the 

characteristics of a WKRP Project. Agree on next steps for out-year planning throughout the 

1.2 million acre WKRP planning area (mapping exercise). Participate in working sessions of 

the Communication and Engagement, and Research and Monitoring working groups.

Understand WKRP decision process and components. Review Somes Bar Integrated Fire 

Management Project (Somes Bar Project) planning material including maps. Provide 

feedback on proposed actions in WKRP pilot project areas.

6/6/2017 –

06/7/2017 Happy Camp

Understand what is happening in each of the geographic subgroups of WKRP: Orleans/

Somes Bar, Salmon River and Happy Camp/Seiad. Understand biomass energy production

and how it might be used in each of the WKRP geographic areas. Understand and develop

strategies to incorporate managed wildfire into strategic areas within the WKRP project area.
Appendix A. Collaboration

Final Environmental Assessment – 321

Table A-2. Western Klamath Restoration Partnership (WKRP) meeting participants.

Name and Affiliation

Jamie Allen, Northern California Resource Center (NCRC)

Russell ‘Buster’ Atteberry, Karuk Tribal Chairman

Nancy Bailey, MKWC

Kimberly Baker, Klamath Forest Alliance/Environmental 

Protection Information Center (EPIC)

Kara Baylog, Shasta Resource Conservation District (RCD)

George Bearnhart, Happy Camp Fire Safe Council (FSC) and 

USFS (retired)

Mike Beasley, USFS (retired)

Wind Beaver, Community Member

Jill Beckman, Karuk Tribe

Roberto Beltran, USFS SRNF

Jamie Bettaso, USFS SRNF

Corrine Black, USFS SRNF

Dan Blessing, USFS KNF

Greg Bloomfeld, USFS KNF

Lisa Blousfeld, USFS KNF

Greg Bousfield, USFS KNF

Leslie Burkhardt, USFS (retired)

Ramona Butz, USFS SRNF

Heather Campbell, MKWC

Nolan Colegrove, USFS SRNF

Mark Cookson, US Fish and Wildlife Service (USFWS) Yreka

Rick Costalas, Siskiyou County

Max Creasy, Community Member and USFS (retired)

Earl Crosby, Karuk Tribe

Leroy Cyr, USFS SRNF

Michelle Medley-Daniels, The Watershed Center (WRTC)

Lynn Decker, TNC/Fire Learning Network (FLN)

Brenda Devlin, USFS SRNF

James Donahay, Natural Resources Conservation Service 

(NRCS)

Guy Duffner, FLN

Alan Dyar, Retired Principal/HCCSD/HCCC

Jennifer Dyer, USFS SRNF

Eamon Engber, Redwood National and State Parks

Bill Estes, Humboldt County Coordination Committee/HCFPD

Imil Ferrara, HSU Grad Student

Tom Fielden, Karuk Tribe

Don Flickinger, National Marine Fisheries Service

Merv George Jr., USFS SRNF

Jaclyn Goodwin, Karuk Tribe

Patty Grantham, USFS KNF

Karuna Greenberg, Salmon River Restoration Council

Jon Grunbaum, USFS KNF and Happy Camp FSC

Scott Hagerty, USFS (retired)

Name and Affiliation

Arielle Halpern, UC Berkeley

Will Harling, MKWC

George Harper, Happy Camp FSC and USFS (retired)

Damien Hawley, AmeriCorps Watershed Steward

Chris Hays, USFS KNF

Mike Hentz, MKWC

Leaf Hillman, Karuk Tribe

Lisa Hillman, Karuk Tribe

Lisa Hoover, USFS SRNF

Mary Huffman, FLN

Gary Hughes, EPIC

John Hunter, USFWS Arcata

Clint Isbell, USFS KNF

David Jaramillo, WRTC

George Jennings, NCRC

David Johnson, USFWS Yreka

Vince Keeler, USFS KNF

Tyrone Kelley, USFS SRNF

Alyson Kral, USFS SRNF

Frank Lake, USFS PSW

Kristen Lark, USFS SRNF

Luna Latimer, MKWC

Fred Levitan, USFS SRNF

Katie Lighthall, Cohesive Strategy Coordinator

Bridget Litten, USFS SRNF

Jeff Marszal, USFS KNF

Andy McBroom, USFS SRNF

Dean McBroom, Community Member

John McRae, USFS SRNF

David Medford, Karuk Tribe

Cathy Meinert, Community Member

Bobbi Miller, USFS KNF

Mike Minton, USFS SRNF

John Morris, USFWS Yreka

Tom Mutz, USFS KNF

Lance Noxon, USFS KNF

Kevin Osborne, USFS KNF

Ed Prather, Seiad FSC

Ron Reed, Karuk Tribe

Erin Rentz, USFS KNF

Rachel Rhinehart, Karuk Tribe

Zach Rodriguez, USFS KNF

Amanda Rudolph, MKWC

Daniel Sarna, UC Berkeley

Kenny Sauve, Karuk Tribe
Appendix A. Collaboration

322 – Somes Bar Integrated Fire Management Project

Name and Affiliation

Ben Saxon, Karuk Tribe

Josh Saxon, Salmon River Restoration Council and Karuk 

Tribe

Mark Severy, Schatz Energy Research Center

Carol Sharp, Happy Camp FSC

Robin Shuckle-Shea, Small Business Coach

Carl Skinner, USFS (retired)

Andrew Spain, USFS SRNF

Carol Spinos, USFS SRNF

Stormy Staats, Klamath Salmon Media Collaborative

Jessica Stauffer, Contract Wildlife Biologist

Peter Stine, USFS PSW

Brian Taylor

Name and Affiliation

Zack Taylor, USFS SRNF

Malcolm Terrence, Community Member and Journalist

Sue Terrence, Community Member

Bill Tripp, Karuk Tribe

Mike Turek, USFS (retired)

Terry Walter, USFS KNF

Matt Watson, USFS KNF

Alex Watts-Tobin, Karuk Tribe

Tim Wilhite, US Environmental Protection Agency (EPA) Yreka

Leslie Wolff, National Marine Fisheries Service

Andy, Schatz Energy Research Center

Peter, Schatz Energy Research Center
Final Environmental Assessment 

– 323

Appendix B. Response to Comments

Appendix B. Response to Comments

Table B-1. Project scoping comments received during February 21 through March 23, 2017 scoping period.

Resource Issue Rule Analysis Conclusion Comment

Gary Strouss, Landowner in Ti Bar, oral comment, See meeting notes; 3/1/2017.

Lands Water tank and water 

pickup on private land 

in Ti-Bar, within unit 

2108. PVC 2′′ waterpipe running above the 

road (#/), through the 

culvert, underground 

from there to the house.

40 CFR §1500.2(d). Policy. 

Encourage and facilitate public 

involvement in decision, which 

affect the quality of the human 

environment.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

National Environmental Policy Act 

(NEPA) procedures.

These private land infrastructure features have been 

recorded and mapped during the analysis process 

to verify locations. Structures would be flagged so 

they are visible to field crews and equipment 

operators, required to protect them by either 

avoiding use of heavy machinery, buffering during 

prescribed burning, and handpiles placed so radiant 

heat is dispersed; contained by manually 

constructed control lines.

US Forest Service (USFS) would protect 

private property via application of project 

design features and mitigation measures.

1

Maria Strouss, Landowner in Ti Bar, oral comment, 3/1/2017. See meeting notes.

Public 

Involvement / 

Lands

Requests adequate 

notification prior to 

implementation near 

private property.

40 CFR §1500.2(d). Policy. 

Encourage and facilitate public 

involvement in decision, which 

affect the quality of the human 

environment.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

The USFS would call, send email, or letter to 

adjacent landowners two weeks prior to 

commencing each operational, phased treatment 

entry. Notifications would be posted at existing 

community bulletin boards, mailed or emailed to the 

public and consulting agencies.

USFS is responsive to landowner request for 

notification of operations near private property.

2

Proper identification of 

private land 

boundaries.

The USFS field verified property land lines and 

improved boundary markers in 2016, recognizing 

select USFS ownership boundary delineations 

recorded in the agency’s GIS corporate database 

required verification and some field markers (red 

paint) have faded since being surveyed. Spot 

flagging would be placed along boundaries where 

markers and/or tree paint are no longer visible prior 

to operations.

USFS has properly field verified and would 

identify (flag) private land boundaries within 

the four project areas to avoid inadvertent 

trespass during implementation.
324

– Somes Bar Integrated Fire Management Project

Appendix B. Response to Comments

Resource Issue Rule Analysis Conclusion Comment

Julie Hoopes and Susan Luidblom, Landowners in Donahue Flat, written comment, 3/1/2017

Transportation Wants chip seal on 

Donahue flat road to 

reduce dust.

40 CFR §1500.2(d). Policy. 

Encourage and facilitate public 

involvement in decision, which 

affect the quality of the human 

environment.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

A USFS representative would contact the landowner 

to address dust abatement options. Notification 

would occur prior to short-term log haul operations.

The USFS considered the landowners 

request to chip seal road segment on 

Donahue Flat Road. The USFS determination 

is the application of spraying the road surface 

with water during hauling would be sufficient 

to abate excessive dust and frequent grading 

would mitigate rutting and erosion from 

motorized uses, whereby expensive road 

improvement surfacing is unwarranted.

3

Visuals Wants Douglas-fir 

removed to re-open 

view from home.

40 CFR §1500.2(d). Policy. 

Encourage and facilitate public 

involvement in decision, which 

affect the quality of the human

environment.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

The USFS would contact the landowner prior to tree 

marking identification and invite resident to 

coordinate with field crews on-site when tree 

marking occurs and where removal of such 

Douglas-fir trees meets the marking prescription 

described in the EA.

USFS would be responsive to the 

landowners request via on-site coordination 

during tree marking identification.

4

Fuels Manually remove tan 

oak root balls.

40 CFR §1500.2(d). Policy. 

Encourage and facilitate public 

involvement in decision, which 

affect the quality of the human 

environment.

The USFS would contact the landowner to discuss 

their requests for removing tan oak root balls and 

pruning branches. They may accommodate selective 

application along the boundary line and be responsive 

to landowner participation in implementation within the 

500-foot defensible space interface.

The USFS is responsive to the landowner’s 

request for site-specific treatments.

5

Limb branches to tan 

oak <4′′ as far as you 

can reach.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

The Western Klamath Restoration Partnership 

(WKRP) designed the treatments to thin re-sprouting 

tanoak clumps and limbing of low-lying branches 

where needed to reduce ladder fuel concentrations.

The Proposed Action would treat low-lying 

limbs.

Lands Nantucket Creek to 

Donahue Flat has 

overland water line; if 

we build a fire line 

around the water line, 

elk will use it as a trail 

and break the water 

line.

40 CFR §1500.2(d). Policy. 

Encourage and facilitate public 

involvement in decision, which 

affect the quality of the human 

environment.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

The USFS would contact the landowner to discuss 

ways to best protect overland waterline damage 

from elk known to dwell in this area. Firelines could 

be relocated as an option.

The USFS is responsive to the landowner’s 

request to ensure protection of overland 

private property.

6
Final Environmental Assessment 

– 325

Appendix B. Response to Comments

Resource Issue Rule Analysis Conclusion Comment

Planning Move to Teneyke as 

part of next project.

40 CFR §1500.2(d). Policy. 

Encourage and facilitate public 

involvement in decision, which 

affect the quality of the human 

environment.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

WKRP recognizes the community’s interest to begin 

considering the location and size of the next project 

and planning strategy for fulfilling federal and state 

procedural mandates. The recommendation would 

be considered.

WKRP is responsive to public input of where 

to plan the next project.

7

Transportation Make sure the road 

stays open 

(sidewinder to Dillion).

40 CFR §1500.2(d). Policy. 

Encourage and facilitate public 

involvement in decision, which 

affect the quality of the human 

environment.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

WKRP would coordinate with the landowner to 

ensure public road access from sidewinder to Dillion 

during operations.

The USFS would provide motorized access 

to private land inholdings during logging 

operations.

8

Public 

Information

FS needs to do a 

better job in notifying 

landowners prior to 

burning.

See comment #2. See comment #2. See comment #2.

9

Dean Hepp, Orleans Resident, oral comments 3/1/2017. See meeting notes.

Support for project, 

covers a lot of ground. 

Northern side of 

rogers creek, if gets 

burned, then outside 

of unit could be 

burned.

40 CFR §1506.6 Public 

involvement. Agencies shall: (a) 

Make diligent efforts to involve the 

public in preparing and 

implementing their NEPA 

procedures.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

WKRP appreciates the support of local residents, as 

it will require an “all-lands” approach to achieve 

defensible space for those living in the wildlandurban interface (WUI). Also see comment #40.

Scoping comment indicates support for 

WKRP’s proposed treatments.

10
326

– Somes Bar Integrated Fire Management Project

Appendix B. Response to Comments

Resource Issue Rule Analysis Conclusion Comment

Sue Terrence, Salmon River resident, oral comments/question, 3/1/2017. See meeting notes.

Implementation Will the collaborative 

be part of the 

implementation? Will 

the collaborative have 

a say on who gets 

awarded the contracts?

40 CFR §1501.2(d). Apply NEPA 

early in the process. Provide for 

cases where actions are planned by 

private applicants or other nonfederal entities before federal 

involvement so that:

(1) Policies or designated staff are 

available to advise potential 

applicants of studies or other 

information foreseeably required for 

later federal action.

(2) The federal agency consults 

early with appropriate state and 

local agencies and Indian tribes and 

with interested private persons and 

organizations when its own 

involvement is reasonably 

foreseeable.

(3) The federal agency commences 

its NEPA process at the earliest 

possible time.

WKRP initiated and participated in the 

interdisciplinary team (IDT) to develop the Somes 

Bar Integrated Fire Management Project (Somes 

Bar Project) and fulfill procedural and 

documentation requirement per the NEPA. The 

USFS is responsive to residents expressing interest 

to participate in implementing and/or monitoring of 

the Somes Bar Project. Ultimately, the authority of 

who is awarded contracts resides with the USFS, as 

the agency with delegated administrative authority.

The USFS is considering a variety of administrative 

procedures for implementation including;

stewardship agreements, stewardship contracts, 

timber sale and service contracts, participating and 

cost-share agreements and Interagency 

agreements. Residents would have an opportunity 

to provide recommendations of who should be 

awarded contracts for the Forest Service to 

consider. The 30-day comment period on the 

forthcoming draft environmental assessment (EA) 

will be provided as an opportunity to again bring 

forward this question.

Community members will be consulted to 

develop an implementation strategy and local 

labor interests and capacity.

The district ranger shared the USFS position 

at the public meeting during the Scoping 

period.

11

Deja Malone-Persha, Somes Bar resident, oral comments, 3/1/2017

Fuels Can see how this 

project will make 

things safer for these 

properties in the long 

run.

40 CFR §1500.2(d). Policy. 

Encourage and facilitate public 

involvement in decision, which 

affect the quality of the human 

environment.

40 CFR §1506.6 Public 

involvement. Agencies shall: (a) 

Make diligent efforts to involve the 

public in preparing and 

implementing their NEPA 

procedures.

WKRP appreciates the support of local residents, as 

it will require an “all-lands” approach to achieve 

defensible space for those living in the WUI. Also, 

see comment #40.

Scoping comment indicates support for 

WKRP’s proposed treatments.

12

Marshall Hansen, Orleans resident, oral comments via landline, 3/3/2017

Fuels Are you aware of the 

storm damage in the 

project area? Looks 

like a war zone, trees 

down everywhere.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

The USFS has inventoried the storm damage and 

recognized the increased fuel loading. Much of the 

excessive fuels adjacent to roads in and around the 

project area was removed during emergency wildfire 

suppression actions in the summer and fall of 2017.

The USFS has inventoried and plans to treat 

fuel concentrations throughout the project 

area to address resident concerns. 13
Final Environmental Assessment 

– 327

Appendix B. Response to Comments

Resource Issue Rule Analysis Conclusion Comment

NEPA Didn’t receive the 

scoping letter until after 

the public meeting.

§1506.6 Public involvement.

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures; (b) Provide 

public notice of NEPA-related 

hearings, public meetings, and the 

availability of environmental 

documents so as to inform those 

persons and agencies who may be 

interested or affected; (1) In all 

cases the agency shall mail notice 

to those who have requested it on 

an individual action.

The USFS identified an inadvertent error in the 

mailing list (he is a part-time resident in Orleans; 

apparently the Orleans Post Office forwarded the 

direct mailing to his McKinleyville address). The 

USFS called the resident and will send future notices 

by email to Mr. Hansen, as requested. The USFS 

shared that he would receive future notifications for 

the upcoming 30-day review and comment period on 

the draft DEA and 45-day objection period on the final 

EA and draft decision notice.

The USFS identified an inadvertent mailing 

error and would send notification by email in 

the future, as Mr. Hansen’s preferred method 

of contact. His email address has been 

included in the project’s mailing list.

14

Fuels Is in favor of thinning 

the forest.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

WKRP appreciates the support of local residents, as 

it will require an “all-lands” approach to achieve 

defensible space for those living in the WUI. Also, 

see comment #40.

Scoping comment indicates support for 

WKRP’s proposed treatments.

15

Economics Expressed general 

support for the project. 

Have we received any 

funding?

40 CFR §1502.23. Cost-benefit 

analysis. For the purposes of 

complying with the Act, the 

weighing of the merits and 

drawbacks of the various 

alternatives need not be displayed.

The USFS called Mr. Hansen to share an update on 

the WKRP funding secured to date, including the 

NFWF grant recently received.

Scoping comment indicates support for 

WKRP’s proposed treatments. The Forest 

Service responded to Mr. Hansen question 

regarding funding status. 16

Bruce Hayes, Sierra Pacific Industries

Implementation Focus on mechanical 

units first.

40 CFR §1502.23. Cost-benefit 

analysis. For the purposes of 

complying with the Act, the 

weighing of the merits and 

drawbacks of the various 

alternatives need not be displayed.

WKRP designed the Somes Bar Project so there is 

a progression of work. In many cases, the roadside 

fuelbreak units planned for mechanical removal of 

ladder fuels is the highest priority to implement, as 

pre-treatment is critical to allow for the safe 

application of prescribed fire within burn plan 

specifications.

In many cases, the progression of work 

designed for the Proposed Action would 

focus on mechanical units first.

17

Economics Where are the funds 

coming from for noncommercial work?

40 CFR §1502.23. Cost-benefit 

analysis. For the purposes of 

complying with the Act, the 

weighing of the merits and 

drawbacks of the various 

alternatives need not be displayed.

WKRP would apply contracting and agreement 

authorities to use revenue from commercial sale of 

forest byproducts to fund non-commercial work. 

WKRP would also seek other federal and state 

grant funding opportunities.

WKRP would seek multiple funding sources 

to complete non-commercial work.

18

Fuels Will private lands 

owners be 

compensated if control 

burns go onto private 

land and FS be held 

responsible?

40 CFR §1505.3 Implementing the 

decision. Agencies may provide for 

monitoring to assure that their 

decisions are carried out and 

should do so in important cases.

The landowner can file a tort claim as the process 

for being compensated for unintentional damages.

Private lands owners would be compensated 

if control burns go onto private land and the 

USFS is held responsible. 19
328

– Somes Bar Integrated Fire Management Project

Appendix B. Response to Comments

Resource Issue Rule Analysis Conclusion Comment

Robert Rohde, Orleans resident

Planning EA conducted for only 

one of the four focal 

areas. Ti Bar location is 

a good place to start.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

In 2013, the WKRP convened workshops and utilized 

an Open Standards Process for Conservation 

planning for the entire Middle Klamath sub-basin. The 

project areas were selected because they protect 

some of the most at-risk private lands in the Orleans 

and Somes Bar communities, while pre-treating 

flammable vegetation so unplanned wildfires can 

become a restorative management tool for resource 

benefits on the west side of the Marble Mountain 

Wilderness.

WKRP considered the recommendation to 

start implementation in the Ti Bar project 

area. The decision was to proceed with a 

progression of work strategy throughout all 

four project areas. 20

Cultural Does not support work 

so close to the Tribes 

Center of the World.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

This project has been conceptualized and planned 

in close consultation and coordination with the 

Karuk Tribe as well as in collaboration with the 

WKRP of which the Tribe is a co-lead.

The Tribe is supportive of implementing the 

currently identified project footprint to 

improve landscape condition so more 

burning in a manner consistent with Karuk 

customs and culture can safely occur.

21

John Stoa, Somes Bar grape grower and winemaker

Air Quality Concerned about 

smoke tainting 

commercial grape 

products (and the 

economic 

consequences of 

tainted grapes). 

Requests no burning 

in August or 

September. Impacts 

can occur from the first 

week of September to 

early October, 

although some 

harvests do extend

into November.

40 CFR §1501.2 (a). Apply NEPA 

early in the process. Comply with 

the mandate of section 102(2)(A) to 

“utilize a systematic, 

interdisciplinary approach which will 

insure the integrated use of the 

natural and social sciences and the 

environmental design arts in 

planning and in decision-making 

which may have an impact on 

man’s environment,” as specified by 

§1507.2.

The USFS would notify and coordinate with Mr. 

Stoa on the timing prescribed burning to mitigate 

smoke tainting of commercial grape products.

The USFS would coordinate prescribed 

burning operations near the Somes Bar grape 

vineyard to address landowner concern.

22
Final Environmental Assessment 

– 329

Appendix B. Response to Comments

Resource Issue Rule Analysis Conclusion Comment

F. Kanawha-Dedali Lake, Orleans Resident

Cultural Supports project 

cultural/Rx burning 

and emphasis on the 

WUI as long as it’s 

aligned with National 

Cohesive Strategy.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

The WKRP aims at transforming the fire exclusion 

paradigm to one of holistic landscape management 

practice in alignment with the National Cohesive 

Wildland Fire Management Strategy. The Somes Bar 

Project seamlessly integrates, in practice, principles 

underlying the Cohesive Strategy and Karuk 

traditions passed down and preserved over 

generations for millennia. The project areas were 

selected because they protect some of the most atrisk private lands in the Orleans/Somes Bar WUI, and 

would bring the community closer to being able to use 

unplanned wildfires for resource benefits on the west 

side of the Marble Mountain Wilderness.

Within the Katimiin Cultural Management Area, 

Karuk ceremonial burning practices are intended to 

be restored and part of what this project does is 

begin to put the land into a condition that will enable 

these ceremonial burning activities to occur once 

again, consistent with Forest Plan direction.

Scoping comment indicates support for 

WKRP’s proposed treatments.

23

Cultural Prioritize treatments in 

WUI by working with 

WKRP partners.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

See comment #18. The Somes Bar Project prioritizes treatments 

in WUI, developed by the WKRP partners.

24

Cultural Prioritize treatments 

that promotes 

resiliency and diversity 

of forest 

plants/animals.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

The proposed fuel treatments are designed to 

enhance cultural and ecological resources and 

reinstate traditional tribal practices dependent on 

the use of fire as a land management tool, and to 

preserve plant and animal species that depend on 

habitats maintained by frequent fires.

The Somes Bar Project prioritizes treatments 

that promote resiliency and diversity of forest 

plants/animals. 25
330

– Somes Bar Integrated Fire Management Project

Appendix B. Response to Comments

Resource Issue Rule Analysis Conclusion Comment

Cultural Promote access by 

reducing surface and 

ladder fuels for 

gathering and 

improved wildlife 

habitat. Integrate TEK.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

The Somes Bar Project was designed in concert 

with the Katimiin Memorandum of Understanding 

between the Karuk Tribe, Six Rivers and Klamath 

national forests (SRNF and KNF), which establishes 

a working partnership between those entities with 

respect to management activities and opportunities 

within and adjacent to the Katimiin Cultural 

Management Area. The project puts into practice 

some of the principles from the Karuk Tribe’s draft 

Eco-Cultural Resources Management Plan 

(ECRMP), which is an over-arching planning 

document that aims at establishing a unified 

approach to managing the human, cultural/natural 

resources, and interests of the Karuk Tribe.

The project would establish up to 250,000 linear feet 

of ridgetop Strategic Fire Control Features (SFCF) 

and implement 5,500 acres of landscape-scale 

integrated vegetative, fuels reduction and 

restorative prescribed burning alongside roads and 

in interior forests, phased over 15 years.

The Somes Bar Project promotes access by 

reducing surface and ladder fuels for 

gathering and improved wildlife habitat, 

integrating traditional ecological knowledge 

(TEK) principles and practices.

26

Cultural Develop and promote 

collaborative 

opportunities for 

broader inclusion of 

partners for 

implementation.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

See comment #11. See comment #11.

27

WKRP collaborative

NEPA Thank you for your 

commitment to the 

collaborative 

development of this 

project.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

The WKRP is dedicated to shared-learning by doing.

The Somes Bar Project exemplifies participatory 

planning wherein all contributors share 

responsibilities for each other’s safety and well-being, 

and for preserving the nation’s natural resources as 

our cultural legacy imparted to future generations.

Scoping comment indicates support for forest 

leadership’s commitment to the collaborative 

development of this project. 28
Final Environmental Assessment 

– 331

Appendix B. Response to Comments

Resource Issue Rule Analysis Conclusion Comment

NEPA Continue with research 

and monitoring aspects 

of the project to 

broaden the public’s 

understanding of 

project goals and 

objectives.

40 CFR §1505.3 Implementing the 

decision.

Agencies may provide for 

monitoring to assure that their 

decisions are carried out and 

should do so in important cases. 

Mitigation (§1505.2(c)) and other 

conditions established in the 

environmental assessment, or 

during its review and committed as 

part of the decision shall be 

implemented by the lead agency or 

other appropriate consenting 

agency or partners.

The WKRP is dedicated to shared-learning by doing. 

The Somes Bar Project multiparty monitoring (MPM) 

strategy would be the primary learning mechanism as 

a Partnership, and as a community, about and from 

the project. The goal is to further refine the strategy 

during the planning process.

WKRP is fully dedicated to continued research 

and monitoring aspects of the Somes Bar 

Project to broaden the public’s understanding 

of project goals and objectives.

29

NEPA Fully analyze the ‘no 

action’ alternative.

40 CFR §1502.14 Alternatives 

including the Proposed Action.

This section is the heart of the 

environmental impact statement. In 

this section, agencies shall: (d) 

Include the alternative of no action.

The No Action Alternative would be analyzed in 

detail and disclosed in the final EA.

The USFS would develop and analyze the no 

action alternative in detail and discuss the 

effects in the final EA per the Council of 

Environmental Quality (CEQ) regulations. 30
332

– Somes Bar Integrated Fire Management Project

Appendix B. Response to Comments

Resource Issue Rule Analysis Conclusion Comment

The Conservation Congress

Wildlife Consider NSO as 

driving force in project 

development.

40 CFR §1508.8. Effects. Effects 

include ecological, aesthetic, 

historic, cultural, economic, social, 

or health, whether direct, indirect, or 

cumulative.

The overall Somes Bar Project purpose, as stated, is 

to “Demonstrate the reintroduction of fire as a step 

towards restoring and maintaining resilient 

ecosystems, communities, and economies in the 

interest of revitalizing balanced human relationships 

with our dynamic landscape”. The project’s Proposed 

Action is to conduct fuels reduction treatments in 

order to restore fire within the project areas.

WKRP designed the proposal addressing the NSO 

as a regulated species, with Pacific fisher as a 

potential surrogate, which is a regalia species 

directly ties to TEK principles. The planning 

approach was from a broad landscape scale 

considering species/habitat function and 

interactions, including recognizing the Pacific fisher 

in fact closely matches the habitat characteristics 

critical to the spotted owl food web. In Karuk culture, 

it is the Pacific fisher that represents NSO habitats 

in the environment. Though owls are known as 

messengers of sickness and death, it is the great 

horned and screech owls that are told to carry these 

specific messages. These two species are known to 

have specific names in the Karuk language. The 

NSO is not known to have a specific name, but has 

been found in practice to be one of the first species 

to decline when the habitat dynamics deteriorate.

Five TEK focal species were selected 

according to the guidelines for the initiation of 

the Somes Bar IFMP and inform the planning 

efforts of the greater WKRP collaborative. The 

focal species represent different components 

of the landscape. Although WKRP considered 

the NSO as one of the five focal species, it 

was not emphasized over the other four focal 

species as a driving force for developing the 

proposed treatments.

The USFS has been working with the Level 1 

team with the goal of receiving a letter of 

concurrence from US Fish and Wildlife 

Service (USFWS) for the project 

determination “May effect not likely to 

adversely affect” NSO and it’s critical habitat 

prior to project implementation.

31

Wildlife No further habitat 

reduction in any AC 

deficient NR or F.

40 CFR §1508.8. Effects. Effects 

include ecological, aesthetic, 

historic, cultural, economic, social, 

or health, whether direct, indirect, or 

cumulative.

During project design, deficit NSO cores received 

additional design features to avoid indirect take of 

an NSO activity center (ACs).

Specific design features:

• No commercial treatment within a NSO nest 

grove or high quality nesting and roosting 

habitat (N/R).

• Treatment of NRF habitat within deficit cores will 

include an 18′′ dbh limit of commercial material 

cut. In N/R habitat, 60% canopy cover will 

maintain habitat suitability. In foraging habitat, 

40% canopy cover will maintain habitat 

suitability post-treatment.

• Temporary roads and landings were dropped 

from consideration during project design if the site 

removed or downgraded suitable NSO habitat

within deficit cores.

Maintaining habitat within deficit NSO ACs 

was a forest priority and was considered 

during project design. Any actions that 

removed or downgraded habitat within deficit 

cores were dropped from consideration to 

prevent “indirect” or direct take of an NSO 

site. The forest’s Level 1 team worked 

extensively with the USFWS to develop a 

project that did not reduce habitat for NSO at 

deficit sites. 32
Final Environmental Assessment 

– 333

Appendix B. Response to Comments

Resource Issue Rule Analysis Conclusion Comment

Wildlife Why are 12 ACs not 

occupied? Are Barred 

owls present? Continue 

with NSO surveys.

40 CFR §1508.8. Effects. Effects 

include ecological, aesthetic, 

historic, cultural, economic, social, 

or health, whether direct, indirect, or 

cumulative.

40 CFR §1502.24 Methodology and 

scientific accuracy.

Agencies shall insure the 

professional integrity, including 

scientific integrity, of the 

discussions and analyses in 

environmental impact statements.

NSO surveys have been conducted and barred owl 

presence has been documented. NSO surveys are 

ongoing and will continue during project activities. The 

analysis area contains NSO activity centers that have 

been active at some point since the early 1990s. Many 

of these ACs have not been active for many years and 

in most cases, the reason for no activity is unknown. 

The Forest is analyzing all possible NSO ACs based 

on information from Forest and California Department 

of Fish and Wildlife databases. The Somes Bar 

Project will protect all high quality habitats (not just oldgrowth), and all spotted owl territories (not just high 

priority sites) and is designed to restore, maintain, and 

accelerate important habitat characteristic for the 

spotted owl. “Maintaining or restoring these forests 

should allow time to determine both the competitive 

effects of barred owls on spotted owls and the 

effectiveness of barred owl removal measures” (II-67 

of the 2011 Recovery Plan).

The BE/BA Reports (Bettaso / Yost 2017) 

and/or field forms documenting survey 

results can be provided upon request.

NSO surveys will continue during project 

implementation.

33

NEPA / Wildlife Include in the EA a 

map showing NSO 

ACs, units proposed 

for mechanical 

treatment and survey 

call points.

40 CFR §1502.24 Methodology and 

scientific accuracy.

Agencies shall insure the 

professional integrity, including 

scientific integrity, of the discussions 

and analyses in environmental 

impact statements. They shall 

identify any methodologies used and 

shall make explicit reference by 

footnote to the scientific and other 

sources relied upon for conclusions 

in the statement.

The map of NSO ACs will be included in the EA. 

Units proposed for mechanical treatment will be 

discussed in detail in the BA. NSO call points are 

maintained in the Somes Bar Project record.

Requested information would be posted on 

the USFS website.

The BE/BA Reports (Bettaso/Yost 2017) 

and/or field forms documenting survey 

results will be provided.

34
334

– Somes Bar Integrated Fire Management Project

Appendix B. Response to Comments

Resource Issue Rule Analysis Conclusion Comment

Wildlife What condition is the 

LSR in that is partially 

in the project area and 

what its primary 

purpose as defined in 

the NWFP?

40 CFR §1502.24 Methodology and 

scientific accuracy.

Agencies shall insure the 

professional integrity, including 

scientific integrity, of the discussions 

and analyses in environmental 

impact statements. They shall 

identify any methodologies used and 

shall make explicit reference by 

footnote to the scientific and other 

sources relied upon for conclusions 

in the statement.

The Klamath National Forest Forest-Wide Late 

Successional Reserve (LSR) Assessment (LSRA 

1999) determined that this LSR was deficient in latesuccessional habitat. Portions of the LSR prior to its 

designation were harvested, therefore, extensive 

stands of dense plantations exist that not only 

create a fuels hazard, they also do not provide 

suitable habitat for late-successional species such 

as the northern spotted owl (NSO). Plantations and 

young natural stands are even-aged and lack the 

horizontal and vertical diversity components 

associated with late-mature stands.

The Somes Bar Project proposes to treat 49.4 acres 

of LSR. Of this, 37.5 acres is manual prescribed 

fuels. The remaining 11.9 acres is mechanical 

treatment consisting of 60% canopy closure and 

removing trees less than 20′′.

The desired condition for the LSR and the 

2011 Revised NSO Recovery Plan is for latesuccessional habitat to be resistant to largescale disturbance. Connectivity for latesuccessional species to be maintained across 

the analysis area. Management activities do 

no not create dispersal barriers to latesuccessional species. The Proposed Action

will drive the Somes Bar Project towards the 

goals of the 2011 Revised NSO Recovery 

Plan and the KNF LSRA assessment.

35

NEPA / Wildlife 40-60% residual 

canopy cover is the 

bare minimum. 

Burning can reduce 

this even more should 

it get out of control.

40 CFR §1502.24 Methodology and 

scientific accuracy.

Agencies shall insure the 

professional integrity, including 

scientific integrity, of the discussions 

and analyses in environmental 

impact statements. They shall 

identify any methodologies used and 

shall make explicit reference by 

footnote to the scientific and other 

sources relied upon for conclusions 

in the statement.

The Proposed Action treatment design for minimum 

canopy closure includes adjustments in tree marking 

(mechanical) canopy closure, as well as follow up 

manual treatments to further reduce fuel loading and 

the potential for any incidental torching of tree crowns 

during prescribed burning operations.

WKRP considered the potential for canopy 

loss from incidental torching during burning 

operations so minimum residual canopy 

closure would not fall below retention 

objectives at the completion of all phased 

treatments; including consideration for 

prescribed fire maintenance operations. 36

NEPA / Wildlife Recommends 18′′ dbh 

cutting limit in natural 

stands and cable units.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

Treatment of NRF habitat within deficit cores will 

include an 18′′ dbh limit of commercial material cut. 

In N/R habitat, 60% canopy cover will maintain 

habitat suitability. In foraging habitat, 40% canopy 

cover will maintain habitat suitability post-treatment.

WKRP considered retaining all trees over 18′′ 

diameter; however, preliminary review 

indicates fuels, TEK and ecological objectives 

would be compromised at a landscape-scale 

with the use of this prescription.

37
Final Environmental Assessment 

– 335

Appendix B. Response to Comments

Resource Issue Rule Analysis Conclusion Comment

NEPA “Less desirable conifer 

species” for what? 

Needs further 

explanation.

40 CFR §1501.2 (a). Apply NEPA 

early in the process. Comply with 

the mandate of section 102(2)(A) to 

“utilize a systematic, 

interdisciplinary approach which will 

insure the integrated use of the 

natural and social sciences and the 

environmental design arts in 

planning and in decision-making 

which may have an impact on 

man’s environment,” as specified by 

Sec. 1507.2.

Karuk stories commonly tell of the relationship of 

people today to the Ikxareyavs, and on the role of 

Coyote in establishing that transition. Coyote is a 

trickster figure and helper of mankind. This story 

tells of how Coyote stole fire. In this story, several 

key themes emerge. The story represents the 

transition from the time of Spirit People to the time 

of people, and it defines their relationship to the 

world. This transition is marked by the howling of 

dogs. Three things happen simultaneously: the 

appearance of fire by the river, the transformation of 

the Spirit People, and the emergence of mankind. 

They are linked. Fire is crucial to who people are, 

and what they do. It enables them to live. It is a 

central component of that duty of care for the whole 

world, which is inherited form their common 

ancestry as Spirit People.

Five focal species have been selected according to 

these guidelines for the initiation of the Somes Bar 

Project and inform the planning efforts of the greater 

WKRP collaborative. The fisher is not just associated 

with the conifer forests, but also with the upland oak 

stands, which are traditionally more open and contain 

bunch grasses. The fisher plays a very central role in 

ceremony and culture: this is the species that is 

carried through the World Renewal Ceremonies by 

way of holding the arrows used to pierce the earth 

and wake up the world.

The favored form of traditional gathering foods are 

acorns from tanoaks; black oaks are used also. For 

this reason, retention of oaks would be prioritized 

over Douglas-fir, removed when its crown is 

overtopping or shading the crown of the oak.

WKRP designed the Proposed Action to 

enhance survival and health of oak species, 

requiring the removal of select conifer species.

38

Wildlife Post BE/BA and FWS 

consultation on 

website.

40 CFR §1502.24 Methodology and 

scientific accuracy.

Agencies shall insure the 

professional integrity, including 

scientific integrity, of the 

discussions and analyses in 

environmental impact statements.

The USFS posts the BE/BA and FWS consultation 

communication on website as a standard practices 

along with the final EA and draft decision notice (DN).

Requested information would be posted on 

the USFS website.

39
336

– Somes Bar Integrated Fire Management Project

Appendix B. Response to Comments

Resource Issue Rule Analysis Conclusion Comment

Botany / Wildlife Provide survey data 

for sensitive species 

and findings. Doubts 

survey efforts are 

sufficient due to 

project size.

40 CFR §1502.24 Methodology and 

scientific accuracy.

Agencies shall insure the 

professional integrity, including 

scientific integrity, of the discussions 

and analyses in environmental 

impact statements. They shall 

identify any methodologies used and 

shall make explicit reference by 

footnote to the scientific and other 

sources relied upon for conclusions 

in the statement.

Botany: Most of the project area was considered 

unsuitable for Sensitive species. With range and 

habitat of Sensitive species in mind, the project area 

was stratified emphasizing units with mature forest 

types, specifically those typed as mid-mature 

(without harvest), late-mature (without and with 

harvest), old-growth (without and with harvest). The 

one exception to the mature forest affiliation is the 

early successional species, Thermopsis robusta is 

associated with clearings and road edges—settings 

of periodic disturbance. Road proximity surveys 

were conducted independently for this species by 

Mid Klamath Watershed Council.

As a result of both the pre-field analysis and field 

reconnaissance (to validate spatial information), 

approximately 1,650 of the 5,570 unit acres (30%) 

were surveyed from June to August 2015 for 

vascular and non-vascular Sensitive species. Units 

or portions thereof not subject to survey were 

plantations (seral stage classified as pole-harvest, 

early mature with harvest) and those characterized 

by shrub-dominated communities, or vegetation 

sub-series lacking habitat components for the 

potential Sensitive species.

Surveys resulted in new detections of Cypripedium 

fasciculatum (1), Sulcaria badia (3), Buxbaumia viridis

(1 new/1 known) and Thermopsis robusta (3-4).

The surveys follow standards established in Forest 

Service Manual direction (FSM 2672.42: USDA 

Forest Service 1991) and complies with National 

Forest Management Act (NFMA), NEPA, and 1994 

and 1995 Land and Resource Management Plan 

(Forest Plan) for the KNF and SRNF. Based on the 

effects of the proposed activities, this direction helps 

in the determination whether these activities will 

lead the Forest Service Sensitive species in a trend 

towards Federal listing (FSM 2672.41).

Botany: An estimated 70% of the project 

area was not considered suitable habitat for 

those Sensitive species with the potential to 

occur in the area based upon range and 

habitat requirements.

It is recognized that survey traverses of a 

given unit with habitat elements suitable for 

Sensitive species may inadvertently bypass 

or overlook a setting of suitable habitat, (i.e., 

the “body” of Buxbaumia viridis is <0.5′′ tall 

and grows on advanced decay class logs) 

but good faith efforts by qualified individuals, 

following standard survey were employed.

Specialist report (Hoover 2017) and/or field 

forms documenting survey results can be 

provided upon request.

Survey results will be provided upon 

request.). The wildlife BE is the project 

record for this analysis and provides the 

details for each species determination.

40

Fisheries Show locations of 

cable units relative to 

water resources. Will 

impact to fish, water or 

soil occur?

40 CFR §1508.8. Effects. Effects 

include ecological, aesthetic, 

historic, cultural, economic, social, 

or health, whether direct, indirect, or 

cumulative.

Effects to fish, water, and soil are analyzed in 

Chapter 3.

Chapter 3 analyzes the effects of cable units 

on fish, water and soil.

Cable units occur in the outer 80 feet of 

riparian reserves (total of 22 acres spread 

over 27 units) and therefore are not located 

near water sources and would not impact 

water resources.

41
Final Environmental Assessment 

– 337

Appendix B. Response to Comments

Resource Issue Rule Analysis Conclusion Comment

NEPA Map of towns in 

project area and 

disclose distance to 

treatment units.

The project is entirely located with WUI designated 

in the KNF and SRNF Land and Resource 

Management Plans. The location of treatment units 

relative to private property is disclosed in the EA.

Proposed action treatment maps in the EA 

display treatment units, access roads, and 

private property boundaries. 42

NEPA Timeframe too long, 

with climate change 

there are unknown 

effects in the future. 

Requires an EIS.

40 CFR §1502.24 Methodology and 

scientific accuracy.

Agencies shall insure the 

professional integrity, including 

scientific integrity, of the discussions 

and analyses in environmental 

impact statements. They shall 

identify any methodologies used and 

shall make explicit reference by 

footnote to the scientific and other 

sources relied upon for conclusions 

in the statement.

Supplemental Information Reports (SIRs) are an 

agency’s internal tool used to determine whether 

changed circumstances, or changes in the 

Proposed Action that arise after the agency decision 

require supplementation of an EA.

If there are substantial physical changes to the 

environment within the WKRP project areas or TEK 

field-based studies, western scientific papers, or 

trend data indicates substantial misassumptions 

used to modeling climatic parameters or analysis 

areas used to determine environmental effects area 

disclosed in the Somes Bar Project EA, an SIR 

would be appropriate to evaluate whether 

supplementation is necessary.

For California, scientist Malcolm North recently 

predicted the rise of mega-fires across the state as 

fuel loading and climate change combine to 

overwhelm the most technologically advanced 

firefighting force in history. The potential for changing 

climatic conditions is discussed in Chapter 3.

Changed circumstances and new information 

arise with the passage of time. CEQ’s 40 

Questions (46 FR 18026, at 18036, Q&A 

#32) state, “As a rule of thumb, if the 

proposal has not yet been implemented, or if 

the EA concerns an ongoing program, EA 

that are more than 5 years old should be 

carefully reexamined to determine if the 

criteria in Section 1502.9 compel preparation 

of an EA supplement.” See also Forest 

Service Handbook 1909.15 § 18.03 (“Review 

the environmental documentation of actions 

that are awaiting implementation and those 

of ongoing programs or projects at least 

every 3 to 5 years to determine if the 

environmental analysis and documentation 

should be corrected, supplemented, or 

revised.”). An SIR is the proper tool to 

accomplish the reexamination described in 

CEQ’s 40.

43

Fisheries Mechanical entry in 

RR violates the Forest 

Plan. How will ACS be 

attained?

40 CFR §1501.1 Purpose. (a) 

Integrating the NEPA process into 

early planning to insure appropriate 

consideration of NEPA’s policies 

and to eliminate delay.

