Sunrise Vegetation and 

Fuels Management Project

Final Environmental Impact Statement

Umatilla National Forest

Pomeroy Ranger District

Forest Service FS-F14-PM-02-19 December 2018

United States Department of Agriculture
Cover photo: the view from Elk Point on the Pomeroy Ranger District offers a dramatic panorama of forest vegetation in 

the headwaters of North Fork Asotin Creek and is a representative portion of the Sunrise project area. 

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SUNRISE VEGETATION AND FUELS MANAGEMENT PROJECT

Draft Environmental Impact Statement

Garfield and Asotin Counties, Washington

Lead Agency: USDA Forest Service

Responsible Official: Monte Fujishin, District Ranger

Umatilla National Forest, Pomeroy Ranger District

71 W. Main Street, Pomeroy, WA 99347

For Information Contact: Johnny Collin

Umatilla National Forest, Pomeroy Ranger District

71 W. Main Street, Pomeroy, WA 99347

Phone: 509-843-4643

Abstract: The USDA Forest Service, Umatilla National Forest has prepared a Final Environmental Impact 

Statement (FEIS) for the Sunrise Vegetation and Fuels Management Project (Sunrise project) located on the 

Pomeroy Ranger District. The proposed project will address the needs for: (1) Reducing fuels and vegetation to 

lessen wildfire effects and promote healthy forests; (2) Improving and maintaining wildlife habitat; (3) Promoting 

timber production and harvest to meet Forest Plan targets; and (4) Providing timber products to local economies. 

Three Alternatives are analyzed, including the No Action Alternative (Alternative A). The Proposed Action 

(Alternative B), and one additional action alternative (Alternative C). These three alternatives were brought forward 

for detailed analyses of effects as they best met the purpose and needs for the project as identified by the 

Interdisciplinary Team (IDT) in internal scoping as well comments from the public in external scoping. Additional 

documentation, including maps and more detailed analyses of project area resources, may be viewed by appointment 

at the Pomeroy District Range, 71 W. Main Street, Pomeroy, Washington 99347, or on the project website: 

https://www.fs.usda.gov/project/?project=45689

This proposed decision is subject to predecisional administrative review pursuant to 36 CFR 218, Subparts A and B, 

also known as the “objection process.” Objections will only be accepted from those who submitted project-specific 

written comments during scoping or other designated comment period. Issues raised in objections must be based on 

previously submitted comments unless based on new information arising after the designated comment period(s). 

Objections must be submitted within add 45 days following the publication of the legal notice in the East Oregonian, 

the paper of record. The date of this legal notice is the exclusive means for calculating the time to file an objection. 

Those wishing to object should not rely upon dates or timeframes provided by any other source. It is the objector’s 

responsibility to ensure evidence of timely receipt (36 CFR 218.9). 

The preferred objection submission platform is via our webpage. Submit electronic objections on the Aquatic 

Restoration Project webpage: https://www.fs.usda.gov/project/?project=45689 by selecting the “Comment/Object on 

Project” link in the “Get Connected” group at the right hand side of the project webpage. Put the project name in the 

subject line; attachments may be in the following formats: plain text (.txt), rich text format (.rtf), Word (.doc, .docx), 

or portable document format (.pdf). Hardcopy objections can be submitted by:

• Mail: Forest Supervisor, Attn: Forest Environmental Coordinator, Umatilla National Forest, 72510 Coyote 

Road, Pendleton, OR 97801 

• Hand delivery: Forest Supervisor, Attn: Forest Environmental Coordinator, Umatilla National Forest, 

72510 Coyote Road, Pendleton, OR 97801. Hand deliveries can occur between 8:00 AM and 4:30 PM, 

Monday through Friday except legal holidays

• Fax: Forest Supervisor, Attn: Forest Environmental Coordinator at 541-278-3730

Objections must include (36 CFR 218.8(d)): 1) name, address and telephone; 2) signature or other verification of 

authorship; 3) identify a single lead objector when applicable; 4) project name, Responsible Official name and title, 

and name of affected National Forest(s) and/or Ranger District(s); 5) description of the specific issues related to the 

proposed project and suggested remedies to resolve, your objections; and, 6) description of the connection between 
your objections and your prior comments. Incorporate documents by reference only as provided for at 36 CFR 

218.8(b).

Send Comments to: Monte Fujishin, Pomeroy District Ranger

ATT: Johnny Collin

71 W. Main Street, Pomeroy, WA 99347

Phone: (509) 843-4620, Fax: (509) 843-4621

Electronic Comments: Submit electronic comments on the Sunrise project webpage: 

http://www.fs.fed.us/nepa/fs-usda-pop.php/?project=45689 by selecting the 

“Comment on Project” link in the “Get Connected” group at the right hand 

side of the project webpage.

Comments must be received by the end of the 45 days following publication of the legal notice in the newspaper of 

record. The publication date of the legal notice in the East Oregonian is the exclusive means for calculating the 

comment period.
Final Environmental Impact Statement

Pomeroy Ranger District i

Preface

Summary

Project Location

The Sunrise Vegetation and Fuels Management Project (henceforth referred to as the Sunrise 

project) planning area is located on the Pomeroy Ranger District, Umatilla National Forest. It is 

approximately 33,150 acres, approximately 32,000 acres are identified as National Forest System 

Lands and is situated in Asotin and Garfield Counties, Washington (Appendix A). The Sunrise 

project is within portions of: 

• Township 7 South, Range. 43 East, Section 6; 

• Township 8 North, R. 42 East, Sections 1-5, 8-16, 22-26, and 36; 

• Township 8 North, R. 43 East, Section 2-11, 15-22, and 28-33; 

• Township 9 North, R. 42 East, Sections 25 and 33-36; 

• Township 9 North, R. 43 East, Sections 8, 9, and 13-36; and

• Township 9 North, R. 44 East, Sections 18, 19, 30, and 31. 

It is within the Lick Creek and North Fork Asotin Creek subwatersheds of the George Creek –

Asotin Creek Watershed. Elevation in the project area ranges from 2400 to 6200 feet.

The Sunrise project area is bordered on the east by the Asotin Creek Wildlife Area, which is 

owned and managed by the Washington Department of Fish and Wildlife. It contains the entire 

Asotin Creek Inventoried Roadless Area (IRA) and is adjacent to Wenatchee and Tucannon 

IRAs. Ecosystems in and around Sunrise project planning area are diverse, ranging from shrub/ 

grasslands to subalpine coniferous forests. There are numerous camping areas, hiking trails, 

scenic vistas, big game hunting opportunities, huckleberry picking opportunities, and forest 

products. There are two inholdings owned by the state of Washington within the project 

boundary, totaling 1,130 acres.

Existing Conditions

An analysis of existing vegetation compared to historical range of variability (HRV) has 

indicated that additional management is warranted for upland forests of the Sunrise project area. 

HRV recognizes that ecosystems are complex and experience a range of conditions across which 

processes are resilient and self-sustaining. When allowed to move beyond the limits of the range 

of variability, ecosystems inevitably move into a state of disequilibrium or disorganization (Egan 

and Howell 2001, Holling and Meffe 1996, Kaufmann et al. 1994). HRV uses a range of 

reference conditions pertaining to the previous several centuries prior to the pre-settlement era –

a timeframe defined as the mid-1800s for the northern Blue Mountains.

Forest stand composition, density, and structure in the project planning area has deviated from 

their respective HRV due to fire suppression and other past forest management practices. A

majority of current forest stands originated as a result of fire disturbances occurring up to the 

early 20th century, and have not experienced fire since then. Late seral tree species, multi-storied 
Sunrise Vegetation and Fuels Project

ii Umatilla National Forest

structural stages, and high-density stands have become dominant after long periods without 

disturbance and are more susceptible to disturbance-caused mortality than early seral species. 

Analysis of forest vegetation conditions in the analysis area and comparison to desired ranges is 

summarized in Chapter 3 of this document, and revealed the following issues, concerns and/or 

opportunities:

Dry Upland Forests

Douglas-fir cover types dominate too much of the dry forested landscape and there is too little 

ponderosa pine cover types compared to the historic range of variability (HRV). Within this 

biophysical setting, there are too many areas with high forest density, and too few areas with low 

and moderate density. Understory reinitiation and old forest multi-strata (OFMS) structural 

stages dominate too much of the dry forested landscape and there is too little stand initiation,

stem exclusion, and old forest single stratum (OFSS) structural stages. 

For the dry upland forest biophysical environment, there is too little of the OFSS late-old 

structural stage and too much of the OFMS stage. Since one of the late-old structural stages is 

below HRV, scenario A of the wildlife screen (one of six Eastside Screens, an amendment to the 

Umatilla Forest Plan) will apply for this biophysical environment (see Appendix C for 

Consistency with Eastside Screens).

Moist Upland Forests

Douglas-fir and subalpine fir/spruce cover types dominate too much of the moist forested 

landscape and there is too little broadleaved trees, western larch, and lodgepole pine, cover 

types. Within this biophysical setting, there are too many areas with high forest density, and too 

few areas with low and moderate density. Old forest multi-strata structural stage dominates too 

much of the moist forested landscape and there is too little stand initiation, stem exclusion, and 

old forest single stratum structural stages.

For the moist upland forest biophysical environment, there is too little of the OFSS late-old 

structural stage and too much of the OFMS stage. Since one of the late-old structural stages is 

below HRV, scenario A of the wildlife screen (one of six Eastside Screens, an amendment to the 

Umatilla Forest Plan) will apply for this biophysical environment. (See Appendix C for 

Consistency with Eastside Screens) 

Cold Upland Forest

Spruce/subalpine fir and Douglas-fir cover types dominate too much of the cold upland forested 

landscape and there is too little of the lodgepole pine cover type. Within this biophysical setting, 

there are too many areas with high forest density, and too few areas with low and moderate 

density. Understory reinitiation and old forest multi-strata structural stage dominates too much of 

the cold forested landscape and there is too little stem exclusion and old forest single-stratum 

structural stages.

For the cold upland forest biophysical environment, there is too little of the OFSS late-old 

structural stage and too much of the OFMS stage. Since one of the late-old structural stages is 

below HRV, scenario A of the wildlife screen (one of six Eastside Screens, an amendment to the 

Umatilla Forest Plan) will apply for this biophysical environment (see Appendix C for 

Consistency with Eastside Screens.)
Final Environmental Impact Statement

Pomeroy Ranger District iii

Fire Regime Condition Class (FRCC)

FRCC is a metric which describes the departure from historical fire regimes in terms of fire 

return intervals and vegetative change from historical composition and density. The FRCC in 

many stands within the project area have been modified due mainly to past harvest history and 

fire suppression (Fuels Resource Report page 9). In many areas, the surface and ladder fuels, 

which historically would have been consumed during periodic wildfires, have increased above 

historical levels. Today, fires in dry and moist forests would exhibit moderate to severe effects 

characterized by high fire severity and intensity on landscapes that historically had low to mixed 

severity. Without treatment, the project area would continue to transition from a low or 

moderately altered fire regime (Condition Classes 1 and 2), to a significantly altered fire regime 

(Class 3), where the risk of losing ecosystem components would be substantially higher. Surface 

fuel loads would continue to build and ladder fuels would continue to increase as shade-tolerant

tree species continue to seed in increasing tree densities and canopy layering. These small trees 

would serve as ladder fuels that can carry fire from the forest floor to the tree canopy, increasing 

the likelihood of high severity, stand-replacement wildfires. Wildfires occurring in the project 

area today would not function as a natural disturbance process within their historical range

pertaining to fire size, frequency, intensity, severity, or landscape patterns.

Purpose and Need

The Pomeroy District Ranger has determined that there is a need for action based upon 

comparisons of the current vegetative and fuel trends in the project planning area and the desired 

future conditions identified in the Umatilla National Forest Land and Resource Management 

Plan (Forest Plan, pp 4-3 to 4-14) and recommendations made in the Asotin Watershed

Assessment (pp VI-1 to VI-3.) The Asotin Watershed Assessment recommended the use of 

timber harvest to thin dense stands, reduce the extent of Douglas-fir and/or grand fir, retain pine 

and larch to convert to early seral species stands, and allow fire prescriptions to reduce fuels. 

Therefore, the purpose of this action is to improve forest heath, vigor, and resilience to fire, 

insect, and disease. This action is needed to move towards the historical range of variability. 

Currently, forests are outside their historical pre-fire suppression conditions for species 

composition, structural diversity, stocking densities, and fuel loadings. In addition, given the 

Forest Plan management area allocations for big game and wildlife habitat goals (C3, C3A, and 

C4), District Ranger determined there is a need to continue to provide and manage wildlife 

habitat and its components (cover and forage) in the Sunrise project planning area. 

The response to the purpose and need for this project is identified as follows:

Vegetation – There is a need to move forest vegetative structure, composition, and density 

toward their HRV. The project would move successional and structural conditions of forests 

toward desired ranges by converting areas in the OFMS to OFSS, converting areas in the stem 

exclusion and/or understory reinitiation stages to stand initiation stages and by moving other 

stands toward old forest as appropriate for the disturbance regime and biophysical characteristics 

of the site. The Sunrise project would also reduce forest density; in some locations reducing 

inter-tree competition and improving residual tree health. Treatments within the project would 

also modify composition to increase the abundance of early-seral species such as ponderosa pine 

and western larch.

Fuels – There is a need to manage forest stands in Condition Classes 2 and 3 to begin to restore 

vegetation characteristics and fire return intervals characteristic of historical fire regimes and 

desired fire regimes. Fuels treatments would be used to lower stand densities; reduce surface, 
Sunrise Vegetation and Fuels Project

iv Umatilla National Forest

ladder and canopy fuels, increase the relative abundance of fire-tolerant tree species, while 

improving suppression capabilities on forest land. Landscape burning within the project area 

would be used to reintroduce and/or perpetuate fire within this fire-dependent ecosystem by 

utilizing a variety of burning strategies over about 60 percent of the area. In addition to creating 

vegetative conditions more consistent with desired fire regimes, it would also increase the 

probability that future fires burn in a manner more consistent with the fire regime associated 

with the biophysical environment of the site. 

Timber Production – There is a need to provide sawlogs and wood fiber for utilization by 

regional and local economies as stipulated in the Forest Plan. Silviculture treatments used to alter 

tree densities, structural diversity, species composition, and ladder and canopy fuels would 

generate wood fiber through timber harvest. Personal and commercial use firewood would 

continue within the project area.

Wildlife Habitat – There is a need to reduce fuels and stand densities in order to maintain 

resilient forest wildlife habitat. 

Alternative A (No Action)

Purpose and Design

• No new management activities as proposed would occur.

• Current biological and physical processes would be allowed to continue along their present 

path along with associated risks and benefits and serve as a baseline for comparison with other 

alternatives. 

• Responds to the requirement to consider a No Action Alternative (40 CFR §1502.14 (d)). 

Description

Under the No Action alternative, no activities identified in either action alternative would occur 

and previously approved ongoing activities such as domestic cattle grazing, wildfire suppression 

and/or containment, firewood cutting, recreation, and road maintenance (including danger tree

removal) would continue. This alternative would allow timber stands, identified at this time as 

needing treatment, to progress through growth and successional processes at their own rate and 

in the absence of ecological disturbances. Natural fuels would not be treated to reduce the risk of 

undesired wildfire intensity or allow for a safer environment for fire-fighting personnel during 

fire suppression. No tree cutting, tree planting, fuels treatments for natural or activity fuels, 

landscape prescribed fire, or road decommissioning would be implemented.

Alternative B (Proposed Action)

Purpose and Design

Alternative B responds to the project purpose and need to modify composition, structure, and 

density through a combination of activities including tree cutting, mastication, tree planting, and 

pile, jackpot and landscape broadcast burning. Activities would occur over a 5-10 year period 

beginning in approximately 2019. No trees equal to or greater than 21 inches in diameter at 

breast height (DBH) would be cut, under this action alternative and no cutting would occur 

within PACFISH buffers (see tiering references in chapter 1.7).
Final Environmental Impact Statement

Pomeroy Ranger District v

Alternative B is most similar to the alternative proposed during scoping, except that acreages 

have been adjusted to reflect additional field reviews and updated GIS information. Treatments 

in Alternative B respond to elements identified in the Purpose and Need (Chapter 1) and are 

designed to accomplish the following objectives, while complying with all applicable laws, 

rules, and regulations:

• Modify dry, moist, and cold upland forests to move species composition, tree density, and 

forest structure compatible with the historical range of variability. 

• Reduce fuel loading (surface, ladder, and canopy fuels) to a level where periodic lowintensity surface fires can safely be reintroduced and where fuel loads would not 

contribute to uncharacteristic wildfire size, intensity and resource damage.

• Provide sawlogs and wood fiber products for utilization by local and regional industry.

• Continue to provide and manage wildlife habitat and its components (cover and forage).

• Reduce risk of personal injury by removing danger trees along haul routes used for timber 

sale activities. 

Alternative C

Purpose and Design

Alternative C was developed to more effectively respond to the key issue of wildlife habitat and 

the potential negative impacts the proposed action could have on elk distribution and habitat 

quality due to decreased cover and security areas, as well as old forest distribution, old forest 

connectivity, and snag habitat.

• Modify dry, moist, and cold upland forests to move species composition, tree density, and 

forest structure compatible with the historical range of variability. 

• Reduce fuel loading (surface, ladder, and canopy fuels) to a level where periodic lowintensity surface fires can safely be reintroduced and where fuel loads would not 

contribute to uncharacteristic wildfire size, intensity and resource damage.

• Continue to provide and mange wildlife habitat and components with emphasis on 

indicator species habitat such as Rocky Mountain elk. 

• Provide sawlogs and wood fiber products for utilization by local and regional industry.

• Reduce risk of personal injury by removing danger trees along haul routes used for timber 

sale activities. 

Major Conclusions

Silviculture

Alternative A, the no action alternative, would result in the existing stand densities, species 

composition, and structural stages remaining outside of the ranges of variability as determined 

for the Umatilla forest. Alternative B treatments would create stand conditions closer to the 

historical range of variability and with improved fire tolerance, meeting the purpose and need. 
Sunrise Vegetation and Fuels Project

vi Umatilla National Forest

Compared to the treatment acreages within Alternative C, Alternative B would treat more acres 

and move closer to the desired condition for silvicultural indicators. 

Alternative C treatments would also create stand conditions closer to the historical range of 

variability and with improved fire tolerance, but to a lesser degree than Alternative B.

Alternative A, the no action alternative, would result in the action area continuing to develop 

increasing fuel loads, increasing the chance of crown fires. High fire class conditions would also 

remain overrepresented when compared to the historical range of variation.

Alternative B would result in a decrease of fuel loads in treated areas. This would improve the 

representation of low-severity fire classes with the project area and reduce the likelihood of 

crown fires.

Alternative C would also result in a decrease of fuel loads in treated areas. Compared to 

Alternative B it treats few acres over all, and thus would decrease fuel loads somewhat less. This 

alternative would still help move the representation of low-severity fire classes more towards the 

historical range of variability and reduce the likelihood of crown fires in treated areas.

Wildlife

Alternative A, the no action alternative, would not result in any disturbance to management 

indicator, threatened, endangered or sensitive species. However, continued fuels build up and 

increasing stand densities would create conditions for a potential large scale habitat reduction for 

forest canopy dependent species. 

Alternative B would result in a considerable change of forest conditions in the area, affecting 

wildlife in various ways depending on the species. The distribution of elk cover would be less 

than desirable. A substantial amount of old forest would be affected by changing it from OFMS 

to OFSS. Creating more resilient forest through stand density reduction, fuels reduction and 

landscape burning would benefit many species in the long term.

Alternative C would change forest conditions but at a lesser magnitude than Alternative B. The 

balance of improving habitat for some species (e.g. increases in dry OFSS) and decreasing the 

amount of habitat for other species (e.g. marten, elk cover) is more in balance, while still 

reducing fuels to a more natural level. 

Fisheries

Alternative A does not include any actions within riparian corridors and therefore would have no 

impact on fish or other aquatic species.

Alternative B and C both contain required design criteria which should prevent treatment 

activities from impacting fish and other aquatic species.

Hydrology

Alternative A is not expected to impact hydrologic function.
Final Environmental Impact Statement

Pomeroy Ranger District vii

Alternative B and C may contribute to negative cumulative impacts on water yield in several 

watersheds if this action is undertaken simultaneously with other planned actions. However, this 

is unlikely as planned actions are expected to take place over a period of several years.

Soils

Alternative A is not expected to negatively impact soils; however no remediation of past 

activities will occur either.

Alternative B and C authorize activities that are expected to have short-term negative impacts on 

soils. However, decommissioning of temporary roads and project design criteria will minimize 

long-term impacts on soils.

Botany

Alternative A will have no effect on Spaulding’s catchfly (Federally listed as threatened), and 

there will be no impact to any sensitive plant species and associated habitats.

Alternatives B and C will have no effect on Spalding’s catchfly (Federally listed as threatened). 

They will have no impact to sensitive plant species that are affiliated with low to moderate 

elevation cliffs, rock outcrops, talus slopes, and riparian or wetland habitats. The effects for 

species that are affiliated with lithosols and grasslands, and upland coniferous forest 

communities are: may impact individuals or habitat, but would not likely contribute to a trend 

toward federal listing or cause a loss of viability to populations of sensitive plant species (MIIH) 

Invasive Plants

Alternative A is not expected to directly result in the spread of invasive plants, although there 

may be an indirect impact if a damaging fire were to occur from increasing fire risk.

Alternative B and C will result in increased risk of the spread of invasive plants, correlating with 

the amount of ground disturbance in each alternative. Project design criteria will help mitigate, 

but not completely eliminate this risk.

Visual Resources

Alternative A would have no impacts on visual resources.

Alternative B and C would have minor, short-term negative impacts as disturbance from 

activities occurred. Long-term, these alternatives would have positive impacts on the visual 

resources by helping blend the visual components of past treatments. 

IRAs

Alternative A would not be expected to impact Inventoried Roadless Areas.

Alternatives B and C would have some minor and short-term, negative impacts within areas 

undergoing timber treatment. 
Sunrise Vegetation and Fuels Project

viii Umatilla National Forest

Recreation

Alternative A would not be expected to impact recreation within the project area.

Alternatives B and C may both result in some short-term localized displacement of dispersed 

recreation users, depending on the timing of prescribed burns. No changes to the Recreation 

Opportunity Spectrum are expected.

Air Quality

Alternative A would not be expected to have a direct impact on air quality. Indirect impacts may 

occur if potentially larger wildfires result from the lack of action.

Alternatives B and C would contribute to short-term negative impacts on air quality during 

prescribed burning activities. 

Range

Alternative A would have no impacts on the quality of range within the action area.

Alternatives B and C would temporarily reduce forage after prescribed burning but have a 

positive effect as forb and grass cover rebound post treatment.

Economics

Alternative A would not produce timber products and therefore would not contribute to the 

economic stability of the nearby communities.

Alternative B would produce approximately 25 mbf and Alternative C would produce 

approximately 12 mbf and contribute to the economic stability of nearby communities by 

providing forest products.
Final Environmental Impact Statement

Pomeroy Ranger District ix

Changes Between the Draft and Final Environmental Impact 

Statements

The Draft Environmental Impact Statement was released for comment in May of 2018. From 9 

comment letters the Forest Service received from the public, 154 separate comments were 

identified (FEIS Appendix D: Responses to Comments on the Draft Environmental Impact 

Statement). As a result of those comments, and input from the Sunrise project interdisciplinary 

team, the changes described below were made to the Final Environmental Impact Statement. 

This list does not include the many minor edits and corrections made throughout the document.

Abstract: Updated with current information

Summary: Botany section has been updated with current information.

1.4 Purpose & Need: Edited for clarity in response to a public comment.

1.7 NEPA Document 

Preparation:

Blue Mountain Expedited Section 7 Consultation Process has been 

updated with current information.

1.9 Tribal and Public 

Involvement:

Updated with current information.

1.11 Scoping 

Comments:

The issue of carbon emissions / climate change was mistakenly 

included in the list of issues considered for detailed study on pg. 1-

28 of the DEIS and has been removed. (Note: it was correctly 

described two paragraphs later in the DEIS as an issue dismissed 

from detailed study.)

2.3 Alternatives 

Considered in Detail:

In response to a comment, information has been added to the 

description of intermediate and regeneration cutting: “These 

treatments would also have the effect of accelerating the pace 

and/or likelihood of old forest creation and development by 

promoting individual tree vigor and/or tree species expected to 

persist for several decades.”

2.4 Project Design 

Criteria:

BOT-5 and FUELS-3 have been added regarding minimizing 

impacts to mountain mahogany.

VEG-2 has been modified for clarity. 

3.6 Vegetation: Methodology: A discussion regarding incomplete or unavailable 

information has been added.

Environmental Consequences:

A statement has been added describing the relative effects of 

Alternatives B and C on susceptibility to future insect and disease 

disturbance. “Alternative B is expected to be greater than for 

Alternative C, because the overall extent of activities is greater for 

Alternative B, but the types of activities are the same for areas 

common to both alternatives.”
Sunrise Vegetation and Fuels Project

x Umatilla National Forest

Alternative C - Forest Structure: The following statement has been 

deleted: "Old Forest Single Stratum is expected to increase over 

time due to decreased densities within the stem exclusion and 

understory re-initiation stages."

Alternative B and C, Indirect Effects: The discussions on forest 

structure and forest density have been substantially revised for 

clarity.

Cumulative Effects, Alternatives B and C: This section has been 

substantially revised for clarity.

3.8 Wildlife Species and 

Habitat:

Environmental Consequences

Table 45. “Features of the Sunrise project contributing to the 

maintenance of primary cavity excavator habitat” has been added.

A paragraph has been added describing how proposed activities in 

combination with other past, ongoing, and potential future projects 

are not expected to cause cumulative effects to wolves.

3.12 Botany: Edited throughout for clarity, and updated with current information 

throughout.

3.15 IRA’s, PWA’s, 

Undeveloped Lands:

Affected Environment: In response to a comment, information has 

been added to explain why, in some cases, the PWA and IRA 

acreages differ. In some cases the PWA boundary extends beyond 

the IRA and in other cases it excludes portions of the IRA. 

Environmental Consequences: This section has been updated to 

provide additional detail on the effects of the proposed project on 

the two largest undeveloped lands polygons: #1 (1,303 acres) and 

#2 (846 acres).

3.18 Range: Methodology: In response to a comment, descriptions of the seven 

established monitoring transects within the Sunrise project have 

been added. 

Affected Environment: Information has been corrected regarding 

the scale of proposed fuels treatment in range allotments (the scale 

of treatment would be greater than was described in the draft EIS). 

Environmental Consequences: A statement that the proposed action 

calls for fuels treatment in the RHCA has been removed. Prescribed 

fire will not be ignited in RHCAs but will be allowed to back into 

RHCAs (Project Design Criteria, RHCA-3). When they occur, such 

backing fires are low intensity, and our experience tells us that they 

do not facilitate changes in livestock usage. 

Chapter 4: Reorganized for clarity.
Final Environmental Impact Statement

Pomeroy Ranger District xi

4.1 Public, 

Governmental and 

Tribal Involvemen:

Updated with current information

4.2 List of Preparers: Updated with current information

4.3 Distribution of the 

Final Environmental 

Impact Statement:

Updated with current information

References: References added to Wildlife Species & Habitat section in response 

to public comments.
Sunrise Vegetation and Fuels Project

xii Umatilla National Forest

Table of Contents

Preface...........................................................................................................................................................i

Summary......................................................................................................................................................................i

Changes Between the Draft and Final Environmental Impact Statements.................................................................ix

Chapter 1. Purpose & Need.......................................................................................................................17

1.1 Introduction......................................................................................................................................................... 17

1.2 Project Location.................................................................................................................................................. 17

1.3 Existing Condition .............................................................................................................................................. 18

1.4 Purpose & Need for Action................................................................................................................................. 20

1.5 Management Direction........................................................................................................................................ 21

1.6 Proposed Action.................................................................................................................................................. 24

1.7 NEPA Document Preparation ............................................................................................................................. 26

1.8 Treaty Rights....................................................................................................................................................... 29

1.9 Tribal and Public Involvement............................................................................................................................30

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

1.11 Scoping Comments........................................................................................................................................... 31

Chapter 2. Alternatives..............................................................................................................................33

2.1 Introduction......................................................................................................................................................... 33

2.2 Range of Alternatives.......................................................................................................................................... 33

2.3 Alternatives Considered in Detail .......................................................................................................................34

2.4 Project Design Criteria........................................................................................................................................ 43

2.5 Alternatives Considered but Eliminated from Detailed Analyses.......................................................................50

2.6 Monitoring Framework....................................................................................................................................... 50

Chapter 3. Environmental Consequences ...............................................................................................51

3.1 Introduction......................................................................................................................................................... 51

3.2 Effects and Impacts............................................................................................................................................. 51

3.3 (Reserved)........................................................................................................................................................... 51

3.4 General Analyses Methodology and Assumptions..............................................................................................51

3.5 Cumulative Effects.............................................................................................................................................. 53

3.6 Vegetation........................................................................................................................................................... 57

3.7 Fuels.................................................................................................................................................................... 69

3.8 Wildlife Species and Habitat............................................................................................................................... 87

3.9 Fisheries............................................................................................................................................................ 137

3.10 Hydrology ....................................................................................................................................................... 151

3.11 Soils................................................................................................................................................................ 171

3.12 Botany............................................................................................................................................................. 193

3.13 Invasive Plants................................................................................................................................................ 203

3.14 Visual Resources (scenery)............................................................................................................................. 211

3.15 Inventoried Roadless Areas (IRA), Potential Wilderness Areas (PWA) and other Undeveloped Lands ........221

3.16 Recreation ....................................................................................................................................................... 235

3.17 Air Quality ...................................................................................................................................................... 241

3.18 Range .............................................................................................................................................................. 247

3.19 Economic Analysis ......................................................................................................................................... 251

3.20 Climate Change............................................................................................................................................... 257

3.21 Findings of Consistency.................................................................................................................................. 259

3.22 Short-term Uses and Long-term Productivity .................................................................................................269

3.23 Unavoidable Adverse Effects..........................................................................................................................269

3.24 Irreversible and Irretrievable Commitments of Resources..............................................................................269

3.25 Other Required Disclosures ............................................................................................................................269

3.26 Cumulative Impacts ........................................................................................................................................ 272

Chapter 4. Public, Governmental and Tribal Involvement; List of Preparers; and Distribution of the 

Environmental Impact Statement ...........................................................................................................277

4.1 Public, Governmental and Tribal Involvement .................................................................................................277

4.2 List of Preparers................................................................................................................................................ 277

4.3 Distribution of the Environmental Impact Statement........................................................................................279
Final Environmental Impact Statement

Pomeroy Ranger District xiii

Glossary....................................................................................................................................................283

Abbreviations ......................................................................................................................................................... 283

Definition of Terms................................................................................................................................................ 285

Index..........................................................................................................................................................302

References................................................................................................................................................307

Botany .................................................................................................................................................................... 307

Fuels....................................................................................................................................................................... 308

Silviculture ............................................................................................................................................................. 311

Hydrology............................................................................................................................................................... 322

Wildlife................................................................................................................................................................... 326

Inventoried Roadless Areas (IRA), Potential Wilderness Areas (PWA), and Other Undeveloped Lands.............. 334

Economics.............................................................................................................................................................. 335

Air Quality.............................................................................................................................................................. 335

Fisheries ................................................................................................................................................................. 335

Invasive Plants........................................................................................................................................................ 337

Soils........................................................................................................................................................................ 339

Visual Resources (scenery)..................................................................................................................................... 341

Appendix A: Project Maps.......................................................................................................................342

Appendix B: Cutting Unit Activities for Action Alternatives.................................................................349

Appendix C: Consistency with Eastside Screens .................................................................................355

Appendix D: Responses to Comments on the Draft Environmental Impact Statement.....................358

List of Figures

Figure 3-1. Fire Regime Condition class for the Sunrise project area. Note, WADNR and WDFW land was not 

analyzed for condition class................................................................................................................................. 73

Figure 3-2. Fuel models currently within the Sunrise project area. ............................................................................... 76

Figure 3-3. Potential crown fire hazard for the Sunrise project area. ............................................................................ 79

Figure 3-4. Distribution of percent cover of down wood > 5 inches diameter in moist upland forest in the snag analysis 

area (41,220 acres)............................................................................................................................................... 98

Figure 3-5. Distribution of percent cover of down wood >20 inches diameter in moist upland forest in the snag 

analysis area (41,220 acres). ................................................................................................................................ 98

Figure 3-6. Elk cover in MA-C4 after implementing Alternative B. ........................................................................... 115

Figure 3-7. Elk cover in MA-C4 after implementing Alternative C. ........................................................................... 116

Figure 3-8. Steelhead distribution within and adjacent to the Sunrise Project............................................................. 140

Figure 3-9. Designated Steelhead Critical Habitat within and adjacent to the Sunrise Project.................................... 141

Figure 3-10. Historical Chinook salmon distribution within and adjacent to the Sunrise Project................................ 142

Figure 3-11. Subwatersheds within the Sunrise project area. ...................................................................................... 153

Figure 3-12: Seven Year Implementation Schedule ECA ........................................................................................... 168

Figure 3-13: Alternative C – Seven Year Implementation Schedule ECA.................................................................. 169

List of Tables

Table 1. Geographic extent for management areas applicable to the Sunrise project.................................................... 22

Table 2. Minimum Tree Stocking Standards................................................................................................................. 37

Table 3. Activity acres, miles, or board-feet for each management alternative for the Sunrise project. Alternative A is 

the No-Action Alternative.................................................................................................................................... 42

Table 4. Project Design Criteria by Resource Objective ............................................................................................... 43

Table 5. Past Vegetation Management Activities by Decade within the Sunrise project Area...................................... 54

Table 6. Tree species cover type extent and distribution for forest Potential Vegetation Groups (PVGs) within the 

Sunrise Project Vegetation Analysis Area. Values listed in bold font currently exceed desired ranges; items in 

italics are currently below desired ranges. ........................................................................................................... 59

Table 7. Forest structural stage extent and distribution for forest Potential Vegetation Groups (PVGs) within the 

Sunrise project Vegetation Analysis Area. Values listed in bold font currently exceed desired ranges; items in 

italics are currently fall below desired ranges...................................................................................................... 60

Table 8 Forest density class extent and distribution for forest Potential Vegetation Groups (PVG) within Sunrise 

Vegetation Analysis Area. Values listed in bold currently exceed desired ranges; items in italics are currently 

below desired ranges............................................................................................................................................ 61

Table 9. Direct effects of project implementation in forest structure stages. Comparison of current existing conditions, 

post treatment conditions for Alt. B and Alt. C, and the changes from existing conditions in Alt. B and Alt. C. 

Values listed in bold currently exceed desired ranges, items listed in italics are currently below desired ranges.62
Sunrise Vegetation and Fuels Project

xiv Umatilla National Forest

Table 10. Direct effects of implementing the activities described under Alternatives B and C on forest density classes.

............................................................................................................................................................................. 63

Table 11. Snag and down wood retention per acre by forest vegetation community type .............................................67

Table 12. Characteristics of common Oregon and Washington fire regimes present within Sunrise project area. ........70

Table 13 Fire Regime Condition Class Descriptions.....................................................................................................70

Table 14. Fire regimes within Sunrise project area by acres..........................................................................................72

Table 15. Acres by condition class within the Sunrise project area. ..............................................................................73

Table 16. Past wildfire acres within the Sunrise project area.1 ......................................................................................74

Table 17. Most common fuel models (Anderson 1982) found in the Sunrise project area. ...........................................75

Table 18. Acres of each fuel model present within the Sunrise project area..................................................................77

Table 19. Crown fire hazard by Fire Regime within the Sunrise project area................................................................78

Table 20. Existing fire regime condition class in the Sunrise project area.....................................................................81

Table 21. Fire regime condition class post treatment for Alternative B.........................................................................81

Table 22. Change in distribution of crown fire hazard in fire regimes 1 and 3..............................................................82

Table 23. Fire regime condition class post treatment for Alternative C.........................................................................83

Table 24. Change in distribution of crown fire potential in fire regimes 1 and 3...........................................................83

Table 25. Fire regime condition class post treatment for Asotin Creek prescribed fire project. ....................................85

Table 26. Change in distribution of crown fire potential in dry upland forests as a result of Asotin Creek prescribed 

fire........................................................................................................................................................................ 85

Table 27. Resource indicators and measures for assessing effects.................................................................................88

Table 28. Wildlife management indicator species for the Umatilla National Forest......................................................89

Table 29. Percent tree cover, HEI value, and open road density by management area. .................................................91

Table 30. Old forest structure range of variation and current conditions.......................................................................93

Table 31. Old forest cover types (acres). .......................................................................................................................94

Table 32. Recent fire events on Pomeroy Ranger District. ............................................................................................97

Table 33. Tolerance levels for woodpeckers occurring in Eastside Mixed Conifer/Blue Mountains habitat type 

(DecAID Table EMC_S/L.sp-22) Snag density/acre for 30%, 50%, 80% tolerance levels.1 ...............................99

Table 34. USFWS Birds of Conservation Concern for Bird Conservation Region 10 that may be present and 

potentially affected by the Sunrise project. ........................................................................................................102

Table 35. Threatened, endangered and sensitive wildlife species for the Umatilla National Forest, Washington. ......103

Table 36. Sensitive invertebrate species for the Umatilla National Forest, Washington..............................................109

Table 37. Sunrise project potential sensitive invertebrates and their habitats. .............................................................110

Table 38. Cover reduction by alternative in MA-C3 (acres)........................................................................................114

Table 39. Cover reduction by alternative in MA-C4 (acres)........................................................................................115

Table 40. Cover reduction by alternative in MA-C8 (acres)........................................................................................116

Table 41. Comparison of effects to elk habitat by alternative......................................................................................117

Table 42. Tree cutting within old forest (acres). ..........................................................................................................119

Table 43. Changes to old forest structure by alternative (acres) ..................................................................................120

Table 44. Vegetation treatments in marten habitat (acres)...........................................................................................121

Table 45. Features of the Sunrise project contributing to the maintenance of primary cavity excavator habitat. ......123

Table 46. Effects to birds of conservation concern in the Sunrise project area............................................................126

Table 47. Summary of effect to sensitive wildlife and invertebrate species. ...............................................................134

Table 48. Management of Watershed affected by the Sunrise Project.........................................................................139

Table 49. Project Area acreage within the watershed ..................................................................................................139

Table 50. Regional Forester's List of Sensitive Aquatic Invertebrate and Vertebrate Species Present or suspected on 

the Umatilla NF.................................................................................................................................................. 144

Table 51. Subwatersheds within the Sunrise project area. ...........................................................................................153

Table 52. Sunrise Riverine Wetlands Summary of Total Acres (Acres of National Forest Lands within Project Area)

........................................................................................................................................................................... 155

Table 53. Water Quality Standards for Temperature and Sediment.............................................................................155

Table 54. Road Density and Stream Crossings on NFS Lands at the Subwatershed Scale ..........................................156

Table 55. RHCA Road Interactions within the project area.........................................................................................156

Table 56. Equivalent Clearcut Area Modeling Summary ............................................................................................165

Table 57. Forest Plan Standards for Effective Ground Cover......................................................................................176

Table 58. Resource Indicators and Measures for the existing condition......................................................................177

Table 59. Resource Indicators and Measures for Alternative B – Lick Creek .............................................................185

Table 60. Resource Indicators and Measures for Alternative B – NF Asotin Creek....................................................185

Table 61: Resource Indicators and Measures for Alternative C – NF Asotin Creek....................................................189

Table 62. Summary of Cumulative Detrimental Soil Condition (DSC) by Alternative ...............................................190

Table 63. Extent of higher-priority invasive plants known to occur within approximately 1 mile of the Sunrise 

planning area. Lower priority species are assumed to be widely distributed across grassy sites within the project 

area..................................................................................................................................................................... 204
Final Environmental Impact Statement

Pomeroy Ranger District xv

Table 64. Low, medium, and high levels of risk to noxious weed invasion for Alternatives B and C (acres)............. 205

Table 65. General effects of selected vegetation species in response to fire disturbance. ........................................... 206

Table 66. Visual Quality Objectives and definitions................................................................................................... 213

Table 67. Seen foreground age classes with Partial Retention Visual Quality Objective ............................................ 214

Table 68. Visible Acres by Visual Quality Objective.................................................................................................. 214

Table 69. Created Openings........................................................................................................................................ 215

Table 70. Created Openings in Even and Uneven-aged Systems ................................................................................ 215

Table 71. Silvicultural Prescription Acres by Visual Quality Objective (Alt. B) ........................................................ 217

Table 72. Percentage of Acres Treated by Visual Quality Objective (Alt. B) ............................................................. 217

Table 73. Silvicultural Prescription Acres by Visual Quality Objective (Alt. C) ........................................................ 217

Table 74. Percentage of Acres Treated by Visual Quality Objective (Alt. C) ............................................................. 218

Table 75. Visible Foreground Age Class in Partial Retention and Trends by Alternative........................................... 218

Table 76. Undeveloped Lands; Map by Map Summary .............................................................................................. 223

Table 77. Summary of wilderness, PWAs, IRAs, undeveloped and developed landscape.......................................... 224

Table 78. Other undeveloped lands within the Sunrise project area by MAs. ............................................................. 224

Table 79. Potential Wilderness in the Sunrise Project Area by Alternative................................................................. 228

Table 80. Summary of undeveloped lands in the Sunrise project area by alternative.................................................. 230

Table 81. Acres of proposed treatment in each polygon for each alternative .............................................................. 230

Table 82. Acres by ROS Classification ....................................................................................................................... 237

Table 83. Estimated Smoke Emissions (lbs. /acre)...................................................................................................... 242

Table 84. Estimated PM2.5 and CO emissions by burn type in the Sunrise Planning area (acres).............................. 242

Table 85. Alternative B Harvest Cost for Commercial Timber Treatments ................................................................ 253

Table 86. Alternative B Gross Revenue of Timber Resources.................................................................................... 253

Table 87. Alternative B Stumpage Value .................................................................................................................... 254

Table 88. Alternative B Additional Activity Costs...................................................................................................... 254

Table 89. Harvest Cost for Commercial Timber Treatments....................................................................................... 255

Table 90. Alternative C Gross Revenue of Timber Resources.................................................................................... 255

Table 91. Alternative C Stumpage Value .................................................................................................................... 255

Table 92. Alternative C Additional Activity Costs...................................................................................................... 256

Table 93. Forest Plan goals and management area direction relative fire and fuels management. .............................. 260

Table 94. Fuels treatments by management area. ........................................................................................................ 261

Final Environmental Impact Statement

Pomeroy Ranger District 17

Chapter 1. Purpose & Need 

1.1 Introduction

The Forest Service has prepared this environmental impact statement in compliance with the 

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

regulations. This environmental impact statement discloses the direct, indirect, and cumulative

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

is organized into four chapters and relevant appendices:

• Purpose of and Need for Action (Chapter 1): briefly describes the proposed action, the need 

for that action, and other purposes to be achieved by the proposal. This section also details 

how the Forest Service informed the public of the proposed action and how the public 

responded.

• Alternatives (Chapter 2): provides a detailed description of the agency’s proposed action as 

well as two alternative actions that were developed in response to comments raised by the 

public during scoping. It describes the key management direction used in developing the 

project which comes from the Forest Plan of the Umatilla National Forest. The end of the 

chapter includes summary tables comparing the proposed action and alternatives with respect 

to the activities proposed for each alternative, how each addresses the purpose and need of the 

project, how each addresses relevant issues, and their environmental effects.

• Affected Environment and Environmental Consequences (Chapter 3): describes the 

affected environment and environmental effects of the proposed action and alternatives on 

forest resources and the overall response from the Forest to responsible opposing views.

• Consultation and Coordination (Chapter 4): provides a list of preparers and agencies 

consulted during the development of the EIS.

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

presented in the EIS. Maps of the alternatives and other maps for this document are located in 

Appendix A. Planning unit treatments by alternative are listed in Appendix B. Additional 

appendices are included as needed to provide support to specialist reports.

Additional documentation, including maps and more detailed analyses of project area resources, 

may be viewed by appointment at the Pomeroy District Range, 71 W. Main Street, Pomeroy, 

Washington 99347 or on the project website: https://www.fs.usda.gov/project/?project=45689.

1.2 Project Location

The Sunrise Vegetation and Fuels Management Project (henceforth referred to as the Sunrise 

project) planning area is located on the Pomeroy Ranger District, Umatilla National Forest. It is 

approximately 33,150 acres, approximately 32,000 acres are identified as National Forest System 

Lands and is situated in Asotin and Garfield Counties, Washington (Appendix A). The Sunrise 

project is within portions of: 

• Township 7 South, Range. 43 East, Section 6; 

• Township 8 North, R. 42 East, Sections 1-5, 8-16, 22-26, and 36; 

• Township 8 North, R. 43 East, Section 2-11, 15-22, and 28-33; 

• Township 9 North, R. 42 East, Sections 25 and 33-36; 

• Township 9 North, R. 43 East, Sections 8, 9, and 13-36; and
Sunrise Vegetation and Fuels Project

18 Umatilla National Forest

• Township 9 North, R. 44 East, Sections 18, 19, 30, and 31. 

It is within the Lick Creek and North Fork Asotin Creek subwatersheds of the George Creek –

Asotin Creek Watershed. Elevation in the project area ranges from 2400 to 6200 feet.

The Sunrise project area is bordered on the east by the Asotin Creek Wildlife Area, which is 

owned and managed by the Washington Department of Fish and Wildlife. It contains the entire 

Asotin Creek Inventoried Roadless Area (IRA) and is adjacent to Wenatchee and Tucannon 

IRAs. Ecosystems in and around Sunrise project planning area are diverse, ranging from shrub/ 

grasslands to subalpine coniferous forests. There are numerous camping areas, hiking trails, 

scenic vistas, big game hunting opportunities, huckleberry picking opportunities, and forest 

products. There are two inholdings owned by the state of Washington within the project 

boundary, totaling 1,130 acres.

1.3 Existing Condition

Forest Composition, Structure, and Density

An analysis of existing and historical vegetation (see Vegetation Report) has indicated that 

additional management is warranted for upland forests of the Sunrise project area. The historical 

range of variability (HRV) recognizes that ecosystems are complex and they experience a range 

of conditions across which processes are resilient and self-sustaining. When allowed to move 

beyond the limits of the range of variability, ecosystems inevitably move into a state of 

disequilibrium or disorganization (Egan and Howell 2001, Holling and Meffe 1996, Kaufmann 

et al. 1994). HRV uses a range of reference conditions pertaining to the previous several 

centuries prior to the pre-settlement era – a timeframe defined as the mid-1800s for the northern 

Blue Mountains.

Forest stand composition, density, and structure in the project planning area have been altered 

from historical ranges of variation due to fire suppression and other past forest management 

practices. A majority of current forest stands originated as a result of fire disturbances occurring 

up to the early 20th century, and have not experienced fire since then. Late seral tree species, 

multi-storied structural stages, and high-density stands have become dominant after long periods 

without disturbance and are more susceptible to disturbance-caused mortality than early seral 

species. Analysis of forest vegetation conditions in the analysis area and comparison to desired 

ranges is summarized in Chapter 3 of this document, and revealed the following issues, concerns 

and/or opportunities:

Dry Upland Forests

• Douglas-fir cover types dominate too much of the dry forested landscape and there is too little 

ponderosa pine cover types compared to the historic range of variability (HRV). Within this 

biophysical setting, there are too many areas with high forest density, and too few areas with 

low and moderate density. Understory reinitiation and old forest multi-strata (OFMS) 

structural stages dominate too much of the dry forested landscape and there is too little stand 

initiation, stem exclusion, and old forest single stratum (OFSS) structural stages. 

• For the dry upland forest biophysical environment, there is too little of the OFSS late-old 

structural stage and too much of the OFMS stage. Since one of the late-old structural stages is 

below HRV, scenario A of the wildlife screen (one of six Eastside Screens, an amendment to 

the Umatilla Forest Plan) will apply for this biophysical environment. (See Appendix C for 

Consistency with Eastside Screens.)
Final Environmental Impact Statement

Pomeroy Ranger District 19

Moist Upland Forests

• Douglas-fir and subalpine fir/spruce cover types dominate too much of the moist forested 

landscape and there is too little broadleaved trees, western larch, and lodgepole pine, cover 

types. Within this biophysical setting, there are too many areas with high forest density, and 

too few areas with low and moderate density. Old forest multi-strata structural stage dominates 

too much of the moist forested landscape and there is too little stand initiation, stem exclusion, 

and old forest single stratum structural stages.

• For the moist upland forest biophysical environment, there is too little of the OFSS late-old 

structural stage and too much of the OFMS stage. Since one of the late-old structural stages is 

below HRV, scenario A of the wildlife screen (one of six Eastside Screens, an amendment to 

the Umatilla Forest Plan) will apply for this biophysical environment (see Appendix C for 

Consistency with Eastside Screens)

• Spruce/subalpine fir and Douglas-fir cover types dominate too much of the cold upland 

forested landscape and there is too little of the lodgepole pine cover type. Within this 

biophysical setting, there are too many areas with high forest density, and too few areas with 

low and moderate density. Understory reinitiation and old forest multi-strata structural stage 

dominates too much of the cold forested landscape and there is too little stem exclusion and 

old forest single-stratum structural stages.

• For the cold upland forest biophysical environment, there is too little of the OFSS late-old 

structural stage and too much of the OFMS stage. Since one of the late-old structural stages is 

below HRV, scenario A of the wildlife screen (one of six Eastside Screens, an amendment to 

the Umatilla Forest Plan) will apply for this biophysical environment (see Appendix C for 

Consistency with Eastside Screens.)

Fire Regime Condition Class

Fire Regime Condition Class1 (FRCC), is a metric which describes the departure from historical 

fire regimes in terms of fire return intervals and vegetative change from historical composition 

and density. The FRCC in many stands within the project area has been modified primarily by 

past harvest history and fire suppression (Fuels Resource Report page 9). In many areas, the 

surface and ladder fuels, which historically would have been consumed during periodic 

wildfires, have increased above historical levels. Today, fires in dry and moist forests would 

exhibit moderate to severe effects characterized by high fire severity and intensity on landscapes 

that historically had low to mixed severity. Without treatment, the project area would continue to 

transition from a low or moderately altered fire regime2 (Condition Classes 1 and 2), to a 

significantly altered fire regime (Class 3), where the risk of losing ecosystem components would 

be substantially higher. Surface fuel loads would continue to build and ladder fuels would 

continue to increase as shade-tolerant tree species continue to seed in increasing tree densities 

and canopy layering. These small trees would serve as ladder fuels that can carry fire from the 

forest floor to the tree canopy, increasing the likelihood of high severity, stand-replacement 

wildfires. Wildfires occurring in the project area today would not function as a natural 

 

1 Condition Class Describes the departure from historic fire regimes in terms of fire return interval and vegetative 

changes from historical composition and density (Hann and Bunnell, 2001). Class 1 – within historical range; Class 2 

– moderately altered from historical range; and Class 3 – significantly altered from historical range. 2 Fire regime: Class 1 –0 to 35-year frequency and of low severity (most commonly associated with surface fires) to 

mixed severity (in which less than 75 percent of the dominant overstory vegetation is replaced). Class 3 –35 to 200-

year frequency and of mixed severity. Less than 75% of the dominate overstory vegetation is replaced.
Sunrise Vegetation and Fuels Project

20 Umatilla National Forest

disturbance process within their historical range pertaining to fire size, frequency, intensity, 

severity, or landscape patterns.

1.4 Purpose & Need for Action

The need for the Sunrise project arises from an interdisciplinary assessment of the differences 

between the existing conditions described above and the desired future conditions identified in 

this document as well as the Umatilla National Forest Land and Resource Management Plan 

(Forest Plan, pp.4-3 to 4-14). The purpose of this project is to modify vegetation and fuels by 

moving vegetation composition, structure, density, and fuels closer to historic conditions which 

existed prior to fire suppression. Meeting Forest Plan objectives by providing sawlogs and wood 

fiber products for utilization by regional and local industries is also considered a need for this 

project. Furthermore, because the majority of acres (about 19,200 acres) in the project planning 

area are Forest Plan management area allocations with big game and wildlife habitat goals (C3, 

C3A, and C4) there is a need to continue to provide and manage wildlife habitat and its 

components (cover and forage) in the Sunrise project planning area. The need for this project is 

identified in further detail as follows:

Vegetation – There is a need to move forest structure, species composition, and stand 

density toward their HRV. By moving these forest attributes more toward HRV, ecosystem

processes, such as response to wildfire, insects and disease, are more resilient and selfsustaining (Egan and Howell 2001, Holling and Meffe 1996, Kaufmann et al. 1994).The 

project would move successional and structural conditions of forests toward desired 

ranges by converting areas in the Old Forest Multi-Strata structural stage to the Old Forest 

Single Stratum stage, converting areas in the Stem Exclusion and/or Understory

Reinitiation stages to Stand Initiation stages and by moving other stands toward Old 

Forest as appropriate for the disturbance regime and biophysical characteristics of the site.

Additionally, there is a need to reduce forest density in some locations as reducing intertree competition will improve residual tree health. Treatments within the project would 

also modify species composition, increasing the abundance of early seral species such as 

ponderosa pine and western larch.

Fuels – There is a need to modify forest stands in Condition Classes 2 and 3 to begin to 

restore vegetation characteristics and fire return intervals characteristic of historical fire 

regimes and desired fire regimes. Fuels treatments would be used to lower stand densities; 

reduce surface, ladder and canopy fuels; increase the relative abundance of fire-tolerant

tree species, while improving suppression capabilities on forest land. Landscape burning 

within the project area would be used to reintroduce and perpetuate fire within this firedependent ecosystem by utilizing a variety of burning strategies over about 60 percent of 

the area. In addition to creating near-term conditions, more consistent with desired fire 

regimes, it would also increase the probability that future fires burn in a manner more 

consistent with the fire regime associated with the biophysical environment of the site. 