Riparian reserve standard and guidelines in the 

Klamath and the SRNF LRMPs. The Klamath NF 

LRMP S&G MA-7 allows for heavy equipment into 

RR for riparian restoration. Silvicultural and fuels 

treatments are permitted in riparian reserves to 

restore riparian vegetation (MA-10 and MA-62).

Baseline conditions of riparian reserves

include areas that had been previously 

harvested prior to riparian reserve designation 

and much of these plantations are now dense 

thickets dominated by Douglas-fir species. 

Past timber harvest practices and wildfire 

suppression creates a need to treat these 

areas. Proposed treatments are designed to 

promote ACS objectives.

44
338

– Somes Bar Integrated Fire Management Project

Appendix B. Response to Comments

Resource Issue Rule Analysis Conclusion Comment

NEPA / Fuels Hysteria around issue 

of wildfire and most is 

myth.

40 CFR §1502.24 Methodology and 

scientific accuracy.

Agencies shall insure the 

professional integrity, including 

scientific integrity, of the discussions 

and analyses in environmental 

impact statements. They shall 

identify any methodologies used and 

shall make explicit reference by 

footnote to the scientific and other 

sources relied upon for conclusions 

in the statement.

40 CFR §1500.1 Purpose (a). The 

NEPA is our basic national charter 

for protection of the environment.

In the Happy Camp Complex fires of 2014, as in the 

fires of 2008, several areas were noticed that 

burned at sufficient temperatures to kill all the plants 

and to prevent any significant regeneration. This 

danger is especially acute because of the overall 

lack of fire across the WKRP planning area. Few 

areas have seen five fires in the last century, and 

most of the project area has seen none at all 

(Harling and Tripp 2014).

The pattern has been set for infrequent, 

uncharacteristically high-intensity fires, instead of 

the traditional practice of introducing frequent, 

designed, and regular fires at low intensity. By not 

taking action on the project landscapes, the 

continued lack of fire would drive stands further and 

further from their historic conditions.

WKRP applied professional integrity, 

including scientific and TEK integrity, to 

develop the Proposed Action and predict the 

effects disclosed in the final EA.

45

Vegetation / 

Cultural

Myths: restoration of 

forest is needed to 

recreate historical 

conditions.

40 CFR §1502.24 Methodology and 

scientific accuracy.

Agencies shall insure the 

professional integrity, including 

scientific integrity, of the discussions 

and analyses in environmental 

impact statements. They shall 

identify any methodologies used and 

shall make explicit reference by 

footnote to the scientific and other 

sources relied upon for conclusions 

in the statement.

The Proposed Action treatments provide for the

reintroduction of prescribed fire. The 

accomplishment of this goal would in turn revitalize 

TEK, practice, and belief systems. The 

reintroduction of fire as a cultural environmental 

management practice promises to mitigate if not 

remediate the era of wildland fire exclusion and past 

management or clearcut logging practices, as well 

as to promote the cultural use species traditionally 

utilized across the landscape.

One of the most threatened species is the California 

black oak (Quercus Kelloggii), which is vulnerable to 

being overtopped and crowded out by Douglas-fir. 

All the same, the Oaks that remain are old and 

serve as indicators of an ancestral state. One of the 

biggest deficits on the landscape is the old upland 

oak woodland. The development of the TEK data 

collection forms has helped summarize most of the 

characteristics of these remnant stands.

Because modern human alteration of many 

ecosystems has been so profound, reference states 

must often be derived from historical information from 

before the onset of anthropogenic change. 

Maintaining managed ecosystems within the bounds 

of the “historical range of variation” for key ecosystem 

patterns or processes has traditionally been seen as 

the best hope for preserving species and landscapes 

and ensuring long-term ecological sustainability 

(Egan and Howell 2001, Landres et al. 1999).

WKRP applied TEK and western science as 

driving forces in designing restoration 

treatments. Archaeological and cultural 

resources surveys document evidence of 

human management throughout the project 

area.

46
Final Environmental Assessment 

– 339

Appendix B. Response to Comments

Resource Issue Rule Analysis Conclusion Comment

Fuels Myth: Logging reduces 

large wildfires

40 CFR §1502.24 Methodology and 

scientific accuracy.

Agencies shall insure the 

professional integrity, including 

scientific integrity, of the discussions 

and analyses in environmental 

impact statements. They shall 

identify any methodologies used and 

shall make explicit reference by 

footnote to the scientific and other 

sources relied upon for conclusions 

in the statement.

The reintroduction of fire as a cultural environmental 

management practice promises in the long-term to 

mitigate if not remediate the era of wildland fire 

exclusion, as well as to promote the cultural use 

species traditionally utilized across the landscape. 

The Somes Bar Project is not designed to reduce 

large wildfires.

The proposed treatments are designed to 

allow the reintroduction of prescribed fire, 

while achieving desired prescribed fire effects. 

The accomplishment of this goal would in turn 

revitalize TEK practice, and belief systems. 

WKRP applied professional integrity, 

including TEK and scientific integrity, to 

develop the Proposed Action.

47

Fuels Myth: Thinning will 

protect homes.

40 CFR §1508.8. Effects. Effects 

include ecological, aesthetic, 

historic, cultural, economic, social, 

or health, whether direct, indirect, or 

cumulative.

40 CFR §1502.24 Methodology and 

scientific accuracy.

Agencies shall insure the 

professional integrity, including 

scientific integrity, of the discussions 

and analyses in environmental 

impact statements. They shall 

identify any methodologies used and 

shall make explicit reference by 

footnote to the scientific and other 

sources relied upon for conclusions 

in the statement.

Between 2006 and 2011, about 600 assessments 

were completed by the Forest Service on wildfires 

that burned into areas where hazardous fuels 

reduction treatments had previously been 

conducted (Stein et al. 2013). These assessments 

evaluated the effects of prescribed fire as well as 

mechanical and chemical treatments on fire 

behavior and fire suppression actions. The data 

indicate that 90 percent of treatments reported in 

the database have helped to reduce wildfire 

intensity, allowing better control by firefighters. In 

most of these cases, as fires moved from untreated 

locations to areas treated by thinning, mowing, or

prescribed burning, the fire behavior changed from 

active crown fires (burning an entire upper story of 

the forest) to passive crown fires (where only a 

single tree or small group of trees burned), or from 

passive crown fires to surface fires (burning only dry 

grass, shrubs, pine needles, and other flammable 

materials on the ground (DellaSala and others 2004, 

Stein et al. 2013).

WKRP designed the Somes Bar Project to 

strategically establish roadside and ridgeline 

fuelbreaks, private land 500 ft. defensible

space buffers, and reduce fuels across the 

landscape to alter forest components; all 

designed so fire managers would be able to 

provide a measure of protection to 

communities and establish anchor points

where prescribed fire could be safely 

employed.

48
340

– Somes Bar Integrated Fire Management Project

Appendix B. Response to Comments

Resource Issue Rule Analysis Conclusion Comment

NEPA Only include 

plantations up to 60 

years old. Drop mature 

stands and cable units 

from project.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

There are approximately 1,481 acres of plantations 

in Somes Bar Project area.

The purpose of the Somes Bar Project is to 

demonstrate how fire restores and maintains 

resilient ecosystems, communities, and 

economies to revitalize balanced human 

relationships with our dynamic landscape. 

The project would also reinstate the use of 

TEK fire integrated with emergent restorative 

fire practices at the landscape scale.

WKRP considered this alternative. 

Preliminary analysis indicates an estimated 

25% of the landbase within the four project 

area would be treated. Large segments 

alongside roads, ridgelines and private 

property would not be treated. As this 

alternative would not be responsive to 

landscape scale restoration and defensible 

space treatment objectives or purpose and 

need, this alternative was eliminated from 

detailed study. The need for manipulating 

fuel patterns and lowering the amount of 

flammable surface fuels represents an 

incremental step on the journey to address 

the fire deficit, that otherwise would be 

deferred to set the stage for a more 

hazardous future.

49

Vegetation / 

Fuels

Myth: Beetle 

outbreaks increase the 

chances of wildfire.

40 CFR §1502.24 Methodology and 

scientific accuracy.

Agencies shall insure the 

professional integrity, including 

scientific integrity, of the discussions 

and analyses in environmental 

impact statements. They shall 

identify any methodologies used and 

shall make explicit reference by 

footnote to the scientific and other 

sources relied upon for conclusions 

in the statement.

Thinning from below increases the residual size of 

trees left in a stand (Agee and Skinner 2005; Smith 

et al. 1997). In general, larger trees have thick bark, 

and are therefore more fire resilient than smaller 

trees. Thinning, no matter whether from below or 

throughout the diameter classes (with the exception 

of pre-dominant and dominant trees), increases 

spacing and reduces stand densities, resulting in 

less inter tree competition, which increases 

individual tree vigor, resulting in stands that are 

more resilient to insects, disease, wildland fire, and 

drought (Agee and Skinner 2005; Fettig et al. 2007; 

Hessburg et al. 2016; van Mantgem et al. 2009; 

Vernon 2017).

With currently high stand densities throughout the 

project area comes increased susceptibility to 

damage and mortality resulting from such stressors 

as insects, disease, fire, and drought (Agee and 

Skinner 2005; Condeso and Meentemeyer 2007; 

Fettig et al. 2007; Vernon 2017). Many trees are 

currently experiencing high levels of competition for 

soil moisture, nutrients, and available light.

The WKRP recognizes beetle outbreaks can 

cause tree mortality and can contribute 

flammable woody fuels. However, the limited 

extent of insect mortality within the four 

project areas is currently not sufficient to 

significantly alter fire behavior.

50
Final Environmental Assessment 

– 341

Appendix B. Response to Comments

Resource Issue Rule Analysis Conclusion Comment

Fuels Another study done by 

fire ecologists at the 

Missoula Fire Lab 

concluded: "Even 

extensive fuel 

treatments may not 

reduce the amount of 

area burned over the 

long-term and 

furthermore, reduction 

of area burned may 

actually be an 

undesirable outcome. 

A new study soon to 

be published found 

that reviewed 1,500 

wildfires between 1984 

and 2014 found that 

actively managed 

forests had the highest 

level of fire severity. 

While those forests in 

protected areas 

burned, on average, 

had the lowest level of 

fire severity. In other 

words, the best way to 

reduce severe fires is 

to protect the land as 

wilderness, not 

“manage” it.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

40 CFR §1502.24 Methodology and 

scientific accuracy.

Agencies shall insure the 

professional integrity, including 

scientific integrity, of the discussions 

and analyses in environmental 

impact statements. They shall 

identify any methodologies used and 

shall make explicit reference by 

footnote to the scientific and other 

sources relied upon for conclusions 

in the statement.

WKRP designed the Somes Bar Project to 

demonstrate how prescribed fire restores and 

maintains resilient ecosystems, communities, and 

economies to revitalize balanced human 

relationships with our dynamic landscape.

The project would also reinstate the use of TEK fire 

integrated with emergent restorative fire practices at 

the landscape scale thereby: Reestablishing 

frequent fire cycles, behavior and patterns 

stimulating resilient, spatially heterogeneous forest 

and riparian habitats and self-sustaining populations 

of culturally important Karuk focal species and 

traditions. Promote shared values, encourage 

widespread personal ownership and local technical 

skills leading to healthy communities and 

economies, capable of well-coordinated land 

stewardship regardless of ownership or 

administrative boundaries.

WKRP applied professional integrity, 

including scientific integrity, to develop the 

Proposed Action. The planning approach 

incorporates TEK prescribed fire principles 

and practices rather than optimizing fire 

suppression. The Karuk skillfully used fire as 

caretakers of the land, as an instrument in 

cooperation with nature to expertly cultivate 

cultural use plants, invigorate forage for elk, 

deer and other wildlife, emit smoke to 

suppress insect infestations and promote 

periods of inversion cooling for anadromous 

fisheries reliant on cold water. Over 80% of 

the plants utilized by Karuk people depend 

on restorative fire for germination, as well as 

the use quality and quantity of the plant 

materials (Anderson 2006).

51

Bruce Robison

NEPA / 

Vegetation

Drop words “existing 

condition” when 

describing reducing 

canopy closure.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

The final EA would clarify that reducing canopy 

closure is an effect of proposed treatments.

The USFS would respond by not using 

“existing condition” when describing reducing 

canopy closure in the final EA. 52

NEPA Doug-fir should not be 

considered “less 

desirable”.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

See comment #38. See comment #38.

53
342

– Somes Bar Integrated Fire Management Project

Appendix B. Response to Comments

Resource Issue Rule Analysis Conclusion Comment

Vegetation / 

Fuels

Thin immature tanoaks, 

leave mature oaks.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

During the development of treatment prescriptions, 

WKRP recognized the need to thin immature tanoaks, 

as these ladder fuels would prevent safe application 

of prescribed fire within burn plan intensity 

specifications. Mature fire resistant oaks would be 

retained for ecological and TEK objectives.

WKRP designed the proposed treatments to 

retain mature oaks and thin immature tanoak, 

in alignment with the commenter’s request. 54

NEPA / Logging 

Systems

Feller buncher 

equipment for 

harvesting gives 

excellent results.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

Logging systems are differentiated in terms of 

ground based or cable based systems. 

Harvesting methods may be performed by a 

variety of equipment conducive to the size of 

material to be extracted and surrounding 

terrain.

55

Hydrology Equipment in the outer 

RR is used on S-T 

forest. Goes straight 

in, no turns, very little 

ground disturbance.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

Mechanical equipment would be permitted under the 

Proposed Action in the outer riparian reserve buffer 

at designated location marked on the ground, with 

provisions to minimize ground disturbance. All units 

proposed for entry in outer portions of riparian 

reserves were validated on the ground by qualified 

soils scientist, geologists, hydrologists and fisheries 

biologist.

WKRP designed the proposed treatments to 

allow for machinery within outer portions of

RR buffer in some units, with restrictions for 

turning, which can cause gouging of soils, in 

alignment with the commenter’s request. 56
Final Environmental Assessment 

– 343

Appendix B. Response to Comments

Resource Issue Rule Analysis Conclusion Comment

Max Creasy, Public Meeting 3/1/2017

Fuels 1st entry burn plans 

need to be developed 

separately for low 

severity as well as 

mixed severity 

prescriptions (habitat 

types, location, fuel 

loading). Specific to TiBar Units 2136 and 

2144.

40 CFR §1506.6 Public involvement. 

Agencies shall: (a) Make diligent 

efforts to involve the public in 

preparing and implementing their 

NEPA procedures.

Units 2136 and 2144 lie within the more active 

portions of the Ti Bar earthflow. 2136 is a Manual 

Treatment with Rx Burn Unit with prescriptions 

planned as 4b, 4d, and 5c. Unit 2144 is a prescribed 

fire Only Treatment Unit with prescriptions planned as 

4d, and 5a. 4d is the manual construction of handline. 

4b is Manual Treatment in non-plantations and has the 

goal of reducing ladder fuels by cutting trees and 

shrubs up to 6′ diameter leaving a maximum residual 

spacing of 20 to 24′, and hand pile burning to reduce 

fuels prior to the burning prescription of 5c. The 4b 

treatment allows for focus on stand conditions to plan 

cutting strategy in order to encourage growth of larger 

trees and create openings for shade intolerant 

species. This manual treatment can provide some 

control of future understory burning intensities. Unit 

2136 was changed from a fire only treatment to 

include manual actions in order to prepare the 

landscape based on these comments. Unit 2144 is 

surrounded by additional treatment units, which should 

provide buffers in order to moderate fire effects within 

Unit 2144.

One of the main goals for fuels reduction activities, 

in order to achieve fire management goals, is to 

conduct appropriate fuels activities to prepare 

strategic features, which will support the restoration 

of fire on the landscape through the application of 

prescribed fire. Part of this process is to identify 

sensitive areas which may need special attention or 

specific burn plan elements to be developed (such 

as moist burning conditions to ensure lower level 

fire severity effects, alternating firing patterns, or 

other burn prep actions needed).

While wildfire hazard modeling using the program 

FlamMap does show potential elevated fire behavior 

across a large majority of the project areas, patches of 

Unit 2144 are depicting surface fire only. Additionally, 

LiDAR tree-density modeling shows more specifically

where a portion of higher density trees exist within Unit 

2144 and this information can also be used during the 

planning for implementation activities.

Burn plans would be developed to meet the 

Proposed Action objectives.

57
344

– Somes Bar Integrated Fire Management Project

Appendix B. Response to Comments

Resource Issue Rule Analysis Conclusion Comment

Dean Prat, Senior Engineering Geologist, Regional Water Board, 3/24/2017 comment letter.

Hydrology Project must be 

designed and 

implemented to meet 

the water quality 

standards in Basin 

Plan and comply with 

TMDL allocations.

40 CFR §130.6 Water quality 

management plans.

40 CFR §1501.1 Purpose. (a) 

Integrating the NEPA process into 

early planning to insure appropriate 

consideration of NEPA’s policies 

and to eliminate delay; (b) 

Emphasizing cooperative 

consultation among agencies 

before the environmental impact 

statement is prepared rather than 

submission of adversary comments 

on a completed document.

Effort was made to reduce the risk of sedimentation 

and turbidity relative to the Proposed Action. The 

Basin Plan states that controllable water quality 

factors shall not cause further degradation of water 

quality when it has already been established as 

degraded, and efforts to restore the impaired 

beneficial uses of these watersheds must be made. 

The hydrology analysis of the Somes Bar Project

has focused on minimizing delivery of managementrelated sediment.

A cumulative watershed effects analysis reveals that 

water quality and beneficial uses would not be 

adversely impacted and the project is unlikely to 

result in added detrimental cumulative watershed 

effects The addition to cumulative effects would leave 

the watersheds below the threshold of concern.

WKRP designed and would implement the 

Somes Bar Project in compliance with the 

water quality standards in Basin Plan and 

comply with TMDL allocations.

58

Hydrology Notice of Intent and 

Waiver application 

shall be filed with the 

Regional Water Board 

at least 30 days prior 

to implementation.

Regional Board waiver (Order No. 

R1-2015-0021). A waiver 

application will be filed under Order 

No. R1-2015-0021 once the 

decision document is signed.

Upon signature of the DN, the Waiver Notice of 

Intent (NOI) and application will be send to the 

Regional Water Board at least 30 days prior to 

implementation.

The USFS would fulfill waiver application 

procedures in a timely manner.

59

Hydrology Waiver application 

requires USFS to 

propose treatments of 

all existing legacy sites 

within the project area 

as part of the 

proposed project 

where no Watershed 

Restoration Action 

Plans in the project 

area are on file.

Regional Board waiver (Order No. 

R1-2015-0021). A waiver 

application will be filed under Order 

No. R1-2015-0021 once the 

decision document is signed.

Restoration actions would occur at existing legacy 

sediment source sites, scheduled for treatment in 

compliance with the Clean Water Act as a condition 

of the North Coast Regional Water Quality Control 

Board waiver of waste discharge requirements 

(Order No. R1-2015-0021). No legacy sites occur 

adjacent to anadromous salmonid habitat or 

resident trout habitat. There are 6 segments, totally 

1.1 miles of legacy roads found in the Somes Bar 

Project area. Restoration activities would include:

Excavated road fill would be stored on-site and in 

stable locations.

Construct waterbars drainage features to prevent 

water from concentrating on the roadbed.

Cover disturbed ground with native material 

gathered on sites (tree boughs).

Install earthen log barrier at locations to effectively 

block motor-vehicle access.

All ground disturbing work would occur during the 

dry season, have appropriate erosion control plans 

developed and Best Management Practices (BMPs) 

incorporated into project plans.

WKRP designed the Proposed Action to 

include restoration of legacy sites within the 

Somes Bar Project area.

60
Final Environmental Assessment 

– 345

Appendix B. Response to Comments

Resource Issue Rule Analysis Conclusion Comment

Hydrology USFS shall include 

specific on the ground 

prescriptions designed 

to meet the USFS 

Best Management 

Practices and include 

in all associated 

implementation 

mechanisms.

40 CFR §1502.24 Methodology and 

scientific accuracy.

Agencies shall insure the 

professional integrity, including 

scientific integrity, of the discussions 

and analyses in environmental 

impact statements. They shall 

identify any methodologies used and 

shall make explicit reference by 

footnote to the scientific and other 

sources relied upon for conclusions 

in the statement.

Proximity of ground disturbance to streams is an 

important factor controlling sediment delivery 

(Rashin et al. 2006). A study on the effectiveness of 

BMPs in the state of Washington found that of 212 

erosion features within 10 meters (approximately 30 

feet) of a stream, 67 percent of the features 

delivered sediment to the stream. Of 193 erosion 

features greater than 30 feet from a stream, 95 

percent did not deliver sediment to the stream (ibid).

WKRP has developed the Proposed Action, 

including specific on the ground prescriptions 

designed to meet the USFS BMPs, which 

would be applied and monitored during 

implementation.

61

Hydrology Measures to mitigate 

water quality impacts 

should be included in 

the design of the 

project.

Regional Board waiver (Order No. 

R1-2015-0021). A waiver 

application will be filed under Order 

No. R1-2015-0021 once the 

decision document is signed.

40 CFR §1502.24 Methodology and 

scientific accuracy.

Agencies shall insure the 

professional integrity, including 

scientific integrity, of the 

discussions and analyses in 

environmental impact statements.

See comment #61.

Erosion Prevention and Control. 

Contract/Agreement provisions would state that

operations shall be conducted reasonably to 

minimize soil erosion. Equipment shall not be 

operated when ground conditions are such that 

excessive damage will result. Operator shall adjust 

the kinds and intensity of erosion control work done 

to ground and weather conditions and the need for 

controlling runoff. Erosion control work shall be kept 

current immediately preceding expected seasonal 

periods of precipitation or runoff.

Pre-operation meetings with all parties of the 

implementation mechanism are conducted to inform 

the legal obligations and to approve annual 

operating plan.

WKRP designed and included mitigation 

measures during the development of the 

proposed treatments to lower impacts of 

increased sedimentation predicted to occur 

during and shortly after implementation. The 

USFS informs the contractors of waiver (BMP) 

obligations as standard operating practice.

62
346

– Somes Bar Integrated Fire Management Project

Appendix B. Response to Comments

Resource Issue Rule Analysis Conclusion Comment

Fisheries / 

Hydrology

USFS shall manage 

and maintain 

designated riparian 

zones to ensure 

retention of adequate 

vegetative cover that 

results in natural shade 

conditions as described 

in the Forest Plan.

Forest Service - Bureau of Land 

Management Aquatic Conservation 

Strategy guidance memo (May 22, 

2007). This memo states that in 

order to make the finding that a 

project or management action 

“meets” or “does not prevent 

attainment” of the Aquatic 

Conservation Strategy objectives, 

the analysis must include a 

description of the existing condition, 

a description of the range of natural 

variability of the important physical 

and biological components of a 

given watershed, and how the 

proposed project or management 

action maintains the existing 

condition or moves it within the 

range of natural variability” (1994 

ROD, Attachment B, p. B-10).

Federal Clean Water Act, and the 

California Porter-Cologne Water 

Quality Act, as addressed in the 

Water Quality Control Plan for the 

North Coast Region. This Plan 

contains water quality standards 

that include water quality objectives 

and protection of applicable 

beneficial uses.

Commercial thinning of stands in the outer portion of 

riparian reserves would be beneficial because the 

objectives are to increase the average diameter of 

the stand, and accelerate the development of the 

shade intolerant species. Benefits include reducing

the potential for untreated riparian reserves to 

contribute to the growth of large fires, as well as 

reducing potential for effects from moderate to 

severe burning on soil structure and erosion.

As the climate in this area is similar to the climate in 

western Oregon, the effect that the Somes Bar 

Project would have on stream shade was estimated 

using the model described in the “Northwest Forest 

Plan Temperature TMDL Implementation

Strategies” (USDA and USDI 2010) commonly used 

to calculate widths providing adequate shade for 

riparian buffers in western Oregon. The model 

provides the process for calculating the width of the 

riparian area adjacent to perennial stream channels 

that provides stream shade for the period of 

greatest solar loading (between 1000 and 1400 

hours), known as the primary shade zone. It also 

provides the process for calculating the width of the 

riparian area that provides shade in the morning and 

afternoon (0600 to 1000 hours; 1400 to 1800 

hours), considered to be the secondary shade zone.

In over-dense riparian areas, optimum shade can be 

provided by the primary shade zone alone, and the 

secondary shade zone may contribute little to shade 

since trees in the primary shade zone are already 

blocking the sun’s solar radiation (USDA and USDI 

2005).

WKRP designed the Somes Bar Project to 

ensure retention of adequate vegetative 

cover that results in natural shade conditions, 

in compliance with legal direction including 

the LRMP.

63
Appendix B. Response to Comments

Final Environmental Assessment – 347

Comment Period on the Draft Environmental Assessment

This section discloses the response to public comments received during the 30-day comment period held 

between February 23 and March 26, 2018, in compliance with the National Environmental Policy Act 

(NEPA).

Summary of Comments Received

In response to the release of the draft EA for comment notifications (letter, posting on the Klamath 

National Forest (KNF or forest) website and email), the Responsible Official received written comments 

from one (1) agency, six (6) organizations, and three (3) individuals. Table B-2 provides a compiled 

listing of the names and locations of the commenters, the organization or entity each commenter 

represents, and the type and date of the comment submitted.

Table B-2. Listing of the names and locations of the commenters, the organization or entity each commenter 

represents, and the type and date of the comment submitted.

Comment ID 

Code Commenter Entity Location Type Date of Comment

1 Ben J. Saxon Individual Orleans, CA Email March 12, 2018

2 Chook-Chook Hillman Individual Orleans, CA Email March 12, 2018

4 Will Harling, Director Mid Klamath Watershed Council Orleans, CA Email March 20, 2018

5 Earl Crosby Individual Orleans, CA Email March 20, 2018

6 Ryan Henson, Policy 

Director California Wilderness Coalition Mad River, CA Email March 23, 2018

7 Denise Boggs, Executive 

Director Conservation Congress (CC) Chico, CA Email March 26, 2018

8 Kimberly Baker,

Executive Director Klamath Forest Alliance (KFA) Orleans, CA Email March 26, 2018

9 Thomas Wheeler, 

Executive Director

Environmental Protection 

Information Center (EPIC) Arcata, CA Email March 26, 2018

10 George Sexton, 

Conservation Director

Klamath Siskiyou Wildlands Center 

(KS Wild) Ashland, OR Email March 26, 2018

11

Fred Blatt, Division Chief 

Nonpoint Source & 

Surface Water Protection 

Division

North Coast Regional Water 

Quality Control Board (RWB) Santa Rosa, CA Email March 26, 2018

12 Ron Reed Individual Orleans, CA Verbal March 23, 2018

13 Jeff Juel Alliance for Wild Rockies Missoula, MT Email March 23, 2018
Appendix B. Response to Comments

348 – Somes Bar Integrated Fire Management Project

Response to Comments on the Draft Environmental Assessment

Introduction

The Council on Environmental Quality (CEQ) regulation 40 CFR 1503.4 states that an agency preparing 

an environmental assessment (EA) shall assess and consider comments both individually and collectively. 

The following includes a narrative of public comment statements received, followed by the Forest Service 

responses, organized by resource topic in alphabetical order. The comment statement is taken from the 

written comments. Copies of the written comments received are available upon request, located in the 

project file at the Six Rivers National Forest’s Supervisor’s Office, 1330 Bayshore Way, Eureka, 

California 95501.

The discussion is organized by topic, presented in alphabetical order as follows:

Aquatic Resources (AR)

Botanical Resources (BR)

Cultural Resources (CR)

Fire and Fuels (FF)

General (G)

Soil Resources (SR)

Vegetation (V)

Watershed Values (WV)

Wildlife Resources (WLH)

Aquatic Resources (AR)

1. What are the population trends of ESA-listed and Sensitive fish species in the cumulative effects 

analysis watersheds? (Denise Boggs, CC, p. 17)

Response: Cooperative adult and juvenile surveys are attempted annually for coho, Chinook and 

steelhead trout. The Fisheries BA contains a summary of these three (3) species. Our analysis of factors 

indicating the collective risk to the Southern Oregon Northern California Coast coho salmon’s persistence 

and upward trend toward recovery has not changed significantly since the ESA listing or the development 

of the SONCC coho salmon Recovery Plan (2014) (final Fish BA/BE pp. 52-57).

2. (T)he BA/BE documented the Proposed Action would result in key recovery actions being 

implemented on 5,570 acres of the Mid-Klamath population of coho salmon to reduce the risk of high 

severity fire.” We think the specter of fire is being inappropriately used to justify heavy logging here. 

But consistent with your world view, since the “risk of high severity fire” would persist in these same 

watersheds (in untreated areas) surrounding the four project areas, where is the analysis of this risk? 

(Denise Boggs, CC, p. 16)
Appendix B. Response to Comments

Final Environmental Assessment – 349

Response: The SONCC Coho Recovery Plan (NMFS 2014) identified one of the key limiting threats is 

related to risk of high severity fire. High-severity fires can torch and damage vegetation and tree roots, 

decrease soil porosity, and cause chronic erosion. High severity fires can also introduce large quantities of 

sediment into streams posing a high threat to all life stages of coho. This project addresses specific 

recovery actions including developing a plan for firebreak stewardship and defensible space, 

implementing fire-safe community action plans in identified areas and reducing stand densities through 

prescribed burning and thinning to reduce high severity fire. Reducing the risk of wildfire would also 

benefit Chinook, steelhead and other aquatic organisms, including TEK focal species (final EA p. 223).

Botany Resources

3. The EA does not cite any empirical basis for expected effectiveness of project mitigations for 

Sensitive plants and soils. The FS should drop treatments in areas containing Sensitive plants. 

(Denise Boggs, CC, p. 20)

Response: The project is designed to restore ecological processes pro-actively supporting sensitive plant 

habitats, whereby reliance on mitigations measures is limited to risk of physical harm during operations. 

Discussed in the (final EA pp. 246-251), are the ecological factors of the Forest Sensitive plant species 

associated with this project (Kaye and Cramer 2005) in light of thresholds to disturbance—type, intensity 

and duration of disturbance. For example, Cypripedium fasciculatum (fascicled lady’s slipper orchid) is 

associated with mature forests of relatively high canopy cover. In keeping with the mature forest association 

is the role of forest floor organics, including logs to sustain the mycorrhizal (underground fungi) associates 

that Cypripedium relies upon for nutrients. For this species, activities were reviewed in light of the extent of 

canopy removal, forest floor disturbance, burn severity and burn intervals (final EA p. 251).

This species was detected in a stand where no mechanical treatments are to occur, only manual fuel 

reduction, followed by hand pile burning and prescribed fire actions. Treatment prescriptions target 

smaller ladder fuels, thereby maintaining existing overstory canopy cover. The project design feature 

(PDF) avoids piling and burning of cut vegetation in the buffer area. Buffer areas are marked on the 

ground. This design feature would reduce the concern related to pile burning and the potential for 

localized burn intensity to Cypripedium plants and their mycorrhizal associates (final EA p. 254). 

Subsequent low intensity prescribed burning could occur through the buffer/management area but at no 

less than 5- to 7-year intervals. Prescribed burning would be planned to ensure relatively low intensity 

burns (e.g., thinning where needed), therefore, if the return interval is at the 5-year end of the scale, the 

risk to Cypripedium would be considered low to moderate in light of its presence in forest types that 

experienced natural wildfire (lightning caused) on average at 16-year intervals (final EA p. 134).

Exclusion of prescribed burning through the buffer/management area was determined to be a greater risk 

to this species, than allowing for low intensity prescribed burning in the long run, due to fuel 

accumulation and resultant increased burn intensity as a result of wildfire.

Buffers/PDFs described above for Cypripedium are also in place for other Sensitive species associated 

with mature forest. For those species such as Sulcaria badia that are in mechanical units, directional felling 
Appendix B. Response to Comments

350 – Somes Bar Integrated Fire Management Project

of trees away from the buffer and equipment exclusion are included in the PDF. One (1) species, 

Thermopsis robusta, is associated with early-successional species, disturbance tolerant, and considered a 

fire follower, so burning is not a concern. Occurrences of this species along road edges were flagged to 

avoid disturbance by heavy equipment and related mechanical operations. Individuals of one (1) 

occurrence on an existing landing may be affected by operations but nearby plants adjacent to the landing 

would likely re-establish the landing after operations are completed (Biological Evaluation, Hoover 

2017a). Of the 10 Sensitive species located in the project area, seven (7) are buffered from project activities 

considered disturbing, with buffer size ranging from 625 sq. ft. to 3,750 sq. ft.

4. The EA does not include an analysis of how project activities might exacerbate the spread of 

invasive plants. It is comprised essentially of mitigation measures, and even those are not shown to 

be effective. For example, “With these features included part of the decision for the project, the risk 

of introduction and spread as result of project activities was reduced to a moderate level.” What 

“moderate” means is not explained.” What has not been undertaken is the monitoring of PDF 

effectiveness let alone implementation.” Those are the EA’s words. (Denise Boggs, CC, p. 19)

Response: During the development of the Proposed Action, the interdisciplinary team (IDT) took a hard 

look at the current variety and distribution of invasive species in context of their competitive advantage 

(high dispersal capabilities, relatively long-lived seed banks, high tolerance for disturbance, few 

herbivores, ability to reproduce both sexually via seed and asexually (via rhizomes)), since it leads to 

displacement of native plant communities. The project design is responsive to invasive plant populations 

and spread, particularly in proximity to known sensitive plant populations, traditional cultural priorities 

(TCPs) and riparian habitats. The IDT recognized mitigations would warrant repeated treatments, bearing 

in mind on-going motorized travel to private land inholdings, road maintenance and land development 

(known vectors for introduction and spread of invasive plants), are not within FS authority. The IDT also 

took into consideration Himalayan blackberry, distinguished from the other invasive plant species in the 

project areas, as this species tolerates both shady and exposed settings (Caplan and Yeakley 2006), and 

has the ability to reproduce by cane sprouting that can produce a thicket up to 15 feet in diameter in less 

than two (2) years (Soll 2004), likely to overtop Woodwardia fern and hazel.

Based on extensive surveys conducted for sensitive plants (2015) and invasive plant species (MKWC, 

a partner in 2015), six (6) species of invasive plants were mapped to inform the development of the PDFs 

and mitigations measure for the Proposed Action. The surveys reveal prior introduction and spread of a 

variety of invasive plants and cover, widespread within portions of the Ti Bar, Patterson, and Rogers 

project areas. All four (4) project areas presently feature Himalayan blackberry, yellow star thistle, Dyer’s 

woad, Dalmatian toadflax, Scotch broom, butterfly bush and tree-of-heaven, most dense near State 

Highway 96 (occupying Klamath River bars) and intersecting lower sections of Forest Service roads, 

alongside road edges and clearings (e.g., roadside turn-outs, existing landings, disposal sites).

Considering the conservation of native plant communities and TEK values are at stake, the Proposed 

Action is designed to ameliorate further spread, likely to occur under the No action Alternative. In light of 

the current condition, the project is designed reduce the risk posed by the invasive plant species to spread 
Appendix B. Response to Comments

Final Environmental Assessment – 351

beyond its current location to vulnerable native habitats (e.g., Himalayan blackberry expanding from the 

road edge to the adjacent riparian areas) and into forest habitats where blackberry canes can grow into the 

tree canopy, thus serving as a fuel for wildfire. The EA and Invasive Plant Risk Assessment documents 

identify the specific activities associated with the implementation of the proposed action that could 

increase the risk of introduction and spread of invasive plant species based upon a set of factors. The 

specific actions that would increase the risk are: use of heavy equipment, staging equipment where 

invasive plants exists, reducing canopy cover proximal to invasive plants, and in association with 

prescribed burning, activities that remove native vegetation serving as competition or a barrier to 

movement of invasive plants from the road into the edge of the unit (final EA p. 251; Hoover 2017 p. 3).

The analysis is presented in terms of the risk of introduction and spread based upon the species, its 

ecology (e.g., ability to reproduce from underground stems), its current distribution in the analysis area, 

habitat vulnerability (e.g., grassland versus forested habitats), non-project dependent vectors (e.g., 

existing roads), habitat alteration (e.g., canopy opening) and increased vectors (e.g., heavy equipment) as 

a result of project implementation (final EA p. 250; Hoover 2017 pp. 2-3).

What the risk assessment did not present is a standardized methodology for determining the risk of 

invasive plant introduction or spread associated with a proposed action. An addendum has been 

developed for the risk assessment that incorporates the methodology and the basis for risk level of “low”, 

“moderate” or “high” (Hoover 2018). This methodology would help clarify the determination of risk with 

the implementation of the PDFs. An example of a PDF or mitigation that links to reducing vectors for 

invasive plant introduction and spread as a result of project implementation is as follows “All mechanical 

equipment used in the project shall be washed after operating in one (1) project area, and before moving 

to another project area.”

Where species such as yellow star thistle, dyer’s woad and broom species exist as small (fewer than 

10 plants) occurrences, consecutive manual treatments (i.e., hand pulling or grubbing out) have proven 

effective. The Six Rivers’ botany program maintains trend data for invasive weed treatment locations 

across the forest. Analysis of trend data for invasive plant treatments has shown that manual treatment 

methods for invasive weeds mentioned above have been reduced in numbers or have been eradicated. The 

combination of consecutive manual pulling, twice a year for small, discrete sites and weed whacking of 

sites with moderate cover (<0.1 acre) with subsequent pile burning are drawn from the literature. With 

both manual and weed whacking/pile burning treatments there is an adaptive management component 

based upon effectiveness monitoring. It is the consecutive treatments and associated monitoring over the 

years, until the site is contained or eradicated, that carries with it an element of adaptive management.

Regarding PDF implementation and efficacy monitoring, a review of past projects identified in 

Chapter 3, Environmental Consequences, under Cumulative Effects—Orleans Community Fuels 

Reduction Project (OCFR) and Roots and Shoots Project warranted further clarification.

OCFR: There are seven (7) OCFR units that coincide with the Donahue project area of the 

Somes Bar Project. Treatment of a small/discrete site of Scotch broom, equipment cleaning, 

progression of work, use of weed-free rock material and erosion control material, and 

clearing invasive plants (i.e., yellow star thistle and Scotch broom) from landings prior to use 
Appendix B. Response to Comments

352 – Somes Bar Integrated Fire Management Project

were identified in the risk assessment for OCFR to reduce the risk of introduction and spread 

of invasive plant species. Of the seven (7) units that coincide with the Somes Bar Project, 

equipment cleaning and progression of work related to infested landings were correctly 

identified in the PDFs for three (3) of the units.

Roots and Shoots: There are four (4) Roots and Shoots units that coincide with the Ti Bar 

project area of the Somes Bar Project. Project design features for this project included 

avoidance of settings with yellow star thistle or timing activities before seed heads develop, 

retention of a native vegetation along the edge of a unit to reduce the risk of Dyer’s woad 

spreading from the road into the unit, and manual treatment at specific sites. These PDFs 

were captured in the environmental document for this project and as applicable, in the 

project’s burn plan. Of the four (4) units that coincide with the Somes Bar Project, avoidance 

of invasive plant sites was correctly identified in the PDFs for one of the units.

5. The EA fails to explain how “the nature of the project ...is designed to retain habitat components 

for fungi.” (Denise Boggs, CC, p. 19)

Response: The final EA (pp. 246-264) and the Biological Assessment/Biological Evaluation (BA/BE pp.

8, 11-12) include Sensitive plants and fungi (Hoover 2017a) provides information on key habitat variables 

associated with fungi, specifically Sensitive fungi species which are above-ground (epigeous) and 

mycorrhizal (having a symbiotic relationship between the fungus’ underground network of mycelia and 

the roots of vascular plants). Common to these species and many other fungi are habitat conditions 

characterized by shady, mature stands with conifer or hardwood hosts (for the mycorrhizal relationship) 

and ample organic material on the forest floor.

Page 250 of the final EA addresses the prescriptions and activities associated with the proposed 

activities coinciding with mature forests. In the context of the habitat fungi species need, the EA provides 

an explanation of how the project would retain habitat components for fungi:

Manual thinning of ladder fuels and prescribed burning or understory burning are proposed 

for mature forests; therefore, no ground disturbance associated with mechanical operations. 

Prescriptions include canopy cover retention of 60 percent (except around culturally 

significant trees or plant species) and retention of pre-dominant trees, which would provide 

shade to the forest floor.

Standards and guidelines pertaining to protection of coarse woody debris and fine organic 

matter also address habitat components that are critical to fungi (USDA Forest Service 2010).

Germane to prescribed and understory burning, frequent fires do not allow for accumulation 

of organic material on the forest floor and thus can reduce the belowground biomass of the 

mycorrhizal fungi network. The burning interval proposed in mature forests is 5 to 7 years,

which would allow for accumulation of organic material on the forest floor.
Appendix B. Response to Comments

Final Environmental Assessment – 353

General (G)

6. Concerns regarding the War Dance area being impacted by the project at Ti Bar. (R. Reed, verbal 

communication)

Response: The collaborative has worked closely with the Karuk Tribe in developing all proposed actions 

associated with the Somes Bar project. “All work within site boundaries shall be monitored by a Forest 

Service archaeologist or tribal monitor to ensure that the work is culturally desirable (i.e., for restoration 

purposes) and to ensure that ground disturbance is minimized and that features and artifacts are protected”

(final EA p. 81).

7. Please mail me a paper copy of the Somes Bar Integrated Fire Management Project. (J.Juel, email)

Response: A hard copy of the draft EA was mailed on March 26, 2018.

8. Our initial comments have to do with process. The EA project came out the same day as the 1st 48 

Project EA, with the same due date for comments (March 26, 2018). Both projects are documented 

in an EA totaling over 600 pages, not counting specialist reports. It’s difficult to believe the SRNF 

wants substantive public comment when it releases two projects at the same time. My understanding 

is this happened to meet some timber targets in the fiscal year. (Denise Boggs, CC, p. 1)

Response: The Forest Service appreciates the commenter’s frustration, recognizing the bulk of the 

materials available for review. It was not our intention to schedule this overlap. The release of the Somes 

Bar (WKRP) Project was originally scheduled to occur two (2) weeks prior to offset the comment periods 

on the draft EAs. Unfortunately, it took longer than expected to complete the Somes Bar Project draft EA, 

which resulted in the simultaneous release of both documents. The Somes Bar Project draft EA was listed 

in the SRNF’s schedule of proposed actions (SOPA) website since 2017, indicating the release of the 

draft EA for public comment in February 2018.

9. To make matters worse the specialist reports were not posted on the website, although we received 

some of them upon request. We did not receive the wildlife BE/BA and FWS consultation. These are 

the most important documents to CC and without them we can’t do the best job of relaying our 

concerns. The EA itself states in numerous places, as well as the response to comments, to refer to 

the BA. That document has never been made available to the public. According to the RO, the forest 

is required to make specialist reports available for public inspection during the comment period. 

There are also court cases stating they must be available during the comment period. Below is 

language from a successful lawsuit in 2014 regarding this issue. It is pertinent to our concerns 

about the Somes Bar Project. (Denise Boggs, CC, pp. 1-2)

Plaintiffs contend that the Forest Service was required to include certain Wildlife 

Specialist Reports in the appendices to its draft EIS and final EIS, yet failed to do so and 

also failed to disclose these reports during the comment period.

Defendants respond that the Forest Service permissibly incorporated the Specialist 

Reports by reference and that deliberative privilege permitted it not to disclose them 

during the comment period.
Appendix B. Response to Comments

354 – Somes Bar Integrated Fire Management Project

The Court finds that the Forest Service violated NEPA by failing to make the Specialist 

Reports accessible to the public. The Forest Service’s failure to include the Specialist 

Reports in the appendices of the draft EIS accompanied by its refusal to disclose during 

the comment period material on which it relied in the draft EIS is contrary to the spirit of 

NEPA and the letter of the CEQ regulations.