Timber Production – There is a need to provide sawlogs and wood fiber to augment the 

regional and local economies due to the dependency on timber production from with the 

Forest. Silvicultural treatments used to alter tree densities, structural diversity, species 

composition, and ladder and canopy fuels would generate wood fiber through timber 

harvest. Personal and commercial use firewood would continue within the project area. 
Final Environmental Impact Statement

Pomeroy Ranger District 21

Wildlife Habitat – There is a need to continue to provide and manage, over time, for 

wildlife habitat, as it is required to meet Forest Plan goals and management area standards 

and guidelines 

1.5 Management Direction

Umatilla Forest Plan

The Umatilla National Forest Land and Resource Management Plan, as amended (Forest Plan, 

1990) includes multiple-use forest-wide goals and objectives for management of the National 

Forest. Forest-wide goals apply to all areas of the forest, whereas allocated management area

(MA) goals are applied to specific management areas. Below is a listing of Forest Plan forestwide goals, desired conditions, and relationship of those items to the project purpose and need.

Forest Plan forest-wide goals (FP pp. 4-1 to 4-3) that are most applicable to the purpose and need 

identified for this project are as follows:

• Forest Plan Goal 1 – Provide land and resource management that achieves a more healthy 

and productive forest and assists in supplying lands, resources, uses, and values which meet 

local, regional, and national social and economic needs.

• Forest Plan Goal 9 – Provide and manage big game (elk and deer) habitat and its components 

(cover, forage, and roads) to assist in meeting states wildlife agency population management 

objectives.

• Forest Plan Goal 13 – Provide for diversity of plant and animal communities and species 

consistent with overall multiple-use objectives for the Forest. Maintain or enhance ecosystem

functions to provide for the long-term integrity (stability) and productivity of biological 

communities.

• Forest Plan Goal 15 – Provide for production and sustained yield of wood fiber and insofar 

as possible meet projected production levels consistent with various resource objectives, 

standards and guidelines, and cost efficiency.

• Forest Plan Goal 25 – Provide and execute a fire protection and fire use program that is cost 

efficient and responsive to land and resource management goals and objectives. 

Forest Plan allocated management areas (MA), each of which emphasizes a particular desired 

future condition (DFC) contain standards and guidelines to provide direction for achieving 

DFCs. The Forest Plan designates management areas as the way to characterize the landscape for 

the type and intensity of management activities that may occur on Umatilla National Forest 

lands. Management areas within the project planning area are listed below and shown in Map 2

of Appendix A. 

Sunrise project area contains portions of nine different Management Areas, the largest of which 

is C4: Wildlife Habitat (36% of project area), followed closely by C8: Grass-Tree Mosaic (29%). 

Table 1 shows the acreage and percent of the total project area by Management Area.
Sunrise Vegetation and Fuels Project

22 Umatilla National Forest

Table 1. Geographic extent for management areas applicable to the Sunrise project

Management Area Allocation Acres Percent of 

Total

A4: Viewshed 2 1,135 4

A6: Developed Recreation 20 <1

C1: Dedicated Old Growth 1,785 6

C3: Big Game Winter Range 4,280 13

C3A: Sensitive Big Game Winter Range 3,255 10

C4: Wildlife Habitat 11,650 36

C5: Riparian (Fish and Wildlife) 490 2

C8: Grass-Tree Mosaic 9,230 29

E2: Timber and Big Game 160 <1

Following are brief descriptions of goals, desired conditions, and relationship to the project 

purpose and need associated with each Forest Plan management area allocation located within 

Sunrise project planning area. Detailed descriptions for each area can be found in the Forest Plan 

(FP pages 4-94 to 4-186). The Sunrise project purpose and need revolves around the concepts of 

forest vegetation, density, structure, and fire regime condition class, but also responds to the 

goals below by maintaining or enhancing the desired conditions for each management area. 

Desired conditions would be maintained or enhanced via planned activities and design criteria

described in detail in Chapter 2 with detailed analysis of effects included in Chapter 3. 

A4 Viewshed 2—Goal: Manage the area seen from a travel route, use area, or water body 

where some forest visitors have a major concern for the scenic qualities (sensitivity level 

2) as a natural appearing to slightly altered landscape

Desired Future Condition: Viewsheds will be managed primarily to meet the visual 

quality objectives of partial retention and modification. An attractive, near natural 

landscape will be maintained or created. 

A6 Developed Recreation—Goal: Provide recreation opportunities that are dependent on 

the development of structural facilities for user conveniences where interaction between 

users and evidence of others is prevalent. 

Desired Future Condition: Readily accessible, appropriately designed recreation 

facilities shall provide for concentrated us by people seeking a variety and convenience 

of developed recreation opportunities and experiences. Recreationists will enjoy outdoor 

opportunities where social interactions are moderate to high. Controls and regulations 

will be noticeable to obvious. 

C1 Dedicated Old Growth—Goal: Provide and protect sufficient suitable habitat for 

wildlife species dependent upon mature and/or over-mature forest stands, and promote a 

diversity of vegetative conditions for such species.

Desired future condition: Old-growth areas will be characterized by stands of naturally 

appearing over-mature trees. Stands of mature trees may be included in the old growth

category to provide a better distribution of this habitat type throughout the forest. Trees 

in these stands are relatively large (with many trees greater than 21 inches dbh); past the 

point of rapid growth, and some have visible evidence of decay and decline including 

mycorrhizal fungi and other microorganisms. Stands will be dispersed in quantities and 

sizes which meet the needs of dependent wildlife. These stands will contribute toward 

the forest diversity and aesthetic values.
Final Environmental Impact Statement

Pomeroy Ranger District 23

C3 Big Game Winter Range—Goal: Manage big game winter range to provide high levels 

of potential habitat effectiveness and high quality forage for big game. 

Desired Future Condition: Big game winter ranges will appear as a mosaic of managed 

forests, brush patches, and large grasslands. Forested areas will contain a mix of 

harvested even-aged, uneven-aged, and natural stands, creating patterns of cover patches 

and forage areas for big game. Areas of early spring green-up and other forage changes 

due to prescribed fires and other means will occur in a mosaic pattern over the winter 

ranges; quality forage will be abundant because of management.

C3A Sensitive Big Game Winter Range—Goal: Manage sensitive areas of big game winter 

range to provide high levels of potential habitat effectiveness (at or above the current 

levels).

Desired Future Condition: The area will appear as a mosaic of plant communities, 

including grassland forage area, brush, and some stands of trees. Use of prescribed fire

will be apparent and carried out to maintain or increase the quality and quantity of 

forage and amount of cover on the area. Areas of early spring forage green-up due to 

prescribed fire will occur in a mosaic pattern over the winter range. Increased forage and 

cover will help encourage big game use on public lands and discourage high levels of 

winter use on the adjacent private lands. Most roads and trails will be closed to vehicle 

traffic during the winter, and there will be minimum human disturbance to big game 

during this period. 

C4 Wildlife Habitat—Goal: Manage Forest Lands to provide high levels of potential 

habitat effectiveness for big game and other wildlife species with emphases on size and 

distribution of habitat components (forage and cover areas for elk, snags and dead and 

down materials for all cavity users) unique wildlife habitats and key use areas will be 

retained or protected.

Desired Future Condition: The forest will be a mosaic of even-aged and uneven-aged 

stands dispersed in a manner to create a pattern of forage, and marginal and satisfactory 

cover for big game.

C5 Riparian (Fish and Wildlife)—Goal: Maintain or enhance water quality, and produce a 

high level of potential habitat capability for all species of fish and wildlife within the 

designated riparian habitat areas while providing for a high level of habitat effectiveness 

for big game.

Desired Future Condition: A near natural setting will predominate adjacent to the 

stream, with a wide variety of plant communities of various species, sizes, and age 

classes. In forested riparian zones, a continuous high tree canopy layer will be present 

and the forest will appear denser than in the surrounding land. Upper and mid-level 

conifer and hardwood canopy structure and lower shrub level will provide desired levels 

of stream surface shading, streambank stability, and satisfactory cover for big game.

C8 Grass – Tree Mosaic—Goal: On areas known as grass-tree mosaic (GTM), provide 

high levels of potential habitat effectiveness, high quality forage for big game wildlife 

species, visual diversity, and protect erosive soils.

Desired Future Condition: Generally these areas will remain natural appearing with the 

predominate view being made up of patches or stringers of timber occurring on open, 

generally steep hillsides. Many forest stands will appear as mature timber with some 

having multi-layered canopies. Some stands will be more open as the result of 
Sunrise Vegetation and Fuels Project

24 Umatilla National Forest

management activities designed to improve big game habitat. Areas of early spring 

forage green-up will occur in a mosaic pattern over the winter range portion of this area. 

Quality big game habitat will be maintained and enhanced, thereby helping to achieve 

big game management population and productivity goals. In addition, during an average 

winter, most of the wintering big game will remain on public lands, helping to keep 

impacts to private lands low.

E2 Timber and Big Game—Goal: Manage Forest Lands to emphasize Production of wood 

fiber (timber), encourage forage production, and maintain a moderate level of big game 

and other wildlife habitat.

Desired Future Condition: Management of forests for timber production, domestic 

livestock, big game, and other wildlife habitat will be apparent. Forests will contain a 

mosaic of even-aged and uneven-aged stands dispersed in a manner creating patterns of 

tree cover for big game and openings providing forage. Created opening will range from 

1-3 acres up to 40 acres, but will often be 20-30 acres in size. Horizontal and vertical 

diversity will be apparent; tree species will be diverse, but seral, more pest-free species 

such as ponderosa pine, western larch, and lodgepole pine will predominate. 

Accumulated fuels will be generally light, and large destructive fires will seldom occur. 

Prescribe fire will continue to be an important management tool.

Vegetation management, including tree harvest and prescribed burning, would occur in 

management areas A4, A6, C3, C3A, C4, and E2. No mechanical tree-cutting activities are 

proposed in PACFISH-designated Riparian Habitat Conservation Areas (RHCAs) or within the 

IRA.

1.6 Proposed Action

The Pomeroy District Ranger proposes the following action and associated activities that may 

occur concurrently for this project. This proposed action is in response to the purpose of and 

need for action identified above as refined by internal and external scoping comments. A more 

detailed description of the proposed action can be found in Chapter 2 of this document. 

Vegetation and fuels treatments are anticipated to continue over a period of approximately three 

to ten years following the signature of the final Record of Decision. 

Timber harvest and other tree-cutting activities

The project would include mechanical tree-cutting activities across approximately 7,790 acres. 

Intermediate tree-cutting would be used to modify the growth, vigor, composition, or structure of 

a forest stand after its establishment and prior to its final harvest (approximately 5,660 acres). In 

other areas where thinning treatments alone will not meet landscape vegetation and fuels-related 

objectives, regeneration harvests (i.e. clearcut, shelterwood, seed tree, etc.) and tree planting 

would occur (up to approximately 2,130 acres). Treatments would be designed to promote 

underrepresented, early seral tree species such as ponderosa pine and western larch. Harvest 

methods would include a combination of conventional ground-based3 (approximately 3,310 

 

3 Conventional ground based logging system: This is tractor or skidder yarding on trails spaced approximately 100 

feet apart. Skidding equipment would be required to remain on the trails and logs dragged to the landings with one end 

suspended. Mechanical felling equipment may be used to fall and bunch logs near the trail and be allowed a single 

pass between skid trails to reduce compaction concerns.
Final Environmental Impact Statement

Pomeroy Ranger District 25

acres) and cable/skyline4 yarding systems (approximately 2,210 acres). Activity units could 

include the removal of sawlogs, small diameter trees (generally less than 7.0 inches diameter at 

breast height (DBH)) and/or excess down wood for use as woody biomass 5 products. Units 

within the Lick Creek area would receive only the cutting of small-diameter trees. Tree-cutting 

objectives and activities would vary depending on existing forest vegetation and fuels conditions 

as well as wildlife habitat needs. Although wood fiber utilization is expected in some areas, the 

focus of each treatment would be on the desired conditions of each activity area and designed to 

move vegetation characteristics towards those desired conditions. No trees greater than or equal 

to 21 inches DBH would be cut, under any action alternative. 

Fuels Treatments (activity and natural)

Activity fuels and existing natural fuels would be treated in harvest units. A combination of the 

following treatments (more than one treatment may occur on an acre) would occur: prescribed 

burning of activity fuels (approximately 877 acres), mechanical grapple piling of activity fuels 

(approximately 1,068 acres), and yarding with tops attached. Non-commercial hand thinning

(about 1,680 acres) and mechanical thinning (about 590 acres) would be used to treat ladder 

fuels in both harvest activity units and natural fuels units where high density small diameter 

understory remain. If it is economically feasible, material from 3 to 10 inches DBH would be 

removed as a woody biomass product, if it is not economically feasible, mechanical fuel 

treatments would be treated by mastication.

Landscape Prescribed Fire

Landscape prescribed fire could occur across approximately 14,055 acres within the Sunrise 

project area. The project area would be burned when fire intensity could be kept low to facilitate 

the likelihood of reducing surface and ladder fuels while limiting the incidences and size of 

individual tree and group torching. This would result in lower stand densities, increased 

abundance of fire-tolerant species, reduced existing ladder, surface, and canopy fuels, while 

improving suppression capabilities on forest land, and re-introducing landscape-scale fire into 

the ecosystem. Upon completion, landscape could be described as a mosaic of unburned, lightly 

burned, moderately burned, and intensely burned patches.

Road Management 

To accomplish implementation of proposed activities approximately 39 miles of closed6 system 

roads (operational maintenance level 17

), and 52 miles of seasonally8 open roads (operational 

 

4 Skyline logging system: In a skyline system, logs are yarded up the hill by a system of cables, and logs are either 

partially or fully suspended to reduce soil disturbance. Skyline yarding landings are slightly smaller than conventional 

ground-based systems. 5 Woody Biomass: Trees and woody plants, including limbs, tops, needles, leaves, and other woody parts, grown in a 

forest, woodland, or rangeland environment, that are the by-products of forest management. 6 Closed Road: These roads are not available for motorized vehicle travel for everyday access and are gated or closed 

by barricades. These roads can be opened for access for resource management activities or fire suppression.

Snowmobile use is allowed except where specifically prohibited. 

7 Operational maintenance level 1: The operational objective is closed more than 1 year. 8 Seasonally Open Roads: These roads are available for public motorized vehicle use only during specified seasons. 
Sunrise Vegetation and Fuels Project

26 Umatilla National Forest

maintenance level 29 and 310) would be used as haul routes. Closed system roads used for project 

activities would not be opened to the public. All system roads would remain the same after 

project implementation; open roads would remain open, closed roads would continue to be 

closed, and seasonally open roads would continue with that designation. Approximately 14 miles 

of temporary road would be constructed; of which 8 miles would be constructed over previous 

road templates. All temporary roads would be decommissioned after project activity use. No new 

specified permanent road construction is proposed.

Danger Tree Removal 

Danger trees11 would be felled and removed along all previously described haul routes used for 

timber sale activity. If considered economically feasible they would be sold as part of a timber 

sale. Danger trees within Riparian Habitat Conservation Areas (RHCAs) would not be removed; 

they would be cut and left to provide additional coarse woody debris.

1.7 NEPA Document Preparation

NEPA Documentation Relying on resource reports and the project file helps implement the 

CEQ's regulation provision that agencies should reduce NEPA paperwork (40 CFR 1500.4), 

through incorporation by reference, keeping documents analytic rather than encyclopedic, and 

keeping NEPA documents no longer than absolutely necessary (40 CFR 1502.2). The objective is 

to furnish enough site-specific information to demonstrate a reasoned consideration of the 

environmental effects of the alternatives and how these effects can be mitigated, without 

repeating detailed analysis and background information available elsewhere.

Project Administrative Record

This EIS hereby incorporates by reference the project file (40 CFR 1502.21). The project file 

contains resource specialist reports and other technical documentation used to support the 

analysis and conclusions in this EIS; as well as all decision making documentation Specific 

information on methodologies, assumptions, and limitations of analysis and other details are 

contained in specialist reports. The following specialist reports are included in the project file: 

soils, hydrology, fisheries, wildlife, botany, vegetation (including historical range of variability, 

insects and disease, and invasive plants), fuels, air quality, transportation system (roads), 

economics, recreation, visuals/scenery, inventoried roadless areas, potential wilderness areas, 

other undeveloped lands, and cultural resources. Other sources of information, documents, 

published studies, and books referred to in this document are also included in the project file 

which is located at Pomeroy Ranger District office.

Tiering and Incorporating by Reference

In order to eliminate repetition and focus on site-specific analysis, this DEIS is tiered to the 

following documents as permitted by 40 CFR 1502.20. When incorporating information sources 

 

9 Operational maintenance level 2: The operational objective is for high clearance vehicles. 10 Operational maintenance level 3: The operational objective is for passenger vehicles – road surface is not smooth. 11 Danger Trees: A danger tree is defined as any standing tree that presents a hazard to people due to conditions such 

as, but not limited to, deterioration or physical damage to the root system, trunk, stem, or limbs and the direction and 

lean of the tree (FSH 6709.11, Glossary). Trees will be felled that have an imminent or likely potential to fail. Trees 

that have an imminent potential to fail are so defective or rotten that it will take little effort to make them fail. Trees 

considered likely to fail include all dead trees and some live trees with specific diseases and/or damage. 
Final Environmental Impact Statement

Pomeroy Ranger District 27

by reference, this document and resource specialist reports summarize the source’s analysis and 

conclusions, and explain its relevance to the Sunrise project analysis.

Umatilla National Forest Land and Resource Management Plan FEIS and Record of 

Decision (ROD) dated June 11, 1990 and all subsequent NEPA analysis for amendments. The 

FEIS contains analyses of resource management practices, levels of resource production and 

management, and the availability and suitability of lands for resource management.

This DEIS also incorporates by reference the following documents:

Umatilla National Forest Land and Resource Management Plan (Forest Plan) dated June 

11, 1990, and all subsequent Forest Plan amendments. The Forest plan provides programmatic 

direction for the Forest, including Sunrise project planning area. Relevant Forest Plan 

amendments for this project are summarized below:

Forest Plan Amendment #10, The Interim Strategies for Managing Anadromous FishProducing Watersheds in Eastern Oregon and Washington, Idaho, and Portions of California 

(PACFISH) dated February 24, 1995. PACFISH provided further protection for fish habitat, 

particularly regarding activities within riparian areas.

Forest Plan Amendment #11, Continuation of Interim Management Direction Establishing 

Riparian, Ecosystem, and Wildlife Standards for Timber Sales (Regional Forester’s Amendment 

No. 2, Screens) dated June 12, 1995. The Screens (Eastside Screens) established additional 

management direction regarding riparian management (screen 4), ecosystem diversity (screen 5), 

and wildlife structural diversity, connectivity of late/old structure, retention of snags and downed 

wood, and goshawk nest-sites (screen 6).

Forest Plan Amendment #30, Pacific Northwest Region Final Environmental Impact Statement

for the Invasive Plant Program, 2005, hereby referred to as the R6 2005 FEIS. The R6 2005 

FEIS culminated in a Record of Decision (R6 2005 ROD) that amended the Umatilla National 

Forest Plan by adding management direction relative to invasive plants. 

The Biological Opinion for the Implementation of Interim Strategies for Managing 

Anadromous Fish-producing Watersheds in Eastern Oregon and Washington, Idaho, and 

Portions of California (PACFISH) from National Marine Fisheries Service dated January 23, 

1995. PACFISH itself does not propose any ground-disturbing actions, but sets in place certain 

riparian management goals and management direction with the intent of arresting the 

degradation and beginning the restoration of riparian and stream habitats. Habitat for 

anadromous fish is present in the watersheds analyzed for this project.

The Biological Opinion for the Effects to Bull Trout from Continued Implementation of 

Land and Resource Management Plans and Resource Management Plans as Amended by 

the Interim Strategy for Managing Fish-producing Watersheds in Eastern Oregon and 

Washington, Idaho, Western Montana, and Portions of Nevada (INFISH), and the Interim 

Strategy for Managing Anadromous Fish-producing Watersheds in Eastern Oregon and 

Washington, Idaho, and Portions of California (PACFISH) from National Marine Fisheries 

Service, dated August 14, 1998. This BO addresses the effects of continued implementation of 

LRMPs as amended by PACFISH standards and guidelines where listed distinct population 

segments of bull trout occur in Idaho, Montana, Oregon, and Washington. Habitat for bull trout 

is present in the watersheds analyzed for this project. 
Sunrise Vegetation and Fuels Project

28 Umatilla National Forest

The Biological Opinion on the Land and Resource Management Plans for the Boise, 

Challis, Nez Perce, Payette, Sawtooth, Umatilla and Wallowa-Whitman National Forests

from National Marine Fisheries Service, dated March 1, 1995. National Marine Fisheries has 

identified a set of goals, objectives, and guidelines that will apply to watershed and site-specific 

consultations until Land and Resource Management Plans are amended. Conformance with the 

provisions of this Opinion, in combination with implementation of PACFISH, should provide 

reasonable certainty that site-specific actions will not result in jeopardy to listed salmon or 

adverse modification of critical habitat. This applies to the Land and Resource Management Plan 

for Umatilla National Forest and PACFISH amendment used for this project. 

The Biological Opinion - Land and Resource Management Plans for National Forests and 

Bureau of Land and Management Resource Areas in the Upper Columbia River Basin and 

Snake River Basin Evolutionarily Significant Units by National Marine Fisheries Service 

dated June 22, 1998. This BO addresses the effects of continued implementation of the 18 

LRMPs as amended by PACFISH standards and guidelines on Snake River salmon and 

steelhead. This applies to the Land and Resource Management Plan for Umatilla National Forest 

incorporated by reference in this project.

Blue Mountain Expedited Section 7 Consultation Process –Consultation with the Level 1 

Team (U.S. Forest Service, NOAA Fisheries, and U. S. Fish and Wildlife Service) occurred in 

August 2018 (letter on file). The project is tiered to Letters of Concurrence for the Blue 

Mountain Expedited Section 7 Consultation Process (Blue Mountain Project Design Criteria 

(PDC) received from Fish and Wildlife Service dated November 20, 2013 (FWS reference 

01EOFW00-2013-I-0173) and NOAA Fisheries dated November 1, 2013 (NMFS reference 

NWR-2013-10339). The Level 1 Team letter will fulfill requirements for Magnuson-Stevens 

Fishery Conservation and Management Act Essential Fish Habitat Consultation.

Bull Trout Critical Habitat Designated in 2010: Letter dated November 16, 2010 from U. S. 

Fish and Wildlife Service, confirmation of Conference Reports and Conference Opinion as 

Letters of Concurrence and a Biological Opinion for Multiple Wallowa-Whitman National Forest 

Actions Involving Proposed Bull Trout Critical Habitat. This letter transmits confirmation of 

previously completed conference documents for actions described in the letter. Date of informal 

conference (13420-2010-1C-0150) for Umatilla National Forest is July 30, 2010. The purpose of 

this letter is to adopt the conference report as a Letter of Concurrence for designated bull trout 

critical habitat for the Blue Mt. Expedited Section 7 Consultation Process. Habitat for bull trout 

is present in the watershed analyzed for this project.

Asotin Watershed Assessment, Umatilla National Forest, Pomeroy Ranger District, January 18, 

1996. A watershed-level ecosystem analysis of current and reference conditions along with 

recommendations for restoration. Sunrise Project is located in the Asotin Watershed and 

recommendations from this assessment were considered for this project.

Invasive Plants Treatment Project (EIS), Umatilla National Forest, decision dated July 2010. 

Authorizes treatment of invasive plant species over a 5-15 year period using manual, 

mechanical, biological, herbicide, and cultural treatments. Up to 4,000 acres may be treated 

annually, including known sites and those detected in the future. Invasive plants in the project 

planning area will be treated as identified in this EIS (Chapter 3, Table 63). 

Environmental Assessment for Pomeroy Ranger District Motorized Access and Travel 

Management Plan, Pomeroy Ranger District, July 1993. A comprehensive program resulting in 

a transportation system which provides for a broad mix of both motorized and non-motorized 
Final Environmental Impact Statement

Pomeroy Ranger District 29

recreation opportunities while moving toward Forest Plan desired future conditions. The 

transportation system for this project is consistent with this EA. 

Analysis of Umatilla National Forest Road System, completed January 2004. Forest-scale 

analysis in determining the minimum road system needed to meet resource and other 

management objectives. Transportation actions for this project are consistent with this Forest 

scale analysis.

The Integrated Scientific Assessment for Ecosystem Management in the Interior Columbia 

Basin released 1996. Links landscape, aquatic, terrestrial, social, and economic 

characterizations to described biophysical and social systems. Biological and social systems for 

this project are described in Chapter 3 of this EIS.

Umatilla National Forest Interim Snag Guidance Letter dated April, 1993, which provides 

direction on the number and distribution of snags to retain in harvest units. Direction from this 

letter was used for this project.

National Fire Plan Developed in August 2000 with the intent of responding to severe wildland 

fires and their impacts to communities while addressing five key points: Firefighting, 

Rehabilitation, Hazardous Fuels Reduction, Community Assistance, and Accountability. Activity 

and natural fuels are proposed for treatment in this project.

Region 6 Protocol for Assessment and Management of Soil Quality Conditions dated 

January 2002. Established consistency in soil assessment methods on the Umatilla National 

Forest and other Blue Mountain forests, and ensures compliance with Forest Plan and NEPA

condition assessment needs.

Analysis and documentation for this project has been done according to direction contained in 

the National Forest Management Act (NFMA), National Environmental Policy Act (NEPA), 

Council on Environmental Quality Regulations (CEQ), Clean Water Act (CWA), Clean Air Act 

(CAA), National Historic Preservation Act (NHPA), and Endangered Species Act (ESA).

1.8 Treaty Rights

The Forest Service, through the Secretary of Agriculture, is vested with statutory authority and 

responsibility for managing resources of the National Forests. Commensurate with the authority 

and responsibility to manage is the obligation to consult, cooperate, and coordinate with Indian 

Tribes in developing and planning management decisions regarding resources on National Forest 

system land that may affect tribal rights.

Locally, the Sunrise project area lies within the area ceded to the United States government by 

the Nez Perce Indians, as a result of the Treaties of 1855. Elements of respective Indian cultures, 

such as tribal welfare, land, and resources were entrusted to the United States government as a 

result of the treaties. Trust responsibilities resulting from the treaties dictate, in part, that the 

United States government facilitate the execution of treaty rights and traditional cultural

practices of Nez Perce Indians by working with them on a government to government basis in a 

manner that attempts a reasonable accommodation of their needs, without compromising the 

legal positions of the respective tribes or the federal government. Specific treaty rights applicable 

to that land base managed by the Umatilla National Forest area generally articulated in Article III 

of the 1855 Nez Perce Treaty, include:
Sunrise Vegetation and Fuels Project

30 Umatilla National Forest

“The exclusive right of taking fish in all the streams where running through or bordering said 

reservation is further secured to said Indians; as also the right of taking fish at all usual and 

accustomed places in common with citizens of the Territory; and of erecting temporary buildings 

for curing, together with the privilege of hunting, gathering roots and berries, and pasturing their 

horses and cattle upon open and unclaimed land.”

Although the 1855 Treaties do not specifically mandate the federal government to manage 

habitats, there is an implied assumption that an adequate reserve of water be available for 

executing treaty related hunting and fishing activities. Of major concern relating to recent Forest 

Service projects are potential effects on Treaty rights, fish habitat and populations, water quality, 

and protection of archaeological sites, traditional cultural properties, and first foods resources. 

Because tribal trust activities often occur in common with the public, Umatilla National Forest 

strives to manage tribal ceded land to enable the execution of tribal rights, as far as practicable, 

while still providing goods and services to all people.

1.9 Tribal and Public Involvement

Tribal Involvement 

For this project, a government to government scoping letter was sent to tribal staff members of 

the Nez Perce Tribe on December 14, 2014, informing them of the Sunrise proposed project and 

requesting any comments or concerns regarding the project. The Pomeroy District Ranger 

presented the District Program of Work to Nez Perce tribal staff members on March 20, 2015 

and continued to update the Nez Perce tribal staff members is subsequent opportunities. At these 

meetings, projects are presented the District Ranger solicits questions, comments, or requests for 

additional information. Several field trips were also organized with tribal staff members on June 

29, 2015; December 08, 2015; and October 24, 2016 to view the project area, discuss potential 

treatments, answer any questions and address any concerns.

General concerns received from tribal staff members on recent projects similar to the Sunrise 

project include the following:

• Potential effects to archeological and traditional properties and first foods resources.

• Potential effects to water quality.

• Potential effects to fish habitat, including salmonid species federally listed as threatened or 

endangered under ESA.

• Potential effects to economic recovery.

• Potential effects to treaty rights.

The Sunrise project remained on the list of topics for all Program of Work meetings since 2014. 

We continued government to government consultation when went letters in May 2018 to the 

tribes announcing the opening of our comment period for the draft EIS. The Nez Perce 

responded with a comment letter, the contents of which were incorporated into our response to 

comments and final EIS. 

Public Involvement

A notice of intent to prepare an EIS was published in the Federal Register on November 28th, 

2014 (79 FR70844). In addition, as part of the public involvement process, the agency sent 

letters on December 12, 2014 describing the project to representatives of the Confederated Tribes 
Final Environmental Impact Statement

Pomeroy Ranger District 31

of the Umatilla Indian Reservation (CTUIR) and Nez Perce Tribe, and to interested individuals, 

organizations, and other agencies that have indicated an interest in this type of project in the 

recent past. Using the comments from the public, other agencies, and the CTUIR and Nez Perce 

Tribe (see Scoping Comments section), the interdisciplinary team developed a list of issues to 

address. A table of scoping input and issues identified is located in the project file at the Pomeroy 

District office. Any issues raised during the public scoping process were considered and 

analyzed in this document. The Forest Service separated the comments into two groups: issues 

considered and comments dismissed. Comments dismissed pertained to activities and/or effects 

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

other higher level decision; 3) irrelevant to the decision to be made; or 4) conjectural and not 

supported by scientific or factual evidence. 

A draft environmental impact statement (DEIS) was published for review and comment on June 

1st, 2018. A list of agencies, organizations, and people who received copies can be found in 

Chapter 4 ( page 277). Mailing were also provided to the Tribes and interested parties list to 

notify them of the comment period. 

Nine comments were received in response to the request for comment on the draft EIS. 

Comments were summarized and pooled for response, and additions, updates and corrections 

made to the EIS as appropriate. Response to comments can be found in Appendix D, and 

comment letters are available on the Sunrise project webpage: http://www.fs.fed.us/nepa/fs-usdapop.php/?project=45689, or from the Pomeroy district office as part of the project record.

1.10 Decision Framework

The scope of the project and decision to be made are limited to: commercial timber harvest, fuels 

treatments (landscape prescribed fire, non-commercial thinning, and non-commercial mechanical 

treatment), danger tree removal along haul routes, and mitigation and monitoring within the 

project planning area. Connected actions include reforestation of harvest units and temporary 

road development and decommissioning of temporary roads. Chapter 2 details the designs of 

these actions. Proposed project activities would occur on National Forest System lands (NFS) 

and the decision to implement them would be limited to NFS lands. 

The responsible deciding official will decide whether to implement the proposed action, another 

alternative action, or take no action at this time. If an action alternative is selected, the 

responsible deciding official will also determine:

1. How much and where timber harvest and fuel treatments, along with their associated 

activities, should occur. 

2. Whether other management activities (landscape prescribed fire, danger tree removal, 

and fuel treatments) and their associated activities should occur.

3. What monitoring requirements are needed to assure the selected alternative and 

mitigation are implemented as designed. 

1.11 Scoping Comments

Issues Considered for Detailed Study 

Issues serve to highlight effects or unintended consequences that may occur from the proposed 

action and alternatives, giving opportunities during the analysis to explore alternative ways to 

meet the purpose and need for the proposal, while reducing adverse effects and compare trade-
Sunrise Vegetation and Fuels Project

32 Umatilla National Forest

offs for the decision maker and public to understand. The responsible official approved the issues 

to be analyzed in depth by the IDT in the environmental analysis, as well as issues considered, 

but not analyzed in depth. Issues to be analyzed in depth include potential direct, indirect, and/or 

cumulative effects upon the following resources or topics that were brought to light through 

internal and external scoping and consideration for significance of any effects:

• Forest vegetation composition, structure, and density

• Fuels: Fire Regime Condition Class

• Amount and distribution of source habitat for rocky mountain elk, pileated woodpecker, 

marten, and three-toed woodpecker

• Economic issues: net present value of forest products

• Invasive plants

• Access management: road decommissioning 

• Inventoried Roadless Areas

• Soil resources

• Water quality / hydrologic function

• Recreation opportunities

• Threatened, Endangered, and/or Sensitive Plants

A majority of the management area acres within the Sunrise project emphasize the management 

of wildlife and timber; therefore, treatments were designed to address the needs associated with

one or both of these resources. Some issues identified from scoping indicated possible 

unresolved conflicts. Specifically, the proposed action could negatively affect management 

indicator species by decreasing the quality, abundance, and distribution of habitat, due to 

decreased cover and security areas, as well as old forest distribution, old forest connectivity, and 

snag habitat. Measures for this issue include:

• Amount and distribution of elk cover and open roads 

• Amount, distribution, and connectivity of old forest 

• Amount and distribution of source habitat for pileated woodpecker, marten, and three-toed 

woodpecker

• Snag and down wood: range of variation analysis 

Issues Dismissed from Detailed Study

Following scoping, only one issue was omitted from detailed study because it did not meet the 

purpose and need or was outside of the scope and scale of the proposed project. Some comments 

addressed the possible effect of the Sunrise project on greenhouse gas emissions. This issue is 

addressed generally in Chapter 3, in relation to the Sunrise project area and vicinity because 

enough is known about the scope and scale of the Sunrise project relative to global emissions to 

determine that overall effects would be negligible in a global context. All other issues identified 

during scoping are considered in detail in this EIS.
Final Environmental Impact Statement

Pomeroy Ranger District 33

Chapter 2. Alternatives

2.1 Introduction

Three alternatives were selected for development along with design criteria and monitoring

elements associated with the alternatives. These alternatives will be described in this chapter 

with supporting information incorporated by reference in associated appendices. Maps showing 

activity areas described in action alternatives are located in Appendix A. The proposed action 

alternatives are limited to connected, similar, and cumulative actions (40 CFR 1508.25). Both 

action alternatives propose activities (prescribed landscape burning) that occur within a 

congressionally designated area: the Asotin Creek Inventoried Roadless Area (IRA). No tree 

cutting will occur within that IRA. A finding that the action alternatives are consistent with 

specific direction and/or provisions in the enabling legislation is discussed in Chapter 3. 

2.2 Range of Alternatives

The phrase “range of alternatives” refers to the alternatives discussed in environmental 

documents. It includes all reasonable alternatives, which must be rigorously explored and 

objectively evaluated as well as other alternatives, which are eliminated from detailed study with 

a brief discussion of the reasons for eliminating them [CFR 40.1502.14 ].

Both action alternatives respond to the project purpose and need to modify species composition, 

forest structure, fuel loading, and tree density through a combination of activities including tree 

cutting, mastication, tree planting, and pile, jackpot and landscape broadcast burning. Activities 

would occur over a 5-10 year period beginning in approximately 2019. No trees ≥21 inches in 

diameter at breast height (DBH) would be cut under this action alternative and no cutting would 

occur within PACFISH buffers. Alternative C includes the same types of activities as Alternative 

B, but tree-cutting and road-related activities would occur to a lesser degree. 

The alternatives for this project were designed to express a range of possible actions. The Interdisciplinary team (IDT) developed the range of alternatives and design criteria presented in this 

chapter. The type and scope of activities were determined by the project purpose and need, 

Forest Plan goals and objectives, Forest Plan standards and guidelines, requirements under the 

Endangered Species Act, and other Federal and State laws and regulations. 

The IDT recommended, and the responsible official approved, two action alternatives and a No 

Action alternative based on the information presented in Chapter 1. Alternative C was developed 

following the scoping period based on comments that identified possible effects of the proposed 

action on wildlife populations and habitat. A modified version of the proposed action - occurring 

over a smaller geographic area - was developed to reduce detrimental effects on habitat, yet still 

meet the project purpose and need. No other action alternatives were considered because none 

were proposed during scoping, and no other activities are known to modify vegetation and fuels 

in the manner required to meet the project purpose and need. The two action alternatives 

represent a range of possible extent that could reasonably be expected to alter vegetation and 

fuels characteristics to the degree indicated by current departures from desired conditions. 
Sunrise Vegetation and Fuels Project

34 Umatilla National Forest

2.3 Alternatives Considered in Detail

Alternative A (No Action)

Purpose and Design

• No new management activities as proposed would occur.

• Current biological and physical processes would be allowed to continue along their present 

path along with associated risks and benefits and serve as a baseline for comparison with other 

alternatives.

• Responds to the requirement to consider a No Action alternative (40 CFR §1502.14 (d)). 

Description

Under the No Action alternative, no activities identified in the proposed action would occur and 

previously approved ongoing activities such as domestic cattle grazing, wildfire suppression 

and/or containment, firewood cutting, recreation, and road maintenance (including danger tree

removal) would continue. This alternative would allow timber stands, identified at this time as 

needing treatment, to progress through growth and successional processes at their own rate and 

in the absence of unsuppressed wildfires or human-caused ecological disturbances. Natural fuels 

would not be treated to reduce the risk of undesired wildfire intensity or allow for a safer 

environment for fire-fighting personnel during fire suppression. No tree cutting, tree planting, 

fuels treatments for natural or activity fuels, landscape prescribed fire, or road decommissioning 

would be implemented to accomplish project goals.

Alternative B – Proposed Action – Preferred Alternative

Purpose and Design

Alternative B responds to the project purpose and need to modify species composition, forest 

structure, fuel loading, and tree density through a combination of activities including tree cutting, 

mastication, tree planting, and pile, jackpot and landscape broadcast burning. Activities would 

occur over a 5-10 year period beginning in approximately 2019. No trees ≥21 inches in diameter 

at breast height (DBH) would be cut under this action alternative and no cutting would occur 

within PACFISH buffers. The extent of activities for both Alternative B and C are described 

further at the end of this chapter. 

Alternative B is a modification of the alternative proposed during scoping, with the difference of 

acreages that have been adjusted to reflect additional field reviews and updated GIS information. 

Treatments in Alternative B respond to elements identified in the Purpose and Need (Chapter 1) 

and are designed to accomplish the following objectives, while complying with all applicable 

laws, rules, and regulations:

• Modify dry, moist, and cold upland forests to a species composition and structure compatible 

with the historical range of variability. Thinning treatments are used to reduce insect and 

disease susceptibility by improving tree and stand vigor. Regeneration treatments are used to 

improve upland forest sites where early-seral species are no longer present in ecologically 

viable amounts.

• Reduce fuel loading (surface, ladder, and canopy fuels) to a level that facilitates future 
Final Environmental Impact Statement

Pomeroy Ranger District 35

reintroduction of low-intensity surface fire, reduce ladder and ground fuelsin natural fuel areas 

to lower the risk of fire spread into the upper canopy, and reduce fuels that would contribute 

to uncharacteristic wildfire intensity and resource damage.

• Provide sawlogs and wood fiber products for utilization by local and regional industry.

• Continue to provide and manage wildlife habitat and its components (cover and forage).

• Reduce risk of personal injury by removing danger trees along haul routes used for timber sale 

activities. 

Description

Vegetation Treatments

Approximately 7,790 acres would be treated with either an intermediate cut (5,660 acres) or a 

regeneration (2,130 acres) tree-cutting activity in an effort to improve tree species composition, 

reduce tree density, and/or alter stand structure (see Appendix A for maps, Appendix B for a 

listing of units and treatments, and the Silviculture report for detailed descriptions of silvicultural 

activities and terminology definitions.). Approximately 5,530 acres of the tree-cutting treatments 

would include the removal of sawlogs and small-diameter trees (generally less than 9 or 10 

inches DBH) and /or excess down wood for use as woody biomass products. In most cases, 

treatments would be designed to promote underrepresented, early seral tree species such as 

ponderosa pine and western larch. No trees greater than or equal to 21 inches DBH would be cut

under this action alternative except for danger trees felled for safety concerns. Small tree 

removal may include mastication or hand thinning. Additionally, no cutting would occur within 

the PACFISH buffers. Approximately 2,130 acres would be reforested through three planning to 

help restore early seral tree species. Fuels treatments would reduce activity generated and 

existing natural fuels on 5,520 of harvest units. These treats may include lop and scatter, 

broadcast and underburning, as well as burning of excess activity generated fuels. 

Intermediate Cutting

Approximately 5,660 acres would be treated with an intermediate cut. These acres include some 

of the “small tree removal” activities described later in this section. Intermediate treatments in 

the Sunrise project would generally retain a forest meeting minimum stocking requirements and 

sufficient over-story density to preclude extensive tree germination and establishment. These 

treatments would also have the effect of accelerating the pace and/or likelihood of old forest 

creation and development by promoting individual tree vigor and/or tree species expected to 

persist for several decades. 

For dry-forest sites, intermediate cutting would be utilized to transform some of the 

overrepresented Douglas-fir cover type to the underrepresented ponderosa pine cover type. For 

moist-forest sites, intermediate cutting would transform some of the overrepresented grand fir 

and spruce-fir cover types to the underrepresented western larch, broadleaved species, and/or 

lodgepole pine cover types. Among dry and cold forest sites, intermediate cutting would be used 

to transform overrepresented understory reinitiation to currently underrepresented stem 

exclusion, and old forest multi-strata structure classes to old forest single-strata classes. 

Intermediate cutting would reduce tree density (stocking) levels for high and moderate-density 

stands on dry, moist, and cold forest sites, thereby increasing amounts of underrepresented 

moderate and low-density stand types. 
Sunrise Vegetation and Fuels Project

36 Umatilla National Forest

Within units designated for intermediate cutting, those identified as “high-retention” areas will 

be treated to maintain marginal or satisfactory wildlife cover and/or satisfactory cover for 

wildlife connectivity corridors. Approximately 2,210 unit acres have been identified for cover 

requirements, 1,372 (62%) of those acres will be hand-thinned and receive landscape-burning 

treatment only. The goal of the activities in high-retention units is to maintain marginal or 

satisfactory elk cover and/or wildlife habitat connectivity. 

Treatments in high-retention units would include small-tree thinning of trees 10 inch DBH or 

less, pruning, and treatment of surface fuels. Tree-felling would generally be limited to subdominant or suppressed trees, surface fuels, or ladder fuels (small live or dead trees immediately 

adjacent to larger, older trees). Prescribed fire would also be implemented within high-retention 

units with higher canopy cover following the removal of trees. The desired prescribed fire effects 

include low overall burn severity within these units (generally less than 10% canopy reduction 

from fire-caused tree mortality), consumption of surface and lower-canopy fuels, promotion of 

sprouting hardwood vegetation, improvement of grass community vigor and density, and 

minimization of tree mortality caused by ladder fuel ignition. Duff pull-back from identified 

large old residual trees and landscape burning would be conducted in such a manner as to 

minimize the possibility of large, old pine mortality caused by smoldering duff consumption, 

following guidance provided in (Hood 2010, Progar et al. 2017). 

Regeneration Cutting

Approximately 2,130 acres would be treated with a regeneration cut. These acres include some 

of the “small tree removal” activities described later in this section. Regeneration cutting is 

defined as tree removal to assist regeneration already present (e.g. existing seedling and 

saplings), or to make new regeneration possible (Helms 1998). The silviculture report contains 

general descriptions of silvicultural activities and terminology definitions. Regeneration cutting 

is proposed for upland-forest sites where early seral species (ponderosa pine, western larch, 

lodgepole pine) are no longer present in ecologically viable amounts. These stands are more 

advanced in ecological succession, and often exhibit high levels of insect or disease mortality. 

The existing stocking of mid or late seral species—primarily Engelmann spruce, subalpine fir, 

grand fir or Douglas-fir—typically exceeds that of the early seral species. Many stands within 

the dry, moist, and cold upland forest sites have become dominated by shade-tolerant, late seral, 

fire-susceptible trees species such as grand fir, Engelmann spruce, subalpine fir, and Douglas-fir.

For dry-forest sites, regeneration cutting would transform some of the overrepresented Douglasfir forest cover types to the underrepresented ponderosa pine cover type. For moist-forest sites, 

regeneration cutting would transform some of the overrepresented Douglas-fir forest cover type 

to the underrepresented western larch or lodgepole pine cover types. Regeneration cutting would 

convert some of the overrepresented subalpine fir and spruce cover types to underrepresented 

lodgepole pine cover types, as well as western larch, which is currently at the low end of the 

desired range.

Regeneration cutting would convert some of the overrepresented stem exclusion or understory

reinitiation structure classes to the underrepresented stand initiation structure classes, which 

would occur in dry, moist, and cold upland forests under this action alternative. It can also be 

used concurrently to move stands with moderate or high tree densities to low or moderate tree 

densities. 

For the Sunrise project, regeneration cutting would include individual-tree selection, group 

selection, shelterwood harvest, seed-tree harvest, or clearcutting methods. Depending on site and 
Final Environmental Impact Statement

Pomeroy Ranger District 37

stand characteristics, regeneration cutting methods may result in the removal and/or retention of 

a variety of tree sizes, species, and density levels; the common element is that substantial 

amounts of tree germination and establishment are expected following the activity. In some 

cases, regeneration cutting methods such as individual-tree or group selection would retain stand 

of moderate density overall, but with enough gaps and openings to allow germination and 

establishment of a new tree cohort. These treatments would also have the effect of accelerating 

the pace and/or likelihood of old forest creation and development by promoting individual tree 

vigor and/or tree species expected to persist for several decades. The amount of retained 

overstory was predicted in the environmental analysis based on existing stand characteristics and 

anticipated cutting methods. 

Tree Planting within Regeneration Units

Approximately 2,130 acres are proposed for reforestation through tree planting. Tree planting is 

defined as “the establishment of trees by planting seedlings, transplants, or cuttings” (Dunster 

and Dunster 1996). Planting is proposed to improve tree composition for currently understocked 

stands, or to help provide desired (future) forest conditions in openings created by the 

regeneration cutting.

The planting proposed action responds to one of the upland forest issues identified in the purpose 

and need in Chapter 1. Planting would help restore early seral tree species (ponderosa pine, and 

western larch) and shrubs for both dry- and moist-forest sites. An emphasis on early seral species 

was included in the forest-wide standards and guidelines section of the Forest Plan (item C on 

page 4-73 in the Plan: “strong consideration should be given to maintenance of stands dominated 

by early successional species”), as well as the purpose and need section of this document.

Created openings resulting from Sunrise regeneration cutting, particularly those where natural 

regeneration might not be sufficient to meet requirements established by the National Forest 

Management Act of 1976 and its regulations (NFMA; 16 U.S. C. 1604), would be planted with 

tree seedlings to reestablish an ecologically appropriate mix of early seral tree species, and to 

ensure that minimum stocking objectives from the Forest Plan are met within 5 years of final 

harvest, as required by 16 U.S.C. 1604 (E) (ii) .

Although not required by NFMA, native shrub seedlings would also be planted when doing so 

would help meet the desired future conditions of an area. Planting helps restore shrub 

populations that have been reduced because of overstory shading caused by uncharacteristically 

high tree density (Hedrick et al. 1968).

Tree planting in regeneration units would meet the following minimum tree stocking guides 

listed in Table 2.

Table 2. Minimum Tree Stocking Standards

Average Stand Diameter After 

Harvest (Inches DBH)

Minimum Acceptable Stocking 

(Live Trees Per Acre)

Minimum Basal Area Stocking 

(Basal Area Per Acre)

<5" 100-200 14 - 27

6" 100 20

8" 80 28

10" 65 35

12" 45 35

14" 30 32

16" 25 35

18" 20 35

20" 15 33

21+" 12 29
Sunrise Vegetation and Fuels Project

38 Umatilla National Forest

Logging Systems

Timber harvest methods would include conventional ground-based logging (approximately 3,310 

acres) and skyline logging (approximately 2,210 acres). For all cutting units in which a 

commercial product is removed, yarding systems could require either whole-tree yarding12 or 

leaving tops attached13 with de-limbing in the woods and leaving the activity slash. Conventional 

ground-based harvesting utilizes a crawler tractor or rubber-tired skidder that would operate on 

designated trails with selected spacing criteria. All equipment would be required to remain on 

designated skid trails. Skyline logging would occur in areas where topography is suitable and 

necessary for this type of logging. In a skyline system, logs would be felled and yarded up the 

hill partially or fully suspended by a system of cables to reduce soil disturbance and improve 

economic efficiency. Skyline systems utilize only hand-felling of trees, while conventional 

ground-based systems may utilize a tracked caterpillar feller-buncher, or hand-felling. Harvest 

units with a chip/biomass component may utilize a chipper/grinder at the landing to process and 

load material to chip trucks for delivery to production facilities. 

Fuels Treatments 

Fuel treatments are proposed to reduce activity generated fuels and existing natural fuels in the 

5,520 acres of harvest units. They are also designed to modify ladder and surface fuels outside of 

harvest units to lower the risk of fire spreading into the upper tree canopy, and in areas where 

fuels would contribute to undesired/uncharacteristic wildfire intensity and resource damage. Fuel 

treatments include the following activities, alone or in combination. 

Whole Tree Yarding: The entire tree above the stump including non-merchantable material 

(tops and limbs) will be yarded to the landing. Once at the landing this material that doesn’t meet 

merchantable specifications may be utilized for woody biomass products or burned. 

Lop and Scatter: In areas where non-merchantable tops and limbs would be left, boles would be 

cut to less than six feet in length and limbs would be severed from bole and scattered to prevent 

fuel bed depth from exceeding two feet in depth.

Jackpot burning: Burning of slash concentrations would be utilized to reduce excess slash 

generated in harvest units. Jackpot burning would be accomplished utilizing hand ignition 

methods. Harvest units located in landscape prescribed fire areas may require jackpot burning 

prior to landscape prescribed fire to reduce heavy slash concentrations.

Broadcast and Under Burning: Low intensity prescribed fire would be applied to a broad area 

using hand ignition devices. This method would be used to favor early seral, fire resistant species 

composition and structure while reducing surface and ladder fuels. Under burning would be used 

to reduce activity and natural fuels in harvest units to reduce activity slash and create 

regeneration/planting spots.

Grapple Piling: Slash generated by timber harvest will be mechanically piled in units where

prescribed fire would not be effective to reduce activity slash or to create planting spots for 

regeneration. Both naturally occurring woody debris and activity generated fuels may be piled. 

 

12 Whole-tree yarding – Tops (with limbs) will be left attached to the last log and yarded to the landing, where piled 

and burned. 

13 Leave tops attached: a contract provision requiring that felled trees meeting minimum merchantability specifications 

are limbed to the minimum top diameter inside bark, bucked according to length, with the final log yarded with the unlimbed tree top attached, and which is processed at the landing. 
Final Environmental Impact Statement

Pomeroy Ranger District 39

Chainsaws may be used to compact material in the pile and throughout the unit to cut logs in 

lengths that are more easily piled. Pile size would vary and will be burned.

Landing Pile Burning: Hand ignition of landing and grapple piles would occur when the threat 

of fire spreading from the pile location would be minimal. Pile specifications would ensure that 

pile burning would have minimal damage to residual trees in the stand. Large landings piles that 

could create areas of bare soil would be replanted to native grasses.

Small Tree Removal

Small tree removal activities are included as part of the intermediate and regeneration cutting 

activities described earlier in this section. Small tree removal would be used to remove 

understory trees in an effort to reduce ladder fuels, decrease stand density, and potentially 

provide woody biomass products for local industry. Removal of ladder fuels would increase 

canopy base height and deter the initiation of a crown fire within the treated stand. Increased 

spacing of trees (reduced canopy bulk density) would result in bringing a crown fire that was 

initiated outside the stand back to the ground. Fire tolerant species (ponderosa pine, western 

larch, and Douglas-fir) would be favored as leave trees where they occur. 

In dry forest stands where under burning would follow harvest, it may be necessary to treat the

<10 inch material prior to burning so that it does not function as ladder fuel. Stands that are 

mechanically thinned would have an increased fire hazard until the resulting fuels abated either 

naturally or with prescribed fire. The needles and smaller branches would fall from severed 

stems after the first 2 to 3 years. Snow pack would help compact smaller fuels, resulting in lower 

fire potential. Methods used for small tree removal are:

Mechanical Thinning (Mastication): Consists of the cutting and mulching of trees 10 inches or 

less DBH. This treatment would be comparable to the intermediate cutting described above, 

except that trees and/or shrubs would be cut and mulched on-site as opposed to being removed 

for a commercial product.

Manual (hand) Thinning: This activity would cut trees measuring less than 10 inches DBH that 

are in excess to full stocking. Undesired trees and fuels would be slashed by hand and scattered. 

Slash would be treated so that the resulting height of surface fuels is no greater than two feet in 

depth. Fire-tolerant species (ponderosa pine, western larch, and Douglas fir) would be favored as 

leave trees where they occur. This activity may include the transfer of activity fuels from the 

base of residual and or reserve trees, and removal of ladder fuels from residual and or reserve 

trees. This may occur in landscape prescribed fire activity units, if needed, to reduce mortality to 

residual and or reserve trees. 

Landscape Prescribed Fire

Landscape prescribed fire would occur across approximately 14,055 acres within Sunrise 

planning area. This treatment would reintroduce fire within the project area’s low severity and 

mixed severity (Fire Regime I and III)14 fire-dependent ecosystems, treating about 60 percent of 

the prescribed fire area to lessen the impact of a future uncharacteristic wildfire and improve 

forage quality for big game, by reducing surface and ladder fuels, and duff accumulations, and 

 

14 Landscape prescribed burning proposed in fire regime 4 is only because of its adjacency to fire regime 1 and 3 

prescribed fire areas and is being included for holding purposes. The intent is to reintroduce and/or perpetuate fire in 

fire regime 1 and 3 which historically experienced low to mixed severity fire and 5 to 100 year fire return intervals.
Sunrise Vegetation and Fuels Project

40 Umatilla National Forest

enhancing fire-tolerant trees species. Fire intensities would be kept low by establishing backing 

fires to minimize fire in the canopy, and burning mainly surface and ladder fuels throughout the 

majority of the prescribed fire area. Individual tree and group torching would likely occur in 

areas where there are sufficient ladder fuels, and in timber stands where there are high 

occurrences of mistletoe infected trees.