Response: On February 22, 2018, the SRNF provided email, CD and/or hardcopy notifications of the 

Somes Bar Project draft EA, along with contact information if individuals needed additional material or 

had questions. On February 22, 2018, you requested specialist reports for review. On February 23, 2018, 

the Forest Service mailed (next day service) a thumb drive in response to your request including the 

following reports: survey and manage report, neo-tropical migratory bird report, management indicator 

species report, invasive plant risk assessment, geology report, soils report, fire and fuels report, and 

watershed cumulative effects analysis spreadsheets prepared for the draft EA. It was indicated that 

separate reports were not prepared for vegetation, visuals, or hydrology, as these were included in their 

entirety in the EA.

The validity and relevancy of court case lawsuits and determinations in context of NEPA compliance 

for the Somes Bar Project regarding distribution of specialist reports and draft reports (draft BAs), during 

the comment period, may solely be determined by Office of General Counsel (OGC).

The SRNF did not release the draft Wildlife Biological Evaluation/Biological Assessment (BE/BA) as 

it was pending FWS consultation under the streamline consultation procedures for Section 7 of the ESA 

(Forest Service (FS) and Fish and Wildlife Service (FWS): MOU, January 31, 2013). The objective of the 

streamline consultation process is to reduce the likelihood of conflicts between listed species or critical 

habitat and proposed actions, and is similar to “early consultation” described at 50 CFR 402.11. Using the 

best scientific and commercial data available, the Services (FS and FWS) will independently make any 

factual determinations within their respective authorities, including final determinations concerning the 

content and findings. On the basis of early planning and Level 1 Team meetings, action agencies will 

prepare a draft BA. “At this point, the action agency will have identified its proposed action and the Level 

1 Team can assume the proposed action will not change in any way that materially changes the analysis in 

the draft BA” (MOU 2013). The Action agency (FS) will submit the draft BA to the FWS for review and 

comment. Level 1 Team members (FS and FWS) met on September 7, 2017, December 13, 2017, and 

January 2, 2018 to clarify comments.

The information in the Wildlife draft Biological Assessment prepared per ESA was incorporated into 

the draft EA. The BA has been approved by the Level 1 team and submitted to FWS to complete 

consultation.

10. We request the legal notice and EA be withdrawn until the BE/BAs are available, and then begin the 

public comment process anew. I was told that in the future, requests for public comment would not 

be issued unless the specialist reports were available. While I appreciate that, it does no good for 

this project (as well as for 1st 48). In addition, I was told the wildlife biologists didn’t want to 

release these documents because they were still working with the USFWS and changes would likely 
Appendix B. Response to Comments

Final Environmental Assessment – 355

be made. This is very problematic because the FS is asking people to comment on a project without 

full knowledge, and in which changes may occur with no other opportunity to comment. The 218 

regs forbid raising new issues during the Objection period, but CC reserves the right to raise new 

issues if an Objection is filed. While the regs don’t permit this, the FS has put everyone in an 

untenable position. We request the BEs, BAs, and documentation of USFWS consultation be sent to 

us ASAP. (Denise Boggs, CC, p. 2)

Response: The responsible official did not select to authorize an extension of the comment period. The 

Somes Bar Project draft EA included the wildlife analysis with identical information from the draft BA 

prepared by the Forest Service, released for 30 day review and comment. The FS mailed and emailed 

additional materials either same day or next day, in response to your requests. The regulations at Title 40, 

Code of Federal Regulations, parts 1500-1508 (40 CFR 1500-1508) set forth specific requirements for 

implementing NEPA. The regulations establish procedures and rules governing environmental analysis 

and documentation; ensure that environmental information is available to public officials and the public 

and provide direction to assist public officials in making decisions based on an understanding of 

environmental consequences. Similar to other public comments received on the Somes Bar Project draft 

EA, revisions from FWS review and comment during the Level 1 streamline consultation process on ESA 

listed species, prompted further clarifications and minor revision/supplemental information to the analysis 

disclosed in the final EA. These updates and rationale are described in the changes between draft and final 

EA section at the beginning of the final EA.

The FS prepares an environment assessment (EA) to provide sufficient evidence and analysis, 

including the environmental impacts and alternative(s), to determine whether to prepare either an EIS or 

FONSI (40 CFR 1508.9). If for any reason, during the Level 1 streamline consultation process there was a 

change in determination to ESA species in the final BA, the FS may prompt a supplement and additional 

comment period, extend the comment period (36 CFR 220.5(f)(3)); or the responsible official could 

determine preparation on an EIS is warranted.

The release of the Somes Bar Project final EA and draft decision notice (draft DN) is in compliance 

with 36 CFR 220.5(h), 36 CFR 220.6(f), and 36 CFR 220.7(d)), along with the concurrent release of 

specialist reports on the KNF website and the final BA for ESA listed species during the 45- day 

objection review period, provides another opportunity for the public to provide comments for 

consideration by the responsible official, prior to the decision. The pending federal decision document 

would document comments received during the objection period and how the responsible official 

addressed those comments.

11. Compounding this problem, many of the scientific and other cites relied upon by the EA are not 

even listed in the EA’s References section. This thwarts the public’s ability to weigh the EA’s claim it 

is using best available science. (Denise Boggs, CC, p. 2)

Response: The inadvertent omission of references in the draft EA bibliography have been corrected in 

the final EA. However, specialist’s reports mailed to you on February 23, 2018, included a 

comprehensive list of references used to support the analysis and findings (Soils Report includes 22 
Appendix B. Response to Comments

356 – Somes Bar Integrated Fire Management Project

references alone). To clarify, as indicated in the 30-day comment period notices, contact information 

(telephone and email) was provided for requests for “additional” information. The Forest Service provides 

electronic copies of references cited in reports when requested anytime during the planning process.

12. CC does not underestimate the capacity of “the contemporary regional economy and monetary 

system” to appropriate the efforts of sincere proponents of cultural practices, via its control over 

federal and other bureaucratic and economic institutions. And as expressed in these comments, our 

concerns are that such appropriation is in full force with this project. (Denise Boggs, CC, p. 2)

Response: The statement aims to provide transparency that the Forest Service and WKRP qualitatively 

considered these dynamics when evaluating impacts to the human environment (determined by context 

and intensity of those effects), recognizing contemporary regional economy and monetary system factors 

influencing local economies are outside the scope of the influence for this federal action.

13. If the FS were in fact making this “paradigm shift” for such an area, included in the timber base 

under the forest plans, then it would not be doing so in the context of an EA with its corresponding 

claim of “no significant impacts.” No, if the FS were making such a “paradigm shift” it would be 

preparing a full-fledged Environmental Impact Statement (EIS), likely to support amending the 

forest plans. Please initiate an EIS process to remedy the vast procedural deficiencies our 

comments identify for the Somes Bar project development. (Denise Boggs, CC, p. 3)

Utilizing “a collaborative IDT process” is also unprecedented; using non-FS employees as IDT 

members is a “significant” departure from NEPA implementation. (Denise Boggs, CC, p. 5)

Response: To clarify, the Forest Service prepares an environmental assessment (EA) for proposals as 

described in §220.4(a), that are not categorically excluded from documentation (§220.6), and for which 

the need of an EIS has not been determined (§220.5). (36 CFR 220.7(a)). The Forest Service prepares an 

environment assessment (EA) to provide sufficient evidence and analysis, including the environmental 

impacts and alternative(s), to determine whether to prepare either an EIS or FONSI (40 CFR 1508.9). The 

purpose of an EA is to:

Briefly provide sufficient evidence and analysis for determining whether to prepare an 

environmental impact statement or a finding of no significant impact.

Aid an agency’s compliance with the Act when no environmental impact statement is 

necessary.

Facilitate preparation of a statement when one is necessary (40 CFR 1508.9(a)).

The Somes Bar Project final EA describes the impacts of the proposed action and alternatives 

developed in detail, in terms of context and intensity, as described in the definition of “significantly” at 40 

CFR 1508.27 (36 CFR 220.7(b)(3)(iii)). The Somes Bar Project final EA includes a FONSI, in 

compliance with CEQ regulations. The FONSI is a document by a federal agency briefly presenting the 

reasons why an action, not otherwise excluded (§1508.4), will not have a significant effect on the human 

environment. It includes the environmental assessment or a summary of it and incorporates by reference 

other environmental documents related to it (§1501.7(a)(5)). The FONSI prepared for the Somes Bar 
Appendix B. Response to Comments

Final Environmental Assessment – 357

Project does not repeat the full discussion in the assessment. Rather, this section summarizes key findings 

relative to the context of the project and intensity of effects considering the 10 factors identified in 40 

CFR 1508.27(b) and includes references to the final EA and reports (40 CFR 1508.13).

The responsible official would have triggered preparation of an EIS if at any time during the NEPA 

process, the environmental analysis indicated any potential for significance affecting the quality of the 

human environment considering context and intensity of the 10 factors (40 CFR 1508.27(b)). The 

responsible official evaluated the effects of the Proposed Action relative to the definition of significance 

established by the CEQ regulations (40 CFR 1508.13), and has determined that the Proposed Action 

would not have a significant effect on the quality of the human environment, whereby preparation of an 

environmental impact statement is not warranted.

The proposed action is subject to Forest Service control and responsibility (see 40 CFR 1508.18); (36 

CFR 220.4(a)), as NEPA process applies to proposed “Federal” actions. The Agency employee who has 

the authority to make and implement a decision on a proposed action (36 CFR 220.3) is the responsible 

official for NEPA compliance.

The paradigm shift in the planning approach and composition of the interdisciplinary team are 

irrelevant to context and intensity factors used to evaluate significance. Whenever invited federal, state, 

tribal and local agencies elect not to become cooperating agencies, they should still be considered for 

inclusion in interdisciplinary teams engaged in the NEPA process and on distribution lists for review and 

comment on NEPA documents (CEQ Memorandum for Heads of Federal Agencies, 1/30/2002).

14. There are additional reasons the FS should be preparing an EIS. The EA represents a piecemeal 

analysis of a larger management action. The EA’s second sentence states, “This project is just the 

first phase in realizing the goals of the National Cohesive Wildland Fire Management Strategy 

(Cohesive Strategy), in accordance with traditional ecological knowledge (TEK) and customs, as a 

framework for living with fire in the western Klamath Mountains of northern California.” (Denise 

Boggs, CC, p. 3).

Response: The Somes Bar Project final EA describes the impacts of the proposed action and alternatives 

developed in detail, in terms of context and intensity, as described in the definition of “significantly” at 40 

CFR 1508.27. This term includes both context and intensity:

Context: This means that the significance of an action must be analyzed in several contexts 

such as society as a whole (human, national), the affected region, the affected interests, and 

the locality. Significance varies with the setting of the proposed action. For instance, in the 

case of a site-specific action, significance would usually depend upon the effects in the locale 

rather than in the world as a whole. Both short- and long-term effects are relevant.

Intensity: This refers to the severity of impact. Responsible officials must bear in mind that 

more than one agency may make decisions about partial aspects of a major action.

See comment 10 and responsible official decision to prepare a FONSI (40 CFR 1508.9), in lieu of 

preparing an EIS.
Appendix B. Response to Comments

358 – Somes Bar Integrated Fire Management Project

The Somes Bar Project is a catalyst for bringing fire leadership at all levels and agencies together and 

prompting a new approach to how wildland fire is managed (www.forestsandrangelands.gov), as 

mandated by the Federal Land Assistance, Management and Enhancement Act of 2009 (FLAME Act). 

The Act states, in part, “Not later than one year after the date of the enactment, the Secretary of the 

Interior and Secretary of Agriculture shall submit to Congress a report that contains a cohesive wildfire 

management strategy.” The Act directs that a cohesive strategy be developed addressing seven (7) 

specific topic areas ranging from how to allocate fire budgets at the federal level to assessing threats to 

communities, and prioritizing hazardous fuels project funds.

Traditional ecological knowledge (TEK) is the cumulative body of knowledge, practice, and belief, 

evolving by adaptive processes and handed down through generations by cultural transmission, about the 

relationship of living beings (including humans) with one another and with their environment (Berkes et 

al. 2000). The Tribal Forest Protection Act (TFPA; 25 USC §§3101 Note and 3115a) provides 

opportunities to complete collaborative stewardship work on federal lands adjacent to tribal trust lands 

through agreements or contracts. It provides for the protection of trust lands and tribal interests from fires, 

insects, disease and other threats that are in need of restoration. The Forest Service and Karuk Tribe 

believe that this can be implemented through tribal/interagency partnerships that provide for an integrated 

working relationship in the planning and implementation of landscape-scale restoration efforts throughout 

Karuk Aboriginal Territory.

15. In addition, the EA states:

In 2010, the Karuk Tribe released a draft Eco-Cultural Resources Management Plan (ECRMP; 

Karuk 2010) to create a long-term adaptation strategy for the protection, enhancement and 

utilization of cultural and natural resources. The ECRMP establishes a framework for considering a 

wide range of human and environmental stressors to the Karuk Tribe and their cultural practices, 

including effects of climate change.

The ECRMP ensures that “Karuk Tribal members and Departmental personnel hold information 

critical to the interworking of the natural environment. Natural Resources staff is working with 

Federal and State agency personnel, academia, and the interested public to ensure that the integrity 

of natural ecosystem processes and traditional values are incorporated into current and future 

management strategies within our area of influence” (ECRMP p. 5).

The intent of the MOU (Karuk Tribe and USDA Forest Service 2017) is to work together to mutually 

coordinate planning and implementation efforts as partners, in and adjacent to the Katimiin CMA, 

in a manner consistent with Karuk customs, culture and federal land management direction. 

(Emphases added.)

(T)he partnership settled on a planning scope that included the entire Salmon River watershed. 

(Emphasis added.)

(T)he Western Klamath Restoration Partnership (WKRP) convened workshops ...for conservation 

planning for the entire Middle Klamath sub-basin. (Emphasis added.)
Appendix B. Response to Comments

Final Environmental Assessment – 359

Since it has taken nearly 100 years of growth to produce present-day, “non-natural” vegetative 

structural conditions, it is predicted that it will likely take several decades of resource management 

to return the cultural environment and balance of ecological cycles. (Emphasis added.)

All these statements directly indicate the management strategy is part of a larger action, with 

uncertain1 human and environmental impacts. Since this is the case, an EIS must be prepared.

This is also clearly illustrated with the EA’s Figure 1-4, which displays the four separate Somes Bar 

project areas within the larger Karuk Aboriginal Territory and WKRP Geographic scope— one or 

both which would be the geographic scope of this larger strategy:

In many ways, the Somes Bar project represents an unprecedented socio-economic experiment with 

highly uncertain outcomes. An EIS is needed to take the necessary hard look at all the implications.

All these statements directly indicate the management strategy is part of a larger action, with 

uncertain1 human and environmental impacts. Since this is the case, an EIS must be prepared (Denise 

Boggs, CC, pp. 3-4).

Response: The Forest Service is a member of the WKRP, formed in 2013, along with the Karuk Tribe, 

Mid Klamath Watershed Council, Orleans-Somes Bar Fire Safe Council, Salmon River Restoration 

Council, The Nature Conservancy Fire Learning Network, Klamath Forest Alliance, Environmental 

Protection Information Center, University of California Berkeley, Bureau of Indian Affairs, National 

Oceanic Atmospheric Administration, Environmental Protection Agency, and US Fish and Wildlife 

Service. As indicated in the comment, numerous open public forums convened workshops ...for 

conservation planning for the entire Middle Klamath sub-basin/the entire Salmon River watershed. The 

WKRP planning endeavor has not been exclusive.

As you know, similar to watershed analysis or travel analysis, strategies, concepts and

recommendations, a Forest Service proposal is only subject to the NEPA requirements when all of the 

following apply:

The Forest Service has a goal and is actively preparing to make a decision on one or more alternative 

means of accomplishing that goal and the effects can be meaningfully evaluated (see 40 CFR 1508.23);

(36 CFR 220.4(a)). An operative term in the CEQ definition of proposal is the term “stage.” Most midlevel analyses, for example watershed analyses, are simply a stage where the Forest Service identifies 

what possible management actions can be taken to move the Agency towards its desired future condition 

or “goals.” However, the results of these analyses generally are a description of the existing condition and 

a myriad of possible management actions. It is not until the Forest Service determines that it wants to 

move forward with one or more possible actions that the Agency is at a stage where a NEPA “proposal” 

exists. If the Agency does not know where or when an activity will occur or if it will occur at all then the 

effects of that action cannot be evaluated meaningfully.

The Indian Self-Determination and Education Assistance Act of 1975 (ISDEAA; 25 USC §450 et 

seq.) guides Indian self-determination and is the cornerstone of the federal relationship with sovereign 

tribal governments. Self-determination contracts, grants, cooperative agreements and self-governance 

compact agreements are authorized by the ISDEAA. In a similar vein, Executive Order 13175 –
Appendix B. Response to Comments

360 – Somes Bar Integrated Fire Management Project

Consultation and Coordination with Indian Tribal Governments (EO 1375; 65 Fed. Reg. 67249) provides 

guidance to establish consultation and collaboration with tribal officials in the development of federal 

policies with tribal implications. The National Historic Preservation Act of 1966 (NHPA; 16 USC §470 et 

seq.) is intended to preserve the cultural and historical legacy of the United States for the benefit of future 

generations. The NHPA requires that federal agencies consult with any Indian tribe that attaches religious 

and cultural significance to historic properties that may be affected by an undertaking. The NHPA is 

important to the Karuk Tribe because it provides the tribe with an opportunity through consultation to 

protect, or mitigate harm to, cultural resources located on federal public lands. In conjunction with the 

Archaeological Resources Protection Act (ARPA), Native American Graves Protection and Repatriation 

Act (NAGPRA), American Indian Religious Freedom Act (AIRFA), Religious Freedom Restoration Act 

(RFRA), Religious Land Use and Institutionalized Persons Act (RLUIPA), and Indian Sacred Sites EO 

13007, the NHPA provides a method of procedural protection for the tribe’s cultural resources. In 

alignment with these laws and policies, the intent of the MOU (Karuk Tribe and USDA Forest Service 

2017) is to work together to mutually coordinate planning and implementation efforts as partners, in and 

adjacent to the Katimiin CMA, in a manner consistent with Karuk customs, culture and federal land 

management direction.

The comment, “Since it has taken nearly 100 years of growth to produce present-day, “non-natural” 

vegetative structural conditions, it is predicted that it will likely take several decades of resource 

management to return the cultural environment and balance of ecological cycles”, represents a recognition 

by the Forest Service that a single management phase cannot rectify human disruptions in ecological 

process. The final EA states, “Environmental and legal constraints, such as weather, on-the-ground 

fuelbed conditions, and application of required mitigations to ensure compliance with air quality, down 

wood, roadless and riparian standards, etc., would restrict treatment intensity and duration in some areas”.

The comment, “In many ways, the Somes Bar Project represents an unprecedented socio-economic 

experiment” is accurate. The hard look disclosed in the analysis for final EA does not indicate there would 

be highly uncertain outcomes.

16. The EA fails to justify the omission of a full analysis for an alternative such as Alternative 3, given 

the continuing decline of the NSO throughout its range. (Denise Boggs, CC, p. 6)

Response: The range of alternatives considered by the responsible official includes all reasonable 

alternatives to the proposed action that are analyzed in the document, as well as other alternatives 

eliminated from detailed study. Alternatives not considered in detail may include, but are not limited to, 

those that fail to meet the purpose and need, are technologically infeasible or illegal, or would result in 

unreasonable environmental harm (FSH 1909.15 (14.4)).

The commenter’s proposal to consider NSO as the driving force in project development does not 

align with the early WKRP community planning efforts, which underpin the purpose for the project. The 

WKRP selected various focal species representing different components of the landscape, rather than 

managing with preference for a single species, such as NSO. Alternative 2 was designed so as 
Appendix B. Response to Comments

Final Environmental Assessment – 361

components are put together, management for the focal species would provide a realistic and holistic 

approach to whole landscape management.

Under Alternative 3, the 2,658 acres of manual treatments, followed by prescribed burning units and 

additional 1,491 acres of prescribed burning only units proposed under Alternative 2 were not considered. 

Although these treatments are within the framework of consideration for Alternative 3, implementation 

would not be feasible and would require a high cost investment (manual treatments) with flame lengths 

exceeding the desired 4 feet.

Landscape-scale prescribed burning may only occur once perimeter containment and interior control 

line fuelbreaks are in place. Without this pre-treatment of hazardous fuels across the landscape proposed 

under Alternative 2, application of introducing fire under Alternative 3 could not be safely contained and 

controlled without substantial augmentation of suppression reinforcements. As Alternative 3 does not 

respond to fundamental elements of the Purpose and Need to revitalize balanced human relationships 

within our dynamic landscapes and would only reduce vegetative fuel hazards along roughly 50 percent 

of the critical ingress/egress routes to private land inholdings, this alternative was considered but 

eliminated from detailed study.

17. Economic analysis: The EA states, “The WKRP and this project, not including the Klamath TREX or 

USFS employees, have already contributed over $1.4 million to the local economy.” How does this 

NOT bias the decision towards the action alternative? How does this NOT constitute conflicts of 

interest?

“Manual fuels treatments ...do not generate funding by themselves and will require a significant 

investment to implement at the scale described.” This is another reason an EIS, with a full economics 

analysis, is required.

The EA claims, “The training and jobs provided and project-generated revenue would be reinvested 

into the local economy through direct and indirect contributions to local county revenues, generated 

from purchases and sales of goods and services produced locally, creating diversified sources of 

revenue streams.” Yet without a full economics analysis, which would show the degree to which the 

project activities are being subsidized by taxpayers all across the U.S., this statement comes off as 

merely a speculative statement supporting the decision already made. (Denise Boggs, CC, p. 11)

Response: Human Environment... shall be interpreted comprehensively to include the natural and 

physical environment and the relationship of people with that environment... This means that economic 

or social effects are not intended by themselves to require preparation of an environmental impact 

statement (40 CFR 1508.14). Jurisdiction by Law... agency authority to approve, veto, or finance all or 

part of the proposal (40 CFR 1508.15). The cost of implementing the Somes Bar Project is being funded 

via multiple sources, including collaborative grants submitted by partners.

The disclosure of the economic indicators ($1.4 million) and foreseen benefits to TEK focal species 

supporting cultural practices is proprietary, funded through the Bureau of Indian Affairs and Karuk Tribe. 

Through meaningful consultation, the Karuk Tribe has led the way in designing the WKRP Somes Bar 

Project to protect, or mitigate harm to, cultural resources located on federal public lands, while enhancing 
Appendix B. Response to Comments

362 – Somes Bar Integrated Fire Management Project

TEK species to supplement their diet and as capital to exchange in the market system. The focal species 

provided an umbrella framework for the landscape-level analysis. Some of these components are regalia 

species in tribal ceremonies. Regalia species are crucial to tribal people through ancestral tradition. The full 

economic extent is not disclosed to protect the location of cultural sites and traditional cultural properties.

18. The EA does not demonstrate that the project area would be managed consistent with the Travel 

Management Rule Subpart A, which requires a publicly involved science-based analysis be used to 

determine the minimum road system, affordable to maintain with expected financial resources. 

(Denise Boggs, CC, p. 11)

Response: Existing travel management direction for each administrative unit or ranger district reflects its 

history of travel planning, occupancy and use, road and trail construction, and past decisions, including 

those contained in the applicable SRNF and KNF land management plans. The route and area 

designations relevant to the Somes Bar Project would simply confirm travel management decisions that 

have already been made (36 CFR 212.52(a); FSM 7715.3). The Proposed Action would not authorize a 

change or addition of new routes or trails to the national forest transportation system (NFTS) or revise 

motor vehicle use map (MVUM). The regulations at 36 CFR Part 212, Subpart B, do not require 

reconsideration of previous travel management decisions. Site-specific issues associated with the Somes 

Bar Project were addressed at the project level (FSH 7709.55, sec. 14).

The use of roads proposed under the Somes Bar Project are consistent with already designated uses 

for which they are currently managed. For example, NFS roads classified at Operational Maintenance 

Levels 2 and 3, have NFS roads already designated for use by highway-legal vehicles and managed as 

open to highway-legal vehicles. The ML 1 designation indicates a road that is closed to motor-vehicle 

traffic and is placed in “storage” until needed. These roads would be taken out of storage and brought up 

to ML 2 standards, when needed to facilitate access to treatment units, and then re-designated as ML 1.

19. Is there any livestock grazing in the project area? (Denise Boggs, CC, p. 19)

Response: There are no grazing allotments in the project area.

Fire and Fuels (FF)

20. “In recent years, a high number of acres have been burned by wildfires in the Klamath Mountains 

and a large percentage of these have burned at uncharacteristically high severity due to a variety of 

conditions.” What is the basis for the EA’s conclusions that those fires burned “at 

uncharacteristically high severity”? What data and analysis are you relying upon? (Denise Boggs, 

CC, p. 8)

Response: We have clarified this statement in the EA. Fire severity data is only available since 1984. 

Previous research does not show an increase in the percentage of high severity fire within the time period 

of 1984-2008 (Miller et al. 2012). However, we do have evidence that the average size of fires is 

increasing over this same period (Miller et al. 2012; Odion et al. 2004). This and other research has 

shown that severity trends correlate well with winter and spring precipitation amounts and temperature 
Appendix B. Response to Comments

Final Environmental Assessment – 363

inversions during smoky conditions (Miller et al. 2012; Estes et al. 2017). The 2014 fires on the Klamath 

National Forest resulted in exceptionally large high severity patches and an elevated percent of high 

severity due to drought conditions and a general lack of inversion conditions that are characteristic of the 

Klamath Mountains (Ebert 2015).

21. The SRNF is basing claims of high risk of stand replacing fire on the 1999 LSRA, which is almost 

20 years old. Fire science has changed dramatically in the past 20 years. The EA lists the many 

benefits the project would have for fire suppression and mentions the fuel loads might result in 

high-intensity fire that “would” negatively impact suitable wildlife habitat. The EA oversells the 

certainty of fire impacts. Many things might happen but we don’t manage for all of them. What is 

certain is the NSO population is precipitously declining in northern California; and every 

commercial timber sale planned on the SRNF is in designated critical habitat/LSR. There are 

implications to this management strategy the SRNF continuously fails to address. Timber sales 

impact owls now. Long term means little to a species trending toward extinction. The SRNF also 

fails to acknowledge that spotted owls evolved with western forests that had wildfires much larger 

than today; burning far more acres; as well as insect and disease epidemics. Spotted owls survived 

just fine before the FS was ever created. Logging to prevent wildfire is a fool’s game and it certainly 

does not improve the habitat for spotted owls – not as proposed and carried out by the FS in 

general or proposed in this project. Fire is not “catastrophic” in late-successional habitat when 

owls evolved with it. It is only catastrophic to the timber industry that wants board feet/volume from 

NF lands regardless of tax payer/wildlife expense (Denise Boggs, CC, pp. 8-9).

Response: Previous research shows that the average size of wildfires is increasing within recent decades 

(Odion et al. 2004; Miller et al. 2012). Mechanical restoration treatments proposed by this project are 

designed to increase the average tree size of remaining habitat patches and also increase the diversity and 

overall structure of these forest patches by retaining and releasing trees of under-represented species (final 

EA pp. 47, 166). The largest trees within stands would be retained in all circumstances, including within 

habitat areas (final EA pp. 46-48). The Recovery Plan specifically mentions wildfire as a threat to NSO, 

especially in the Klamath region, calling for management that results in forests that are more fire resilient 

and fire resistant (final EA p.183-184). The proposed restoration treatments in this project are expected to 

increase forest resiliency and resistance by increasing the proportion of basally sprouting species and 

increasing vigor of released trees (final EA pp. 170-171).

22. The EA does not adequately explain or justify the “WUI Threat zone boundaries” and why they are 

where the EA considers them to be (Denise Boggs, CC, p. 9).

Response: The wildland urban interface (WUI) zone is an area where human habitation is mixed with 

areas of flammable wildland vegetation. It extends out from the edge of developed private land into 

federal, private, and state jurisdictions. The WUI Threat zone boundaries generally extend approximately 

11⁄4 miles out from the defense zone boundary; however, actual extents of threat zones are based on fire 

history, local fuel conditions, weather, topography, existing and proposed fuel treatments, and natural 

barriers to fire. Fuels treatments in these zones are spatially placed to reduce wildfire intensity and 
Appendix B. Response to Comments

364 – Somes Bar Integrated Fire Management Project

interrupt spread, designed to link to the larger fuelbreak network to the north and south and other features, 

such as roads and rocky areas, effective as anchor areas to contain wildfire (final EA p. 16). Spatial 

boundaries for WUI threat zones are based on California Department of Forestry and Fire Protection’s 

fire and resource assessment program (http://frap.fire.ca.gov/index) and subsequently incorporated into 

the Orleans/Somes Bar CWPP (2012).

23. The EA also cites the “dry forests of the CA Klamath Province” for management actions that result 

in fire resilient and fire resistant forests. Yet the SRNF is within the Moist Forest Zone of the NSO 

range as delineated in the RRP. One reason this is particularly important is the distinction between 

forest conditions under natural conditions and those under human manipulation scenarios. (Denise 

Boggs, CC, p. 9)

Response: The Recovery Plan was informed by Forsman et al. (2011) and Dugger et al. (in press at the 

time, but subsequently published in 2011). The Recovery Plan states, “The continued decline of the 

spotted owl populations and low occupancy rates in large habitat reserves, and the growing negative 

impact from barred owl invasions of spotted owl habitats (Forsman et al. 2011, Dugger et al. in press), 

which is greater than anticipated in the NWFP. In view of the increasing risk posed to northern spotted 

owl habitat by wildland fire in the dry forests of the California Klamath Province, the Recovery Plan calls 

for management actions that result in forests that are more fire resilient and fire-resistant.” The Somes Bar 

Project is located within the Northern California Interior Coast Ranges Region (ICC) modeling zone, as 

identified in the USFWS Revised Recovery Plan (2011) for NSO.

The ICC region consists of the Northern California Coast Ranges ecological Section M261B (McNab 

and Avers 1994), and differs markedly from the adjacent redwood coast region. Marine air moderates 

winter climate, but precipitation is limited by rain shadow effects from steep elevational gradients (100 to 

2,400 m.) along a series of north-south trending mountain ridges. Forest communities in this modeling 

zone tend to be relatively dry mixed conifer, blue and Oregon white oak, and the Douglas-fir tanoak series 

(USFW 2011). The Somes Bar Project draft and final EAs state, “The SRNF and KNF is within the moist 

forest zone of the northern spotted owl’s range as delineated in the Recovery Plan.

However, the area’s dry, hot summers and extreme departure from its historic fire return interval mean 

that owl habitat within many areas of the Forest is at risk of being lost to, or significantly degraded by, 

severe fire. The 1999 Megram Fire (120,000 acres), 2002 Biscuit Fire (500,000 acres), the 2008 Lightning 

Complex (45,000), the 2013 Butler (14,600 acres), the 2013 Coral fire (12,500 acres), the 2015 lightning 

fires (100,000 acres forest-wide), the 2017 lightning fires (54,387 acres forest-wide) and many other 

smaller fires including the 2011 Ruth Fire (1,414 acres), all removed suitable NSO habitat on the Six 

Rivers, and demonstrates that the fire risk on the Forest is genuine. Active management to reduce the fire 

hazard and increase resilience should contribute to the spotted owl’s persistence and recovery. Such longterm protection of owl habitat is consistent with the recommendations in Forsman (2011), as well as the 

Recovery Plan and Critical Habitat Rule.

24. The EA states, “Historically, wildfire and cultural burning have played major roles in the 

development and maintenance of our local ecosystems. Wildfire is often the primary natural 
Appendix B. Response to Comments

Final Environmental Assessment – 365

disturbance influencing vegetation structure, species composition, soil properties, nutrient cycling, 

and ecosystem processes (Odion et al. 2004).” It also states, “through the exclusion of fire (cultural 

burning), more fire prone species have become established encroaching in on more fire adapted 

native species or the sheer abundance of individuals have created a situation where there is no 

longer a process regulated by natural disturbance events that maintain historic pre-European 

conditions (Hessburg et al. 2015).” However, how aboriginal fire practices shaped the ecosystem as 

compared to how natural processes did so before humans arrived on the scene is not explained in 

the EA. (Denise Boggs, CC, p. 9)

Response: Comparisons with how Karuk cultural management practices shaped the ecosystem compared 

to how natural processes did so before the arrival of humans is beyond the scope of this EA, and irrelevant 

to the purpose and need of the project. Nonetheless, Figure 1-8 from Anderson and Barbour (2003) does 

generalize ecosystem differences between natural and anthropogenic fire regimes (final EA p. 9). Further, 

western scientific evidence supports Karuk knowledge indicating that cultural management results in 

unique and diverse plant assemblages that are different than what would be expected based on climate 

trends alone (Crawford 2012, Crawford et al. 2015, Taylor et al. 2016; (final EA pp. 126, 157). Karuk 

indigenous fire management principles differ from natural fire regimes with respect to the frequency and 

timing of burning (final EA p. 119). Generally speaking, areas close to village sites and resource areas are 

burned at a high frequency. The timing of these burns is planned based on traditional knowledge 

indicators, which also results in avoidance of negative impacts to regenerating plants and animals and 

desired fire effects with respect to reducing fuels, controlling pests, and inciting growth that improve the 

quality of materials (final EA p. 119). Traditional ignition sources for indigenous burning are found along 

ridgetops within our region. This indicator reflects the landscape-scale approach of indigenous burning that 

often was initiated along ridges and trails (final EA p. 40, 119-120). These same principles (burning along 

travel routes and ridges) are considered and incorporated into Alternative 2.

25. So where the EA makes statements such as, “The lack of natural mixed-severity fires in the 

landscape...” (emphasis added), what is “natural” is not explained. The EA is afflicted by this 

unreconciled distinction throughout. (Denise Boggs, CC, p. 9)

Response: The purpose of the Somes Bar Project is to demonstrate how prescribed fire restores and 

maintains resilient ecosystems, communities, and economies to revitalize balanced human relationships 

with our dynamic landscape. This includes incremental but purposeful reversal of changes to forest 

conditions that have resulted from fire suppression (final EA pp. 8-10). Therefore, within the context of 

the EA, a “natural” mixed-severity fire regime is understood to be one that is similar to the fire regime 

that was present on the landscape prior to the arrival of Europeans and fire suppression policy. This 

regime incorporates anthropogenic fire use by Karuk people.

26. Even if we were to accept a premise that traditional cultural burning practices were somehow 

consistent with natural processes, this still doesn’t address how 21st Century tribally controlled 

burning practices in the context of the overall dominant American cultural/economic system will 

contrast with the traditional cultural burning practices before the arrival of the white man. This is 
Appendix B. Response to Comments

366 – Somes Bar Integrated Fire Management Project

reflected, for example, in the stated need to perpetually maintain ridge top fuel breaks and safe 

egress routes along roads and use aerial fire retardants, which are certainly not traditional cultural 

adaptations to fire. The project does not genuinely represent “restoration of the landscape to its 

ancestral state.” (Denise Boggs, CC, p. 9)

Response: It is not the intent of this project to restore the landscape to its ancestral state and the EA has 

been corrected. However, the purpose of this project is to demonstrate how prescribed fire restores and 

maintains resilient ecosystems, communities, and economies to revitalize balanced human relationships 

with our dynamic landscape (final EA pp. 8-12). The WKRP vision is to: “Establish and maintain resilient 

ecosystems, communities, and economies guided by cultural and contemporary knowledge through a truly 

collaborative process that effectuates the revitalization of continual human relationships with our dynamic 

landscape” (final EA p. 21). Further, one of the WKRP’s strategies is to “increase use of fire to restore and 

maintain pre-European conditions in a contemporary context” (final EA p. 27). The purpose is not to 

reinstate cultural burning and prescribed fire in the context of pre-European settlement, but to do so within 

a contemporary context, which acknowledges the existence of the modern wildland-urban interface.

27. The EA states: “Fire behavior modeling predicts about half of the project area would experience 

low intensity fires and half would be considered as very high, likely resulting in a significant loss or 

degradation of late successional habitats.” In making statements or implications such as this, 

which occurs throughout the EA, the EA fails to acknowledge that the very nature of mixed severity 

fires IS one of interspersed high severity and low severity patches. These forests have naturally 

(however one wants to define that term) experienced stand-replacing fires when periodic drier 

weather conditions combined with ignition events (Denise Boggs, CC, p. 9).

Response: The EA does acknowledge the inclusion of high-severity patches within mixed severity fires 

(final EA p. 136). While there is no long-term record of fire severity patterns, wildfire within recent 

decades has shown high-severity patches to comprise about 12 percent of the fire area (Odion 2004) and 

about 14 percent of the Thompson Ridge area that was examined between 1850 and 1950 (Taylor and 

Skinner 1998).

28. The EA is unable to cite the results of any study of recent fires in the vicinity which confirm the dire 

predictions of catastrophe if fire were to occur under the no action alternative. For example, “the 

Ukonom and Haypress fires burned approximately 25,000 acres immediately adjacent to the focal 

areas” and the “wildland fire recorded within the project area was the Marble Fire, in August 

2017.” (EA at 32.) In fact, what the EA has to say about 2017 fires at page 191 does not support the 

assumption of impeding catastrophe.

“(T)he 2017 fires within the NSO analysis area for the Somes Bar Project burned at lower 

intensities and did not remove large areas of suitable habitat.” EA at 191. Also, “Those stands 

that are proposed for commercial thinning under the action alternative shows the lowest potential 

basal area loss under severe conditions as almost all been previously thinned from below, have a 

dense canopy and very high canopy base height.” EA at 105. (Denise Boggs, CC, p. 10)
Appendix B. Response to Comments

Final Environmental Assessment – 367

Response: The FVS modeling of wildfire occurring during 90th percentile weather conditions show 

increased basal area mortality under Alternative 1 compared to Alternative 2 (final EA pp. 143-144, 150).

Previous research shows that fire severity trends correlate well with winter and spring precipitation 

amounts and temperature inversions during smoky conditions (Miller et al. 2012, Estes et al. 2017). The

fact that 2017 was one of the wettest years in recent history explains why the 2017 fires burned at lower 

intensities. By contrast, the 2014 fires on adjacent portions of the Klamath National Forest resulted in 

many large high severity patches due to historic drought conditions and general lack of inversion 

conditions that are characteristic of fire in the Klamath Mountains.

The excerpt from (final EA pp. 107-108) illustrates the effectiveness of previous mechanical 

treatments (commercial and pre-commercial thinning) in reducing the potential basal area loss under 

severe wildfire conditions compared to areas that have not been thinned. The vegetation report further 

explains that these areas nonetheless are enhanced and made increasingly resilient by additional 

treatment, with the primary goal of maintaining and enhancing trees of interest and TEK resources, as 

well as maintaining these stand conditions that result in reduced expected basal area mortality during 

wildfire events (final EA p. 166).

29. What is the scientific basis for the EA’s statement that sites exist in the project areas “that (have) 

undergone a type-level conversion due to lack of fire”? (EA at 29). How are these distinguished from 

sites changed due to the heavy logging that has occurred in the project areas? (Denise Boggs, CC, p. 

10)

Response: The statement regarding a type-level conversion on page 31 of the final EA, was in reference 

to how fire suppression and timber harvest practices have contributed to altering species composition in 

the project area. We acknowledge the serious and dramatic vegetation changes that have occurred within 

areas that have been previously clear-cut (final EA p. 7). In addition, there is abundant evidence that in 

the absence of disturbance shade-intolerant species are quickly crowded, over-topped, and eventually 

killed by encroaching conifers (Hunter and Barbor 2001; final EA p. 157). This has resulted in a loss in 

forest heterogeneity, diversity, and structure, including the availability and abundance of TEK forest 

resources. Where this change has progressed to the point that encroaching conifers have reached sizes that 

cannot be thinned using manual fuels reduction and/or prescribed fire, we are forced to consider use of 

mechanical treatments or girdling to achieve desired results of increasing heterogeneity and restoring 

cultural vegetation habitat (final EA pp. 157-158). This strategy has been shown to be effective, as those 

non-plantation areas that have been previously thinned are currently some of the most diverse and fire 

resistant places within the project area (final EA p. 166).

30. The EA indicates that “Exotic grasses, star thistle and Scotch broom function as flashy fuel hazards 

and can increase flammability during wildfires.” Where is any scientific support for the implication 

that the FS would be able to get a handle on populations of these exotic “fuel hazards”? Since there 

is none, the lack of consideration of this fact also befuddles the EA’s larger analyses of predicted 

fire effects. (Denise Boggs, CC, p. 10)
Appendix B. Response to Comments

368 – Somes Bar Integrated Fire Management Project

Response: This quote was taken from the Orleans/Somes Bar CWPP (2012) and is applies to the entire 

Orleans and Somes Bar CWPP planning area. Project design features and mitigation measures for 

containment and management of invasive weeds populations are described on pages 82-85 of the final 

EA. While the project would not be able to eliminate all weed populations within the project area, 

prescriptions have been developed to reduce the risk of further introduction and spread of weed 

populations, and mitigation measures would eradicate small satellite populations of invasive plants (final 

EA p. 100). These actions comply with LRMP guidance and effects on invasive plant populations are 

further detailed in the section on invasive plant species (final EA pp. 258-264).

31. The EA mostly ignores the fact that weather conditions, not “fuels”, drives fire behavior. (Denise 

Boggs, CC, p. 10)

Response: The EA acknowledges the importance of weather conditions as one of several factors that 

determine the probability of fire occurrence (final EA p. 37) and as an important factor driving fire 

behavior (final EA pp. 138-139). The 2017 fires within the NSO analysis area for the Somes Bar Project

burned at lower intensities and did not remove large areas of suitable habitat. Previous research shows that 

fire severity trends correlate well with winter and spring precipitation amounts and temperature inversions 

during smoky conditions (Miller et al. 2012, Estes et al. 2017). The fact that 2017 was one of the wettest 

years in recent history explains why the 2017 fires burned at lower intensities (final EA p.191).Weather is 

one of three (3) components of the famous fire behavior triangle. Of these (fuels, weather, and 

topography), we have the ability as a land management agency to only directly manipulate fuels.

32. Finally, the EA also does not analyze and disclose how the effects of climate change will be in 

harmony with the assumed fire regime that would supposedly come under control of cultural 

practices. No amount of application of practices that were applied in a vastly different climatic 

regime3 can be expected to result in the same conditions in these times and into the future, which 

even FS scientists agree will lead to highly altered fire regimes. “(C)limate change has made 

historic fire regimes a moving target...” EA at 24 (Denise Boggs, CC, p. 10)

Response: The EA acknowledges that climate change is likely to result in conditions different from 

those that were present prior to the fire suppression era (final EA pp. 26, 28). However, we point out that 

TEK and scientific evidence shows that anthropogenic management affects ecosystems in significant 

ways, in spite of climate conditions (Crawford 2012, Crawford et al. 2015, Taylor et al. 2016); (final EA

pp. 126, 157). Therefore, using guidance from both western science and traditional ecological knowledge, 

it is reasonable to implement a prescribed fire and fuels reduction strategy with the hope and expectation 

that it would confer fire resistance and resiliency to these same ecosystems under a future novel climate 

as well. Within the treatment area, the primary objectives are treating dense early and mid-seral stands, 

enhancing resistance and resiliency of mixed hardwood-conifer forests, reintroducing fire, and 

establishing functioning resilient heterogeneous forests at multiple scales (final EA pp.191-192). The 

Somes Bar Project prioritizes treatments that promote resiliency and diversity of forest plants/animals.
Appendix B. Response to Comments

Final Environmental Assessment – 369

33. The best available science that came directly from the FS states that homeowners implementing

firewise practices within 100 feet from the structure will protect homes more than anything else. 

Creating defensible space occurs at the home site, not farther away on national forest lands.

Yet, to the degree that the EA poses fuel reductions outside this home ignition zone as necessary to 

alter fire behavior, in contradiction it fails to consider “fuel” conditions in the surrounding forest, 

which would also influence fire behavior. It makes no sense from a scientific standpoint to be 

analyzing four separate project areas within a larger landscape that is also forest, with undisclosed 

conditions that would respond in undisclosed ways to fire (Denise Boggs, CC, p. 10).