All landscape prescribed fire areas are accessible by forest roads, but due to the steep terrain and 

natural fuel breaks, such as ridges and rock outcroppings, handline will be utilized along 

landscape prescribed fire area perimeters. The 14,055 acres proposed for prescribed burning are 

divided into four landscape prescribed fire areas (see Appendix A). These four areas would be 

divided further into burn blocks and may take multiple prescribed fire entries over multiple years 

to complete. Hand fireline and blackline will be utilized along burn area and burn block 

perimeters to control or stop the progression of fire. Blacklining methods would be completed by 

hand (manual methods) and in some areas by aerial ignition methods. Aerial and hand ignition 

would be utilized to ignite and establish backing fires in prescribed fire areas and burn block 

interiors. 

Danger Tree Removal

A danger tree is defined as any standing tree that presents hazard to people due to conditions 

such as, but not limited to, deterioration or physical damage to the root system, trunk, stem, or 

limbs and the direction or lean of the tree (FSH 6709.11). Along roadways, danger trees would 

be evaluated in accordance with the Field Guide for Danger Tree Identification and Response, 

Pacific Northwest Region, 2008. Hazard trees around trailheads would be evaluated in the 

context of Long Range Planning for Developed Sites in the Pacific Northwest: The Context of 

Hazard Tree Management, Pacific Northwest Region, 1992. A tree’s potential failure zone is the 

area that could be reached by any part of a failed tree. This is generally one and one-half tree 

lengths, but can vary depending on slope, tree height, lean, individual tree characteristics, and 

other factors. 

Danger trees would be felled and removed along all haul routes used for timber sale activity and 

around trailheads. Only danger trees with an imminent failure potential would be felled on 

closed system roads. Trees with an imminent failure potential and those deemed likely to fail 

within a 5-10 year period would be felled along open system roads except for sections of Forest 

Roads (FRs) 4400, 4300, and 4304 that separate Asotin Creek and Wenatchee Creek Inventoried 

Roadless Areas (IRAs) from the project planning area. Only danger trees with an imminent 

failure potential will be removed from these sections of road that are adjacent to the IRAs. (See 

Danger Trees in Glossary for definitions of imminent failure and likely to fail). Danger tree 

removal, for public safety, is part of Forest Service general road maintenance for these roads. 

Danger tree removal is currently occurring where needed on these roads, and danger trees will 

continue to be removed from 300 feet on each side of Forest Roads 4400, 4300, and 4304 as long 

as they remain open for public use. If considered economically feasible, danger trees would be 

sold as part of a timber sale. Danger trees within Riparian Habitat Conservation Areas (RHCAs) 

would be felled and left to provide additional coarse woody debris.
Final Environmental Impact Statement

Pomeroy Ranger District 41

Road Management

To accomplish implementation of proposed harvest activities approximately 52 miles of seasonal 

open system roads (operational maintenance level 215 and 316) and about 37 miles of closed 

system roads (operational maintenance level 117), would be used as haul routes on NFS lands. 

Closed system roads used for project activities would not be opened to the public during project 

activities. All system roads would remain the same after project implementation; closed roads 

would continue to be closed, and open roads would continue with preexisting designations. 

Approximately 14 miles of temporary roads would be constructed, of which 8 miles would be 

constructed over previous road templates. All temporary roads would be decommissioned after 

project activity use. No new system road construction is proposed. Detailed maps of the 

proposed activities are included in Appendix A. Road information is summarized by alternative

in the Recreation section in Chapter 3 of this EIS. 

Two existing rock sources would be used during project activities. One rock sources is located in 

T9N, R42E, S32, and the other in T7N, R44E S5, just north of the junction of FR 4304 and FR 

4305. Three water sources would be utilized; first source in T8N, R42E, S4, second source on 

FR 4302 in T8N, R43E, S28, and third source located at one of the named rock sources, is 

located in T9N., R42E., S32. All water sources would require a moderate amount of 

development to permit water use for road maintenance. Any Alternate rock sources used would 

not require expansion, but would be within an existing rock source. 

Alternative C

Alternative C was developed to more effectively respond to the key issue of wildlife habitat. 

This was due to the potential for negative effects on elk distribution and habitat quality due to 

decrease cover and security areas. This Alternative would also respond to the issues of old forest 

distribution, old forest connectivity, and snag habitat.

The types of treatment activities within Alternative C are the same as Alternative B. Alternative 

C, however, proposes fewer harvest acres and therefore, fewer roads would be needed to access 

these acres. There would be 940 acres of regeneration cutting activities, and 3,880 acres of 

intermediate cutting activities. The 940 acres of regeneration cutting would be replanted. Harvest 

would occur 2,550 acres (1,640 acres ground-based and 910 acres skyline). The same fuels 

treatment as Alternative B will be used on the smaller 2,550 acres of harvest. There would be 3

fewer miles of temporary roads. Activity within the winter range are the same as Alternative B, 

including small diameter tree cutting, fuels treatments and tree planning. 

Landscape burning would occur over the same number of acres as Alternative B. 

Devil’s Tailbone Road (4000-360) currently closes October 11, opens November 5, and closes 

again December 1. Alternative C proposes closing the gate on Forest Road 4000-360 on August 

1 to match nearby roads. Having the same closure date would reduce confusion on our travel 

maps, reduce administrative costs, and improve elk security.

 

15 Operational maintenance level 2 – The operational objective is for high clearance vehicles. 16 Operational maintenance level 3 – The operational objective is for passenger vehicles – road surface is not smooth. 17 Operational maintenance level 1 – The operational objective is closed more than 1 year.
Sunrise Vegetation and Fuels Project

42 Umatilla National Forest

Activity acres, miles, or board-feet for each action alternative for the Sunrise project are shown 

in Table 3.

Table 3. Activity acres, miles, or board-feet for each management alternative for the Sunrise project. 

Alternative A is the No-Action Alternative.

Activity Alternative A Alternative B Alternative C

Tree-cutting activities (Acres)

Intermediate cutting methods – thinning (free or low thin) 

and improvement cutting (Both alternatives include 2,210 

acres of units with a high-retention prescription)

0 5,660 3,880

Regeneration cutting – individual-tree selection, group 

selection, shelterwood or seed-tree, or clearcutting

methods

0 2,130 940

Tree-Planting 0 2,130 940

Economics

Cutting areas of likely positive appraised value (acres) 0 5,520 2,550

Cutting areas of marginal or negative appraised value 

(acres) 0 2,270 2,270

Commercial timber volume (thousand board-feet / MBF) 0 26,500 12,100

Cutting/harvest Systems (Acres)

Hand-felling, lop/scatter slash 0 2,270 2,270

Conventional ground-based (tractor or skidder) 0 3,310 1,640

Skyline 0 2,210 910

Fuels Treatments (Acres)

Whole-tree yarding/ landing-pile burning 0 5,520 2,550

Mechanical grapple-piling and burning 0 1070 330

Manual (hand) thinning / lop and scatter 0 1,680 1,150

Mechanical thinning (slash-buster/mastication) 0 590 590

Broadcast/jackpot burning of activity fuels 0 880 600

Landscape prescribed burning 0 14,055 14,055

Transportation and Access (Miles)

Gated closed roads opened for haul or project vehicle 

access, then reclosed 0 39 34

Temporary roads constructed on new template (prism) and 

post-harvest decommissioning 0 6 3

Temporary roads constructed on existing template (prism) 

and post-harvest decommissioning 0 8 5

4000-360 road closure changed to August 1 to March 31 N N Y

Note: Acres values are approximate and rounded to nearest 10 acres. Mile values are approximate and rounded to the nearest 1 mile. 

Intermediate cutting methods acres listed under Tree-Cutting Activities includes thinning and/or burning activities also listed under Fuels 

Treatments. Fuels treatments may occur alone or in combination.
Final Environmental Impact Statement

Pomeroy Ranger District 43

2.4 Project Design Criteria 

Management requirements are established to protect natural resources and the quality of the human 

environment, and include standards and practices incorporated into planned activities. The project 

design criteria (PDCs) listed in the following table include standards and/or practices that the IDT

developed during project planning and analysis to address site-specific environmental and resource 

concerns not sufficiently addressed by existing management requirements. They are tiered to the 

Forest Plan Standards and Guidelines. PDC’s are specific actions designed to address site-specific 

environmental or resource concerns that were not sufficiently addressed by existing management 

requirements. PDC’s occur during or after project implementation and can include avoiding the 

effect, minimizing the effect by limiting the action, rectifying the effect, reducing the effect through 

maintenance, or compensating for the effect. Additionally, Best Management Practices (BMP’s) are a 

standard set of general guidelines used throughout the Forest Service that are primarily intended to 

provide protections for water and aquatic resources. For purposes of clarity and simplicity, BMPs 

have been added to PDCs in a single table (Table 4). The project design criteria and BMPs apply to 

all action alternatives. 

Table 4. Project Design Criteria by Resource Objective

Design 

Criteria Description

RHCA-1

Stream and riparian protection is based on the Forest Plan as amended by PACFISH. PACFISH standards 

and guidelines related to timber harvest, roads, and fire apply to this project and are incorporated by reference 

into this document. No harvest, landings, noncommercial thinning or slash piling will take place in RHCAs 

which are described below as they apply to this project. 

Category 1 - Fish-bearing streams: RHCAs consist of the stream and the area on either side of the stream 

extending 300 feet slope distance from the edges of the active stream channel. 

Category 2 - Perennial non-fish-bearing streams: RHCAs consist of the stream and the area on either 

side of the stream extending 150 feet slope distance from the edges of the active stream channel.

Category 3 - Ponds, lakes, reservoirs, and wetlands greater than 1 acre: RHCAs consist of the body of 

water or wetland and the area to the outer edges of the riparian vegetation, or the extent of the seasonally 

saturated soil, or 150 feet slope distance from the edge of the maximum pool elevation of constructed ponds 

and reservoirs or from the edge of the wetland, pond or lake, whichever is greatest.

Category 4 - Seasonally flowing or intermittent streams, wetlands less than 1 acre, landslides, and 

landslide-prone areas: This category includes criteria with high variability in size and site-specific 

characteristics. At a minimum the RHCAs must include: the area from the edges of the stream channel,

wetland, landslide, or land-slide prone area to a distance equal to 100 feet. 

RHCA-2 Trees may be felled in RHCAs when they pose a safety risk. If possible, keep all trees on site to meet woody 

material objectives. 

RHCA-3 Prescribed Fire will not be ignited in RHCAs but will be allowed to back into RHCAs (see Protection of fish 

habitat for additional guidelines).

WQ-1

Implement and monitor Best Management Practices (BMPs) and incorporate findings into project 

implementation (See Appendix C for a listing of BMPs selected for project implementation along with 

effectiveness rating).

WQ-2

Ground based equipment will only cross ephemeral draws and channels at sites pre-approved by the 

responsible Forest official, and crossings will be minimized.

Harvest systems will be designed to minimize crossing ephemeral draws. Ephemeral draws will not be 

crossed where equipment will cause bank breakdown. Woody debris or rock may be placed into crossings to 

reduce soil disturbance and compaction. 
Sunrise Vegetation and Fuels Project

44 Umatilla National Forest

Design 

Criteria Description

All embedded wood will be retained. Other wood will be retained as specified in project design criteria for 

Wildlife.

WQ-3 Ephemeral stream channels will not be used as forwarder trails, landing sites, or as road locations.

WQ-4

As referenced under timber sale contract standard provisions B(T)6.5 “Stream course Protection and B(T)6.6 

“Erosion Prevention and Control”, commercial use of National Forest roads shall be suspended when 

commercial contract or permit operations create movement of sediment laden water from the road surface in 

areas where it could flow into stream channels. This may be from pumping of saturated fines by passage of 

commercial or contract vehicles, creating sediment laden water on the road surface during rain or snowmelt 

periods.

WQ-5

Timber sale purchaser will prepare a spill containment plan that will ensure that spilled fuel will not leave the 

site. Fuel will not be stored within any RHCA. Refueling, repair, and maintenance of equipment will be done at 

landings or on forest roads outside of RHCAs.

WQ-6 Where the proposed haul routes encounter wet areas, new drainage structures and surface rock will be 

installed.

WQ-7

Proposed temporary roads will have drainage installed if retained over-winter. Upon completion of project 

activity, roads will be obliterated using criteria in WQ-9. Berms will be pulled into the roadbed and recontoured, and the road will be revegetated with native seed and mulched with existing slash. Road entrances 

may be camouflaged to discourage use.

WQ-8

Installation and removal of culverts on Forest Road 4027016 would be bedded on native material, placed on 

natural stream grades and occur under dry conditions; slopes would be pulled back to a stable angle and soils 

stabilized as described in WQ-9.

WQ-9

The following design criteria will be used for road obliteration/decommissioning:

a) Where decommissioning crosses draws or channels, work will be done when channels are dry.

b) Draws will be contoured to match upstream and downstream channel features including: gradient, 

bankfull width and channel cross-section, and floodplain.

c) Re-contoured draws will be seeded with local, weed free native seed and mulched with on-site 

material or weed free straw or hay.

d) Roadbeds will be de-compacted and drained as necessary to prevent erosion.

e) Where full re-contour does not occur, remaining fill will be stabilized.

f) Where re-contouring occurs reconnect the surface of the cut bank slope with the re-contoured fill 

slope

Objective: Protection of Fish Habitat

FISH-1

When drafting water, sources will be monitored for reduced flows. During low flow (less than 5 cfs) conditions, 

spring-fed ponds will be used as sources prior to the use of stream sources whenever feasible. If spring-fed 

ponds are not feasible, stream sources can be used but pumping rates must not reduce flows to less than 5 

cfs. If the stream has less than 10 cfs, stream flow cannot be reduced more than 1/10th of the existing stream 

flow and will discontinue drafting if this amount is exceeded.

FISH-2

During road maintenance and snow plowing side casting of materials will not occur where these materials 

could be directly or indirectly introduced into a stream, or where the placement of these materials could 

contribute to the destabilization of the slope.

FISH-3

Slough and waste materials removed during road maintenance activities, including ditch and culvert cleaning, 

will be deposited in approved disposal areas outside of RHCAs. For erosion control and stabilization the 

disposal site will be seeded with native species. 

FISH-4 Ditches will only be maintained where the water captured by the ditch is not able to be transported to the 

adjacent drainage structure that carries the water across the road.
Final Environmental Impact Statement

Pomeroy Ranger District 45

Design 

Criteria Description

FISH-5 Prescribed fire will follow requirements in the Blue Mountain PDCs.

Objective: Protection of soil during burning

SOIL-1 Retain as much duff as possible, while meeting fuel reduction objectives to control erosion and provide 

organic matter.

SOIL-2 For jackpot or underburning, soil exposure will be limited to 20 percent or less of the area on slopes greater 

than 35%.

SOIL-3 Within RHCA mechanical fuels treatment areas soil exposure will be limited to 10 percent or less.

Objective: Erosion control on fire lines

SOIL-4

Fireline construction will only occur where necessary. Any fireline constructed will be to minimal standard 

needed to complete prescribed burning. Locations will be evaluated post-harvest. Water bars will be installed 

along fireline and all firelines will be seeded after project completion, as needed.

Objective: Soil protection and erosion control

SOIL-5 All logging systems will provide at least one-end suspension.

SOIL-6

Yarding will be spaced for optimum efficiency and minimum soil disturbance. Forwarder trails will average 50 

feet apart, except where converging. Conventional system trail spacing will average 100 feet. Skyline system 

corridors will average 100 feet apart. All trails will be approved prior to use.

SOIL-7 Use existing trail system as much as possible. Ground based equipment will operate when soil conditions are 

dry enough to support machinery adequately. 

SOIL-8 No ground-based equipment will operate on sustained slopes greater than 35% in order to reduce the 

potential for soil movement. 

SOIL-9 Minimize exposure of soils and keep erosion control current. 

SOIL-10 Landings will be designed and constructed to minimize size and provide for safe operations. 

SOIL-11

Erosion control measures will occur on all skid trails and landings, as specified under timber sale contract 

provisions B (T) 6.67 and C (T) 6.6#. Seed soil exposed by contract operations using native seed. Subsoil, 

waterbar, and mulch using existing slash as necessary to prevent erosion. 

SOIL-12 Temporary roads (Alternatives B and D) - install drainage if roads remain over-winter and will be 

decommissioned following use.

SOIL-13 If using mechanical treatment methods utilize low ground pressure equipment and existing skid trails 

wherever possible.

SOIL-14 Avoid ground equipment operations (including ATV and truck driving and parking) on unstable, wet or easily 

compacted soils and steep slopes as described per Umatilla Forest Plan.

SOIL-15 Retain sufficient slash/biomass material to provide organic matter and nutrients commensurate with existing 

technical recommendations. 

Objective: Control and prevention of invasive plants

INPLT-1

Invasive plant sites will be treated consistent with the 2005 Region 6 Invasive Plant FEIS and ROD that 

amended the Umatilla Forest Plan in March, 2006, and the July 2010 Umatilla National Forest Invasive Plant 

Treatment Project FEIS and ROD.
Sunrise Vegetation and Fuels Project

46 Umatilla National Forest

Design 

Criteria Description

INPLT-2

All gravel, fill, sand stockpiles, quarry sites, and borrow material will be inspected for the presence of invasive 

plants before use and transport. Use only gravel, fill, sand, and rock that are judged to be weed seed free by 

District or Forest weed specialist.

INPLT-3 Road blading, brushing, and ditch cleaning in areas with high concentrations of invasive plants will be 

conducted in consultation with District or Forest-level invasive plant specialists. 

INPLT-4 Invasive plant treatment and prevention practices will be incorporated as appropriate. 

INPLT-5 Project or contract maps will show currently inventoried high priority noxious weed infestations as a means of 

aiding in avoidance and/or monitoring.

INPLT-6

Prior to moving onto the Forest, reasonable measures will be taken to insure that all off-road equipment is free 

of soil, seeds, vegetative matter, or other debris that could contain or hold seeds. In addition, prior to moving 

off-road equipment from a cutting unit known to be infested with invasive species to any other unit that is 

believed to be free of noxious weeds, reasonable measures will again be taken to make sure equipment is 

free of soil, seeds, vegetative matter, or other debris that could contain or hold seeds (timber sale contract 

provision B/BT 6.35 or equivalent provision).

INPLT-7

Use state certified weed-free straw and mulch for all projects conducted or authorized by the Forest Service 

on National Forest System Lands. If state certified straw and/or mulch is not available, individual forests 

should require sources certified to be weed-free using the North American Weed Free Forage Program 

standards, or a similar certification process.

INPLT-8 Soils disturbed by project activities will be revegetated with certified weed-free native seed.

INPLT-9 Logging system design will consider the objectives of maintaining ground cover and minimizing ground 

disturbance. Forest Plan standards and guidelines for ground and soil disturbance will be followed.

INPLT-10 Landings and parking areas will be located outside known areas of invasive plants. If no other location is 

feasible the site will be surveyed and treated for noxious weeds prior to use. 

Objective: Consistency with the Clean Air Act

AIR-1 Washington State Smoke Management Plan regulations will be followed to protect air quality, avoid smoke 

intrusion into sensitive areas, and be consistent with the Clean Air Act.

Objective: protection of cultural resources

ARCH-1

Historic properties will either be avoided by all project activities (this includes access to treatment areas and 

landing sites) or by site-specific mitigation measures approved by the assistant Forest Archeologist and 

SHPO.

ARCH-2 Since some project activities will be implemented over multiple years, project leaders will contact the North 

Zone Archaeologist prior to project implementation for monitoring and avoidance purposes.

Objective: Populations of Federally listed and Forest Service designated sensitive plant species and unique 

plant habitats.

BOT-1

Populations of Federally listed and Forest Service designated sensitive plant species that are in, or near, 

areas with proposed ground disturbing activities shall be designated as “Special Management Areas” (SMAs). 

These sites shall be buffered and protected from all ground disturbances. Vehicle and equipment parking, log 

decking, yarding, slash piling and burning, and construction of fire lines shall be prohibited within these areas. 

SMAs shall be clearly marked on sale maps, and on implementation planning maps. SMAs may be flagged on 

the ground prior to treatment. A botanist may assist with unit layout in areas where the SMAs occur. Aerial, 

hand, or vehicle-based fire ignition in areas with populations of sensitive plants may be done in consultation

with a botanist. This would depend upon the particular species expected response to fire. 

Any additional populations of Federally listed and FS sensitive plants discovered during field surveys shall be 

evaluated for the need to be designated as SMAs.
Final Environmental Impact Statement

Pomeroy Ranger District 47

Design 

Criteria Description

Timber sale administrator and/or implementing staff shall notify botany staff when activities are scheduled to 

begin in areas where SMAs are designated.

BOT-2

Pre-implementation monitoring of selected high probability habitats for Federally listed and Forest Service 

designated sensitive plants shall be conducted in specific areas of proposed activities. These shall be 

determined based upon potential habitat and the potential risk to rare plants due to the proposed activities.

BOT-3

All documented, and any newly discovered, populations of Spalding’s catchfly shall be excluded from all 

burning activities. Routes for motorized off road access in Spalding’s catchfly habitat shall be preapproved by 

qualified botany personnel. All proposed fire-lines in Spalding’s catchfly habitat shall be field surveyed and 

approved by qualified botany personnel.

BOT-4

Protect unique habitats: lithosols (scablands), seeps, springs, wallows, and wetland areas (including wet 

meadows) from harvest activities. Buffer riparian and wetland areas in accordance with PACFISH buffers. Log 

decking, piling, and burning of slash piles shall not occur in these areas. If caves, cliff faces, or other unique 

habitats not listed above are encountered during recon or layout, their value to wildlife and botany would be 

evaluated, and appropriate protection, as determined by the District Wildlife Biologist and botanist, would be 

provided.

BOT-5 Require harvest operators to work with the timber sale administrator to identify stands of mountain mahogany, 

and to minimize disturbance to the trees from mechanical equipment.

FUELS-1 Slash will not be piled against large trees or snags to prevent loss from prescribed fire.

FUELS-2

Where open, park-like conditions occurred historically (pre-settlement areas characterized by frequent, lowseverity fire regimes), maintain such conditions by implementing intermediate treatments and/or emphasize 

the removal of fire-intolerant species. 

FUELS-3 When conducting prescribed burning, do not light within, or encourage fire to burn into, stands of mountain 

mahogany

VEG-1 Maintain all live trees ≥ 21" dbh that currently exist within stands proposed for harvest activities.

VEG-2 All tree-cutting activities occurring in existing old forest will emphasize the retention of individual trees and tree 

species sufficient to maintain minimum requirements for old forest, as described in the Forest Plan.

VEG-3

In stands that do not meet current late and old structural conditions, manipulate vegetative structure in such a 

manner that moves it towards those conditions, as appropriate to meet HRV within the applicable biophysical

environment of the forest vegetation affected environment.

VEG-4

For even-aged stands on lands identified as suited for timber production and where timber production is the 

primary purpose for the harvest, do not prescribe regeneration activities unless stand-level growth has 

reached the culmination of mean annual increment.

WILD Prescriptions for habitat connectivity corridors must ensure the retention of some amount of understory (if any 

occurs) left in patches or scattered to assist in supporting stand density and cover.

WILD Leave all hollow or partially hollow, broken-top snags greater than 15 inches DBH to provide roost habitat for 

bats. Dead grand fir most commonly provides hollow tree habitat.

WILD

Protect goshawk nests from disturbance if any are located during project activities. Defer harvest on 30 acres 

of the most suitable nesting habitat around nest sites. Retain late and old structure forest in a 400-acre postfledging area (PFA) as determined by the District wildlife biologist. Defer activities in active PFAs from April 

through August.

WILD Seeps, springs, bogs, wallows, and other wet areas will be evaluated and protection measures determined by 

the District wildlife biologist (Forest Plan pages 4-57, 4-160).

WILD If cliffs, talus or cave habitat is found, protection measures will be determined by the District wildlife biologist. 

(Forest Plan pages 4-57)
Sunrise Vegetation and Fuels Project

48 Umatilla National Forest

Design 

Criteria Description

WILD

Retain all snags 20 inches DBH and larger, except for hazard trees. If there are less than 3 large snags per 

acre available, smaller snags will be retained to meet 3 per acre. Maintain down wood habitat and green 

replacement trees at or beyond levels identified below. Tree species and soundness at the base will also be 

considered. The tree species most preferred are ponderosa pine, western larch, and Douglas-fir. Specific 

design criteria for snags, green tree replacements, and down wood are as follows: 

Ponderosa 

pine

Mixed 

conifer Grand fir Lodgepole pine

Subalpine 

zone

Leave all snags 20 inches dbh and 

larger. If unavailable, leave at least 3 

per acre over 10 inches dbh.

All > 20 All > 20 All > 20 All > 20 All > 20

Green Tree Replacements (per acre) 16 16 9 14 19

Down Wood Pieces (per acre) 3 - 6 15 - 20 15 - 20

Diameter at the small end > 12 

inches > 12 inches > 8 inches

Length per piece > 6 feet > 6 feet > 8 feet

Total length per acre > 20 feet > 100 feet > 120 feet

WILD

Protect known or discovered raptor nest sites from management and human disturbances until fledging has 

been completed. Level of protection will vary by species and will be recommended by the District wildlife 

biologist (Forest Plan pages 4-57).

WILD Prescriptions for habitat connectivity corridors must maintain abundant medium diameter or larger trees, with 

total canopy closures within the top one-third (33%) of site potential.

WILD Avoid prescribed burning during the mostly likely time that birds are nesting, May 15 – July 5. 

WILD Do not create forest openings18 through even-aged cutting methods that exceed 40 acres in size, unless 

allowed by exceptions provided in the Forest Plan.

SCEN-1

Create natural appearing opening(s) when viewed individually and a natural appearing mosaic when viewed 

within the broader landscape.

a) Created openings and treatment units should not be symmetrical, or geometric in shape. 

b) Straight lines and right angles should be avoided. 

c) Created openings should resemble the size and shape of those found in the surrounding natural 

landscape. 

d) Treatments should follow natural topographic breaks and changes in vegetation. 

e) Where small landforms exist, consider treating the entire landform rather than creating artificial lines 

and patterns. 

f) Along sensitive roadways, vary unit sizes, widths, shapes and distance from the center line. 

SCEN-2

Create natural appearing transition between treated and untreated vegetation.

a) Utilize natural breaks in topography and vegetation type to delineate treatment edges. 

b) Edges will be shaped and/or feathered to avoid a shadowing effect in the cut unit. 

c) Where the unit is adjacent to denser forest, the percent of thinning within the transition zone will be 

progressively reduced toward the outside edge of the unit. In addition, vary the width of the 

transition zone. 

 

18 A harvested area is considered a created opening for timber management when the prescribed crop tree stocking is below minimum 

acceptable levels and trees are at or below 4 1⁄2 feet in height and/or not free to grow.
Final Environmental Impact Statement

Pomeroy Ranger District 49

Design 

Criteria Description

d) Where the unit interfaces with an opening, the percent of thinning within the transition zone will be 

progressively increased toward the outside edge of the unit. In addition, vary the width of the 

transition zone. 

e) Soften edges by thinning adjacent to existing unit boundaries, removing taller, older trees and 

favoring younger ones. 2 This will reduce a vertical wall effect. 

f) Treatment boundaries should extend up and over ridgelines to avoid the “Mohawk” look. This is 

especially important along ridgelines silhouetted against the sky. 

g) Avoid widely spaced trees that are silhouetted along the skyline. 

h) Consider leaving single trees and/or groups of trees to visually connect with the unit’s edges.

SCEN-3

Minimize patterns created by implementation and maintain natural appearing mosaic of vegetation across the 

landscape.

a) Where multiple clear cuts are planned, vary the size and spacing across the project area. 

b) Interlock individual openings to prevent artificial, isolated openings unrelated to topography or 

natural disturbance processes. 

SCEN-4

Maximize diversity of species and age class that are within the landscape’s natural range of variation/Forest 

Plan Desired Condition. 

a) Where feasible, leave a diversity of species and age classes.

b) Leave healthy, windthrow-resistant trees and groups of trees to add variety and interest. 

c) A range of stem diameters should be left where compatible with silvicultural objectives. 

SCEN-5

Minimize long-term visual effects of access roads, skid trails, and landings.

a) Side cast topsoil during the construction of temporary roads and use for later obliteration and 

recontouring. 

b) Where new access roads and skid trails meet FSRD 40, they should intersect at a right angle and, 

where feasible, curve after the junction to minimize the length of route seen from the primary travel 

route. 

c) Where feasible, retain screening trees one tree-height below roads and landings (including cable 

landings) when viewed from below. Avoid creating a straight edge of trees by saving clumps of 

trees and single trees with varied spacing.

d) When viewed from above, retain, screening trees one tree-height above roads and landings and/or 

prescribe a higher leave basal area. Avoid creating a straight edge of trees by saving clumps of 

trees and single trees with varied spacing.

e) Log landings, roads, gravel pits, borrow areas, and bladed skid trails should be minimized within the 

FSRD 40 viewshed.

SCEN-6

Minimize slash piles and residue that appears man-made. 

a) Ensure slash is abated near landings by scattering, chipping, or other techniques.

b) In sensitive foreground areas, stumps should be cut to 6 inches or less in height, in immediate 

foreground, stumps should be cut to 2 inches or less in height.

c) Slash, root wads, and other debris will be removed, buried, burned, chipped or lopped to a height of 

2 feet or less in sensitive view sheds. If slash is buried, locate in previously disturbed areas where 

possible.

SCEN-7

Minimize the long term visual effects of skyline operations. 

a) Minimize the number of skyline corridors in visually sensitive areas. 

SCEN-8

Maintain a forest floor that appears natural and clear of excessive debris.

a) In the immediate foreground (300 feet from FSRD 40Fuel loadings meeting reforestation and 

wildlife standards in middleground and background areas will normally be compatible with the visual 

objectives.
Sunrise Vegetation and Fuels Project

50 Umatilla National Forest

2.5 Alternatives Considered but Eliminated from Detailed

Analyses

After consideration of all scoping comments as well as internal analysis, the three alternatives 

discussed in this chapter were finalized. There were no other alternatives proposed for consideration 

and subsequently dismissed. 

2.6 Monitoring Framework

Monitoring for both implementation (whether the project was implemented as planned) and 

effectiveness (whether overall management objectives were met) would occur. Design criteria and 

Best Management Practices are incorporated into the project (Table 4). 

Any action which might occur in this planning area will be considered for monitoring in the Umatilla 

National Forest annual BMP monitoring. District staff will conduct monitoring in areas that have the 

highest probability of showing effects. 

• RHCA widths in harvest units, road maintenance work, and road use and maintenance during wet 

weather are items that will be monitored. 

• The Forest Service contract representative or other staff will monitor during and after activities to 

insure sediment and soil disturbance objectives are met. If objectives are not met, Forest Service 

personnel will identify and implement corrective action and document modifications to be used in 

future projects. 

• Number, size, and distribution of snags and down logs within a sample of units will be field checked 

by Forest Service personnel. 

• Known invasive plant locations are identified prior to activities and will be re-assessed after project 

implementation where applicable. 

• After prescribed fire treatments, Forest Service fire and fuel personnel will field check a sample of 

burned units to determine whether the prescription objectives (i.e. mortality, mineral soil exposure, 

fuel load reductions, etc.) have been met. 
Final Environmental Impact Statement

Pomeroy Ranger District 51

Chapter 3. Environmental Consequences

3.1 Introduction

This Environmental Consequences Chapter analyzes both beneficial and adverse effects that would 

result from implementing any of the alternatives considered in this DEIS. In accomplishment of these 

analyses, each resource section will describe the affected environment specific to that resource, as 

well as the effect analysis of each alternative, resource specific mitigation measures, and the 

cumulative effects. 

Past, present, and reasonably foreseeable actions and affected environment of area resources are also 

mentioned, as described in Chapter 2.

Effects are shown as being direct (occurring at the same time and plane as the triggering action), 

indirect (separate in time or space from the action that caused them), or cumulative (incremental 

effect of the project when added to effects from other past, present, and reasonably foreseeable 

actions). Each resource specialist considered and included activities relevant to the individual 

resource in the cumulative effects analysis. Direct, indirect, and cumulative effects are described in 

terms of increases, decreases, intensity, duration, and timing. The discussion of these effects also 

provides a comparison of the trade-offs associated with each alternative. Relevant direction from 

Umatilla Land and Resource Management Plan (Forest Plan) and applicable laws, regulations, and 

agency policies are also discussed in this chapter. The scale of analysis may be different for each 

resource. This chapter ends with a discussion of compliance with environmental laws and executive 

orders. 

3.2 Effects and Impacts

For the purpose of this EIS, it is imperative to explain the difference between effects and impacts, and 

how they are used in this document. For the purpose of this document, an effect from an action can be 

beneficial, adverse, or negligible. An impact, as used in this document, implies greater magnitude and 

is used to describe either beneficial or adverse conditions. That is, an action can effect a resource, but 

the action may not rise to the level of an impact to the resource. Effects and impacts are not used 

interchangeably in this document.

3.3 (Reserved)

3.4 General Analyses Methodology and Assumptions

This chapter evaluates effects on the human environment (i.e., physical, natural, cultural, and 

socioeconomic resources) from proposed vegetation and fuels management alternatives. The 

approach includes the following elements:

• Focusing the analysis, to the greatest extent possible, on management changes and associated issues 

that could have meaningful impacts on the resources or values being evaluated.

• Using general analysis methods and assumptions that follow the USDA Forest Service National 

Environmental Policy Act Handbook (FS 2014).

• Evaluating cumulative effects for each resource topic.

• The importance and severity of effects from management activities are assessed and described in 

each resource topic as applicable. If effects are not likely to be significant, no determination on 

significance is provided.
Sunrise Vegetation and Fuels Project

52 Umatilla National Forest

The Interdisciplinary team reviewed a substantial body of scientific literature and studies applicable 

to the project areas and the associated resources. This information augments site-specific field studies, 

observations, and documentation gathered by IDT members to support the quantitative and qualitative 

statement presented for each analyzed resource. The effect analyses focuses on perceived or expected 

environmental issues from the implementation of the alternatives and their likelihood of being 

significant. 

Assessing Effects and Impacts Using CEQ Criteria

According to the Council on Environmental Quality (CEQ) NEPA regulations (40 CFR 1500-1508) 

the term significantly is based on the criteria of both context and intensity (40 CFR 1508.27).

Context: This means that the significance of an action must be analyzed in several contexts to include 

society as a whole (human, national), the affected region, the affected interests, and the locality. 

Significance varies with the setting of the proposed action. Both short term and long term 

effects/impacts are relevant.

Intensity: This refers to the severity of magnitude of an effect. An EIS considers direct, indirect, and 

cumulative effects to determine intensity. The CEQ has identified set standards for conducting and 

presenting impact analysis.

Assumptions

The following guiding assumptions were used to provide context for this analysis:

Analyses Period: This DEIS considered management actions over 5-10 years, however, as long as 

there are no substantial changes to the proposed action that are relevant to environmental concerns, no 

new information and no changed conditions, management activities may continue without additional 

NEPA analyses. 

Duration of Effect: Duration describes the length of time over which an effect may occur. Effects

could occur over minutes, days, months, or years. Each analyses includes a description of the 

expected time frame over which effects are expected. 

Type of Effect: Description of the effect as beneficial or adverse. A beneficial effect is one which 

moves current conditions found in the project area to conditions more in line with historical norms. 

While an adverse effect would be something that would negatively affect conditions found in the 

project area beyond the current conditions. While the current conditions are not necessarily desired, 

an adverse condition would be a further step backward. These effects however, have elements of 

duration, intensity, and magnitude as part of their analysis, meaning for examples they could be short 

term, minor, and beneficial effects. 
Final Environmental Impact Statement

Pomeroy Ranger District 53

3.5 Cumulative Effects

Past, Present, and Reasonably Foreseeable Actions

The temporal and spatial scale of analysis is variable depending on the resource concern being 

evaluated, particularly when considering the effects of past, present, and reasonably foreseeable 

actions. During the interdisciplinary process the team followed guidance provided by the CEQ. Using 

this guidance the following summary of past, present, and reasonably foreseeable actions within and 

adjacent to Sunrise Vegetation and Fuels Management Project planning area was developed. These 

projects were considered, where relevant, when addressing cumulative effects for various resources.

Cumulative impact (or effect) is defined in CEQ regulations as, “...the impact on the environment 

which results from the incremental impact of the action when added to other past, present, and 

reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person 

undertakes such other actions. Cumulative impacts can result from individually minor but collectively 

significant actions taking place over a period of time” (40 CFR 1508.7).

Summary of Past Actions

Some residual effects remain visible on the landscape and contribute to the description of the current 

conditions (affected environment). Past actions are maintained as a layer in the District’s Geographic 

Information System (GIS) database and are used in analysis for multiple forest-wide management 

goals including: calculating Equivalent Treatment Acres for watershed conditions, elk habitat

effectiveness index (HEI), cover values for big game, soil conditions, and historic range of variability

(HRV). In some cases, the activities listed below in Table 5 overlap in space. 

• Planting: Approximately 3,812 acres were planted between 1967 and 2011.

• Invasive Plant Treatments (Non-Mechanical): Approximately 2,448 acres were treated between 

2006 and 2015 within the planning area.

• Wildfire: Since 1910 approximately 10,781 acres, by 107 fires, have burned in the Sunrise planning 

area. Wildfire is unpredictable, but it is likely some portion of the planning area could burn in the 

foreseeable future.

• Grazing: Asotin C&H Allotment - Grazing has occurred at various levels beginning in the mid1800s. Wild horses used the area from 1885 to 1910. The average amount of permitted livestock 

grazing from 1929 to 1964 was 815 head of cattle. Range improvements include: 28 springs, 29 

ponds, 3 corrals, and 18 miles of fence (includes boundary fence) within the project planning area. 

Peola Allotment - grazing allotment totaling 39,238 acres with a seasonal total of 355 pair of cattle 

located in Asotin, Columbia and Garfield counties.
Sunrise Vegetation and Fuels Project

54 Umatilla National Forest

Table 5. Past Vegetation Management Activities by Decade within the Sunrise project Area

Years Treatment Acres

1960 - 1969 Pre-commercial Thin

Pre-commercial Thin

Single-Tree Selection

Stand Clearcut

155

155

1,345

3,313

1970 - 1979 Commercial Thin

Pre-commercial Thin

Salvage Cut

Sanitation Cut

Shelterwood Cut

Single-tree Selection

Stand Clearcut

1,131

1,220

537

143

486

4,372

2,626

1980-1989 Pile Burning

Commercial Thin

Pre-commercial Thin

Range Seeding

Sanitation Cut

Shelterwood Cut

Single-tree Selection

Stand Clearcut

131

104

148

365

617

1,697

612

377

1990-1999 Broadcast Burning

Pile Burning

Overstory Removal Cut

Pre-commercial Thin

Range Seeding

Shelterwood Cut

Single-tree Selection

Stand Clearcut

Underburn

1,259

987

64

1,588

550

796

1,413

1,227

5,040

2000-2009 Pile Burning

Chipping of Fuels

Commercial Thinning

Fuel Break

Pre-commercial Thin

Rearrangement of Fuels

Salvage Cut

Single-tree Selection

Site Preparation

Underburn

40

11

47

217

840

483

26

14

329

4266

2010-2016 Pile Burning

Chipping of Fuels

Invasive Mechanical

Jackpot Burning

Pre-commercial Thin

Salvage Cut

Thinning

Underburn

Yarding

17

240

109

45

309

188

2

550

188
Final Environmental Impact Statement

Pomeroy Ranger District 55

Summary of Present Actions (ongoing)

• Invasive Plant Treatments: Umatilla National Forest Invasive Plants Treatment FEIS and Record 

of Decision (ROD) (July 2010) will continue to be implemented. Invasive plant treatments 

(herbicide, hand pulling and biological agent release) is currently being done. Where appropriate, 

treated areas are seeded with local sources of native grasses and forbs after treatment.

• Recreation: Ongoing use of dispersed camping, hunting, and sightseeing occurs year-round. Public 

firewood gathering and snowmobile use will continue to occur.

• Road Maintenance: Road maintenance consists of a variety of activity components including 

surface rock replacement, spot surfacing, roadside brushing, erosion control, logging out, road 

surface blading, ditch cleanout, slide removal, dust abatement, culvert cleaning or replacement, 

danger tree removal, and other items that contribute to the preservation of the existing road and its 

safe use.

• Asotin Prescribed Burn: Project consisting of 7,957 acres of Forest Service land 2,423 acres of 

Washington Fish and Wildlife (WDFW) land. Proposed treatments are located in the Asotin Creek 

Watershed and within Forest Plan Management Areas that allow prescribed fire.

• Grazing: Asotin C&H Allotment: The current number of permitted cow/calf pairs has been 495 

since 1965, however, only 413 cow/calf pairs have actually grazed the allotment from 1995 to the 

present. The allotment area totals approximately 39,400 acres, of which about 21,000 acres are 

within the project planning area. Currently used pastures include the Park/Cook and Hogback 

pastures, totaling approximately 1,770 acres. Peola Allotment – The grazing allotment totaling 

39,238 acres, includes the Lick and Charley pastures (8,000 acres), with a seasonal total of 355 pair 

of cattle.

Summary of Reasonably Foreseeable Actions

• Invasive Plant Treatments: The 2,448 acres mentioned above plus an additional 3 percent of acres 

are planned for herbicide treatments based on current increases being noted. Where appropriate, 

treated areas will be seeded with local sources of native grasses and forbs after treatment.

• Asotin Prescribed Burn: This burn, as described above, is an ongoing fuels management project. 

The total prescribed acres will take multiple seasons to treat, and is therefore a foreseeable action 

as well.

• Elk habitat projects: Seeding and fertilizing key areas to enhance elk forage.

• Road Maintenance: Road maintenance would continue to be the same as identified above in 

ongoing activities. 

• Recreation: Recreation use would continue to be the same as identified above in on-going 

activities.

Final Environmental Impact Statement

Pomeroy Ranger District 57

3.6 Vegetation

A summary of the current conditions of the affected environment and the predicted effects of the 

Proposed Action and its alternatives are discussed in this section. Specific information on the 

methodologies, assumptions, and limitations of analysis and other details are contained in the Sunrise 

silviculture specialist’s report, incorporated herein by reference, and available to the public on the 

project webpage at http://www.fs.fed.us/nepa/fs-usda-pop.php/?project=45689. 

Introduction

The purpose of this section is to look at the current conditions and the effects of the Sunrise 

Vegetation and Fuels Management Project on the vegetation in the project area. The Silvicultural 

conditions within the project area can best be described by examining species composition, structural 

stages, and forest density. The action alternatives were designed to move the existing conditions in the 

project area towards the desired conditions.

Regulatory Framework

This project is consistent with all applicable laws, rules, and regulations pertaining to National Forest 

vegetation affected by the decision alternatives. For a more detailed description of how this project 

meets the applicable laws please refer to the Silviculture Report.

The most important factor influencing whether, or to what degree, a forested area might be affected 

during implementation of an action alternative is management direction from the 1990 Land and 

Resource Management Plan for the Umatilla National Forest (Forest Plan). The Sunrise project area

includes several Forest Plan Management Areas, with additional designation for Riparian Habitat 

Conservation Areas (RHCAs) adjoining rivers, streams, and other wetlands. This Forest-wide riparian 

habitat allocation is referred to as PACFISH (USDA Forest Service; USDI Bureau of Land 

Management 1995). Forest-wide and Management Area direction is incorporated by reference into 

this document. Additional vegetation management direction is provided by two amendments in 

particular: “Interim Management Direction Establishing Riparian, Ecosystem and Wildlife Standards 

for Timber Sales” (USDA Forest Service 1995; also known as Eastside Screens); and “Interim 

Strategies for Managing Anadromous Fish-Producing Watersheds on Federal Lands in Eastern 

Oregon and Washington, Idaho and Portions of California” (USDA Forest Service; USDI Bureau of 

Land Management 1995; also known as PACFISH).

Methodology 

The Sunrise Vegetation and Fuels Management analysis area is defined in this report as all forested 

Umatilla National Forest lands in the North Fork Asotin and Lick Creek watersheds. This area is 

approximately 22,800 acres which includes all dry, moist, and cold uplands forest in the project area. 

The greater Sunrise Project Area includes both forested and non-forested areas and is approximately 

33,150 acres in size. For the temporal context of this analysis, short-term will be defined as up to 10 

years following the implementation for the activities and long-term will be defined as anytime time 

beyond that.

Indicators used for comparison purposes between alternatives include the following:

• Forest vegetation species cover type: the tree species or species group that occupies a majority or 

plurality of total canopy cover. 

• Forest vegetation structural stage: the vertical architecture of coniferous vegetation occurring along 
Sunrise Vegetation and Fuels Project

58 Umatilla National Forest

a successional pathway. 

• Forest vegetation density class: the relative occupancy of available site resources by coniferous 

forest vegetation, allocated into discrete classes by biophysical environment.

The methodology utilized to assess and disclose the existing conditions, direct, indirect, and

cumulative effects of the activities included under the project’s action alternatives incorporated a 

variety of information sources. Any particular assessment method is associated with a set of both 

strengths (accuracy and precision) and weaknesses (uncertainty and error). This analysis of effects on 

forest vegetation resources derives assessment and analytical strength through multiple lines of 

evidence (Goetz et al. 2012). The various methods utilized for this report are described in detail in the 

Silviculture Specialist Report, along with their associated strengths and weaknesses. The methods are 

characterized in terms relevant to successful implementation of the National Environmental Policy 

Act and associated case law, which require or recommend that disclosure of environmental effects 

include consideration and discussion of data validation and error, use of methods standard in the field 

relevant to the resource being considered (in this case, forestry), and incomplete and/or unavailable 

information. 

As with any assessment of forest vegetation and activity effects, this analysis is associated with 

incomplete and unavailable information, the most relevant and noteworthy of which is associated 

with either direct project effects, or indirect and cumulative effects. Incomplete and/or unavailable 

information associated with direct effects on forest vegetation include incomplete measurements (not 

every tree, shrub, forb, or graminoid is carefully measured), as well as uncertainty of project activity 

impacts: no one can know in the future exactly which trees will be harvested, what harvest impacts 

may occur (tree rubbing), or how broadcast burning activities will affect each and every plant. Future 

indirect and cumulative effects are also partially obscured by incomplete or unavailable information 

relating to uncertainty regarding impacts from future climate, insects, diseases, tree regeneration 

patterns, abiotic factors (extreme weather, comets, meteors, wildfires, earthquakes), and human 

activities not included within the cumulative effects analysis in this report.

Affected Environment

The Sunrise project area totals 33,150 acres, of which 22,800 acres is dry, moist, and cold uplands 

forest.

Species Composition

The current composition and extent of forest species cover types within the Project Forest Analysis 

Area and a comparison between existing conditions and desired ranges are shown in Table 6. Desired 

conditions are stratified by biophysical environment (dry, moist, and cold upland forest potential 

vegetation groups), as well as cover type extent and relative abundance. In general, cover types are 

defined by the tree species (or species group) that constitute a majority or plurality of occupied 

growing space in a delineated forest stand

The existing cover types are dominated by late seral tree species and forest stands dominated by early 

seral species are under-represented (Table 6). Some old forests have shifted in both species 

composition and structure; for example, some ponderosa pine forests with an old forest-single stratum 

structure have shifted to a Douglas-fir cover type with an old forest multi strata structure. This 

undesirable condition is caused by combination of factors described further in the specialist report.
Final Environmental Impact Statement

Pomeroy Ranger District 59

In the dry upland forest portion of the Sunrise project area, the Douglas-fir cover type currently 

exceeds the desired range, while the ponderosa pine cover type is below the desired range. Grand fir 

cover type is at the high end of the desired range. In the moist upland forest, the extent of Douglas-fir 

and Subalpine fir/spruce cover type currently exceed desired ranges, while the western larch and 

lodgepole pine cover types are less than desired ranges. In the cold upland forest, the extent of 

subalpine fir/spruce and Douglas-fir cover types currently exceed desired ranges, and the extent of 

lodgepole pine cover types are currently below desired ranges.

Table 6. Tree species cover type extent and distribution for forest Potential Vegetation Groups (PVGs) 

within the Sunrise Project Vegetation Analysis Area. Values listed in bold font currently exceed desired 

ranges; items in italics are currently below desired ranges.

Existing conditions Desired Range

Percent Acres

Species cover type / PVG Tolerance class Acres % of total Low High Low High

Dry Upland Forest

Western juniper Shade-intolerant 0 0 0 5 0 560

Ponderosa pine Shade-intolerant 3793 34 50 80 5597 8956

Douglas-fir Mixed-tolerant 5806 52 5 20 560 2239

Western larch Shade-intolerant 68 1 1 10 112 1119

Broadleaved trees Shade-intolerant 0 0 0 5 0 560

Lodgepole pine Shade-intolerant 19 <1 0 0 0 0

Western white pine Mixed-tolerant 0 0 0 5 0 560

Grand fir Shade-tolerant 1116 10 1 10 112 1119

Subalpine fir and spruce Shade-tolerant 73 1 0 0 0 0

Total 11,195

Moist Upland Forest

Western juniper Shade-intolerant 0 0 0 0 0 0

Ponderosa pine Shade-intolerant 1292 13 5 15 499 1498

Douglas-fir Mixed-tolerant 3325 33 15 30 1498 2995

Western larch Shade-intolerant 204 2 10 30 998 2995

Broadleaved trees Shade-intolerant 0 0 1 10 100 998

Lodgepole pine Shade-intolerant 1053 11 25 45 2496 4493

Western white pine Mixed-tolerant 0 0 0 5 0 499

Grand fir Shade-tolerant 1853 19 15 30 1498 2995

Subalpine fir and spruce Shade-tolerant 2230 22 1 10 100 998

Total 9,983

Cold Upland Forest

Grass-forb Not applicable 0 0 0 5 0 81

Shrub Not applicable 0 0 0 15 0 243

Western juniper Shade-intolerant 0 0 0 0 0 0

Ponderosa pine Shade-intolerant 0 0 0 5 0 81

Douglas-fir Mixed-tolerant 295 18 5 15 81 243

Western larch Shade-intolerant 74 5 5 15 81 243

Broadleaved trees Shade-intolerant 0 0 0 5 0 81

Lodgepole pine Shade-intolerant 129 8 25 45 406 730

Western white pine Mixed-tolerant 0 0 0 0 0 0

Grand fir Shade-tolerant 121 7 5 15 81 243

Subalpine fir and spruce Shade-tolerant 1003 62 15 35 243 568

Total 1,622

Forest Structural Stages

The existing structural stages in the Sunrise project area generally reflects the succession, vegetation 

growth, and lack of recent disturbance. Structural stages that are created by recent and regular 

intervals of disturbance are under-represented and structural stages representing a lack of disturbance 

are over-represented. Table 7 displays the existing and desired conditions for forest structural stages 
Sunrise Vegetation and Fuels Project

60 Umatilla National Forest

within each upland forest potential vegetation group for the project area. For further information on 

structural stages and how they are derived please refer to the Silviculture Specialist report.

In the dry upland forest, the understory reinitiation and old forest multi-strata structures currently 

exceed desired ranges, and the extent of stand initiation, stem exclusion, and old forest single stratum 

structural stages are below desired ranges. In the moist upland forest, the old forest multi-strata 

structural stage currently exceeds the desired range, and the extent of old forest single stratum 

structural stage is below the desired range. In the cold upland forest, the understory reinitiation and 

old forest multi-strata structural stages currently exceed desired ranges, and the extent of stem 

exclusion and old forest single stratum structural stages are below desired ranges. Table 7 shows the 

existing and desired extent of each structural stage in the project area.

Table 7. Forest structural stage extent and distribution for forest Potential Vegetation Groups (PVGs) 

within the Sunrise project Vegetation Analysis Area. Values listed in bold font currently exceed desired 

ranges; items in italics are currently fall below desired ranges.

Existing Conditions Desired Conditions

Percent of PVG Acres

Acres % of total Low High Low High

Dry Upland Forest

Stand Initiation 432 4 15 30 1,647 3,293

Stem Exclusion 965 9 10 20 1,098 2,195

Understory Reinitiation 2,288 21 0 5 0 549

Old Forest Single-Stratum 843 8 40 65 4,391 7,135

Old Forest Multi-Strata 6,450 59 1 15 110 1,647

Total 10,977

Moist Upland Forest

Stand Initiation 1,691 17 20 30 1,993 2,989

Stem Exclusion 1,629 16 20 30 1,993 2,989

Understory Reinitiation 1,467 15 15 25 1,494 2,491

Old Forest Single-Stratum 22 <1 10 20 996 1,993

Old Forest Multi-Strata 5,153 52 15 20 1,494 1,993

Total 9,963

Cold Upland Forest

Stand Initiation 387 24 20 45 317 713

Stem Exclusion 96 6 15 30 238 475

Understory Reinitiation 655 41 10 25 158 396

Old Forest Single-Stratum 25 2 5 20 79 317

Old Forest Multi-Strata 422 27 10 25 158 396

Total 1,584

Note: Total forested acres for each potential vegetation group may differ than total acres reported in Table 4 because they do 

not include bare ground and other non-forest locations classified under a potential forested vegetation group. 

Forest Density

Stand density refers to a measure of the amount of tree vegetation per unit of land area. The current 

and desired type and extent of forest vegetation structural stages within the Sunrise project area are 

described in Table 8. Desired conditions are stratified by biophysical environment and forest density 

classes. Across all biophysical environment types high density is over represented while low and 

moderate density classes are below the desired range.
Final Environmental Impact Statement

Pomeroy Ranger District 61

Table 8 Forest density class extent and distribution for forest Potential Vegetation Groups (PVG) within 

Sunrise Vegetation Analysis Area. Values listed in bold currently exceed desired ranges; items in italics 

are currently below desired ranges.