Response: Fuel conditions outside of project area were taken into account in assessing fire hazard and 

planning treatments (final EA p. 140). The Somes Bar Project would aim to blend treatments on federal 

land with treatments conducted on private lands through TREX efforts or others in an effort to build 

resiliency at local as well as landscape scales. To date, the Klamath TREX has accomplished over 950 

acres of prescribed fire on private lands in Orleans and Somes Bar (final EA p.14).

34. What is the scientific basis for the 500-foot buffer? (Denise Boggs, CC, p. 10)

Response: The WKRP partnership realized early on that a landscape-scale approach to fuels 

management was necessary to truly reduce fire hazard and achieve desired cultural and ecological 

benefits and fire effects throughout the WKRP geographic scope (final EA p. 27). However, a 500-foot 

buffer around private property was specifically prioritized for treatment at higher level than other areas 

based primarily on feedback from landowners who wanted to reduce fire hazard and minimize tree 

mortality and visual impacts in these areas (final EA pp. 27-31, 43, 274).

35. Furthermore, as EA Figure 1-3 displays, there are blocks of private land outside of the four project 

areas that are between and among them, but not included in the analysis. And Figure 2-3 shows 

many areas of supposedly moderate and high priority for “treatment.” The EA doesn’t reconcile 

this omission with the project’s need to “reduce vegetative fuel hazards around private properties 

and critical ingress/egress routes...” (Denise Boggs, CC, p. 11).

Response: The four (4) project areas were prioritized and selected during WKRP workshops open to the 

general public using WKRP Zones of Agreement (final EA p. 32). Factors such as; proximity to 

dwellings, critical access and egress routes, existing firelines, trails or ridges suitable for use as control 

features, focal species benefit, as well as building on fuel reduction treatments previously conducted by 

the WKRP Collaborative on private and tribal lands.

Soil Resources (SR)

36. We have concerns with the amount of soil disturbance from mechanical treatments and opening 

vegetation in Riparian Reserves and mastication areas. These concerns have been somewhat 

addressed knowing that the implementation will be closely monitored and that there is a 

rehabilitation component to the Project. (Kimberly Baker, KFA/EPIC, George Sexton, KS Wild, p. 

2).
Appendix B. Response to Comments

370 – Somes Bar Integrated Fire Management Project

Response: The WKRP recognized the likelihood anytime equipment (tractors, masticators, vehicles, 

etc.) traverses off the road and into the forests, there is potential for soil disturbances (displacement, 

compaction, puddling, etc.). For this reason, in 2015 (Hagerty) and 2016 (Hagerty and Young) conducted 

a 100 percent field review of units with proposed mechanical treatments and/or previous management 

using mechanical harvest methods per Region 5 Supplement to the FS-WO Soil Management Manual 

guidance, as outlined in the soils report (pp. 4-6). The objective was to ensure the following soil 

management objectives with this project would be achievable, including keeping soils in place, 

minimizing erosion and sedimentation and maintaining effective soil cover at or above minimum levels.

Soil disturbance has severity and extent aspects that are evaluated together to determine if impacts are 

“detrimental” as defined in the Forest Plan; this is described in the soils report (p. 7). Soil management 

objectives as stated in the report (p. 23) are to minimize soil disturbance severity and spatial extent to be 

within allowable limits established in the Forest Plans, with project-specific provisions (PDFs) to be 

implemented to help achieve those objectives. Specific PDFs have been identified specifically to 

minimize soil disturbance and retention of soil cover in mechanical treatments (final EA pp. 93-94).

37. The EA states that soil impacts are analyzed at a “treatment” unit scale (“the entire ‘footprint’ of 

the project activity units”), but the project proposes to “treat” practically every acre of national 

forest land in the project areas. So where is the quantitative analysis of the past impacts on each of 

these units? The EA also fails to disclose the numbers for increases of detrimental disturbance for 

each of the project units. (Denise Boggs, CC, p. 17)

Response: The requirement for an EA is to demonstrate that the project would be in compliance with the 

Forest Plan(s). The Region 5 Supplement to the FS-WO Soil Management Manual states, “Assessments 

can be conducted on individual treatment units, entire activity areas, or specially designated land 

management areas. The area bounded by the assessment would be described or defined.” This area was 

described in the soils report (p. 14). More importantly, measures are specified (soils report, pp. 23-24) to 

reasonably assure that detrimental soil disturbances would be within allowable limits as set forth in the

Forest Plan(s) post activity. Individual units with concerning levels of past disturbance are disclosed in 

the soils report (p. 30) which triggers additional mitigations. Other units visited were determined to have 

very small or negligible levels of “detrimental”-variety disturbance, except as noted (soils report, pp. 24-

25), given PDFs prescribing rehabilitation for the compacted features.

38. What is the scientific basis that validates the use of measures/estimates of detrimental soil 

disturbance as a proxy for changes in or losses of soil productivity? The detrimental soil 

disturbance limits relied upon are a mitigation of unproven validity. (Denise Boggs, CC, p. 17)

Response: Detrimental disturbance proxy measures are established in the Forest Plan(s). Some of them 

are known to be less than optimal, as discussed in the soils report (pp. 7-10). One of the primary 

objectives of the Long-Term Soil Productivity (LTSP) Research Program (referenced in the soils report, 

p. 31) is to validate or invalidate Forest Service soil quality standards that were put in effect in the Forest 

Plans in the early 1990s; progress along these lines is still a work in progress. However, those 

publications describe a scientific basis wherein proxy indicators must be used, because of the many 
Appendix B. Response to Comments

Final Environmental Assessment – 371

complexities in measuring productivity directly. For example, variations in year-to-year climate, 

particularly springtime precipitation, directly affects productivity of vegetation in that year, so any net 

primary productivity (NPP) measurements must be taken over several to many years, not simply pre and 

post some activity, to statistically deal with climatic variability. Other complexities include individual tree 

measurements where roots surrounding one (1) tree may reside in several different disturbance classes, 

and crowns (especially in an uneven-aged stand) receive different levels of light for photosynthesis; these 

complexities dictate that NPP measurements must be taken on a stand-area basis. More complexities 

involve stand history, disturbance history, genetics, species mix, etc. Directly measuring productivity and 

changes in productivity is a research-level endeavor, and for operational analysis and monitoring purposes 

proxy measures must be used. The ongoing challenge is validating such measures and establishing 

appropriate thresholds for a variety of soil types.

39. The EA relies upon survey methodology that appears to not yield reliable data. What is the 

reliability of “ocular estimates”, LiDAR imagery, and damage you have “assessed qualitatively”? 

(Denise Boggs, CC, p. 17).

Response: LiDAR data was one of many data sources used (similar to use of photographic imagery 

analysis) and was not used as a substitute for on-the-ground observation of field conditions in assessing 

existing conditions or planning PDFs and mitigation methods. LiDAR imagery was utilized solely to 

increase the resolution of topographic features to inform data collection strategies for cultural resources, 

riparian reserves, vegetation and existing features such as ridges, streams and trails. The LiDAR dataset 

collected by Quantum Spatial Inc. and used during project planning has a pulse density of greater than 8 

pulses per m2

. At this pulse density, elevation products, which are the basis of roads and stream analyses, 

can be expected to be accurate within 1 meter (horizontally and vertically).The fine resolution imagery 

that LiDAR provides helped to validate vegetation patterns and variability in stand structure and was 

utilized to inform the retention and openings prescriptions.

The Forest Service has as one (1) method of assessment our National Forest Soil Disturbance 

Monitoring Protocol (NFSDMP, Page-Dumroese et al., 2009; refer to for details [accessed 3/29/2018]:

https://forest.moscowfsl.wsu.edu/smp/solo/InfoPath/monitoring/documents.php#reference); this protocol 

uses entirely qualitative ocular methods, and is scientifically and statistically proven with many 

supporting publications. Qualitative and ocular methods are common and accepted in the soil science 

community, and there is nothing inherently unreliable about such methods, especially when practiced by 

an experienced individual.

40. Since soil porosity reduced by soil compaction is mostly below the surface, why hasn’t the FS 

measured soil porosity directly in the project area? (Denise Boggs, CC, p. 17)

Response: There is no proven technology to measure soil porosity directly. The conventional method is 

to calculate total porosity from soil bulk density, which can be measured from core sampling or 

excavation methods. The project soil scientist has a robust background in quantitative compaction 

research while with PSW Research Station, and trains others in using the NFSDMP protocols already 

mentioned. Most quantitative compaction methods fail to quantify pore connectivity, pore size 
Appendix B. Response to Comments

372 – Somes Bar Integrated Fire Management Project

distribution, or root distribution patterns. Some soil scientists suggest that qualitative assessment of 

compaction is superior to measurements, because root growth patterns can be inspected, which may more 

directly assess the soils’ quality as a growth medium for roots. This latter approach is described in the 

soils report (p. 20): “for compaction inspecting soil for platy structure and presence & distribution of fine 

to medium roots to estimate whether root growth pattern was affected (excluded or restricted).” This is a 

commonly accepted compaction inspection method.

41. “Less-frequented old skids (with fewer passes) are assumed to be okay...” Define “okay” using 

scientifically and statistically sound terminology. (Denise Boggs, CC, p. 17)

Response: In the context of the preceding portion of the paragraph (soils report, p. 20), “okay” means 

below the detrimental compaction threshold established in the Six Rivers LRMP (10% reduction in total 

porosity), as assessed qualitatively by conventional inspection methods for this project.

42. “(E)ffects of burning have apparently recovered...” Define “apparently recovered” using 

scientifically and statistically sound terminology. (Denise Boggs, CC, p. 17)

Response: As stated in context in the soils report (pp. 20-21), “apparently recovered” means “having no 

heavily oxidized or charred surface soils” which would be expected immediately after pile burning at the 

time it had occurred. Such observable effects would have been present, they are now absent, and ergo the 

soil has recovered. This is based on scientific observation and professional judgement.

43. “The Proposed Action is in compliance with FSM direction and all S&Gs...” Why doesn’t the EA 

state the “R5 SQS” and FSM direction and all S&Gs it relies upon? (Denise Boggs, CC, p. 17).

Response: The final EA discloses the “R5 SQS” and FSM direction and all S&Gs it relies upon under 

“Regulatory Framework” section of the soils report (pp. 4-11), which outlines in detail all of these 

directives and standards and guidelines.

44. “Detrimental disturbance in greater than 15 percent of the area is used to constitute adverse 

impacts.” What is best available science to support the implication that only disturbance greater 

than 15% of some area is significant? (Denise Boggs, CC, p. 18)

Response: The Six Rivers LRMP (pp. IV-71, Appendix L-1) states that detrimental compaction (as 

defined) cannot occur in greater than 15 percent of the area; the Klamath LRMP has no equivalent aerial 

extent of compaction standard or limitation of skid trail area. Conventionally we use 15 percent of the area 

for all detrimental disturbances collectively within a defined area as a threshold of concern which may 

constitute “substantial and permanent impairment of the land” in NFMA (1976) parlance, or “adverse” in 

NEPA (1970) parlance. It has no scientific basis. Best available science indicates that “significant” soil 

disturbance levels would be different for different sites and soils and kinds of disturbance, but there is no 

“modern” direction in terms of standards on the matter. The latest results from the LTSP study (ibid) 

indicate that most sites can tolerate soil disturbance far exceeding our current standards and guidelines (in 

severity and extent) without negatively affecting productivity, indicating that the Six Rivers standard may 

well be too conservative; yet it is still in effect and directed to be used here. The Klamath Plan has no 
Appendix B. Response to Comments

Final Environmental Assessment – 373

restrictions on aerial extent of soil disturbances, so this project is taking a conservative approach toward 

minimizing soil impacts project-wide to less than 15 percent of any given area as defined.

45. “(A)reas of units that were previously managed with mechanical ground-based entry...are 

considered detrimentally compacted. This is generally estimated to be about 5 to 10 percent aerial 

extent of these units...” Statistically speaking, how much error is characteristic of the kind of 

measurements or estimates used here? (Denise Boggs, CC, p. 18).

Response: The observed unit mean would conservatively be +/-4 percent absolute, and when 

amalgamated standard error would be +/-10 percent of the true mean with 80 percent confidence interval.

Units approaching anywhere close to 15 percent detrimental disturbance were highlighted for additional 

mitigations (soils report p. 30).

46. “Organic matter currently exists in kinds and amounts sufficient to prevent significant nutrient 

cycle deficits, and to avoid detrimental physical and biological soil conditions...” This statement 

seems to be made in the absence of any data or reference to best available science. The EA states in 

contradiction, “Coarse woody debris is generally ... deficient in plantations currently.” (Denise 

Boggs, CC, p. 18)

Response: Coarse woody debris is but one form of organic matter that contributes to nutrient cycling and 

substrate for soil biota. This is not a contradiction, both statements are correct. For soils, the fine organic 

matter (duff, leaves, needles, twigs) is much more nutrient rich than CWD and more important for soil 

nutrient cycling and humus formation by soil microbes. Furthermore, Forest Plan directives: “Both Forest 

Plans specify at least 50 percent cover of duff and fine litter for soil productivity” (soils report p. 29).

Prescribed burns that aim to preserve greater than 50 percent duff cover for erosion prevention should 

likewise not be hot enough to significantly degrade SOM in the surface soil, except perhaps in small 

patches, as with pile burning. Broadcast burning prescriptions as practiced usually produce low to 

moderate soil burn severity (SBS), as opposed to 5 to 15 percent high SBS + 30 to 40 percent moderate 

SBS typical for wildfires in this vicinity (BAER records, on file with author).

47. How can “extra CWD” in one place “compensate for plantations on a project-wide basis”? This 

makes no sense in the context of soil cumulative effects specifically stated to be analyzed on a 

“treatment” unit basis. (Denise Boggs, CC, p. 18)

Response: Despite this comment being stated as an “unknown” in the soils report (p. 29), this is a good 

point that deserves explanation. The response to the previous comment pertains here as well. CWD 

certainly has ecological benefits aboveground, but has limited value for soils proper as an organic matter 

input due to its low nutrient content and high lignin content, and its tendency to burn before it becomes 

soil organic matter in this environment. The “new” R5 Soil Management Supplement (2010, renewed 

2017) has no CWD standards at all for soils, which is perhaps why it is discussed differently. CWD by 

nature is “clumpy” and is thought to be more appropriately assessed at larger scale, i.e., “project wide 

basis.” However, we concede that both Forest Plans have CWD standards in effect that apply to soils, 

even if out of date. The full context of discussion on this matter within the soils report and EA.
Appendix B. Response to Comments

374 – Somes Bar Integrated Fire Management Project

48. “It is an assumption that runoff and erosion concerns are expected to be controlled on-site through 

effective BMPs and drainage controls.” What is the scientific basis that validates this assumption? 

(Denise Boggs, CC, p. 18)

Response: The BMPs are very relevant to soils in that they are designed on a project-specific to prevent 

or minimize surface erosion and sediment movement, and the comment comes from the soils report (p. 

14). The quote follows a discussion on the previous page where it states the assumption is that BMPs 

would be “effectively applied as intended” (soils report p. 13). BMPs are proven effective measures with 

a long history of applied scientific basis and monitoring programs at national and state levels. The soil 

scientist does not prescribe BMPs. Rather, monitoring by the hydrologist ensures BMPs would be 

implemented as intended or corrected as necessary, as stated in the soils report (p. 13).

49. “Soil temperatures would be elevated due to opening the canopy and increased solar exposure of 

the soils.” Since this logically translates to higher temperatures of runoff and/or water infiltrating 

to groundwater, how does this avoid increasing stream temperatures? (Denise Boggs, CC, p. 18)

Response: Being in a Mediterranean climate, with hot dry summers and cool wet winters, precipitation 

events rarely occur in the summer season when soil temperatures would be elevated. Runoff and water 

infiltrating to groundwater would occur primarily in the winter season, when soil temperatures would 

actually be cooler if not covered by snow, or neutral (normal) if covered by snow. A lesser portion of 

precipitation would come in fall and spring seasons, when daylight is shorter and soil temperatures would 

be neutral (normal) or close to it.

Relative to temperature effects, non-fish-bearing streams tend to be narrow channels in steeper 

constrained valleys (Moore et al. 2005). Near-stream vegetation and topographic features often shade the 

entire channel such settings (Janische et al. 2012; final EA pp. 218-219). A study conducted in western 

Oregon (comparable vegetation types and geology as in the project area) of thinning treatments and the 

effects on stream temperature showed that thinning in primary shade zones (area adjacent to stream 

channels that provides stream shade during periods of greatest solar loading) along 6 miles of stream led 

to a 4 degree (F) increase in temperature (NWFP Temperature TMDL Implementation Strategy 2010). In 

dense riparian areas such as in the project area, optimum shade can be provided by the primary shade 

zone alone (ibid). Near-stream vegetation and topographic features often shade the entire channel in such 

settings (Janische et al. 2012). Water temperatures in headwater streams are also strongly influenced by 

in-channel substrate (ibid). Neither of these factors would be affected managing vegetation within riparian 

reserves. The table below displays findings relative to minimum widths of primary shade zones needed 

maintain suitable shade. All proposed buffer widths are greater than the widths recommended in Table B3 below. Given the project conservative protection of the primary shade zone, increase in stream 

temperature is unlikely. In the long term, a more fire-resilient stand would promote and maintain 

appropriate shade over time, provide for larger trees and a diversity of desired species in the riparian area 

(final EA pp. 221-222). And any such effects would temporary (soils report p. 31).
Appendix B. Response to Comments

Final Environmental Assessment – 375

Table B-3. Minimum width of primary shade zone (feet) based on slope and tree height.35

Tree height Hill Slope Percent

<30 30 to 60 >60

<20 feet 12 14 15

20 to 60 feet 28 33 55

>60 to 100 feet 50 55 60

>100-140 feet 70 75 85

50. “The threat of wildfire to the soil resource should not be underestimated.” If we suspend better 

judgment that tells us the specter of fire is being used to justify logging, please explain how this 

threat is being estimated in ANY quantitative, objective means? Please cite examples, from 

assessments of recent fires in or near the project area, that validate what appears to be merely an 

inflammatory statement. (No pun intended.) (Denise Boggs, CC, p. 18.)

Response: Mechanical treatments are employed to restore forest conditions, including increasing and 

enhancing forest structure, heterogeneity, diversity, and TEK resources, and are also expected to increase 

wildfire resistance and resiliency in treated areas, especially when combined with manual and prescribed

fire treatments (final EA p. 55) The project soil scientist is a nationally reputed figure in the Forest 

Service’s Burned Area Emergency Response Program (BAER), and has mapped soil burn severity on 

millions of wildfire acres to date across the western United States and abroad (Australia, Israel). Closer to 

the project area, the project soil scientist has been Team Leader and/or lead soil scientist on fires such as 

Backbone, Happy Camp Complex, Route Complex, River Complex, Gap, Pony, and most recently the 

Eclipse Complex which includes the Oak Fire that burned just north of the project area. BAER soils 

reports exist for all these fires, documenting wildfire effects to soils and relative proportions of fieldverified soil burn severity classes (www.fs.fed.us/rm/pubs/rmrs_gtr243.pdf). High soil burn severity by 

definition is damaging to soil organic matter, structure, and aggregate stability, and exposes the soil to 

erosion for lack of soil cover, all of which may have lasting effects to soil recovery and productivity. It is 

sobering to witness the scale of soil damage from wildfires year after year; individual “patches” of high 

soil burn severity often far exceed the footprint size of management projects, or by orders of magnitude 

for some of the “megafires” such as Moonlight, Rim, King, and Pioneer, all of which this project soil 

scientist has mapped. Some of that experience translates over to put a greater context on the minor scale 

of soil impacts seen on projects such as this. One explicit objective with prescribed burns associated with 

this project is to avoid high soil burn severity effects, to be accomplished through burn plan prescription 

parameters as well as the PDFs described in the EA.

51. The EA expresses “a concern with the extent and frequency of burning being proposed with this 

project.” Yet, “It is expected that burns would be conducted with target residual cover levels in the 

prescription, and all units should accordingly meet this requirement at unit-scale post- activity.” 

Why is it “expected”? (Denise Boggs, CC, p. 18)

 35 Source: Northwest Forest Plan Temperature TMDL Implementation Strategy 2010.
Appendix B. Response to Comments

376 – Somes Bar Integrated Fire Management Project

Response: The soils concern is appropriately phrased and disclosed, as erosion from denuded areas of 

significant scale, if delivered to a stream course, represents an export of soil and an irretrievable loss in 

human timeframes. Thus, the concern must be mitigated, such as with soil cover retention PDFs proposed 

for this project (soil report p. 23). A site visit was taken to one such prescribed burn area (Roots and 

Shoots Cultural Burn), with soil cover (duff) levels acceptable and signs of any significant erosion absent.

The soil scientist was satisfied with a demonstration that local staff could implement prescribed burns 

with favorable results, and it was thus “expected” that similar results would be the norm for the Somes 

Bar project, which would be monitored to confirm or deny assumptions, in the latter case requiring 

corrections to subsequent burn plans.

52. “It is thus expected that all units would meet this (15%) standard post-activity.” Please explain why 

is it “expected”?” (Denise Boggs, CC, p. 18)

Response: This quote is connected to the appropriate disclosure that there are some project units that are 

close to exceeding the 15 percent standard currently; unit-specific mitigations were prescribed for these 

units to ensure compliance, as stated in the soils report (pp. 28, 30). These are practices that have 

produced favorable results on many other projects, and there is no reason to expect different results here.

All other units that do not have higher levels of current (past) disturbance are simply a matter of limiting 

skidding area with the proposed project, which is a standard mitigation applied to most projects, here and 

elsewhere, a standard that sale administration staff are accustomed to, and a standard that has been 

demonstrated as implementable and achievable without undue burden in many, many projects. Thus it is 

expected to be an achievable end result with this project as well. Forming expectations, from many 

observations of like actions on a variety of soils elsewhere, is a very basic part of the analysis process, as 

stated in the soils report (p. 13): “Analysis first requires an assessment of the existing or baseline 

condition and then a prediction of the effects from the proposed activities... Soil impacts from proposed 

activities consider the types of activities, types of equipment and manner of operations expected, potential 

for detrimental disturbances, including where and to what extent, and further how long impacts are 

expected to persist considering expected rates of natural recovery or revegetation.” There obviously must 

be “expectations” built into the process of predicting effects. One cannot “know” future effects, but one 

may reasonably deduce from observations taken from other like projects that have occurred.

53. Why does the FS rely upon a “non-implementable” standard? (Denise Boggs, CC, p. 18)

Response: The Forest Service Washington Office (WO) Manual 2550 – Soil Management (Nov. 2010) 

provides a national directive to maintain or restore soil quality on NFS lands, and establishes the 

management framework for sustaining soil quality and hydrologic function while providing goods and 

ecosystem services outlined in Forest and Grassland land management plans. The FSM defines soil 

productivity and soil quality, and describes soil functions that may be used in evaluating soil quality. The 

FSM outlines programmatic requirements for assessments, analyses, and monitoring pursuant to 

management activities, and outlines general requirements that Standards and Guidelines be developed and 

implemented at Regional and Forest levels.
Appendix B. Response to Comments

Final Environmental Assessment – 377

The Forest Service Region 5 FSM Supplement – Soil Quality Mgmt (R5-2500-2017-1) is applied to 

lands dedicated to growing vegetation. The Supplement specifies three (3) key soil functions to be used in 

R5 for assessment and analysis of soil quality: support for plant growth function, soil hydrologic function, 

and filtering-buffering function. Indicators and desired conditions for indicators are outlined for each soil 

function. Soil condition is rated as good, fair, or poor for each indicator relative to the desired condition. 

This approach is intended to help determine the status and trend of soil management, determine whether 

ecosystem health and long-term soil productivity is being maintained, and better determine needs and 

priorities for restoration activities.

Quantitative measures or thresholds/limits for various types of soil disturbance are not provided in the 

Supplement, recognizing that one-size-fits-all ‘standards’ are often inappropriate for particular or 

differing soil types, and recognizing that disturbances need to be evaluated in a site and soil specific 

manner during assessments and analyses. The soils analysis for the Somes Bar Project was based on 33 

years of experience as a Soil Scientist, experienced in design, implementing, and monitoring a wide 

variety of forestry and vegetation management projects in the west-coast states and Alaska, with 

specialties in soils, geology, silviculture and logging systems. Based on expert knowledge in soils 

management, specific measures, indicators, and thresholds were established for the Somes Bar Project to 

evaluate effects to soil quality and site productivity (final EA p. 232-246).

The only “non-implementable” standard mentioned in the soils report (p. 9) is the “soil environmental 

health” standard in the Six Rivers Plan (p. L-2) which pertains specifically to “added chemical, heavy 

metals, or organic compounds” which is not applicable to activities proposed with this project. Adding 

such materials to soils would be unusual, so this standard is rarely raised; the only applicable examples 

may be for herbicide or biochar applications.

54. How have invasive plants affected soil productivity in the project areas? (Denise Boggs, CC, p. 18).

Response: The majority of the invasive plant sites in the project area were associated with previously 

and chronically disturbed settings such as road edges, clearings and turnouts. Soil productivity in these 

settings is already compromised. Most of the project area is forested and therefore not vulnerable to 

invasive plant species, which are typically shade intolerant. An exception is the Himalayan blackberry 

that does occur in riparian areas and PDFs are employed to maintain appropriate shade and native plant 

competition. There are studies with specific invasive plant species that indicate that invasive plants can 

suppresses native plant growth by disrupting mutualistic associations between native canopy tree 

seedlings and belowground arbuscular mycorrhizal fungi upon which the native tree seedlings depend 

(Stinson et. al. 2006). In another case that involved an invasive grass species, it was determined that the 

presence of the species, Holcus lanatus, resulted in negative soil feedback on native plants (e.g., changing 

the available nitrogen to the native plants).

55. The EA does not cite any empirical basis for expected effectiveness of project mitigations for 

Sensitive plants and soils. (Denise Boggs, CC, p. 20)

Response: The project soil mitigations have been applied and observed on many other projects with the 

same activity types and objectives and similar terrain and soils, and this observational experience is an 
Appendix B. Response to Comments

378 – Somes Bar Integrated Fire Management Project

empirical basis by definition. Soil mitigations have been observed to be effective elsewhere, and there is 

no basis to believe it would be different here with this project.

The following references provided the empirical basis for the analysis:

Hoover, L.D. 2017b. Invasive Plant Risk Assessment and Project Design Features, Somes Bar 

Integrated Fire Management Project, Orleans and Ukonom Ranger Districts, December 12, 

2017.

Hoover, L.D. 2018. Invasive Plant Risk Assessment and Project Design Features, Somes Bar 

Integrated Fire Management Project, December 15, 2017, Addendum March 28, 2018.

Hoshovsky, M. 2015. Invasive Plants of California’s Wildlands. California Invasive Plant 

Council. Himalayan blackberry, Rubus discolor, R. armeniacus. www.calipc.org/ip/management/ipcw.

Soll, J. 2004. Controlling Himalayan Blackberry (Rubus armeniacus [R. discolor, R. 

procerus]) in the Pacific Northwest. Ed. Brian Lipinski. The Nature Conservancy. 

www.invasive.org/gist/moredocs/rubarm01.pdf.

Vegetation (V)

56. A pressing request that we have is to err on the side of more forest canopy, primarily in nonplantation stands. Canopy closure is very subjective. The Project proposes to take canopies down to 

habitat minimums for late seral dependent species. (Kimberly Baker, KS Wild, p. 2)

Response: WKRP designed treatment prescriptions within non-plantations centered on a conservative 

half release of culturally important tree species (“trees of interest”) whose populations have declined as 

the result of fire suppression (Taylor and Skinner 2003; Crawford et al. 2015; final EA p. 47, 157). These 

species are expected to respond quickly by increasing the size of their crowns within just a few years after 

release (Devine and Harrington 2006). While we allow canopy cover within the thinning area to be 

reduced the habitat minimums for late seral species within these areas, crown expansion by epicormic 

sprouting species is likely to partially fill in canopy gaps very quickly around released trees of interest 

(final EA p. 171). The only other way that canopy closure would be affected in non-plantations is through 

the creation of openings. The location of these openings would be focused in areas that are devoid of 

large trees (relative to stand conditions) and in high insolation areas. Smaller openings (<0.5 acre) are 

proposed in NSO habitat areas (Final EA pp. 413-422).

Watershed Values (WV)

57. The EA makes statements to the effect that the project would be consistent with the Klamath River 

TMDL and “the Waiver” but it doesn’t disclose what those requirements are. (Denise Boggs, CC, p. 

17)

Response: Comments 58 to 63 in Appendix B (final EA pp. 344-346) of the EA disclose how the project 

will meet the conditions of The Waiver and the Klamath River TMDL. For example, the proposed action 
Appendix B. Response to Comments

Final Environmental Assessment – 379

includes restoration of legacy sediment sources discovered in the project area, a requirement for The 

Waiver. The Somes Bar Project would rehabilitate 1.1 miles of legacy roads in the project area (final EA

pp. 70-71). Treatments within and adjacent to stream channels have riparian reserves buffer widths

designed to maintain proper shade to prevent elevated stream temperatures (final EA pp. 221-222) in 

compliance with the Klamath River TMDL.

58. How has the FS estimated the amount of sediment movement into streams and waters attributable to 

log hauling and other uses of roads in the cumulative effects analysis area? (Denise Boggs, CC, p. 

17)

Response: The ERA model is designed to determine whether past and present land management 

activities in a given watershed approach or exceed a TOC whereby changes in peak flows and hence 

sedimentation might occur (final EA p. 232). All roads in the cumulative effects analysis area (analysis 

area is depicted in the final EA p. 225) regardless of whether or not it would be utilized for project 

implementation. ERAs associated with roads in the analysis area are calculated and included in the total 

existing ERA by watershed (final EA p. 233).

59. Does the FS consider scientific information that discusses where BMPs have not effectively 

protected water quality and fish habitat? (Denise Boggs, CC, p. 17)

Response: Yes, the FS conducts a non-bias review of scientific information, including circumstances 

where BMPS have been found to be less effective than predicted, or not effect at all. Consequently, BMPs 

implementation and effectiveness protocols are validated on the ground and documented. The purpose for 

the National BMP Program is to provide a consistent, credible, and affordable agency-wide BMP 

monitoring program with coordinated data collection; monitoring information that can be aggregated at 

any scale; a database accessible to all Forest Service users; and reports that would be shared with EPA,

States, and other partners. This type of monitoring program provides a continuous feedback loop for a 

successful adaptive management process. Descriptions of the applicable BMPs are shown in Appendix D

(final EA pp. 433-441).

60. Draft EA identifies and describes legacy sediment site treatments but lacks a proposed legacy 

sediment site treatment plan. An acceptable legacy sediment site treatment plan includes an 

inventory and schedule for treatment of all legacy sediment sites within the project boundary. The 

legacy sediment site treatment plan for the Project shall be submitted with the Waiver application 

and approved by the Executive Officer before Waiver coverage will be granted. Given the large 

project area, if SRNF does not propose to treat all legacy sediment sites within the Project area, an 

alternative legacy sediment site treatment plan may be submitted to the Executive Officer for review 

prior to approval. (Fred Blatt, RWB, p. 3)

Response: The EA lists six (6) segments, totaling 1.1 miles of legacy roads found in the project area 

(final EA p. 70-71). The identified legacy sites would be scheduled for treatment upon completion of the 

NEPA process. The following actions would be employed at all legacy sediment sources identified in the 

EA, aimed at removing the potential for off-site sedimentation that could impact water quality and:
Appendix B. Response to Comments

380 – Somes Bar Integrated Fire Management Project

Excavated road fill would be stored on-site and in stable locations.

Construct waterbars drainage features to prevent water from concentrating on the roadbed.

Cover disturbed ground with native material gathered on sites (tree boughs).

Install earthen log barrier at locations to effectively block motor vehicle access.

All ground-disturbing work would occur during the dry season, have appropriate erosion 

control plans developed and BMPs incorporated into project plans (final EA pp. 70-71).

Since the adoption of the Aquatic Conservation Strategy objectives in both Six Rivers and Klamath 

national forest LRMPs, emphasis on watershed restoration has been a focus in the project area. Beginning 

in 1999, approximately 156 miles of forest road were stormproofed and 62 miles of roads have been 

decommissioned to date (final EA p. 227).

61. The Draft EA identifies several units within ground-based harvest units that either propose use of 

heavy equipment or end lining trees out of the outer 80-feet of riparian reserves. Please provide 

maps of units that propose use of heavy equipment or end lining within riparian reserves in the 

Final EA or Waiver application. (Fred Blatt, RWB, p.3)

Response: The EA lists all the units that either propose use of heavy equipment or end lining of trees 

within the outer 80-feet of riparian reserves (final EA pp. 85-87). These units are shown in the proposed 

action maps (final EA pp. 72, 74, 76, 78). The Waiver application would provide maps of only the units 

where these activities occur within riparian reserves.

62. The Draft EA identifies the use of existing landings within or adjacent to riparian reserves. Please 

incorporate in the Final EA the specific on-the-ground prescriptions or the project design features 

designed to meet the USFS best management practices and provide protection measures for 

landings within riparian reserves. Additionally, please provide a map of designated landing 

locations proposed for use within riparian reserves in the Final EA or Waiver application. (Fred 

Blatt, RWB, p. 3)

Response: The EA lists all applicable BMPs and includes specific measures to protect water quality. The 

BMP that addresses erosion control of existing landings is Road-9 Parking and Staging Areas (final EA p. 

447). A map of all existing landings located within riparian reserves would be included with the Waiver 

application.

63. The Draft EA identifies that existing skid trails are proposed for use within the Project area. Please 

identify, in the Final EA or Waiver application, if the Project area has been evaluated for the 

presence of legacy sediment sites associated with any existing skid trail watercourse crossings. If 

there are legacy sediment sites associated with existing skid trail watercourse crossings within the 

Project area, please include the sites in the legacy sediment site treatment plan in the Waiver 

application. (Fred Blatt, RWB, p. 4).
Appendix B. Response to Comments

Final Environmental Assessment – 381

Response: No legacy sediments sites associated with skid trail watercourse crossings were discovered in 

the project area. All legacy sediment sources included in the proposed action area are disclosed in the 

final EA (pp. 70-71).

64. The EA states, “After 15 years under the riparian reserves system, 70 percent of the watersheds had 

improved and 18 declined. The primary factors for improvement were an increase in the number of 

large trees (>20 inches dbh) in riparian areas and reduction in road densities in watersheds.” Now 

the FS wants to reduce large trees in riparian areas. The EA states that mechanical (commercial) 

“treatments” would be approved for 147 acres in the outer 80 feet of the riparian reserves. Some of 

this is coho salmon critical habitat, where adverse impacts are unavoidable. And somewhere near 

182 acres of ground disturbance could occur within riparian reserves upstream of fish bearing 

portions of the stream. (Denise Boggs, CC, p.15.)

Response: The purpose and need for the project aims at restoring and maintaining resilient landscapes 

by reducing ladder fuel patterns and lowering the amount of flammable surface fuel (final EA pp. 9-10). 

The proposed action calls for thinning from below (thinning the smallest trees in a stand) (final EA p. 

156). The proposed action retains all pre-dominant and dominant tree size classes in all treatment units 

(final EA pp. 46, 414-419). Thinning is focused on areas that can benefit from low thin to reduce the 

likelihood of passive crown fire (final EA p. 417). The 147 number are acres that are thinned using 

mechanical means. The 172 represents the 147 plus riparian acres disturbed through legacy road 

decommissioning and culvert upgrading (final EA p. 232).

No mechanical fuel reduction units are found adjacent to occupied coho salmon habitat or 

within the inner 80 (non-fish bearing) to 240 (fish bearing) feet of all riparian reserves (final 

EA p. 230). The final Fish BA/BE determination was agreed to through the Level 1 process 

with NMFS as “may affect not likely to adversely affect” (final Fish BA/BE pp. 5, 78) 

All management actions on NFS lands must be consistent with the Aquatic Conservation 

Strategy Objectives including riparian reserve S&Gs (final EA p.217).

65. What scientific research establishes water quality and riparian and aquatic habitat benefits of the 

proposed “treatments”? (Denise Boggs, CC, p. 15).

Response: The hydrologic function most vulnerable to the Proposed Action is quality of streamflow. 

Proximity of ground disturbance to riparian reserves in an important factor controlling sediment delivery 

(Rashin et al. 2006; final EA p. 221). Analysis of the proposed actions reveals that less than 172 acres of 

ground disturbance would occur within riparian reserves upstream of fish bearing portions of the stream. 

The vast majority of these actions occur within the outer 80 feet of the riparian reserves, leaving the inner 

riparian reserve (80 feet for non-fish bearing streams) function as a filter to sediment movement. Project 

design features, wet weather operating standards and Best Management Practices (BMPs) are 

incorporated into the Proposed Action specifically to further insure a low risk to water quality as a result 

of implementing this project. Fuel reduction treatments can influence wildfire severity. Fuel reduction 

treatments conducted on the neighboring district (Lower Trinity RD, SRNF) a few years prior to the 
Appendix B. Response to Comments

382 – Somes Bar Integrated Fire Management Project

Megram fire in 1999, reduced high burn severity to 3 percent of the acres treated (Horse Linto, Mill and 

Tish Tang Watershed Analysis, USDA Forest Service 2000b; final EA pp. 231-232).

A recent publication, Riparian Fuel Treatments in the Western USA: Challenges and Considerations

(Dwire et al. 2016), described the following considerations for managing fuels in riparian areas:

Riparian areas are part of the landscape and may need fuel treatments based on fuel loading 

within and in surrounding uplands. Reducing the risk of high severity fire in riparian areas 

can limit the effects to riparian dependent species such as TEK focal species willow and 

pacific giant salamander as well as limit the spread of invasive species.

Fuel reduction treatments can potentially assist in riparian and stream restoration by returning 

fuel loads and vegetation and result in more spatially diverse range of habitat components with 

long-term benefits for multiple wildlife species, including TEK focal species Roosevelt Elk.

Forest plans direction allows for silviculture and fuels treatments within riparian reserves when needed 

to meet ACS objectives. Fuel reduction treatments can potentially assist in riparian and stream restoration 

when actions include the return to fuel loads and vegetation that supports ecosystem processes and natural 

disturbance regimes, including restoring fire to the landscape (Dwire et al. 2016; final EA p. 220).

66. “Ground disturbing activities are proposed on approximately 15 acres (1 percent of all mechanical 

timber harvest units) of riparian reserves associated with unstable lands...” Why not drop these 15 

acres, given the risk involved? (Denise Boggs, CC, p. 16)

Response: No mechanical vegetation management activities are occurring on the geologically unstable 

lands which are defined as active landslides, all inner gorges, margins and toe zones of dormant 

landslides, and severely weathered and dissected granitic lands. Mechanical treatments occurring on areas 

mapped as unstable lands occur only within the dormant sections of deep-seated earthflows, are very 

minimal in area, and use low impact ground-based, road-based and cable methods (final EA p. 220). For 

these reasons, there is minimal to no risk of altering the extent or form of landslides in these areas. 

Because the prescriptions aim to thin stands leaving the majority of trees, this greatly decreases the risk of 

landslide activation due to loss of root strength and increase in pore pressures from increased groundwater 

volume known to be associated with total loss of vegetation (Reid 2010, Ziemer 1981, Robichaud 2000, 

Bosch and Hewlett 1982; Geology Report p.3).

67. What scientific research validated Threshold of Concern (TOC) and Equivalent Roaded Area (ERA) 

for analyses such as for the Some Bar? (Denise Boggs, CC, p. 16)

Response: Threshold of Concern by watershed is established in the 1995 Six Rivers and Klamath 

National Forest Plans. The TOC is an estimated upper limit of total disturbance that a watershed can 

tolerate without adverse impacts to beneficial uses. In the event that the total percent ERAs approach a 

TOC, management actions should be evaluated to insure that detrimental cumulative watershed effects do 

not occur. In developing TOCs, several physical and biological parameters were evaluated, including 

inherent geologic stability, extent of inner gorges plus active and inactive landslides, erodibility of soils, 

slope steepness, status of anadromous fish, condition of riparian areas and others. Assigning a TOC to a 
Appendix B. Response to Comments

Final Environmental Assessment – 383

given watershed is an interdisciplinary professional judgment that weighs the various environmental 

indicators described above (final EA p. 451).

The Forest Service in Region 5 has adopted the Equivalent Roaded Acres (ERA) model as a method of 

addressing cumulative watershed effects (Forest Service Region 5 FSH 2509.22 Soil and Water 

Conservation Handbook, Chapter 20; final EA p. 455), requires that the Forest Service assess and consider 

the potential for cumulative watershed effects of proposed activities. The Forest Service Pacific Southwest 

Region Cumulative Watershed Effects policy provides an approach to assessing the potential for 

cumulative watershed effects related to management activities on NFS lands. The approach uses the 

equivalent roaded area model to make a preliminary assessment of watershed conditions by comparing 

effects of past, existing, and reasonably foreseeable actions to a watershed threshold of concern. More 

detailed analyses are required when equivalent roaded area totals equal or exceed the threshold of concern.

68. “Because all of the units identified for mechanical treatments are in previously managed stands 

that were either high graded or clear cut, there are ample existing skid roads and old logging roads 

with which to operate on, thereby decreasing the need for new skids or temporary roads.” Does this 

mean all the stated 147 acres of riparian reserve logging is in old clearcuts? And with all the 

“ample existing skid roads and old logging roads” in riparian areas, the EA doesn’t quantify, map 

locations of, or disclose the ongoing impacts of these damaged areas. (Denise Boggs, CC, p. 16)

Response: All mechanical treatments proposed within riparian reserves occur in previously managed 

stands that were either clearcut or selectively harvested (final EA pp. 44-46). Results of the ERA model 

indicate that current conditions of the watersheds in the project area are well below the TOC for adverse 

CWEs. The current conditions of Ti Creek and Reynolds Creek watersheds are due in a large part to the 

NWFP revisions in 1995, of which both the KNF and SRNF LRMPs were updated to align with this new 

direction. Aquatic Conservation Strategy objectives were established, paving the way for extensive 

watershed analyses and subsequent restoration of sediment sources. In response to this new direction, the 

SRNF completed the East Ishi Pishi Road Restoration Environmental Assessment (2001). As a result, 

approximately 156 miles of road were stormproofed and 62 miles of road decommissioned. Additionally, 

the bulk of past timber harvest areas are well over 30 years old and much of the hydrologic processes 

impacted by past timber harvest activities have since recovered, and there have been limited timber 

harvesting (primarily commercial thinning for hazardous fuels reduction) in the Ti and Reynolds creek 

watersheds (final EA p.227).

69. “Project design features require any heavy equipment that operates within the riparian reserve do 

so in such a manner (linear passes and no turning of machinery) that does not displace or compact 

soils.” How can the FS say straight-faced that heavy equipment in riparian areas won’t compact 

soils? And if there is no turning, how does the equipment get back out? (Denise Boggs, CC, p. 16)

Response: Heavy equipment operations shall occur when soils are dry enough to avoid deep rutting or 

puddling; operating over a duff and slash “mattress” .Heavy equipment can travel in reverse gear and 

back out the same path as entered. The EA clarifies that limited use of heavy equipment in riparian 

reserves would not result in detrimental soil compaction (final EA p.229).
Appendix B. Response to Comments

384 – Somes Bar Integrated Fire Management Project

70. “Restoration of legacy sediment sources in the project area is a requirement to receive a Waiver...” 

Is there a comprehensive inventory of legacy sediment sources in the project area? (Denise Boggs, 

CC, p. 16).

Response: All legacy sediment sources included in the proposed action area are disclosed in the final EA 

pp. 70-71.