Existing Conditions

Desired Conditions

Percent of PVG Acres

Acres % of total Low High Low High

Dry Upland Forest

Low 695 6 40 85 4.448 9,453

Moderate 1,605 14 10 15 1,668 3,336

High 8821 79 0 5 556 1,668

Total 11,121

Moist Upland Forest

Low 773 8 20 40 1,997 3,993

Moderate 2,012 20 25 60 2,496 5,990

High 7,190 72 15 30 1,498 2,995

Total 9,963

Cold Upland Forest

Low 47 3 15 30 243 486

Moderate 186 11 20 40 324 649

High 1,390 86 25 60 405 973

Total 1,622

Atmospheric Greenhouse Gas Emissions

See Chapter 3, Cumulative Effects, Global Climate Change.

Environmental Consequences 

Direct and Indirect Effects

Alternative A (No Action)

Under the project No Action Alternative, ongoing disturbance and succession processes influencing 

vegetation conditions in the Sunrise area would continue as they have in the recent past without 

additional treatment. If none of the proposed activities would be implemented to move existing 

conditions closer to desired conditions, then forest vegetation within the project planning area would 

remain excessively dense and continue to be dominated by mid- and late-seral stages of species 

composition. Old forest single-strata structure on moist-forest sites would continue to be deficient 

because proposed activities would not be used to increase tree growth and thereby promote largediameter trees (trees whose diameter is 21 inches or greater), or to reduce stand density sufficiently 

for establishment of a new cohort (stratum) of understory trees. Vegetation within the area would also 

become more susceptible to insect, dwarf mistletoe, disease and wildfire disturbances. 

Alternative B

Species composition

Alternative B emphasizes the retention of early seral species and the removal of late seral species 

across all three biophysical environments. Changes in species composition would vary based on the 

existing composition of the stand and amount of overstory cut or killed by fire application. In this 

section there will be references to “mix” stands. These are stands in which activity is not likely to 
Sunrise Vegetation and Fuels Project

62 Umatilla National Forest

change the current species majority, but is likely to create growing space for more desirable early 

seral species.

If a stand cover type is expected to change as a result of a silvicultural treatment, it would move from 

a late seral species cover type to a mix type or early seral type. Implementing this action alternative

would result in an increase of early seral and mix cover types, and a decrease of late seral types. Over 

time it is expected that up to 3,364 acres in Dry Upland Forest, 3,270 acres in Moist Upland Forest, 

and 776 acres Cold Upland Forest have the potential to move from late seral to early seral species 

groups. Some treatment areas may not change species type as a result of activity implemented during 

this project, and this is likely due to minimal tree mortality during treatment. Treatment of those acres 

may still have an effect on the structural stage of the stand and the tree density.

Forest Structure

The direct effects of implementing the activities described in Alternative B of the project on forest 

structural stage are described in Table 9. Effects within the project area are driven by changes of 

existing species composition and tree size. Compositional changes have minor influence on structural 

stage, but tree-size changes have major influence on structural state outcomes. Some structural 

changes are designed to reflect constraints and objectives associated with the Umatilla Forest Plan

and Eastside Screens amendment.

Overall there will be an increase in the Stand Initiation, Stem Exclusion, and Old Forest SingleStratum stand stages that are currently deficient. There will be a decrease in the stand stages currently 

exceeding the desired conditions: Understory Reinitiation and Old Forest Multi Strata. The changes in 

the stand structures are expected to bring all of the stands to within the desired ranges. Old Forest 

Single Stratum is expected to increase over time due to decreased densities within the stem exclusion 

and understory reinitiation stages.

Table 9. Direct effects of project implementation in forest structure stages. Comparison of current 

existing conditions, post treatment conditions for Alt. B and Alt. C, and the changes from existing 

conditions in Alt. B and Alt. C. Values listed in bold currently exceed desired ranges, items listed in 

italics are currently below desired ranges.

Existing Conditions

Post-treatment Change from Existing

Alt B Alt C Alt B Alt C

Acres. % Ac. % Ac. % Ac. % Ac. %

Dry Upland Forest

Stand Initiation (SI) 432 4 488 4 488 4 56 1 56 1

Stem Exclusion (SE) 965 9 1,827 17 1,467 13 861 8 502 5

Understory Reinitiation (UR) 2,288 21 1,633 15 1,993 18 -655 -6 -295 -3

Old Forest Single-Stratum (OFSS) 843 8 2,733 25 2,484 23 1,891 17 1,641 15

Old Forest Multi-Stratum (OFMS) 6,450 59 4,297 39 4,546 41 -2,153 -20 -1,904 -17

Total 10,977

Moist Upland Forest

SI 1,691 17 2,258 23 1,958 20 567 6 267 3

SE 1,629 16 2,246 23 1,951 20 616 6 322 3

UR 1,467 15 529 5 1,124 11 -938 -9 -343 -3

OFSS 22 <1 1,975 20 983 10 1,953 20 961 10

OFMS 5,153 52 2,954 30 3,947 40 -2,199 -22 -1,207 -12

Total 9,963
Final Environmental Impact Statement

Pomeroy Ranger District 63

Existing Conditions

Post-treatment Change from Existing

Alt B Alt C Alt B Alt C

Acres. % Ac. % Ac. % Ac. % Ac. %

Cold Upland Forest

SI 387 24 432 27 393 25 44 0 6 <1

SE 96 6 480 30 260 16 384 4 164 10

UR 655 41 226 14 485 31 -428 -4 -170 -11

OFSS 25 2 245 15 242 15 221 2 217 14

OFMS 422 27 201 13 205 13 -221 -2 -217 -14

Total 1,584

Forest Density

All activities would be conducted to reduce total stand density, albeit Alternative B will reduce 

densities more than Alternative C. In stands designated as habitat connectivity corridors or elk cover, 

density reductions would mostly occur in the understory with minimal reductions in overstory. In 

most areas, total stand density will be reduced to varying degree. Density reductions planned for both 

action alternatives reflect a balance: the relative proportion of desirable and undesirable species, and 

wildlife habitat cover. Alternative B favors vegetation changes by including more acres of density 

reduction and removal of undesirable trees. The direct effects of implementing the activities described 

under Alternatives B of the project on forest density classes are described in Table 10.

Overall, Alternative B lowers the percentage of high density stands and raises the amount of low and 

moderate densities across all three biophysical environments. The resulting change will bring all three 

into the desired conditions for forest density.

Table 10. Direct effects of implementing the activities described under Alternatives B and C on forest 

density classes.

Existing Conditions Post-treatment Change from Existing

Alt B Alt C Alt B Alt C

Ac. % Ac % Ac % Ac. % Ac. %

Dry Upland Forest

Low 695 6 1,417 12 1,033 9 722 6 338 3

Moderate 1,605 14 5,525 48 5,471 48 3,915 34 3,861 34

High 8,821 79 4,490 39 4,928 43 -4,637 -41 -4,199 -37

Total 11,121

 Moist Upland Forest

Low 773 8 3,480 35 1,867 16 2,707 27 1,094 9

Moderate 2,012 20 3,463 34 3,415 30 1,447 14 1,399 10

High 7,198 72 3,119 31 4,780 42 -4,154 -41 -2,493 -30

Total 9,983

 Cold Upland Forest

Low 47 3 751 46 461 28 705 43 414 26

Moderate 186 11 304 19 240 15 118 7 54 3

High 1,390 86 569 35 924 57 -823 -51 -469 -29

Total 1,622
Sunrise Vegetation and Fuels Project

64 Umatilla National Forest

Susceptibility to future insect and disease disturbance

Direct effects of an action alternative result in shifts of structure, stand density and tree vigor. These

conditions that are less susceptible to most bark beetles, dwarf mistletoes, and defoliators (Johnson et 

al. 2015, Schmitt and Powell 2005, Schmitt and Powell 2012). Shifts in species composition in favor 

of early seral species does not eliminate tree or stand susceptibility to biotic damage agents, as these 

tree species serve as hosts for their own variety of pests. 

The project action alternatives are expected to reduce general susceptibility across the Sunrise project 

area in two additional ways. The first, is that the action alternatives would diversify species 

composition across the landscape by increasing under-represented species, (Table 3-5). This method 

of reducing susceptibility does so by reducing the overall amount of host species in a given stand, as 

well as reducing the vulnerability of remaining host species, as they are more isolated within a 

broader landscape and less prone to disturbance propagation and dispersion. Early seral species such 

as western white pine and western larch are all relatively drought-tolerant and thus resistant to attack 

by damage agents which seek drought stressed hosts. The second way the project will have direct 

effects on forest susceptibility is by immediately shifting species composition toward host species less 

prone to stress-induced biotic disturbances. 

Direct effects of Alternative B on susceptibility to future insect and disease disturbance is expected to 

be greater than for Alternative C, because the overall extent of activities is greater for Alternative B, 

but the types of activities are the same for areas common to both alternatives. 

Alternative C

Species composition

Alternative C emphasizes the retention of early seral species and the removal of late seral species 

across all three biophysical environments. Changes in species composition would vary based on the 

existing composition of the stand and amount of overstory cut or killed by fire application. As in the 

Alternative B section, this section will refer to “mix” stands. Forest activity will not immediately 

change the majority species for mixed-species stands, but it will provide growing space for early seral 

species. 

If a stand cover type is expected to change as a result of a silvicultural treatment, it would move from 

a late seral species cover type to a mix type or early seral type. Implementing this action alternative

would result in an increase of early seral and mix cover types, and a decrease of late seral types. Over 

time it is expected that up to 2,983 acres in Dry Upland Forest, 1,743 acres in Moist Upland Forest, 

and 458 acres in Cold Upland Forest, will potentially move from late seral to early seral species 

groups. Some treated areas did not change species type due to minimal tree mortality due to treatment

activity. Treatment of those acres may still have an effect on the stand structure and density. 

Forest Structure

The direct effects of implementing the activities described under Alternative C of the Project on forest 

stand structure are described in Table 3-5. Effects within the project area are driven by changes of 

existing species composition and tree size. Some structural changes are designed to reflect constraints

and objectives associated with the Umatilla Forest Plan and Eastside Screens amendment.

Overall, there will be an increase in the Stand Initiation, Stem Exclusion, and Old Forest Single 

Stratum stages that are currently present. There will be a decrease in the stand stages currently 
Final Environmental Impact Statement

Pomeroy Ranger District 65

exceeding the desired conditions; Understory Reinitiation and Old Forest Multi Strata. The changes in 

the stand structures are expected to bring all of the stands to within the desired ranges. 

Forest Density

All activities would be expected to reduce total stand density, albeit Alt. C will retain higher densities 

than Alt. B. In stands designated as habitat connectivity corridors or elk cover, density reductions 

would mostly occur in the understory with minimal reductions in overstory cover. In most areas, total 

stand density will be reduced to varying degree. Density reductions planned for both action 

alternatives reflect a balance struck between the relative proportion of desirable and undesirable 

species, and wildlife habitat cover. The direct effects of implementing the activities described under 

Alternatives C of the Project on forest density classes are described in Table 10.

Overall, Alternative C lowers the percentage of high density stands and raises the amount of low and 

moderate densities class across all three biophysical environments, but to a lesser extent than results 

from implementation of alternative B. The resulting change will bring all three into the desired 

conditions for forest density.

Susceptibility to future insect and disease disturbance

Direct effects of an action alternative result in shifts of structure, stand density and tree vigor. These

shifts will result in lower susceptibility to most bark beetles, dwarf mistletoes, and defoliators 

(Johnson et al. 2015, Schmitt and Powell 2005, Schmitt and Powell 2012). Shifts in species 

composition in favor of early seral species does not eliminate tree or stand susceptibility to biotic 

damage agents, as these tree species serve as hosts for their own variety of pests. 

The project action alternatives are expected to reduce general susceptibility across the Sunrise Forest 

Vegetation Analysis Area in two additional ways. First, is that the action alternatives would diversify 

species composition across the landscape by increasing under-represented species (Table 3-5). This 

method of reducing susceptibility does so by reducing the overall amount of host species in a given 

stand, as well as reducing the vulnerability of remaining host species, as they are more isolated within 

a broader landscape and less prone to disturbance propagation and dispersion. The second way project 

will have direct effects on forest susceptibility is by immediately shifting species composition toward 

of host-species less prone to stress-induced biotic disturbances. Early seral species such as, western 

white pine, and western larch are all relatively drought-tolerant and thus resistant to attack by damage 

agents which seek drought-stressed hosts.

Direct effects of Alternative B on susceptibility to future insect and disease disturbance is expected to 

be greater than for Alternative C, because the overall extent of activities is greater for Alternative B, 

but the types of activities are the same for areas common to both alternatives. 

Alternative B and C Indirect Effects

Species Composition

Areas affected by Action Alternatives would develop along their natural succession earlier than if the 

activities had not occurred. The mixed cover type would retain more early seral, fire tolerant species 

than the No Action Alternative. Even with the stand movement toward early seral species, all but the 

driest of stands will retain some presence of late seral species. This would allow for the establishment 

of shade tolerant species in the understory in the years following treatment. Regardless, desired, 

early-seral species will be promoted best under either Action Alternative.
Sunrise Vegetation and Fuels Project

66 Umatilla National Forest

Forest Structure

As described in the direct effects section above, activities included under the action alternatives 

would generally lower forest density and allow more light, water, and nutrient resources to be 

utilized by residual trees, increasing individual tree growth and increasing physiological resistance to 

insect and disease damage. The indirect effects of the project would be a continuation of those effects 

over time, gradually diminishing as stand density increases. In addition, activities included under 

either action alternative would generally move affected stands that are in the stand initiation, stem 

exclusion, and understory reinitiation stages immediately following project activities to old-forest 

structural stages sooner than if no action had occurred. Such a process is likely in the absence of 

future disturbance or in the event of low-severity disturbances, but unlikely if future moderate or 

severe disturbances convert areas to an earlier structural stage. The exact timing, extent, and severity

of such stochastic impacts are highly uncertain, but likelihood increases with time. 

Forest Density

Following action alternative implementation and the occurrence of direct effects, indirect effects of 

the project on stand density are expected to diminish with time as forest vegetation growth continues 

and stand density increases. Other indirect effects include a lower forest density in affected stands 

than if the action alternative activities had not occurred. 

Susceptibility to future insect and disease disturbance

As the direct effects of both action alternatives on forest density class, structural stage, and cover type 

diminish over time, effectiveness on the reduction of susceptibility to insect and disease will also 

decrease. The cumulative effects of wildfire suppression in the project Sunrise Forest Vegetation 

Analysis Area will enable forests to develop multi-strata canopies, shade-tolerant species to flourish, 

and stand density to increase, all of which are associated with increased susceptibility to a host of 

future biological disturbances. Unless future disturbances decrease stand density, canopy layering, or 

the amount of host species, susceptibility to such disturbances will gradually increase to preimplementation levels over a 50 to 75-year period. 

Indirect effects of Alternative B on susceptibility to future insect and disease disturbance is expected 

to be greater than for Alternative C, because the overall extent of activities is greater for Alternative 

B, but the types of activities are the same for areas common to both alternatives. 

Mitigation Measures

Silvicultural design features related to the Eastside Screens Forest Plan amendment and 

Important Habitat Features

One of the Old Forest structure classes (OFSS) falls below HRV in all three biophysical environments 

present within the project area. Both action alternatives fall under Scenario A of the Eastside Screens

Forest Plan Amendment (see Appendix C). In order to ensure consistency with the Screens 

amendment, the following design features are incorporated into both action alternatives for the 

Sunrise project: 

• Maintain all remnant late and old seral, and/or structural live trees ≥ 21" dbh that currently exist 

within stands proposed for harvest activities.

• All timber harvest activities outside of LOS forests must be prescribed in such a manner that it does 

not prevent attainment of HRV within the project analysis area for both LOS types (single and 

multi-stratum). All prescriptions will emphasize the retention of individual trees and tree species 
Final Environmental Impact Statement

Pomeroy Ranger District 67

sufficient to maintain or attain minimum requirements for old forest, as described in the Forest 

Plan. 

• Prescriptions for habitat connectivity corridors must ensure the retention of abundant medium or 

larger diameter trees, and canopy closures within the top one-third (33%) of site potential.

• Do not create forest openings19 through even-aged cutting methods that exceed 40 acres in size, 

unless allowed by exceptions provided in the Forest Plan. 

• Prescriptions for habitat connectivity corridors must retain some level of understory (if any already 

exists) and left in patches or scattered to assist in supporting stand density and cover.

• Where open, park-like conditions occurred historically (pre-settlement areas characterized by 

frequent, low-severity fire regimes), maintain such conditions by implementing intermediate 

treatments and/or emphasize the removal of fire-intolerant species. Maintain a sufficient number 

of seedlings, saplings, and poles to allow for the development of future stands. 

• Slash will not be piled against large trees or snags to prevent loss from prescribed fire. 

• Hollow or partially hollow, broken top snags greater than 15 inches DBH will be left to provide 

roost habitat for bats. Dead grand fir most commonly provides hollow tree habitat.

• Protect goshawk nests from disturbance if any are located during project activities. Defer harvest

on 30 acres of the most suitable nesting habitat around nest sites. Retain late and old structure forest 

in a 400-acre post-fledging area (PFA) as determined by the district biologist. Defer activities in 

active PFAs from April through August.

• Protect known or discovered raptor nest sites from management and human disturbances until 

fledging has been completed. Level of protection will vary by species and will be recommended 

by the District wildlife biologist (FP 4-57).

• Seeps, springs, bogs, wallows, and other wet areas will be evaluated and protection measures 

determined by the District wildlife biologist (FP 4-57, 4-160).

• If cliffs, talus or cave habitat is found, protection measures will be determined by the District 

wildlife biologist. (FP 4-57)

Concerning snag retention, retain all snags 20 inches DBH and larger, except for hazard trees. If there 

are less than 3 large snags per acre available, smaller snags will be retained to meet 3 per acre. 

Maintain down wood habitat and green replacement trees at or beyond levels identified in the table 

below. Tree species and soundness at the base will also be considered. The tree species most 

preferred are ponderosa pine, western larch, and Douglas-fir. For a per-acre reference see Table 11

below. 

Table 11. Snag and down wood retention per acre by forest vegetation community type

 

19 A harvested area is considered a created opening for timber management when the prescribed crop tree 

stocking is below minimum acceptable levels and trees are at or below 4 1⁄2 feet in height and/or not free to 

grow.

Snag and Down Wood Retention Ponderosa

pine

Mixed 

conifer

Grand 

fir

Lodgepole 

pine

Subalpine 

zone

Leave all snags 20 inches dbh and larger. If 

unavailable, leave at least 3 per acre over 10 

inches dbh. 

All (3) All (3) All (3) All (3) All (3)

Green Tree Replacements (per acre) 16 16 9 14 19

Down Wood Pieces (per acre) 3 - 6 15 - 20 15 - 20

Diameter at the small end > 12 inches > 12 inches > 8 inches

Length per piece > 6 feet > 6 feet > 8 feet

Total length per acre > 20 feet > 100 feet > 120 feet
Sunrise Vegetation and Fuels Project

68 Umatilla National Forest

Cumulative Effects

Alternative A

Under the project No Action Alternative, ongoing disturbance and succession processes influencing 

vegetation conditions in the Sunrise area would continue as they have in the recent past without 

additional treatment. It is reasonable to assume other actions would continue in other areas and 

generally move landscape towards desired conditions. Cumulatively, however, the impacts would not 

be as positive if no action was chosen compared to the action alternatives. 

Alternatives B and C

Cumulative effects analysis must consider the effects of all past, present, and reasonably foreseeable 

future actions, are listed in Section 3.5 of this EIS.

All past actions, which include timber harvest, reforestation, non-commercial thinning and prescribed 

fire, established the existing conditions found in the project area today. The Sunrise project action 

alternatives would have additive effects to these activities, increasing the extent of structural 

conditions, density class, and species compositions created by past activities.

Present vegetative treatment activities occurring in the project area with measurable effects on forest 

vegetation include the Asotin Burn project and the Asotin C&H grazing allotment. Livestock grazing 

tends to suppress herbaceous cover and production. One effect of this production and selective 

grazing pressure is an increase of conifer seedling germination, survival, and growth. The Sunrise 

project action alternatives would tend to negate this effect where overlaps occur in space time, such 

that cutting and burning activities included under alternatives B and C would result in widespread 

mortality of understory seedlings and promote herbaceous cover over the 1-20 years following project 

implementation.. 

Other activities included in Section 3.5 are likely to have negligible cumulative effects on forest 

vegetation. 

Irreversible and Irretrievable Commitment of Resources

For all action alternatives (B and C) there would be no irreversible or irretrievable commitment of 

resources with implementation of proposed activities.
Final Environmental Impact Statement

Pomeroy Ranger District 69

3.7 Fuels 

A summary of the current conditions of the affected environment and the predicted effects of the 

Proposed Action and its alternatives are discussed in this section. Specific information on the 

methodologies, assumptions, and limitations of analysis and other details are contained in the Sunrise 

fuel’s specialist’s report, incorporated herein by reference, and available to the public on the project 

webpage at http://www.fs.fed.us/nepa/fs-usda-pop.php/?project=45689. 

Introduction

The implementation of either action alternative has the potential to impact the health and safety of 

local residents and those utilizing public lands by increased smoke in the area. In addition, excess fuel 

loading is outside the range of historic variability (see Silviculture Specialist Report). Either through 

inaction, Alternative A, and the continued risk of large wildfires, or through prescribed fire, air quality

was identified as a resource that should be analyzed for potential impacts. 

Regulatory Framework

Implementation of Alternatives B or C complies with the Forest Plan and desired condition for fire 

and fuels as outlined in the report. The Umatilla National Forest Land and Resource Management 

Plan (USDA Forest Service 1990) provides the overall direction of management activities on the 

Forest. Forest-wide management goals, as well as management area direction, represent the desired 

future condition that management actions are designed to achieve. The projects meets the desired 

future conditions for the following management areas: A4-Viewshed 2, A6-Developed Recreation, 

C1-Dedicated Old Growth, C3-Big Game Winter Range, C4-Wildlife Habitat, C5-Riparian, C8-Grass 

Tree Mosaic, and E2-Timber and Big Game. 

Methodology 

Information for this fuels analysis was gathered and synthesized from field reconnaissance, the 

Umatilla National Forest’s Geographic Information System (GIS), historic vegetation mapping, 

FSVeg Spatial and FSVeg Data Analyzer, and FVS Fire and Fuels Extension. Existing condition and 

effects analyzed for this project includes only the Forest Service portion of the planning area for 

approximately 32,000 acres. Project activities, in conjunction with past, ongoing, and reasonably 

foreseeable activities, have effects on fuels and fuel continuity; therefore, the planning area is 

sufficient to display effects on the landscape20. All acres in the project planning area were assigned a 

fire regime and condition class, as well as evaluated for crown fire potential. 

Indicators

Indicators used in the analysis of the vegetation and fuel activities occurring in the Sunrise planning 

area are acres of fire regime 1, 2 and 3 in condition classes 2 and 3, and historical range of variability

(HRV) for both dry and moist forest that support high density conditions and level of crown fire

potential. 

Fire Regime Condition Class and Historical Range of Variability (RV)

A natural fire regime is a classification of the historical role fire would play across the landscape in 

the absence of modern human mechanical intervention, but including the influence of aboriginal 

 
Sunrise Vegetation and Fuels Project

70 Umatilla National Forest

burning (Agee 1993, Brown 1995). Fire regimes are classified based on the average number of years 

between fires (frequency) combined with the severity of the fire. Severity can be low (surface fires), 

mixed (less the 75 percent of overstory mortality), and high (greater than 75 percent overstory 

mortality). There are four historical fire regimes which commonly occur in the Blue Mountains 

(Powell 2005). They are fire regimes 1, 2), 3 and 4. Fire regime 3 and 4 have sub-regimes which are 

defined with more detail based on region specific characteristics identified by local resource experts 

and regional fire ecologist, and are based on Umatilla National Forest historical fire data. The four 

fire regimes and sub-regimes are described further in Table 3-7.

Table 12. Characteristics of common Oregon and Washington fire regimes present within Sunrise project 

area.

Fire 

Regime

Return Interval 

(years) Severity Potential Plant Communities Historical Burned Area21 (%)

1 <25 – 35 Low, Surface Fire Ponderosa pine, dry Douglas-fir 75

2 <35 Mixed, High True grasslands 5

3A <50 Mixed Mixed conifer, dry Douglas-fir, dry grand 

fir

15

3B 50-100 Mixed Warm, mesic grand fir

3C 100-200 Mixed Mesic grand fir and Douglas-fir

4C 100-200 High Subalpine mixed conifer (spruce-fir), 

western larch

5

Fire Regime Condition Class (FRCC) describes the amount of departure of the landscape from the 

historical fire regime. Condition class describes the condition of the landscape by characterizing the 

vegetation’s departure from its historical range of variability. This characterization describes the 

landscapes vulnerability to uncharacteristic wildfire intensities, severities, and insect and disease 

susceptibility. Condition Class is divided into three categories. Condition Class 1, within the historical 

range of variability of vegetation and fuels composition. Condition Class 2, is moderately altered 

from historic conditions. Condition Class 3, substantially altered from historic conditions. Table 13

below describes condition class in more detail below. 

Table 13 Fire Regime Condition Class Descriptions

Condition 

Class

Description Species Composition and Structure

1 Within the historical range of 

variability of the vegetation 

characteristics; fuel composition; 

fire frequency, severity and pattern

Species composition and structure are function within 

their historical range.

2 Fire regimes have been moderately 

altered from historical range. Fire 

frequencies have departed from 

natural historical frequencies by one 

or more return intervals. The result 

is moderate changes to one or more 

of the following: fire size, intensity

and severity, and landscape 

patterns. 

Species composition and structure have been 

moderately altered. For example:

Grassland – Moderate encroachment of shrubs and 

trees or invasive exotic species.

Forestland – Moderate increase in density, 

encroachment of shade tolerant trees species, 

moderate fire tolerant tree species.

 

21 Historical burned area is an estimate of annual burned area (percent) for the Blue Mountains prior to Euro-American 

settlement (defined as pre-1850O. Data were derived from Agee (1996).
Final Environmental Impact Statement

Pomeroy Ranger District 71

Condition 

Class

Description Species Composition and Structure

3 Fire regimes have been 

substantially altered from their 

historical range. Fire frequencies 

have departed from natural 

frequencies by multiple return 

intervals. Dramatic changes occur 

to one or more of the following: fire 

size, intensity and severity and 

landscape patterns.

Species composition and structure have been 

substantially altered from their historical range. For 

example:

Grassland – High encroachment and establishment of 

shrubs, trees, or invasive exotic species. 

Forestland – High increases in density, encroachment 

of shade tolerant tree species, or high loss of fire 

tolerant tree species.

High mortality or defoliation from disease and insect.

Historical range of variability (HRV) is a conservation strategy used to establish reference conditions 

for managing landscapes. These reference conditions describe the forest composition and structure 

that existed before Euro-American settlement. For the northern Blue Mountains, HRV uses a range of 

reference conditions pertaining to the pre-settlement era (mid 1800’s) (Powell 2009, Schmidt et al. 

2002). HRV was used with a wide variety of vegetation indicators, such as species composition, stand 

density, canopy biomass, and insect and disease susceptibility, when completing analysis for the 

Sunrise planning area.

Crown Fire Potential

Crown fire potential describes a stands ability to initiate and sustain a crown fire. Some fire regimes

experience crown fires under historic conditions (fire regime 4). For others, such as fire regime 1 and 

3, sustained crown fires are uncharacteristic. The spatial continuity and density of tree canopies in 

combination with wind and physical setting provide the conditions for crown fires (Graham, 

McCaffrey and Jain 2004). Canopy base height22, canopy bulk density23, and canopy continuity are 

key characteristics of forest structure that affect the initiation and propagation of crown fire (Albini 

1976, Rothermel 1991). Canopy base height is important because it affects crown fire initiation and 

canopy continuity influences the spread of fire (Graham 2004).

Ladder fuels, as they relate to canopy base height, provide avenues for fire to move from the ground 

to the tree crowns. Stands with low canopy base height are more susceptible to crown fires. Crown 

fires are high intensity wildfires that advance through a stand’s canopy and can exhibit extreme fire 

behavior that is difficult and dangerous to suppress, and cause economic damage (Keyes 2002). They 

occur when surface fires create enough energy to preheat and combust live fuels well above the 

ground or when ladder fuels, in the form of small seedlings, saplings and young trees with low 

hanging branches, carry fire into the upper canopy. There are two stages of crown fires: the initiation 

of crown fire activity, referred to as “torching” (also known as passive crown fire), and the process of 

active crown fire spread, where fire moves from tree crown to tree crown. Torching commences when 

the surface flame length exceeds a critical threshold, defined by (Van Wagner 1977) as a function of 

the moisture content of overstory foliage and the vertical distance to live crown, known as canopy 

base height (CBH). Once in the crowns, fire must maintain a minimum rate of spread to become an 

active crown fire and is primarily determined by topography and weather conditions. The spread rate 

required to keep fire in the crown hinges on the density (Agee 2005) of fuels in the canopy, called 

canopy bulk density (CBD) (Keyes and O'Hara 2002). Torching and crowning also create fire brands 

 

22 Canopy base height is the lowest point in the stand was there is sufficient available fuel to propagate fire vertically. 23 Canopy bulk density is the canopy weight for a given volume.
Sunrise Vegetation and Fuels Project

72 Umatilla National Forest

that can spread fire well beyond their source, increasing fire spread to adjacent stands. Crowning 

significantly limits fire suppression options, requiring suppression personnel to rely on aerial 

resources or implement other indirect attack techniques. 

Affected Environment

Fire Regime Condition Class and Historic Range of Variability (HRV)

The Sunrise project planning area is comprised of 35 percent fire regime 1, 29 percent fire regime 2, 

18 percent fire regime 3, and 18 percent fire regime 4. Table 14 displays the historical fire regimes 

and associated acres present in the project area, and the Figure 3-2 visually displays the fire regimes 

throughout the Sunrise project planning area. 

Table 14. Fire regimes within Sunrise project area by acres.

Fire Regime Acres Percent

1 11,181 35

2 9,178 29

3 5,828 18

4 5,780 18

No Data 

(Administration Sites)

22 N/A

WADNR & WDFW1 1130 N/A

1 WADNR and WDFW land was not analyzed for fire regime.

Prior to European settlement, dry forests of the Inland northwest, ponderosa pine and mixed conifer 

(grand fir and Douglas-fir), were burned by relatively frequent low and mixed severity fires 

(Hessburg et al., 2005). The low severity fires occurred frequently, usually every 1 to 25 years, and as 

a result less than 20 percent of the tree basal area was killed (Agee 2004). The mixed severity fires 

occurred every 25-100 years and 20 to 70 percent of the basal area may have been fire killed, but in 

the context of drier fire regime 3 eco classes, such as Douglas-fir/ninebark, this mortality tended to be 

at the lower end of this overstory mortality (Hessburg et al., 2005). 

In stands with low severity fires, fire-tolerant forest structures were maintained by removing the 

lower crown classes. These fires carried primarily by surface fuels; consumed litter, duff and downed 

wood; controlled establishment of fire-intolerant species (such as grand fir) and eliminated ladder 

fuels; and elevated crown bases by killing the majority of trees in the suppressed and intermediate 

crown layers (Agee 1994b, Youngblood 2008). This reduced the threat of running crown fires by 

continually thinning stands, eliminating ladder fuels and elevating crown base heights (Hessburg et 

al., 2005). Crown fires rarely occurred under these conditions, which can be attributed to lack of 

surface fuel continuity, raised crown base heights, and reduced crown bulk densities.
Final Environmental Impact Statement

Pomeroy Ranger District 73

Figure 3-1. Fire Regime Condition class for the Sunrise project area. Note, WADNR and WDFW land was 

not analyzed for condition class.

Approximately 29 percent of the Sunrise project area is considered to be in condition class 2 and 

another 15 percent in condition class 3. This indicates a transition to more complex fuel conditions 

than historically were present in the planning area. Fuels that would have historically been consumed 

during periodic wildfires have increased and in many areas, surface and aerial (within the canopy) 

fuel loadings are above historical levels. Table 15 groups the project planning area into the 3 

condition classes by acres and percent of planning area, and the map above visually displays the 

condition class of the landscape within the Sunrise planning area.

Table 15. Acres by condition class within the Sunrise project area.

Condition 

Class Acres Percent of Planning Area

1 11613 35%

2 9588 29%

3 5030 15%

A reason for this change in forest composition and structure is due to the decline in fire occurrence 

caused by changes in land use (Heyerdahl 1997). Fire is thought to be a dominant disturbance type in 

the Blue Mountains prior to European settlement (Agee 1994a). These fires kept stands from 

becoming overstocked and ground fuels from accumulating. In the late 1800’s and early 1900’s 

settlers began moving to the northwest, so began timber harvest, grazing and the establishment of the 
Sunrise Vegetation and Fuels Project

74 Umatilla National Forest

Forest Service (Agee 1993). Along with establishment of the Forest Service agency came policy to 

suppress all wildfires (Agee 1993). Aggressive fire suppression has been the Forest Service policy 

since the destructive fire season in northern Idaho and western Montana in 1910. By restricting fire 

spread through suppression, fuels that would have been reduced by wildfire have been allowed to 

accumulate, increasing the probability of large, more intense fires. Fire suppression has also affected 

current conditions by substantially decreasing fire mosaics or patches on the landscape. Historically, 

fires burned large areas creating a landscape consisting of a mixture of succession patterns or 

mosaics, with some of these patches serving as natural fire barriers. With successful fire suppression, 

the large-scale fire mosaics or patches on the landscape are being lost, creating a more uniform fuel 

structure with little or no natural barriers to help contain fire growth. This absence of fire has allowed 

stands to become overstocked, species composition to change fire-intolerant trees, and ground fuels to 

accumulate resulting in increased fire severity in forest types that once were adapted to low intensity

wildfires. 

Historical wildland fire data shows that very small acreages have burned during the last 100 years in 

the Sunrise project area. With respect to fire return frequency, this means at least two fire return 

intervals have been missed in fire regime 1 and one or more in fire regime 3 (depending on the 

classification, example IIIa or IIIc). This absence of fire has resulted in increased surface fuel loads, 

increased tree density and lower canopy base heights. Increased canopy cover has led to regeneration

of shade-tolerant, fire-intolerant species with low crown bases. These abundant small trees serve as 

ladders that carry fire from the forest floor to the canopy, increasing the likelihood of crown fire (Huff 

et al. 1995.) Table 16 displays wildfire acres in the project area by decade. 

Table 16. Past wildfire acres within the Sunrise project area.1

Decade Number of Fires Total Acres Burned

1910 1 8710

1970 25 4.3

1980 31 48.6

1990 34 1864.5

2000 6 0.8

2010 – present 10 152.7

1 There are no fires on record between 1911 and 1969.

Fire exclusion and fire suppression have also indirectly contributed to advancing secondary 

succession by preventing fires of a size and frequency that allow establishment of early seral species 

(Hessburg et al., 2005). Tree densities in the Sunrise project are above historical densities in dry 

upland forestland (see Silviculture report). High tree densities in dry upland forest historically 

occupied 5 to 15 percent of the area, but currently occupy 79 percent of the dry upland forest area. 

Historical range of variability analysis for species composition shows that dry forestland currently 

supports too much of the Douglas-fir forest cover type and too little of the ponderosa pine forest 

cover type. Historical range of variability analysis also shows moist forestland supports too much of 

the subalpine fir/spruce and Douglas-fir forest types and too little of the western larch and lodgepole 

pine forest cover types. In dry upland forest, the HRV for ponderosa pine is 50 to 80 percent cover, 

Douglas-fir is 5-20 percent, and grand fir is one to 10 percent. Currently ponderosa pine cover type is 

at 34 percent, Douglas-fir is 52 percent, and grand fir is at 10 percent (see Silviculture report). 

For moist upland forest the HRV is 5-15 percent ponderosa pine cover type, 15 to 30 percent 

Douglas-fir cover type, 10 to 30 percent western larch, 15 to 30 percent grand fir and one to 10 
Final Environmental Impact Statement

Pomeroy Ranger District 75

percent spruce-fir. Current percentages are 13 percent ponderosa pine (within HRV), 33 percent 

Douglas-fir, two percent western larch, 19 percent grand fir and 22 percent spruce-fir (see Silviculture

Report). 

Acres of the national forest are further described in terms of fuel models. Table 3-11 below explains 

the most common models found within the project area, while Figure 3-3 visual represents each 

model’s geographic location within the project area. 

Surface Fuel Loading

Across the project area, the absence of low and mixed severity fires has caused a substantial increase 

in surface fuel loading, understory vegetation and stand density. There are areas with high fuel 

loadings caused by insects and disease, self-thinning and overstory tree mortality. The loss of the fireresistant large-tree component has reduced the fire resiliency of many stands. Past overstory removal 

and lack of fire has resulted in a shift from ponderosa pine forest cover type, on dry-forest sites, to 

Douglas-fir and grand fir. Moist-forest sites have shifted from Douglas-fir, western larch cover types 

to grand fir, spruce cover types in many stands, significantly increasing ladder fuels and decreasing 

canopy base height. If a fire occurs in these areas under favorable burning conditions, it is likely that 

torching and/or crowning would cause overstory mortality. 

Table 17. Most common fuel models (Anderson 1982) found in the Sunrise project area.

Fuel 

Model Category Description

1 Short Grass

Surface fires that move rapidly through the continuous, cured or nearly cured herbaceous fuels. 

Surface fuel loading, less than 3 inches in diameter, is less than .74 tons per acre. Surface fuel 

bed depth is 1.0 foot.

2 Timber, Grass, 

and understory

Fire spread is primarily through the fine fuels, such as grass and pine needles. The stand is 

open where larger pine and Douglas-fir cover one-to two-thirds of the area. Surface fuel 

loading, less than 3 inches in diameter, averages 4 tons per acre. Surface fuel bed depth is 1 

foot.

5 Low Brush

Fire is generally carried in the surface fuels that are made up of litter cast by the shrubs and the 

grasses or forbs in the understory. The fires are generally less intense because surface fuel 

loads are light. Surface fuel loading, less than 3 inches in diameter, averages 3.5 tons per acre. 

Surface fuel bed depth is 2.0 feet.

8

Timber, 

Closed Timber 

Litter

A typical stand includes a closed canopy of short-needled conifers, such as Douglas-fir. The 

compact litter layer consists of needles, leaves and occasional twigs. Surface fuel loading, less 

than 3 inches in diameter, averages 5 tons per acre. Surface fuel bed depth is 0.2 feet.

10 Timber, Litter,

Understory

Fires burn in the surface and ground fuels with greater fire intensity than the other timber litter

models. Fuels in this model include greater quantities of dead and down material 3 inches and 

greater. Crowning, spotting and torching are more frequent in this fuel situation. Surface fuel 

loading, less than 3 inches in diameter, averages 12.0 tons per acres. Surface fuel bed depth is 

1.0 feet.

Surface fuel loadings vary throughout the project area and are best described by fuel models. Fuel 

models contained within the proposed areas are described by Anderson (1982). The difference in fire 

behavior among fuel models is related to the fuel load and its distribution among the fuel particle size 

classes (Anderson 1982). Fuel load and depth are significant fuel properties for predicting whether a 

fire would be ignited, rate of spread and intensity (Anderson 1982). Fuel models do not indicate 

potential for uncharacteristic wildfire behavior and effects, fire regime condition class, or departure 

from historical conditions. However, the combination of an indicator of departure from historical 

conditions, along with fuel models, can be of considerable value in determining if wildfire behavior 
Sunrise Vegetation and Fuels Project

76 Umatilla National Forest

and effects have departed from natural conditions (Hann 2003). Intensity and duration of surface fires 

depend on the availability and condition of surface fuels (Graham 2004). Woody fuel can greatly 

increase the energy released from surface fires and in some cases increase flame lengths sufficiently 

to ignite ladder and/or canopy fuels (Graham 2004). In terms of fuels and fire potential, a majority of 

the closed stands proposed for commercial harvest treatment have fuel loads that are best represented 

as fuel model 10. Fuel model 5 occurs in the more open stands. Areas proposed for landscape 

prescribed fire are represented by fuel models 1, 2 and 5 with minor inclusions of fuel models 8 and 

10. 

Figure 3-2. Fuel models currently within the Sunrise project area.

Fuel model 2 and 8 are fuel models which would have abundantly existed in fire regime 1 and 3 

dominated landscapes. The fire behavior of these representative models (except fuel model 8) is 

determined by accumulations of fine fuels. Some stands may not have changed enough to move into a 

different fuel model classification, but fire exclusion and the associated changes in stand condition 

have significantly increased the fire behavior potential. 3-12 below, contains the relative percentages 

of fuel models in the Sunrise planning area as they are currently classified. As an example, many of 

the stands classified as Fuel model 8 are becoming older. As these stands have aged, numerous trees 

have been out competed for sunlight and nutrients and are now standing dead or have recently fallen, 

creating higher fuel loads in all fuel size classes. These higher surface fuel loads are more 

characteristic of a fuel model 10. 

In the Sunrise planning area, the changes in forest stands and the concurrent increase in down woody 

fuel loadings have caused a shift from a historical dominance from fuel models 1 and 2, to fuel model 

5, and from fuel model 8 to the dominance of fuel model 10. This could potentially result in a shift of 
Final Environmental Impact Statement

Pomeroy Ranger District 77

fire behavior during severe fire weather conditions from what were historically fast moving, low 

intensity, surface fires to fast moving, high intensity crown fires which can be stand replacing. 

Table 18. Acres of each fuel model present within the Sunrise project area.

Fuel Model Acres Percent of Area

1 9527 30

2 6414 20

5 2474 8

8 1759 5

10, 11, 12 1 11793 37

No Data 22 N/A

WDFW and WADNR 2 1130 N/A

1 Fuel Models 11 and 12 where combined with Fuel Model 10 because Fuel Model 10 more accurately resembles down 

woody fuel. 2 WADNR and WDFW land was not analyzed for fuel model.

Crown Fire Hazard

Under historical disturbance regimes, frequent surface fires consumed litter, duff, and down wood; 

controlled establishment of fire intolerant species; reduced density of small diameter stems; opened 

the stands to increased sunlight; led to vertical stratification of fuels by eliminating fuel ladders 

between the forest floor and overstory canopy; and maintained early seral plant associations. Crown

fires rarely occurred under these historical disturbance regimes. Consequently, the structure in these 

stands consisted of open, predominantly widely spaced medium to large, old trees, light and patchy 

ground fuels, and low and patchy cover of fire-tolerant shrubs (Youngblood et al. 2008). 

It is estimated that with a properly functioning disturbance regime, influenced primarily by frequent 

surface fire (Agee, 1998), dry forest had 60 percent of its acreage supporting low-density forest, 30 

percent supporting moderate-density forest and 10 percent supporting high-density forest (Powel, 

2009). As for mixed severity fire, moist forest had 30 percent supporting low-density, 50 percent 

moderate density and 20 percent high density (Powell 2009). 

Currently in the Sunrise planning area, 79 percent of the dry upland forest acres are classified as high 

tree density, 14 percent moderate and 6 percent low. Historically, 5 - 15 percent of dry upland forest 

would have been high tree density and 40 - 85 percent classified low. For moist upland forest 72 

percent is currently in the high tree density category, 20 percent in the moderate class, and 8 in the 

low. Historically, 15 - 30 percent of moist upland forest would have been high tree density and 20 to 

40 percent classified low (see Silviculture report). 

Crown fire hazard in the Sunrise project area was calculated based upon the potential for individual 

stands to support a fire moving from the ground into the crowns of the trees, initiating and sustaining 

a crown fire. The Forest Vegetation Simulator Fire and Fuels Extension (FVS/FFE) utilizes a torching 

index24 and a crowning index25 to calculate crown fire hazard and summarizes the potential into four 

categories surface fire, passive crown fire, active crown fire and conditional crown fire. Surface fire 

does not burn in the crowns, passive crown fires would burn as individual trees or groups or groups of 

trees torch and active crown fires move through the tree crowns, burning all crowns in the stand 

 

24 Torching index is the 20 foot wind speed required at which a surface fire is expected to ignite the crown layer (Rebain, et. 

al., 48).

25 Crowning index is the 20 foot wind speed needed to support an active or running crown fire (Rebain, et. al., 48).
Sunrise Vegetation and Fuels Project

78 Umatilla National Forest

(Rebain et al. 2015.) Conditional crown fires are fires that if beginning as surface fire would remain a 

surface fire, but beginning as an active crown fire in an adjacent stand may continue to spread as an 

active crown fire. Crown fire hazard for the Sunrise project area is displayed in Figure 3-4 below. 

Roughly 34 percent of the dry and moist forest types in the Sunrise project planning area are 

classified as having active or passive crown fire hazard (see Table 19 below). 

Table 19. Crown fire hazard by Fire Regime within the Sunrise project area26.

Crown Fire

Potential

Fire 

Regime 1 

(Acres)

Percent of 

Planning Area 

(FS Only)

Fire 

Regime 3 

(Acres)

Percent of 

Planning Area 

(FS Only)

Fire Regime 4 

(Acres)

Percent of 

Planning Area 

(FS Only)

Surface Fire 4,011 13% 1,452 4% 1,515 5%

Passive 

Crown Fire

3,388 11% 1,269 4% 2,802 9%

Conditional 

Crown Fire 458 1% 279 1% 501 1%

Active Crown

Fire

3,213 10% 2,829 9% 959 3%

11,175 35% 5,828 19% 5,778 19%

 

26 Fire Type was not calculated for 9163 acres of Fire Regime 2, 22 acres of administrative sites and 2 acres of no data 

equaling 29% of planning area (FS acres only).
Final Environmental Impact Statement

Pomeroy Ranger District 79

Figure 3-3. Potential crown fire hazard for the Sunrise project area.

Environmental Consequences 

Direct and Indirect Effects

Alternative A (No Action)

Taking no action in the analysis area would allow Fire Regimes (FR) to continue outside their 

historical range of variability (HRV), as reflected by their condition classes, and further deviation 

from HRV would occur across the landscape. In the dry upland forests as described in Hessburg et al. 

(2005), fire severity, intensity, frequency, and vegetative characteristics would continue to place 

ecosystem function at risk in the event of an uncharacteristic wildfire (Barrett et al. 2010). 

In the absence of treatment in the Sunrise project area, fire regimes 1 and 3 would continue to shift 

from frequent low/mixed severity fires to infrequent moderate/high severity fires characterized by 

increased fire return intervals and associated fire disturbance severities. The area would continue to 

develop dense, multi-storied stands with forest composition continuing to shift towards fire intolerant 

species dominance (Powell 2009). Insects and disease would act as a surrogate to the historical fire 

disturbance, and the relative distribution of low, moderate, and high severity disturbance would 

continue to be outside HRV across the landscape.
Sunrise Vegetation and Fuels Project

80 Umatilla National Forest

Vegetation characteristics associated with condition classes would continue to depart under the No 

Action alternative. FRCC 1 represents the historical state of the landscape by definition and currently 

characterizes less than 35 percent of the planning area. This means that 65% of the landscape has 

experienced some degree of departure from its historical condition. 

Taking no action in the Sunrise planning area would result in species compositions that remain 

outside the historical range of variability. In the dry upland forests, ponderosa pine cover type would 

continue to be underrepresented, and on moist-forest sites western larch and associated species would 

also be underrepresented.

No change would occur to tree density levels, so the low density condition would continue to be 

under represented on dry forest sites, as well as canopy biomass levels for both dry and moist foresttypes. 

Fuel Loading

Fuel loading would remain high and continue to increase. Standing dead fuel (snags) would continue 

to accumulate and add to the existing down fuel load leading to increased departure in FRCC and 

HRV. 

Crown Fire Hazard

Under the No Action alternative 34 percent of the dry (fire regime 1) and moist (fire regime 3) forest 

areas in the Sunrise analysis area would continue to be at risk of historically uncharacteristic crown

fire. Crown fire is dependent upon stand structure, composition, density, and fuel loading. In the 

absence of treatment, the Sunrise analysis area would continue to depart from historical conditions in 

all of the listed characteristics that contribute to the initiation of crown fire. Structure would remain 

multi-storied where it occurs and develop in areas not currently exhibiting multi-storied canopies. 

Density would increase in most areas under the No Action alternative creating the ability of fire to 

spread from crown to crown. Fire intolerant species would be allowed to occupy a more dominant 

role in the forested stands leading to physical characteristics that increase torching and the ability to 

initiate and sustain crown fire. Accumulating surface and aerial fuels would increase fire intensity

which is a major component driving initiation of crown fire.

Alternative B

Alternative B would include a mix of treatments including 5,520 acres of timber harvest; 1,068 acres 

of associated mechanical grapple piling; 878 acres of associated activity fuels prescribed burning; 585 

acres of mechanical and 1,677 acres of hand non-commercial mechanical thinning and ladder fuel 

reduction; and 14,055 acres of landscape prescribed burning. 

Thinning treatments are designed to reduce stocking levels and stand densities while altering species 

composition to favor fire-tolerant and insect and disease resistant species. 

Fire Regime Condition Class

Alternative B addresses the need to shift FRCC 2 and 3 acres towards FRCC 1 in fire regimes 1, 2 

and 3. Table 20 summarizes the existing FRCC within the Sunrise project area.
Final Environmental Impact Statement

Pomeroy Ranger District 81

Table 20. Existing fire regime condition class in the Sunrise project area.

Fire Regime Condition Class Acres Percentage

1 1 4,903 15

2 5,247 16

3 917 3

2 1 5,093 16

2 0 0

3 4,113 13

3 1 1,617 5

2 4,341 14

3 0 0

Table 20 summarized the post-treatment condition class by FRCC. This analysis is based on the 

definition of fire regime 1 representing HRV for all dry upland forest types described by Hessburg et 

al., 2005. Fire regime 3 represents a mix of both moist and cold upland forest types and ranges from 

mixed conifer, dry Douglas-fir and dry grand fir to mesic grand fir and Douglas-fir cover types. 

Overall, Alternative B would move approximately 19% (5,986) of upland forest towards a more 

resilient and historically appropriate condition. Alternative B would also treat 447 acres of condition 

class 2 in fire regime 2. 

Table 21. Fire regime condition class post treatment for Alternative B.

Fire Regime Condition Class Existing Acres Alt. B Post Treatment Acres Percentage Change

1 1 4,903 7,824 60

2 5,247 2,709 -48

3 917 534 -42

2 1 5,093 5,357 8%

2 0 0 0%

3 4,113 3,631 -10%

3 1 1,617 4,459 179%

2 4,341 1,377 -68%

3 0 0 0

Percentages are calculated based on 31,989 Forest Service acres within the planning area. Condition 

class was not calculated for Washington Department of Fish and Wildlife lands or Washington State 

Department of Natural Resources land. Acres were not double counted for post treatment 

effectiveness. For example, if 24 acres of a cutting unit intersected with landscape prescribed fire, the 

24 acres were only counted once in post treatment (Table 21.)

Reduction in Crown Fire Hazard 

The fuels and vegetative structure that initiates and spreads crown fire would be changed under 

Alternative B. The treatments would increase height to live crown, reduce surface fuel loading, shift 

the landscape towards fire adapted species, and reduce canopy bulk density in the treated areas. 

Commercial harvest and subsequent fuels treatments would significantly reduce the crown fire hazard 

by decreasing stem and crown densities, and reducing surface fuel loadings. Ladder fuels are 
Sunrise Vegetation and Fuels Project

82 Umatilla National Forest

significantly reduced through timber harvest and non-commercial thinning followed by underburning 

or grapple piling.

In dry upland forests, under the 75th percentile weather scenario, Alternative B treatments would treat 

approximately 2,859 acres of dry forest (fire regime 1) in the passive and crown fire category. Under 

the 95th percentile weather scenario 3994 acres of the dry forest would be treated in the passive and/or 

active crown fire categories. In moist upland forests (fire regime 3), under the 75th percentile weather 

scenario, 1,398 acres would be treated in the passive and/or active fire categories and under 95th

percentile weather, 2,858 acres would be treated. Table 22 summarizes the change in abundance of 

crown fire potential for fire regimes 1 and 3 under Alternative B. 

Table 22. Change in distribution of crown fire hazard in fire regimes 1 and 3.

Percentile Weather Fire Regime Crown Fire Hazard Existing Acres Acres Treated Percent Treated1

75 1 Surface 6,590 3,896 59

Passive 3,424 2,445 71

Active 1,063 414 39

3 Surface 3,289 2,670 81

Passive 2,049 1,038 51

Active 490 360 73

95 1 Surface 4014 2,561 64

Passive 3,390 2,645 78

Active 3,214 1,349 42

3 Surface 1,452 1,043 72

Passive 1,269 851 67

Active 2,829 2,007 71

1 Percent treated = acres treated divided by existing acres. For example 59 percent treated for percentile weather of 75, fire 

regime 1, surface fire simply means that 59 percent of existing 6,590 acres of surface fire is proposed for treatment.

The indirect effects of the action alternatives would be negligible. In the future, if there is no further 

action, it is anticipated the Fire Regime Condition Class and Crown Fire Potential will move toward 

where they are at present.

Alternative C

Alternative C would include a mix of treatments including 4830 acres of timber harvest; 329 acres of 

associated grapple piling and 2,730 acres of jackpot burning of activity fuels; 593 acres mechanical 

and 1,676 acres of hand non-commercial thinning and ladder fuel reduction; and approximately 

14,000 acres of landscape prescribed burning.

Thinning treatments are designed to reduce stocking levels and stand densities while altering species 

composition to favor fire tolerant and insect and disease resistant species. 
Final Environmental Impact Statement

Pomeroy Ranger District 83

Fire Regime Condition Class (FRCC)

Alternative C addresses the need to shift from condition classes 2 and 3 acres 

towards condition class 1. 

Table 23. Fire regime condition class post treatment for Alternative C.