Wildlife (W)

71. Also, there is no substantive information on whether or not “take” will be authorized in this 

project. We can only assume there will be, considering four activity centers (ACs) are under 

minimum habitat thresholds while the project will log inside each of them. Without this 

determination, we cannot make fully informed comments (Denise Boggs, CC, p. 2).

The EA indicates the FS worked with the USFWS on the BA during the consultation process. The BA 

could change after the public comment period ends – and if so that’s a NEPA violation. This project is 

documented in an EA and therefore a FONSI is required. Under the USFWS own rules it will have to 

authorize “take” in this project, and if so, a MANLAA and FONSI cannot be supported. (Denise 

Boggs, CC, p.13)

Response: As stated in the final EA (p. 206) and the final BA (pp. 8, 82) the USFWS (Level 1 team) 

determined that the project was “not likely to adversely affect” the NSO or NSO Critical habitat. No take 

occurs under a “may affect, not likely to adversely affect” determination. No nesting/roosting or foraging 

habitat will be removed or downgraded with the proposed treatments, with the exception of 3.4 acres of 

nesting/roosting and 7.5 acres of foraging habitat removed for road and landing construction in the action 

area.

Each road or landing segment of habitat removed would be less than 0.25 acres in any one area in the 

outer 1.3 miles of any affected non-deficit home range. The exception is .1 acres of foraging habitat 

within the core of ACs 1073. The USFWS has considers this amount of habitat loss to be insignificant 

when considered with PDFs. The USFWS considers that effects to spotted owl habitats around activity 

centers will be minimized if there are no treatments or removal in the 70-plus acre nest groves, highquality nest/roost habitat is not proposed for commercial treatment, post-treatment canopy closure will be 

maintained at 60 percent or greater in nesting/roosting habitat and 40 percent or greater in foraging and 

dispersal habitat, no pre-dominant or dominant trees will be removed, and all large logs and snags 20-inch

dbh or greater will be retained (unless they pose a safety hazard). The project may affect but is not likely 

to adversely affect the NSO or Critical habitat.

The NEPA includes a demonstration of compliance during project planning and execution with other 

measures for the protection of environmental values. The Forest Service prepared a biological assessment 

as a part of the environmental analysis process. Informal consultation with the USFWS or National 

Oceanic and Atmospheric Administration Fisheries were initiated early in the project planning stages to 

provide the best opportunity for the formulation of project or program alternatives that would not have an 

adverse effect on listed or proposed species or their habitat (FSM 2671.44). The Forest Service would not 
Appendix B. Response to Comments

Final Environmental Assessment – 385

make a decision until formal consultation is concluded to ensure no irreversible or irretrievable 

commitment of resources occurs to avoid jeopardizing the continued existence of any listed or proposed 

species or adversely modifying its critical habitat (FSM 2671.45c). Any new information and changed 

circumstances that might affect decisions for actions may require the environmental analysis and 

documentation be corrected, supplemented, or revised.

72. Some resource sections of the EA fail to demonstrate consistency with applicable forest plan 

standards, guidelines, and other direction. And one cannot even discern, from maps and discussions 

in the EA which forest plan (Kamath or Six Rivers) applies to a given project area or “treatment” 

unit.(Denise Boggs, CC, p.20)

Response: The proposed land management treatments were designed in alignment with the Klamath and 

Six Rivers national forest’s LRMPs and records of decision (final EA p. 2).

73. “Once again the SRNF describes this project as benefiting northern spotted owl (NSO) habitat and 

the FS states it won’t result in significant impacts. In our opinion these claims are false, as we 

discuss further in these comments. It is disappointing to see the FS rely on debunked science; old 

and outdated information; cherry picking portions of the NSO Revised Recovery Plan (RRP) and 

LSR Assessment that allegedly support the project; etc. CC could easily cherry pick portions of the 

RRP and LSR Assessment that would discourage this project, or major aspects of it. These 

documents must be read in their entirety in order to understand the complexity of the issues. One 

can’t choose a specific sentence and infer it is an accurate representation of the entire document.” 

(Denise Boggs, CC, pp.5-6).

Response: The final BA follows the guidance of the KNF (1994) and SRNF (1995) LRMPs, 2012 

Revised Recovery Plan, LSRA Assessment for the Klamath National Forest (1999), 2012 USFWS NSO 

survey protocol, and the 2012Revised Critical Habitat Rule. These are the guiding documents the forests 

used in consultation with USFWS to determine the effects of our proposed action on the listed northern 

spotted owl. The USFWS considers that effects to spotted owl habitats around activity centers would be 

minimized if there are no treatments or removal in the 70-plus acre nest groves, high-quality nest/roost 

habitat is not proposed for commercial treatment, post-treatment canopy closure would be maintained at 

60 percent or greater in nesting/roosting habitat and 40 percent or greater in foraging and dispersal 

habitat, no pre-dominant or dominant trees would be removed, and all large logs and snags 20-inch dbh or 

greater would be retained (unless they pose a safety hazard). NSO habitat would be maintained within 

commercial and manual treatments proposed. The project may affect but is not likely to adversely affect 

the NSO or Critical habitat (final EA pp. 88-91, 206).

74. The EA indicates 1,233 acres of the project be logged via “mechanical thinning” and other 

prescriptions, expected to yield 6 million board feet of timber. There is an inherent conflict between 

an economically viable commercial timber sale and a project that would improve NSO habitat. Both 

goals can’t be achieved in one project.” (Denise Boggs, CC p. 6)
Appendix B. Response to Comments

386 – Somes Bar Integrated Fire Management Project

Response: The design of the Somes Bar Project is similar to other forest projects (Beaverslide, Little 

Doe Low Gulch Project, Gordon Hill) all of which the USFWS has determined to maintain current habitat 

function, and were “not likely to adversely affect” the NSO or critical habitat. The USFWS defines 

“habitat maintenance” as a reduction in stand density, but the current habitat function would be 

maintained immediately post project with the purpose of improving its quality for the species over time.

The Level 1 team conducted a post-treatment habitat monitoring of the Beaverslide Project, as well as 

the Little Doe Low Gulch Project. The Level 1 team found that all the units exceeded canopy closure 

requirements, and protected pre-dominant trees, snags, and downed logs. The Level 1 team agreed that: 1) 

the prescriptions had been met, 2) that the units are still functional habitat as expected, and 3) the units 

should respond well to the treatments. The Level 1 Team agreed the treatments would have a beneficial 

effect on the future habitat conditions of the area.

75. Please disclose the scientific basis for assuming why the fisher is used as a “surrogate, for which 

the NSO could serve as an indicator regarding varying components of its habitat dynamic.”

(Denise Boggs, CC, p.6)

Response: This is presented from a cultural point-of-view that is based on TEK, and does not require a 

“scientific basis” as outlined in the Somes Bar Project draft and final EA. In 2005, the CEQ accepted 

traditional ecological knowledge (TEK) as an available science. Many intricacies of our natural systems 

have not been studied, particularly the traditional human relationships of the Karuk as an indigenous 

people that lived with fire in this place for millennia. The Karuk Tribe has identified this information as 

being important to include in our consideration of this project as well as in monitoring and adaptation 

activities. Fisher has a larger range that NSO so in that respect, restoring healthy resilient habitat dynamics 

for the fisher may reveal positive correlations with post treatment habitat use by the NSO.

See below except in the full context of surrogate use in relation to the Pacific fisher in lieu of NSO to 

recognize habitat types (final EA pp.38-39).

Northern spotted owl (NSO): This regulated species tends to use old growth forest habitats. 

While the interpretation could be made that the NSO is a messenger of a sick forest habitat 

dynamic, that function is traditionally associated with another species—the Pacific fisher—

which is not only legally regulated, but is a regalia species. In Karuk culture, the Pacific 

fisher represents NSO habitats in the environment. Though owls are known as messengers of 

sickness and death, it is the great horned and screech owls that are told to carry these specific 

messages. These two (2) species are known to have specific names in the Karuk language. 

The NSO is not known to have a specific name, but has been found in practice to be one of 

the first species to decline when the habitat dynamics deteriorate owing to fire exclusion and 

other contemporary management practices.

Pacific fisher: This species, which as a regalia species directly ties to TEK principles, is a 

potential surrogate for NSO using the forest and oak woodlands. The fisher, in fact, covers a 

wider array of habitat dynamics, which in turn is more representative of fire process and 

function. The fisher is not just associated with conifer forests, but also with upland oak 
Appendix B. Response to Comments

Final Environmental Assessment – 387

stands, which are traditionally more open and contain bunch grasses. The fisher plays a very 

central role in ceremony and culture—the Pacific fisher is carried through the Karuk World 

Renewal ceremonies holding the arrows used to pierce the earth and wake up the world.

76. “How is the use of TEK focal species, unprecedented up until now, to be validated with this 

project?” (Denise Boggs, CC, p. 6)

Response: Traditional ecological knowledge (TEK) as an available science does not need to be validated 

to be considered in the NEPA process and this is not the intent. The selection of focal species based on 

TEK is a starting point in taking a closer look at associated species and habitat dynamics. The species 

selected represent the NEPA requirements and treatment design from a cultural perspective in the 

following sense (final EA pp. 38-39):

Pacific fisher represents balance in ecosystem process and function at the landscape scale. 

Particularly those correlating with NSO habitat but also considers large hardwoods in open 

space.

Roosevelt elk represents transition from dense cover to open space, it provides for the 

consideration of large ungulates, and a component of human relationship with fire. Open 

space is lacking in the project area, especially those in relative proximity to dense cover 

preferred when protecting themselves from species like wolves.

Willow represents the human relationship with fire as well as focus on healthy and resilient 

riparian areas. It also brings back a tie to burn timing in relation to respecting nesting birds 

first and foremost.

Pacific giant salamander represents cool clean water and provides for additional 

consideration in regard to avoiding impacts to water.

These species are utilized more in the context of project design consideration. The monitoring 

strategy does not get into specifics as to what the research/monitoring method or protocols are, as much as 

provides for a starting point to plan the project, monitor outcomes, and build a story that ties back to these 

(and associated) species that we can then use to adapt our future activities.

77. “What it the best available science the EA relies upon for using its NSO reproduction analysis 

indicator methodology. For each AC, please disclose the number of acres it would receive of each 

of the various “treatments” both within and outside of core?” (Denise Boggs, CC, pp.6-7)

Response: Reproduction is one of the primary elements of a species existence and effects to 

reproduction can have a significant effect on any population. The amount of suitable habitat within both 

the home range and core has been shown to influence NSO productivity and survivorship (Bart 1995, 

Franklin et al. 2000, Dugger et al. 2005). Based on results of these studies, the USDI Fish and Wildlife 

Service has concluded that significant effects to reproduction are not likely to occur if management 

activities retain a higher proportion (at least half or 250 acres) of the core area’s high quality habitat and 

1,086 acres of suitable habitat in the home range (outside the core) (USDI Fish and Wildlife Service 

2009). Core areas falling below these habitat acre levels may affect the productivity and survival of NSO. 
Appendix B. Response to Comments

388 – Somes Bar Integrated Fire Management Project

Older forest is more likely than other vegetation classes to provide NSO with suitable structures for 

perching and nesting, a stable, moderate microclimate at nest and roost sites, and visual screening from 

both predators and prey.

This analysis will calculate the change in NSO habitat (nesting/roosting, foraging, or dispersal 

habitat) within the core and home range resulting from the action alternative. The changes in NSO habitat 

will be analyzed and compared to the suggested levels of habitat as described by the USFWS (USDI FWS 

2009), published research, and professional judgement. In the final BA, see Appendices D and E for 

treatment within the core and home range of each NSO activity center.

The Critical habitat analysis is a separate analysis and discusses the impacts to each PCE. The results 

are available in the final BA (p. 64).

78. “The EA also doesn’t adequately justify dropping four of the historic ACs in the project area.” 

(Denise Boggs, CC, p.7)

Response: The final EA (p. 180) discusses the rationale for not including these ACs in the analysis. The 

final BA (p. 43) discusses the rationale for not including these ACs in the analysis.

The Level 1 team rationale for dismissing sites from action area (final EA p. 192):

Three (3) of the ACs (4082, 307 and 308) were located west of the Klamath River. During

Level 1 discussion it was determined these NSO sites would have a low likelihood of foraging 

back and forth across the Klamath River corridor and were not included in the analysis.

The fourth AC dropped was 1075. The distance of the AC was 1.27 miles from the Patterson 

Project boundary. The homerange overlap was 1.9 acres.

No proposed treatment would occur within the core (0.5 mile) of these sites (4082, 307, 308, 

and 1075).

79. “The EA indicates only three years of protocol surveys have been undertaken, and even those 

surveys don’t include all the potentially suitable acres because they were concentrated on ACs. Yet in 

other places the EA acknowledges NSO habitat value for places outside the ACs.” (Denise Boggs, 

CC, p. 7)

Response: The project follows the 2012 USFWS NSO survey protocol and all suitable NSO habitat 

within the project area was surveyed including areas without NSO activity centers. If surveys discover 

new ACs or find an AC location has moved, consultation with the USFWS will be reinitiated and the

project will be modified if necessary to maintain a “not likely to adversely affect” determination. NSO 

surveys will continue during the life of the project.

80. “The project states the high quality owl habitat was “dropped from commercial treatment” and the 

habitat in the project is not as preferred by NSO as if that somehow makes it better. The RRP states 

to protect ALL suitable habitat. If the habitat in the project is critical habitat it is suitable enough. 

(Denise Boggs, CC, p. 7)

Response: The 2011 Recovery Plan (RP) does not state that ALL suitable habitat must be protected. 

Rather the RP states the agencies should maintain or restore “older and more structurally complex multi-
Appendix B. Response to Comments

Final Environmental Assessment – 389

layered conifer forests.....while allowing for other threats, such as fire and insects, to be addressed by 

restoration management actions. These high-quality spotted owl habitat stands are characterized as 

having large diameter trees, high amounts of canopy cover, and decadence components such as brokentopped live trees, mistletoe, cavities, large snags, and fallen trees” (Recovery Action 32).

There would be no high quality habitat commercially treated under the Somes Bar Project. Although 

the Recovery Plan does not require all suitable habitat be protected, the Somes Bar Project is designed to 

maintain or improve all suitable habitat conditions within the project area. Please be advised that Critical 

habitat, as defined by the USFWS, does not equate to “suitable” habitat for the NSO. Critical habitat is a 

land designation or a specific area on a map. “Suitable habitat” is what the NSO actually uses. Not all 

areas of Critical habitat are suitable for the NSO. However, the Somes Bar Project was designed to 

maintain or improve all suitable habitat, regardless of land allocation.

The stands selected for treatment minimally met the definition of suitable nesting/roosting/ foraging 

habitat, but had a lower likelihood contributing to survivorship or reproduction. The stands had one or 

more features of suitable habitat, but lacked other important characteristics that reduce their likelihood of 

occupancy or use. For example, a stand may have an average tree size of 21-inch dbh and 60 percent 

canopy cover, but lack large nest trees and multi-layered canopy conditions. The Somes Bar Project was 

designed to maintain current characteristics of nesting/roosting and foraging habitat, but more 

importantly, would create the currently lacking, critically important habitat characteristics for 

nesting/roosting and foraging habitat. It is expected that current habitat function would be maintained in 

all treatment areas immediately post-project (as was seen in the post-treatment review of the Beaverslide 

Project; however, approximately 90 percent of the nesting/roosting/foraging habitat in the action area 

would not have any treatment. Therefore, “adequate alternative habitat” as suggested by Forsman (2011) 

remains available in the action area for owl use. The project would develop functional habitat that is 

currently lacking in the stands.

This project would protect all high-quality habitat, all spotted owl home ranges (not just high priority 

sites, RA 10) and would restore and accelerate important habitat characteristic for the spotted owl (RA 6) 

in young overstocked stands. Such long-term protection of owl habitat is consistent with the 

recommendations in the Recovery Plan.

Landing or road construction would remove <0.25 acres of habitat in any one area. All of the habitat 

removal would occur within the homerange of non-deficit NSO sites (see Appendix D and E of the final 

BA) with the exception of .1 acres of foraging habitat that will be removed within the core of ACs 1073. 

The majority of landings and roads that would be used for this project are existing openings that would 

only need minor expansion and brushing for safe operations. Small, scattered openings across the project 

area can be beneficial in stands lacking structural diversity to “maximize individual tree development, 

encourage some understory vegetation development, and encourage the initiation of structural diversity” 

(Interagency Regional Ecosystem Office memorandum 1996). In addition, the USFWS has considered 

this amount of habitat loss to be insignificant when considered with the PDFs.

USFWS considers that effects to spotted owl habitats around activity centers will be minimized if 

there are no treatments or removal in the 70-plus acre nest groves, no high quality habitat is being 
Appendix B. Response to Comments

390 – Somes Bar Integrated Fire Management Project

commercially treated, post-treatment canopy closure will be maintained at 60 percent or greater in 

nesting/roosting habitats and 40 percent or greater in foraging and dispersal habitats in all treated areas, 

no pre-dominant or dominant trees will be removed, and all large logs and snags 20-inch dbh or greater 

will be retained (unless they pose a safety hazard). The Somes Bar Project is not likely to affect the NSO 

or Critical habitat.

81. The EA downplays habitat removal. Habitat will be removed for landings and temporary roads. 

Given the still declining population of the NSO, that is a significant loss of suitable habitat and

should be considered as such. (CC, p. 7)

Response: Habitat removal was a concern of the Forest. The Level 1 Team reevaluated NSO habitat 

removal for road and landing construction between the draft and final BAs. The habitat numbers would be 

presented in the final EA and the final BA. Landing or road construction would remove <0.25 acres of 

habitat in any one area. All of the habitat removal would occur within the homerange of non-deficit NSO 

sites (see Appendices D and E) of the final BA with the exception of 0.1 acres of foraging habitat that will 

be removed within the core of ACs 1073. The majority of landings and roads that would be used for this 

project are existing openings that would only need minor expansion and brushing for safe operations. 

Small, scattered openings across the project area can be beneficial in stands lacking structural diversity to 

“maximize individual tree development, encourage some understory vegetation development, and 

encourage the initiation of structural diversity” (Interagency REO memorandum 1996). In addition, the 

USFWS has considered this amount of habitat loss to be insignificant when considered with the PDFs.

USFWS considers that effects to spotted owl habitats around activity centers will be minimized if 

there are no treatments or removal in the 70-plus acre nest groves, no high quality habitat is being 

commercially treated, post-treatment canopy closure will be maintained at 60 percent or greater in 

nesting/roosting habitats and 40 percent or greater in foraging and dispersal habitats in all treated areas, 

no pre-dominant or dominant trees will be removed, and all large logs and snags 20-inch dbh or greater 

will be retained (unless they pose a safety hazard). The Somes Bar Project is not likely to affect the NSO 

or Critical habitat.

82. “The project concedes that codominant trees will be removed. These are trees preferred by NSO for 

every life stage. We believe codominant trees should not be logged if the goal is to improve NSO 

habitat. The project should include diameter limits on trees to be cut, not just in the ACs that are 

admitted to be deficient.” (Denise Boggs, CC, p. 7)

Response: The largest, oldest (pre-dominant and dominant) trees in the stands will be maintained.

Primarily suppressed and intermediate trees will be removed, with co-dominant trees only being removed 

under specific conditions (to improve growing conditions for a larger conifer or large diameter 

hardwood). Co-dominant and smaller trees will be harvested with a primary objective of releasing cultural 

trees of interest, reducing stand competition, increasing stand resilience, and reducing fire risk. Suitable 

NSO habitat would be maintained in all nesting/roosting and foraging habitats.
Appendix B. Response to Comments

Final Environmental Assessment – 391

83. “Project design should occur where standards are met and the NSO is provided with the habitat it 

requires. Economics should not drive projects in designated critical habitat. Regardless, the FS is 

required to comply with the forest plans.” (Denise Boggs, CC, p.7)

Response: The final BA follows the guidance of the KNF (1994) and SRNF (1995) LRMPs, 2012 

Revised Recovery Plan, LSRA Assessment for the Klamath National Forest (1999), 2012 USFWS NSO 

survey protocol, and the 2012 Revised Critical Habitat Rule. These are the guiding documents the forests 

used in consultation with USFWS to determine the effects of our proposed action on the listed northern 

spotted owl. The USFWS considers that effects to spotted owl habitats around activity centers will be 

minimized if there are no treatments or removal in the 70-plus acre nest groves, high-quality nest/roost 

habitat is not proposed for commercial treatment, post-treatment canopy closure will be maintained at 60

percent or greater in nesting/roosting habitat and 40 percent or greater in foraging and dispersal habitat, 

no pre-dominant or dominant trees will be removed, and all large logs and snags 20-inch dbh or greater 

will be retained (unless they pose a safety hazard). Northern spotted owl habitat will be maintained within 

commercial and manual treatments proposed. The project may affect but is not likely to adversely affect 

the NSO or Critical habitat. Also see response to comment 74.

84. “Of the non-plantations, only an estimated 61 acres across three focal areas overlap with midmature and older stands.” If this project is intended to be beneficial to owl habitat, then only 

plantations 80 years old and younger should be thinned; not mature and late successional stands. 

The FS should start by dropping these 61 acres. This is a commercial timber sale to benefit 

industry. If implemented, it will harm the NSO and its habitat. Please disclose how much old growth 

is being maintained in the 5th field watershed as required by the NWFP.” (Denise Boggs, CC, p. 7)

Response: The largest, oldest (pre-dominant and dominant) trees in the stands will be maintained. No 

harvesting of old growth would occur in the project area. Primarily suppressed and intermediate trees will 

be removed, with co-dominant trees only being removed under specific conditions (to improve growing 

conditions for a larger conifer or large diameter hardwood). Co-dominant and smaller trees will be 

harvested with a primary objective of releasing cultural trees of interest, reducing stand competition, 

increasing stand resilience, and reducing fire risk Suitable NSO habitat will be maintained in all areas 

(final EA pp.47-48). Response to comment 79 also pertain to this comment.

85. “The SRNF downplays the project area that is in LSR, stating there are only about 63 acres of LSR 

“treatment” in the project, including 11.9 acres of logging. Then why not drop those 63 acres? 

Codominant trees should not be logged in the LSR. What about all of the desired conditions to 

protect LSR habitat; not log any trees over 80 years of age; not to build roads in LSR; to manage 

them for the benefit of late-successional species?” (Denise Boggs, CC, p7)

Response: The Somes Bar Project occurs partially within LSR RC 349 Ten Bear and one 100 acre LSR 

KL0058. Under the 1994 NWFP, S&Gs were developed for silvicultural treatments in LSRs in order to 

maintain or improve habitat conditions for late-successional species. The Klamath National Forest Forestwide Late-successional Reserve Assessment (LSRA; 1999) sets the objective that fuels management 
Appendix B. Response to Comments

392 – Somes Bar Integrated Fire Management Project

treatments effects in LSRs must be neutral and should have a long-term positive effect on late-successional 

habitat. Proposed project treatments should not diminish suitable habitat now or in the future.

Late-successional reserve treatment Table B-4) will include approximately 49 acres specifically in 

LSR Ten Bear RC349 and a 100-acre LSR KL0058. Treatment within Ten Bear LSR 349 includes 14 

acres of manual prescribed fuels (Units 2247 and 2252), and 11.9 acres of mechanical treatment with a 

20-inch-dbh limit (Unit 2249) in the Patterson project area. The Ti Bar project area will have 9.6 acres 

treatment with manual, prescribed burn (Units 2107 and 2108). Treatment in the Donahue project area 

will include 13.5 acres of manual prescribed fuels (Unit 2440) in LSR100-KL0058 (final BA Table 9).

One S&G required that all 20-inch dbh and above trees be maintained within the treated stands unless 

reviewed by the REO. In the July 9, 1999 letter, the REO allows “Individual trees ... exceeding 20-inches 

dbh in any province, shall not be harvested except for the purpose of creating openings, providing other 

habitat structure such as downed logs, elimination of a hazard from a standing danger tree, or cutting 

minimal yarding corridors.” The Somes Bar Project meets LSR objectives for habitat protection and 

restoration, and will not need the exemption. The Somes Bar Project will not cut trees over 20-inch dbh 

and will retain pre-dominant and dominant trees (final EA pp. 177-178).

Table B-4. Units, prescription treatments, and approximate acres of late-successional reserves (LSRs) in the 

Somes Bar Project.

Unit Acres in Unit Rx Fuels Approximate LSR Acres

2440 22.2 Manual, Rx Burn 13.5

2252 25.3 Manual, Rx Burn 12.8

2249 78.4 Mechanical - ground-based / Manual, Rx Burn 11.9

2107 4.8 Manual, Rx Burn 4.8

2108 5.0 Manual, Rx Burn 4.8

2247 14.0 Manual, Rx Burn 1.2

Total acres 49.0

86. The FS cherry picked “active management” from the RRP to “recognize the importance of 

maintaining and restoring habitat for the recovery and long-term survival of the spotted owl.” The 

problem is active management in the Somes Bar project will not “maintain or restore habitat.” In 

fact, it will log trees over 100 years old; remove much basal area in some units; continue logging 

ACs that are already under minimum habitat thresholds; and overall continue to chip away at 

designated critical habitat and LSR at the expense of spotted owls. The EA mentions RA 32 and RA 

10 from the RRP and claims the project will meet them. We don’t agree.” (Denise Boggs, CC, p.8)

Response: Please see responses in the impacts to NSO Habitat, and treatment within LSR above 

concerning habitat maintenance (See response to comments 79 and 83), and minimum standards. The 

Somes Bar Project meets or exceeds the RA10 and RA32 guidance as stated below.

Recovery Action 10:

 Description: “Conserve spotted owl sites and high value spotted owl habitat to provide 

additional demographic support to the spotted owl population.”
Appendix B. Response to Comments

Final Environmental Assessment – 393

 Intent: Intent of this recovery action is to protect, enhance, and develop habitat in the 

quantity and distribution necessary to provide for the long-term recovery of spotted owls.

 Proposed Action: Project design standards will be managed to maintain and improve 

habitat stand conditions inside and outside known NSO home ranges for short and longterm; habitat modification will not preclude NSO use and significant impacts are not 

expected to habitat or individuals. Proposed treatments were designed to minimize effects 

to existing habitat and promote stand development throughout the treatment areas. The 

proposed treatments provide for long-term improvement to the habitat by removing fuels 

and consequently reducing the potential of high severity fire moving across the treatment 

into existing NSO habitat.

Recovery Action 32

 Description: “Federal and non-federal landowners should work with the Service to 

maintain and restore older and more structurally complex multi-layered conifer forests 

...allowing for other threats, such as fire and insects to be addressed by restoration 

management actions.”

 Intent: Maintaining forests with high-quality habitat will provide additional support for 

reducing key threats faced by NSO; protecting these forests should provide NSO highquality refugia habitat from negative competitive interactions with barred owls that are 

likely occurring where the two (2) species’ home ranges overlap.

 Proposed Action: High quality nest/roost spotted owl habitat and known NSO nest groves 

meeting intent of RA 32 have been identified within the project area. Commercial 

treatments will not occur in these stands. Within nest groves proposed treatments include 

less than 4-inch cut, pile and burn along ingress and egress roads and along private property 

boundaries. In high quality nest/roost habitat polygons proposed treatments include less 

than 4-inch cut, pile and burn and/or low intensity underburning. These fuels treatments 

will contribute to the overall prevention of stand replacing fire within areas of high quality 

habitat through the strategic placement of fuel breaks and prescribed fire. Hazard tree 

removal is occurring in all habitat types but is necessary for human health and safety.

Thinning and fuels reduction activities may have a short-term reduction of stand density in suitable 

NSO nesting/roosting habitat; however, the habitat will remain suitable post project implementation. 

Canopy closure will be maintained at greater than 60 percent in nesting/roosting habitat and greater than 

40 percent in foraging and dispersal habitats, no pre-dominant or dominant trees will be removed and 

large snags and downed wood would be maintained to Forest Plan standards. Co-dominant trees will only 

be removed if under specific conditions that will improve growing conditions of an adjacent larger conifer 

or large hardwood. All high-quality nesting/roosting habitat and NSO nest groves consisting of old 

growth late mature forest were excluded from commercial harvest. Selected stands for thinning are 

considered low to moderate quality, with the potential to be improved through treatment. Within the 
Appendix B. Response to Comments

394 – Somes Bar Integrated Fire Management Project

action area (46,243 acres) approximately 15,369 acres is suitable nesting/roosting habitat. The 

nesting/roosting habitat proposed for treatment within the Somes Bar Project is 1,372 acres (9%) of which 

the habitat function will be maintained. Therefore, “adequate alternative habitat” as suggested by 

Forsman (2011) remains available in the action area for owl use.

As stated above, the USFWS considers that effects to spotted owl habitats around activity centers will 

be minimized with the design features above. The project will maintain and restore habitat conditions within 

the project area. The project may affect but is not likely to adversely affect the NSO or Critical habitat.

87. “To meet RA 32 the EA claims no habitat will be removed. That is not true. Habitat will be removed

for landings and temporary roads, and some of these landings will be in Activity Centers. The EA 

attempts to brush this off and fails. Removal is removal. Using an unscientific definition of N/R 

habitat and habitat removal does not meet the intent of RA 32 and this project fails to comply with 

the RRP.” (CC, p.8)

Response: Landing or road construction would remove <0.25 acres of habitat in any one area. All of the 

habitat removal would occur within the homerange of non-deficit NSO sites (see Appendices D and E) of 

the final BA with the exception of 0.1 acres of foraging habitat that will be removed within the core of 

ACs 1073. The majority of landings and roads that would be used for this project are existing openings 

that would only need minor expansion and brushing for safe operations. Small, scattered openings across 

the project area can be beneficial in stands lacking structural diversity to “maximize individual tree 

development, encourage some understory vegetation development, and encourage the initiation of 

structural diversity” (Interagency REO memorandum 1996). In addition, the USFWS has considered this 

amount of habitat loss to be insignificant when considered with the PDFs.

The USFWS considers that effects to spotted owl habitats around activity centers will be minimized if 

there are no treatments or removal in the 70-plus acre nest groves, no high quality habitat is being 

commercially treated, post-treatment canopy closure will be maintained at 60 percent or greater in 

nesting/roosting habitats and 40 percent or greater in foraging and dispersal habitats in all treated areas, 

no pre-dominant or dominant trees will be removed, and all large logs and snags 20” dbh or greater will 

be retained (unless they pose a safety hazard). The Somes Bar Project is not likely to affect the NSO or 

Critical habitat.

88. “RA 10 requires conserving spotted owl sites and high value habitat to provide additional 

demographic support; and to prioritize known historic owl sites for conservation and/or 

maintenance of existing levels of habitat. Neither of these criteria have been met. The EA is silent 

on the LSR’s direction for demographic support; and nowhere else in the document is demographic 

support even mentioned. The Somes Bar project proposes to log N/R/F habitat in ACs that are 

already under minimum habitat thresholds. This is not conserving or maintaining existing levels of 

habitat. It is further reducing habitat in these ACs. RA 10 will not be met in this project.” (CC, p.7)

Response: As stated in the final BA (Table 26 p. 80), within the project area no habitat downgrade or 

removal will occur in any AC within commercial and manual proposed treatment areas. Habitat removal 

would occur within road and landing construction. Landing or road construction would remove <0.25 
Appendix B. Response to Comments

Final Environmental Assessment – 395

acres of habitat in any one area. All of the habitat removal would occur within the homerange of nondeficit NSO sites (see Appendices D and E) of the final BA with the exception of 0.1 acres of foraging 

habitat that will be removed within the core of ACs 1073. The majority of landings and roads that would 

be used for this project are existing openings that would only need minor expansion and brushing for safe 

operations. Small, scattered openings across the project area can be beneficial in stands lacking structural 

diversity to “maximize individual tree development, encourage some understory vegetation development, 

and encourage the initiation of structural diversity” (Interagency REO memorandum 1996). In addition, 

the USFWS has considered this amount of habitat loss to be insignificant when considered with the PDFs.

Because the SRNF strives towards recovery of the spotted owl, all ACs receive the same level of 

protection and are not prioritized with some ACs getting lower levels of protection as allowed by the 

Recovery Plan. This goes beyond the requirement of the RA 10 of the 2011 RP. The project meets the 

objectives of RA 10 and the RRP. Because the Six Rivers strives towards recovery of the spotted owl, all

activity centers (ACs) receive the same level of protection and are not prioritized with some ACs getting 

less protection as allowed by the Recovery Plan. This exceeds the requirement of the RA 10 of the 

Recovery Plan. In addition, the USFWS requires a 70-acre nest grove protection zone. In this project we 

exceeded 70 acres around each of the two (2) known nest groves within the project area (ACs 1250 100 

acres, ACs 53 95 acres), which was incorporated into the project design (see the final BA for the project for 

specific information relating to nest groves). No commercial activities would occur within the nest groves.

USFWS considers that effects to spotted owl habitats around activity centers will be minimized if 

there are no treatments or removal in the 70-plus acre nest groves, no high quality habitat is being 

commercially treated, post-treatment canopy closure will be maintained at 60 percent or greater in 

nesting/roosting habitats and 40 percent or greater in foraging and dispersal habitats in all treated areas, 

no pre-dominant or dominant trees will be removed, and all large logs and snags 20-inch dbh or greater 

will be retained (unless they pose a safety hazard). The Somes Bar Project is not likely to affect the NSO 

or Critical habitat.

This project has protected all high-quality habitat, all spotted owl home ranges (not just high priority 

sites, RA 10) and would restore and accelerate important habitat characteristic for the spotted owl (RA 6) 

in young overstocked stands. Such long-term protection of owl habitat is consistent with the 

recommendations in the Recovery Plan.

89. “The NSO ACs in the project area would likely have a high likelihood of being reproductively 

successful and contain enough suitable habitat to reproduce successfully if occupied.” So the 

quality of habitat is said to be good enough, but this ignores the fact that barred owls compete with 

the NSO in the project area.” (Denise Boggs, CC, p. 12)

Response: The Somes Bar Project area has 10 historic ACs identified within the Action Area. The 

USFWS requires a 70-acre nest grove protection zone. In this project we exceeded 70 acres around each 

of the two (2) known nest groves within the project area (ACs 1250 100 acres, ACs 53 95 acres), which 

was incorporated into the project design (see the final BA for the project for specific information relating 

to nest groves). No treatments would occur within the 100 acres designated for ACs 1250 or the 95 acres 
Appendix B. Response to Comments

396 – Somes Bar Integrated Fire Management Project

designated for ACs 53. No commercial activities would occur in high-quality nesting/roosting habitat 

anywhere in the project area. Commercial and manual treatments in suitable NSO habitat will maintain 

current habitat function. Surveys to the most current, USFWS approved-protocol have been conducted 

throughout the project area. Limited operating periods have been established for all activities within 0.25 

miles of each AC. Updated surveys would be maintained throughout the life of the project or additional 

LOPs would be implemented on activities within 0.25 miles of suitable NSO habitat without up-to-date 

surveys. The project will protect and maintain all NSO ACs (final EA pp. 179-184).

90. “The EA is relying on RA 32 and RA 10 to meet mitigation requirements for barred owls. As we 

discuss, neither of those RAs will be met. The Somes Bar project will not maintain historic ACs. 

Barred owls are already present in the project area and the project provides no meaningful 

mitigation for NSO from this threat, which is a much greater threat than fire.” (Denise Boggs, CC, 

p.12)

Response: The barred owl is addressed in the final BA (pp. 42, 81). As described in responses above, 

both RA 32 and RA10 will be met.

The Somes Bar Project has protected all high-quality habitats (not just old growth), all spotted owl 

territories (not just high priority sites) and would restore, maintain, and accelerate important habitat 

characteristic for the spotted owl. “Maintaining or restoring these forests should allow time to determine 

both the competitive effects of barred owls on spotted owls and the effectiveness of barred owl removal 

measures” (II-67 of the Recovery Plan). Protecting these forests should provide spotted owls high-quality 

refugia habitat from the negative interactions with barred owls that are likely occurring where the two (2) 

species’ home ranges overlap. The Somes Bar Project would not exacerbate competitive interactions 

between the two (2) species. Without the implementing the additional protection measures and recovery 

actions of the Recovery Plan, the barred owl may be successful in out-competing the spotted owl. It is 

imperative to the spotted owl’s recovery to take such actions. The Somes Bar Project is meeting the 

objectives of the Recovery Plan (final EA p. 182).

91. The EA fails to recognize the scientific information that indicates the project would alter habitat 

conditions to favor barred owls even more than management actions already have. The EA states 

that barred owls have been recently found in the project area whereas spotted owls were not 

detected in the most recent (2017) surveys.” (Denise Boggs, CC, p.12)

Response: The barred owl is addressed in the final BA (pp. 42, 81) (final EA pp. 179, 181-183, 189, 

192). There is also some indication that more homogenous landscapes of either young or mature stands 

benefit the expansion of the barred owl with its generalist prey characteristics (Livezey 2007) where as a 

more diverse mosaic (Sakai and Noon 1993, Ward et al. 1998, Carey 1995, and Zabel et al. 1995 and 

Franklin et al. 2000) of habitats benefits the development of rodents such as the dusky-footed woodrat 

and therefore the spotted owl. The Somes Bar Project will protect habitat components critical to NSO 

survival and reproduction (see paragraphs above and below) while encouraging PDFs that would create a 

mosaic of habitats and forest edge within the project areas that stimulates woodrat productivity and would 

increase foraging opportunities for NSO. These edges or transitional habitats appear to be more important 
Appendix B. Response to Comments

Final Environmental Assessment – 397

to foraging NSO when woodrats dominate the diet (Zabel et al. 1995, Ward et al. 1998). Forest edges may 

provide cover to conceal owls from predators while making them inconspicuous to woodrats.

The Somes Bar Project has protected all high-quality habitats (not just old growth), all spotted owl 

territories (not just high priority sites) and would restore, maintain, and accelerate important habitat 

characteristic for the spotted owl. “Maintaining or restoring these forests should allow time to determine 

both the competitive effects of barred owls on spotted owls and the effectiveness of barred owl removal 

measures” (II-67 of the Recovery Plan). Protecting these forests should provide spotted owls high-quality 

refugia habitat from the negative interactions with barred owls that are likely occurring where the two (2) 

species’ home ranges overlap. The Somes Bar Project would not exacerbate competitive interactions 

between the two (2) species. Without the implementing the additional protection measures and recovery 

actions of the Recovery Plan, the barred owl may be successful in out-competing the spotted owl. It is 

imperative to the spotted owl’s recovery to take such actions. The Somes Bar Project is meeting the 

objectives of the Recovery Plan (final EA pp. 179-184).

92. Spotted owls can use different nest sites or are forced out by barred owls to take up some place else. 

Protocol surveys on the Mendocino NF have found new ACs because of this very reason. The SRNF 

has not made an attempt to find NSO outside historic ACs, unless this information is in the BA that 

was withheld from the public. Survey results are important because they affect when LOPs will be 

implemented.” (Denise Boggs, CC, p.12)

Response: The project area is surveyed using the 2012 USFWS NSO survey protocol. All suitable NSO 

habitat within the project area will be surveyed including areas without known NSO activity centers. This 

will continue during the life of the project. If surveys discover new ACs or find an AC location has 

moved, consultation with the USFWS will be reinitiated and the project will be modified if necessary to 

maintain a “not likely to adversely affect” determination (final EA pp. 183, 189) .

93. “The EA states dusky-footed wood rats are the most important prey species of spotted owls, and 

carcasses killed by predators are most often found in old forest. After logging and burning woodrats 

would be scarcer in the project area. When owls leave a secure area to hunt they are exposed to 

avian predators.” (Denise Boggs, CC, p.12).

Response: Northern spotted owl prey is addressed in the final BA (p. 44). The EA does not state that 

“woodrats may be scarce”. Potential effects to prey species are discussed in final BA (pp 44). The 

proposed treatments would promote a mosaic of unburned material on the forest floor, this would promote 

increased vegetative complexity for understory species such as the dusky-footed woodrat (Sakai and 

Noon 1993, Ward et al. 1998, Carey 1995, and Zabel et al. 1995).

All proposed actions within suitable NSO habitat will modify the understory shrubs and some small 

saplings would be killed and some smaller downed logs would be consumed from burning; however, 

current habitat function will be maintained. The results will be a more complex understory and forest 

floor that will benefit key prey species for the spotted owl such as the dusky-footed woodrat.

Prescribed fire prescriptions are designed to prevent severe burn levels and retain large down woody 

material, and snags. In the short term, these small openings may be utilized by the owls for foraging as the 
Appendix B. Response to Comments

398 – Somes Bar Integrated Fire Management Project

prey leave the untreated forested areas adjacent to project units (Sakai and Noon 1993, Carey 1995). In 

contrast to an unplanned wildfire, prescribed burning will be conducted under conditions where the flame 

length and intensity will be low. Dead and down materials are usually large enough in diameter that the 

logs are not burned completely and continue to provide key habitat features such as refugia and escape 

cover. Some of these stands once treated will be immediately improved for foraging by owls. In addition, 

owls are known to forage within areas once the understory vegetation begins to grow again (Sakai and 

Noon 1993, Ward et al. 1998, Carey 1995, Irwin et al. 2007 and Zabel et al. 1995).

94. What is the scientific (research) basis for claiming the design features will “create future woodrat 

habitat?” Has this been demonstrated in field research?” (Denise Boggs, CC, p.12)

Response: Northern spotted owl prey is addressed in the final BA (p. 44). See paragraph above. The 

proposed treatments would promote a mosaic of unburned material on the forest floor, this would promote 

increased vegetative complexity for understory species such as the dusky-footed woodrat (Sakai and 

Noon 1993, Ward et al. 1998, Carey 1995, and Zabel et al. 1995) while maintaining dead and down 

materials which will continue to provide key habitat features such as refugia and escape cover. In 

addition, silvicultural procedures that maintain or enhance woodrat populations adjacent to spotted owl 

habitat may benefit spotted owls (Sakai and Noon 1993, Irwin et al. 2007).

95. “Since the FS relied on minimal FS habitat definitions, the analyses to consider impacts to PCEs is 

flawed.” (Denise Boggs, CC, p.12)

Response: The final BA and the Critical habitat analysis follows the guidance of the KNF (1994) and 

SRNF (1995) LRMPs, 2012 Revised Recovery Plan, LSRA Assessment for the Klamath National Forest 

(1999), 2012 USFWS NSO survey protocol, and the 2012 Revised Critical Habitat Rule. These are the 

guiding documents the Forests used in consultation with USFWS to determine the effects of our proposed 

action on the listed northern spotted owl. USFWS considers that effects to spotted owl habitats around 

activity centers will be minimized if there are no treatments or removal in the 70-plus acre nest groves, 

high-quality nest/roost habitat is not proposed for commercial treatment, post-treatment canopy closure 

will be maintained at 60 percent or greater in nesting/roosting habitat and 40 percent or greater in 

foraging and dispersal habitat, no pre-dominant or dominant trees will be removed, and all large logs and 

snags 20-inchdbh or greater will be retained (unless they pose a safety hazard). NSO habitat will be 

maintained within commercial and manual treatments proposed. The project may affect but is not likely to 

adversely affect the NSO or Critical habitat (final EA p. 202). The Critical habitat analysis documents the 

impacts to PCEs within the Action Area (final BA pp. 64-73).

96. The EA is silent on compliance with NWFP Standards & Guidelines. NWFP NSO direction is barely 

mentioned in the EA. It may be addressed in the BA but that document was not made available to 

the public in violation of NEPA. It would also be helpful for the FS to inform the public on how 

much critical habitat was logged in past projects and also in upcoming projects. This would present 

a more accurate reflection of how critical habitat is functioning on the SRNF.” (Denise Boggs, CC, 

p.12).
Appendix B. Response to Comments

Final Environmental Assessment – 399

Response: The final BA and the Critical habitat analysis follows the guidance of the KNF (1994) and 

SRNF (1995) LRMPs, 2012 Revised Recovery Plan, LSRA Assessment for the Klamath National Forest 

(1999), 2012 USFWS NSO survey protocol, and the 2012 Revised Critical Habitat Rule. These are the 

guiding documents the Forests used in consultation with USFWS to determine the effects of our proposed 

action on the listed northern spotted owl. USFWS considers that effects to spotted owl habitats around 

activity centers will be minimized if there are no treatments or removal in the 70-plus acre nest groves, 

high-quality nest/roost habitat is not proposed for commercial treatment, post-treatment canopy closure 

will be maintained at 60 percent or greater in nesting/roosting habitat and 40 percent or greater in 

foraging and dispersal habitat, no pre-dominant or dominant trees will be removed, and all large logs and 

snags 20-inch dbh or greater will be retained (unless they pose a safety hazard). NSO habitat will be 

maintained within commercial and manual treatments proposed. The project may affect but is not likely to 

adversely affect the NSO or Critical habitat.

As stated above, the design of the Somes Bar Project is similar to the Little Doe/Low Gulch, Gordon 

Hill, Beaverslide, and Kelsey projects, all of which the USFWS has determined to maintain current 

habitat function, and were “not likely to adversely affect” the NSO or NSO Critical habitat. The USFWS 

defines “habitat maintenance” as a reduction in stand density, but the current habitat function would be 

maintained immediately post project with the purpose of improving its quality for the species over time.

No habitat was removed in the previous projects nor will be by the Somes Bar Project except for 

negligible amounts for landing and road construction; therefore, there were no changes to the habitat 

baseline within Critical habitat from any of these projects. The Critical habitat analysis documents the 

impacts to PCEs within the Action Area (final BA pp.64-73).

97. It is important to note here the USFWS has determined minimum habitat thresholds for ACs in 

order for NSO pairs to persist at the site. “Habitat removal or downgrading that reduces habitat 

below this minimum threshold may be considered ‘take’ under the ESA. ...actions that modify 

habitat but maintain functionality without any habitat removal could still have adverse impacts on 

the owl if territory was already below the ‘take’ threshold”. Some ACs are below minimum habitat 

thresholds and therefore “take” has already occurred; and this project will further reduce habitat 

in all ACs. We assume the USFWS is authorizing take in the Some Bar project—it really has no 

other choice. And additional take will not support a MANLAA determination or a FONSI. A review 

of the BA is required to further flesh out this issue, and said BA has been withheld, in violation of 

NEPA.” (Denise Boggs, CC, p.12-13).

Response: The final BA and the Critical habitat analysis follows the guidance of the KNF (1994) and 

SRNF (1995) LRMPs, 2012 Revised Recovery Plan, LSRA Assessment for the Klamath National Forest 

(1999), 2012 USFWS NSO survey protocol, and the 2012 Revised Critical Habitat Rule. These are the 

guiding documents the Forests used in consultation with USFWS to determine the effects of our proposed 

action on the listed northern spotted owl. USFWS considers that effects to spotted owl habitats around 

activity centers will be minimized if there are no treatments or removal in the 70-plus acre nest groves, 

high-quality nest/roost habitat is not proposed for commercial treatment, post-treatment canopy closure 
Appendix B. Response to Comments

400 – Somes Bar Integrated Fire Management Project

will be maintained at 60 percent or greater in nesting/roosting habitat and 40 percent or greater in 

foraging and dispersal habitat, no pre-dominant or dominant trees will be removed, and all large logs and 

snags 20-inch dbh or greater will be retained (unless they pose a safety hazard). NSO habitat will be 

maintained within commercial and manual treatments proposed. See the final BA for project 

determinations and Appendices D and E for each NSO ACs.

As stated in the final EA (p. 202) and the final BA (pp. 8, 82), the USFWS (Level 1 team) determined 

that the project was “not likely to adversely affect” the NSO or NSO Critical habitat. No take occurs 

under a “may affect, not likely to adversely affect” determination. No nesting/roosting or foraging habitat 

will be removed or downgraded with the proposed treatments, with the exception of 3.4 acres of 

nesting/roosting and 7.5 acres of foraging habitat removed for road and landing construction in the Action 

Area. The Action Area is 46,243 acres and 1,372 acres (9%) is proposed for treatment. The treated habitat 

(1,372 acres) will maintain habitat function post-treatment. No suitable habitat will be downgraded or 

removed with proposed treatments. Habitat removal will occur due to road and landing construction and 

this 3.4 acres of habitat removed represents 0.02 percent of the nesting/roosting habitat in the Action

Area. None of this habitat removal will occur in Deficit NSO sites (core or homerange) with the exception 

of 0.1 acres of foraging habitat within the core of ACs 1073. Each road or landing segment of habitat 

removed would be less than 0.25 acres in any one area. The project may affect but is not likely to 

adversely affect the NSO or Critical habitat.

98. Limited Operating Period: The EA states clumsily, “The Proposed Action is consistent with the 

2011 NSO Recovery Plan. Limited operating periods (LOPs) would be imposed to prevent noise 

and smoke disturbance during the peak breeding season.” The EA doesn’t disclose what these LOPs 

would be. And as stated, the determination of LOPs is based on flawed survey data. The LOPs 

should be within 0.5 miles of each AC according to the USFWS, and we believe a Sept. 15th date is 

warranted.” (Denise Boggs, CC, p.13)

Response: We concur with the Conservation Congress; however, LOP dates are presented on pages 88-

89 of the final EA. The first three (3) bullet points under wildlife are below for clarity.

No project activities that modify NSO nesting/roosting and foraging habitat from February 1 

to September 15, unless protocol surveys determine no nesting activity. If surveys result in 

determining no NSO nesting activity, this restricted project operations time period would be

lifted for the year in consultation with the USFWS.

No project activities that result in creating noise above ambient levels within 0.25 miles of 

nesting/roosting and foraging habitat or within known NSO activity center cores from 

February 1 to July 9 on the KNF (Ukonom RD). No project activities that create smoke within 

0.25 miles of nesting/roosting and foraging habitat within known NSO activity centers from 

February 1 to July 31 on the KNF (Ukonom RD). If surveys result in determining no NSO 

nesting activity or non-occupancy, this restricted project operations time period would be lifted 

for the year. This PDF is not intended to be applied to motor-vehicle travel on roadways.
Appendix B. Response to Comments

Final Environmental Assessment – 401

No project activities that result in creating smoke or noise above ambient levels within 0.25 

miles of nesting/roosting and foraging habitat or within known NSO activity center cores from 

February 1 to July 31 on the SRNF (Orleans RD). If surveys result in determining no NSO 

nesting activity or non-occupancy, this restricted project operations time period would be lifted 

for the year. This PDF is not intended to be applied to motor-vehicle travel on roadways.

99. USFWS Consultation: The EA indicates the FS worked with the USFWS on the BA during the 

consultation process. The BA could change after the public comment period ends – and if so that’s a 

NEPA violation. This project is documented in an EA and therefore a FONSI is required. Under the 

USFWS own rules it will have to authorize “take” in this project, and if so, a MANLAA and FONSI 

cannot be supported.” (Denise Boggs, CC, p. 13)

Response: See comment 71 and response.

100. Wildlife analysis concerns: The EA fails to insure that viable populations of Sensitive, survey & 

manage, management indicator, and TEK Focal species are—and would be—maintained under any 

management regime.” (Denise Boggs, CC, p. 13)

Response: The biological evaluation (BE) follows standards established in FSM 2672.42 and complies 

with NFMA, NEPA and LRMPs for the Klamath and Six Rivers national forests. Based on the effects of 

the proposed activities, this analysis determines whether these activities will lead the Forest Service 

Sensitive Species in a trend towards federal listing (FSM 2672.41) (final EA pp. 210-211).

The USDA Pacific Southwest Region sensitive species list (File Code 2670, USDA Forest Service 

Sensitive Species list revised July 3, 2017) were considered for this analysis.

Survey and Manage Species: The Survey and Manage report follows standards established by 

the following document: “Forest Service Correspondence, File Code 1950 - Direction 

Regarding the Survey and Manage Standards and Guidelines - May 13, 2014” provides the

current Forest Service direction for the S & M program. The 2003 Survey Protocol for Survey 

and Manage Terrestrial Mollusk Species from the Northwest Forest Plan (Version 3.0 2003).

Management Indicator Species (MIS): The Management Indicator Species Report follows the 

Direction Regarding Monitoring of MIS Population and Habitat Trends at the Forest Scale. 

Forest scale monitoring requirements for the Klamath National Forest MIS are found in Table 

5-1 of Monitoring Plan by Resource of the Forest Plan. The SRNF follows direction under 

the NFMA, the Forest Service is directed to “provide for diversity of plant and animal 

communities based on the suitability and capability of the specific land area in order to meet 

overall multiple-use objectives” (PL 94-588 §6(g)(3)(B)). The 1982 regulations implementing 

NFMA require that “Fish and wildlife habitat shall be managed to maintain viable 

populations of existing native and desired non-native vertebrate species in the planning area” 

(36 CFR 219.19). Management indicator species is a concept used by the agency to serve as a 

barometer for species viability at the forest level. Population changes of MIS are believed to 

indicate the effects of management activities. The SRNF LRMP uses MIS to assess potential 
Appendix B. Response to Comments

402 – Somes Bar Integrated Fire Management Project

effects of project activities on the various habitats and habitat assemblages with which these 

species are associated. Forty-one (41) fish and wildlife species have been selected as MIS or 

assemblages for a variety of habitats that are potentially affected by resource management 

activities on the forest (LRMP IV-97) (final EA pp. 173, 176, 178, 206-209) .

Traditional Ecological Knowledge (TEK) focal species:

 Northern spotted owl: This ESA regulated species tends to use old-growth forest habitats. 

While the interpretation could be made that the NSO is a messenger of a sick forest 

habitat dynamic, that function is traditionally associated with another species. The NSO 

is not known to have a specific name, but has been found in practice to be one of the first 

species to decline when the habitat dynamics deteriorate owing to fire exclusion and 

other contemporary management practices.

 Pacific fisher – FS sensitive species: This species, which as a regalia species directly tied

to TEK principles. The fisher covers a wider array of habitat dynamics, which in turn is 

more representative of fire process and function. The fisher plays a very central role in 

ceremony and culture.

 Roosevelt elk: This species tends to use open areas, higher elevation grasslands, or 

passageways provided by native serpentine soils, representing a bridge between the 

human-fire relationships (men carry fire in elk horns) and howling dogs (wolf returning to 

adjacent landscapes). In looking to an imminent return of the wolf, elk habitat dynamics 

are critical in protecting their reproductive rights from the wolf, as well as enhancing our 

ability to see things through the eyes of the wolf in teaching the importance of family, 

togetherness, or collaboration. With elk specifically, there is the traditional male 

responsibility of taking care of the animals. In fulfilling this male role in fire management, 

fire is carried in an elk horn. In integrating the habitat needs of large ungulates and other 

species needing more open space, we start to enhance the entire spectrum of habitat needs 

Elk (big game) species. Proposed monitoring research is underway.

 Pacific giant salamander – TEK focal species: Pacific giant salamander is considered to 

be the sacred water purifier. In Karuk culture this species carries its own prayer in regard 

to the respect owed in our actions on the landscape and how that affects the water out to 

the ocean and back to the landscape as rain and subsequently fire via lightning. It helps to 

stress the need to meet the requirements of the aquatic conservation strategy by means of 

not using drip torches to ignite fire in riparian reserves, as well as restoring fire regimes 

and maintaining resiliency in these systems. By using backing fire instead of strip/head 

fire, etc. in these areas. It also helps to support the principles behind selection of willow 

as a focal species (see Cultural Resources section).

 Willow – TEK focal species: Willow is not specific to an individual species of willow, but 

broadly as associated with riparian areas and nesting birds. This as a focal species ties 
Appendix B. Response to Comments

Final Environmental Assessment – 403

back to the story of How Coyote Stole Fire (see Cultural Resources section ), and how we 

as humans need to reemerge as agents of balanced human use and responsibility 

especially in regard to the use of fire. The connections back to the willow are too many to 

bring to the discussion initially, but as a focal species, it helps frame the need for assuring 

not only the maintenance of species viability, but vitality as well. It is through this 

responsibility that we do not use fire in a particular location once the birds come back to 

nest, and we don’t start burning again until after the constellation Pleiades shows itself 

again in the sky in early to mid-June this helps to avoid interrupt the primary 

reproductive cycles in these natural systems.

101. The EA relies upon metrics such as levels of habitat alteration or disturbance, etc. but fails to 

identify any thresholds that management actions might cross which would threaten viability.”

(Denise Boggs, CC, p. 13)

Response: The Biological Evaluation (BE) follows standards established in FSM 2672.42 and complies 

with NFMA, NEPA and LRMPs for the Klamath and Six Rivers national forests. Based on the effects of 

the proposed activities, this analysis determines whether these activities will lead the Forest Service 

Sensitive Species in a trend towards federal listing (FSM 2672.41).

The USDA Pacific Southwest Region sensitive species list (File Code 2670, USDA Forest Service 

Sensitive Species list revised July 3, 2017) were considered for this analysis.

The final BA and the Critical habitat analysis follows the guidance of the KNF (1994) and SRNF 

(1995) LRMPs, 2012 Revised Recovery Plan, LSRA Assessment for the KNF (1999), 2012 USFWS NSO 

survey protocol, and the 2012 Revised Critical Habitat Rule. These are the guiding documents the forests 

used in consultation with USFWS to determine the effects of our proposed action on the listed NSO. The 

USFWS considers that effects to spotted owl habitats around activity centers will be minimized if there are 

no treatments or removal in the 70-plus acre nest groves, high-quality nest/roost habitat is not proposed for 

commercial treatment, post-treatment canopy closure will be maintained at 60 percent or greater in 

nesting/roosting habitat and 40 percent or greater in foraging and dispersal habitat, no pre-dominant or 

dominant trees will be removed, and all large logs and snags 20-inch dbh or greater will be retained (unless 

they pose a safety hazard). NSO habitat will be maintained within commercial and manual treatments 

proposed. The project may affect but is not likely to adversely affect the NSO or Critical habitat.

102. The EA does not provide any scientific basis for stating that species such as the Sensitive great 

gray owl would not be affected by the project.” (Denise Boggs, CC, p. 13)

Response: The project is located outside of the known breeding range for this species (final EA p. 198) .

103. The project would log within riparian reserves, yet the EA doesn’t provide any scientificbasis that 

habitat alterations for riparian dependent species (e.g., willow flycatcher, Southern torrent 

salamander, foothill yellow-legged frog, western pond turtle) wouldn’t be significant. “ (Denise 

Boggs, CC, p. 13)
Appendix B. Response to Comments

404 – Somes Bar Integrated Fire Management Project

Response: The BE documents the rationale and methods for the analysis indicators (BE p. 9) and the 

analysis indicator used for the willow flycatcher (pg. 31), foothill yellow-legged frog (p. 35), southern 

torrent salamander (p. 37), western pond turtle (p. 39). This analysis is in compliance with the paragraph 

below for Forest Sensitive species.

The Biological Evaluation (BE) follows standards established in FSM 2672.42 and complies with 

NFMA, NEPA and LRMPs for the Klamath and Six Rivers national forests. Based on the effects of the 

proposed activities, this analysis determines whether these activities will lead the Forest Service Sensitive 

Species in a trend towards federal listing (FSM 2672.41).

The USDA Pacific Southwest Region sensitive species list (File Code 2670, USDA Forest Service 

Sensitive Species list revised July 3, 2017) were considered for this analysis.

104. Table 3-16 states that “NSO habitat is used as a proxy for suitable fisher, marten, and wolverine 

habitat” but the EA fails to explain how the distinct habitat requirements of the latter three species 

are somehow represented by the NSO proxy. Furthermore, in other places the EA makes seemingly 

contradictory (or at least confusing statements) such as, “The Pacific fisher was identified as a 

potential surrogate, for which the NSO could serve as an indicator regarding varying components 

of its habitat dynamic.” (Denise Boggs, CC, p. 13)

Response: Forest Service Fisher Analysis: Northern spotted owl-modeled habitat depicted with 

EVEG2007 serves as a surrogate for fisher habitat suitability. EVEG 2007 depicts suitable NSO habitat 

and breaks down the vegetation layer into three (3) categories of suitability (nesting/roosting, foraging 

and dispersal). These NSO habitat types fit within the habitat suitability model for the fisher (Refer to 

habitat suitability models below). Please review Klamath National Forest EIS (Appendix I Wildlife 

Habitat Capability Models Table I-5 p. I-9) and Six Rivers National Forest FEIS (Appendix V Habitat 

Capability Models Table B-18 p. B-52).

NSO nesting/roosting habitat greater than 80 percent canopy cover (CC) – High capability 

fisher habitat.

NSO nesting/roosting habitat 61 to 8 percent CC – Moderate capability for fisher habitat.

NSO foraging habitat 40 to 60 percent CC – Low capability for fisher habitat.

Foraging and dispersal habitat 40 percent CC – Movement cover for fisher.

This range of canopy cover will be found in the project area post-treatment and the untreated portion 

of the 10 7th-field watershed analysis area (54,726 acres). This will maintain connectivity to other suitable 

patches of habitat and provide fisher, marten and wolverine the ability to disperse across the project area. 

In addition, pre-dominant and dominant trees will be retained with emphasis placed on retention of 

hardwood species which are used by fisher and marten for denning and resting (See BE for specifics on 

habitat use). For the TEK perspective please see the responses to comments 74 and 75 above.

105. The EA even states that “Fisher as spotted owl surrogate “is one of the “Larger questions that 

are outside the scope of this project.” Then why does the EA bring this up to begin with?” (Denise 

Boggs, CC, p. 14)
Appendix B. Response to Comments

Final Environmental Assessment – 405

Response: Please see responses to numbers 75 and 76 of this document.

106. The EA largely relies upon mitigation devices rather than scientifically sound habitat plans in its 

analyses for sensitive, survey & manage, management indicator, and TEK Focal species. Little or 

no science is apparently being relied upon for these species—how can the FS claim to use best 

available science? For all the concern for Pacific giant salamanders stated in the EA, it fails to cite 

any scientific source for its biology.” (Denise Boggs, CC, p. 14)

Response: As focal species, they are used more as a baseline for TEK based project design leading to 

additional research and monitoring activities. For example, access to an abundance of quality traditional 

food and fiber resources is how humans and animals alike have perpetuated on these landscapes 

historically. Fire drives the functional processes that renews these resources. An emerging scientific study

on huckleberries indicates by having more open canopy (50 to 60%) cover in dense tanoak/fir stands on 

northeast aspect can stimulate higher quality and increase abundance of huckleberry. When one considers 

this from the perspective of elk browsing freshly burned huckleberry, and humans harvesting a portion of 

viable berries, plenty of coppicing occurs which triggers more fruiting response the following year. Food 

security for people may directly correlate to food security for the NSO. Viable huckleberries would 

intuitively produce massive biomass source of seeds upon which rodents could then feed. If the area is 

burned or thinned to provide access for people to harvest, then the NSO would also have access to the 

rodents that would be forced to expose themselves more than they would in a continuous thicket of 

huckleberry bushes. More rodents means more food for owls and fishers. Too many rodents means higher 

potential for disease in humans. Sustainable harvest of huckleberry by humans lies in the balance of these 

functional processes. Although independently brought forward by a doctoral candidate from UC Davis 

through the Karuk-UC Berkeley Collaborative, the Somes Bar Project provides an ideal setting to evaluate 

pre and post prescribed burning (applied via TREK) on TEK plant species such as huckleberry and 

localized influences where chinguapin is present in relationship habitat and uses for the NSO and Pacific 

fisher (pers. comm. Bill Tripp). See comment 100 and response for Forest Service Sensitive, MIS, and 

Survey and Manage species guidance.

107. There is also little in the way of a cumulative effects analysis for these species. “Approximately 

3,079 acres of federal and non-federal timber harvest have occurred in the watersheds since 1966.” 

The FS largely dons blinders as to how this previous management has affected habitats for and 

viability of these species.” (Denise Boggs, CC, p. 14)

Response: The discussion for cumulative effects for these species is found on pages 173-178 and 206-

216 of the final EA.

108. “Trees would increase growth rates, expand crown and root systems, and would generally be 

healthier and more resistant to drought and insect attack with more available water and xylem 

flow.” A woodpecker, which relies upon insects and tree defects would disagree that this is a 

beneficial effect of the project.” (Denise Boggs, CC, p. 14)
Appendix B. Response to Comments

406 – Somes Bar Integrated Fire Management Project

Response: Western pine beetles are already present in the project area, they would continue to attack 

potential host trees, but healthier more vigorous trees have a far better chance of surviving an attack than 

those that are stressed (Fetting et al. 2010, 2007; final EA pp. 99, 167, 171).

109. Pacific Fisher: Fisher are said to be common in the project area, den sites were not located. A 

stated above, the EA relies upon the analysis metric, “levels of habitat alteration” but fails to 

identify any thresholds that management actions might cross which would threaten viability.” 

(Denise Boggs, CC, p. 14)

Response: The BE follows standards established in FSM 2672.42 and complies with NFMA, NEPA, and 

LRMPs for the Klamath and Six Rivers national forests. Based on the effects of the proposed activities, 

this analysis determines whether these activities will lead the Forest Service Sensitive species in a trend 

towards federal listing (FSM 2672.41).

The USDA Pacific Southwest Region sensitive species list (File Code 2670, USDA Forest Service 

Sensitive Species list revised July 3, 2017) were considered for this analysis.

The project, as designed, will protect all pre-dominant and dominant trees, large logs, and large 

diameter snags (20-inch dbh or greater) unless they pose a safety hazard.

Also see PDF (“if a den site is found”) on page 34 of the final BA, and in the final EA (p. 90).

110. The EA states of the action alternative, “In the long-term, late successional habitat would be 

more resistant to large-scale disturbance.” Yet the EA presents no scientifically based metric for 

which this “resistance” could be measured. This is consistent with the EA’s deficient basis in 

science and monitoring.” (Denise Boggs, CC, p. 14)

Response: The use of prescribed “controlled” fire is proposed to meet two (2) objectives: 1) returning 

the ecological role of fire into a landscape historically adapted to this type of disturbance, and 2) spatially 

locating these burn units in areas that will result a landscape that, if and when natural fires occur, would 

be more resilient to the effects of mixed severity fires. Prescribed fire will mimic low-intensity wildfires 

and will decrease surface and ladder fuels. Combined, these efforts would contribute to protecting the 

larger blocks of late-successional habitat and increasing the landscape’s resilience to severe wildfires, and 

return fire to the ecological system.

Another threat to the NSO addressed by the 2011 Recovery Plan is wildfire. The 2011 Recovery Plan

identifies stand-replacing wildfire as one of the three top threats to the recovery of species stating 

“currently the primary source of habitat loss is catastrophic wildfire ....” The 2011 Recovery Plan further 

notes that wildfire size and frequency have been increasing in the western United States and that acres 

burned are expected to continue to increase due to climate changes and past land management practices.

This overall increase in acres burned translates to a corresponding increase in the acres of spotted owl 

habitat lost to fire. While the risk of habitat loss to wildfire varies by location, the 2011 Recovery Plan 

emphasized that the Klamath region is one of the main areas at risk:

“fire-prone provinces (including) California Klamath scored high on threats from 

ongoing habitat loss as a result of wildfire and the effects of fire exclusion on vegetation 

change.”
Appendix B. Response to Comments

Final Environmental Assessment – 407

“In view of the increasing risk posed to northern spotted owl habitat by wildland fire in 

the dry forests of the California Klamath Province, the Recovery Plan calls for 

management actions that result in forests that are more fire resilient and fire-resistant.”

However, the area’s dry, hot summers and extreme departure from its historic fire return interval mean 

that owl habitat within many areas of the Forests is at risk of being lost to, or significantly modified by, 

severe uncharacteristic fire. The 1999 Megram Fire (120,000 acres), 2002 Biscuit Fire (500,000 acres), 

the 2008 Lightning Complex (45,000), 2013 Butler (22,932 acres), 2013 Salmon Complex (15,004 acres), 

2014 Beaver Fire (32,307 acres), 2014 Happy Camp Complex (131,389 acres), 2014 Man Fire (15,645 

acres), 2014 July Complex (3,362 acres), 2014 Little Deer (5,503 acres), 2015 Saddle Fire (1,541 acres), 

2015 Fork Complex (36,562 acres), 2015 Mad River Complex (5,746 acres), 2015 River Complex 

(71,493 acres), 2015 Route Complex (17,095 acres), 2015 South Complex (28,724 acres), 2016 Pony 

Fire, 2016 Gap Fire, 2017 Orleans Complex, and the 2017 Marble Fire (319 acres) and many other fires 

within the range of the species that has removed or downgraded suitable NSO habitat demonstrates that 

fire risk on the Forests and within the range of the species is genuine (Davis et al. 2011, Davis 2015)

(final EA p. 184). Active management to reduce the fire hazard and increase resilience, as well as to 

accelerate the development of higher quality NSO habitat, should contribute to the spotted owl’s 

persistence and recovery. Such long-term protection of owl habitat is consistent with the 

recommendations in Forsman et al. (2011), as well as the 2011 Recovery Plan and 2012 Revised NSO 

Critical Habitat Rule.

Impacts to Pacific Northwest forests from wildfire appear to be increasing along with fire occurrence, 

size, and intensity. Although some researchers disagree on the magnitude of these changes and what to do 

about them (e.g., Hanson et al. 2009, Hanson et al. 2018, Jones et al. 2016, and Rockweit et al. 2017), 

most researchers believe, as does the USFWS (USDI 2012b), that these changes are happening, and that 

active management should be considered (e.g., Hessburg et al. 2007, Healey et al, 2008, Heyerdahl et al. 

2008, Kennedy and Wimberly 2009, Latta et al. 2010, Littell et al. 2009, 2010, Spies et al. 2010, Perry et 

al. 2011, Syphard et al. 2011, Waring et al. 2011, Jenkins et al. 2012, Marlon et al. 2012, Miller et al., 

2009, 2012). Thus, this project takes the active management intervention approach rather than a passive 

approach to restoring NSO habitat. This approach is what was envisioned by the Northwest Forest Plan, 

the 2011 NSO RP, and the 2012 Revised NSO Critical Habitat Rule.

111. And there is no analysis of cumulative effects, in violation of NEPA.” (Denise Boggs, CC, p. 14)

Response: The cumulative effects section in the final EA (pp. 211-216) was updated to incorporate 

information from the Biological Evaluation (pp. 59-82) and completed Level 1 consultation and 

Biological Assessment (pp. 81 and 82).

112. Northern Goshawk: The EA states, “One goshawk nest was detected near the Rogers focal area 

and the site produced offspring in 2015.” The EA does not state how intensive or frequently the 

surveys for goshawks have been conducted. Single year surveys are not adequate for locating 

goshawk territories.” (Denise Boggs, CC, p. 14)
Appendix B. Response to Comments

408 – Somes Bar Integrated Fire Management Project

Response: Northern goshawk surveys were conducted for two (2) years and will continue prior to 

implementation of the project (final EA p. 90).

113. What is the best available science the forest plan relies upon for recommending “that 

management in the goshawk primary nest zone (0.5 mile radius around nest site) maintain at least 

60 percent canopy cover over 300 acres (primary nest zone equals 504 acres; KNF LRMP p. 4-

29).” (Denise Boggs, CC, p. 14)

Response: The forest would follow guidance found in the KNF LRMP (p. 4-38 wildlife 8-20 for goshawk).

114. What is the empirical basis for believing the “PDF ...to avoid disturbance of this nest location 

during the sensitive part of nesting” would be effective?” (Denise Boggs, CC, p. 14)

Response: See Goshawk LOP in the SRNF LRMP (p. IV-98 Table IV-11) and the KNF LRMP p. 4-38 

8-20 III Disturbance).

115. Marten: The EA states that during fisher survey efforts a marten was detected in 2016 and no den 

sites have been found. What is the basis for the EA’s conclusion that the marten detected “was most 

likely a dispersing individual”? What does this mean—that it doesn’t belong in the project area?” 

(Denise Boggs, CC, p. 14)

Response: Marten population viability is related to the amount and quality of habitat. Like fisher, marten

are also associated with late-successional conifer forests characterized by an abundance of large dead and 

downed wood and large, decadent live and dead trees (Powell et al. 2003, Buskirk and Ruggiero 1994). In 

general, marten elevation range overlaps the fisher slightly, but marten occupy higher elevations, typically 

in true fir and lodgepole forests. Marten appear to select particular physical structure in the forest over the 

tree species composition. Foraging sites are commonly associated with riparian areas near latesuccessional habitat (Zielinski 1983). Resting sites are common in large trees and snags and possibly logs 

and stumps that create an opening near the ground (Spencer 1987). Denning sites are typically cavities in 

large diameter trees or snags. Marten may inhabit younger forests as long as the area contains important 

habitat components for resting and denning (e.g., large trees and snags) (Thompson et al. 2011).

Martens typically avoid areas lacking sufficient overhead cover (Slauson et al. 2007) and are sensitive 

to forest fragmentation (Chapin et al. 1998). Distribution of mature forest on the landscape scale may be 

the primary determinant of marten distribution and subsequently affect habitat selection at finer scales 

(e.g., home range) (Kirk and Zielinski 2009). Marten were found to select areas with more habitat, larger 

patch sizes, and larger areas of interior forest (Hargis et al. 1999, Kirk and Zielinski 2009). Habitat 

characteristics usually include high (greater than 40 percent) canopy cover (Hargis et al. 1999).

Areas without overhead cover may inhibit marten movements. In the Rocky Mountains, marten were 

found to cross clearcuts (no standing trees) about 460ft in width (Heinemeyer 2002) while a different 

study found a similar relationship from a habitat modeling approach (Hargis et al. 1999). In other forest 

treatment areas that contain some structure (isolated trees, snags, and logs) in the unit, marten crossed 

areas up to 600ft in width (Heinemeyer 2002).
Appendix B. Response to Comments

Final Environmental Assessment – 409

Marten dispersal is not well known or documented (Broquet et al. 2006). In Ontario, Canada, marten 

were found to disperse about 4 miles (maximum 112 miles) on average for females and about 11 miles 

(maximum 150 miles) for males (Johnson et al. 2009). Genetic testing has shown evidence of marten 

disperse over long distances (greater than 150 miles) (Kyle and Strobeck 2003). The variation in the 

distances for marten dispersal may be in response to changes in landscape pattern and habitat loss (Hargis 

et al. 1999). Martens are sensitive to increasing size of open areas and decreasing distance between 

openings (Hargis et al. 1999). However, marten survival decreases as the distance of dispersal increases 

(Johnson et al. 2009). Therefore, marten that travel long distances have a much higher likelihood of dying 

compared to marten that disperse a short distance.

The project area is located in habitat between the Klamath River corridor and 2900’ in elevation. In 

general, marten elevation range overlaps the fisher slightly, but marten occupy higher elevations, typically 

in true fir and lodgepole forests. If found in the project area marten would most likely be dispersing 

animals (personal communication Slauson 2018) and the project area post-treatment would allow 

movement between suitable patches of habitat.

Surveys were conducted in the SBIFMP project area in 2016 and 2017 using camera stations. A 

marten was detected on one occasion in 2016. This detection occurred on March 4, 2016 at T4 station 

within the Donahue project area. No incidental have been recorded and no den sites have been found.

Also see the PDF (“if a den site is found”) on page 34 of the final BA and in the final EA on page 90.

116. Wolverine: What is the scientific basis for the EA’s stating that the wolverine “would use the same 

basic habitat as the fisher?” (Denise Boggs, CC, p. 15)

Response: See the BE for detailed account of habitat use (final BE pp. 22-23).

Wolverine population viability is related to the amount and quality of habitat. Wolverines are typically 

associated with high elevation (greater than 7,200 feet) montane conifer forest consisting of Douglas fir in 

lower elevation to true fir and lodgepole pine at higher elevation (Copeland et al. 2007). In California, 

wolverines have been documented at much lower elevations (1,600feet) than recorded for most of the 

species range. Studies in Montana, Yukon, and Alaska reported wolverines having a strong association to 

mid- to late-successional conifer forest habitat possibly indicating conifer forests as the preferred habitat 

type (Hornocker and Hash 1981, Banci and Harestad 1990), but wolverines have been found in a variety 

of high elevation habitat types (Copeland et al. 2006).

Young females typically establish residency next to or within the natal home range (Magoun 1985). 

Natal dens are difficult to find, but the small number of dens located were found in a variety of conditions 

from snow created caves, under tree stump or boulders or within dense conifer forest (Hash 1987). Males 

typically disperse possibly traveling great distances (e.g., 230 miles) and through varying habitat types 

(Magoun 1985). Wolverines are known to use rivers and streams as travel routes possibly because the 

riparian area provides water and food resources (Magoun 1985). Wolverines typically avoid humans and 

human related infrastructure, but a few exceptions have been recorded (Copeland et al. 2006). Deep, 

persistent, and reliable spring snow cover (April 15 to May 14) is the best overall predictor of wolverine 

occurrence in the contiguous United States (USFWS 2011).
Appendix B. Response to Comments

410 – Somes Bar Integrated Fire Management Project

“The dispersal and travel corridors that connect refugia, at least for males, likely need not have the 

habitat attributes necessary to support self-sustaining populations. Atypical or low quality habitats may be 

important to wolverines if they connect otherwise isolated populations and allow for genetic exchange or 

colonization.” (Ruggiero et al. 1994).

There are no verified records of wolverine on the SRNF: however, incidental sightings of wolverines 

have been reported on the northern part of the Forest. Most of the sightings occurred in the 1970s and 

1980s. Considering their need for persistent spring snow cover, preference for subalpine and alpine 

habitats or climatic conditions and their aversion to human disturbance, wolverines would most likely 

occur on the Forest within higher elevation areas such as the Forest Wilderness habitats.

The project area is located in habitat between the Klamath River corridor and 2,900 feet in elevation. 

Wolverine are typically associated with habitats greater than 7,200 feet in high elevation montane conifer 

forest consisting of Douglas fir in lower elevation to true fir and lodgepole pine at higher elevation 

(Copeland et al. 2007). If found in the project area wolverine would most likely be dispersing animals and 

the project post-treatment would allow movement between suitable patches of habitat.

Surveys were conducted in the SBIFMP project area in 2016 and 2017 using baited camera stations. 

No wolverine were detected.

117. Roosevelt elk: The EA claims the “treatments” would benefit elk, but it doesn’t provide any 

quantitative analysis of risk, security, or cover. The EA doesn’t disclose forest plan direction for elk, 

nor demonstrate project consistency?” (Denise Boggs, CC, p. 15)

Response: There are two (2) main points:

During project design, the team identified areas for calving, enhancing forage, and enhancing 

wintering habitats. Components of these habitat dynamics were built into the selection 

process for identifying opening and retention areas during treatment layout (final EA p. 206).

A grant with California Department of Fish and Wildlife titled “Marble Mountain Elk 

Ecology and Management Collaborative Research Institute” has been awarded to the Karuk 

Tribe. The Karuk Department of Natural Resources (KDNR) in partnership with California 

Department of Fish and Wildlife and academic researchers are developing strategies to 

restore elk habitat in Karuk Aboriginal Territory through prescribed fire and fuels treatments 

in coordination with the WKRP. The goals of this research project are to provide a better 

understanding of elk population dynamics, migrations, and habitat utilization. Data collection 

will help determine population dynamics, movement, and habitat use of elk utilizing the study 

area in the Marble Mountain portion of Siskiyou County.

118. What is the basis (scientific and survey data) for the EA statement, “suitable large tree roost sites 

are fairly common?” (Denise Boggs, CC, p. 15)

Response: From the Forest-wide Reference Document, Klamath Province, the SRNF is where the 

primary literature review for species occurs. This document is available upon request. Pallid bats are 

largely an arid-lands species but does occur in forested landscapes. They are primarily associated with 
Appendix B. Response to Comments

Final Environmental Assessment – 411

caves and rock crevices for roost sites. In the Somes Bar Project area, these habitats are not as abundant 

as the potential use of large trees that can be also utilized by the species (final EA pp. 201-202). The 

suitable habitat description from the Forest-wide Reference Document follows:

Pallid bats are common to the arid deserts and grasslands of the southwestern US. The range extends 

north through California, Oregon, Washington, and into southern British Columbia (Hermanson and 

O’Shea 1983). In California, the pallid bat is usually found in low to middle elevation habitats below 

6000 ft. (Philpott 1997). It is most common in arid Sonoran life zones and occurs throughout California 

except in the high Sierra Nevada and the far northwest corner of the state in Del Norte and western 

Siskiyou County (CDFG 2002). However, Sherwin (1998) has documented this species up to 10,000 ft. in 

the Sierra Nevada. A variety of habitats are used, including grasslands, shrublands, woodlands, and 

coniferous forests (Philpott 1997). Pallid bats are most common in open, dry habitats near water that 

contain rocky areas for roosting. Occasional forays may be made in winter for food and water (Philpott 

1997). Pallid bats are unusual in that most of their food consists of large insects captured on the ground 

(Verts and Carraway 1998). Open areas such as forest roads and canyon mouths are used for foraging.

Day and night roosts include crevices in rocky outcrops and cliffs, caves, mines, trees (e.g., basal 

hollows of coast redwoods and giant sequoias, bole cavities of oaks, exfoliating Ponderosa pine and valley 

oak bark, deciduous trees in riparian areas, and fruit trees in orchards), and various human structures such 

as bridges (especially wooden and concrete girder designs), barns, porches, bat boxes, and human-occupied

as well as vacant buildings (Sherwin and Rambaldini 2005). Cavities in broken branches of black oak are 

very important and there is a strong association with black oak for roosting (USDA Klamath National 

Forest 2002). Roosting sites are usually selected near the entrance to the roost in twilight rather than total 

darkness. The site must protect bats from high temperatures, as this species is intolerant of roosts in excess 

of 104°F. Pallid bats are also very sensitive to roost site disturbance (Zeiner et al. 1990; Philpott 1997). 

Night roosts are usually more open sites and may include trees or snags, open buildings, porches, mines, 

caves, and under bridges (Philpott 1997; USDA Klamath National Forest 2002; Pierson 1996).

119. The EA states, “suitable roost sites for Townsend’s big-eared bats in the form of large diameter 

trees are scattered throughout the project area.” With a key habitat component being “scattered 

throughout”, how does this translate to demonstrating sufficient habitat for viability or a 

cumulative effects analysis?” (Denise Boggs, CC, p. 15)

Response: From the Forest-wide Reference Document, Klamath Province, the SRNF is where the 

primary literature review for species occurs. This document is available upon request. Townsend’s bigeared bats does occur in forested landscapes. They are primarily associated with caves and rock crevices 

for roost sites. In the Somes Bar Project area, these habitats are not as abundant as the potential use of 

large trees that can be also utilized by the species (final EAp. 201). The suitable habitat description from 

the Forest-wide Reference Document follows:

Townsend’s big-eared bat occurs in a variety of habitats, and is strongly correlated with the 

availability of caves or cave-like roosting habitat. It has been found from sea level to 8d700 feet in

elevation (Humphrey and Kunz 1976, Kunz and Martin 1982, Pierson and Rainey 1994) and occurs in 
Appendix B. Response to Comments

412 – Somes Bar Integrated Fire Management Project

xeric to mesic habitats; although throughout much of its range it occurs in mesic habitats characterized by 

deciduous and coniferous forests (Kunz and Martin 1982). The species tends to avoid open grassland 

when foraging and flying to and from roost sites. In coastal California, they prefer riparian habitats near 

streams and small tributaries, foraging along the edge of the forest (Fellers and Pierson 2002). They have 

been observed at day roosts in cavities, created by decay or fire, of California bay (Umbellularia 

californica) and redwood. Because of this, it is difficult to define measurable habitat variables. The most 

limiting factor appears to be availability of suitable roost sites. They will use cave, mines and abandon 

buildings for maternity roosts and hibernacula, and have been known to use abandon bridges and large 

tree cavities for day and night roosts (Idaho State Conservation Effort 1995). They do not roost in 

crevices but rather on exposed surfaces, often close to the entrance of the cave making them extremely 

vulnerable to disturbance and may abandon a site with one human entry (Pierson et al. 1991). Factors in 

the decline of the species are disturbance, pesticide use, habitat loss, and roost destruction (Idaho State 

Conservation Effort 1995).

120. Western Bumblebee: What does the Western Bumblebee eat, and where do they nest? How are 

these habitat components affected by proposed and cumulative habitat alterations?” (Denise 

Boggs, CC, p. 15)

Response: According to Hatfield et al. 2012, high floral diversity are required for feeding and nesting of 

the genera of Bombus are ground nesters, but utilize human-made structures as well.

The EA states that bumblebees utilize open meadow habitats and that this project does not impact 

meadow habitats within the four (4) project areas (final EA p. 203).

.
Appendix C. Somes Bar Integrated Fire Management Project Prescriptions

Final Environmental Assessment – 413

Appendix C. Somes Bar Integrated Fire Management 

Project Prescriptions

Mechanical Thinning

Prescription #1a

Douglas-fir Plantations: Target residual canopy cover (CC) of 50% (prior to burning).

1. Choose retention patches – minimum of 5 to 10 percent of unit in 0.25- to 1.0-acre sections.

• Number of patches determined by the size of the unit and size of retention patches chosen.

• Inner riparian reserves and other areas where work is restricted can count as retention patches.

• Preferably choose areas where there is evidence of woodrat nests

 If woodrat nests are found, also choose a 0.25-acre area adjacent to this area in 

which to cut some tanoak sprouts (to encourage resprouting/create future woodrat 

habitat).

• Preferably, choose areas where there is evidence of tanoak mushrooms and/or lessencroached mature tanoak.

• Preferably, choose patches of taller trees with closed canopy (use height as reference to find 

these patches) and/or uneven complex structure, including understory cover.

• Lastly, choose relatively cool sites compared to rest of stand.

2. Choose location of openings—no less than 10 percent, up to 20 percent of the unit, not adjacent to 

system roads. For road or cable-based harvest systems, due to operational limitations, no openings 

will be identified. It is expected that cable corridors would function as openings.

• Size:

 Elk habitat and warmer sites – 0.5- to 1-acre openings

 Non-elk habitat and cooler sites – 0.25- to 0.5-acre openings

• First calculate how many openings need to be identified:

 Acres of landings + (# of openings x size) = 10 to 20 percent of unit acres

 Inventory landings – count interior landings towards opening target

• Prioritize openings in areas infected with black stain root disease. Create an opening of at 

least 35 feet radius away from infected trees. This is equivalent to a minimum opening size of 

0.1 acres around each black stain infection – increase this distance to meet minimum opening 

size of at least 0.25 acres.
Appendix C. Somes Bar Integrated Fire Management Project Prescriptions

414 – Somes Bar Integrated Fire Management Project

• Use Canopy Height Model to identify existing openings that may be enhanced

• Use traditional ecological knowledge (TEK) data and on-site observation to choose areas 

with TEK species that benefit from increased light. For example, beargrass, iris, adjacent 

to/south of manzanita, adjacent to/south of oaks.

• Avoid areas where large trees exist, rather choose areas with low site quality or where less 

desirable tree species are concentrated.

• Preferably, choose areas with moderate-high insolation.

• May ‘feather’ south edge of openings to allow more light into openings.

3. Mark remaining stand using variable density retention methods.

• Calculate max canopy reduction of the area to be treated, based on size of selected retention 

patches, openings and target canopy cover retention.

• Calculate maximum Canopy Cover (CC) reduction in thinning area:

 (retention patch acres × existing CC of retention areas) + (openings acres ×

0% CC) + [thinning area acres × (existing thinning area CC −

maximum CC redution in thinning area)] = unit size in acres ×

target retention CC).