Fire 

Regime

Condition 

Class

Existing 

Acres

Alt. C PostTreatment AcresPercentage 

Change

1

1 4,949 7557 54

2 5,237 2934 -44

3 902 575 -37

2

1 4,952 5535 9

2 0 0 0

3 4,036 3671 -11

3

1 1,597 4094 153

2 4239 1864 -57

3 0 0 0

Table 23 summarizes the post-treatment condition class by FRCC. This analysis is based on the 

definition of fire regime 1 representing HRV for all dry upland forest types described by Hessburg et 

al. 2005. Fire regime 3 represents a mix of both moist and cold upland forest types and ranges from 

mixed conifer, dry Douglas-fir and dry grand fir to mesic grand fir and Douglas-fir cover types. 

Overall, Alternative C would move approximately 16% (5,131 acres) of upland forest towards a more 

resilient and historically appropriate condition. Alternative C would also treat approximately 442 

acres of condition class 3 in fire regime 2. 

Reduction in Crown Fire Potential

In dry upland forests, under the 75th percentile weather scenario, Alternative C treatments would 

move approximately 2,570 acres of dry forest (fire regime 1) from passive or active crown fire

categories to the surface fire category. Under the 95th percentile weather scenario 3,673 acres of the 

dry forest would be treated in the passive and/or active crown fire categories. In moist upland forests 

(fire regime 3), under the 75th percentile weather scenario, 989 acres would be treated in the passive 

and/or active fire categories and under 95th percentile weather, 1592 acres would be treated. Table 24

summarizes the change in abundance of crown fire potential in moist upland forest under Alternative 

C. 

Table 24. Change in distribution of crown fire potential in fire regimes 1 and 3

Percentile 

Weather

Fire 

Regime

Crown Fire

Hazard

Existing 

Acres

Alt. C Post 

Treatment Acres

Percent 

Change

75 1 Surface 6,590 3,782 57%

Passive 3,424 2,219 65%

Active 1,063 369 35%

3 Surface 3,289 2,299 70%

Passive 2,049 646 32%

Active 490 343 70%
Sunrise Vegetation and Fuels Project

84 Umatilla National Forest

Percentile 

Weather

Fire 

Regime

Crown Fire

Hazard

Existing 

Acres

Alt. C Post 

Treatment Acres

Percent 

Change

95 1 Surface 4,014 2,478 62%

Passive 3,390 2,448 72%

Active 3,214 1,244 39%

3 Surface 1,452 761 52%

Passive 1,269 677 53%

Active 2,829 1,689 60%

In relation to indirect effects, it is believed that the indirect effects of the action alternatives would be 

negligible. In the future, if there is no further action, it is anticipated the Fire Regime Condition Class 

and Crown Fire Potential will move toward where they are at present.

Mitigation Measures

The Interagency Prescribed Fire Planning and Implementation Procedures Guide (PMS 484) 

provides standardized procedures specifically associated with planning an implementation of 

prescribed fire. Prior to implementing prescribed fire under the standards in the PMS 484, there must 

be compliance with the National Environment Policy Act (NEPA), National Historical Preservation 

Act (NHPA) and Endangered Species Act (ESA) requirements. PMS 484 describes what is minimally 

acceptable for prescribe fire planning and implementation and is documented, reviewed and signed in 

a Prescribed Fire Burn Plan. 

Cumulative Effects

Activities considered for cumulative effects are those that further modify indicators used in this 

analysis. The indicators utilized to measure changes in conditions for this analysis are fire regime

condition Class, associated HRV, and crown fire potential. Past actions were considered and 

addressed in the current conditions section of this document. For an activity to be considered a 

cumulative effect they must overlap in space and time with proposed treatments. The following 

reasonably foreseeable activities are recognized as having potential cumulative effects relating to 

fuels activities outlined in direct and indirect effects portion of this analysis. All activities listed below 

are expected to occur within the same time frame as implementation of the Sunrise project and are 

located within the project planning area. The same analysis area (Sunrise project planning area) used 

to analyze direct and indirect effects above are used in the cumulative effects analysis because effects 

are not expected to move outside the project planning area. 

Alternative A (No Action)

Because no direct or indirect effects would occur with implementing Alternative A, there are no 

cumulative effects.

Alternatives B and C

Asotin Prescribed Fire Project

Asotin Prescribed Fire project would treat 7,957 acres of Forest Service land within the Sunrise 

project planning area with prescribed fire. The objective of the Asotin Prescribed Fire project is to 

maintain, or reestablish, vegetation characteristics and disturbance regimes associated with fire 
Final Environmental Impact Statement

Pomeroy Ranger District 85

regimes of the Blue Mountains, and improve the health and resiliency of native grasses and shrubs to 

improve wildlife forage in big game winter range and bighorn sheep habitat. 

The Asotin Creek prescribed fire projects would contribute to the reduction of stands in condition 

class 2 and 3 in fire regimes 1, 2 and 3, and would reduce acres of passive and active crown fire. 

Table 25 and Table 26 display the amount of acres that would be effected in fire regimes 1, 2 and 3 in 

condition classes 2 and 3, and crown fire potential categories low, moderate and high. These effected 

acres are in addition to acres listed above in the effects analysis.

Table 25. Fire regime condition class post treatment for Asotin Creek prescribed fire project.

Fire 

Regime

Condition 

Class

Existing 

Acres

Asotin Post 

Treatment 

Acres

Percentage 

Change

1

1 4,949 6,181 25%

2 5,237 4,412 -16%

3 902 495 -45%

2

1 4,952 8023 62%

2 0 0 0

3 4,036 965 -76%

3

1 1,597 1,620 1%

2 4,239 4,216 -.05%

3 0 0 0

Table 26. Change in distribution of crown fire potential in dry upland forests

as a result of Asotin Creek prescribed fire.

Percentile Weather Fire Regime Crown Fire Hazard Existing 

Acres

Asotin Post Treatment 

Acres

Percent 

Change

75

1

Surface 6,590 7,776 18%

Passive 3,424 2,752 -20%

Active 1,063 549 -48%

3

Surface 3,289 3,312 1%

Passive 2,049 2,027 -1%

Active 490 489 0%

95

1

Surface 4,014 6,051 51%

Passive 3,390 2,751 -19%

Active 3,214 1,726 -46%

3

Surface 1,452 1475 2%

Passive 1,269 1,248 -2%

Active 2,829 2,828 0%

Irreversible and Irretrievable Commitment of Resources

For all action alternatives (B and C) there would be no irreversible or irretrievable commitment of 

resources with implementation of proposed activities.

Final Environmental Impact Statement

Pomeroy Ranger District 87

3.8 Wildlife Species and Habitat

A summary of the current conditions of the affected environment and the predicted effects of the 

Proposed Action and its alternatives are discussed in this section. Specific information on the 

methodologies, assumptions, and limitations of analysis and other details are contained in the Sunrise 

wildlife specialist’s report, incorporated herein by reference, and available to the public on the project 

webpage at http://www.fs.fed.us/nepa/fs-usda-pop.php/?project=45689. 

The Sunrise project would change the distribution and amounts of various types of wildlife habitat in 

the area. Habitat conditions and species status in the area are described, as well as changes that would 

be expected. This section includes the Biological evaluation for Threatened, Endangered, Proposed 

and Sensitive wildlife and invertebrate species. 

Regulatory Framework

The following federal laws relating to wildlife habitat and species apply to the Sunrise project: 

Endangered Species Act, Migratory Bird Treaty Act, National Forest Management Act, and the Bald 

and Golden Eagle Protection Act. Applicable Executive Orders are the Facilitation of Hunting 

Heritage, Wildlife Conservation Executive Order, and the Migratory Bird Order.

Agency policy direction is provided in the Forest Service Manual (FSM 2670) and the Umatilla 

National Forest Land and Resource Management Plan (Forest Plan) (USFS 1990). The Forest Plan 

contains standards and guidelines that must be met for specific Management Areas and wildlife 

habitats. The Eastside Screens Amendment (USFS 1995) and other direction amends some of the 

standards contained in the Forest Plan and establishes standards for old growth habitat, snag and 

down wood densities, and habitat connectivity. The standards and guidelines in the Forest Plan, as 

amended, apply to the proposed activities contained in this analysis. 

Methodology

The geographic scale of analysis for most species is the roughly 32,000 acre project area itself 

because it is large enough to encompass the home range or range for most species considered in this 

project area. The following exceptions are made: 

• Elk habitat is assessed by forest plan management area as described in the elk section, because 

forest plan standards for elk are specific to each area. 

• NFMA viability compliance for management indicator species is determined at the forest scale.

• Habitat for the primary cavity excavator group is assessed at the watershed scale. 

Time frames considered for direct, indirect, and cumulative effects to wildlife are short-term (within 

10 years), mid-term (10-50 years) and long-term (more than 50 years). These temporal scales are 

appropriate given the parameters of the proposed activities and the duration of potential effects to all 

wildlife species addressed in this document. Indirect effects are estimated for 10-50 years into the 

future because that is a timeframe in which changes in structure, species composition, and density are 

expected to remain measurable and predictable with a reasonable degree of certainty.

The cumulative effects analysis will consider the incremental effects of all past, present, and 

reasonably foreseeable future actions known in the analysis area. Projects are listed in section 3.5.
Sunrise Vegetation and Fuels Project

88 Umatilla National Forest

Information Sources

The quantity and quality of wildlife habitat and the effects of proposed activities were assessed using 

the following sources of information:

• Personal knowledge and personal communications with state and other wildlife biologists

• Notes, summaries, and other documents generated from field reconnaissance of the project area

• Publications, reports, and scientific papers

• Layers, data tables, graphics, maps and other information within and/or generated from information 

stored within the corporate Geographic Information System (GIS) database

• Aerial photos or other imagery

• Forest wide wildlife survey and observation records

• Project vegetation analysis and information from other specialist reports 

• Other vegetation data such as Current Vegetation Survey and Gradient Nearest Neighbor datasets 

to evaluate snag densities

• DecAID online repository of information on dead wood habitat

Incomplete and Unavailable Information 

The presence or absence of many wildlife and invertebrate species in the project area is unknown. If 

habitat is present, we assume that the species may be present now or in the near future. Where 

information is available, it is presented. 

Affected Environment

Resource Indicators and Measures 

Proposed silviculture treatments could change forest stand structure, composition, and density on a 

maximum of 7,790 acres. An additional 14,055 acres would be burned in a mosaic fashion, over a 

period of years. This totals nearly 70 percent of the 32,000 acre project area. Some wildlife species 

may benefit from these changes while others may not, and there are short term versus long term tradeoffs. 

The following categories of wildlife or habitats are discussed: elk habitat, old forest structure, 

Management Indicator Species, threatened, endangered and sensitive wildlife species, and sensitive 

invertebrate species (Table 27). The main issue utilized for alternative development in this EIS

reflects several wildlife issues that were brought up during project scoping. Alternative C was 

developed to respond to the wildlife habitat issue.

Table 27. Resource indicators and measures for assessing effects.

Resource Element Resource Indicator Measure

Used to 

address 

issue?

Elk habitat Amount and distribution Acres Yes

Old Forest Amount and distribution Acres Yes

Source habitat for Management 

Indicator Species

Amount and distribution Acres Yes

Snag and down wood habitat Amount and distribution Acres Yes

TES wildlife species Presence of species or habitat Determination of effects No

Sensitive invertebrate species Presence of species or habitat Determination of effects No
Final Environmental Impact Statement

Pomeroy Ranger District 89

The National Forest Management Act (NFMA) directs the Forest Service to provide habitat to 

maintain viable populations of existing native and desired non-native vertebrate species. Management 

Indicator Species (MIS) were selected for emphasis in planning, and are assessed during forest plan 

implementation in order to determine the effects of management activities on their populations and 

the populations of other species with similar habitat needs. The amount and quality of habitat is used 

as a proxy for determining the effects of projects on MIS. All of these Management Indicator Species 

could be present in the project area (Table 28.)

Table 28. Wildlife management indicator species for the Umatilla National Forest.

Species Habitat Types

Rocky Mountain elk general forest habitat and winter ranges

American marten mature and old growth stands at high elevations

primary cavity excavators dead/down tree (snag) habitat

pileated woodpecker dead/down tree habitat (mixed conifer) in mature and old growth stands

northern three-toed woodpecker dead/down tree habitat (lodgepole pine) in mature and old growth stands

Existing Conditions and Environmental Consequences

Elk Habitat

Rocky Mountain elk was selected as an indicator species in the Umatilla Forest Plan (FP) to represent 

general forest habitat and winter ranges for big game. Elk habitat serves as an indicator of the quality 

and diversity of general forested habitat, the interspersion of cover and forage areas, and security 

provided by cover and low levels of human activity. 

Elk use a variety of habitat types in all successional stages, and patterns of use change both daily and 

seasonally. Elk are primarily grazing animals, preferring a diet of grasses and forbs, but in winter they 

turn to browsing the tips of twigs from willow, alder, aspen or other woody vegetation (Csuti et al. 

2001). Summer nutrition is extremely important for elk survival into the following year. Summer elk 

forage consists of a combination of lush forbs, grasses, and shrubs that are high in nutrients and easily 

digestible. Early summer diets in the Blue Mountains include big huckleberry and snowberry, while 

elderberry, ninebark, and ocean spray become more important in late summer (Korfhage et al. 1980). 

Generally, higher elevation wet meadows, springs, and riparian areas in close proximity to forested 

stands offer these conditions for the longest period. Such areas provide nutritious forage and moist, 

cool places for bedding and escaping summer heat and insects (ODFW 2003).

The Sunrise project is within the Lick Creek Game Management Unit. Surveys conducted by WDFW 

in 2017 indicated that there are approximately 650 elk in the Lick Creek Unit (Wik, pers. Commun.), 

which is low compared to the previous 5 years. The 8 year average in Lick Creek is about 850 elk and 

in some years has achieved the management objective of 1,000 elk. The entire Blue Mountain elk 

population in Washington, however, has generally been doing well, with total numbers meeting the 

state objective of 4,950-6,050 elk for the past 7 years (Wik and Vekasy 2016).

Scale of Analysis for Forest Plan Standards

The Sunrise project area falls within summer range, winter range, and calving habitat for elk. Forest 

plan standards for elk are specific to each Management Area (MA). Generally the winter range 

actually used by elk overlaps our forest plan MA-C3, but not exactly. Summer use and calving areas 

in this project are mostly in MA-C4 and C8. Forest plan standards for percent cover, HEI, and road 
Sunrise Vegetation and Fuels Project

90 Umatilla National Forest

density are currently being met in each of the Sunrise project elk analysis areas. Three management 

areas are assessed for the Sunrise project: 

MA-C4, Wildlife Habitat: designated in the Forest Plan to ‘provide high levels of potential habitat 

effectiveness for big game and other wildlife species’ (FP 4-158). A mosaic of even-aged and 

uneven-aged stands dispersed in a manner is desired to create a pattern of forage and cover. 

Managing roads is emphasized to provide big game security.

MA-C3, Big Game Winter Range: designated to provide high levels of potential habitat effectiveness 

and high quality forage for big game (FP 4-151). The desired condition is a mosaic of 

managed forest, brush patches, and large grasslands. Forested areas will contain a mix of 

harvested even-aged, uneven-aged, and natural stands, creating patterns of cover and forage 

areas. MA-C3A, Sensitive Big Game Winter Range, is included in the overall winter range 

analysis because it has the same standards as MA-C3.

MA-C8, Grass-Tree Mosaic: designated to provide (in part) high levels of potential habitat

effectiveness and high quality forage for big game (FP 4-171). Desired condition is natural 

appearing patches or stringers of timber on open steep hillsides. Stands may be mature multilayered timber or more open as the result of management designed to improve big game 

habitat. The MA-C8 in the Sunrise project is roadless and relatively unmanaged. 

Three forest plan standards are used to evaluate effects of management actions on elk habitat: percent 

tree cover, open road density, and habitat effectiveness. The Habitat Effectiveness Index (HEI) model 

combines the amount of elk cover, the ratio and configuration of cover and forage areas, and open 

road density to provide an index value. Elk forage and elk security are also discussed, but there are no 

forest plan standards. 

Tree Cover

Forested stands with relatively closed canopies are often used by elk disproportional to their 

availability and can function as hiding cover or reduce the difference between an animal's body 

temperature and ambient air temperature. Research from the nearby Starkey Experimental Forest 

(Cook et al. 1998) and other studies suggest that the presumed thermal benefits of cover could not be 

substantiated, but recognized that multi-story forested stands are important to elk because of their 

tendency to use these areas throughout the year. 

The Forest Plan defines satisfactory cover as a stand of trees at least 40 feet tall and providing 70 

percent or more canopy closure. Marginal cover is defined as a stand of trees at least 10 feet tall and 

providing 40 percent or more canopy closure. Both types should have sufficient understory structure 

to obscure 90 percent of a standing elk at a distance of 200 feet. There is no forest plan standard for 

marginal cover; rather it is added to satisfactory cover for the total cover standard. 

MA-C3 is right at the minimum of 30 percent total cover. No overstory harvest is proposed in this 

area. Only small diameter tree cutting and prescribed burning are proposed in MA-C3 and 

C3A.

MA-C4 is 53 percent cover, well above the forest plan minimum of 30%; however, the roadless area 

is providing much of the cover while the managed areas are lacking. Outside of roadless, 

MA-C4 has only 20% elk cover, however the forest plan is designed to include roadless in 

these calculations. Alternative C addresses the issue of cover distribution.. 
Final Environmental Impact Statement

Pomeroy Ranger District 91

MA-C8 is well above the minimum forest plan standards for cover. It is roadless and the only recent 

management in the area has been landscape prescribed fire. 

Open Roads

All three elk analysis areas have relatively low open road densities and are within the desired 

condition of an average of 2 miles per square mile or less, forest-wide (FP p. 4-11).

MA-C3 has 13 miles of road and about 5 miles of motorcycle trail open in the summer and fall, but 

roads are gated December 1 for the winter. The main access road (FR 41) opens April 1, but 

arterial roads are closed until July 1 to limit disturbance to elk calving. The summer open 

road density is 1.2 miles per square mile. 

MA-C4 open road density is 1.2 miles per square mile. Approximately one third of the MA-C4 is 

within the Asotin Creek Roadless Area. MA-C8 is completely within the Asotin Creek 

Roadless Area. Less than 1 mile of road is open in this area for .05 miles per square mile.

Habitat Effectiveness Index

The elk habitat effectiveness index model (HEI) is used to predict the influence of forest management 

on elk and other big game species. The model uses the distribution of cover and forage areas, cover 

quality, and road factors to help indicate how effective an area will be in supporting big game 

(Thomas et al. 1988.) It is intended to be a relative measure of habitat, and does not consider many 

other factors such as topography, forage quality, weather, predation, and hunting. The HEI model 

provides an index rating from 0 to 1, with 0 indicating the least effective elk habitat and 1 indicating 

optimal effective habitat. The index number is multiplied by 100 to get a whole number for 

comparison purposes. 

MA-C3 elk analysis area has an HEI value of 78, which is above forest plan standard of 70. The value 

is high because all roads are closed in the winter, which creates effective habitat during the 

winter use period.

MA-C4 HEI value is 70, which is above the minimum forest plan standard of 60. Although this value 

is high, it does not reflect the poor distribution of cover in much of the C4 analysis area. The 

roadless area has good cover and no open roads, which brings up the overall HEI value. 

MA-C8 HEI value is 82, well above the forest plan standard of 70. The high value is due to the area 

being roadless and not having previous timber harvest.

Table 29. Percent tree cover, HEI value, and open road density by management area.

Scale Measure Forest Plan Standard Existing Condition

Management Area C3/C3A

(7,070 acres)

Satisfactory Cover 10 % 16 %

Total Cover 30 % 30 %

HEI 70 78

Open Road Density < 2.0 1.2

Management Area C4

(13,425 acres)

Satisfactory Cover 15 % 36 %

Total Cover 30 % 53 %

HEI 60 70

Open Road Density < 2.0 1.2

Management Area C8 Satisfactory Cover 10 % 18 %
Sunrise Vegetation and Fuels Project

92 Umatilla National Forest

Scale Measure Forest Plan Standard Existing Condition

(9,670 acres) Total Cover 30 % 33 %

HEI 70 82

Open Road Density < 2.0 .05

Elk Security

The forest plan uses an open road standard in part to address elk security, as described above under 

the Open Road heading and Habitat Effectiveness heading. Continued research and monitoring 

indicates that open roads cause a significant amount disturbance to elk particularly during hunting 

seasons. 

Elk have been found to select habitats preferentially based on increasing distance from open roads 

(Rowland et al. 2000). Vulnerability and hunting mortality have been found to be higher in forested 

stands with greater road densities and less hiding cover (Weber et al. 2000). The Sunrise project area 

was included in an elk study that showed higher elk mortality (e.g. hunter success) near roads 

(McCorquodale et al. 2010). Unregulated hunting is also contributing to elk mortality near roads 

(WDFW letter). 

Elk security is defined in the revised forest plan (not yet in place) as areas 250 acres or larger at least 

one half mile from an open road. The desired condition is 30 to 100 percent security within priority 

subwatersheds (Blue Mountain Forest Plan Revision FEIS). 

Approximately 30 percent of the Lick Creek subwatershed is providing elk security, and 35 percent of 

the Asotin watershed is providing elk security. There is a desire by WDFW to see a reduction in open 

road density in summer elk range to increase the amount of elk security area, thereby providing 

critical quality nutrition necessary for improved pregnancy rates and calf rearing for a population that 

has been declining for the past 3-4 years. This quality habitat is also necessary to keep elk 

distribution on public lands, versus elk moving to private lands where conflict occurs and elk 

numbers are not socially sustainable (Wik pers. commun.).

Elk Forage

Forage availability can be affected by competition with livestock, invasive plants, and created 

openings. However, the amount and quality of forage is largely controlled by the year to year weather 

(Wisdom et al. 2005).

Grazing occurs in primarily winter range (MA-C3) and grass-tree mosaic (MA-C8) management 

areas on the north half of the project planning area. Active pastures (8,000 acres) include Lick and 

Charley in the Peola Allotment, and Park/Cook and Hogback in the Asotin Allotment. Monitoring in 

2016 indicates that forage utilization is within Forest Plan standards (Project Range Report). These 

utilization standards were calculated to provide forage for both livestock and big game. Once an area 

has reached full utilization, livestock must move out in order to reserve remaining forage for big 

game.

Timber management, grazing, and prescribed fire can all contribute to the spread of invasive plants. 

Several species of non-native invasive plants are present in the Sunrise project area, including yellow 

star thistle, spotted knapweed and diffuse knapweed (Invasive Plant Report). Uncontrolled spread of 

invasive plants can have substantial impacts to elk forage resources (Sheley and Petroff 1999). 

Fortunately efforts to control invasive plants on the Umatilla forest have prevented widespread 

reductions of native big game forage species. 
Final Environmental Impact Statement

Pomeroy Ranger District 93

Late and Old Forest

A number of species present on the Umatilla National Forest require late and old structure habitat. 

These species include pileated woodpecker, white-headed woodpecker, Lewis’ woodpecker, pine 

marten, northern goshawk, Cooper’s hawk, sharp-shinned hawk, flammulated owl, great gray owl, 

Vaux’s swift, Townsend’s warbler, Hammond’s flycatcher, and others.

The Forest Plan allocated specific areas as Management Area C1-Dedicated Old Growth to provide 

old growth forest habitat across the Forest. No timber harvest is allowed in these areas. Four 

dedicated old growth stands are designated within the project boundary, totaling 1,785 acres (Figure 

4). All are on steep hillsides along Asotin Creek. These areas are large compared to most dedicated 

old growth stands on the forest, the largest of which was designated as a replacement for MA-C1 that 

was burned in the School Fire. 

In addition, the Eastside Screens (USFS 1995) were implemented to preserve options for long term 

ecosystem strategies that would maintain habitat for species dependent on late and old forest 

structure. Harvest in late and old structure stands is restricted in some cases, and stands connecting 

them are given special consideration to prevent short term habitat fragmentation. The Eastside 

Screens also establish desired conditions for snags and down wood, and protection for goshawk 

nesting areas. 

An analysis of stand conditions in the Sunrise project area was completed to determine the amount 

and distribution of old forest structure (Silviculture Report). Old forest structure is generally wide 

spread and well connected in the project planning area (Table 30), totaling 13,200 acres or 57 percent 

of the forested acres. 

While only structure is considered for the purposes of identifying old forest, a number of other factors 

actually affect the quality and effectiveness of these stands for providing habitat for associated 

wildlife species. In addition to large diameter trees, old growth habitat would consist of large 

diameter snags and downed wood, stand complexity/heterogeneity, and trees with broken tops, 

decay/hollows, wind/ice/fire damage, mistletoe brooms, and other features indicative of decadence. 

These elements were not evaluated in most of these stands. 

The total amounts of old forest are within the ranges of variation for each biophysical environment, 

but the amount of old forest single stratum is far below and the amount of old forest multi strata is far 

above the reference condition for both moist and dry forest (Table 30). Therefore Scenario A of the 

Eastside Screens was applied such that no net decrease in old forest would occur from timber removal 

activity. Harvest is allowed in old forest but only to maintain or enhance late and old structure habitat

within a particular biophysical environment, or to move one type of late old structure habitat into 

another that is deficit (OFMS to OFSS). No trees greater than or equal to 21 inches in diameter at 

breast height (DBH) would be cut, under any action alternative. 

Table 30. Old forest structure range of variation and current conditions.

Potential Vegetation 

Group

Old Forest Multi-strata % Old Forest Single-stratum %

Total Old Forest 

Range of Acres

Variation Current Range of Variation Current

Dry 1-15 59 40-65 7 7295

Moist 15-20 52 10-20 < 1 5175

Cold 10-25 27 5-20 2 445

Total 12915
Sunrise Vegetation and Fuels Project

94 Umatilla National Forest

Douglas-fir and ponderosa pine cover types dominate the northern two thirds of the project planning 

area. At higher elevations on the southwest part of the project area, grand fir and subalpine fir are 

prominent. 

The largest component of old forest is in the Douglas-fir cover type (7,900 acres), followed by grand 

fir (2,285 acres) and ponderosa pine (2,225 acres). Douglas-fir is considered ‘overrepresented’ 

compared to the range of variation for the Umatilla forest (Powell 2014), but provides the majority of 

old forest in this project area.

Single stratum old forest in the ponderosa pine cover type is rare, occurring in a handful of widely 

scattered stands (320 acres). This is due to past harvest and fire suppression. 

Table 31. Old forest cover types (acres).

Cover Type OFMS OFSS Total Old Forest

Douglas-fir 7,190 540 7,730

Grand fir 2,270 0 2,270

Ponderosa pine 1,805 320 2,125

Subalpine fir/other 760 30 790

Total 12,025 890 12,915

American Marten

The American marten (Martes americanus) was selected as a Management Indicator Species in the 

Forest Plan to represent mature and old growth stands at high elevations. 

In Oregon, American marten occur in the southern Oregon Coast Range, Siskiyou Mountains, 

Cascade Mountains, and Blue Mountains (Marcot et al. 2003). The global conservation status of 

marten is considered ‘widespread, abundant, and secure’ (NatureServe 2015). 

A study in northeastern Oregon showed that martens selected for areas with denser canopy, more 

canopy layers, larger diameter live and dead trees, larger down logs, and closer proximity to water as 

compared to what was available in the area (Bull et al. 2005). 

Marten use a variety of structures for rest and den sites, such as tree cavities, mistletoe brooms, and 

accumulations of down logs (Bull and Heater 2000). Bull et al. (2005) found density of potential rest 

sites was significantly higher in marten home ranges than in unoccupied areas. 

In a comparison of historical versus current conditions in the Blue Mountains, marten habitat appears 

to be strongly increasing (Wisdom et al. 2000). Suitable environments for marten are broadly 

distributed and of high abundance on the Umatilla National Forest, and there has been little change 

from historical to current conditions (Wales et al. 2011). The Umatilla National Forest provides 

roughly 100,000 acres of marten source habitat according to Wales et al. analysis. Source habitat is 

defined as those habitats contributing to long-term population persistence (Wisdom et al. 2000). 

Recent vegetation data was used to determine the current amount and distribution of marten habitat in 

the project area. The project area provides about 6,225 acres of well-distributed marten habitat, 

generally associated with the headwaters of Asotin Creek. 

A study in Eastern Oregon indicated that the average home range size for males was about 6,700 

acres, and the average for females was about 3,500 acres (Bull and Heater 2001). Home ranges 
Final Environmental Impact Statement

Pomeroy Ranger District 95

typically include both source habitat as well as foraging areas and non-habitat. The authors suggest 

that a marten reproductive pair would likely have higher success where an average of 6,700 acres are 

available for foraging and denning. Although no marten observations have been recorded in this area, 

it is possible that the area could support a reproducing pair of marten.

According to the HRV analysis, old forest multi-strata is overrepresented compared to the range of 

variability in the Blue Mountains. The area is probably not capable of maintaining this amount of 

marten habitat over the long term. Considering there are 5,150 acres of existing moist old forest 

multi-strata, and 1,500-2,000 being the ‘desired range’ for long term sustainability, it follows that the 

area should have about half as much structurally diverse marten source habitat (OFMS) as is currently 

being provided.

Dead and Down Tree Habitat

Primary cavity excavators as a group were selected to represent dead/down tree (snag) habitat that a 

wide array of species depend on for reproduction and/or foraging. Primary cavity excavators (PCE) 

create holes for nesting or roosting in live, dead or decaying trees. Secondary cavity users such as 

owls, bluebirds, and flying squirrels may use these cavities later for denning, roosting, and nesting. 

Populations of cavity nesting birds may have declined across the Blue Mountains compared to 

historical conditions, primarily due to reductions in the numbers of large snags (Wisdom et al. 2000). 

However, breeding bird surveys since 1966 indicate a stable, increase, or positive population trend for 

most of the PCE species in Oregon (Sauer et al. 2014). Partners in Flight (PIF) data indicate that some 

species may be ‘of concern.’ Lewis woodpecker and white-headed woodpecker have the highest 

concern PIF scores of all PCEs, and both are listed on our Regional Forester’s Sensitive species list. 

They are addressed specifically later in this document (see TES wildlife section). 

Additional information on cavity-excavating birds’ habitat associations, distribution and life history 

requirements is summarized in Mellen-McLean (2012a). Habitat for primary cavity excavators 

includes coniferous and hardwood stands in a variety of structural stages and the availability of dead 

trees in various size and decay classes (Thomas et al. 1979). Primary habitat generally contains snags

greater than 15 inches DBH, while smaller sizes provide secondary habitat. 

Because dead and down tree habitat was selected to represent primary cavity excavators, this analysis 

and discussion focuses primarily on that habitat component. While maintaining snags and down wood 

in managed areas contributes to providing habitat for cavity excavators, habitat for each woodpecker 

species is more than just dead wood, and different for each species. Snag availability is the most 

limiting factor because that is where reproduction occurs.

Treatment unit standard

The Forest Plan established minimum standards for snag retention in harvest units based on a 1970’s 

publication that synthesized the habitat requirements of snag-associated species (Thomas et al. 1979). 

Snag retention in harvest units, plus acre amounts of habitat in the area, presumed a level of PCE 

viability. The forest plan also determined that in addition to snag retention in harvest units, Dedicated 

Old Growth areas, the amount of other old forest, and the amount of forest that would not be managed 

(e.g. wilderness, etc.) would provide for viable populations. 

The biological potential model used in the forest plan is an outdated technique for determining both 

snag retention needs at the unit level and for determining viability of woodpecker populations at the 

forest level (Rose et al. 2001). New information about the ecology, dynamics, and management of 
Sunrise Vegetation and Fuels Project

96 Umatilla National Forest

decayed wood has been published since then, and the state of the knowledge continues to change. 

However, until the forest plan is amended to reflect the new science, the 100% biological potential 

calculation is the minimum number of snags that need to be maintained through the life of the stand 

rotation. 

The Sunrise project snag recommendation exceeds the minimum required by the Forest Plan by 

requiring retention of all snags > 20 inches dbh, except for hazard trees. If there are less than 3 large 

snags per acre available, smaller snags would be retained to meet at least 3 per acre at a minimum. 

Actual snag density would most likely be much higher since all large snags would be retained 

wherever possible. In addition to snag retention in harvest units, design criteria for snag replacement 

trees and down wood is provided (see Ch. 2 Design Criteria). 

Dead and Down Wood Analysis

Historic Range of Variability

Integration of the latest science is incorporated into this analysis using DecAID Advisor (version 2.2) 

(Mellen-McLean et al. 2012) which is an internet-based summary, synthesis, and integration (a "metaanalysis") of the best available science: published scientific literature, research data, wildlife 

databases, forest inventory databases, and expert judgment and experience. In addition to data 

showing wildlife use of dead wood, DecAID also contains data showing amounts and sizes of dead 

wood across the landscape based on vegetation inventory data.

Project area contribution to the forest wide viability of primary cavity excavators (PCE) is assessed 

using the historical range of variability (HRV) concept; comparing current amounts and distribution 

of habitat to historical conditions (Wisdom et al. 2000, Suring et al. 2011). Scientists assume that 

species are more likely to persist into the future under the conditions that remain most similar to the 

conditions that they persisted in during the past (Landres et al. 1999, Samson et al. 2003). By 

managing habitat within HRV it is assumed that adequate habitat would be provided because species 

survived those levels of habitat in the past to be present today. Thus, if we manage current habitats 

within the range of historic variability, we are likely to do an adequate job of maintaining population 

viability for those species that remain. Generally the further current habitat conditions are from HRV, 

the more likely it is that population viability would be compromised.

Reference conditions

USFS Region 6 Continuous Vegetation Surveys (CVS) are permanent plots on a 1.7-mile grid that 

sample the vegetative condition on Forest Service land (Brown 2003). DecAID contains snag

information from this data source by watershed and by habitat types. CVS data collected from plots 

that fell within unharvested areas of the Blue Mountains is used as a reference condition. Data for the 

small/medium, large, and open structure classes was weighted to best reflect HRV conditions on the 

Umatilla Forest as determined by the Forest Silviculturist (Powell 2014). Although the data from 

unharvested areas may not accurately reflect “pre-settlement” or “natural” conditions in eastside 

forests due to years of fire exclusion (Mellen-McLean et al. 2012), it is comparable to other estimates 

of historical dead wood densities (Harrod et al. 1998, Agee 2002, Ohmann and Waddell 2002). 

Current levels of dead wood may be elevated above historical conditions in some areas due to fire 

suppression and increased mortality, and may be depleted below historical levels in local areas burned 

by intense fire or subjected to repeated salvage and firewood cutting (Mellen-McLean et al. 2012). 

Even with this caveat, the CVS reference data are used in this analysis because: they are still some of 

the best data available to assess HRV of dead wood, even in eastside dry forests; they are the only 

available data showing distribution and variation in snag and down wood amounts across the 
Final Environmental Impact Statement

Pomeroy Ranger District 97

landscape; and the data from unharvested stands are in the range of other published data on HRV of 

dead wood even in the drier vegetation types (Mellen-McLean 2011). 

Existing conditions

Current snag and down wood habitat for the Sunrise project was evaluated using the 2012 Gradient 

Nearest Neighbor (GNN) vegetation data (Ohmann and Gregory 2002). GNN produces pixel-based 

maps with associated snag and down wood data. In addition, this data was updated with snags 

identified by aerial detection surveys from 2013 through 2016. 

GNN snag and down wood data is organized by watershed and habitat type. The Sunrise project is 

entirely within the George Creek-Asotin Creek Watershed. The portion of the watershed that lies 

within the National Forest boundary is approximately 63,155 acres (Figure 3-9). Of the forested area, 

only the Eastside Mixed Conifer East Cascades/Blue Mountains (EMC/ECB) wildlife habitat type 

(WHT) (Mellen-McLean et al. 2012) had sufficient acreage to analyze (41,220 acres). 

Snags

Snag data was weighted by structure type to result in one number that reflects the proportion of data 

within each type (large, open, and small/medium) for the entire snag analysis area. A distribution 

analysis was used to determine how close current conditions for snags on the landscape match 

reference conditions. For a comparison of approximated existing snag density distributions in the 

Sunrise snag analysis area to reference conditions see the Wildlife Report.

Updates to the 2012 GNN data within the snag analysis area included aerial detection surveys 

conducted between 2013 and 2016 to estimate impacts of insects and disease and the Little Butte 

prescribed fire. The aerial detection surveys detected approximately 1,660 acres of low density large 

snags and small snags. The Little Butte prescribed fire was implemented in September 2016 with 

approximately 775 acres burned and about 1% of the burn area resulted in snag creation. 

Not included in the analysis, but worth mentioning are several fires that have contributed to snag 

creation on the landscape within the last decade. In 2014, the Wenatchee prescribed fire was 

implemented by the Forest adjacent to the Sunrise planning area in the Lower Grande Ronde River 

Watershed. This burn was approximately 4,300 acres and about 5% of the area resulted in snag 

creation. No recent wildfires occurred within the Sunrise snag analysis area; however, there were 

three large wildfires that occurred in adjacent or nearby watersheds since 2005 that added to snags 

and down wood across the landscape (Table 13). Variable effects resulted from these fires, from light 

burn to severe burn, with much of it in non-forested areas. 

Table 32. Recent fire events on Pomeroy Ranger District.

Fire Name Type FS Acres Year

School Fire Wildfire 26,000 2005

Columbia Complex Wildfire 48,000 2006

Grizzly Bear Complex Wildfire 71,000 2015

Wenatchee Prescribed burn 4,300 2014

Little Butte Prescribed burn 775 2016

Generally, there is a relatively good distribution of snag densities in the Sunrise snag analysis area 

and densities are fairly consistent with reference conditions for both > 10 and > 20 inch dbh snags. 

There is a slight deficiency in larger snags in the 4-6 snags/acre density class and a slight abundance 

of larger snags in the 0-2 snags/acre density class (Figure 3-4 and ). 
Sunrise Vegetation and Fuels Project

98 Umatilla National Forest

Figure 3-4. Distribution of percent cover of down wood > 5 inches diameter in moist upland forest in the 

snag analysis area (41,220 acres).

Figure 3-5. Distribution of percent cover of down wood >20 inches diameter in moist upland forest in the 

snag analysis area (41,220 acres).
Final Environmental Impact Statement

Pomeroy Ranger District 99

Snag densities are at or above the 30%, 50%, and 80% tolerance levels for several primary cavity

excavator species (gray area in Table 33). Although not meeting all of the highest tolerance levels 

(unshaded blocks), areas of high snag density habitat are available within the George Creek-Asotin 

Creek Watershed and across the landscape. In addition, not meeting each level does not indicate that 

the species would not be present. A 50% tolerance level means that 50% of the woodpecker 

observations were in those snag densities. Therefore 50% were also observed in study areas with 

higher or lower snag densities.

Snag densities are meeting the 80% tolerance level for white-headed woodpecker, pygmy nuthatch, 

and black-backed woodpecker. Recent fires outside of the project area are also providing post-fire 

habitat for black-backed woodpeckers. 

Pileated woodpecker and Williamson’s sapsucker generally use areas with high snag densities. While 

this condition may be more limited, areas of higher snag density (>12 per acre) occur on 38 percent of 

the snag analysis areas. For snags greater than 20 inches dbh, habitat for Williamson’s sapsucker and 

pileated woodpecker meet both the 30% and 50% tolerance levels on about 20 percent of the snag 

analysis area (> 4 snags per acre). 

Many observations of pileated woodpeckers have been recorded over the years throughout the project 

area and in adjacent areas. Williamson’s sapsucker have also been documented.

Table 33. Tolerance levels for woodpeckers occurring in Eastside Mixed Conifer/Blue Mountains habitat

type (DecAID Table EMC_S/L.sp-22) Snag density/acre for 30%, 50%, 80% tolerance levels.1

Species >10” dbh >20” dbh

Tolerance level 30% 50% 80% 30% 50% 80%

White-headed woodpecker 0.3 1.9 4.3 0.0 1.5 3.8

Pygmy nuthatch 1.1 5.6 12.1 0.0 1.6 4.0

Black-backed woodpecker 2.5 13.6 29.2 0.0 1.4 5.6

Williamson’s sapsucker 14.0 28.4 49.7 3.3 8.6 16.6

Pileated woodpecker 14.9 30.1 49.3 3.5 7.8 18.4

1 A tolerance level is an estimate of percent of individuals in a population that use a particular range of values. 50% tolerance 

means that studies showed 50% of sites used by the species were in areas with that snag density. Gray shading indicates 

levels in the Sunrise snag analysis area are at or above Blue Mountains reference values.

Down wood 

A distribution analysis was used to determine how close current conditions for down wood on the 

landscape match reference conditions. Figures 8 and 9 are a comparison of approximated existing 

percent cover of down wood in the Sunrise snag analysis area to reference conditions. As snags fall 

down, more down wood is created. The analysis did not include fall down rates of snags after 2012. 

Only a slight increase of down wood between 2012 and the present would be expected and the change 

would not be significant in this analysis.

Generally, there is a relatively good distribution of down wood in the Sunrise snag analysis area. 

Small diameter (>5 inches) down wood is mostly in excess of reference conditions (Figure 3-10). 

Large diameter (>20 inches) down wood is fairly consistent with reference conditions, with some 

variation (Figure 3-11). The amount of the analysis area with more than 2 percent cover is less than 

reference conditions, which indicates there is a slight deficiency of large diameter down wood in 

these cover classes. The >2 percent class reference is 10 percent of the area, and the current condition 

is about 5 percent of the area, so it is small in proportion to the entire analysis area. 
Sunrise Vegetation and Fuels Project

100 Umatilla National Forest

Pileated Woodpecker

The pileated woodpecker (Dryocopus pileatus) is an MIS for old growth habitats. Below is a 

summary of pileated woodpecker ecology important to providing information pertinent to assessing 

impact of the project on the species. For additional details see Mellen-McLean (2012a) in the analysis 

file. Also see the body of work by Evelyn Bull in the Blue Mountains (Bull 1987, Bull and 

Holthausen 1993, Bull et al. 1992, Bull et al. 2007) and Nielsen-Pincus and Garton (2007).

Pileated woodpeckers are widely distributed in forested areas of eastern North America, westward 

across a large swath of forest in Canada, and then southward into Montana, Idaho, Washington, 

Oregon, and California (NatureServe 2017). The pileated woodpecker is ranked as ‘widespread, 

abundant, and secure’ globally, and ‘apparently secure’ in Washington (NatureServe 2017). The state 

of Washington lists pileated woodpecker as a ‘priority species.’ The PIF database (Partners in Flight 

2012) indicates an increasing population and expected future ongoing stability.

Pileated woodpeckers are associated with late seral stages of the subalpine, montane, lower montane 

forests and specifically old forest structure in mixed conifer forests (Wisdom et al. 2000). In the Blue 

Mountains, densities of nesting pairs of pileated woodpeckers were positively associated with the 

amount of late structural stage forest and negatively associated with the amount of area with 

regeneration harvests since 1970 (Bull et al. 2007). 

Snags, down logs, and large hollow trees are important habitat components for pileated woodpeckers. 

Approximately 90 percent of the diet of these birds consists of carpenter ants, which are associated 

with large standing and down wood. Ponderosa pine, Douglas-fir and western larch were preferred 

species for foraging substrate (Bull and Holthausen 1993). The woodpeckers also use large, decadent 

trees and hollow grand fir for roosting (Bull et al. 1992). The majority of roost trees were hollow 

grand fir infected with Indian paint fungus and large ponderosa pine snags. 

Within mixed conifer forest, pileated woodpeckers nested preferentially in ponderosa pine and 

western larch in northeast Oregon (Bull 1987, Nielsen-Pincus and Garton 2007). Bull and Holthausen 

(1993) found that density of large snags (> 20 inches dbh) was the best predictor of density of 

pileated woodpeckers in the Blue Mountains. 

Due to an increase in dense, multi-canopy stands due to fire suppression, habitat for pileated 

woodpeckers is increasing across the Blue Mountains (Wisdom et al. 2000). However, densities of 

large-diameter snags (>20 inches dbh) have declined from historic to current levels (Wisdom et al. 

2000, Korol et al. 2002). 

According to 2012 GNN data, snag densities of large snags are providing habitat at the 50% tolerance 

level for pileated woodpeckers (see Wildlife Report). The 80 % tolerance level is not met, however 

the density indicated (over 18 large snags per acre) is an unusual condition and would only be 

expected on two percent of the landscape, or 800 acres. This density is provided on about 400 acres of 

the snag analysis area (Figure 3-9).

The project area contains approximately 10,300 acres of pileated woodpecker habitat. Mean home 

range size for paired birds in northeastern Oregon was 1,180 acres (Bull and Holthausen 1993), which 

would include both reproductive and foraging habitat. Based on habitat distribution, the Sunrise 

project area could reasonably support eight pair of pileated woodpeckers. Many observations of 

pileated woodpeckers have been recorded over the years throughout the project area and in adjacent 

areas.
Final Environmental Impact Statement

Pomeroy Ranger District 101

Dedicated Old Growth areas are generally providing good habitat for pileated woodpecker forest 

wide. In 1992, biologists surveyed 100 Dedicated Old Growth areas in the Blue Mountains, including 

20 on the Umatilla National Forest (NF). All of the areas surveyed on the Umatilla NF (100%) were 

occupied by pileated woodpecker at that time (Bull and Carter 1993). The current forest management 

emphasis on retaining large trees and old forest conditions is beneficial to pileated woodpecker. 

A viability assessment completed for the Blue Mountains forest plan revision effort indicates no 

viability concern for the pileated woodpecker on the Umatilla National Forest. Suitable environments 

for pileated woodpecker have declined slightly, but are broadly distributed and of high abundance on 

the Umatilla National Forest (Wales et al. 2011). The Umatilla National Forest provides roughly 

200,000 acres of pileated woodpecker source habitat. Source habitat is defined as those habitats 

contributing to long-term population persistence (Wisdom et al. 2000). Overall there is little risk to 

pileated woodpecker viability (Wales et al. 2011). 

Three-toed Woodpecker

Three-toed woodpecker (Picoides dorsalis) was selected as a management indicator species in the 

Forest Plan to represent dead and down tree habitat in mature and old growth lodgepole pine stands. 

Their relatively large home range and close association with old-growth conifer forests make them 

sensitive to forest harvesting and fragmentation (Leonard 2001).

The three-toed woodpecker is a year-round resident throughout forested regions of Canada and 

Alaska, south into the northern New England states, Minnesota and Michigan, and south into 

Washington, Oregon, Idaho, and Montana, the Black Hills of South Dakota, Wyoming, Utah, 

Colorado, eastern Nevada, central Arizona, and southern New Mexico (NatureServe 2017, Wiggins 

2004).

The global status of three-toed woodpecker is ‘secure’ due to its wide distribution (NatureServe 

2017), but ‘vulnerable’ in the state of Washington. They are considered vulnerable due to a decline in 

old forests of lodgepole, subalpine fir, and Engelmann spruce, salvage of dead trees, and fire 

suppression (Wisdom et al. 2000). However, a trend analysis of habitat for this woodpecker showed 

an increasing trend in the Interior columbia Basin (Wisdom et al. 2000). 

American three-toed woodpecker are largely restricted to high elevation conifer forests (Wiggins 

2004). They appears to prefer disturbed coniferous forests with trees that exhibit thin, flaky bark such 

as spruce and lodgepole pine. Foraging occurs on a variety of tree species including ponderosa and 

lodgepole pine, Douglas-fir, and western larch. Most foraging occurs on large standing snags and 

dying trees. A habitat relationship model developed for the three-toed woodpecker in Oregon 

indicates that the presence of recently dead trees killed by mountain pine beetle was the best predictor 

of presence of the woodpecker (Chapman 2011).

According to the Sunrise project insect and disease reports, mountain pine beetles are present in 

remnant lodgepole pines. Older pine beetle killed trees are on the ground. This appears to be limited 

in extent and within mixed species stands. The main concerns in the overall area appear to be balsam 

wooly adelgid in the subalpine fir, and Armillaria root rot. 

While various forest habitats are used for foraging, nesting appears to be consistently tied to the 

presence of lodgepole pine. Nesting primarily takes place in unsalvaged, recent, post fire habitat

(Mellen-McLean 2012b), and in northeast Oregon they were found nesting in beetle-killed lodgepole 

pine (Bull 1980).
Sunrise Vegetation and Fuels Project

102 Umatilla National Forest

The Columbia Complex fire of 2006 was immediately adjacent to the Sunrise project area. After the 

fire, there was an increase in mountain pine beetle and Douglas-fir beetle activity both within and 

adjacent to the fire perimeter. Post-fire salvage projects Teal and Spruce were completed in 2007 and 

2011 respectively. There were approximately 250 acres of salvage within the Sunrise project area, in 

stands of mixed subalpine fir, spruce and lodgepole pine. This reduced the amount of post fire nesting 

habitat for three-toed woodpecker habitat in the project area. Three-toed woodpeckers were observed 

in or very close to the project area in 1998, 2005 and 2006. 

Current habitat for three-toed woodpeckers in the Sunrise project area was identified by querying the 

vegetation database for dense, moist mixed conifer, spruce, subalpine fir, and lodgepole pine. 

Query results indicate that there are about 4,670 acres of potential foraging habitat for three-toed 

woodpeckers in the project area. Approximately 620 acres of this habitat are of the lodgepole pine 

cover type, present in 3 distinct areas of the upper elevations of the project area. There is a slight 

possiblity that nesting could occur. 

Current estimates indicate there are 170,000 acres of three-toed woodpecker habitat on the forest 

(Wales, pers. commun). The Sunrise project area contributes about three percent to the forest-wide 

habitat for three-toed woodpeckers.

Birds of Conservation Concern

The appropriate state Bird Conservation Plan and USFWS Birds of Conservation Concern species list 

(USFWS 2008) for the project area were reviewed. Those species and habitats that may occur in the 

Sunrise project area and may be affected by proposed actions are listed (Table 34

Table 34. USFWS Birds of Conservation Concern for Bird Conservation Region 10 that may be present 

and potentially affected by the Sunrise project.

Species Preferred Habitat

Flammulated owl Montane forest, prefers mature ponderosa pine and Douglas-fir with open canopy, most often found 

on ridges and upper slopes. 

White-headed 

woodpecker

Mixed conifer forests (< 40 % canopy cover) dominated by old growth Ponderosa pine and open 

habitats with standing snags and scattered tall trees.

Lewis' 

woodpecker

Often used burned pine forest; open canopy, shrubby understory, dead and down material, available 

perches and abundant insects. 

Williamson's 

sapsucker

Montane and subalpine coniferous forest, mixed deciduous-coniferous forest, nests usually in dead or 

decaying pine, fir, larch, or aspen. Snags are a critical component.

Olive-sided 

flycatcher

Open conifer forests (< 40 % canopy cover) and edge habitats where standing snags and scattered 

tall trees remain after a disturbance.

Calliope 

hummingbird

Montane forest, mountain meadows, second-growth, and willow and alder thickets. Nests are in trees 

(frequently conifers) at meadow edges or in canyons or thickets along streams, and forests 

regenerating after a fire or logging.

Cassin’s finch Open, mature coniferous forests of lodgepole and ponderosa pine, aspen, alpine fir, grand fir and 

juniper steppe woodlands. 

Threatened, Endangered, and Sensitive Wildlife and Invertebrate Species

An endangered species is an animal or plant species listed under the Endangered Species Act that is in 

danger of extinction throughout all, or a significant portion, of its range. A threatened species is an 

animal or plant species listed under the Endangered Species Act that is likely to become endangered 

within the foreseeable future throughout all or a significant portion of, its range. 
Final Environmental Impact Statement

Pomeroy Ranger District 103

A sensitive species is an animal or plant species identified by the Forest Service Regional Forester for 

which species viability is a concern either a) because of significant current or predicted downward 

trend in population numbers or density, or b) because of significant current or predicted downward 

trends in habitat capability that would reduce a species existing distribution.

A species list was requested from the US Fish and Wildlife Service on May 18, 2017 for the Sunrise 

project (USFWS 2017) in order to identify which endangered, threatened, de-listed, candidate, and 

proposed species, if any, may be present in the project area. This species list indicated that there is a 

potential for the Canada lynx and yellow-billed cuckoo within Asotin and Garfield Counties, however 

neither of these species are expected to occur in the Sunrise project area. 

Threatened, Endangered and Sensitive Species addressed on the Umatilla National Forest include 

those that have been documented from a valid, recorded observation, or suspected as likely to occur 

based on available habitat to support breeding pairs/groups. Whether these species may occur in the 

project analysis area is determined by observation records, vegetative and wildlife species inventory 

and monitoring, published literature on the distribution and habitat utilization of wildlife species, 

information provided by the U.S. Fish and Wildlife Service, and the experience and professional 

judgment of wildlife biologists on the Umatilla National Forest. These tables are based on the 2015 

Regional Forester’s sensitive species list.

Table 35. Threatened, endangered and sensitive wildlife species for the Umatilla National Forest, 

Washington.

Species Scientific Name Status Umatilla 

Forest

Sunrise 

project

Mammals

Canada lynx Lynx canadensis Threatened Documented Not expected

Yellow-billed cuckoo Coccyzus americanus Threatened Not expected Not expected

North American wolverine Gulo gulo Proposed 

Threatened Suspected Possible

Gray wolf Canis lupus Sensitive Documented Documented

Preble’s shrew Sorex preblei Sensitive Documented Documented

Rocky Mountain bighorn 

sheep Ovis canadensis Sensitive Documented Documented

Mountain goat Oreamnos americanus Sensitive Documented Not expected

Townsend’s big-eared bat Corynorhinus townsendii Sensitive Documented Not expected

Little brown myotis Myotis lucifugus Sensitive Documented Possible

Birds

Bald eagle Haliaeetus 

leucocephalus Sensitive Documented Documented

Peregrine falcon Falco peregrinus Sensitive Suspected Not expected

Great gray owl Strix nebulosa Sensitive Documented Possible

Northern goshawk Accipiter gentilis Sensitive Documented Documented

White-headed woodpecker Picoides albolarvatus Sensitive Documented Documented

Lewis’ woodpecker Melanerpes lewis Sensitive Documented Documented

Green-tailed towhee Pipilo chlorurus Sensitive Documented Documented

Mountain quail Oreortyx pictus Sensitive Documented Documented

Amphibians

Rocky Mountain tailed frog Ascaphus montanus Sensitive Documented Documented

The following species are not expected to occur in the project area and will not be discussed further: 

• Canada lynx – Umatilla forest is considered unoccupied (USFS 2006). There have been no verified 

records since one was trapped near Mt. Misery in 1931. The U.S. Fish and Wildlife Service 
Sunrise Vegetation and Fuels Project

104 Umatilla National Forest

concluded that lynx may occur on the forest as dispersers that have never maintained resident 

populations. This is based on the lack of reproduction records, limited verified records of lynx, low 

frequency of occurrences, and correlations with cyclic highs with populations in Canada (USFWS 

2003). 

• Yellow-billed cuckoo – breeding populations are considered extirpated in the state of Washington 

(USFWS 2014, USFWS 2014b).

• Townsend’s big-eared bat is strongly associated with spacious cavern-like structures for roosting 

during all stages of its life cycle (Gruver and Keinath 2006). Individuals or small groups may day 

roost in hollow and creviced trees and snags near water for a limited time, but tend to stay within a

few miles of colonial roosts (Perkins and Schommer 1992). The nearest colonial roost is about 20 

miles away near the town of Asotin and there are no records of Townsend’s big-eared bats on the 

district.

• Mountain goat – the existing goat population in the Wenaha-Tucannon Wilderness was introduced 

on the Oregon side and is not contiguous with the Cascade or Rocky Mountain populations. 

Mountain goats are not known to inhabit the project area. 

• Peregrine falcon – There are no suitable cliff nesting areas and no record of presence. There are no 

known nest sites on the Umatilla National Forest.

Wolverine

The northern Rocky Mountains, including the Blue Mountains, are considered the southern portion of 

the species range. Wolverines here require high elevation alpine forest with deep persistent snow 

(Copeland et al. 2010). Most year-round habitat is found near the tree line in conifer forests, and in 

cirque basins and avalanche chutes that have food sources such as marmots, voles, and carrion (Inman 

et al. 2011). 

While there have been many reports of wolverines on the forest, none have been verifiable. The 

nearest known area of confirmed wolverine activity is in the Wallowa Mountain Range. Extensive 

track and camera surveys and resulted in the detection of four different individual wolverines in the 

Eagle Cap Wilderness in the years 2010-2012 (Magoun et al. 2013). The Wallowa Range appears to 

have enough snow cover to support wolverine, but at this time it does not appear that a breeding 

population exists (Magoun et al. 2013). 

Various winter track surveys have been conducted intermittently on the forest, and no tracks have 

been detected. There are also ongoing efforts to detect American marten and wolverine on the forest 

with cameras, but not on the scale that is necessary to complete a systematic survey. 

The Umatilla forest contains very little alpine or high elevation tree line habitat and provides 

relatively small areas with persistent snow cover in comparison to areas with known wolverine 

populations. However the forest may provide foraging opportunities for individuals. Wolverines are 

opportunistic scavengers with large mammal carrion the primary food source year-round. They 

depend on carnivores like wolves, cougars, and bears in part to provide scavenging opportunities 

(Banci 1994, Van Dijk, et al. 2008). They are known to travel 18-24 miles in a day in their daily hunt 

for food (Banci 1994).

The project area is not within or near any high elevation alpine forest that would support deep snow 

into May for wolverine reproduction. There are no cirque basins, avalanche chutes, or open boulder 

slopes.
Final Environmental Impact Statement

Pomeroy Ranger District 105

Gray wolf

The project area is within the Northern Rocky Mountain Distinct Population Segment (DPS) of the 

gray wolf, which was recently removed from the federal Endangered Species List (USFWS 2011, 

USFWS 2009). Wolves remain listed on the state of Washington’s Endangered Species List (WDFW 

et al. 2017). 

A wolf pack known as the Tucannon pack utilizes areas in and around the Sunrise project area. 

Wolves in Washington are managed according to a state wolf conservation and management plan 

(Wiles et al. 2011).

Wolves can occupy a variety of habitat types provided adequate prey exists (Keith 1983, Fuller 1989, 

Haight et al. 1998) and human activity is minimal (Oakleaf et al. 2006, Belongie 2008). The primary 

prey species of gray wolves are large native ungulates (Haight et al. 1998, Fuller et al. 2003). Gray 

wolves are typically sensitive to human disturbance near den and rendezvous sites. The entire Forest 

is considered suitable habitat for gray wolves.

The primary prey species in this area are elk and deer, both of which have healthy populations. There 

are no known wolf dens or rendezvous sites within the project area. Repeated conflicts with livestock 

have not been reported for the Tucannon wolf pack.

Preble’s shrew

Preble’s shrew are an uncommonly noted species that has been primarily found in high desert riparian 

areas. Only a few records have been noted in coniferous forest. According to Armstrong (1957), nine 

specimens of Preble’s shrew were captured in pit traps on the western edge of the project planning 

area near Clearwater lookout. These are the only records of Preble’s shrew in the state of Washington. 

The Pomeroy sites were described in very general terms as lodgepole pine with small poles and fir 

forest (Armstrong 1957). Unfortunately there is not enough information to revisit the precise 

locations they were found. They were not far from major roads, which may have been the only roads 

at the time. Clearcut harvesting occurred in the general area in the past, as well as salvage harvest in 

recent years (see map in project file). 

Rocky Mountain bighorn sheep

Bighorn sheep are native to the area but were gone from the region by 1945 due to over-hunting, 

competition for forage with domestic livestock, and introduced diseases (Coggins and Mathews 

1996). Restoration of bighorn sheep to Hells Canyon and adjacent habitat has been an ongoing effort 

with measured success, however populations continue to be primarily threatened by disease 

transmission from domestic sheep. 

Bighorn sheep typically use rugged, open to semi-open grassland that allows high visibility. They 

may be seen on both steep and gentle slopes, broken cliffs, rock outcrops, and canyons and their 

adjacent river benches and mesa tops (Beecham et al. 2007). Expanses of rim rock, broken cliffs, and 

rock outcrops are especially important for lambing and escape from predators. Grasses are the staple 

forage species, complemented seasonally with forbs and shrubs.

The Sunrise project planning area is utilized by the Asotin bighorn sheep herd, which is part of the 

Hells Canyon bighorn sheep meta-population. They use North Fork Asotin Creek drainage and in 

particular, the Asotin Creek Roadless Area. The population is about 70 sheep (Fortin and Cassirer 

2015). 
Sunrise Vegetation and Fuels Project

106 Umatilla National Forest

After the Sunrise EIS Wildlife Report was prepared in 2017, an analysis of bighorn sheep habitat was 

completed as part of the Blue Mountain forest plan revision. Landscape scale data was not field 

reviewed, but provided a general picture of areas that bighorn sheep could utilize. The mapping 

shows potential habitat in the Sunrise project area that is outside of the current Asotin bighorn sheep 

herd home range. The areas are essentially non-contiguous grassland and rock areas, which is 

borderline habitat but could provide intermittent forage and escape terrain for sheep that disperse or 

‘foray’ away from the herd home range.

Although expansion of sensitive populations would seem desireable, movement between herds is 

generally undesirable due to the concern for spread of fatal disease (WDFW letter). 

Little brown myotis

Little brown myotis is considered ‘apparently secure’ in the state of Washington (S4), but globally 

vulnerable (G3) (Natureserve 2017). There has been a rapid decline in numbers in eastern North 

Amercia due to white-nose syndrom, an introduced fungal disease. White-nose syndrome was 

recently detected in northwestern Washington, and one of the cases was a little brown myotis 

(WDFW 2016). Mortality from wind turbines is also a factor in little brown myotis declines. 

The presence of this bat was documented in a 2007 survey on state land along the Tucannon River, 

outside of the project area. Since no other surveys have been done, these are the only documented 

locations on or near the Pomeroy Ranger District. 

Little brown myotis use a wide range of habitats and often use human-made structures for resting and 

maternity sites. Foraging habitat requirements are generalized; foraging occurs over water, along the 

margins of lakes and streams, or in woodlands near water. Winter hibernation sites (caves, tunnels, 

abandoned mines, and similar sites) generally have a relatively stable temperature of about 2-12 C. 

Maternity colonies commonly are in warm sites in buildings (e.g., attics) and other structures; also 

infrequently in hollow trees. Microclimate conditions suitable for raising young are relatively narrow, 

and availability of suitable maternity sites may limit the species' abundance and distribution 

(NatureServe 2017).

There are mixed conclusions regarding forest management effects to bats (Thomas 1988, Humes et al. 

1999, Grindal and Brigham 1999). Bat survey methods have site biases and capture data cannot 

provide unequivocal information on the distribution of bats among various sites or habitats (Thomas 

and West 1991). In general, removal of large old trees and snags is a concern (Christy and West 1993) 

because it reduces roosting opportunities. Structural characteristics of large old trees and snags such 

as cracks and crevices in thick bark, bark pulling away from the trunk thus forming crevices, and 

holes in the bole where limbs have been shed, hollow interiors offer many potential roosting sites. 

These large live and dead trees are primarily associated with older stands, but may also be present in 

younger stands.

Bald eagle

Bald eagles occasionally travel through the project area. They have been seen in Asotin Creek and 

Lick Creek, but no roost or nest sites are known in the project area. There are bald eagle nests on the 

Tucannon River to the west and on the Snake River to the east, both more than 10 miles from the 

Sunrise project area. 

Great gray owl

Great gray owls use a variety of habitats, primarily mature forests interspersed with open areas 

suitable for foraging (Duncan and Hayward 1994). Older and mature forests with high canopy
Final Environmental Impact Statement

Pomeroy Ranger District 107

closure, adjacent to open areas suitable for foraging, are preferred for nesting, although secondgrowth forests are sometimes used (Bryan and Forsman 1987; Bull and Henjum 1990). Its preferred 

foraging habitat includes montane meadows and open forests and prey species include voles, gophers 

and other rodents. Bogs, clearcuts, and early successional forests are also used for foraging (Bryan 

and Forsman 1987).

There are no reports of great gray owl in the project planning area. Nesting has not been documented 

on the forest to date. Grassy areas next to mature forest are common in the Sunrise project area, so it 

is possible that nesting could occur. They typically use large diameter broken off snags or abandoned 

nests of other raptors.

Northern goshawk

The northern goshawk is considered a habitat generalist at large spatial scales, however it typically 

nests in a narrow range of structural conditions (Squires and Kennedy 2006). Goshawks prefer mature 

forest with large trees, and relatively closed canopy with an open understory for nesting. Nests are 

frequently found near the lower portion of moderate slopes and near water. 

A study in the Blue Mountains found that structural stage, tree basal area, and low topographic 

position reliably discriminated between nests and random sites. Positive correlations were found 

between fledging rate and tree basal area within 1 ha of the nest (McGrath, et al. 2003). Most nests in 

the Blue Mountains have been found in stands with ponderosa pine, but survey effort has been 

lacking in other cover types. Therefore non-pine cover types are not ruled out as potential goshawk 

habitat. 

No goshawk nests are currently documented in the planning area. A query of vegetation data for areas 

with at least 50 percent tree cover and the presence of large diameter trees resulted in approximately 

9,500 acres of potential goshawk nesting habitat. These stands are well distributed throughout most of 

the planning area. Not all of these areas would actually be suitable for nesting; quality nesting habitat 

would typically be within 1⁄4 mile of water, in the lower portion of the slope, and often on the north 

facing slope. 

Important habitat attributes of goshawk prey species include snags, downed logs, woody debris, large 

trees, openings, herbaceous and shrubby understories and an intermixture of various forest structural 

stages (Wisdom et al. 2000).

Goshawk surveys will be conducted in areas of high potential that may be affected by project 

activities. The Eastside Screens (USFS 1995) provide for specific protections for goshawk nesting 

territories. If active nests are found at any time, they would be protected as specified in the project 

design criteria (see Chapter 2).

Lewis’s woodpecker and White-headed woodpecker

Both Lewis’ and white-headed woodpeckers are associated with open ponderosa pine forest. Although 

habitat is currently limited, both species have been observed in the project area. 

Lewis woodpeckers tend to use open ponderosa pine forest, open riparian woodland dominated by 

cottonwood, and burned pine forest (Tobalske 1997). Perhaps due to their lack of excavation abilities 

typical of other woodpeckers, they nest primarily in snags or soft-wooded trees in areas that provide 

an abundance of aerial insects. Lewis’s woodpeckers rarely, if ever, probe for wood-boring insects but 

instead employ the technique of fly catching (Abele et al. 2004). 
Sunrise Vegetation and Fuels Project

108 Umatilla National Forest

White-headed woodpecker habitat is typically open ponderosa pine with large trees and snags. This 

species relies almost exclusively upon the seeds from large ponderosa pine cones for its foraging 

needs. They will also utilize insects that are gleaned off ponderosa pine trees. Large ponderosa pine 

snags are utilized for nesting. 

The loss of breeding and wintering habitats in the form of open park-like ponderosa pine forests, 

burned pine forests and riparian cottonwood stands is thought to be the primary threat to the longterm persistence of Lewis’s woodpecker populations (Abele et al. 2004). Maintenance of open forest 

stands through natural fires, prescribed burns, selective timber harvest, and restoration of cottonwood 

would serve to conserve Lewis’ woodpecker.

The Sunrise project area has about 1,000 acres of ponderosa pine cover type with open pine. Much of 

it is not technically classified as old forest, single-stratum ponderosa pine (OFSS), but potentially 

does have stand characteristics that these species would use. Cottonwood groves and burned pine 

forest are not found in the area. 

Green-tailed towhee 

Green-tailed towhees breed mainly at higher elevations (5,000-10,000 feet) throughout much of the 

Rocky Mountains, Great Basin, and Sierra Nevada of the western United States (Dobbs 2006). In 

Washington, they don’t appear to breed any further north than the Blue Mountains. 

Green-tailed towhee have been documented just over the ridge from the Sunrise project on a shrubby

south-facing slope. The species is primarily associated with heterogeneous shrub habitat. In forested 

areas, they commonly use dry shrubby hillsides and post-disturbance, shrubby second growth conifer 

forest (Dobbs et al. 1998). They also are known to occur in shrubland-woodland savannah’ or very 

open ponderosa pine with sagebrush, juniper and other shrubs dominating (Dobbs 2006).

Mountain quail

In the drier eastern portions of its range, mountain quail are found in mountain and riparian shrub 

communities on steeper slopes, and in early successional-stage shrub vegetation following fire, 

logging, and other disturbances (USFWS 2003b).

Mountain quail occurred historically in the Blue Mountains in southeastern Washington (Crawford 

2000), but this was likely due to translocations in the late 19th century. Little evidence suggests that 

they were native to Washington (Vogel and Reese 1995). Birds from multiple sources were brought 

into Washington, resulting in mixing of various subspecies. Populations in eastern Washington have 

been in a severe decline, as reported by Vogel and Reese (2002). 

The nearby Chief Joseph Wildlife Area contains a remnant population of mountain quail (WDFW 

2006). Washington Department of Fish and Wildlife has attempted introductions in the North and 

South Forks of Asotin Creek in recent years with little success (Vekasy and Wik 2015), but it is 

possible a few may occur in the project planning area. 

Rocky Mountain tailed frog

Tailed frogs are associated with cold, high gradient, boulder and cobble dominated streams. Tadpoles 

have long larval periods and require permanent, rocky streams that are cool and well oxygenated all 

year (Bury and Adams 1999). Froglets and adults often hide in gravel and cobble substrates, and 

tadpoles cling to boulders and cobbles. 
Final Environmental Impact Statement

Pomeroy Ranger District 109

Tailed frogs have documented in many areas of the Umatilla forest and are present in and adjacent to 

the project planning area. They were observed in Charley Creek in 2004 and North Fork Asotin Creek 

in 2005. 

Invertebrate species

The distribution and habitat requirements of the sensitive invertebrates listed for the Umatilla forest 

are poorly understood. Sometimes an invertebrate species is found to be more common than 

originally thought, once specific surveys are conducted. Several surveys have been conducted on the 

Umatilla NF in recent years, but none were within the project area for these specific species. Only the 

Great Basin fritillary has been documented in the project area and it is found in numerous places on 

the forest. No other sensitive invertebrate species potentially occurring on the Umatilla National 

Forest have been documented within the Sunrise project area.

Most of the snail species are found where moist microsites are created by key habitat components 

such as talus rock, down logs, moist ravines, nearby water features. All of the sensitive insects are 

reliant upon flower nectar. Key habitat components for the butterflies and bumble bee are meadows 

and other forest openings, open hillsides, ridges and talus. Johnson’s hairstreak is unique in that its 

larval state is associated with mistletoe in the trees and adults are often in the forest canopy.

Historic records of meadow fritillary place it on the Umatilla NF, but it is now believed to be absent 

from Oregon and Washington (Fleckenstein and Huff 2007a). Barry’s hairstreak caterpillars feed on 

juniper and this habitat is not present in the project area (Fleckenstein and Huff 2007b). Columbia 

clubtail have not been found on the forest. The nearest known location to the Sunrise project is the 

Yakima River. They have a very restricted range that seems to be associated with slow moving rivers 

(Scheuering 2006). It is unlikely that this species occurs in the project area.

Table 36. Sensitive invertebrate species for the Umatilla National Forest, Washington.

Species Scientific Name Status Umatilla Forest Sunrise project

Molluscs

Fir pinwheel Radiodiscus abietum Sensitive Documented Possible

Columbia Gorge oregonian Cryptomastix hendersoni Sensitive Documented Possible

Pristine springsnail Pristinicola hemphilli Sensitive Documented Possible

Thinlip tightcoil Pristiloma idahoense Sensitive Documented Possible

Humped coin Polygyrella polygyrella Sensitive Documented Possible

Shiny tightcoil Pristiloma wascoense Sensitive Suspected Possible

Salmon coil Helicodiscus salmonaceus Sensitive Suspected Possible

Butterflies 

Great Basin fritillary Speyeria egleis Sensitive Documented Documented

Meadow fritillary Boloria bellona Sensitive Documented Not expected

Johnson’s hairstreak Callophrys johnsoni Sensitive Suspected Possible

Barry’s hairstreak Callophrys gryneus barryi Sensitive Documented Not expected

Lustrous copper Lycaena cupreus Sensitive Suspected Possible

Other Insects

Columbia clubtail Gomphus lynnae Sensitive Suspected Not expected

Western bumble bee Bombus occidentalis Sensitive Documented Possible
Sunrise Vegetation and Fuels Project

110 Umatilla National Forest

Table 37. Sunrise project potential sensitive invertebrates and their habitats.

Species Documented on 

UNF

Habitat, surveys, and known locations

Fir pinwheel Yes Recently documented in the Touchet River drainage on the Umatilla NF, 20 air 

miles southwest of Sunrise project. Inhabits moist and rocky Douglas-fir forest at 

mid-elevations in valleys and ravines (Duncan and Huff 2009). It is known to live in 

or near talus of a variety of rock types or under fallen logs (Frest and Johannes 

1995).

Columbia 

Oregonian

Yes Surveys in 2010 and 2012 found this snail at four sites in the Touchet River 

drainage, as well as in the South Fork Umatilla River on the Umatilla NF (Jepsen 

and Jordan 2011). Little is known about the ecology of this species, but these sites 

were rocky and generally moist areas on hillsides just above the rivers. 

Pristine pryg 

(springsnail)

Yes The only completely aquatic snail on our sensitive list. Found at many locations on 

the Oregon side of the Umatilla forest, but only one record known from a state 

inholding on the Washington side. Associated with springs and seeps in ‘pristine’ 

condition and associated small streams with coarse gravel or cobble. See Andrews 

and Huff 2010

Thinlip tightcoil Yes Low elevation ponderosa pine and Douglas-fir forests. Moist valley, ravine, gorge or 

talus. This species was found in the South Fork Umatilla River area in 2012 

(Jepsen et al 2012). 

Shiny tightcoil No Ponderosa pine and Douglas-fir forests at moderate to high elevations (Frest and 

Johannes 1995). The nearest record is near Wallowa Lake in Oregon.

Salmon coil No Dry rocky habitats, often intermixed with sagebrush and grasses. Found in 2012 on 

BLM lands in Asotin County, east of the project planning area near the Idaho border 

(Jepsen and Jordan 2011).

Humped coin Yes Recently documented in the Touchet River drainage (Jepsen and Jordan 2011), 

this species is associated with moist Douglas-fir and spruce forest, often in 

association with outcrops and talus of various rock types (Frest and Johannes 

1995). It inhabits moss and decaying wood in dampest areas of forest cover; moist 

valley, ravine, and talus sites are preferred, apparently near water (Frest and 

Johannes 1995). 

Johnson’s 

hairstreak

No An old growth obligate, caterpillars of this butterfly feed exclusively on aerial shoots 

of dwarf mistletoe plants (Andrews and Huff 2011). Johnson’s hairstreak in 

northeastern Oregon were found feeding on western dwarf mistletoe on ponderosa 

pine (Spiegel 2014). The nearest known location is on the Wallowa Whitman 

National Forest, east of North Powder, Oregon. Recent surveys on the Heppner 

Ranger District failed to locate any Johnson’s hairstreak. 

Great Basin 

fritillary

Yes Great Basin fritillary have been found in numerous places on the Pomeroy Ranger 

District. One record of this butterfly is within the project area, near Sunset point. 

Many records are outside the planning area, but close by. This butterfly inhabits 

openings and edges in forest habitats including montane meadows, forest 

clearings, exposed rocky ridges, and stream banks (Fleckenstein and Huff 2007c).

Lustrous copper No There are no records of lustrous copper on the Umatilla NF; the nearest known 

location is in northern Idaho, but it is also found in Oregon, so there is a possibility it 

would be in between. Habitat is mountain ridges and slopes, meadows, talus fields, 

and sometimes along streams (Fleckenstein and Huff 2007d).

Western bumble 

bee

Yes The nearest known location of Western bumble bee is from 1922 near Field Peak, 

about 10 miles west of the project area. These bees have been observed taking 

nectar from a variety of flowering plants (Evans et al 2008). Meadows and other 

openings often provide flowers for food, and abandoned rodent burrows provide 

nest and hibernation sites.
Final Environmental Impact Statement

Pomeroy Ranger District 111

Environmental Consequences

Alternative A (No Action)

Elk

Tree Cover

The amount and distribution of elk cover would not likely change in the short-term. Over the mid and 

long-term (beyond 10 years), some stands could grow into thicker hiding cover while others may 

deteriorate. Increased susceptibility to insect, dwarf mistletoe, and disease disturbances (see 

Silviculture Report) would potentially cause some trees to die and fall, which would allow pockets of 

foraging areas to develop. If wildfire occurred in the future, the combination of high tree densities, 

increasing fuel loads, and the presence of fire-intolerant tree species could result in uncharacteristic 

crown fires (Fuels Report) and potentially large scale but short term loss of elk cover. 

HEI, Roads, and Elk Security

There would be no change to the HEI value. The area would likely remain within forest plan 

standards. No changes in open road densities are anticipated. The 4000-360 road would continue to 

close in October. Elk would continue to be disturbed by vehicle traffic from August to October, an 

important time for calf growth and putting on weight to last through the winter. 

Forage

Without proposed controlled burns important elk forage species may become more decadent and less 

nutritious or palatable to ungulates. Previously planned burning (Asotin Burn) in the northeast portion 

of the planning area would move forward.

Late and Old Forest

Taking no action contributes toward meeting Forest Plan direction over the short-term by maintaining 

existing habitat for late and old structure dependent species such as pileated woodpecker, American 

marten and northern three-toed woodpecker. Ongoing disturbance and succession processes 

influencing vegetation conditions would continue as they have in recent years. Forest density would 

increase and multi-strata old forest would continue to occupy a large percentage of the forest 

landscape (>50%). 

Over the mid and long term, there would be increasing amounts of multi-strata old forest, higher tree 

densities and susceptibility to natural disturbances (Silviculture Report). Thirty-two percent of moist 

and dry forest would continue to be at risk of uncharacteristic crown fire (Fuels Report). Over the 

long-term, by increasing the risk of insect infestations, disease, and uncharacteristic wildfire, the No 

Action alternative does not contribute toward development or maintenance of healthy diverse forest 

conditions that would move forests toward desired conditions for the Blue Mountains.

American Marten

Existing marten habitat would remain in its current state in the short term. Multi-strata, moist and 

cold old forest would continue to occupy a large percentage of the forest landscape (5,500 acres), 

which is currently providing the majority of marten habitat (6,225 acres). Over the mid and long term, 

there would be increasing amounts of old forest, stands with higher tree densities, mid and late seral
Sunrise Vegetation and Fuels Project

112 Umatilla National Forest

species, and susceptibility to natural disturbances (Silviculture Report). Because marten utilize areas 

of high down wood densities, they would benefit from an increase in snags and down wood as stands 

mature. The longevity of such stands is questionable, however, due to the increased potential for 

widespread mortality due to natural disturbances such as insect, disease, and uncharacteristic wildfire.

Dead and Down Tree Habitat

Within the next five years, dead standing trees (snags) would continue to occupy the project area at 

current densities and size classes, barring disturbance such as a large scale, high severity wildfire. 

Although snags would continue to be lost and created on the landscape in the short term, the existing 

snag density distribution would not be expected to change in this short timeframe. 

In the mid and long term, snag densities have the potential to increase in the analysis area through 

naturally occurring mortality caused by insect and disease, or due to wind and wildfire. Some existing 

snags would fall to the ground, increasing down wood in the analysis area.

Mortality caused by insects and disease would be patchy, creating small to moderately sized “islands” 

with high densities of snags in the early stages of decay. These islands would provide habitat for 

primary cavity excavators (e.g., black-backed, three-toed, and Lewis’ woodpeckers) and other wildlife 

that require pulses of high-density snags. 

The risk of high-severity wildfire would also increase over time. If fires occurred, snag densities 

would initially increase due to immediate and delayed fire mortality. Species that show an affinity for 

post-fire conditions (e.g., black-backed, three-toed, and hairy woodpeckers) would benefit in the short 

term following this type of event. Ultimately, snags resulting from this event would fall and snags 

would be relatively scarce until regenerating stands become old enough to produce large trees, a time 

period ranging from 80 to 100 years.

Pileated Woodpecker

Existing pileated woodpecker habitat would remain in its current state in the short term. In the mid 

and long term, more snags would be created as trees die. Over the mid and long term, there would be 

increasing amounts of old forest, stands with higher tree densities, mid and late seral species, and 

susceptibility to natural disturbances (Silviculture Report). Because woodpeckers utilize areas of high 

snag and down wood densities, they would benefit from an increase in snags and down wood as 

stands mature. The longevity of such stands is questionable, however, due to the increased potential 

for widespread mortality due to natural disturbances such as insect, disease, and uncharacteristic 

wildfire.

Three-toed Woodpecker

Existing three-toed woodpecker habitat would remain in its current state in the short term, with 

habitat enhanced by limited amounts of additional mortality from mountain pine beetle activity. 

Over the mid and long term, there would be increasing amounts of old forest, stands with higher tree 

densities, mid and late seral species, and susceptibility to natural disturbances (Silviculture Report). 

Any future fire and/or beetle mortality in trees would benefit three-toed woodpeckers. 
Final Environmental Impact Statement

Pomeroy Ranger District 113

Threatened, Endangered, and Sensitive Wildlife and Invertebrate Species

Wolverine

Existing habitat conditions would continue to provide foraging habitat for wolverine. No decline in 

prey species would be expected in the short term, and there would be no change in open road 

densities. In the event of a large wildfire, forest cover could be removed over large areas, but 

eventually shrubs would respond positively and wolverine prey species would still be present.

Gray wolf

No decline in prey species would be expected in the short term, and there would be no change in open 

road densities. There may be increased risk of uncharacteristic wildlife if fuels are not reduced. If fire 

reduces forest cover over a large area, wolves may be less likely to use the area for a few years, but 

then resume activity in relation to ungulate availability as shrubs and grasses sprout up (Ballard et al. 

2000). 

Preble’s shrew

With continued fire suppression, tree densities would increase and surface fuels and fuel ladders 

would continue to accumulate in the area, leading to a corresponding increase in the potential for 

high-intensity crown fires. Such events could remove entire forest stands across extensive areas in 

both upland and riparian habitats. In burned areas, leaf litter and low concealing cover would be 

removed or adversely modified over the short-term. This could negatively impact prey species and 

potentially make shrews more susceptible to predation.

Rocky Mountain bighorn sheep

There would be no effects to bighorn sheep if the proposed actions are not implemented. If the 

prescribed burning were not implemented, that would be a lost opportunity to enhance forage in the 

grassy areas, but other burning in the Asotin bighorn sheep area has already been planned and would 

be implemented over the next few years.

Little brown myotis

Alternative A would maintain potential habitats for little brown myotis in the short-term, but this 

alternative would not address the increasing risk of a high intensity fire which could remove potential 

roosting structures. In the absence of wildfire, increasing densities of large decaying and dead trees 

would provide more roosting habitat for bats.

Bald eagle

There would be no effects to bald eagles if the proposed actions are not implemented. There are no 

nest sites or roost sites, and presence is very infrequent. 

Great Gray Owl

Alternative A would maintain potential habitats for great gray owls in the short-term, but this 

alternative would not address the increasing risk of a high intensity fire which could remove potential 

nesting structures and entire nest stands in the area. 

Northern goshawk

Alternative A would maintain all of the potential habitat for goshawk in the short-term, but this 

alternative would not address the increasing risk of a high intensity fire which could remove entire 

stands. 
Sunrise Vegetation and Fuels Project

114 Umatilla National Forest

Lewis’s woodpecker and White-headed woodpecker

Alternative A would maintain all of the potential habitat for these species in the short-term, but this 

alternative would not address the increasing risk of a high intensity fire which could remove entire 

stands. If lower intensity fires occur in ponderosa pine forest, which happens at times, that would be 

beneficial to Lewis’ woodpecker. 

Green-tailed towhee

Alternative A would maintain all of the potential habitat for green-tailed towhee in the short-term. 

Wildfire could potentially reduce habitat, but this species is associated with shrubby areas and second 

growth forest, so effects would be short-lived. 

Mountain quail

There would be no impacts to mountain quail since new forest management activities would not be 

initiated in the project area. Even in the event of wildfire, mountain quail are known to return to 

burned areas where there is cover remaining or sprouting. 

Rocky Mountain tailed frog

There would be no impacts to tailed frogs since new forest management activities would not be 

initiated in the project area. Generally the only indirect effect might be a high intensity wildfire 

caused by fuels build up that could burn riparian areas, affecting water quality and streamside shade. 

Invertebrate species

There would be no immediate impacts to sensitive invertebrates since new forest management 

activities would not be initiated in the project area. Generally the only indirect effect might be a 

future high intensity wildfire caused by fuels build up. 

Alternatives B and C

Elk

Tree Cover

• Cover for elk would meet forest plan standards in both action alternatives (Table 38).

• Landscape burning would be designed to maintain adequate amounts of elk cover

MA-C3: The amount of total cover would not change in MA-C3, but some satisfactory cover would 

be converted to marginal cover. (Table 38).

MA-C4: Harvest and fuels treatments proposed in MA-C4 would substantially reduce the amount of 

satisfactory and total cover (2,630 acres). Alternative C would maintain 1,800 acres more elk cover

than Alternative B on the landscape in a better distribution pattern for elk and other wildlife (Table 

38). More elk cover would be maintained in these areas (1,800 acres) until the surrounding openings 

created develop into cover. 

Table 38. Cover reduction by alternative in MA-C3 (acres).

Management Area C3 (7,100 

acres)

Current Elk Cover Alternative B Alternative C

Satisfactory Cover 1140 - 375 - 375
Final Environmental Impact Statement

Pomeroy Ranger District 115

Management Area C3 (7,100 

acres)

Current Elk Cover Alternative B Alternative C

Marginal Cover 995 + 375 + 375

Total 2135 +/- 0 +/- 0

Table 39. Cover reduction by alternative in MA-C4 (acres).

Management Area C4 

(13,425 acres)

Current Elk

Cover Alternative B Alternative C

Satisfactory Cover 4770 -1870 -730

Marginal Cover 2300 -760 -60

Total 7070 -2630 -790

Figure 3-6. Elk cover in MA-C4 after implementing Alternative B.
Sunrise Vegetation and Fuels Project

116 Umatilla National Forest

Figure 3-7. Elk cover in MA-C4 after implementing Alternative C.

MA-C8: Landscape burning is the only activity proposed in MA C8 because it is a roadless area. 

Although we would not anticipate a loss of cover due to landscape burning, we identified some likely 

areas where that could happen in the roadless area (Table 40). 

Table 40. Cover reduction by alternative in MA-C8 (acres).

Management Area C8 (9,665 acres) Current Elk Cover Alternative B Alternative C

Satisfactory Cover 1745 -415 -415

Marginal Cover 1430 +150 +150

Total 3175 -265 -265

HEI and Roads

• HEI values would remain within forest plan minimum standards in both Alternatives for all three 

management areas (Table 41). 

• For both action alternatives, there would be no change in the open road densities. 
Final Environmental Impact Statement

Pomeroy Ranger District 117

Table 41. Comparison of effects to elk habitat by alternative.

Scale Measure Forest Plan

Standard Alt. A Alt. B Alt. C

Management Area C3/C3A

(7,070 acres)

Satisfactory Cover 10 % 16 % 11 % 11 %

Total Cover 30 % 30 % 30 % 30 %

HEI 70 78 75 75

Open Road Density < 2.0 1.2 1.2 1.2

Management Area C4

(13,425 acres)

Satisfactory Cover 15 % 36 % 21 % 30 %

Total Cover 30 % 53 % 33 % 47 %

HEI 60 70 68 70

Open Road Density < 2.0 1.2 1.2 1.2

Management Area C8

(9,670 acres)

Satisfactory Cover 10 % 18 % 13 % 13 %

Total Cover 30 % 33 % 30 % 30 %

HEI 70 82 80 80

Open Road Density < 2.0 .05 .05 .05

Some closed roads would be opened temporarily for harvest and fuels activities; however they would 

remain closed to the public. Temporary roads would be established, but decommissioned once the 

project is completed. These areas would be seeded and would likely have established vegetation 

within a year. Alternative B would require using 39 miles of existing closed roads and 14 miles of 

temporary road. Alternative C would require using 34 miles of existing closed roads, and 8 miles of 

temporary road. 

Because Alternative C would have fewer miles of road being used and fewer miles of vegetation 

disturbed for temporary access, there would be less effect to elk during project activities. Motorized 

vehicles using temporary roads and existing roads that have been closed for many years would likely 

cause elk to avoid these areas when activity is occurring. Since proposed activities would take place 

gradually over several years, activities would be spread out in space and time, the road use would not 

cause elk to move out of the area permanently. Elk may even return to the areas at night when 

operations shut down. 

During harvest, closed and temporary roads remain closed to the public. If gates are in place, they 

would be closed at night. All activities in the winter range would be restricted from December 1 

through March 30. Roads closed for elk calving would not be used until after June 30.

Elk Security

Open roads

There would be no change to open road densities with this project, therefore technically there is no 

change to elk security as defined in the Blue Mountains Forest Plan Revision FEIS. However, the 

plan recognizes there are other factors affecting elk security such as vegetation and topography. The 

thinning and other prescriptions proposed in Alternative B would visually open up large areas and 

potentially make elk more vulnerable to displacement. This is true in particular because road densities 

are higher in the areas proposed for timber harvest. 

In lieu of closing additional roads, Alternative C proposes to treat fewer stands to maintain marginal 

and satisfactory cover in elk summer range. Additional road closures should be considered in the 

future if Alternative B is selected.
Sunrise Vegetation and Fuels Project

118 Umatilla National Forest

Seasonally open roads

Devil’s Tailbone Road (4000-360) currently closes October 11, opens November 5, and closes again 

December 1. Alternative C proposes closing the gate on Forest Road 4000-360 on August 1 to match

nearby roads. Having the same closure date would reduce confusion on our travel maps, reduce 

administrative costs, and improve elk security. The first mile of the road would remain open yearround.

Cover is currently limited along this road, due to natural openings as well as past harvest. Alternative

B proposes treatments along the entire length of this road, and much of it on both sides of the road. A 

substantial amount of canopy cover and hiding cover would be removed with regeneration harvest

and thinning. Alternative C also maintains 200 more acres of cover along this road than Alternative B.

The earlier closure date in Alternative C would provide additional elk security during late summer 

and fall, a time when elk are putting on weight to last through the winter and cows need fat reserves 

to be able to become pregnant. Forage

Prescribed burning would directly decrease forage for big game for a short time, but burning activities 

would be spread over multiple years. Upon completion of each burn area, there would be a mosaic of 

unburned, lightly burned, moderately burned, and intensely burned patches. As green-up occurs the 

following spring and summer; new grass sprouts would be highly palatable and rich in nutrients. 

Increased vigor and palatability of grasses lasts only a year or two, but where shrubs and understory

trees are burned, the forage base would increase over the mid-term. Similarly, non-commercial 

thinning, commercial thinning, and regeneration harvest of trees can increase forage for elk in the 

mid-term (Cook 2002).

All management activities would be followed by seeding with native seed where it is needed. Aerial 

fertilizer may be applied to key forage areas if funding is available. Growth in the elk population 

would not be likely, or at least not attributable to this project, but elk may be more inclined to stay on 

national forest where forage is enhanced rather than move onto private lands where crop damage may 

occur.

Cumulative Effects

Past timber harvest, roadbuilding, fire suppression and other past changes to habitat are reflected in 

the existing condition. Ongoing management activities in the Sunrise project area include landscape 

prescribed fire (Asotin Burn, 8,000 acres), 44 Road Grapple project, livestock grazing, invasive plant 

treatments, resurfacing of the 41 road, road and trail maintenance, personal use firewood collection, 

and public recreation. 

The 8,000 acre Asotin burn project would improve elk forage habitat similar to that described for the 

Sunrise project burning. All of the burning for Sunrise and Asotin would be accomplished over a 

period of 10 years or more, typically around 2,000 acres per year. This would lengthen the time that 

elk benefit from forage enhancement. Because of overlap with Sunrise unit burning, the Asotin Creek 

burn technically adds 7,475 acres. 

The 44 Road Grapple project is a fuels reduction project along the southern boundary of the project 

area that will remove some of the down wood within 100 feet of the road. The project is along a 

major road with existing activity, is limited in scope and duration and therefore would not 

cumulatively affect elk.
Final Environmental Impact Statement

Pomeroy Ranger District 119

Monitoring indicates that cattle forage utilization is within Forest Plan standards (Range Report). 

These utilization standards were calculated to provide forage for both livestock and big game. No 

cumulative effects to elk are expected as long as livestock utilization standards are being met. 

Based on recent year’s efforts, ongoing control of invasive plants would be expected to prevent 

widespread infestations of weeds. 

Cumulatively the effects of proposed activities in combination with other existing and potential future 

effects are minor and not expected to have lasting negative impacts to Rocky Mountain elk. 

Forest Plan Consistency

Alternative B could result in a slightly negative habitat trend due to the resulting poor distribution of 

cover in elk summer range. Alternative C would maintain a better distribution of summer range cover 

and the change in Forest road 4000-360 closure date would improve elk security. Alternative C would 

likely result in no net change in mid to long-term habitat trend. Forest plan standards for elk habitat 

would be met, and no changes to the elk population are expected as a result of these actions. Both 

Alternatives B and C are consistent with the forest plan and continued viability of Rocky Mountain 

elk is expected on the Umatilla National Forest.

Late and Old Forest

There are 3,030 acres of OFMS and 100 acres of OFSS affected by cutting units, totaling 3,130 acres

(Table 42). Alternative B includes 2,130 acres of tree cutting with removal of larger trees (up to 21 

inches dbh), plus 1,000 acres of tree cutting with removal of small trees only (up to10 inches dbh). 

Alternative C includes 880 acres of tree cutting with removal of larger trees and the same 1,000 acres 

of small diameter cutting. The effects from small diameter thinning and landscape burning are the 

same for both action alternatives.

Table 42. Tree cutting within old forest (acres).

Cutting activity Alternative B Alternative C

Thinning and regeneration harvest up to 21 inch dbh trees 2,130 880

Thinning only up to 10 inch dbh trees 1,000 1,000

Total 3,130 1,880

No live trees > 21 inches DBH would be removed except for danger trees, and no snags > 20 inches 

dbh would be removed except for danger trees. Large snags may not be available in all affected 

stands, but all units would maintain snags and down wood equal to or in excess of Forest Plan

standards where they are available. The healthiest large trees and the soundest large snags would 

remain as the building blocks for present and future stand and wildlife habitat development. 

About one third of the silvicultural activities in old forest include movement from old forest multistrata (OFMS) to old forest single-stratum (OFSS) (Table 33). Cutting methods occurring in existing 

old forest include intermediate and regeneration harvests. Regeneration methods would include 

individual-tree and group selection, shelterwood preparatory cutting, or shelterwood seed cutting. All 

treatments in existing old forest would retain at least 10 trees/acre > 21 inches dbh. 

Group selection harvests in old forest would typically create openings less than two acres in size, and 

the stand as a whole is still considered well-stocked and meeting minimum old forest requirements. 

Such openings to allow more light penetration to the ground to regenerate shade-intolerant, early seral

species such as western larch and lodgepole pine. 
Sunrise Vegetation and Fuels Project

120 Umatilla National Forest

Landscape burning outside of cutting units is predicted to potentially create 1,800 acres of OFSS in 

both alternatives by burning the small trees in the understory. Effects from landscape burning are also 

included in Table 43.

Note that Alternatives B and C are similar in the amount of OFMS converted to OFSS in dry forest. 

This is because the treatments are the same for the majority of dry forest. 

There is a larger discrepancy in moist old forest between alternatives because many units retained for 

elk cover in Alternative C happen to be moist upland, old forest. The end result of both alternatives is 

a substantial change from OFMS to OFSS. 

There are also some cutting units that would maintain enough understory to remain classified as 

OFMS (800 acres, both alternatives). Stands that are currently OFSS would only be treated with hand 

thinning and landscape fire such that they remain OFSS (100 acres). 

Table 43. Changes to old forest structure by alternative (acres)

Old Forest Structure Type Existing Alt B Change Alt C Change Alt B Result Alt C Result

Dry OFSS 843 +1,891 +1,641 2,733 2,484

Dry OFMS 6450 -2,153 -1,904 4,297 4,546

Moist OFSS 22 +1,953 +961 1,975 983

Moist OFMS 5153 -2,199 -1,207 2,954 3,947

Cold OFSS 25 +221 +217 245 242

Cold OFMS 422 -221 -217 201 205

Total 12915 -540 -540 12,405 12,407

The predicted reduction of total old forest in Alternatives B and C (500 acres). The extra 40 acres is 

an allowance for potential mortality from landscape burning. That is why the -/+ conversions from 

OFMS to OFSS are not equal. When the burning occurs, plans include modifications to adjust 

operations such that areas of elk cover would be protected and thus, most of the old forest would as 

well. Based on past burning in similar areas, resulting small areas of high burn severity are normal, 

but at a very small scale if at all. If this occurs, rich snag habitat would be created in these areas and 

diversity of habitat would increase.

Canopy would be reduced in some of the connective corridors between old forest stands via tree 

cutting, small diameter thinning, and/or landscape burning. Alternative B would affect 545 acres of 

connective forest and Alternative C would affect 190 acres of connective forest. These areas would be 

thinned, but are noted as ‘high retention’ areas; in other words thinning would be light and the 

corridor would continue to provide for movement of various wildlife species associated with late and 

old structural conditions. 

Proposed temporary roads considered ‘new’ (not on old roadbed) would remove trees and vegetation 

within old forest in both alternatives. Alternative B proposes 3 miles and Alternative C proposes 1.7 

miles of new temporary road within old forest. The effects to vegetation are accounted for in the prior 

effects stated for tree cutting because all of the old forest stands impacted by temporary roads are also 

within cutting units. All temporary roads would be re-vegetated after use. Since these roads would be 

closed to the public, access to old forest stands for activities such as firewood cutting would not 

increase. 
Final Environmental Impact Statement

Pomeroy Ranger District 121

Other proposed activities such as road maintenance and removal of danger trees along roads would 

have little to no effect to old forest stands, because only trees adjacent to roads would be affected and 

interior old forest would not. 

The Asotin Creek Prescribed fire project will primarily affect grassland area, but may reduce 

understory in some old forest stringers within the Asotin Creek Roadless area. The majority of these 

are dry OFMS that will benefit from understory fire. Outside of the roadless area, 525 acres of hand 

thinning are proposed within the Asotin Creek burn under the Sunrise EIS, in both Alternatives B and 

C. The effects of this thinning and subsequent burning have been accounted for in the direct and 

indirect effects stated above. Therefore the Asotin Creek burn cumulatively adds 7,475 acres of 

primarily grassland burning, and would have little cumulative effect to old forest.

The 44 Road Grapple project would not occur within old forest stands. Other activities such as 

livestock grazing, future seeding and planting, road projects and public use of the area in combination 

with proposed activities in this EIS would have no cumulative effects to old forest stand structure.

American Marten

Cutting units would affect 40 percent of the 6,225 acres of marten habitat (2,465 acres) in Alternative 

B, and 20 percent (1,160 acres) in Alternative C. The landscape prescribed fire boundary includes 

about 2,000 additional acres of marten habitat (outside of proposed cutting units). The expected result 

of fire would mimic historic patterns of fire disturbance, with a mosaic of burned and unburned 

grassland and scattered areas of tree mortality. 

Table 44. Vegetation treatments in marten habitat (acres).

Treatment method Alt B Alt C

Thinning 1,380 520

Regeneration 705 260

Hand thinning 380 380

Total 2,465 1,160

Landscape burning 2,000 2,000

Marten habitat that would be hand thinned and underburned is predicted to remain old forest 

multistory, and would continue to provide habitat for marten. In the remainder of the project area, 

nearly all marten habitat that is not protected by MA-C1 (Dedicated Old Growth, MA-C5 (Riparian) 

and Asotin Creek Roadless Area designations would be affected by cutting activity proposed in 

Alternative B. Within MA-C4, 100 percent of the marten habitat would be affected by tree cutting 

(1,950 acres). 

Alternative C cutting activities would affect about half the amount of marten habitat compared to 

Alternative B. Alternative B would require 3.7 miles of temporary road within marten habitat, and 

Alternative C would require 2.1 miles within marten habitat. 

A recent study of Pacific marten showed that fuels treatments that simplify forest structure (e.g., 

removal of small diameter trees, downed logs) have negative effects on marten movement dynamics 

(Moriarty et al. 2016). Marten moved quickly through simplified forest stands, most likely as a 

predator avoidance strategy. In complex stands, martens moved ‘deliberately and consistently.’ They 

also continued to use areas of natural mortality that retained down wood for winter access and 
Sunrise Vegetation and Fuels Project

122 Umatilla National Forest

foraging. The authors suggest that where fuels treatments are planned in higher elevation forests 

within marten habitat, strategically increasing structural variation while increasing resilience from fire 

will be important for maintaining marten populations.

The majority of effect from Sunrise project would be multi-strata moist old forest converting to 

single-stratum moist old forest. The regeneration acres (Table 12) are prescriptions that would not 

remove large trees or change the stand structure to something other than old forest. Minimum down 

wood and all large snags would be retained, and large trees (> 21 inches dbh) would not be removed. 

These stands would still qualify as marten foraging habitat, but modifications to stand structure could 

make them unsuitable for winter denning in the short term. 

The Sunrise cutting units in marten habitat would have a variety of treatments, including ‘high 

retention’ of cover in some areas (370 acres) and only small diameter tree removal in others (380 

acres). 

Since marten home ranges typically include both source habitat as well as foraging areas and nonhabitat, the project area may continue to provide enough habitat for a reproducing pair. With 

Alternative B, Management Area C-4 would no longer provide high quality habitat. Quality source 

habitat would be available in the roadless area, and marten could continue to use managed areas to 

find prey. In general, Alternative C would treat half as much marten habitat as Alternative B, and 

would provide a balance between maintaining marten habitat and reducing fuels.

Past timber harvest and road construction has occurred throughout the project area, which is reflected 

in the existing condition. The Asotin Creek Prescribed Fire project boundary only contains 42 acres 

of marten habitat which will not likely be affected. The 44 Road Grapple project would not occur 

within marten habitat. Forest recreation activities such as hunting, hiking, sightseeing, and berry 

picking take place during the day time when marten are less active. Open road densities would remain 

low, which restricts the amount of human disturbance. These and other activities such as livestock 

grazing, future seeding and planting, weed treatments, and road projects in combination with 

proposed activities in this EIS would have no cumulative effects to marten habitat.

Forest Plan Consistency

The overall direct, indirect and cumulative effects would result in a small negative habitat trend for 

American marten. Alternative B would affect about 2 percent of the marten source habitat on the 

forest, and Alternative C would affect about 1 percent. The amount of effect from this project is too 

small to cause changes to the Umatilla forest marten population. The Sunrise project is consistent 

with the forest plan and thus continued viability of American marten is expected on the Umatilla 

National Forest.

Dead and Down Tree Habitat

Tree cutting activities and prescribed burning would have the greatest effect to dead wood habitat. 

This includes hand thinning and pruning, mechanical harvest, underburning within units, and 

landscape fire. 

Hand thinning and pruning would not affect snag densities, however follow up burning could reduce 

snags and down wood, while also causing some new tree mortality. There could be a short term 

reduction but a mid- to long-term increase in dead wood habitat.
Final Environmental Impact Statement

Pomeroy Ranger District 123

Thinning and selection harvests should accelerate the development of large trees in the project area. 

Over the long term, large diameter snags and down logs would be recruited from these trees. Timber 

harvest and fuel reduction activities would reduce ladder fuels and tree crown biomass, reducing the 

potential for hot, crown fires to occur in the project area. The supply of snags would be less subject to 

“boom and bust” cycles and should become more stable and continuous over time. The average snag 

diameter should slowly increase. 

Following the project there would be a short to mid-term reduction in snag recruitment in harvest

units, since logging would “capture” much of the potential habitat that would have resulted from 

density or age dependent tree mortality factors. Most of this potential habitat would have consisted of 

smaller diameter trees. With all logging methods, an occasional green reserve tree might be 

mechanically injured during felling and skidding operations. These tree injuries could provide forest 

pathogens access into the tree bole, potentially resulting in defective live trees or snags over a few 

years. In addition, many of the mechanical units would also be burned and create new snags.

Current and future snag and down wood habitat could be provided in a variety of ways within 

mechanical harvest units. In general, large trees and snag retention would be emphasized. Large snags 

would be left standing except for incidental snags that need to be felled for safety purposes, for 

skyline corridors, or during clearing for temporary roads. Large diameter snags are emphasized 

because they are in shorter supply, stand longer, and are used by more wildlife species than smaller 

snags.

Table 45. Features of the Sunrise project contributing to 

the maintenance of primary cavity excavator habitat.

Project design elements 

Old forest stand structure

Retain all old growth (MA-C1) and late and old structural stage stands (OFSS, OFMS). 

Retain live trees > 21 inches dbh. Thin stands in young and mid-successional stages to 

accelerate the development of old forest structures and increase patch size. Move stands 

toward HRV.

Fire frequency Use timber harvest and under-burning to reduce forest fuels and restore fire to its historic 

function across the landscape. 

Large snags

Retain existing large snags > 20 inches dbh. Fire mortality could create additional snags. 

Trees injured but not killed by underburning could develop heart rot or other defects that 

could provide future opportunities for cavity excavation.

Snag replacement trees

Provide adequate trees for future snag and down wood replacement. Retain large live trees 

(> 21 inches in diameter) in harvest units. Large snags would be recruited from these trees 

over time. 

Down wood 

Retain required amounts of down wood. Some thin-barked and fire sensitive over-story 

trees would be killed by underburning. After a decade or two, most of these trees would 

have fallen to the ground and provide additional down log habitat. Some retained live overstory trees might be wind-thrown and contribute to down log levels.

Under Alternative B; mechanical activities could result in some short term snag loss on 5,520 acres, 

or 11.4 percent of the forest in the watershed (48,270 acres on FS). Again, all existing large snags 

would be retained wherever possible. Under Alternative C, mechanical activities could result in some 

snag loss on 2,555 acres, or 5 percent of the forest in the watershed. 

Landscape fire would be prescribed in stands that are not being harvested, both within and outside the 

Asotin Creek Roadless Area. Although a loss of snags and down wood is expected with prescribed 

burning, small scale torching would result in snag recruitment. Overall there is expected to be a net 

loss of down wood and a net increase in snags, due to fire mortality. Fuels would be consumed in 

relation to their diameter and moisture content. 
Sunrise Vegetation and Fuels Project

124 Umatilla National Forest

Structural habitat for cavity excavating birds could be slightly reduced at the stand scale, but 

measures taken to provide current and future habitat (mentioned above) would contribute to long term 

dead wood habitat needs on the forest. The improvement of long term forest resiliency would provide 

snag and down wood habitat over the long term. In general, managing forests within or towards the 

historical range of variability should provide habitat for a wide range of cavity excavator species. 

Managing within Eastside Screens direction also ensures that the old forest habitat that many primary 

cavity excavators utilize remains available. 

The Asotin Creek burn would affect an additional 7,475 acres within the watershed. This is the size of 

the area, but only a portion would actually burn. The Asotin Creek burn area is a mix of grassland and 

timber, with a variable mosaic of burn severity and intensities expected.

Timber sales associated with the South George EIS total 3,450 acres of treatment in this same 

watershed. South George units in combination with mechanical treatments in Sunrise project, 

Alternatives B and C would affect 19 and 12 percent of total forest respectively. At the forest scale, 

the effect is very small (<1%)

Forest Plan Consistency

Effects to species viability are determined at the forest scale. Forest-wide average snag densities are 

relatively close to reference values (Mason and Countryman 2010). At the forest scale there may be 

areas depleted of snags due to fires, salvage, and past management, but there are also areas with high 

numbers of snags due to recent fires and other causes of tree mortality. Mechanical treatments in the 

Sunrise project would affect less than one percent (0.5) of the forested land on the Umatilla National 

Forest. In combination with South George timber sales, the effects are still less than one percent (0.9) 

(Table 17).