 Example: A 20-acre unit with target CC retention of 45 percent (prior to burning), 

2 acres retention with 90 percent CC, 3 acres in openings, and current thinning 

area CC of 90 percent:

• (2 × 0.9) + (3 × 0) + [15 × (0.9 −

maximum CC redution in thinning area)] = (20 × 0.45)

• Maximum CC redution in thinning area = 0.42

• Therefore, CC in the thinning area can be reduced by an average of 

42 percent.

• Retain all pre-dominant and dominant trees in the treatment area.

• First, use lightest (most canopy retention) prescription to mark trees along roadways and 

around weeds (see botany PDFs) ~quantify canopy cover or basal area (BA).

• Second, use heaviest (most open) prescription along ridges and adjacent to retention patches.

• Third, mark the remaining stand.

 Preferentially retain individuals with heterogeneity in species and structural 

complexity (large trees, vigorous lateral growth, defects).

 Preferentially retain largest trees on the unit.
Appendix C. Somes Bar Integrated Fire Management Project Prescriptions

Final Environmental Assessment – 415

 Remove all Douglas-fir trees within 20 feet of trees of shade-intolerant species 

which have achieved a somewhat fire-resistant diameter at breast height (dbh) 

size (approximately greater than 8-inch dbh) of the following species:

• Black oak, white oak, sugar pine, ponderosa pine, dogwood, Pacific 

yew, madrone (greater than 12 inches).

 Thin re-sprouting tan oak clumps when stem dbh is greater than 4 inches, leaving 

the largest 25 to 50 percent of stems.

4. General guidelines/restrictions:

• In suitable habitat where nesting, roosting or foraging habitat is in deficit, limit harvesting of 

trees to less than 18-inch dbh.

Prescription #1b

Pine Plantations: Target residual canopy cover (CC) of 55% (prior to burning).

1. Follow steps 1 through 4 as described above in 1a.

2. Treatments in plantations with a substantial pine tree component would be thinned to 80 to 100 

residual BA per acre dependent on the size and age of the stand to minimize the potential for 

increasing unwanted bark beetle populations.

Prescription #2

Mechanical prescription for areas with no history of regeneration harvest (may have 

been previously thinned). Minimum residual canopy cover of 40 to 60 percent.

1. Release of Trees of Interest

• Selection of Trees of Interest:

 Release mature trees (approximately greater than 18-inch diameter – may choose 

smaller individuals of true oaks) of the following species, provided here in 

general priority order:

• Black oak, white oak, sugar pine, madrone (especially large 

individuals), ponderosa pine, chinquapin, tanoak (especially large 

individuals).

 Retain all pre-dominant and dominant trees on the unit.

 Mark all Douglas-fir within the drip line of the Trees of Interest for removal. 

Consider girdling instead of removal where damage to residual trees is excessive 

and unavoidable.
Appendix C. Somes Bar Integrated Fire Management Project Prescriptions

416 – Somes Bar Integrated Fire Management Project

 Continue to mark additional Douglas-fir for removal around the Tree of Interest, 

starting with the most marginal/least dominant and suppressed individuals, until 

shade on the crown area of the Tree of Interest has been reduced by 50 percent 

relative to the current level of crown area shading from surrounding trees.

• This is not anticipated to be an issue, but if a large number of Trees of Interest are present in 

the unit, ensure that the release of Trees of Interest does not result in over-reduction of canopy 

cover compared with the target CC.

2. Choose retention patches – minimum of 5 to 10 percent of unit in 0.25- to 1.0-acre sections.

• Number of patches determined by the size of the unit and size of retention patches chosen.

• Inner riparian reserves, unstable areas, high quality northern spotted owl (NSO) nesting/ 

roosting habitat, and other areas where work is restricted can count as retention patches.

• Preferably, choose areas where there is evidence of woodrat nests.

• Preferably, choose areas where there is evidence of tanoak mushrooms and/or open grown 

mature tanoak.

• Preferably, choose patches of tallest trees with closed canopy (use to 10 percent TAO by 

height as reference to find these patches).

• Lastly, choose relatively cool sites compared to rest of stand

3. Choose location of openings – no less than 10 percent, up to 20 percent of the unit.

• For road or cable-based harvest systems, due to operational limitations, no openings will be 

identified and marked in road-based or cable system units. It is expected that cable corridors 

could function as openings.

• Retain all pre-dominant and dominant trees.

• After completing items 1-3, considering further thinning of Douglas-fir if CC targets can 

accommodate additional thinning, or if thinning can be done to suppressed trees only such 

that it does not further reduce residual overstory CC.

• Size:

 Elk habitat and warmer sites – 0.5- to 1-acre openings.

 NSO foraging and/or nesting/roosting habitat – 0.25- to 0.5-acre openings.

• First, calculate how many openings need to be identified.

 Acres of landings + (# of openings x size) = 10 to 20 percent of unit acres.

 Inventory landings – count interior landings towards opening target.

• Use Canopy Height Model (CHM) to identify existing openings that may be enhanced.

• Use TEK data and on-site observation to choose areas with TEK species that benefit from 

increased light.
Appendix C. Somes Bar Integrated Fire Management Project Prescriptions

Final Environmental Assessment – 417

 Beargrass, iris, adjacent to/south of manzanita, adjacent to/south of oaks.

• Avoid areas where large trees exist – preferentially choose areas with low site quality and/or 

undesirable trees.

• Preferably, choose areas with moderate-high insolation.

• May ‘feather’ south edge of openings to allow more light into openings.

4. Thin approximately 50 percent of suppressed and intermediate Douglas-fir ladder fuel trees across 

the unit. Intermediate and suppressed trees are best characterized as smaller diameter trees greater 

than 10-inch dbh that do not contribute to the overstory canopy cover (while maintaining some 

structural diversity).

• Focus thinning on areas that can benefit most from low thin to reduce the likelihood of 

passive crown fire.

• Thin re-sprouting tan oak clumps when stem dbh is greater than 4 inches, leaving the largest 

25 to 50 percent of stems.

• Calculate possible further reduction of CC:

 (retention patch acres × existing CC of retention areas) + (opening acres ×

0% CC) + [thinning area acres ×

(estimated residual CC after release of Trees of Interest −

possible further reduction of CC)] = (unit size acres × target retention CC)

 Example: A 20-acre unit with target CC retention of 65 percent (prior to burning), 

4 acres of retention patches with 90 percent CC, and 2 acres in openings. 

Residual CC in thin area after release of Trees of Interest is 75 percent:

• (4 × 0.9) + (2 × 0) + [14 × (0.75 −

possible further reduction of CC)] = (20 × 0.65)

• possible further reduction of CC = 0.08

• Therefore, some additional low thinning can be done of intermediate 

and suppressed Douglas-fir, as long as it does not further reduce the 

residual canopy cover by 8 percent on average throughout the unit.

5. General guidelines/restrictions:

• In suitable habitat where foraging habitat is in deficit, limit harvesting of trees to less than 18-

inch dbh.
Appendix C. Somes Bar Integrated Fire Management Project Prescriptions

418 – Somes Bar Integrated Fire Management Project

Mastication

Prescription #3

Mastication in plantations in preparation for burning.

1. Overall objectives are to:

• Break up vertical and horizontal continuity of fuels, while retaining “more desirable” species.

• Improve access for collection of forest materials (such as nuts or berries) and create travel 

corridors for wildlife species.

• Improve access and safety for hand crews and other personnel implementing manual fuels 

reduction and prescribed burning.

2. Masticate the access road(s) first.

• Access treatment unit by identified existing temporary or system road. Using the width of the 

access road as a measurement, masticate small diameter trees and shrubs (generally under 4-

inch dbh) within and along the previously disturbed area to an average width of 20 feet 

(generally between 15 and 30 feet) to a depth no greater than 18 inches.

• On a 15-foot-wide masticated road, approximately 1,740 feet equals 1 acre of treatment; 30-

foot-wide masticated road, approximately 871 feet equals 1 acre of treatment. So on an 

average width of 20 feet for a treatment path, approximately 1,300 feet may be masticated per 

1 acre. (Note: this assumes masticating 60 percent of the unit).

• Where feasible, avoid damaging and/or masticating larger trees whenever possible.

3. Choose retention patches – minimum of 5 to 10 percent of unit in 0.25- to 1.0-acre sections.

• Number of patches determined by the size of the unit and size of retention patches chosen.

• Inner riparian reserves and other areas where work is restricted can count as retention patches.

• Preferably, choose areas where there is evidence of woodrat nests.

 If woodrat nests are found, also choose a 0.25-acre area adjacent to this area in 

which to cut some tanoak sprouts (to encourage resprouting/create future woodrat 

habitat)

• Preferably, choose areas with desirable species, such as sugar pine, ponderosa and Jeffrey

pine, Pacific yew, and true oaks.

• Preferably, choose areas where there is evidence of tanoak mushrooms and/or lessencroached mature tanoak.

• Lastly, choose relatively cool sites compared to rest of stand.
Appendix C. Somes Bar Integrated Fire Management Project Prescriptions

Final Environmental Assessment – 419

4. If treatment unit borders private property, identify property boundary markers and restrict 

mastication activities near property boundaries.

5. Treatment within units should be limited to approximately 30 to 40 percent of total unit size in 

order to safely conduct follow-up burning and not increase fuels to a potentially unacceptable level.

For example, in a 3-acre unit, about 1 acre should be masticated to help facilitate burning 

operations (this equates to between 1,960 to 2,615 feet in length of 20-foot-wide masticated paths in 

the unit).

• Once inside the treatment unit, identify opportunities to create unevenly spaced rows 

depending on terrain and size/species of material to masticate. If unit allows for connection of 

mastication access roads, then connect access points when feasible.

6. Manual actions (cutting, hand piling and hand pile burning) should be considered following 

mastication in order to address fuels concerns prior to understory burning (see Prescription 4c).

7. Follow up prescribed burning would be delayed for approximately 2 to 5 years to allow for 

decomposition of masticated material. Hand piles of material may be created in some masticated 

areas prior to broadcast burning where fuel loading is noticeably higher than acceptable levels 

(these areas will be site specific based on nearby strategic control features).

Manual Prescriptions – Burning Preparation

Prescription #4a

Manual Treatment in Plantations (minimum residual canopy cover of 40 to 60 percent 

prior to burning).

1. The goal of treatment is to reduce ladder fuels by breaking up fuel continuity (both horizontal and 

vertical) of high concentrations. High priority treatment areas are those associated with strategic 

control features (private property, roads and ridges) and in areas identified as having unacceptably 

high fuel loading which would lead to negative prescribed fire effects.

2. Thin small diameter trees and shrubs (up to 6-inch dbh) and reduce ladder fuels.

• Maximum residual spacing of trees should be roughly 16 to 25 feet.

• Enhance diversity of species by thinning around true oaks, incense cedar, madrone, pacific 

yew, sugar pine and ponderosa pine when feasible in order to provide protection from 

negative fire effects.

• Reduce tanoak/hardwood clumps but retain largest 25 to 50 percent of live stems over 4-inch

dbh per clump.

• Thin more heavily in areas where trees show thinning crowns.
Appendix C. Somes Bar Integrated Fire Management Project Prescriptions

420 – Somes Bar Integrated Fire Management Project

• Use TEK data and other on-site indicators to further prioritize areas for varying levels of 

thinning in order to enhance resources and create heterogeneous conditions.

• Feather treatment adjacent to access/egress routes and private property.

 In close proximity to the access/egress route (within 150 feet), thin and pile (or 

lop and scatter) all material up to the allowable size limit.

 Within the outer buffer (150 to 300 feet from the road), retain wildlife cover by 

leaving approximately 30 percent of the total area untreated.

 Retention buffers may also occur near private boundaries if identified as needed 

by wildlife personnel.

3. Hand piles

• On slopes up to 65 percent, hand piles in dimensions smaller than 5 feet by 5 feet should be 

created away from the dripline of pre-dominant trees.

• Slash generated from the thinning may be hand piled or jackpot piled in dimensions larger 

than 5 feet by 5 feet to create openings but this action will be very site specific.

• Consider leaving piles unburned when adjacent to perennial or intermittent stream channels.

4. Create or enhance openings roughly 0.25 to 0.33 acres in size when opportunities exist (reference 

specifications for prescriptions above).

5. When feasible, maintain areas of structural diversity (roughly 5 to 10 percent of the unit) as 

retention patches similar to prescriptions listed above.

Prescription #4b

Manual Treatment in Non-Plantations (minimum residual canopy cover of 60 percent).

1. The goal of treatment is to reduce ladder fuels by breaking up fuel continuity (both horizontal and 

vertical) of high concentrations. High priority treatment areas are those associated with strategic 

control features (private property, roads and ridges) and in areas identified as having unacceptably 

high fuel loading which would lead to negative prescribed fire effects.

2. Thin small diameter trees and shrubs (4 to 6 inches depending on NSO habitat) and reduce density 

of intermediate and suppressed trees.

• Maximum residual spacing of trees should be roughly 20 to 24 feet.

• Enhance diversity of species by thinning around true oaks, madrone, Pacific yew, sugar pine 

and ponderosa pine when feasible in order to provide protection from negative fire effects.

• Reduce tanoak/hardwood clumps but retain largest 25 to 50 percent of live stems over 4-inch 

dbh per clump.
Appendix C. Somes Bar Integrated Fire Management Project Prescriptions

Final Environmental Assessment – 421

 Use TEK data and other on-site indicators to further prioritize areas for varying 

levels of thinning in order to enhance resources and create heterogeneous 

conditions.

 Thin more heavily in areas where trees show thinning crowns.

 Feather treatment adjacent to access/egress routes and private property.

• In close proximity to the access/egress route (within 150 feet), thin 

and pile (or lop and scatter) all material up to the allowable size 

limit.

• Within the outer buffer (150 to 300 feet from the road), retain 

wildlife cover by leaving approximately 30 percent of the total area 

untreated.

• Retention buffers may also occur near private boundaries if 

identified as needed by wildlife personnel or private landowners.

3. Hand piles

• On slopes up to 65 percent, hand piles in dimensions smaller than 5 feet by 5 feet should be 

created away from the dripline of pre-dominant trees.

• Slash generated from the thinning may be hand piled or jackpot piled to create openings.

• Consider leaving piles unburned when adjacent to perennial or intermittent stream channels.

4. Create or enhance openings roughly 0.25 to 0.33 acre in size when opportunities exist (reference 

specifications for prescriptions above). Consider girdling to achieve desired opening where 

necessary.

5. When feasible, maintain areas of structural diversity (roughly 5 to 10 percent of the unit) as 

retention patches similar to prescriptions listed above.

Prescription #4c

Manual Treatment in Mechanically Thinned (or Masticated) Units.

1. As a follow-up action to a mechanical thinning and/or mastication, these areas need to be treated 

to reduce activity fuels and ladder fuels by breaking up fuel continuity (both horizontal and vertical). 

High priority treatment areas are those associated with strategic control features (private property, 

roads and ridges) or in areas identified as having unacceptably high fuel loading which could lead to 

negative prescribed fire effects. This would be a site-specific identified condition following

mechanical thinning activities.

2. Thin small diameter trees and shrubs (4 to 6 inch depending on NSO habitat).
Appendix C. Somes Bar Integrated Fire Management Project Prescriptions

422 – Somes Bar Integrated Fire Management Project

• Enhance variability of species by thinning around true oaks, incense cedar, madrone, pacific 

yew, sugar pine and ponderosa pine when feasible.

• Reduce tanoak/hardwood clumps but retain largest 25 to 50 percent of live stems over 4-inch 

dbh.

3. Slash generated from the thinning would generally hand piled, jackpot or lopped and scattered 

depending on fuel loading conditions.

• On slopes up to 65 percent, hand piles in dimensions smaller than 5 feet by 5 feet should be 

created away from the dripline of pre-dominant trees.

• Consider leaving piles unburned when adjacent to perennial or intermittent stream channels.

Prescription #4d

Manual construction of handline

1. Locations of primary and secondary handline have been pre-identified in order to conduct prescribed 

burning operations. These proposed handlines are located on strategic ridges, private property 

boundaries, as well as areas identified to treat mechanical activity fuels or to support prescribed burning.

• The standard definition of a handline is an average 2-foot-wide scrape down to bare mineral 

soil supported by a “brush cut” where ALL brush material and small trees (up to 6 inches) are 

cut to an average width of 6 feet. In some cases, a wider brushing cut may be needed to 

address a heavy fuel loading.

• Larger size trees (such as snags) adjacent to handline locations would ONLY be felled if they 

pose a safety risk to firefighters.

• Handlines will be constructed with cup trenches in areas greater than 45 percent slope (and 

where handlines are below a unit) where necessary to mitigate potential rollout of material.

• Some handlines may be rehabilitated after use, while those located in strategic locations 

would be maintained on the landscape to aid in future prescribed and wildfire activities.

2. Ridges identified as shaded fuelbreaks would have a standard handline (as described above) 

accompanied by a 100-foot-wide cut of small diameter (generally under 6 inch) material which may 

be hand piled or lopped and scattered.

3. In addition to main handlines for the units, small “check lines” may be temporarily installed within 

units or in riparian reserves, in order to mitigate negative fire effects or to temporarily halt the 

progression of the prescribed fire. These lines would be rehabilitated after use and would not 

remain on the landscape for an extended period.
Appendix C. Somes Bar Integrated Fire Management Project Prescriptions

Final Environmental Assessment – 423

Understory Burning

General Guidelines:

• Overall, burn intensity design aims for low to moderate fire effects (average 4-foot flame lengths 

anticipated) with isolated pockets of potentially higher fire effects.

• Some of the project area (particularly strategic areas as described in manual treatment descriptions) 

may undergo thinning and hand pile burning or thinning with lop and scatter prior to reintroducing 

managed fire, in order to reduce fuels and build resiliency in an area prior to prescribe burning.

• In some instances, understory burning may be an initial action, following some handline installation, 

where values at risk and fuel loading conditions are minimal.

• Timing and sequencing of prescribed fire entries should consider TEK habitat elements present within 

the burn unit as well as biophysical settings (such as slope and aspect).

• Once understory burning has occurred on a unit, a cyclical application of fire (burning frequency) will 

be planned occur according to an appropriate sequence. Burning frequencies will depend on 

conditions such as, but not limited to, existing fuel loading, elevation, aspect, TEK resources, habitat 

types, and unit location.

• Many understory burn units were developed on the landscape scale, taking advantage of natural 

control features, and may encompass different types of treatment units and fuel loading. Therefore, 

fire effects in these units will be moderated as changes in fuel loading, topography, and other 

conditions are observed on the ground.

• Ignition would not occur within riparian reserves, but prescribe fire would be allowed to back or 

creep within the area. If fuel loading is determined to be heavy, temporary handlines may be installed, 

away from stream banks when necessary, to minimize unintended fire effects.

Prescription #5a

Prescribed Fire Treatments in untreated plantations or non-plantations.

• The application of prescribed fire here would be considered a “first-entry” activity and could have 

potentially high levels of fire effects. These treatment units generally exist interior to strategic 

features which would undergo some amount of preparation (thinning, hand pile burning) prior to a 

larger application usage of fire, however some areas may just not have associated features and need to 

be assessed carefully.

• Burn bosses need to have a strong consideration of environmental conditions present during the 

application of prescribed fire. Lower percentile burning conditions (moister, cooler weather) could be 

more favorable to achieve desired fire effects initially.
Appendix C. Somes Bar Integrated Fire Management Project Prescriptions

424 – Somes Bar Integrated Fire Management Project

Prescription #5b

Prescribed Fire Treatments in mechanically treated areas plantations or non-plantations.

• In areas with no history of regeneration harvest, delay broadcast burn by 2 growing seasons after 

mechanical treatment is complete, in order to allow previously encroached Trees of Interest (or trees 

retained in the units) to adjust to new light conditions, increase vigor, and improve bark thickness.

• Consider moderating fire patterns around fuel concentrations to minimize mortality to remaining stand.

Prescription #5c

Prescribed Fire Treatments in manually treated plantations or non-plantations.

• Burning considerations here should be based on TEK factors as well as treatment unit position.

Prescription #5d

Prescribed Fire Treatments in mastication treated plantations.

• Depending on unit location, high consideration should be given to potential fire effects, given the 

associated environmental conditions present in the units.

• In general, prescribed burning activities should be delayed by approximately 2 to 5 years in 

order to allow for decomposition of masticated material.

• Where feasible, consider creating and burning handpiles in some heavily treated areas prior to 

understory burning.

• Burn bosses should consider lower percentile burning conditions for initial understory burn 

applications following mastication activities.

• Second entry understory burning may consider a higher percentile burning condition to 

achieve objectives, but those conditions should be assessed following the first entry.
Appendix C. Somes Bar Integrated Fire Management Project Prescriptions

Final Environmental Assessment – 425

Unit Attributes for Prescription Application

Table C-1. Mechanical harvest units (Prescriptions 1a, 1b and 2).

Unit # Proposed Action Management History Year Planted Acres

2101 Mech - ground-based Plantation 1967 9.7

2105 Mech - ground-based Plantation 1967 7.4

2110 Mech - ground-based Plantation 1978 5.7

2111 Mech - ground-based Plantation <Null> 8.1

2112 Mech - ground-based Plantation 1975 16.5

2113 Mech - ground-based Previously Thinned <Null> 13.3

2114 Mech - ground-based Previously Thinned <Null> 16.4

2116 Mech - ground-based Previously Thinned <Null> 19.6

2117 Mech - ground-based Plantation 1977 12.4

2119 Mech - ground-based Previously Thinned <Null> 3.2

2120 Mech - road-based No Previous Harvest <Null> 6.1

2124 Mech - cable Previously Thinned <Null> 4.0

2127 Mech - ground-based Previously Thinned <Null> 35.2

2128 Mech - ground-based Plantation 1987 2.5

2131 Mech - ground-based Plantation 1960 8.0

2132 Mech - ground-based Previously Thinned <Null> 11.2

2142 Mech - ground-based Previously Thinned <Null> 9.0

2145 Mech - ground-based No Previous Harvest <Null> 19.9

2148 Mech - ground-based Previously Thinned <Null> 5.0

2151 Mech - ground-based Plantation 1999 1.2

2157 Mech - road-based Previously Thinned <Null> 0.5

2158 Mech - road-based Previously Thinned <Null> 2.8

2200 Mech - ground-based Plantation 1964 5.8

2203 Mech - ground-based Plantation 1985 13.4

2217 Mech - ground-based Plantation 1976 24.2

2218 Mech - ground-based Previously Thinned <Null> 10.0

2221 Mech - ground-based Plantation 1983 10.1

2224 Mech - ground-based No Previous Harvest <Null> 2.9

2225 Mech - ground-based No Previous Harvest <Null> 7.3

2226 Mech - ground-based Plantation 1969 3.7

2227 Mech - ground-based Plantation 1983 33.3

2228 Mech - road-based Previously Thinned <Null> 7.7

2230 Mech - ground-based Plantation 1979 16.4

2231 Mech - road-based Previously Thinned <Null> 1.4

2235 Mech - ground-based Plantation 1980 9.5

2237 Mech - ground-based Plantation 1965 17.2

2242 Mech - ground-based Plantation 1984 25.8

2248 Mech - ground-based Previously Thinned <Null> 29.4

2249 Mech - ground-based Previously Thinned <Null> 78.4

2260 Mech - ground-based Previously Thinned <Null> 5.6

2264 Mech - ground-based Plantation 1975 25.8

2265 Mech - ground-based Plantation 1965 39.6

2266 Mech - ground-based Previously Thinned <Null> 6.8

2272 Mech - ground-based Previously Thinned <Null> 2.9
Appendix C. Somes Bar Integrated Fire Management Project Prescriptions

426 – Somes Bar Integrated Fire Management Project

Unit # Proposed Action Management History Year Planted Acres

2273 Mech - ground-based No Previous Harvest <Null> 3.4

2320 Mech - cable Plantation 1977 3.8

2321 Mech - cable No Previous Harvest <Null> 9.5

2328 Mech - ground-based Plantation 1986 11.7

2336 Mech - cable No Previous Harvest <Null> 16.8

2400 Mech - ground-based Previously Thinned <Null> 34.3

2401 Mech - road-based No Previous Harvest <Null> 1.8

2402 Mech - ground-based Plantation 1980 7.2

2404 Mech - ground-based Plantation 1962 4.3

2405 Mech - ground-based Plantation 1980 4.4

2407 Mech - ground-based Plantation 1964 26.0

2409 Mech - ground-based Plantation 1967 9.0

2411 Mech - ground-based Plantation 1969 23.5

2412 Mech - ground-based Plantation 1969 18.9

2414 Mech - road-based Plantation 1969 6.6

2419 Mech - ground-based Plantation 1968 7.8

2421 Mech - ground-based Plantation 1967 19.1

2422 Mech - ground-based Previously Thinned <Null> 5.4

2423 Mech - road-based Previously Thinned <Null> 6.1

2425 Mech - cable Plantation 1983 17.0

2426 Mech - road-based No Previous Harvest <Null> 5.6

2431 Mech - road-based No Previous Harvest <Null> 16.2

2433 Mech - ground-based Plantation 1975 8.0

2434 Mech - road-based No Previous Harvest <Null> 5.4

2452 Mech - ground-based Previously Thinned <Null> 6.1

2453 Mech - ground-based Previously Thinned <Null> 6.9

2454 Mech - ground-based Previously Thinned <Null> 30.7

2456 Mech - ground-based Plantation 1968 8.7

2460 Mech - cable Plantation 1967 20.4

2461 Mech - ground-based Plantation 1969 44.1

2462 Mech - cable No Previous Harvest <Null> 25.5

2463 Mech - ground-based Plantation 1966 11.2

2465 Mech - road-based Plantation 1969 10.2

2466 Mech - ground-based Plantation 1983 7.5

2467 Mech - ground-based Plantation 1987 11.4

2470 Mech - ground-based Plantation 1969 10.2

2474 Mech - ground-based No Previous Harvest <Null> 28.7

2475 Mech - ground-based Plantation 1962 17.2

2480 Mech - ground-based Plantation 1968 17.5

2481 Mech - ground-based Plantation 1965 25.9

2492 Mech - ground-based Plantation 1987 4.3

2493 Mech - ground-based Previously Thinned <Null> 29.3

2494 Mech - cable No Previous Harvest <Null> 6.0

2500 Mech - ground-based Previously Thinned <Null> 34.9

2505 Mech - ground-based Plantation 1965 7.7

2508 Mech - road-based No Previous Harvest <Null> 2.2
Appendix C. Somes Bar Integrated Fire Management Project Prescriptions

Final Environmental Assessment – 427

Table C-2. Mastication units (Prescription 3).

Unit # Proposed Action Management History Year Planted Acres

2130 Mastication Plantation 1989 6.8

2212 Mastication Plantation 1992 13.7

2214 Mastication Plantation 1991 5.1

2229 Mastication Plantation 1993 12.3

2240 Mastication Plantation 1966 29.7

2413 Mastication Plantation 1987 5.8

2427 Mastication Plantation 1982 22.0

2428 Mastication Plantation 1987 3.0

2441 Mastication Plantation 1987 9.5

2457 Mastication Plantation 1987 7.4

2477 Mastication Plantation 1980 3.4

2484 Mastication Plantation 1985 9.0

2486 Mastication Plantation 1983 30.2

2487 Mastication Plantation 1987 7.1

2489 Mastication Plantation 1989 6.9

2490 Mastication Plantation 1983 14.9

Table C-3. Manual Units (Prescriptions 4a and 4b).

Unit # Proposed Action Management History Year Planted Acres

2100 Manual No Previous Harvest <Null> 84.2

2102 Manual Plantation 1967 6.9

2103 Manual No Previous Harvest <Null> 4.5

2107 Manual Plantation 1967 4.8

2108 Manual Plantation 1987 5.0

2115 Manual Plantation 1969 44.2

2118 Manual Previously Thinned <Null> 14.0

2121 Manual Previously Thinned <Null> 14.6

2122 Manual No Previous Harvest <Null> 7.7

2123 Manual Previously Thinned <Null> 11.8

2125 Manual No Previous Harvest <Null> 3.6

2126 Manual No Previous Harvest <Null> 22.2

2129 Manual Plantation 1999 6.3

2133 Manual No Previous Harvest <Null> 3.1

2134 Manual No Previous Harvest <Null> 12.2

2135 Manual No Previous Harvest <Null> 11.8

2136 Manual No Previous Harvest <Null> 81.3

2137 Manual No Previous Harvest <Null> 27.6

2138 Manual No Previous Harvest <Null> 6.3

2139 Manual No Previous Harvest <Null> 26.2

2140 Manual No Previous Harvest <Null> 20.8

2141 Manual No Previous Harvest <Null> 19.6

2143 Manual No Previous Harvest <Null> 8.4

2146 Manual No Previous Harvest <Null> 40.4

2147 Manual No Previous Harvest <Null> 17.3

2149 Manual No Previous Harvest <Null> 7.9
Appendix C. Somes Bar Integrated Fire Management Project Prescriptions

428 – Somes Bar Integrated Fire Management Project

Unit # Proposed Action Management History Year Planted Acres

2150 Manual Plantation <Null> 2.9

2152 Manual Previously Thinned <Null> 10.9

2153 Manual No Previous Harvest <Null> 13.6

2154 Manual Previously Thinned <Null> 8.8

2155 Manual No Previous Harvest <Null> 7.9

2156 Manual No Previous Harvest <Null> 8.5

2159 Manual No Previous Harvest <Null> 7.8

2160 Manual Previously Thinned <Null> 9.8

2161 Manual No Previous Harvest <Null> 8.5

2162 Manual Previously Thinned <Null> 9.2

2163 Manual No Previous Harvest <Null> 21.7

2164 Manual Previously Thinned <Null> 5.5

2165 Manual No Previous Harvest <Null> 19.1

2166 Manual Previously Thinned <Null> 35.5

2167 Manual Previously Thinned <Null> 1.3

2168 Manual No Previous Harvest <Null> 8.4

2169 Manual Previously Thinned <Null> 4.5

2202 Manual No Previous Harvest <Null> 11.7

2206 Manual Previously Thinned <Null> 18.3

2207 Manual Plantation 1985 12.0

2210 Manual Plantation 1964 14.4

2211 Manual No Previous Harvest <Null> 10.6

2213 Manual No Previous Harvest <Null> 10.1

2216 Manual No Previous Harvest <Null> 3.5

2219 Manual No Previous Harvest <Null> 4.3

2220 Manual Plantation 1964 19.8

2222 Manual No Previous Harvest <Null> 10.2

2223 Manual No Previous Harvest <Null> 6.7

2233 Manual Plantation 1964 8.4

2236 Manual Plantation 1980 6.1

2239 Manual Previously Thinned <Null> 2.7

2241 Manual No Previous Harvest <Null> 2.0

2243 Manual No Previous Harvest <Null> 27.9

2244 Manual Plantation 1982 5.9

2245 Manual No Previous Harvest <Null> 5.6

2246 Manual Previously Thinned <Null> 10.8

2247 Manual Previously Thinned <Null> 14.0

2250 Manual No Previous Harvest <Null> 18.0

2251 Manual No Previous Harvest <Null> 7.2

2252 Manual No Previous Harvest <Null> 25.3

2253 Manual No Previous Harvest <Null> 59.3

2254 Manual No Previous Harvest <Null> 11.8

2255 Manual No Previous Harvest <Null> 23.8

2256 Manual No Previous Harvest <Null> 28.0

2257 Manual No Previous Harvest <Null> 10.0

2258 Manual No Previous Harvest <Null> 9.2
Appendix C. Somes Bar Integrated Fire Management Project Prescriptions

Final Environmental Assessment – 429

Unit # Proposed Action Management History Year Planted Acres

2259 Manual No Previous Harvest <Null> 104.0

2261 Manual Plantation 1984 6.2

2262 Manual Previously Thinned <Null> 2.0

2263 Manual No Previous Harvest <Null> 21.1

2267 Manual Plantation 1984 2.1

2271 Manual Previously Thinned <Null> 7.3

2274 Manual No Previous Harvest <Null> 9.6

2275 Manual No Previous Harvest <Null> 2.7

2276 Manual Plantation 1979 4.2

2277 Manual Plantation 1984 3.2

2278 Manual Plantation 1989 4.9

2279 Manual Plantation 1964 3.9

2280 Manual Previously Thinned <Null> 2.6

2281 Manual Previously Thinned <Null> 4.4

2282 Manual No Previous Harvest <Null> 3.6

2283 Manual Previously Thinned <Null> 3.0

2284 Manual Previously Thinned <Null> 17.4

2285 Manual No Previous Harvest <Null> 5.9

2286 Manual No Previous Harvest <Null> 7.0

2287 Manual Plantation 1964 4.8

2288 Manual No Previous Harvest <Null> 12.0

2289 Manual Previously Thinned <Null> 1.6

2290 Manual No Previous Harvest <Null> 20.4

2291 Manual No Previous Harvest <Null> 9.6

2292 Manual Previously Thinned <Null> 1.6

2293 Manual Previously Thinned <Null> 13.2

2294 Manual Previously Thinned <Null> 5.0

2295 Manual Plantation 1984 4.4

2300 Manual Previously Thinned <Null> 61.4

2301 Manual Plantation 1986 14.6

2302 Manual Plantation <Null> 4.5

2303 Manual No Previous Harvest <Null> 36.2

2305 Manual Plantation 1968 5.4

2307 Manual Plantation 1987 10.5

2308 Manual Plantation 1971 22.1

2309 Manual Plantation 1971 14.1

2311 Manual No Previous Harvest <Null> 10.6

2312 Manual No Previous Harvest <Null> 6.4

2313 Manual Plantation 1971 5.4

2314 Manual No Previous Harvest <Null> 39.8

2316 Manual No Previous Harvest <Null> 4.2

2318 Manual Plantation 1973 7.0

2319 Manual Plantation 1977 17.7

2322 Manual No Previous Harvest <Null> 32.6

2323 Manual No Previous Harvest <Null> 47.4

2325 Manual No Previous Harvest <Null> 14.9
Appendix C. Somes Bar Integrated Fire Management Project Prescriptions

430 – Somes Bar Integrated Fire Management Project

Unit # Proposed Action Management History Year Planted Acres

2326 Manual Plantation 1985 13.9

2327 Manual Plantation 1985 5.2

2329 Manual No Previous Harvest <Null> 13.7

2330 Manual Previously Thinned <Null> 9.8

2331 Manual Plantation 1985 6.3

2332 Manual Plantation 1985 5.6

2333 Manual No Previous Harvest <Null> 25.5

2334 Manual No Previous Harvest <Null> 11.8

2335 Manual No Previous Harvest <Null> 30.1

2343 Manual No Previous Harvest <Null> 18.7

2345 Manual No Previous Harvest <Null> 3.2

2346 Manual Plantation 1987 16.5

2347 Manual Plantation 1968 2.3

2348 Manual No Previous Harvest <Null> 17.1

2351 Manual Plantation 1971 2.2

2352 Manual Plantation 1971 10.3

2354 Manual No Previous Harvest <Null> 20.2

2355 Manual No Previous Harvest <Null> 7.1

2356 Manual No Previous Harvest <Null> 38.2

2357 Manual No Previous Harvest <Null> 30.3

2358 Manual No Previous Harvest <Null> 24.8

2359 Manual No Previous Harvest <Null> 6.0

2360 Manual Plantation 1977 6.8

2361 Manual No Previous Harvest <Null> 20.8

2403 Manual No Previous Harvest <Null> 8.9

2406 Manual No Previous Harvest <Null> 12.5

2408 Manual Plantation 1970 3.9

2410 Manual No Previous Harvest <Null> 8.9

2415 Manual Plantation 1965 10.6

2416 Manual No Previous Harvest <Null> 6.1

2417 Manual No Previous Harvest <Null> 29.4

2418 Manual No Previous Harvest <Null> 9.0

2420 Manual Plantation 1987 7.0

2424 Manual No Previous Harvest <Null> 2.0

2429 Manual Plantation 1987 1.0

2430 Manual No Previous Harvest <Null> 17.4

2432 Manual No Previous Harvest <Null> 13.3

2435 Manual No Previous Harvest <Null> 13.0

2436 Manual No Previous Harvest <Null> 5.1

2437 Manual Plantation 1987 12.4

2438 Manual No Previous Harvest <Null> 3.3

2439 Manual Previously Thinned <Null> 20.4

2440 Manual No Previous Harvest <Null> 22.2

2448 Manual No Previous Harvest <Null> 16.2

2449 Manual Previously Thinned <Null> 5.3

2450 Manual No Previous Harvest <Null> 4.8
Appendix C. Somes Bar Integrated Fire Management Project Prescriptions

Final Environmental Assessment – 431

Unit # Proposed Action Management History Year Planted Acres

2451 Manual Previously Thinned <Null> 2.2

2455 Manual No Previous Harvest <Null> 6.3

2458 Manual No Previous Harvest <Null> 11.4

2459 Manual Plantation 1987 19.7

2464 Manual Plantation 1987 16.3

2468 Manual No Previous Harvest <Null> 4.6

2469 Manual Plantation 1969 15.9

2471 Manual No Previous Harvest <Null> 5.4

2472 Manual Plantation 1970 26.1

2473 Manual Previously Thinned <Null> 7.6

2476 Manual Plantation 1982 4.0

2478 Manual Plantation 1982 6.9

2479 Manual Previously Thinned <Null> 31.4

2482 Manual Plantation 1987 2.7

2483 Manual No Previous Harvest <Null> 3.4

2485 Manual No Previous Harvest <Null> 9.7

2488 Manual Plantation 1970 6.5

2491 Manual No Previous Harvest <Null> 8.8

2495 Manual No Previous Harvest <Null> 17.1

2496 Manual No Previous Harvest <Null> 15.1

2497 Manual No Previous Harvest <Null> 2.9

2498 Manual Previously Thinned <Null> 10.8

2499 Manual No Previous Harvest <Null> 19.0

2501 Manual Plantation 1969 4.7

2502 Manual Plantation 1962 12.7

2503 Manual Plantation 1987 6.9

2504 Manual Plantation 1964 3.6

2509 Manual No Previous Harvest <Null> 45.7

2510 Manual No Previous Harvest <Null> 14.9

Table C-4. Prescribed fire units (Prescription 5a).

Unit # Proposed Action Management History Year Planted Acres

2201 Prescribed Fire No Previous Harvest <Null> 12.1

2204 Prescribed Fire No Previous Harvest <Null> 19.7

2205 Prescribed Fire No Previous Harvest <Null> 15.1

2208 Prescribed Fire No Previous Harvest <Null> 59.1

2209 Prescribed Fire No Previous Harvest <Null> 31.5

2215 Prescribed Fire No Previous Harvest <Null> 10.8

2232 Prescribed Fire No Previous Harvest <Null> 3.9

2234 Prescribed Fire Plantation 1964 7.0

2296 Prescribed Fire Plantation 1989 6.3

2268 Prescribed Fire No Previous Harvest <Null> 361.7

2269 Prescribed Fire No Previous Harvest <Null> 18.1

2270 Prescribed Fire No Previous Harvest <Null> 13.4
Appendix C. Somes Bar Integrated Fire Management Project Prescriptions

432 – Somes Bar Integrated Fire Management Project

Unit # Proposed Action Management History Year Planted Acres

2144 Prescribed Fire No Previous Harvest <Null> 73.0

2304 Prescribed Fire Plantation 1968 28.3

2306 Prescribed Fire Plantation 1987 19.2

2310 Prescribed Fire Plantation 1971 24.9

2315 Prescribed Fire No Previous Harvest <Null> 15.6

2317 Prescribed Fire Plantation 1973 15.4

2324 Prescribed Fire No Previous Harvest <Null> 18.9

2337 Prescribed Fire No Previous Harvest <Null> 9.8

2338 Prescribed Fire No Previous Harvest <Null> 31.3

2339 Prescribed Fire No Previous Harvest <Null> 172.3

2340 Prescribed Fire No Previous Harvest <Null> 129.5

2341 Prescribed Fire No Previous Harvest <Null> 29.9

2342 Prescribed Fire No Previous Harvest <Null> 72.1

2344 Prescribed Fire No Previous Harvest <Null> 18.9

2349 Prescribed Fire Plantation 1971 1.9

2350 Prescribed Fire Plantation 1971 3.0

2353 Prescribed Fire No Previous Harvest <Null> 8.9

2443 Prescribed Fire No Previous Harvest <Null> 160.6

2444 Prescribed Fire No Previous Harvest <Null> 2.9

2445 Prescribed Fire Previously Thinned <Null> 2.3

2446 Prescribed Fire No Previous Harvest <Null> 51.4

2447 Prescribed Fire No Previous Harvest <Null> 11.0

2506 Prescribed Fire Plantation 1987 18.5

2507 Prescribed Fire Plantation 1964 9.0

2238 Prescribed Fire No Previous Harvest <Null> 4.4
Appendix D. National Best Management Practices for Water Quality Management

Final Environmental Assessment – 433

Appendix D. National Best Management Practices for 

Water Quality Management36

National Best Management Practices (BMPs) are derived from the Forest Service publications National 

Best Management Practices for Water Quality Management on Nation Forest System Lands (USDA 

Forest Service 2012. The Somes Bar Integrated Fire Management Project (Somes Bar Project) will 

follow all applicable water quality BMPs. The purpose of this summary is to emphasize a selection of 

methods employed by the project that exemplify how the project meets applicable BMPs.

Aquatic Ecosystems Management Activities

AqEco-1 Aquatic Ecosystem Improvement and Restoration Planning

• “Reestablish and retain ecological resilience of aquatic ecosystems and associated resources to 

achieve sustainability and provide a broad range of ecosystem services.”

The project has undergone four (4) years of extensive planning using a rigorous approach combining 

best available science, professional experience, and traditional ecological knowledge to ensure sitespecific maintenance, improvement, and restoration of unique waterbodies to meet the objectives of the 

AqEco-1 BMPs.

Specific project planning that adheres to the AqEco BMPs are recognizing that inhabitants and uses 

alter the ecosystem, considering potential future environmental changes as a result of the project such as 

changes in runoff and species distribution, and prioritization of sites and sequence of implementation 

within a watershed to be most effective in achieving restoration goals.

AqEco-2 Operations in Aquatic Ecosystems

• Avoid, minimize or mitigate adverse impacts to water quality when working in aquatic ecosystems.

The project meets AqEco-2 objectives specifically by prohibiting any operations directly in 

waterbodies with the exception of water drafting, clearly defining the locations of riparian reserves, 

identifying aquatic and aquatic-dependent species, adhering to clear erosion control plans, wet weather 

operating standards, using low ground pressure equipment where applicable, and scheduling mechanical 

based operations in dry periods to avoid and minimize soil, water and species impacts.

AqEco-3 Ponds and Wetlands

• Design and implement pond and wetlands projects in a manner that increases the potential for success 

in meeting project objectives and avoids, minimizes or mitigates adverse effects to soil, water quality 

and riparian resources.

 36 National Best Management Practices for Water Quality Management applicable to Somes Bar Integrated Fire Management Project.
Appendix D. National Best Management Practices for Water Quality Management

434 – Somes Bar Integrated Fire Management Project

The project mitigates potential impacts to ponds by excluding all operations from within 25 feet of 

the winter-wetted perimeter. There are no wetlands in the project area.

WatUses-3. Administrative Water Developments

• Avoid, minimize, or mitigate adverse effects to soil, water quality, and riparian resources when 

developing and operating water sources for Forest Service administrative and resource management.

• Conduct operations at water source developments in such a manner as to avoid, minimize, or mitigate 

adverse effects to aquatic species and habitats from water drafting purposes.

The project uses existing water sources outside of occupied coho habitat. Operations would be 

conducted at water source developments in such a manner as to avoid, minimize or mitigate adverse effects 

to aquatic species and habitats from water drafting. Pumping rate will not exceed 350 gallons-per-minute or 

10 percent of the flow in anadromous reaches. Otherwise pumping rate will not exceed 50 percent of surface 

flow. Adhere to NMFS water drafting specification and guidelines at designated water sources: 

www.westcoast.fisheries.noaa.gov/publications/hydropower/water_drafting_specification_guidelines.pdf.