It is likely that some primary cavity excavators adapted to higher snag densities in denser stands 

would be displaced by mechanical treatment. The snag density distribution would be expected to 

change slightly. There would likely be slight increases in the lower and mid density groups through 

mechanical treatments, and increases in the mid and high density groups through landscape burning. 

The analysis area would likely maintain a snag density distribution that resembles the DecAID 

reference condition; therefore habitat for the primary cavity excavator group would be maintained and 

contribute towards the viability of this group at the Forest scale.

Pileated Woodpecker

Pileated woodpecker habitat that would be hand thinned and underburned is predicted to remain in the 

old forest or understory reinitiation stand structure, and would continue to provide habitat.

The majority of effect from Sunrise project would be multi-strata old forest converting to singlestratum old forest; both of which can be source habitat for pileated woodpeckers. Minimum down 

wood and all large snags would be retained, and large trees (> 21 inches dbh) would not be removed. 

Thinning and selection harvests should accelerate the development of large trees in the project area. 

Over the long term, large diameter snags and down logs would be recruited from these trees. Timber 

harvest and fuel reduction activities would reduce ladder fuels and tree crown biomass, reducing the 

potential for hot, crown fires to occur in the project area. The supply of snags would be less subject to 

“boom and bust” cycles and should become more stable and continuous over time. The average snag 

diameter should slowly increase. 
Final Environmental Impact Statement

Pomeroy Ranger District 125

Landscape fire could reduce snags and down wood, but small scale torching would result in snag and 

down wood recruitment. Overall there is expected to be a net loss of down wood and a net increase in 

snags, due to fire mortality. 

Structural habitat for pileated woodpecker could be slightly reduced at the stand scale, but measures 

taken to provide current and future habitat would contribute to long term dead wood habitat needs on 

the forest. The improvement of long term forest resiliency would provide snag and down wood 

habitat over the long term. In general, managing forests within or towards the historical range of 

variability should provide habitat for a wide range of cavity excavator species. Managing within 

Eastside Screens direction also ensures that the old forest habitat for pileated woodpecker remains 

available. 

The Asotin Creek Prescribed Fire project could affect an additional 1,500 acres of pileated 

woodpecker habitat. These are for the most part timber stringers in draws and along North Fork 

Asotin Creek. Burning effects are expected to be minimal in these areas, as the objective is to burn 

the extensive grasslands in the area. 

About one mile of the 44 Road Grapple project is immediately adjacent to pileated woodpecker 

habitat. There would be minimal encroachment of the project into these stands, if any, because of the 

limited distance the grapple piling will occur from the road. 

Open road densities would remain low, which reduces the potential for snag loss from personal use 

firewood cutting. Other activities such as livestock grazing, future seeding and planting, weed 

treatments, recreational uses and road projects in combination with proposed activities in this EIS

would have no cumulative effects to pileated woodpecker.

Forest Plan Consistency

The overall direct, indirect and cumulative effects would result in a small negative habitat trend for 

pileated woodpecker. Including landscape burning, Alternative B would affect about four percent of 

the pileated woodpecker habitat on the forest, and Alternative C would affect about three percent. 

Post-treatment habitat will remain useable by pileated woodpeckers for the most part. The amount of 

effect from this project is too small to cause changes to the Umatilla forest pileated woodpecker 

population. The Sunrise project is consistent with the forest plan and thus continued viability of 

pileated woodpecker is expected on the Umatilla National Forest.

Three-Toed Woodpecker

Alternative B would reduce tree density on about 64 percent (3,000 acres) of the three-toed 

woodpecker habitat. Alternative C would reduce tree density on about 30 percent (1,400 acres) of the 

three-toed woodpecker habitat in the project area. 

Three-toed woodpeckers would likely continue to use post-harvest stands that retain at least 50 

percent canopy cover; this would be the case for about 600 activity acres in Alternative B and 300 

acres in Alternative C. 

The majority of treatments would be a moderate or mixed amount of cover retention (< 50% canopy

cover retained). Generally these treatments would reduce habitat in the short term but create more 

resilient stands in the long term. Increases in lodgepole pine would be expected.

Within the moderate and mixed retention prescription, Alternative B would change 300 acres of threetoed woodpecker habitat to a stand initiation structure, with 75 acres of that being the lodgepole pine 
Sunrise Vegetation and Fuels Project

126 Umatilla National Forest

cover type (units 61 and 63). Only 26 acres of currently OFMS lodgepole pine would be treated, and 

it would change to an OFSS stand structure; which may also be used by three-toed woodpeckers.

Landscape prescribed fire would potentially affect an additional 1,400 acres of three-toed woodpecker 

habitat. Any mortality associated with burning would probably enhance foraging opportunities.

Foraging habitat for three-toed woodpeckers would remain available on over 2,000 acres with 

Alternative B and 3,570 acres with Alternative C.

Recent fires on the Pomeroy Ranger District (School, Columbia Complex, Grizzly Bear Complex) 

have created large amounts of dead tree habitat in adjacent areas. Other ongoing activities such as the 

Asotin Creek burn, livestock grazing, and recreation uses would not affect three-toed woodpecker 

habitat. 

Forest Plan Consistency

The overall direct, indirect and cumulative effects of any of the action alternatives would result in a 

small negative habitat trend for three-toed woodpecker. Because the project would impact about 1.4 

percent of the three-toed woodpecker habitat on the forest, the amount of effect from this project is 

too small to cause measurable changes to the population. There would be no impacts on Dedicated 

Old Growth stands designated by the forest plan (USFS 1990) to provide for the viability of the threetoed woodpecker. Recent large fires have increased the amount of habitat on the forest. The project is 

consistent with the forest plan and thus continued viability of three-toed woodpecker is expected on 

the Umatilla National Forest. Alternative C proposes to treat fewer stands to maintain marginal and 

satisfactory cover in elk summer range

Birds of Conservation Concern

All action alternatives are consistent with the 1918 Migratory Bird Treaty Act (MBTA) and the 

Migratory Bird Executive Order 13186. The Forest Service supports the conservation intent of the 

migratory bird conventions by integrating bird conservation principles, measures, and practices into 

agency activities and by avoiding or minimizing, to the extent practicable, adverse impacts on 

migratory bird resources when conducting agency actions. Some specific examples for this project 

include retaining snags, retention of large trees, avoiding riparian areas, protecting raptor nests, and 

not burning during nesting season. 

The appropriate state Bird Conservation Plan and USFWS Birds of Conservation Concern species list 

(USFWS 2008) for the project area were reviewed. Specific species of concern were considered and 

the Conservation Strategy for Landbirds (Altman 2000) was reviewed for effects disclosures. The 

effects on those species and habitats that may occur in the Sunrise project are disclosed below (Table 

46.)

Table 46. Effects to birds of conservation concern in the Sunrise project area.

Bird Species Effects of Alternative A (No 

Action) to Habitat

Effects of Alternatives B and C to Habitat

Flammulated 

owl

Mature ponderosa pine and 

Douglas-fir with open canopy

would continue to be scarce.

Habitat would be enhanced through understory thinning and 

burning.

White-headed 

woodpecker

Ponderosa pine with open 

understory would continue to be 

scarce.

Ponderosa pine habitat would be enhanced through understory

thinning and burning.
Final Environmental Impact Statement

Pomeroy Ranger District 127

Bird Species Effects of Alternative A (No 

Action) to Habitat

Effects of Alternatives B and C to Habitat

Lewis' 

woodpecker

Habitat would continue to be 

present.

Habitat would be enhanced through understory thinning and 

burning, and retention of snags and down wood.

Williamson's 

sapsucker

Deciduous forest is limited but 

conifer habitat would continue to 

be present.

Habitat would be reduced due to removal of existing and future 

decaying trees, potentially enhanced through burning and 

maintenance of snags and down wood.

Olive-sided 

flycatcher

Habitat would continue to be 

present.

Landscape burning would enhance habitat. Thinning would create 

more diverse stand conditions, retaining largest trees and snags.

Forest gaps and forest edge habitat would enhance foraging 

opportunities.

Calliope 

hummingbird

Habitat would continue to be 

present.

Minor effects to second growth stands from non-commercial 

thinning. No effect to meadow edge, riparian, or canyon nesting 

habitat.

Cassin’s finch Habitat would be present but is 

declining over time as stands 

become dense.

Thinning from below in ponderosa pine stands would benefit this 

species.

Threatened, Endangered, and Sensitive Wildlife and Invertebrate Species

Wolverine

Management actions such as timber harvest, prescribed fire, and grazing, are not considered a threat 

to this species (USFWS 2013). Because wolverines are dependent on deep snow cover that persists 

into the month of May for successful denning, the primary threat is from habitat and range loss due to 

climate warming (USFWS 2013). Since denning is not expected in the area, there would be no effects 

to reproduction.

Timber harvest and underburning could lead to improvements in green forage production and 

palatability as well as berry production. Prey species and scavenging opportunities would likely 

remain the same. Open road densities would remain low, which restricts the amount of human 

disturbance. Forest corridors would be maintained.

Proposed activities in combination with other past, ongoing, and potential future projects are not 

expected to cause cumulative effects to marten or their habitat. Past timber harvest and road 

construction has occurred throughout the project area, which is reflected in the existing condition. 

The Asotin Creek Prescribed Fire project would not affect wolverine habitat. The 44 Road Grapple 

project is along a major road and would not be much more disturbance than normal road use. Forest 

recreation activities such as hunting, hiking, sightseeing, and berry picking take place during the day 

time when wolverine are less active. These and other activities such as livestock grazing, future 

seeding and planting, weed treatments, and road projects in combination with proposed activities in 

this EIS would have no cumulative effects to wolverine.

Determination

Because wolverines are not known to reside in the area, foraging and movement potential would 

remain about the same, and the project does not have denning habitat, implementation of either 

Alternative B or C would have no effect to North American wolverine.
Sunrise Vegetation and Fuels Project

128 Umatilla National Forest

Gray wolf

Timber harvest, mechanical fuels treatments, and low-intensity prescribed fires would reduce ground 

fuels and continuous fuel ladders. Future wildfires that occur in treated stands should burn cooler and 

would be less likely to ascend into the crowns of over-story trees. Thus, the risk of a hot crown fire

removing forest cover over large areas would be reduced. Where low-intensity, prescribed fire is 

employed, decadent vegetation on upland shrubs and grasses would be removed. Forage plants for big 

game should respond to these burns with robust basal sprouting and an increase in palatability for 

several years following treatment. In short, the proposed activities are not expected to reduce prey 

availability. See the elk section in this chapter for further information.

If a den or rendezvous site is identified prior to or during project activities, the Forest Service would 

consult with Washington Department of Fish and Wildlife personnel to determine if seasonal 

restrictions or other requirements are necessary. Because these sites are difficult to locate and can 

change yearly, this would need to be assessed on an ongoing basis throughout the life of the project. 

In the experience of regional and local biologists, timber harvest and associated activities has thus far 

had no evident impact to wolves on the Umatilla Forest (Berkley and Hickman 2015). The wolf 

population continues to grow (WDFW et al. 2017).

Proposed activities in combination with other past, ongoing, and potential future projects are not 

expected to cause cumulative effects to wolves. Past timber harvest and road construction has 

occurred throughout the project area, which is reflected in the existing condition. The Asotin Creek 

Prescribed Fire project would enhance habitat for wolf prey species. The 44 Road Grapple project is 

along a major road and would not be much more disturbance than normal road use. Forest recreation 

activities such as hunting, hiking, sightseeing, and berry picking take place during the day time when 

wolverine are less active. These and other activities such as livestock grazing, future seeding and 

planting, weed treatments, and road projects in combination with proposed activities in this EIS 

would have no cumulative effects to wolves. 

Determination

Since denning is not occurring within the project area, road densities would not change, and prey 

availability would remain high, the proposed activities in combination with other past, present, and 

reasonably foreseeable future actions would have no impact to gray wolf.

Preble’s shrew

Project requirements such as no-harvest buffers adjacent to springs, wetlands and stream habitats 

would reduce potential impacts to Preble’s shrew. Retention of down logs would help maintain moist 

microsite conditions. Effects to riparian and wet areas is unlikely. There is a slight chance that 

individual shrews could be killed by heavy equipment and burning operations. Timber harvest and 

fuels reduction would also remove or reduce the concealing cover of live ground vegetation and leaf 

litter over at least the short-term. Some down logs would be disturbed or removed. In the mid to longterm, timber harvest and landscape burning would promote the growth of dense understory vegetation 

by reducing competition with conifers for sunlight, water, and soil nutrients. These increases in herb 

and shrub growth could result in an increased abundance and diversity of insect prey. 

The proposed Asotin Creek burn as well as ongoing livestock grazing has the potential to reduce 

habitat quality for Preble’s shrew. However, if present, the species would have persisted through 

historic natural fires. Without knowledge of the current existence of the species in the project area, it 

is difficult to predict cumulative effects of the project in addition to proposed or ongoing effects. 

Protection of wet areas during operations and retention of down logs should make project effects 
Final Environmental Impact Statement

Pomeroy Ranger District 129

negligible and not cumulative with burning or grazing effects. No other ongoing or proposed 

activities would cause cumulative effects to Preble’s shrew. 

Determination

The Sunrise project may impact individual Preble’s shrews, but would not likely cause a loss of 

viability of the species or a trend toward federal listing.

Rocky Mountain bighorn sheep

Bighorn sheep tend to stay in open habitats but may use areas of forest where openings may have 

created by clear-cuts or fire (Beecham 2007). Washington Department of Fish and Wildlife expressed 

concern that opening up large acreages of forest in the Sunrise project could increase sight distance, 

and may encourage the relatively healthy Asotin bighorn sheep to venture out and make contact with 

other sheep herds. The Mountain View, Wenaha, and Tucannon herd home ranges are separated by 4, 

7, and 9 air miles respectively from the Asotin herd home range. Benefits of genetic interchange 

must be weighed against heightened risks of possible disease transmission particularly where

dispersing or wandering wild sheep might result in the transfer of locally endemic pathogens 

from an infected wild herd to a naïve herd (WAFWA 2010). 

There is no in depth analysis or research demonstrating the likelihood that this would happen after 

timber harvest. It would depend on the final outcome of the stand treatments, which are somewhat 

unknown at this time. Various scenarios and modeling would need to be done that reflect how open 

each stand would be at various locations, and whether that creates a corridor or suitable sight 

distance. The remote likelihood of timber harvest leading to disease transmission between bighorn 

sheep herds does not warrant this in-depth analysis. 

The main activity affecting bighorn sheep habitat would be landscape prescribed fire in the project 

area. Burning proposed in this EIS would improve 1,250 acres of bighorn sheep habitat within the 

Asotin Core Herd Home Range. Grass forage production and palatability would increase, and 

reduction of some trees in the grassy areas would improve visibility.

Cumulatively, the adjacent Asotin Creek prescribed fire project will improve an additional 4,500 

acres, which may help to encourage the sheep to stay on the east side away from other bighorn herds. 

Determination

Landscape prescribed fire would likely improve bighorn sheep habitat for a few years. The proposed 

activities overall are expected to have a net a beneficial effect and therefore, the project may impact 

Rocky Mountain bighorn sheep, but would not likely cause a loss of viability of the species or a trend 

toward federal listing.

Little brown myotis

Roosting habitat for bats could be slightly reduced at the stand scale, but measures taken to provide 

current and future habitat would contribute to long term snag habitat. Large tree and snag retention 

would be emphasized. Large snags would be left standing except for incidental snags that need to be 

felled for safety purposes, for skyline corridors, or during clearing for temporary roads. 

Thinning and selection harvests should accelerate the development of large trees in the project area. 

Over the long term, large diameter snags and down logs would be recruited from these trees. Timber 

harvest and fuel reduction activities would reduce ladder fuels and tree crown biomass, reducing the 

potential for hot, crown fires to occur in the project area. The supply of snags would be less subject to 
Sunrise Vegetation and Fuels Project

130 Umatilla National Forest

“boom and bust” cycles and should become more stable and continuous over time. The average snag 

diameter should slowly increase.

Landscape fire would be prescribed in stands that are not being harvested, both within and outside the 

Asotin Creek Roadless Area. Although a loss of snags is expected with prescribed burning, small 

scale torching would result in snag recruitment. Overall there is expected to be a net increase in snags, 

due to fire mortality. 

The Asotin Creek burn would potentially provide more decaying trees and snags, but there are fewer 

trees in that burn area. Personal firewood collection can contribute to snag reductions, however the 

overall effect would be small because removal typically occurs along open roads. Other ongoing and 

proposed activities would have no cumulative effect to dead wood habitat and little brown myotis.

For more information about effects to snags, see the Dead and Down Tree Habitat section of the 

wildlife report.

Determination

Threats to this species are primarily white-nose syndrome and wind turbines. Large snag habitat

would continue to be available for roosting bats. Therefore the Sunrise project may impact individual 

little brown myotis, but would not likely cause a loss of viability of the species or a trend toward 

federal listing.

Bald eagle

Use of the area by bald eagle is incidental. If this species were in the area during project activities, 

increased human presence and noise could cause it to move a short distance. Smoke from prescribed 

fires may discourage use of the area, but this is limited in duration. 

Proposed activities in combination with other past, ongoing, and potential future projects are not 

expected to cause cumulative effects to bald eagles or their habitat. Past timber harvest and road 

construction has occurred throughout the project area, which is reflected in the existing condition. 

The 44 Road Grapple project is along a major road and would not be much more disturbance than 

normal road use. These and other activities such as livestock grazing, future seeding and planting, 

weed treatments, and road projects in combination with proposed activities in this EIS would have no 

cumulative effects to bald eagles.

Determination

Bald eagle use of the area is incidental and there are no nearby nests. Since it is highly unlikely that 

individuals would be in close proximity during project activities, there would be no impact to bald 

eagle. 

Great Gray Owl

Opening up old forest multi-strata (OFMS) stands to old forest single-stratum could reduce the 

attractiveness of the stands for great gray owl nesting, but currently there is more than twice the 

amount of OFMS in the area than there should be. Reducing this condition is necessary to insure the 

long term health of the forest. There would be little to no loss of large trees or snags (>21 inches dbh) 

and no net loss of old forest. The roadless area as well as a substantial Dedicated Old Growth area 

would provide large areas of undisturbed habitat. 

Landscape burning would like enhance great gay owl habitat by maintaining grassy openings and 

stimulating plant species used by prey such as voles and other rodents. The proposed Asotin burn 
Final Environmental Impact Statement

Pomeroy Ranger District 131

would cumulatively contribute to maintaining open grassy areas. Other activities such as livestock 

grazing, future seeding and planting, weed treatments, and road projects in combination with 

proposed activities in this EIS would have no cumulative effects to great gray owls considering they 

do not seem to be present in the area.

Determination

Based on the lack of great gray owl observations in the project area, and lack of known nesting on the 

Umatilla forest, the Sunrise project would have no impact to great gray owl. If a nest is found at any 

time, it would be protected as described in the project design criteria (Chapter 2).

Northern goshawk

Within cutting units, the primary effect to potential goshawk habitat would be changing stand 

structure from OFMS to OFSS. Generally canopy cover would be reduced to the point that goshawks 

would not be drawn to these stands for nesting. Hand thinning and mechanical units with high cover 

retention would retain large trees for future nesting, but the understory would probably be altered 

enough that prey habitat would be reduced. Landscape burning would have a lesser effect, with 

variable effects to trees and understory stand components. 

Alternative B would reduce canopy cover below 50% on about 1,700 acres of potential goshawk 

habitat, while Alternative C would do the same on about 700 acres. 

Additional landscape burning would affect 2,400 acres, although fire would be patchy so the actual 

acres would be less. This includes riparian areas which would have minimal fire effects. 

This leaves 5,400 to 7,000 acres of well-connected and well-distributed potential goshawk habitat in 

Alternative B (depending on fire activity), and 6,400 to 7,000 acres in Alternative C. The best habitat 

in riparian areas would not likely be affected.

The Asotin Creek burn could affect an additional 1,500 more acres, depending on burning conditions. 

The majority of these are dry OFMS that is expected to remain OFMS because this is primarily a 

grassland burn and fire would not likely get into the forested stands. 

Other activities such as livestock grazing, future seeding and planting, weed treatments, and road 

projects in combination with proposed activities in this EIS would have not affect goshawk habitat.

Determination

The Sunrise project may impact individual northern goshawk, but would not likely cause a loss of 

viability of the species or a trend toward federal listing. If a nest is found at any time, it would be 

protected as described in the project design criteria (Chapter 2).

Lewis’s woodpecker and White-headed woodpecker

Both Alternatives B and C would potentially create healthier stands and more open conditions on 

about 1,800 acres of old forest multi-strata ponderosa pine stands. This would occur via thinning (800 

acres) or burning (1,000 acres). Areas not being thinned, but within the landscape burning perimeter 

(1,000 acres) may or may not be affected depending on site conditions and management of the burn. 

About 50 acres of OFMS pine would have a regeneration prescription but would still qualify as OFSS 

post-treatment (Units 130 and 226). All of these areas would retain large trees and snags.
Sunrise Vegetation and Fuels Project

132 Umatilla National Forest

The Asotin Creek Prescribed Fire project could create additional snag habitat. Burning effects are 

expected to be minimal, as the objective is to burn the extensive grasslands in the area. For more 

information about project effects to snags, see the Dead and Down Tree Habitat section of the wildlife 

report.

Determination

Lewis’ woodpecker and white-headed woodpecker habitat would likely be improved with both action 

alternatives in the long term. Therefore the proposed project may impact Lewis woodpecker and 

white-headed woodpecker, but is not expected to cause a loss of population viability or result in a 

trend toward federal listing. 

Green-tailed towhee

The most important management consideration for the green-tailed towhee probably is the 

maintenance of habitat heterogeneity, with respect to species composition, vigor, cover, and age 

structure of shrubs, and the prevention of invasion by non-native annual grasses (Dobbs 2006). 

Activities that promote species-rich shrub habitats with high shrub vigor should benefit green-tailed 

towhee (NatureServe 2017). Towhees can benefit from burns, timber harvest, and other management 

activities where post-fire or post-harvest habitats develop into brush fields (NatureServe 2017). 

Restoration of natural disturbance regimes may minimize unnaturally high levels of habitat alteration 

due to uncharacteristic fires.

Proposed activities would likely have a beneficial effect to habitat for green-tailed towhee. Burning is 

most commonly done in the fall and should have no effect to breeding birds if they are present. 

Controlled burns typically invigorate shrub growth. Timber management activities would reduce the 

chance for uncharacteristic wildfire, as well as open canopy up and allow for more shrub growth.

The Asotin Creek burn would also enhance habitat for this species. Other activities such as livestock 

grazing, future seeding and planting, weed treatments, and road projects in combination with 

proposed activities in this EIS would have not affect green-tailed towhee habitat.

Determination

The proposed activities would have an overall beneficial effect and therefore, the project may impact 

green-tailed towhee, but would not likely cause a loss of viability of the species or a trend toward 

federal listing.

Mountain quail

If present, smoke and fire may displace quail temporarily but they would eventually return to post-fire 

habitat. Landscape burning may reduce shrubs that quail use for cover in the short term, but increase 

in the mid to long term. The shrubs and grasses will often be stimulated by fire and grow with more 

vigor and improve the overall habitat quality for quail. Quail habitat in riparian areas would generally 

not be affected. Timber removal and tree thinning could also create early successional-stage shrub 

vegetation in the short term. 

The adjacent Asotin Creek prescribed fire project have similar effects as burning proposed in this 

project. Other ongoing activities such as seeding, planting, and invasive plant treatment could have 

beneficial effects to mountain quail habitat. Livestock grazing could reduce cover, but not at a scale 

that mountain quail habitat would be eliminated. On balance, the cumulative effects from the Sunrise 

project and other activities would likely be positive. 
Final Environmental Impact Statement

Pomeroy Ranger District 133

Determination

The proposed activities would have an overall beneficial effect and therefore, the project may impact 

mountain quail, but would not likely cause a loss of viability of the species or a trend toward federal 

listing.

Rocky Mountain tailed frog

Timber management activities would not affect riparian areas, and thus would not directly affect 

tailed frogs. The stream environment is not expected to be disturbed. Indirectly, any changes to water 

temperature or stream quality could affect tailed frog reproductive success. No effects to water 

temperature and channel morphology are expected. There may be short term, slight effects to 

sediment levels in some area streams due to thinning followed by prescribed burning (Hydrologist 

report). 

Landscape fire would be allowed to back into some riparian areas. Fire and smoke could temporarily 

cause terrestrial tailed frogs to move out of the area or stay in the water, but should cause no harm. 

Tailed frogs in the water would not be affected by low intensity fire. 

The adjacent Asotin Creek prescribed fire project have similar effects as burning proposed in this 

project. Other ongoing activities such as seeding, planting, and invasive plant treatment would not 

affect amphibian habitat. Livestock grazing could reduce ground cover, but not at a scale that would 

cumulatively cause harm to the species. 

Determination

The project may impact Rocky Mountain tailed frog, but would not likely cause a loss of viability of 

the species or a trend toward federal listing. Effects from this project are expected to be slight to none 

since no activities are proposed within riparian areas and effects to water quality would be minimal.

Invertebrate species

Heavy equipment operation and prescribed burning could directly kill individual sensitive

invertebrates; particularly the less mobile species such as the mollusks or the larvae of butterflies. 

Food plants could be crushed or removed. Down logs which provide essential habitats for the 

mollusks could be removed, broken down by heavy equipment operation, or charred in areas that are 

under-burned. 

Off-setting these potential adverse effects, timber harvest would create openings and edge habitat that 

would provide some species with increased flowering plants. Project design criteria require protection 

of rock outcrops, talus, meadows and riparian areas. PACFISH buffers would protect springsnail and 

other species that are closely associated with water sources.

Down log habitat would be reduced, but not in wet areas or in any of the aforementioned habitats. 

The prescribed amount of large down wood (derived from a natural range) that could harbor sensitive

snails would be retained within harvest units. Burning in moist or wet areas would cause minimal or 

no changes to down wood. 

Proposed landscape burning could affect ravines, open ridges and hillsides. This is a natural part of 

the ecosystem, but is applied in a controlled manner. Burn plans include specific objectives and 

controls, with considerations for topography, wind pattern, amount of burned area, etc. Effects would 

be much less than if a wildfire occurred. 
Sunrise Vegetation and Fuels Project

134 Umatilla National Forest

Western dwarf mistletoe has not been reported in the ponderosa pines in the analysis area. Areas with 

the most pine and highest potential for western dwarf mistletoe would see primarily small diameter 

hand thinning and underburning. Ponderosa pine stands would be improved overall, providing habitat

(host plants) longer. Since Johnson’s hairstreak are not documented in or near the project area, and 

most potential habitat would have minimal disturbance, no effects to Johnson’s hairstreak would be 

expected.

The Asotin Creek Prescribed Fire project would have similar effects as described above for the 

proposed landscape burning. Ongoing livestock grazing may have additional effects to sensitive 

invertebrates through disturbance to meadows, down wood, and riparian areas. With no known 

locations for most of these invertebrates, that is difficult to assess. 

Determination

Based on the short to long-term project effects described earlier, and the lack of evidence indicating 

these species are present, the alternatives as proposed may impact individuals, but would not likely 

cause a trend to federal listing of any sensitive invertebrate species (Table 47.)

Table 47. Summary of effect to sensitive wildlife and invertebrate species.

Species Alternative A Alternative B Alternative C

Mammals

Canada lynx No Effect No Effect No Effect

Yellow-billed cuckoo No Effect No Effect No Effect

North American wolverine No Effect No Effect No Effect

Gray wolf No Impact No Impact No Impact

Preble’s shrew No Impact May Impact May Impact

Rocky Mountain bighorn sheep No Impact May Impact May Impact

Mountain goat No Impact No Impact No Impact

Townsend’s big-eared bat No Impact No Impact No Impact

Little brown myotis No Impact May Impact May Impact

Birds

Bald eagle No Impact No Impact No Impact

Peregrine falcon No Impact No Impact No Impact

Great gray owl No Impact No Impact No Impact

Northern goshawk No Impact May Impact May Impact

White-headed woodpecker No Impact May Impact May Impact

Lewis’ woodpecker No Impact May Impact May Impact

Green-tailed towhee No Impact May Impact May Impact

Mountain quail No Impact May Impact May Impact

Amphibians

Rocky Mountain tailed frog No Impact May Impact May Impact

Molluscs

Fir pinwheel No Impact May Impact May Impact

Columbia Gorge oregonian No Impact May Impact May Impact

Pristine springsnail No Impact No Impact No Impact

Humped coin No Impact May Impact May Impact

Thinlip tightcoil No Impact May Impact May Impact

Shiny tightcoil No Impact May Impact May Impact
Final Environmental Impact Statement

Pomeroy Ranger District 135

Species Alternative A Alternative B Alternative C

Salmon coil No Impact May Impact May Impact

Butterflies 

Great Basin fritillary No Impact May Impact May Impact

Meadow fritillary No Impact No Impact No Impact

Johnson’s hairstreak No Impact May Impact May Impact

Barry’s hairstreak No Impact No Impact No Impact

Lustrous copper No Impact May Impact May Impact

Other Insects

Columbia clubtail No Impact No Impact No Impact

Western bumble bee No Impact May Impact May Impact

No Effect: no effect on a proposed or listed species or critical habitat; No Impact: no impact to R6 sensitive species 

individuals, populations, or their habitat; May Impact: may impact sensitive species, but will not cause a loss of viability or 

trend toward federal listing.

Findings of Consistency

All alternatives would be consistent with Forest Plan standards and guidelines, because they would 

meet project design features set for the project, meet standards and guidelines for affected land 

management allocations, and provide for viable populations of wildlife species. All alternatives 

would provide for diversity of plant and animal communities in the Sunrise project area, based on the 

suitability and capability of the land therein. All project alternatives are consistent with the 

Endangered Species Action, Migratory Bird Treaty Act, Bald and Golden Eagle Protection Act, and 

Facilitation of Hunting Heritage and Wildlife Conservation Executive Order.

Final Environmental Impact Statement

Pomeroy Ranger District 137

3.9 Fisheries

Introduction

Special attention is paid to fisheries in the Pacific Northwest. The region is home to many iconic 

aquatic species, some of which are threatened or endangered. Therefore fisheries require special 

attention and additional analysis.

Regulatory Framework

The Sunrise Vegetation and Fuels Management Fisheries Specialist Report was prepared in 

accordance with the following guidance and direction:

• Section 7(a)(2) of the Endangered Species Act of 1973 (as amended),

• Magnuson-Stevens Fishery Conservation and Management Act (§ 305(b)) and it’s 

implementing regulations (50CFR § 600).

• National Forest Management Act of 1976

• Clean Water Act of 1972

• Land and Resource Management Plan – Umatilla National Forest (1990) as amended by 

PACFISH (1995)

Threatened, Endangered and Sensitive (TES) Fish and Habitat

Snake River Basin (SR) steelhead, Bull trout, Snake River Spring/Summer Chinook (historically) 

salmon and their designated critical habitats and salmon essential fish habitat are the only species and 

habitats listed under the Endangered Species Act (ESA), which are found in or adjacent to the project 

area. Information on the Regional Forester’s sensitive species suspected or known to occur on the 

Umatilla National Forest can be found in Table 50.

Management Indicator Species (MIS)

Steelhead trout (anadromous) and resident rainbow trout (aka Redband trout) are the designated 

aquatic Management Indicators Species (MIS) for the Umatilla National Forest. The Forest Plan was 

amended in 1995 by PACFISH which incorporated standards and guides to allow for near-natural 

rates of habitat restoration, and avoid adverse effects to listed species and their Designated Critical 

Habitats. Streams surveys and broadscale efforts, i.e. PACFISH/INFISH Biological Opinion, (aka 

“PIBO”) monitoring, are in place to collect data and monitor habitat conditions.

Snake River Basin steelhead and their Designated Critical Habitat

Wild steelhead and resident interior Columbia Basin redband trout in the analysis area, are the 

anadromous and resident forms respectively, of the same salmonid subspecies (Oncorhynchus mykiss 

gairneri). Redband trout are another name for native resident rainbow trout in the Interior Columbia 

River Basin and are indistinguishable visually from the anadromous form as juveniles. Steelhead rear 

in freshwater streams for their first 1 to 3 years prior to smolting. They then migrate to the ocean 

where they can spend up to 3 years before returning to their native freshwater stream to spawn. 

Unlike Pacific salmon, steelhead are iteroparous, meaning they do not necessarily die after spawning 

and are able to spawn more than once, although this varies among runs
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138 Umatilla National Forest

Methodology

For this document, the environmental baseline discussion and discussion of effects use FS habitat

stream survey data and WDFW stream survey data as well as GIS analysis and the Interior Columbia 

Basin Ecosystem Management Project (ICBEMP) summary values (McKinney et al. 1996, see table 

11) as directed under ICBEMP memorandum FS agreement No. 03-RMU-11046000-007, and reports 

in published scientific literature. Water temperature data is referenced from the Umatilla National 

Forest monitoring records. The seven-day moving maximum and average summer time water 

temperatures are measured. Stream surveys follow the Region 6 Level II stream survey protocol 

(following a modified Hankin and Reeves 1988 protocol). 

The surveys were conducted to document stream conditions and establish a baseline. Surveys have 

been completed and updated for most major streams in the Project Area. 

These habitat parameters are specifically addressed as PACFISH Riparian Management Objectives 

(RMO’s) (referencing Section 7 Fish Habitat Monitoring Protocol for the Upper Columbia River 

Basin, USDA Forest Service, 1994), Please see the Fisheries Specialist Report for further details. 

Under the Section 7 Habitat Monitoring Protocol for the Upper Columbia River Basin (USDA 1994), 

PACFISH RMO’s are intended to apply to fish bearing Rosgen (1996) C-type channels and are meant 

to describe good fish habitat. Table 8, above, has a list of streams and their associated Rosgen stream 

channel type. These types of channels are most commonly found in low-gradient channels in wide 

alluvial valley bottoms. For example, monitoring protocol for determining pool frequency requires 

count of only pools greater than 1 meter (~3 feet) deep in low gradient (1% -2%) stream channels. 

Streams within or adjacent to the analysis area that do not fit these criteria include Cougar Creek, 

Lick Creek, NF Asotin Creek , Middle Branch of NF Asotin Creek and SF of NF Asotin Creek. These 

Streams are more representative of a Rosgen Type B stream channel. Because of this, ICBEMP pool 

frequencies are more applicable to these streams than the PACFISH standard. ICBEMP pool 

frequency values are more representative of stream capabilities within the analysis area. 

Affected Environment

The Sunrise Project is proposed in the headwaters of the North Fork Asotin Creek Subwatershed 

(HUC 170601030201) and Lick Creek Subwatershed (HUC 170601030202) both of which are part of 

the George Creek – Asotin Creek Watershed (HUC 1706010302). 

The George Creek – Asotin Creek Watershed is part of the Lower Snake - Asotin Sub-basin and the 

Lower Snake Basin, a tributary to the Mid-Columbia River. The watershed area is approximately 

208,267 acres, of which 63,163 acres (30 percent) are managed by the US Forest Service (USFS). 

Please See below. 

The George Creek – Asotin Creek Watershed will be the analysis area for cumulative effects on Snake 

River Basin steelhead, Snake River spring Chinook, Bull trout and their Designated Critical Habitats. 

The same watershed will be the analysis area for the cumulative effects on Essential Fish Habitat. The 

George Creek – Asotin Creek Watershed contains the Sunrise Project area. Table 49 shows acreage of 

the Sunrise Project area within the watershed.
Final Environmental Impact Statement

Pomeroy Ranger District 139

Table 48. Management of Watershed affected by the Sunrise Project

Manager Acres Percent

US Forest Service (Umatilla NF) 63,163 30%

Other (BLM, Private and State) 145,104 70%

Total 208,267 100%

Table 49. Project Area acreage within the watershed

Watershed Name (HUC) Watershed Size 

(acres)

Project Acres in 

Watershed

Watershed in Project 

Boundary

George Creek – Asotin Creek Watershed

(HUC 1706010302) 208,267 32,000 15.3%

Indicators

Within the George Creek and Asotin Creek watersheds there is 115.2 miles of stream occupied by 

steelhead, with 17.6 miles located within the project area. Steelhead in the analysis area display a 

broad life history pattern of spawn timing typically called summer-run. Steelhead spawning occurs 

between March and May. Prior to spawning, maturing adults hold in pools or in side channels to 

avoid high winter flows. Typically, they spawn in stream reaches with a moderate to high gradient. 

Fry typically emerge between April and June. Migration to the ocean typically occurs at age 2 for 

wild summer steelhead, while most hatchery smolts migrate at age 1 (Carmichael and Taylor, 2009).

The steelhead population utilizing the Sunrise Project area is part of the Lower Snake Major 

Population Group (MPG), within the Snake River Basin Steelhead DPS. Figure 3-8 shows the 

Steelhead distribution within and adjacent to the Sunrise project area.
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140 Umatilla National Forest

Figure 3-8. Steelhead distribution within and adjacent to the Sunrise Project.

Designated critical habitat for Snake River Basin Steelhead includes all rivers and stream reaches 

accessible to steelhead below long-standing natural barriers (Federal Register Vol. 70 (52630); 

September 2, 2005). There are approximately 8.9 miles of designated critical habitat for Snake River 

Basin Steelhead within the project area.

Snake River Spring Chinook salmon and their Designated Critical Habitat

Chinook salmon are anadromous, living part of their life in salt water while breeding in fresh water; 

and semelparous, reproducing only once in a lifetime. Biologists recognize different seasonal (i.e., 

spring, summer, fall, or winter) "races" or “runs” in the Chinook salmon migration from the ocean to 

fresh water. 

Spring/summer-run Chinook salmon from the Snake River basin exhibit stream-type life history 

characteristics. The spring-run Chinook salmon return to the Columbia River from the ocean in early 

spring and pass Bonneville Dam beginning in early March and ending the first week of June. The 

summer-run Chinook salmon return to the Columbia River from June through August. Returning fish 

hold in deep mainstem and tributary pools until late summer, when they emigrate up into tributary 

areas and spawn. In general, Snake River Basin spring-run Chinook salmon tend to spawn in higherelevation reaches of major Snake River tributaries in mid- through late August. Snake River Basin 

summer-run Chinook salmon spawn approximately one month later than spring-run fish and tend to 

spawn lower in the Snake River Basin drainages, although their spawning areas often overlap with 

spring-run spawners.
Final Environmental Impact Statement

Pomeroy Ranger District 141

Figure 3-9. Designated Steelhead Critical Habitat within and adjacent to the Sunrise Project

The stream-type life history may be adapted to select spawning and rearing areas that are consistently 

productive with limited susceptibility to dramatic changes in water flow. The eggs that Snake River 

spring and summer Chinook salmon deposit in late summer and early fall incubate over the following 

winter, and hatch in late winter and early spring of the following year. Juveniles rear through the 

summer, overwinter, and typically migrate to sea in the spring of their second year of life, although 

some juveniles may spend an additional year in fresh water. Depending on the tributary and the 

specific habitat conditions, juveniles may migrate extensively from natal reaches into alternative

summer-rearing or overwintering areas. Most of the fish spend two or three years in the ocean before 

returning to tributary spawning grounds primarily as 4- and 5-year-old fish. A small fraction of the 

fish spend only one year in the ocean and return as 3-year-old “jacks,” heavily predominated by males 

(Good et al. 2005). 

The Snake River spring/summer Chinook salmon was listed as Threatened under the Endangered 

Species Act on April 22, 1992 (50 FR 37160). Critical habitat was designated for Snake River 

spring/summer Chinook salmon on December 28, 1993 (58 FR 68543) and revised October 25 of 

1999 (64 FR 57399). Although Designated Critical Habitat is not mapped for Snake River 

Spring/Summer Chinook salmon, it is described in the narrative or rule 64 FR 57399. Critical Habitat 

includes those waters that are accessible upstream of occupied habitat. These listings decisions were 

reaffirmed in 2005 (Good et al. 2005; 50 FR 37160).

Snake River spring/summer Chinook salmon were historically found within and adjacent to the 

Sunrise Project boundary. They were known to occupy approximately 5.4 miles of NF Asotin Creek 

within the Project boundary; and also downstream of the project area in NF Asotin Creek and 
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142 Umatilla National Forest

mainstem Asotin Creek. Due to few adult spawners returning to Asotin Creek, the Interior Columbia 

Technical Review Team considers the Asotin Spring Chinook population to be functionally extinct. 

Figure 3-10. Historical Chinook salmon distribution within and adjacent to the Sunrise Project

Essential Fish Habitat

The federal Magnuson-Stevens Act (MSA) requires analysis for effects to Essential Fish Habitat

(EFH) specifically for Pacific salmon. Amendment 18, of the Pacific salmon Fisheries Management 

Plan, revises the description and identification of EFH for Pacific salmon managed under the FMP. 

Freshwater EFH, identified in Amendment 18 of the FMP, is described using fourth field hydrologic 

unit codes (HUCs). 

EFH includes all streams, lakes, ponds, wetlands, and other currently viable water bodies and most of 

the currently and historically accessible habitat to Pacific salmon species. The riparian zone adjacent 

to these waterways is also considered EFH. This zone is defined as shade, sediment, nutrient/chemical 

regulation, streambank stability, and LWD/organic matter. 

The Sunrise project area falls within one HUC 8 (Lower Snake - Asotin) identified in the Pacific 

salmon Fisheries Management Plan as EFH and contains EFH for Chinook salmon. 

Bull trout and their critical habitat

Bull trout (Salvelinus confluentus) are members of the Salmonidae family. They are often referred to 

as char, which is the common name for members of the genus Salvelinus. 
Final Environmental Impact Statement

Pomeroy Ranger District 143

In general, bull trout are a cold water species that inhabits Pacific slope drainages from northern 

California through British Columbia to extreme southeastern Alaska (Meehan and Bjornn 1991). 

Natural climactic warming and loss of cold water habitats since the Pleistocene period exacerbated by 

effects of human activities have reduced their distribution (Cavender 1978). 

GIS databases show Bull trout are known to occur in 78.4 miles of streams in the George Creek –

Asotin Creek watershed. Those same streams are listed as Designated Critical Habitat (DCH) by the 

U.S. Fish and Wildlife Service. Of those occupied and DCH streams, approximately 14.8 miles are 

within the Sunrise project boundary. 

Redband/Rainbow Trout 

Interior Columbia Basin redband trout are a resident subspecies of Oncorhynchus mykiss found east 

of the Cascade Mountains in Oregon and Washington, in northern California, and in eastern British 

Columbia. Behnke (1979) noted two main evolutionary lines of the species dating back to the 

Pleistocene; the coastal rainbow trout west of the Cascades and the inland Columbia Basin redband 

trout east of the Cascades. Both of these evolutionary lines include steelhead populations of their 

respective areas. They are currently recognized as being two separate subspecies, with the natural 

break between them being the Cascades Mountains in Oregon. 

Hatchery rainbow trout stocked for sport fisheries are typically produced from the coastal subspecies 

(Oncorhynchus mykiss irideus), and had been stocked in analysis area waters in earlier decades, but 

hatchery stocking in free-flowing streams has been discontinued in recent years. Absent genetic 

analyses to show dominant hatchery genetics, all resident O. mykiss in the analysis area are presumed 

to be O. mykiss gairdneri/interior Columbia Basin redband trout, particularly since the two subspecies 

display different patterns of coloration. Genetically pure populations of redband can generally be 

found isolated above migratory barriers where stocking has not occurred (Behnke 1979). 

Redband trout require stream and riparian habitat conditions in the area favorable to spawning and 

rearing. Factors concerning their habitats include water temperature, water quality, timing and 

quantity of peak stream flows, and physical in-stream and riparian habitat characteristics. Good water 

quality is essential for spawning and rearing. Redband require similar in-stream habitat characteristics 

as other cool-water salmonids. A variety of habitat types are important in providing adequate habitats 

for all life stages.

GIS data show Redband/rainbow trout are present in 27.1 miles of streams within the Sunrise project 

boundary. Of those occupied streams, 3.2 miles are above physical barriers 

Regional Sensitive Invertebrate and Vertebrate Species

A number of sensitive invertebrate and aquatic vertebrate species are known or suspected on the 

Umatilla National Forest. Table 50 describes their known or suspected presence in the analysis area.
Sunrise Vegetation and Fuels Project

144 Umatilla National Forest

Table 50. Regional Forester's List of Sensitive Aquatic Invertebrate and Vertebrate Species Present or 

suspected on the Umatilla NF

Regional 

Sensitive

Aquatic Species

Habitat Description* Habitat

Present in 

Analysis 

Area

Species Present in 

Analysis Area

Known Current 

Distribution

Western ridged 

mussel 

(Gonidea 

angulata)

Occur in streams of all sizes of 

low to mid-elevation 

watersheds. Common in stable 

stream reaches, tolerant of fine 

sediments and occupy 

depositional areas.

Habitat likely 

present in 

NF Asotin 

Creek.

Assumed present 

within the analysis 

area although none 

have been found 

during stream surveys 

or project field visits.

Widely distributed west 

of the Continental 

Divide, CA to BC. It is 

mainly distributed east 

of the Cascades.

Shortface lanx 

(Fisherola nuttalli)

Occurs in large low to midelevation riverine habitats. 

Common in unpolluted, cold, 

well oxygenated, perennial 

streams with cobble-boulder 

substrate.

No No Found throughout the 

Snake River and the 

Mid-Columbia basin 

limited to large rivers.

Westslope 

Cutthroat Trout 

(Oncorhynchus 

clarkii lewisi)

Cold clear, water, high 

mountain streams with variable 

habitat complexity

No No Found throughout the 

Mid-Columbia River 

Basin, NFJD and Upper 

John Day R. subbasins

*Frest and Johannes 1995, Nedeau et al. 2009, Neitzel and Frest 1990, NatureServe Explorer 2009, Paulson 1999, 

Scheuering 2006, forest stream survey data (on file); Xerces.org database.

Westslope cutthroat trout

Westslope cutthroat are considered a sensitive species on the Forest. The only known or suspected 

populations are located in high-elevation watersheds of the John Day River basin. There are no 

Westslope cutthroat trout located in the Sunrise project area and will not be discussed any further in 

this Fisheries Specialist Report.

Western ridged mussel

Western Ridged mussels (G. angulate) are filter feeders that consume phytoplankton and zooplankton 

suspended in the water. Gonidea angulata is a relatively slow growing and long lived species –

perhaps living 20 to 30 years (COSEWIC 2003, Vannote and Minshall 1982). To reproduce, adult 

females release fertilized juvenile mussels, or glochidia, in packets called conglutinates. Glochidia 

attach to host fish for a period of weeks to months. Once glochidia are released, they attach to a fish 

host. In northern California, the release of glochidia apparently peaks in June, and the glochidia are 

probably excysted from fish primarily during the period from late June to late July (Spring Rivers 

2007). Gonidea angulata is not known to occur in the Sunrise Project area. 

Shortface lanx

Fisherola nuttalli is generally restricted to relatively large perennial streams ranging from 30-100 m 

(98-300 ft.) wide in the Columbia River Basin. Within such streams it is found primarily at the edges 

of rapids or immediately downstream from rapids in areas that have suitable substrate. This species 

requires clean, cold, well-oxygenated water with gravel, cobble, and boulder substrate. In an 

assessment of Hells Canyon Dam (Snake River, Idaho), F. nuttalli was found on cobbles in higher 

velocity areas of the stream much more frequently than any other mollusk species; this was 

considered to reflect the species’ preference to attach themselves to hard surfaces in high velocities to 

avoid competition with other species (Richards et al. 2005).
Final Environmental Impact Statement

Pomeroy Ranger District 145

Fisherola nuttalli has not been found in areas with the following characteristics: slow flow; silt or 

mud substrates; extreme seasonal variations in discharge; an abundance of macrophytes (aquatic 

plants) or epiphytic algae; a bedrock substrate; or where dredging or mining occurs (Neitzel & Frest 

1992; Frest & Johannes 1995; Frest 1999; Richards et al. 2005). The snails feed by scraping algae and 

diatoms from the surface of rocks and boulders.

Freshwater pulmonate snails generally reproduce sexually, laying their eggs from spring to fall in a 

gelatinous capsule attached to plants or stones. Egg capsules of F. nuttalli are usually laid on the 

undersides or sides of cobbles in protected areas where adults occur. Fisherola are hermaphrodites but 

do not appear to be self-fertilized, i.e. mating occurs between two individuals. Hatchlings are 

morphologically similar to adults, except that they lack a functional reproductive system. Young 

snails appear to grow rapidly and require only a few months to reach full size. Individual F. nuttalli

generally live for only one year, as this species breeds once and dies afterwards (semelparous 

breeding) (comments by T. Frest in 5-year review and evaluation of Banbury Springs limpet, U.S. 

Fish and Wildlife Service 2006). Individuals are present year-round in the streams they inhabit, but 

are inactive during the winter. Dispersal of F. nuttalli occurs as snails crawl slowly across the 

substrate or are carried by the current.

Fisherola nuttalli was historically widespread, with populations scattered throughout the lower 

Columbia and Snake Rivers as well as some of their major tributaries, and was known from 

Washington, Oregon, Idaho, and Montana. It has also been documented in the Columbia River 

drainage in British Columbia, Canada, although its presence there was assumed based on the 

discovery of a shell (Clarke 1981). Prior to 1987, collections of F. nuttalli are reported from Columbia 

and Spokane Rivers in Washington; the Snake and Salmon Rivers in Idaho; the Deschutes River in 

Oregon; and the Kootenai River in British Columbia. Columbia River sites extended from Portland, 

Oregon, to the Hanford Reach in Washington. Most of these sites no longer have suitable F. nuttalli

habitat due to the effects of damming, impoundment, pollution, and water withdrawals for irrigation 

(Neitzel & Frest 1992), although one occurrence is known in Oregon near the Bonneville Dam. This 

species is now presumed extirpated in Montana and British Columbia, although it may persist in the 

Okanogan River drainage in British Columbia (Stagliano et al. 2007).

Currently, large populations of F. nuttalli persist in only four streams: the lower Deschutes River, 

Oregon; the Okanogan River and the Hanford Reach of the Columbia River, Washington; and the 

Snake River in Oregon and Idaho. Additional small populations are found in Oregon in the John Day 

and Imnaha Rivers, and the lower Columbia River near Bonneville Dam; the Methow River, 

Washington; and the Grande Ronde River, Washington and Oregon (Neitzel & Frest 1992; Frest & 

Johannes 1995, 2000; Frest 1999; Richards et al. 2005; Idaho Conservation

Data Center 2006). Many of these areas are on federal lands, including the Hanford Reach 

(Department of Energy); Deschutes Wild and Scenic River; Hells Canyon National Recreation Area; 

Okanogan, Gifford Pinchot, and Mt. Hood National Forests; and the Bonneville Power

Administration. Shortface Lanx are not known to occur within or adjacent to the Sunrise Project area.
Sunrise Vegetation and Fuels Project

146 Umatilla National Forest

Environmental Consequences

Direct and Indirect Effects

Alternative A (No Action)

There are no direct or indirect effects under this Alternative. Under Alternative A of the Sunrise 

Project, the FS would not change management in the project area. There would be no proposed road 

maintenance/construction, harvest, thinning, prescribed burning or other associated activities. 

Therefore, there would be no mechanism for direct, indirect or cumulative effects to ESA listed fish 

species and their DCH, Essential Fish Habitat (EFH) or USFS R6 sensitive fish and aquatic 

invertebrates and their habitat. 

Therefore, there would be no effect to Proposed, Endangered, and Threatened fish species and DCH 

or EFH and no impact to Sensitive fish and aquatic invertebrate species and their habitats considered 

in this analysis.

For additional information, see the Fisheries Specialists Report.

Alternatives B and C

Snake River Basin steelhead and Designated Critical Habitat

The steelhead population that inhabits the Sunrise project area is part of the Lower Snake River Major 

Population Group (MPG), within the Snake River Basin Steelhead DPS. They spawn and rear in 17.6 

miles of stream within the George Creek – Asotin Creek watershed portions of the project area. There 

are 8.9 miles of designated critical habitat (DCH) for Snake River Basin steelhead within the project 

area.

SRB steelhead and their DCH may be indirectly affected by harvest, burning and road management 

activities, particularly where those activities occur within RHCAs. Project design criteria and BMP

monitoring would ensure that the probability and magnitude of those effects remain both negligible 

and discountable. There would be no measurable cumulative effects to the species or to DCH. 

Therefore, the implementation of the Sunrise Vegetation and Fuels Management Project activities 

(harvesting, prescribed fire/fuels management and road management) under the Proposed Action 

alternative May Affect, Not Likely to Adversely Affect Snake River Basin steelhead and May Affect, 

Not Likely to Adversely Affect Designated Critical Habitat for SRB steelhead.

Chinook salmon, Designated Critical Habitat and Essential Fish Habitat

Snake River spring/summer Chinook salmon are found within the Sunrise Vegetation and Fuels 

Management project boundary. Historically they were found in approximately 5.8 miles of NF Asotin 

Creek within of the project area (Figure 3-10). Chinook salmon found in the project area are from the 

Asotin population of the Lower Snake River MPG. This MPG historically had two populations 

(Tucannon and Asotin populations). In 2011, the ICTRT declared the Asotin population to be 

functionally extirpated. Designated critical habitat for the Snake River spring/summer Chinook 

salmon is not mapped but is described in narrative in the rule (64 FR 57399). Critical Habitat includes 

those waters that are accessible upstream of occupied habitat. 
Final Environmental Impact Statement

Pomeroy Ranger District 147

The Lower Snake - Asotin HUC contains EFH and is associated with the Snake River spring Chinook 

ESU. The project area contains approximately 5.8 miles of occupied EFH associated with North Fork 

Asotin Creek. Chinook can also be found downstream of the project area in mainstem Asotin Creek. 

Through the implementation of project design criteria and BMP monitoring, there would be no 

measurable direct, indirect or cumulative effects from the implementation of the Sunrise Vegetation 

and Fuels Management Project under the proposed action Alternative. 