Facilities and Non-recreation Special Uses Management Activities

Fac-6. Hazardous Materials

• Avoid or minimize short- and long-term adverse effects to soil and water resources by preventing 

releases of hazardous materials.

Petroleum products would be stored at roads or landings outside of riparian reserves wherever 

possible and a minimum distance from streams, ponds, and wet areas such that fuels and other harmful 

materials would not reach any waterbody. Appropriate spill containment measures would be on site and 

would be employed as needed (for example, absorbent pads, drip pans and containment trays). Containers 

of fuel and oil are removed daily off-site.

Fac-7. Vehicle and Equipment Wash Water

• Avoid or minimize contamination of surface water and groundwater by vehicle or equipment wash 

water that may contain oil, grease, phosphates, soaps, road salts, other chemicals, suspended solids, 

and invasive species.

Heavy equipment and vehicles will be washed and cleaned off-site at designated locations prior to 

entering project area to prevent spread and introduction of invasive weeds and chemicals to waterbodies. 

A progression of work has been established in order to reduce the risk for spreading of invasive weeds. In 

the event that the progression of work cannot be adhered to, subsequent washing of heavy equipment at 

designated locations would be required.
Appendix D. National Best Management Practices for Water Quality Management

Final Environmental Assessment – 435

Wildland Fire Management Activities

Fire-1. Wildland Fire Management Planning

• Use the fire management planning process to develop measures to avoid, minimize, or mitigate adverse 

effects to soil, water quality, and riparian resources during wildland fire management activities.

The project’s core goals and values of landscape and forest restoration adhere well to the Fire-1 

BMPs because the project has undergone extensive analysis to arrive at project design features (PDF) that 

meets the BMP objectives for low prescribed burning fire effects. As discussed in Fire-1, the proposed 

actions uses a series of scheduled prescribed fire over the next 15 years to address the greatest need for 

fuel reduction around wildland-urban interface (WUI) areas. By planning to apply prescribed fire during 

periods of higher fuel moisture, using natural and constructed fire control lines, the burn area is intended 

to have a minimal risk of escape and a high likelihood for controlling the burn intensity at low to 

moderate intensities. These prescribed fire prescriptions result in minimal ground disturbance and 

minimal adverse effects to soil, water quality and riparian resources. As is specified in the Fire-1 BMPs, 

the project has identified areas where the adverse effects of unplanned wildfire outweigh any benefits it 

may bring, therefore making prescribed burning a highly appropriate approach. Site-specific design 

features, such as no direct ignition in riparian reserves, are used throughout the project area. Water 

sources needed as part of a prescribed burn plan are evaluated in the project and are at existing locations 

that minimize impacts to waterbodies and riparian reserves.

Fire-2. Use of Prescribed Fire

• Avoid, minimize, or mitigate adverse effects of prescribed fire and associated activities on soil, water 

quality, and riparian resources that may result from excessive soil disturbance as well as inputs of ash, 

sediment, nutrients, and debris.

The project specifically meets the Fire-2 BMPs by keeping staging areas as small as possible and 

outside of riparian reserves, constructing fire control lines at a minimum size needed to achieve 

objectives, prohibiting ignition within and keeping moderate to high-intensity fire out of riparian reserves, 

controlling fire spread and intensity by timing burning during periods of high soil moisture content, 

having clear design specifications that minimize size of hand piles to be burned, thereby minimizing area 

of soil impacts and avoiding adverse soil impacts, prevent surface erosion, and promote rapid natural 

revegetation.

Road Management Activities

Road-2 Road Location and Design

• Locate and design roads to avoid, minimize, or mitigate adverse effects to soil, water quality, and 

riparian resources.
Appendix D. National Best Management Practices for Water Quality Management

436 – Somes Bar Integrated Fire Management Project

The project specifically meets Road-2 BMPs by not using or constructing temporary use roads on 

unstable slopes, selecting existing temporary roads with an emphasis on roads far from wet areas, ponds, 

and streams, applying site specific design specifications to disperse and direct flow away from 

waterbodies and prevent direct discharge to water bodies, using only temporary roads that have very few 

and small stream crossings, and using proper road shaping and installing drainage features for roads 

remaining intact during wet seasons.

Road-3 Road Construction and Reconstruction

• Avoid or minimize adverse effects to soil, water quality, and riparian resources from erosion, 

sediment, and other pollutant delivery during road construction or reconstruction.

No new permanent roads are proposed. Less than five (5) miles of closed Level 1 roads would require 

some minor reconstruction, most only require maintenance and brushing. Level 1 roads requiring 

reconditioning or reconstruction actions would be done in the normal operating season when conditions 

are favorable to control an minimize any erosion or sedimentation that could occur during these 

operations. Erosion control plans are reviewed and approved prior to commencing work. Sidecasting is 

prohibited in or adjacent to streamcourses. Storm damage repair on 13N14A requires a new stream 

crossing culvert, appropriately sized to meet land and resource management plan (LRMP) standards and 

constructed in a rock fill.

Road-4 Road Operations and Maintenance

• Avoid, minimize, or mitigate adverse effects to soil, water quality, and riparian resources by 

controlling road use and operations and providing adequate and appropriate maintenance to minimize 

sediment production and other pollutants during the useful life of the road.

Haul roads would be maintained during the life of the project specially to minimize sediment 

production. Level 1 roads and all temporary use roads would be used only during normal operating 

periods and physically closed and winterized in the wet weather season.

Road-5 Temporary Roads

• Avoid, minimize, or mitigate adverse effects to soil, water quality, and riparian resources from the 

construction and use of temporary roads.

No new temporary use roads are proposed to be constructed in riparian reserves. About a half mile of 

new construction would occur where soils, water quality and riparian resources are not affected. Existing 

temporary roads that cross or are adjacent to riparian reserves would be utilized during normal operating 

periods, and closed and winterized during the wet weather season. Upon completion of the project, all 

temporary roads used for the project would left in a stable and maintenance free condition and closed to 

vehicle traffic.
Appendix D. National Best Management Practices for Water Quality Management

Final Environmental Assessment – 437

Road-6 Road Storage and Decommissioning

• Avoid, minimize, or mitigate adverse effects to soil, water quality, and riparian resources by storing 

closed roads not needed for at least one (1) year (intermittent stored service) and decommissioning 

unneeded roads in a hydrologically stable manner to eliminate hydrologic connectivity, restore natural 

flow patterns, and minimize soil erosion.

Level 1 roads brought into service for the life of the project would be left in a hydrological stable 

condition and returned closed status when no longer needed for implementation. The project will restore 

1.1 miles of legacy roads discovered in the project area. Restoration of legacy roads includes 

disconnecting any hydrologic connectivity thereby restoring natural flow patterns that may have been 

disrupted when the road was constructed. All excavated fill would be stored away from streams in a stable 

location. All stored and closed roads would be closed to vehicle traffic when no longer in service.

Road-7 Stream Crossings

• Avoid, minimize, or mitigate adverse effects to soil, water quality, and riparian resources when 

constructing, reconstructing, or maintaining temporary and permanent waterbody crossings.

New planned stream crossings (one on 13N14A) will be appropriately sized to best accommodate 

anticipated 100-year-flood events, have no diversion potential, and placed in clean rock fill. Stream 

crossings in the project area would be cleaned annually where needed and associated debris removed 

stored in a stable location. Any temporary road that may need a new stream crossing culvert (none are 

anticipated) would be removed each wet weather season and closed to vehicle traffic.

Road-8 Snow Removal and Storage

• Avoid or minimize erosion, sedimentation, and chemical pollution that may result from snow removal 

and storage activities.

Snow removal is not an anticipated action associated with this project. Much of the project area is at 

elevations below where snow typically accumulates.

Road-9 Parking and Staging Areas

• Avoid, minimize, or mitigate adverse effects to soil, water quality, and riparian resources when 

constructing and maintaining parking and staging areas.

No new landings are proposed in riparian reserves. Drainage of existing landings within or adjacent to 

riparian reserves would be directed and dispersed that rainfall flows away from streamcourses and 

prevents direct delivery.
Appendix D. National Best Management Practices for Water Quality Management

438 – Somes Bar Integrated Fire Management Project

Road-10 Equipment Refueling and Servicing

• Avoid or minimize adverse effects to soil, water quality, and riparian resources from fuels, lubricants, 

cleaners, and other harmful materials discharging into nearby surface waters or infiltrating through 

soils to contaminate groundwater resources during equipment refueling and servicing activities.

Servicing of equipment would occur at landings outside of riparian reserves wherever possible and a 

minimum distance from streams, ponds, and wet areas such that fuels and other harmful materials would 

not reach any waterbody. Appropriate spill containment measures would be on site and would be 

employed as needed (for example, absorbent pads, drip pans and containment trays). Containers of fuel 

and oil are removed daily off-site.

Road-1 Travel Management Planning and Analysis

• Use the travel management planning and analysis processes to develop measures to avoid, minimize, or 

mitigate adverse effects to soil, water quality, and riparian resources during road management activities.

Selection of roads for use was guided according to the Road-1 BMPs by prioritizing use of existing 

system roads and existing temporary roads, and emphasizing use of the minimum length of roads 

necessary to achieve project objectives. No new permanent road construction would occur. About 4.7 

miles of Level 1 (closed system road) would be brought into service for the life of the project as a Level 

2, and rehabilitated and returned to closed status upon completion of the project. New temporary road use 

is limited to only a half mile and is not located in riparian reserves. Every effort was made to utilize 

previous logging spurs. Less than 6.5 miles of existing temporary roads segments are located within 

riparian reserves. Temporary road use would occur during normal operating season and closed to traffic 

during seasonal wet weather. When the temporary road is no longer needed, it would be left in a free 

draining condition (no culverts or other structure that would require maintenance to maintain 

effectiveness) and travelway ripped to promote infiltration where needed so as to not concentrate flow on 

the old travelway and lead to off-site erosion and sedimentation. For the small percentage of existing and 

temporary roads and landings within riparian reserves, detailed site-specific design features have been 

developed to mitigate and prevent potential adverse effects to soil, water, and riparian resources and 

adhere to all road BMPs.

Mechanical Vegetation Management Activities

Veg-1 Vegetation Management Planning

• Use the applicable vegetation management planning processes to develop measures to avoid, 

minimize, or mitigate adverse effects to soil, water quality, and riparian resources during mechanical 

vegetation treatment activities.

The project places an emphasis on achieving the desired goals and objectives of fuel reduction in and 

outside of riparian reserves while also incorporating measures to avoid, minimize, or mitigate adverse 
Appendix D. National Best Management Practices for Water Quality Management

Final Environmental Assessment – 439

effects to soil, water quality, and riparian resources. Great effort has gone into planning the appropriate 

site-specific treatment type to address treatment timing, treatment of existing fuel types and levels, and 

promotion of desired enhancement of forest structure and species. Treatment types and locations were 

developed collaboratively among several local partners over many years to arrive at methods with 

minimal impact and high chance of success. All areas were evaluated by resource and cultural specialists 

and their findings intricately incorporated into vegetation management planning. Treatment prescriptions 

were determined in accordance with needs regarding sensitive soils, unstable slopes, ponds, wet areas, 

sensitive species and riparian reserves in order to avoid and minimize adverse impacts. Rock and water 

sources have been identified and evaluated. Contracts will include and adhere to all applicable Vegetation 

Management BMPs, and will contain clear mapping of all riparian reserves and site-specific 

requirements. The project will meet the requirements of the National Environmental Policy Act (NEPA)

process in the form of an environmental assessment (EA).

Veg-2 Erosion Prevention and Control

• Avoid, minimize, or mitigate adverse effects to soil, water quality, and riparian resources by 

implementing measures to control surface erosion, gully formation, mass slope failure, and resulting 

sediment movement before, during, and after mechanical vegetation treatments.

The project meets Veg-2 BMPs through adherence to quantitative standards and guides set in the Six 

Rivers (SRNF) and Klamath (KNF) national forests LRMPs. The project specifically meets Veg-2 BMPs 

by limiting percent area of soil disturbance, setting conditions and requirements for applying ground 

cover and erosion structures, prohibiting ground based mechanical treatment on steep and unstable slopes 

and on sensitive soils, limiting operations to dry periods, careful planning of locations for skids, roads, 

landings, cable corridors and other mechanical treatment infrastructure, and prescribing avoidance areas 

where needed.

Veg-3 Aquatic Management Zones

• Avoid, minimize, or mitigate adverse effects to soil, water quality, and riparian resources when 

conducting mechanical vegetation treatment activities in the aquatic management zones (AMZ).

The project specifically meets Veg-3 BMPs by identifying extent and type of streams and springs based 

on specialist investigations, and defining the widths of riparian reserve boundaries according to the SRNF 

and KNF LRMPs. All riparian reserves will be identified in implementation plans, and clearly marked on the 

ground. Mechanical treatments in the outer 80 feet of riparian reserves will be selectively applied to achieve a 

variety of cultural and natural resource-desired conditions and objectives. Project design features will 

maintain riparian and aquatic ecosystem structure, function, and processes while also avoiding, minimizing, 

or mitigating soil disturbance, damage to the waterbody, and loss of large woody debris recruitment, and 

shading. Streams and water bodies will not be entered or crossed by mechanical equipment in riparian 

reserves. Residual canopy cover would be maintained to at least 60 percent in riparian reserves to provide 

shading, bank stabilization, and as a future source of large woody debris within riparian reserves. Limitations 
Appendix D. National Best Management Practices for Water Quality Management

440 – Somes Bar Integrated Fire Management Project

on types of treatments, equipment, and equipment movements are incorporated into the project specifically 

for minimization of ground surface disturbance in riparian reserves.

Veg-4 Ground-Based Skidding and Yarding Operations

• Avoid, minimize, or mitigate adverse effects to soil, water quality, and riparian resources during 

ground-based skidding and yarding operations by minimizing site disturbance and controlling the 

introduction of sediment, nutrients, and chemical pollutants to waterbodies.

Project design features require the use of existing skid trails wherever possible. Because much of the 

project area was previously harvested using ground base operations, the need to create new skid trails is 

low. Some units have explicit PDFs that restrict new skid trail use to avoid any adverse effects to soils and 

water quality. Where equipment is permitted in the outer portions of riparian reserves, PDFs require that 

low-impact equipment that works in linear passes be used to avoid subsequent soil displacement. Limit or 

avoid skidding and yarding operations avoid on steep and geologically unstable slopes, and saturated, 

highly erodible, or easily compacted soils, skidding upslope and away from waterbodies, prohibiting 

skidding across or through waterbodies. Skidding and yarding operations would occur in the normal 

operating season to minimize site disturbance. All skidding and yarding operations would require an 

approved erosion control plan prior to implementation.

Veg-5 Cable and Aerial Yarding Operations

• Avoid, minimize, or mitigate adverse effects to soil, water quality, and riparian resources during cable 

and aerial yarding operations by minimizing site disturbance and controlling the introduction of 

sediment, nutrients, and chemical pollutants to waterbodies.

Cable systems employed would not yard across or through streamcourses and 60 percent canopy 

closure would be maintained within riparian reserves. Cable systems would require one end suspension of 

harvested material.

Veg-6 Landings

• Avoid, minimize, or mitigate adverse effects to soil, water quality, and riparian resources from the 

construction and use of log landings.

No new landings would be constructed in riparian reserves. Existing landing use within the outer 

riparian reserve requires proper surface shaping and drainage structures where necessary to direct and 

disperse flow away from riparian reserves to prevent direct delivery to waterbodies. All heavy equipment 

operations require approved erosion control plans when working outside of the normal operating season.

Veg-8 Mechanical Site Treatment

• Avoid, minimize, or mitigate adverse effects to soil, water quality, and riparian resources by 

controlling the introduction of sediment, nutrients, chemical, or other pollutants to waterbodies during 
Appendix D. National Best Management Practices for Water Quality Management

Final Environmental Assessment – 441

mechanical site treatment. Mechanical treatments include cutting and piling; chipping or mulching; 

roller chopping or masticating using heavy equipment; and pushing over vegetation.

Mechanical site treatments would be conducted primarily with masticators and chippers, working 

from existing roads or skid trails. Chainsaws are employed to cut understory vegetation where designated. 

All mechanical treatments in riparian reserves retain at least 30 percent of the vegetation to be cut and 

maintain a minimum of 60 percent canopy closure in the riparian reserves.
Appendix D. National Best Management Practices for Water Quality Management

442 – Somes Bar Integrated Fire Management Project

This page intentionally left blank.
Appendix E. Aquatic Conservation Strategy Objectives

Final Environmental Assessment – 443

Appendix E. Aquatic Conservation Strategy Objectives

In order to make the finding that a project “meets” or “does not prevent attainment” of the Aquatic 

Conservation Strategy (ACS) objectives the analysis must include a description of the existing condition, 

a description of the range of natural variability of the important physical and biological components of a 

given watershed, and how the proposed project or management action maintains the existing conditions or 

moves it within the range of natural variability (1994 ROD Attachment B p B-10).

The ACS outlines specific objectives regarding forest goals in the management of aquatic and riparian 

resources. Project NEPA decisions must be consistent with the wording regarding ACS consistency, including 

consistency with the nine (9) ACS objectives, as ACS consistency is described in the 1994 Northwest Forest 

Plan (NWFP) Record of Decision (1994 ROD) on page B-10 and in the May 22, 2007 Memorandum.

Four Components of ACS

The ACS has four (4) components: 1) key watersheds, 2) watershed or ecosystem analysis, 3) watershed 

restoration, and 4) riparian reserves. Within riparian reserves are standards that prohibit and regulate

activities that retard or prevent attainment of ACS objectives. This analysis documents the consistency of 

the project with the ACS objectives at the site scale and the 5th-field watershed scale. The consistency is 

analyzed at the short-term (during implementation up to the first 1 to 2 years) and the longer-term scales 

(greater than 2 years).

Riparian Reserves

Riparian reserves maintain riparian-dependent aquatic and terrestrial processes around running and still 

waters, and could function as corridors for movement of upland species. Lands along streams, meadows, 

seeps and springs including potentially unstable areas where special standards and guidelines direct land 

use. These standards and guidelines prohibit and regulate activities in riparian reserves that retard or 

prevent attainment of the ACS objectives.

The three (3) key standards and guidelines pertaining to Somes Bar Project are:

• Apply silvicultural practices for riparian reserves to control stocking, reestablish and manage 

stands, and acquire desired vegetation characteristics needed to attain ACS objectives.

• Design fuel treatment and fires suppression strategies, practices and activities to meet ACS 

objectives, and to minimize disturbance of riparian ground cover and vegetation. Strategies 

should recognize the role of fire in ecosystem function and identify those instances where fire 

suppression or fuels management activities could be damaging to long-term ecosystem function.

• Design prescribed burn projects and prescriptions to contribute to attainment of ACS objectives.

For the purposes of this analysis, riparian reserve includes the interim riparian buffers along intermittent 

and perennial streams (stream course riparian reserves) and inner gorges. Active landslides, toe zones of 

dormant landslides and steep-weathered granitic lands are also geologic riparian reserves but for this 
Appendix E. Aquatic Conservation Strategy Objectives

444 – Somes Bar Integrated Fire Management Project

report, they will be referred to as unstable lands to avoid confusion. See below for analysis as to how the 

Somes Bar Project meets the ACS objectives.

Key Watersheds

Key watersheds are the existing refugia for at-risk species, or are areas with high water quality. Key 

watersheds can have a mix of reserve, riparian buffer, and matrix allocations. A system of large refugia 

comprised of watersheds that are crucial to at-risk fish species and stocks and provide high water quality. 

The Somes Bar Project does not occur within a key watershed.

Watershed Analysis

Watershed analysis forms the basis to evaluate geomorphic and ecologic processes and enables planning 

to achieve ACS objectives. Analysis that evaluates geomorphic and ecologic processes and enables 

planning to achieve ACS objectives. The Ishi-Pishi Ecosystem Analysis was completed in 1998 

recommended actions to reduce the risk of high-intensity wildfires.

Watershed Restoration

Watershed restoration is a long-term program to restore watershed health and aquatic ecosystems that

• Reduces the risk of high intensity wildfire, and

• Decommissions 1.1 miles of legacy roads.

Somes Bar Integrated Fuels Management Project

Riparian Reserves

The riparian reserve network, a cornerstone of the ACS, defines the spatial extent of the riparian 

ecosystem based on the distance from the stream at which the key ecological processes occur. Riparian 

reserve widths of two-site potential tree-heights on fish-bearing streams and one site-potential tree-height 

on non-fish-bearing streams were established when the Northwest Plan was adopted. Riparian areas 

provide the ecological functions and processes necessary to create and maintain habitat for aquatic and 

riparian-dependent organisms over time, dispersal corridors for a variety of terrestrial organisms and 

connectivity of streams within a watershed (FEMAT 1993). After 15 years under the riparian reserves 

system, 70 percent of the watersheds had improved and 18 declined (Lanigan et al. 2012). The primary 

factors for improvement were an increase in the number of large trees (>20 inches dbh) in riparian areas 

and reduction in road densities in watersheds. Watersheds in which conditions declined have recently 

experienced wildfires (Reeves et al. 2016).

Ecologically diverse riparian corridors are maintained by active natural disturbance regimes, 

including fires that operate over a range of spatial and temporal scales. However, the role of fire, the 

streamside factors that influence fire properties and the response of riparian and aquatic communities to 
Appendix E. Aquatic Conservation Strategy Objectives

Final Environmental Assessment – 445

fire can differ widely, depending on characteristic of both the fire and the riparian area (Dwire et al. 

2016). Fire regimes in riparian areas relative to adjacent uplands vary depending on the physical features 

of the watershed, location within a given watershed, vegetation type and fuel characteristics, and 

disturbance and land use history (Olson and Agee 2005, Van de Water and North 2011). In the Klamath 

Mountains of Northern California, Skinner (2003) found that the median fire return intervals were 

approximately twice as long in riparian reserves as in upland sites, indicating that fires occurred less 

frequently in riparian areas. However, fires can be less severe or as severe as those in adjacent uplands, 

depending on the local topography, vegetation characteristics (especially fuel moisture and loading), and 

fire weather (Dwire et al. 2016).

Headwater streams are among the most dynamic portions of aquatic ecosystems (Naiman et al. 1992). 

Tributary junctions between headwater streams and larger channels are important nodes for regulating 

material flows in a watershed (Benda et al. 2004).

It is also important to note, however, that plantations and previously harvested units, comprise about 

41 percent of the project treatment area and they predate the NWFP and the Klamath and Six Rivers land 

and resource management plans (LRMPs). Within some of these old logging units that reveal riparian 

features, these riparian reserves had a very small stream buffer (up to 50-foot width) or showed no sign at 

all of streamside management zone (SMZ) protections at the time of previous harvesting.

Based upon field reconnaissance of the project, it was determined that some mechanical entry into the 

outer 80 feet of the stream riparian reserves was warranted, within these plantations and previously 

harvested units, in order to efficiently reduce high fuel loads and improve stand structure. The NWFP

recognized the need to manage within riparian reserves to address legacy issues of old silvicultural 

practices that encroached or even eliminated large trees within riparian reserves and adjacent stream 

channels such as in plantations.

ACS Objectives

The following is a summation of the environmental analysis from Chapter 3 regarding consistency with 

the elements and components of the ACS Objectives. Additional discussion and rationale may be found in 

Chapter 3 in the Watershed Values, Soils, Invasive Species and Wildlife sections.

• ACS 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.

The Proposed Action is expected to have no effect on watershed and landscape-scale features because 

they are largely avoided. Riparian areas are part of the landscape and may need fuel treatments based on 

fuel loading within and in surrounding uplands.

Vegetation management for fuels treatment would occur within the outer 80 feet of non-fish bearing 

stream riparian reserves, however canopy closure would not be reduced below 60 percent overall as 

thinning would target the suppressed and intermediate trees. The majority of these units are in previous 

plantations. Treatments would reduce the risk of uncharacteristically high intensity fires from occurring 
Appendix E. Aquatic Conservation Strategy Objectives

446 – Somes Bar Integrated Fire Management Project

and improving resiliency in stand structure and composition in the watersheds. Connected actions such as 

temporary roads would be developed outside of riparian reserves, utilized and decommissioned after use. 

Mechanical ground based and cable systems and use of temporary and existing roads would follow 

project design criteria. The type of fuel treatments in the riparian reserves would not vary from upslope, 

but design features would be implement such that canopy cover and large woody debris levels would not 

change significantly. Reducing the risk of uncharacteristically high severity fire in riparian areas can limit 

the effects to riparian dependent species such as TEK focal species willow and pacific giant salamander 

as well as limit the spread of invasive species.

Wood recruitment typically comes from the inner half of a site potential tree-height; therefore, 

managing the outer half of the riparian reserves should maintain wood recruitment process in non-fishbearing streams. The inner riparian reserve would have manual fuel treatments with vegetation up to 6 

inches removed to reduce the fuel loading.

Also included in the proposed actions is the restoration of six (6) segments, 1.1 miles total of legacy 

roads discovered in the project area. Restoration of legacy roads includes removing one culvert and 

associated fill, storing fill in stable locations, covering of excavation sites and storage areas with suitable 

material to minimize surface erosion until native vegetation is reestablished, seed with native grass where 

needed, placing waterbars or dips to prevent water from concentrating on the roadbed, and decompacting 

the travelway. The Proposed Action would have an insignificant and undetectable effect with a long-term 

beneficial effect on watershed and landscape-scale features.

Alternative 2 was designed so as components are put together, management for the focal species, 

including willow and Pacific giant salamander would provide a realistic and holistic approach to whole 

landscape management, which aligns with this objective.

• ACS 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.

The Proposed Action is expected to maintain spatial and temporal connectivity within and between 

watersheds. Vegetation treatments would occur within portions of non-fish bearing stream riparian

reserves; however, canopy closure would not be reduced below 60 percent overall as thinning would 

target suppressed and intermediate trees. Treatments would improve stand structure and composition. 

Connected actions such as new temporary roads and landings would be developed outside of riparian 

reserves, utilized and decommissioned after use. Logging systems and use of temporary and existing 

roads for haul would employ extensive Project Design Criteria and Mitigation Measures. The Proposed 

Action may impact spatial connectivity for terrestrial species during project implementation, however, 

would have no effect on long-term network connections and would not create any physical obstructions. 

There would be no measurable effect on aquatic and riparian dependent species, with a long-term 

beneficial effect.
Appendix E. Aquatic Conservation Strategy Objectives

Final Environmental Assessment – 447

• ACS Objective 3. Maintain and restore the physical integrity of the aquatic system, including 

shorelines, banks, and bottom configurations.

The Proposed Action is expected to maintain physical integrity of the aquatic system as shorelines, banks 

and stream bottoms would not be affected. Vegetation treatments would improve stand structure, 

composition and the integrity of the aquatic system. All mechanical treatments would occur in the outer 

80 feet of both fish-bearing and non-fish-bearing streams. Connected actions such as temporary roads 

would be developed outside of riparian reserves, utilized and decommissioned after use.

• ACS 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.

The Proposed Action is expected to maintain water quality. Project operations would adhere to all BMPs 

pertaining to containment and prevention of all petroleum product spills from reaching water bodies. 

Heavy equipment fueling would only occur on roads and landings. Chainsaw fueling or storing of fuel 

would not occur adjacent to stream courses. Spill trays and absorbent padding would always accompany 

fueling or storage of fuel and oil during operations. Containers of fuel and oil are removed daily off-site. 

Chemical contamination would not occur.

• ACS 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.

The Proposed Action is expected to maintain the sediment regime under which aquatic ecosystems 

evolved, with an insignificant and undetectable effect on sediment regime. Interdisciplinary team (IDT) 

members representing disciplines of hydrology, soils, geology, forestry and fisheries carefully evaluated 

potential impacts from heavy equipment use within riparian reserves and ground based cable harvesting 

(endlining) outside of riparian reserve buffers. Because this is a fuel reduction project, the intent is to 

remove smaller diameter trees, while retaining the larger, more fire resilient trees in the stand. No 

equipment or other ground disturbing activities would occur within the inner 80 feet of the riparian 

reserve (immediately adjacent to the stream channel) or within active landslides, providing for adequate 

buffers and filtering of soil that may have become displaced in the outer riparian reserve, thus posing a 

low risk to sedimentation. Kreutzweiser and Capell (2001) found no significant input of sediment when 

machine travel was greater than 10 feet from streams and harvesting equipment did not create channeled 

flow paths. Manual and mechanical would not result in significant expose of disturbed soil with the 

implementation of best management practices (BMPs).

In the long term, as a result of these activities, the potential for road-related sedimentation is expected 

to be reduced to a minor degree due to restoration of 1.1 miles of legacy road and because the overall 

hydrologic function of treated roads would be improved. The integration of BMPs during project planning 

and implementation phase would also reduce the risk for long term and short term adverse impacts to 
Appendix E. Aquatic Conservation Strategy Objectives

448 – Somes Bar Integrated Fire Management Project

water quality. The stream crossings in the legacy roads would not fail; therefore, up to 1,100 cubic yards 

of sediment would not be delivered.

At the watershed scale, changes in the overall sediment rates will not be detectable given the high 

variability in natural rates of sediment input.

• ACS 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.

The Proposed Action is expected to maintain stream flow. Water drafting to support prescribed burns and 

dust abatement for watering roads could occur from developed water sources near the project area. It is 

unlikely that flows would be affected from the drafting as relatively small amounts would be removed and 

the area would be continually recharged from upstream. BMPs require less than 10 percent of base flow 

be drafted at any given time. For these reasons, implementation of the project would not adversely impact 

the volume or timing of streamflow. There would be no measurable effect on stream flow.

• ACS Objective 7. Maintain and restore the timing, variability, and duration of floodplain inundation 

and water table elevation in meadows and wetlands.

The Proposed Action is expected to have no effect on the timing, variability, and duration of floodplain 

inundation and water table elevation in meadows and wetlands.

• ACS Objective 8. Maintain and restore the species composition and structural diversity of plant 

communities in riparian reserves 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 distributions of coarse woody debris sufficient to sustain 

physical complexity and stability.

The Proposed Action is expected to maintain and enhance the species composition and structural diversity 

of plant communities in riparian reserves and wet areas (springs and seeps). Manipulation of vegetation 

within riparian reserves would be generally avoided. No effects are anticipated that would adversely affect 

species composition and structural diversity of plant communities within riparian reserves and wet areas.

• ACS Objective 9. Maintain and restore habitat to support well-distributed populations of native plant, 

invertebrate and vertebrate riparian-dependent species.

The Proposed Action is expected to maintain habitat to support well-distributed populations of native 

plant, invertebrate and vertebrate riparian-dependent species. Fuel-reduction treatments can potentially 

assist in riparian and stream restoration by returning fuel loads and vegetation, and result in more spatially 

diverse range of habitat components with long-term benefits for multiple wildlife species, including TEK 

focal species Roosevelt elk. There would be no measurable adverse effects, with a long-term beneficial 

effect. Therefore, as an overall determination, the impacts associated with the Proposed Action, either 

directly, indirectly, individually or cumulatively, would not prevent attainment of Aquatic Conservation 

Strategy, nor the nine (9) ACS Objectives, at the site (project area), watershed (Analysis Area) or 

landscape (Mid Klamath watershed) scales.
Appendix E. Aquatic Conservation Strategy Objectives

Final Environmental Assessment – 449

Consistency Finding

Project implementation does not prevent attainment of ACS objectives at the HUC 6 and larger scales in 

the short-term, and promotes attainment of ACS objectives in the long-term. Fuel treatments are in accord 

with recommendations in the Ishi Pishi Ecosystem Analysis (1998). CWE would remain below threshold 

for adverse watershed effects. Minimal disturbances are not expected to adversely affect anadromous fish 

and habitat because PDFs would contain effects to the project site and the effects are negligible in the 

action area. The project would maintain and help restore many of the Indicators of the HUC 6 

subwatersheds in the short term and are expected to improve aquatic habitats and watershed conditions 

for fish populations in the Ti Creek, Boise Creek and Reynolds Creek composite subwatersheds, and in 

the lower mid-Klamath River in the long term.
Appendix E. Aquatic Conservation Strategy Objectives

450 – Somes Bar Integrated Fire Management Project

This page intentionally left blank.
Appendix F. Cumulative Watershed Effects Analysis Using R5 ERA Model

Final Environmental Assessment – 451

Appendix F. Cumulative Watershed Effects Analysis 

Using R5 ERA Model

Assumptions

The Forest Service in Region 5 has adopted the Equivalent Roaded Acres (ERA) model as a method of 

addressing cumulative watershed effects. This model is designed as a preliminary indicator for managers 

to determine whether past and present land management disturbances in a given watershed approach or 

exceed a threshold of concern (TOC). Where ERAs approach or exceed a given watershed’s TOC, further 

fieldwork would be necessary to ascertain whether cumulative watershed effects (CWE) are present and if 

land management activities would adversely add to those effects and result in detrimental impacts to 

beneficial uses. The ERA methodology has both strengths and weaknesses. The analysis is readily 

duplicated and easily understood. It also incorporates rates of management disturbance and recovery 

times associated with those disturbances, an attribute which is missing in many other CWE models. It 

does not account for the phasing of proposed treatments and assumes all actions happen at the same time. 

It also does not address physical or biological processes in stream channels, nor does it account for the 

time lag associated with routing sediment delivered from a given activity. Recovery times in the ERA 

model apply only to onsite treatments, not to recovery of potential downstream impacts.

Threshold of Concern

Thresholds of concern (TOC) by watershed were developed in 1995 Six Rivers (SRNF) and Klamath 

(KNF) National Forests Land and Resource Management Plan (LRMPs) revisions. The TOC is an 

estimated upper limit of total disturbance that a watershed can tolerate without adverse impacts to 

beneficial uses. In the event that the total percent ERAs approach a TOC, management actions should be 

evaluated to insure that detrimental cumulative watershed effects do not occur. In developing TOCs, 

several physical and biological parameters were evaluated, including inherent geologic stability, extent of 

inner gorges plus active and inactive landslides, erodibility of soils, slope steepness, status of anadromous 

fish, condition of riparian areas and others. Assigning a TOC to a given watershed is an interdisciplinary 

professional judgment that weighs the various environmental indicators described above. The TOCs for 

this project range are shown below in Table F-1.

Table F-1. Threshold of concern by watershed.

Name of 6th-Field HUC Watershed Threshold of Concern (percent)

Boise Creek-Klamath River 13.7

Reynolds Creek 8

Ti Creek Klamath River 8
Appendix F. Cumulative Watershed Effects Analysis Using R5 ERA Model

452 – Somes Bar Integrated Fire Management Project

ERA Calculations

The CWE ERA analysis for the project was conducted on all lands within the affected watersheds (public and 

private). The methods used to calculate percent ERAs for past, present and reasonably foreseeable future land 

management activities are described below. The coefficients and recovery time used in the ERA calculations 

are listed in Table F-1 through Table F-7, which include the rational for assigning of coefficients.

Fuels Reduction and Timber Harvest

Proposed actions ERA is calculated using the following formula:

• ERA = [Acres Treated] x [Method Coefficient]

Past actions ERA calculations include a recovery time (recovery time = 1 - (current year - year of 

action)/recovery time.

• ERA = [Acres Treated] x [Method Coefficient] x [Recovery Time].

Table F-2 lists the coefficients and recovery time assigned to various activities related to past and 

proposed fuel reduction treatments and timber harvest.

Table F-2. ERA coefficients and recovery times.

Activity Method Method Coefficient Recovery Time

Fuel-Treatment Understory Burn 0.1 10

Fuel-Treatment Broadcast/Jackpot Burn 0.04 4

Fuel-Treatment Burn Hand Piles 0.02 2

Fuel-Treatment Mastication 0.15 15

Fuel-Treatment Cut and Hand Pile 0.02 2

Fuel-Treatment Cut and Tractor Pile 0.15 15

Fuel-Treatment Understory Burn 0.1 10

Fuel-Treatment Strategic Fuelbreaks 0.02 5

Harvest Clear-cut (unknown method) 0.25 25

Harvest Clear-cut, Skyline 0.2 20

Harvest Clear-cut, Tractor/Mechanical 0.3 30

Harvest Group Select 0.2 20

Harvest Group Select, Helicopter 0.1 10

Harvest Group Select, Skyline 0.15 15

Harvest Group Select, Tractor/Mechanical 0.2 20

Harvest Overstory Removal 0.25 25

Harvest Overstory Removal, Helicopter 0.1 10

Harvest Overstory Removal, Skyline 0.2 20

Harvest Overstory Removal, Tractor/Mechanical 0.3 30

Harvest Shelter wood 0.25 25

Harvest Shelter wood, Skyline 0.2 20

Harvest Shelter wood, Tractor/Mechanical 0.25 25

Harvest Commercial Thin 0.2 20

Harvest Commercial Thin, Skyline 0.15 15

Harvest Commercial Thin, Tractor/Mechanical 0.2 20
Appendix F. Cumulative Watershed Effects Analysis Using R5 ERA Model

Final Environmental Assessment – 453

Activity Method Method Coefficient Recovery Time

TSI Pre-commercial Thin (unknown method) 0.05 5

TSI Pre-commercial Thin, Biomass 0.15 15

TSI Pre-commercial Thin, Manual 0.02 2

TSI Pre-commercial Thin, Tractor 0.15 15

Roads

The existing road ERA is calculated using the following formula: 

• ERA = [Road Length] x [Road Width] x [ERAs per Mile]

Road miles (all public, state, county and privately owned) were assessed, including legacy roads 

identified from LIDAR imagery. Roads are a permanent feature on the landscape and unless they are 

decommissioned or restored, they do not recover over time. The recovery rate for a decommissioned or 

restored roads and landings, based on professional judgment and experience, is estimated to be 10 years. 

Recovery rates are assigned for all temporary roads, landings and legacy road restoration in the project area.

The restored roads and landings ERA is calculated using the following formula: 

• ERA = [Road Length] x [Road Width] x [ERAs per Mile] x [Recovery Time].

• Recovery time = 1 - (current year - year of action)/recovery time.

The ERAs associated with open roads and landings will stay constant over time and not reduce as in 

the case of most activities that recover over time. Table F-3 lists the coefficients used to develop ERAs 

per road mile.

Table F-3. Road ERA coefficient and recovery times.

Roads and Landings ERAs per Mile Recovery Time

Existing/In Use 4.2 0

Decommissioned or Restored 4.2 10

Wildfire

Table F-4 shows the ERAs assigned to burn areas (within the past 15 years when recovery is assumed) in 

the analysis watersheds. It was assumed that low to moderate burn intensities had no negative watershed 

impacts. Moderate intensity burns were assumed to have a light impact on a watershed similar to that of 

an extremely light land management ground disturbing activity (for example, manual fuel reduction 

treatments). Higher burn intensities were given ERAs/Acre similar to more ground disturbing activities 

such as skyline or cable suspension systems and in the case of the most intense burned areas, ERAs per 

acre values were assigned similar to disturbances associated with tractor yarding systems.

Wildfire burn severity ERAs were calculated using the following formula:

• ERA = [Wildfire Acres] x [Burn Severity ERA] x [Burn Severity Recovery Years]

• Recovery time = 1 - (current year - year of action)/recovery time.
Appendix F. Cumulative Watershed Effects Analysis Using R5 ERA Model

454 – Somes Bar Integrated Fire Management Project

Table F-4. Wildfire ERAs.

Wildfire Burn Severity Description and Suppression Actions ERAs Years To Recovery

Low Severity 0.00 0

Moderate Severity 0.05 5

High Severity 0.10 10

Extreme Severity 0.15 15

Dozer Lines and Safety Zones (assumes suppression repair) 0.10 5

Handlines and manual fuel breaks (assumes suppression repair) 0.05 2

Table F-4 lists the estimates made as to how long it would take a burned area to recover relative to the 

burn severity. Estimates on recovery times were extremely conservative, especially since evidence exists 

that surface erosion is essentially negligible after the first 1 to 5 years after a fire. However, due to the 

decay of roots associated with dead trees, steep hillslopes may reach maximum instability 10 to 15 years 

after the fire and become more susceptible to mass wasting processes. Assumes suppression repair actions 

taken promote active and passive recovery.

Current Condition ERA Results

The CWE ERA Analysis for the Somes Bar Project was conducted across three 6th-field watersheds, 

including federal, state and privately owned lands (see Table F-7). The methods used to calculate percent 

ERAs for past and present land management activities are described in the above sections. The 

coefficients used in the ERA calculations are listed above in Table F-1 through Table F-4.

The following equation is used to calculate total percent ERAs for all past actions and represents the 

current condition:

• Percent ERA = (([Timber and Fuels ERA] + [Roads ERA] + [Wildfire ERA] + [Fire

Suppression Containment Lines)/[watershed acres]) x 100.

The total percent current condition ERA results are shown in Table F-5. All of the roads previously 

decommissioned in the analysis watersheds have since recovered. Since 1995, timber harvest 

management actions have changed from primarily clear-cutting to thinning for fuel reduction. Much of 

the past clear-cuts are greater than 30 years, hence hydrologic processes are considered recovered. Some 

of the recent wildfire footprints have yet to fully recover, as well as the fire suppression control lines built 

using heavy equipment.

Results of the ERA analysis indicate that the affected watersheds are well below the TOC, indicating 

that past management actions and wildfires have not resulted in adverse cumulative watershed effects.

Table F-5. Current condition percent ERA compared to TOC.

Name of 6th-Field HUC Watershed Existing Condition ERA 

(percent) Threshold of Concern (percent)

Boise Creek – Klamath River 0.8 13.7

Reynolds Creek 4.9 8

Ti Creek – Klamath River 4.3 8
Appendix F. Cumulative Watershed Effects Analysis Using R5 ERA Model

Final Environmental Assessment – 455

Proposed Action ERAs

The following equation is used to calculate total ERAs associated with the Proposed Action:

• Percent ERA = (([Mechanical Treatments ERA] + [Manual Treatments ERA] + [Temporary 

road and landing ERAs] + [Fuel breaks and Handlines] + [Prescribed Fire ERA]) / [watershed 

acres]) x 100.

Results of the ERA analysis for the proposed actions are shown in Table F-6 below.

Table F-6. Proposed Action ERA results.

Name of 6th-Field HUC Watershed

Mechanical, 

Manual and 

Prescribed Fire 

Treatments ERA

Temporary 

Roads and 

Landings

Fuel Breaks 

and Handlines 

ERAs

Total 

Proposed 

Action ERAs

Boise Creek – Klamath River 19.79 3.7 .05 23.54

Reynolds Creek 387.02 140.24 8.02 535.28

Ti Creek – Klamath River 84.46 40.25 2.85 127.56

Foreseeable Future Proposed Actions in Analysis Watersheds

The Six Rivers Aquatic Restoration Project would occur in the affected watersheds in the foreseeable 

future. Planned actions in the affected watersheds are limited to riparian and stream enhancement (for 

example, strategic large woody debris placement). No new roads or temporary roads would be required. 

The actions would not create measurable ground disturbance, nor would the action lead to added adverse 

cumulative effects.

Results of ERA Analysis

Table F-7 displays the ERA findings. All of the affected watersheds are below the threshold of concern. 

While the ERA percentage shows an increase over time, it is expected that implementation of this project 

will promote a more fire resilient landscape and reduce the potential for high severity wildfires in the future.

Table F-7. ERA analysis results.

Name of 6th-Field HUC 

Watershed

Watershed 

Acres Current ERA Proposed Action ERA Total ERA Total Percent ERA

Threshold of 

Concern 

(percent)

Boise Creek – Klamath River 31,343 241 23.54 264.54 0.84 13.7

Reynolds Creek – Klamath River 34,611 1,680 535.28 2,215.28 6.4 8

Ti Creek – Klamath River 13,623 579 127.56 706.56 5.2 8
Appendix F. Cumulative Watershed Effects Analysis Using R5 ERA Model

456 – Somes Bar Integrated Fire Management Project

This page intentionally left blank.