Therefore, implementation of the Sunrise Vegetation and Fuels Management Project activities 

(harvesting, prescribed fire/fuels management and road management) under the proposed action 

Alternative May Affect, Not Likely Adversely Affect SR spring/summer Chinook salmon if present or 

their Designated Critical Habitat and Will Not Adversely Affect Essential Fish Habitat for Chinook 

salmon. 

Bull trout and Designated Critical Habitat

Bull trout are known to occupy approximately 14.8 miles of stream within the Sunrise Project area. 

Those same streams are listed as Designated Critical Habitat (DCH) for Bull trout. Based on the 

distance from project activities and occupied habitat, and the implementation of project design criteria 

and BMP monitoring, there would be no measurable direct, indirect or cumulative effects from the 

implementation of the Sunrise Vegetation and Fuels Management Project under the proposed action 

Alternative. 

For the reasons stated above, the implementation of the Sunrise Project under the proposed action 

Alternative May Affect, Not Likely to Adversely Affect Bull trout and/or their Designated Critical 

Habitat. 

Western ridged mussel

Gonidea angulate is not known to occur within or adjacent to the Sunrise project boundary. Due to 

the lack of presence and through the implementation of project design criteria and BMP monitoring, 

there would be no direct, indirect or cumulative effects from the implementation of the Sunrise 

Vegetation and Fuels Management Project under the proposed action Alternative. 

For reasons stated above, the implementation of the Sunrise Project under the proposed action 

Alternative would have no impact to Western Ridged Mussel individuals or their habitat. 

Shortface lanx

Shortface Lanx, aka Giant Columbia River Limpet, are not known to occur within or adjacent to the 

Sunrise Vegetation and Fuels Management Project area. Due to the species not being present in the 

project area and through implementation of project design criteria and BMP monitoring, there would 

be no direct, indirect or cumulative effects from the implementation of the Sunrise Project under the 

proposed action Alternative.

For reasons stated above, the implementation of the Sunrise Project under the proposed action 

Alternative would have no impact to Shortface Lanx individuals or their habitat.

For additional information on either action Alternative, please see the Fisheries Specialists Report.
Sunrise Vegetation and Fuels Project

148 Umatilla National Forest

Cumulative Effects

Alternative A (No Action)

Cumulative impacts result from the incremental impact of the action when added to other past, 

present and reasonably foreseeable future actions. Since there is no action under Alternative A, there 

are no direct or indirect effects and therefore no cumulative effects.

Species composition and structural changes at the landscape scale described in the Vegetation Report 

would not occur by mechanical means, therefore succession would remain on its current trajectory 

further away from landscape range of variation. 

Stream temperatures would be unaffected under the No Action alternative. 

Under the No Action alternative, the current road densities, road use designations and use patterns 

within the analysis area would not change. Motor vehicle and recreational off road vehicle use would 

continue to occur on routes designated on the Umatilla National Forest motor vehicle use map 

(MVUM). Erosion and sedimentation from roads would continue as roads are used and maintained 

according to their respective maintenance level. Continued deferred maintenance of the majority of 

system roads would be the primary management related sources of accelerated erosion. Natural 

disturbance events such as fires and floods could affect stream temperature and sediment regimes 

over time, if these events cause large-scale changes to vegetation or stream channel morphology. 

The hydrologic function of streams in the project area would continue to recover within the 

limitations of past and present management (timber harvest and roads) and periodic high flow events. 

Large scale fire could affect water yield and peak flows, with resultant adverse effects to channel and 

riparian condition, with resultant loss of fish habitat.

Alternative B

Stream Temperature

Past management activities, including road construction/maintenance, timber harvest and fuels 

treatments affected the overstory structure and thus the shade component of the streams. This 

ultimately affected stream temperature. This alternative proposes to use prescribed fire to treat fuels. 

Fire ignition could occur within 100 feet of fish bearing streams in the NF Asotin Creek subwatershed 

and within 100 feet of fish bearing streams in the Lick Creek subwatershed. These activities are not 

expected to remove shade producing trees along the streams and therefore would not be expected to 

affect stream temperature. 

There would be no cumulative effects to stream shade or water temperature as a consequence of 

implementing this alternative.

Sedimentation

Past actions including grazing, fires, fire exclusion, harvest, road construction, road obliteration and 

recreation have occurred in the project area. Plant species composition and ground cover have 

changed and invasive plant species are present. 

Effects to water quality are directly linked to water yield. If erosion from a road or upslope treatment 

does not enter into a waterbody, there would be no effect to water quality. Sediment transport occurs 
Final Environmental Impact Statement

Pomeroy Ranger District 149

primarily during spring runoff. For more information on sedimentation, see the Hydrology and Soils 

Reports. 

Temporary roads would be decommissioned after use. Decommissioning would reduce sediment

potential and help restore infiltration capacity. Decommissioning may include blocking, 

ripping/scarifying, seeding, and possible mulching with emphasis to improve hydrologic soil 

function. BMP monitoring of decommissioned temporary roads would be performed to help ensure 

resultant erosion is reduced to background levels. 

No cumulative sediment effects are expected because design criteria and BMPs shape the actions 

proposed in this project such that no measurable sediment is expected to reach surface waters. See 

also the Soils Report. 

Large Woody Debris

Historic logging in the riparian areas likely affected large wood recruitment in watershed streams. 

Dispersed recreation may have impacted and could still impact in-stream large wood and potential 

recruitment. Recreational impacts would come in the form of firewood cutters and campers utilizing 

wood from within the riparian areas.

The felling of hazard trees within the RHCAs would increase the amount of wood at the reach scale 

but may not be measureable at the watershed scale.

No cumulative large woody debris effects are expected because design criteria and BMPs shape the 

actions proposed in this project such that no measurable impacts are expected. 

Pools/mile

Historic logging and recreational impacts likely affected pools/mile over time by reducing the amount 

of large wood available for recruitment. This has led to a reduction in stream channel roughness, bed 

scour and in-channel deposition. 

This alternative is not expected to have any direct or indirect effects on pools and therefore would

have no cumulative effects. 

Width/Depth ratio

Historic logging and recreational impacts likely affected width/depth ratio over time by reducing the 

amount of large wood available for recruitment. This has led to a reduction in stream channel

roughness and in-channel deposition. 

This alternative is not expected to have any direct or indirect effects on channel morphology and 

therefore would have no cumulative effects. 

Alternative C

Cumulative effects under this alternative would be the same as those described in Alternative B.

Irreversible and Irretrievable Commitment of Resources

For all action alternatives (B and C) there would be no irreversible or irretrievable commitment of 

resources with implementation of proposed activities.

Final Environmental Impact Statement

Pomeroy Ranger District 151

3.10 Hydrology 

A summary of the current conditions of the affected environment and the predicted effects of the 

Proposed Action and its alternatives are discussed in this section. Specific information on the 

methodologies, assumptions, and limitations of analysis and other details are contained in the Sunrise 

hydrology specialist’s report, incorporated herein by reference, and available to the public on the 

project webpage at http://www.fs.fed.us/nepa/fs-usda-pop.php/?project=45689. 

Introduction

As the action alternatives consist of commercial timber harvest, commercial and non-commercial 

thinning, prescribed burns – and each will utilize system and temporary roads, the effects to

hydrological functions is of utmost importance to the project analysis. 

Regulatory Framework

Land and Resource Management Plan

The Umatilla National Forest Land and Resource Management Plan (LRMP) provides standards and 

guidelines as shown in Appendix C. Implementation of design criteria and best management practices

as described above, Umatilla National Forest Road Use Rules, as well as standard Umatilla NF timber 

sale contract specifications or the corresponding stewardship contract specifications would constitute 

compliance with the Umatilla National Forest Land and Resource Management Plan for hydrologic 

and water quality components.

Compliance with LRMP and Other Relevant Laws, Regulations, Policies and Plans 

Clean Water Act of 1972 

The Clean Water Act of 1972 and amendments require the restoration and maintenance of the 

chemical, physical, and biological integrity of the nation’s waters. All of the activities proposed in 

this project were designed to be consistent with the Clean Water Act and State of Washington Water 

Quality Standards.

Floodplains, Executive Order 11988

E.O. 11988 requires the Forest Service to avoid “to the extent possible the long and short term 

adverse impacts associated with the ... occupation ... or modification of floodplains...” The E.O. also 

provides direction to restore and preserve the natural and beneficial values served by floodplains. 

Actions proposed in the Sunrise Project would preserve the beneficial values of floodplains within the 

project area and for this reason, the Sunrise Project is consistent with this EO. 

Wetlands, Executive Order 11990

E.O. 11990 requires the Forest Service to "avoid to the extent possible the long and short term 

adverse impacts associated with the destruction or modification of wetlands." The Sunrise Project 

does not propose to destroy or modify any wetland. For this reason, the Sunrise Project is consistent 

with this EO. 
Sunrise Vegetation and Fuels Project

152 Umatilla National Forest

Municipal Watersheds

There are no designated municipal watersheds in the Sunrise Project area. 

Methodology

Analysis indicators used to summarize past, present, and future conditions include road density, 

location and road-stream crossings. These parameters represent the potential for increased drainage 

efficiency (rate of runoff) from roads compared to the unroaded condition. Roads that intersect or 

parallel streams may extend channel networks, contribute polluted runoff directly to streams, and alter 

shade and temperature conditions. 

Continuous recording thermographs have been deployed in several streams in and downstream of the 

project area. The WEPP Model (Flanagan and Livingston 1995) is a physically-based soil erosion

model that can provide estimates of soil erosion and sediment yield by considering the specific soil, 

climate, ground cover, topographic condition, and management activity. The Disturbed WEPP module 

was used by the Forest soil scientist to model hillslope erosion due to vegetation treatments and 

burning (see Soils Report). The WEPP Road module was used to compare road-derived sediment 

among alternatives (Elliot et al 1999b). 

A method commonly used to evaluate harvest effects on water yield and peak flow is the Equivalent 

Clearcut Acre (ECA) analysis (King 1989). A procedure was developed for the Umatilla National 

Forest as part of Endangered Species Act consultation (Ager and Clifton 2005). ECAs were calculated 

following the Umatilla National Forest protocol to determine existing levels of harvest and estimate 

potential water yield and peak flow effects in the analysis area. Percent ECA measures the extent of 

created openings and is used as an indirect measure of the hydrological effects (increases in water 

yield and peak flow) of vegetation alteration. The procedure to determine percent ECA includes 

harvest method and vegetative recovery rates developed for the Blue Mountains. Roads are included 

in the calculation of ECA as part of this analysis. 

The ECA model accounts for changes in the forest canopy caused by past timber harvest, fires, insect 

infestations, and road construction. Effects of actions and events are pro-rated over time to model 

their recovery on the ground. The ECA model assumes that disturbances which remove certain 

percentages of basal area recover hydrologically over certain periods of time, depending on the plant 

associations. Model results should be considered relative values only (not absolute predictions) for 

purposes of comparing background and activity effects. Actual conditions and activities are more 

complex than those used to make model estimates. The ECA model assumes that project 

implementation would occur in the same year, and be completed by the end of 2018. This assumption 

affects the timing of the response indicator of the ECA. In actual practice, the activities would be 

likely take approximately 5 to 10 years to fully implement. However, the assumptions and 

simplifications provide a reasonable analysis and estimation of project effects for purposes of 

comparing relative differences with and without activities and between alternatives. 

Affected Environment

The hydrologic system and the hydrologic effects of proposed actions will be analyzed for National 

Forest System (NFS) lands by the 12 digit Hydrologic Unit Code (HUC), also known as a 

subwatershed (SWS). HUC is a national level interagency map of the hydrologic system. Table 51

shows examples of HUC codes. Cumulative effect indicators including Equivalent Clearcut Area 

(ECA) are reported by HUC 12. Effects to water quality are based on the stream reaches identified by 
Final Environmental Impact Statement

Pomeroy Ranger District 153

Washington Department of Ecology (WDOE). WDOE designates beneficial uses of water resources 

and establishes water quality standards protective of those uses. 

The Sunrise analysis area contains about 32,000 acres of National Forest Service (NFS) lands located 

in portions of eight subwatersheds and Figure 3-11 shows the two main subwatersheds of the analysis 

area.

Table 51. Subwatersheds within the Sunrise project area.

Subwatershed

(HUC12)

SWS Name SWS 

acres

NFS acres in 

SWS

Project Acres in 

SWS

% Project Area in 

SWS

170601030201 North Fork Asotin Creek 28,163 25,007 24,822 88%

170601030202 Lick Creek 12,342 8,231 6,567 53%

170601030203 South Fork Asotin Creek 25,794 11,961 222 0.9%

170601030204 Charley Creek 14,403 9,277 218 1.5%

170601060310 First Creek 13,576 13,576 18 0.1%

170601060704 Menatchee Creek 21,079 16,563 36 0.2%

170601070501 Headwaters Pataha Creek 18,320 8,906 19 0.1%

170601070601 Headwaters Tucannon River 24,508 24,508 96 0.4%

Figure 3-11. Subwatersheds within the Sunrise project area.
Sunrise Vegetation and Fuels Project

154 Umatilla National Forest

Resource Indicators and Measures

Treatment alternatives will be evaluated based on their effect to hydrologic function and condition, 

water quality, and water yield. Indicators used to analyze effects of proposed actions are as follows: 

Hydrologic Function, Floodplains and Wetlands: 

• road density (mi/mi2

)

• roads in RHCAs (mi)

• road-stream crossings (number)

Water Quality:

• water temperature

• sediment

Water Yield: 

• Equivalent Clearcut Area (ECA < 20%)

• road density (mi/mi2

)

Existing Condition and Regulatory Framework

Elevations in the Sunrise planning area range from about 2,400 feet where North Fork Asotin leaves 

NSF lands to about 6,000 feet along ridge tops near Forest Road 40. The increase in elevation from 

this uplift caused streams to cut down and form very steep, and generally narrow, V-shaped canyons. 

The area is drained by the North Fork Asotin Creek and Lick Creek, which generally flow from the 

Southwest to Northeast. Numerous springs and seeps occur, predominantly in headwater areas. 

Annual precipitation ranges from about 20 inches per year at lower elevations to 40 inches per year at 

the highest elevations. Most of the annual precipitation falls between November and May and much 

of the winter’s precipitation occurs as snow.

Hydrologic Function and Condition

The mapped stream system in the Sunrise Project area includes 49 miles of perennial streams, 62 

miles of intermittent streams and 3 miles of streams with a discontinuous flow regime. These streams 

represent the channeled system. The analysis area also contains numerous unchanneled ephemeral 

draws, with 121 miles mapped in GIS.

Floodplain Function (Executive Order 11988)

Executive Order 11988 is applicable to those Federal actions which will occur in or which will impact 

upon flood prone areas, which includes portions of Lick Creek. The order requires agencies to take 

action to reduce the risk of flood loss and minimize the impact of floods, as well as preserve the 

values served by floodplains. Each agency has a responsibility to evaluate the potential effects of any 

actions it may take in a floodplain. Most of these effects occurred downstream of the Forest boundary 

where the stream flows through deeper sediments and where the stream is confined in the valley 

bottom along FR40. A floodplain is present and developing, but is narrower and less complex than 

historically, due to channel incision and lack of large wood.

Wetlands (Executive Order 11990) and Groundwater Dependent Ecosystems (GDE)

Executive Order 11990 requires agencies to take action to minimize the destruction, loss or 

degradation of wetlands, and to preserve and enhance the natural and beneficial values of wetlands. 
Final Environmental Impact Statement

Pomeroy Ranger District 155

The US Fish and Wildlife Service National Wetlands Inventory identifies 345 acres of riverine 

wetlands in the two project watersheds.

Table 52. Sunrise Riverine Wetlands Summary of Total Acres (Acres of National Forest Lands within 

Project Area)

Subwatershed Total Subwatershed Acres (Acres Within Project Area)

Lick Creek 108 (82 within project area)

NF Asotin Creek 263 (263)

Total 371 (345)

Water Quality

The Clean Water Act (CWA) as statute requires both State and Federal agencies to develop standards 

for water quality. The State of Washington and the Forest Service developed a Memorandum of

Agreement (MOA) defining each entities responsibilities for compliance with the CWA. The MOA 

designates the Forest Service as the management agency responsible for meeting the Clean Water Act 

on NFS lands and recognizes best management practices (BMPs) as the primary mechanism to 

control nonpoint source pollution on NFS lands.

Water quality standards are based on life stages of fish and the most restrictive need sets the standard. 

Water temperature and sediment are the main water quality parameters related to the proposed action 

(Table 53). 

Table 53. Water Quality Standards for Temperature and Sediment

Water Body Aquatic Life Uses Temperature Turbidity

Lick Creek and tributaries Core Summer Habitat 16oC (60.8oF) Not to exceed 5 NTU over 

background OR < 10% increase 

when background > 50 NTU

North Fork Asotin Creek and 

tributaries

Char Spawning and 

Rearing 12oC (53.6oF)

Water Temperature

The MOA designates the Forest Service as the management agency responsible for meeting the Clean 

Water Act on NFS lands and recognizes best management practices (BMPs) as the primary 

mechanism to control nonpoint source pollution on NFS lands.

Lick Creek has exceeded the temperature standard 3 of 18 years and nearly all data collected from the 

North Fork Asotin Creek on the Umatilla National Forest have exceeded the bull trout standard.

Sediment

Sediment mobilized from hillslopes and roads may be stored in channels for years or delivered into a 

stream within a season depending on precipitation patterns. Suspended sediment yield measured in 

the High Ridge Evaluation Area of the Umatilla Barometer Watershed (located about 40 miles 

southwest of the Sunrise Project) had a 12-year (1984-95) average annual yield of 19 tons/mi2 (range

3 – 43) for the control (unlogged) catchment, with high inter-annual variability (Helvey and Fowler 

1995). Sediment transport during spring snowmelt was the dominant transport process, although rainon-snow events produced some of the largest single event volumes.

The Lick Creek Demonstration project monitored hillslope erosion effects from prescribed burning, 

mechanical harvest and mechanical fuels treatments from 2002-2005 (Wondzell and Clifton 2005; 

Zamora and Martin 2006). Background hillslope erosion was very low (< 2 tons/mi2) which 

suggested a low amount of sediment was delivered to valley floors and into streams. The Lick Creek 
Sunrise Vegetation and Fuels Project

156 Umatilla National Forest

Demonstration Project only collected four years of data, so other long-term studies, such as the High 

Ridge study, may provide more accurate background levels for analysis.

Roads

The road system within the Lick Creek and North Fork Asotin Creek subwatersheds contain about 

124 miles of open, closed and decommissioned routes (Table 54). Routes on FS lands include 4.6 

miles of maintenance level (ML) 4 roads, 17.3 miles of ML 3 roads, 37.8 miles of ML 2 roads and 

38.9 miles of ML 1 (closed) roads. Crushed aggregate has been applied to about 55 miles of road 

surface. The North-South ATV trail has about 5.5 miles in the project area and occurs on about 4 

miles of non-system routes and about a mile of open and closed roads. WEPP modelling of all roads 

within the Sunrise project area estimates that erosion from road surfaces entering into stream channels 

is currently 1.5 tons of sediment per year from 58 crossings (Hydrology resource specialist report). 

The road system within the North Fork Asotin subwatershed occurs predominantly in upland areas 

and only enters into RHCAs at road-stream crossings. About 64% of the road crossings are on native 

surface roads and most of these (39 of 47) occur on Class IV or V (unchanneled) streams. The 

sediment transport rate from road surfaces at stream crossings using the WEPP model (Elliot et al 

1999a) calculated that the current road system is adding < 1 ton per year of sediment in the North 

Fork Asotin Creek and Lick Creek subwatersheds. 

Road density is used as an indicator of potential for affects to hydrologic function (extension of the 

stream network) and water quality (sediment delivery to surface waters). Stream crossings are used as 

an indicator of the degree of connectivity between the road system and the drainage network.

Table 54. Road Density and Stream Crossings on NFS Lands at the Subwatershed Scale

Subwatershed NFS 

(mi2)

System Roads (mi, 

open and closed)

Road Density 

(mi/mi2)

Decommissioned 

Roads (mi)

Stream 

Crossings

Lick Creek 12.8 23.8 1.9 31.7 35

NF Asotin Creek 39.1 62.4* 1.6 5.8 23

Both SWS have few miles of road in RHCA. Most of the stream-road intersections are ephemeral or 

intermittent crossings. Field reconnaissance from 2014-2016 found that > 80% of the formally 

decommissioned roads are effectively closed to motorized use. 

Within the project area, the higher RHCA road densities (Table 55) are the result of geomorphic 

constraints, with most roads located on ridgetops, rather than steep hillslopes and deep canyon 

bottoms. Roads selected for decommissioning were mostly located on steep hillslopes or near valley 

bottoms where the risk for erosion and sedimentation were the highest. 

Table 55. RHCA Road Interactions within the project area

SWS Name RHCA

(mi2)

Open Road 

Miles w/in 

RHCAs

RHCA Road 

Density 

(mi/mi2)

Road Miles 

Decommissioned

Stream- Road 

Intersections (open 

roads)

Lick Creek 0.9 4.6 5.1 4.4 26

NF Asotin Creek 5.2 3.1 2.7 0.3 20

Total 7.7 4.7 46

Grazing

In the Sunrise Project area, the Peola Allotment has 37 stock ponds and 5 spring developments in 

Lick Creek and 4 stock ponds and 3 spring developments in North Fork Asotin subwatersheds. There 
Final Environmental Impact Statement

Pomeroy Ranger District 157

are 5 stock ponds and 2 spring developments in the North Fork Asotin Creek subwatershed in the 

Asotin Allotment. The ungrazed portion of the Sunrise Analysis area has 3 old stock ponds and 3 

spring developments in the North Fork Asotin Creek subwatershed. Livestock are trailed along roads 

in the RHCAs of Lick Creek, Dry Fork Lick Creek and Sheep Gulch in the Peola Allotment. Lick 

Creek is fenced near the mouth of Dry Fork Lick Creek to prevent livestock effects to the streambank 

and near bank vegetation. 

Water Yield

McCammon (1993) assigned risk to watersheds from changes in cover and evapotranspiration as low 

(< 15%), moderate (15 – 30%) and high (> 30%). Reviews of literature demonstrate that the 

relationship is highly variable (Stednick 1995 and Scherer 2001). Generally effects are not seen below 

20% ECA and in a local study effects were not seen below 50% ECA (Helvey and Folwer 1995). 

Grant et al (2008) reported that increased peakflows could occur at >20% ECA and that the potential 

for effects to channel morphology is in the 5-10 year recurrence interval flow ranges. 

Subwatersheds in the planning area are below the 15% threshold of concern established by NMFS 

and the 20% threshold for hydrologic effects. Based on model assumptions, management induced 

changes in water yield, timing of flow, or peak flow are currently negligible. 

Prescribed Burning

Troendle et al (2010) summarized the hydrological effects of prescribed fire, which are largely a 

function of fire severity and area burned. Fires are typically set during times when flame lengths are 

expected to be low, fire residence times short and soil heating expected to be low. Because the low 

severity of prescribed fires do not cause a high degree of mortality or litter combustion, the effects to 

overstory canopy, evapotranspiration and forest floor water storage are generally too small to 

measurably change shade or watershed-scale water yields.

Environmental Consequences

Direct and Indirect Effects

Alternative A (No Action)

The ecological processes described would continue on the current trajectory unless a large-scale 

disturbance such as a high severity fire or high intensity rainfall or rain-on-snow event occurs within 

the project area. 

Hydrologic Function

No change to the existing road system would occur under this alternative. Road density, proximity to 

channels and number and location of stream crossings would remain the same. Few of the analysis 

area roads have regular maintenance. FR44 (Smoothing Iron Road) was improved in 2014 for log 

haul from South George timber sale units and FR41 (Lick Creek Road) was resurfaced in 2017. 

Unauthorized ATV use on some closed, decommissioned and non-system roads would continue to 

inhibit vegetation re-establishment, reduce infiltration rates and increase the potential for runoff. 
Sunrise Vegetation and Fuels Project

158 Umatilla National Forest

Floodplains

There would be no direct or indirect effects to floodplain function because this alternative would not 

change water yield, peak flows or sediment regime, thus current levels of channel stability and 

morphology would not be altered. 

Wetlands and GDEs

Alternative A does not propose new ground disturbing activities in stream- or spring-associated 

wetlands; therefore, there would be no direct or indirect effects to wetlands or GDEs as a result of this 

alternative. 

Water Quality

Water Temperature

Alternative A would continue with passive RHCA management, which is to allow the current rate of 

succession without intentionally altering species density or composition. Water temperature would 

improve slowly over time as near channel vegetation grows and provides more shade. The magnitude 

of this change is unknown and related to the degree that shade currently departs from site potential. 

Temperature standards in Lick Creek may be exceeded in years with warmer summers and low 

snowpack winters. Water temperature in North Fork Asotin Creek would continue to exceed state 

standard for bull trout, as evidenced by past monitoring. 

Disturbance events such as fires and floods could reverse this trend in vegetation. The time frame for 

shade and water temperature improvement is long, related to the growth rate of site potential

vegetation, which in the case of overstory canopy would take decades to regrow. 

Sediment

Modelling by the soil scientist indicates that current rates of sedimentation from hillslopes are low 

(0.03 tons/acre or < 19 tons/mi2

). Road-related modelling by the hydrologist indicates that the road 

system is contributing sediment at rates considerably lower than background estimates (< 2 tons total) 

and this would continue to be an ongoing sediment source. Natural disturbance regimes such as fires 

and floods would be the dominant sediment risks for the future, as indicated by sediment modelling 

based on expected fire behavior (see Fuels Report). Research has shown that elevated sedimentation 

could be expected for up to five years post-fire.

MacDonald and Sosa-Perez (2017) found that 15 months after burning 100% of the road segments in 

areas burned at high and moderate severity were connected to streams, even though the mean stream 

distance was > 200 feet away from a stream, whereas, pre-fire only about 15% of roads were 

hydrologically connected to streams. 

Water Yield

No change to the existing road system would occur under this alternative. Road density and number 

and location of stream crossings would remain the same. Therefore, drainage patterns would remain 

unchanged and there would be no effect to water yield. Alternatives B and C

Floodplains

There would be no direct effects from timber harvest activities on floodplain function because no new 

roads would be constructed in floodplains and landings and skidding would not occur in floodplains. 

Previously approved prescribed fire projects would proceed under the No Action alternative. 

Prescribed fire ignition for landscape prescribed fire or activity fuel treatments would not occur inside 
Final Environmental Impact Statement

Pomeroy Ranger District 159

RHCAs but fire would be allowed to back into RHCAs. The high level of moisture would lessen fire 

severity in these areas. 

There would be no indirect effects to floodplain function because this alternative would not change 

water yield, peak flows or sediment regime, thus current levels of channel stability and morphology 

would not be altered.

Wetlands

Alternatives do not propose new ground disturbing activities in stream- or spring-associated wetlands

during harvest and thinning operations and these areas would be protected by PACFISH RHCA

buffers. Implementation of prescribed fire operations would include no ignition zones within 100 feet 

of springs and other perennial wetlands < 1 acre in size and 150 feet for wetlands > 1 acre. 

Subsequent erosion and sedimentation are expected to be minor. There would be no indirect effects to 

wetlands or groundwater dependent ecosystems as a result of this alternative because these areas 

would burn with none to low soil burn severity and vegetative recovery would occur rapidly and 

hydrologic function would not be altered. 

Water Quality

Current policies, regulations, BMPs, and adaptive management techniques are expected to minimize 

unwanted sedimentation from forestry related activities.

Water Temperature

With peak stream temperatures occurring in July and August, summer stream temperature increases 

due to removal of riparian vegetation are well documented and have led to development of best 

management practices to protect shade. 

Proposed harvest/thinning and associated activity fuels treatments would not occur inside of interim 

PACFISH RHCAs, therefore the canopy density in RHCAs and shading would be maintained along 

all perennial streams. Because shade would not be changed, water temperature changes due to 

increased solar loading would not occur from this project. 

Landscape Prescribed Fire

Proposed landscape burning is included in action alternatives totaling approximately 14,060 acres 

(11,000 acres forested and 3,000 acres grassland). Several of the project design criteria are prescribed 

to limit the intensity of the fire (see Fuels Report). Fire intensities would be kept low via the 

prescription. Short head fire runs may occur, as well as individual tree and group torching in areas 

where there are sufficient ladder fuels, and in timber stands with high occurrences of mistletoe 

infected trees. 

The 14,060 acres proposed for prescribed burning are divided into four landscape prescribed fire

areas. These four areas would be divided further into burn blocks and may take multiple prescribed 

fire entries over multiple years to complete. 

No created openings are expected to occur in RHCAs of perennial and fish-bearing streams. Shade 

and therefore effects to water temperature from landscape burning at near natural rates would be 

protected. 
Sunrise Vegetation and Fuels Project

160 Umatilla National Forest

Danger Tree Removal

Danger trees would be felled along all haul routes used in the proposed timber sales. They would be 

left on the ground inside RHCAs and commercially removed elsewhere. Most stream crossings on 

haul routes are ephemeral or intermittent with no or very low summer flows. Danger trees felled on 

haul routes within RHCAs of perennial streams would have negligible effect on shade density for 

affected streams. 

Sediment

Silvicultural ground disturbing activities which may result in runoff include harvesting operations, 

road maintenance, construction and use, mechanical site preparation and prescribed fire. Potential 

downstream effects are increased where these activities impinge on unchanneled swales or low order 

stream channels. 

Effects to sedimentation are expected to be limited when best management practices (BMPs) and 

other design criteria are implemented.

Non-Commercial Hand Thinning

Noncommercial hand thinning is planned for 1,677 and there would be no ground disturbance and 

therefore no erosion or sediment from this activity.

Harvest and Treatments

Design criteria for each action would include no-harvest within interim PACFISH RHCAs. These 

design criteria would prevent damage that could contribute to erosion and sedimentation into channels 

and streams (Belt et al, 1992). Minimal detrimental soil acres would occur in RHCAs and haul road 

effects would be mitigated when design criteria are implemented and landings would occur outside of 

the RHCAs. Refer to the Soils Report for discussion of logging and mastication systems effects to 

ground cover and soil stability. 

Heavy equipment trails have the potential to impact ephemeral streams by introducing fine sediment. 

The trails may also capture the ephemeral flows, and begin to function as Class IV streams. 

Ephemeral streams are protected from these impacts by design criteria. Sites would be chosen to 

avoid, minimize or mitigate potential for erosion and sediment delivery to nearby. 

Landscape and Prescribed Fuels Reduction Burning

This treatment would reintroduce fire to a fire-dependent ecosystem, lessening the effects of a future 

uncharacteristic wildfire and improve forage quality for big game. Fire intensities would be kept low, 

by establishing backing fires to minimize fire in the canopy, and burning mainly surface fuels

throughout the majority of the project area. Individual tree and group torching would likely occur in 

areas where there are sufficient ladder fuels, and in timber stands with high occurrences of mistletoe 

infected trees.

The Pomeroy Ranger District has been conducting prescribed burns for decades. Fuels management

activities would be designed and executed to maintain or enhance fish and wildlife habitat within the 

Forest Plan Standards and Guidelines of 10% mineral soils and 80% stream surface shading (Forest 

Plan, C5, pg. 4-166). This will be accomplished by incorporating design criteria identified in Chapter 

2. All burning operations are conducted in accordance with a detailed Burn Plan. Proposed prescribed 

burning in the North Fork Asotin Creek and Lick Creek subwatersheds alone would not increase ECA 

above threshold values and therefore, would not cause detectable changes in water yield, peak flows 

or base flows. 
Final Environmental Impact Statement

Pomeroy Ranger District 161

Haul Roads

Maintenance, reconstruction and construction would be performed using standard specifications to 

accomplish surface blading, hazard tree removal, construction of drainage dips or water bars, dust 

abatement with water, surface rock placement, roadside brushing, ditch cleanout, culvert maintenance 

or removal and replacement, road surface shaping and draining, surface material processing and 

erosion control. BMPs, design criteria and applicable road maintenance specifications are contained 

in EM-7730-20. 

Temporary roads are constructed on stable soils and are intended for project use only. To minimize 

impacts to soil and water resources, pre-existing temporary road alignments and alignments of 

previously decommissioned system roads would be used. New temporary roads are proposed to 

access landings where existing system roads or existing alignments are not adequate. After use, newly 

constructed temporary roads would be obliterated by reestablishing former drainage patterns or 

natural contours, installing waterbars (if needed), removing gravel surfacing, decompacting road 

surfaces, pulling back unstable fill slopes or shoulders, scattering slash on the roadbed, applying 

erosion control much, seeding disturbed areas and blocking or disguising the former road entrance to 

prevent motorized vehicle traffic. 

Danger Tree Removal

This activity would occur along haul routes. Danger trees felled inside RHCAs would be left on the 

ground and no ground disturbance would occur. Removal of danger trees outside of RHCAs could 

lead to ground disturbance as equipment traveled off road or trees were winched to the road. Slope 

distances would be short and erosion and sedimentation would be unlikely. 

Direct and Indirect Effects

Alternative B 

The direct effects of implementing the Alternative B would be the removal of 26.5 MBF of timber 

from 5,520 acres (including development of skid trails, landings and 13.7 miles of temporary road) 

and pre-commercial thinning (hand and mastication) an additional 2,270 acres. Treatment of activity 

fuels would include mastication, lop and scatter, hand piling, grapple piling, pile burning, jackpot 

burning and/or broadcast burning. Prescribed fire is proposed for 14,055 acres of forest and grassland.

Hydrologic Function

The existing road system would not change in Alternative B (no new roads are proposed and the 

project would not decommission any National Forest System roads) and temporary road construction 

would be located and managed such that there would be no effect to the drainage network. Road 

maintenance would occur on up to 90 miles of system roads used by timber sales and would include 

blading, ditch relief culvert cleanout, spot rock and ditch cleanout as needed (see Transportation 

Report). Culvert cleanout and necessary ditch cleanout would lead to immediate reductions in risk 

from the road system. Detrimental effects from ditch cleanout would be short term, less than one year. 

Closed roads would be left in a self-maintaining condition. 

Access to units 120 and 190 via FR4027016 would require 3 culverts to be installed in Class IV 

streams and access to units 71 and 216 via FR4000224 would require 1 culvert to be installed on a 

Class IV stream. The original culverts were removed when the roads were closed. The culverts would 

be appropriately sized per standard engineering design. Per BMPs, road reconstruction and culvert 
Sunrise Vegetation and Fuels Project

162 Umatilla National Forest

installation would occur under dry conditions and no disturbance would occur outside of the existing 

footprint. Culverts would be removed and embankments stabilized by seeding and mulching after

completion of silvicultural treatments. 

Alternative B would require the construction of 13.7 miles of temporary roads to access vegetation 

treatment units in the North Fork Asotin Creek subwatershed and road density would temporarily 

increase from 1.6 to 1.9 mi/mi2 until these roads are decommissioned. No temporary roads would 

occur in RHCAs and using McCammon (1993) as a guide, road densities < 3 mi/mi2 would constitute 

a low risk to detrimental effects to hydrologic function. No effect to watershed function would occur.

Road density in the Lick Creek subwatershed would not change because no temporary roads are 

proposed under Alternative B, and there would be no direct or indirect effects to hydrologic function

in Lick Creek subwatershed. 

Floodplains

Alternative B requires the installation of four culverts. Culverts would be re-installed in previous 

locations, then removed after completion of silvicultural treatments, hence there would be no new 

disturbance to floodplains. 

Water Temperature

Alternative B would not adversely affect water temperature because harvest, thinning and burning 

would not measurably remove the shade component along any stream channel. Because there would 

be no change to shade, there would be no adverse effect to beneficial uses and no effect on the 303(d) 

listing status of streams. In addition, no adverse changes to channel condition from silvicultural 

treatments are predicted because water yield and peak flow would not be affected, therefore, 

morphological channel changes which could affect stream temperature would not occur. 

Sediment

Harvest and Fuels Treatments

Harvest, thinning and prescribed burning would produce lower short and long term sedimentation 

rates than a higher severity wildfire based on WEPP model runs and assumed background levels (see 

Soils Report). In addition, the longer term benefit of treatments would be to reduce the severity of 

future wildfires commensurate with changes to desired fire regime condition classes (see Fuels 

Report), which would result in lower erosion and sedimentation rates. This effect is expected to last 

for decades because of the reduced fuel loading from proposed treatments. 

Based on the Lick Creek study, effective ground cover would remain within Forest Plan standards 

during and after treatments and ground cover is expected to recover to pre-activity levels within 2 

years. Therefore, any potential increase in hillslope erosion and sedimentation would return to 

background levels within this time frame. There would be a low risk of sediment entering into stream 

channels when design criteria are implemented. 

Roads

Approximately 13.7 miles of temporary road construction is proposed in Alternative B in the North 

Fork Asotin Creek Subwatershed. 5.8 miles or temporary road would occur on previously disturbed 

areas (old roads or skid trails). Associated with 5 road segments are 6 areas where these roads would 

cross unchanneled swales. BMPs such as rock armor or corduroy log mats would be placed at draw 

bottom crossings to maintain the integrity of the ground surface during use. 
Final Environmental Impact Statement

Pomeroy Ranger District 163

Water Yield

All temporary roads would occur in upland areas, above the point on the landscape in which 

snowmelt or rainfall runoff enters into a defined channel. Stream density would remain in the low risk 

category and there would be no new road crossings that would extend the stream network farther into 

upland areas. There would be no changes to the road system in the Lick Creek subwatershed. As a 

result, there would be no measureable increase in streamflow at the subwatershed scale. Therefore 

there would be no direct or indirect effect to water yield or peak flows from these actions under this 

alternative. 

Alternative C

The direct effects of implementing Alternative C would be the removal of 12.1 MBF of timber from 

2,550 acres (including development of skid trails, landings and 8.4 miles of temporary road) and 

precommercially thinning an additional 2,270 acres. Treatment of activity fuels would include 

mastication, lop and scatter, hand piling, grapple piling, pile burning, jackpot burning and/or 

broadcast burning. Prescribed fire is proposed for 14,055 acres.

Hydrologic Function

The existing road system would not change in Alternative C (no new roads are proposed and the 

project would not decommission any National Forest System roads) and temporary road construction 

would be located and managed such that there would be no effect to the drainage network. 

Alternative C would require the construction of 8.4 miles of temporary roads to access vegetation 

treatment units in the North Fork Asotin Creek subwatershed and road density would temporarily 

increase from 1.6 to 1.8 mi/mi2 until these roads are decommissioned. No temporary roads would 

occur in RHCAs and using McCammon (1993) as a guide, road densities < 3 mi/mi2 would constitute 

a low risk to detrimental effects to hydrologic function. The road locations would be upslope of where 

channel formation has occurred in draw bottoms. Temporary roads would occur across 2 unchanneled 

ephemeral draws and design criteria would include rock or other armoring to prevent rutting and 

maintain ground cover. Cut and fill construction would be needed for about 2 miles of temporary 

roads. Decompaction, pulling of sidecast berms, recontouring where needed, revegetation and 

camouflaging of entranceways would be used to completely decommission these roads at the end of 

harvest. No effect to watershed function would occur.

Road density in the Lick Creek subwatershed would not change because no temporary roads are 

proposed under Alternative C, and there would be no direct or indirect effects to hydrologic function

in Lick Creek subwatershed. 

Water Temperature

Alternative C would not adversely affect water temperature because harvest, thinning and burning 

would not measurably remove the shade component along any stream channel. Because there would 

be no change to shade, there would be no adverse effect to beneficial uses and no effect on the 303(d) 

listing status of streams. In addition, no adverse changes to channel condition from silvicultural 

treatments are predicted because water yield and peak flow would not be.

Sediment

Harvest and Fuels Treatments

Effects in the Lick Creek subwatershed would be the same as Alternative B. Alternative C would treat 

approximately 2,970 acres less than Alternative B in the North Fork Asotin Creek subwatershed. 
Sunrise Vegetation and Fuels Project

164 Umatilla National Forest

Although the overall rate (tons/acre) of change in fire regime condition class and 

erosion/sedimentation are similar to Alternative B, the amount of sediment (tons) would be less 

because fewer acres are treated (see Soils Report). Initially, the potential sediment load from thinning

and mastication areas would be less than alternative B. However, the net long-term benefit of wildfire 

risk reduction would not be as much as alternative B because 1,700 fewer acres with moderate to high 

fire behavior would be treated under Alternative C. 

Roads

Approximately 8.4 miles of temporary road construction is proposed in Alternative C in the North 

Fork Asotin Creek Subwatershed. 3.6 miles or temporary road would occur on previously disturbed 

areas (old roads or skid trails). Associated with 2 road segments are 2 areas where these roads would 

cross unchanneled swales. BMPs such as rock armor or corduroy log mats would be placed at draw 

bottom crossings to maintain the integrity of the ground surface during use. 

Fuels Treatments and Landscape Prescribed Fire

The longer term benefit of treatments would be to reduce the severity of future wildfires 

commensurate with changes to desired condition classes, which would result in lower erosion and 

sedimentation rates. However, the net long-term benefit of wildfire risk reduction would not be as 

much as Alternative B. 

Water Yield

Alternative C would add 8.4 miles of temporary road in the North Fork Asotin Creek subwatershed 

and temporarily increase road density from 1.6 to 1.8 mi/mi2. Temporary roads would not occur in 

RHCAs. All temporary roads would occur in upland areas, above the point on the landscape in which 

snowmelt or rainfall runoff enters into a defined channel. Stream density would remain in the low risk 

category and there would be no new road crossings that would extend the stream network farther into 

upland areas. There would be no changes to the road system in the Lick Creek subwatershed. As a 

result, there would be no measureable increase in streamflow at the subwatershed scale. Therefore 

there would be no direct or indirect effect to water yield or peak flows from these actions under this 

alternative. 

Cumulative Effects Common to All Alternatives

Water Quality

Motor vehicle and recreational off road vehicle use would continue to occur on routes designated on 

the Umatilla National Forest motor vehicle use map (MVUM). Erosion and sedimentation from roads 

would continue. Continued deferred maintenance of the majority of system roads would be the 

primary management related sources of accelerated erosion. 

The current level of livestock use would continue and would be managed under the allotment

management plans and annual operating instructions which allows flexibility to meet resource 

objectives. Weeds treatment would continue to occur along roads and in areas identified on the 2017 

Planned Treatments Map (USFS 2017) and implementation would follow design features described in 

the Umatilla National Forest Weeds EIS (USFS 2010). Natural disturbance events such as fires and 

floods could affect stream temperature and sediment regimes over time, if these events cause largescale changes to vegetation or stream channel morphology. 
Final Environmental Impact Statement

Pomeroy Ranger District 165

The Asotin Prescribed Burn would occur on about 7,943 acres within the Sunrise Project area. Under 

the modeled wildfire scenario, there would be an additional 0.09 tons/acre from the Lick Creek 

subwatershed and 0.11 tons/acre from the North Fork Asotin subwatershed (see Soils Report). 

Cumulative Effects

Alternative A

Species composition and structural changes at the landscape scale described in the Silviculture Report 

would not occur by mechanical means, therefore succession would remain on its current trajectory 

further away from landscape scale range of variation. 

Water Quality

Stream temperatures would be unaffected under the No Action alternative. 

Road densities and road use designations would remain unchanged with the No Action alternative. 

Erosion and sedimentation from roads would continue as roads are used and maintained according to 

their respective maintenance level. 

Current levels of hillslope erosion are low and erosion from hillslopes is expected to be localized. 

Alternative A would not reduce the severity of wildfire, as described in the Fuels Report, and the 

effects wildfire are higher soil burn severity, loss of effective ground cover, increased soil exposure 

increasing the potential for hillslope erosion and potential failures. 

Floodplain Condition

The hydrologic function of streams in the project area would continue to recover from past harvest

within the limitations of past and present management (timber harvest and roads) and periodic high 

flow events. Large scale fire could affect water yield and peak flows, with resultant adverse effects to 

channel and riparian condition, with resultant loss of fish habitat.

Wetlands and Groundwater Dependent Ecosystems

The hydrologic function of stream-associated wetlands in the project area would continue to recover 

within the limitations of past and present management (timber harvest and roads) and periodic high 

flow events. The condition of seeps and springs in the project area would continue to be influenced by 

current livestock management, as summarized in the Range Report. 

Water Yield

Current ECA values for Lick Creek and North Fork Asotin Creek subwatersheds are low compared to 

threshold value of 20% and suggest that there is no measurable difference between current conditions 

and those with no harvest. Vegetative recovery through time would continue to reduce ECA values. 

Current values of ECA when added to the Asotin Prescribed Fire Project (Table 56) indicates that 

there would continue to be no measurable increase in water yield or peakflows. 

Table 56. Equivalent Clearcut Area Modeling Summary

Subwatershed Current ETA Asotin Rx Total ECA

Lick Creek 3.2% 4.2% 7.4%

NF Asotin Creek 1.5% 3.4% 4.9%
Sunrise Vegetation and Fuels Project

166 Umatilla National Forest

Cumulative Effects Common to All Action Alternatives

Water Quality

Temperature

Past actions, including road construction and timber harvest, affected overstory structure and, by 

default, shade which resulted in a higher exposure of surface water to solar radiation. In the 

alternatives, prescribed fire ignition would not occur within 600 feet of each side of fish-bearing 

streams in North Fork Asotin Creek subwatershed, 600 feet of each side of fish bearing streams in 

Lick Creek subwatershed, within 150 feet each side of perennial non-fish bearing streams, or within

100 feet of springs and other isolated wetlands. All alternatives would temporarily open roads for log 

haul in RHCAs with perennial streams. These activities would not remove any overstory shadeproducing trees, although understory hardwoods, such as alder would be cut. As described in Direct 

and Indirect Effects, shade would not be affected and there would be no affect to water temperature at 

the reach scale from the proposed project and so no mechanism for cumulative effects to water 

temperature.

Road construction and previous timber sale activities on Forest Service lands removed shadeproducing vegetation along portions of perennial streams. The last timber sales within what are now 

RHCAs occurred nearly 25 years ago. Occasional hazard trees are felled along roads within RHCAs 

and this activity has a negligible effect to shade. An exclosure fence was constructed on lower Lick 

Creek about 15 years ago to limit livestock access. Approximately 38 miles of roads have been 

decommissioned in the two subwatersheds during the past 20 years. Most of these roads are 

effectively closed to motor vehicles and are in the process of hydrologic and vegetative recovery. The 

combined effect of these activities has had a positive effect to shade-producing vegetation in RHCAs. 

Sediment

Past actions including grazing, fires, fire suppression, timber harvest, road construction, road 

obliteration and recreation have occurred in the project area. Plant species composition has changed 

and invasive plant species are present. Ground cover has been affected and the sediment regime has 

likely changed some unquantified amount through time, including ongoing actions. Sediment 

transport would continue to occur primarily during spring runoff. Effects to water quality are directly 

linked to water yield because, if erosion from a road or hillslope treatment does not enter into a 

waterbody, there would be no effect to water quality. 

Erosion resulting from prescribed burning is generally less than that resulting from roads, skid trails, 

and site preparation techniques that cause soil disturbance (Robichaud et al 2010). Robichaud et al 

(2010) also reported that sediment effects from fuel management activities generally return to predisturbance levels within 1 to 2 years. The Fuels Report describes predicted modification of fire 

behavior as a result of changes to fire regime condition class from vegetation management and fuels 

reduction projects in the Sunrise Project area. These actions, together with the Asotin Creek 

Prescribed Burn Project would provide long term beneficial effects to water quality because lower 

fire severity and intensity from future wildfires are expected to result in lower soil burn severity at the 

landscape scale (see Soils Report). 

Sediments are a major nonpoint-source pollution problem in forests, most often associated with forest 

roads (MacDonald and Stednick 2003). Direct and indirect effects to soil and watershed resources 

under proposed action would include short-term (hours to days) effects such as erosion and sediment

delivery resulting from removal of ground cover during construction of temporary roads and landings. 
Final Environmental Impact Statement

Pomeroy Ranger District 167

Approximately 38 miles of roads have been decommissioned in the two subwatersheds during the 

past 20 years. Most of these roads are effectively closed to motor vehicles and are in the process of 

hydrologic and vegetative recovery. FR41 along Lick Creek was resurfaced with crushed aggregate in 

2017 which has improved the running surface and stabilized the eroding subgrade material. An 

exclosure fence was constructed on lower Lick Creek about 15 years ago to limit livestock access to 

streambanks. The combined effect of these activities has had a positive effect to reducing hillslope 

and road-related sedimentation to streams. 

Temporary roads would be decommissioned as soon as feasible after use to reduce sediment potential 

and help restore infiltration capacity. Decommissioning would include a combination of the following 

to improve hydrologic soil function: recontouring, ripping/scarifying, seeding, mulching and blocking 

the entrance. The Forest Service policy for control of nonpoint sources of pollution is to use BMPs, 

monitor the implementation and effectiveness of those BMPs, and adjust management practices using 

monitoring results. 

All action alternatives would increase livestock distribution on the allotment by increasing access 

and/or increasing available forage for livestock. Management of livestock would improve with all 

action alternatives due to increased visibility and access for livestock herding and due to the short 

term increase in forage. An increase in distribution of livestock on the uplands could decrease the 

amount of use on riparian areas. Field reconnaissance in 2014 and 2016 indicates that there would 

continue to be a low risk of sediment transported downstream into Class I, II and III waters from 

livestock grazing. 

Floodplain Condition

Channel stability is the ability of a stream, over time, in the present climate, to transport the sediment

and flows produced by its watershed in such a manner that the stream maintains its dimension, pattern 

and profile without either aggrading or degrading (Rosgen 1996). Natural processes of floods and 

high severity wildland fire would occur, over time and the surrounding forest would continue to grow 

and trees would die and some would fall into streams. The result of these phenomena would result in 

changes to the stream shape and sediment dynamics. 

The Sunrise Project would not change the flow regime (water yield or peak flows) or sediment

regime, therefore there would be no cumulative effect to channel morphology from proposed 

silvicultural activities. Cumulative effects to floodplains would be not occur because temporary 

changes to road densities and stream crossings at the subwatershed scale of analysis are negligible 

and implementation of design criteria would not increase detrimental soil conditions above threshold 

amounts. 

Wetlands and GDEs

Ground disturbing activities would not occur in stream- or spring-associated wetlands as a result of 

the alternatives. Spring, seep and other wetland areas not previously identified and which are 

identified during unit layout would also be protected with no-skid buffers. Prescribed fire that burn 

near or across seeps, springs and other wetland areas would not permanently alter hydrologic 

properties associated with those features. Water developments for livestock are the main sources of 

hydrologic alteration to springs in the project area and there would be no additional adverse effects to 

these resources as a result of the Sunrise Project. 
Sunrise Vegetation and Fuels Project

168 Umatilla National Forest

Alternative B

Water Yield

Effects of past harvest and road building, proposed harvest, and landscape burning on water yield and 

peak flows were analyzed with ECA Model as described in the Existing Condition section of this 

report and the Hydrology Report. Based on the assumptions of the ECA model and the literature cited 

and assuming that vegetation and fuels treatments would occur over a several year time frame, the 

proposed harvest and landscape burning would not have a measurable effect to hydrologic functions 

(capture, storage, and release of water) in the North Fork Asotin Creek and Lick Creek subwatersheds 

when combined with the Asotin Prescribed Burn Project and other past vegetation treatments. 

Figure 3-12 shows how ECA would change over a ten year time frame under this scenario, with ECA 

remaining below the 20% threshold value for cumulative effects to water yield. 

Figure 3-12: Seven Year Implementation Schedule ECA

Alternative C

Water Yield

The same timber sale and prescribed fire scenario described for Alternative B were input into the ETA

model for Alternative C, which indicates that when treatments are implemented over the course of 

several years, rather than instantaneously, the ECA would remain below the 20% threshold value for 

cumulative effects to water yield for Lick Creek and NF Asotin Creek (see Figure 3-13).

0%

2%

4%

6%

8%

10%

12%

14%

16%

18%

2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028

NF Asotin...

Lick Creek
Final Environmental Impact Statement

Pomeroy Ranger District 169

Figure 3-13: Alternative C – Seven Year Implementation Schedule ECA

Project Design Criteria and Mitigation Measures

Implementation of actions proposed under the Sunrise project would include BMPs and project 

design criteria applicable to all action alternatives and these are listed in Appendix C and additional 

BMPs are identified in the Soils Report. 

Irreversible and Irretrievable Commitment of Resources

For all action alternatives (B and C) there would be no irreversible or irretrievable commitment of 

resources with implementation of proposed activities.

0%

2%

4%

6%

8%

10%

12%

14%

16%

18%

2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028

NF Asotin Creek

Lick Creek

Final Environmental Impact Statement

Pomeroy Ranger District 171

3.11 Soils

A summary of the current conditions of the affected environment and the predicted effects of the 

Proposed Action and its alternatives are discussed in this section. Specific information on the 

methodologies, assumptions, and limitations of analysis and other details are contained in the Sunrise 

soils specialist’s report, incorporated herein by reference, and available to the public on the project 

webpage at http://www.fs.fed.us/nepa/fs-usda-pop.php/?project=45689. 

Introduction

Soil is the vital link that connects so much to so many in a healthy forest ecosystem, and as such was 

chosen as a resource due additional analysis. 

Regulatory Framework

Land and Resource Management Plan

The Umatilla National Forest Land and Resource Management Plan (LRMP) provides standards and 

guidelines for all activities. 

The Desired Future Condition in the 1990 Forest Plan (LRMP) for water/soil is to maintain soil 

productivity (Forest Plan p. 4-9). The plan further states that Standards and Guidelines are to maintain 

a minimum of 80 percent of an activity area in a condition of acceptable productivity potential. 

Acceptable productivity is defined as:

• Less than 20% increase in bulk density of volcanic soil or a less than 15 percent increase in soil 

bulk density for other forest soils.

• Soil disturbance of less than 50 percent of the topsoil humus enriched A1 and or AC horizons from 

an area 100 sq. ft. (i.e. 5ft. by 20ft.)

o Molding of the soil in vehicle tracks that area rutted to a depth less than 6 inches.

• Severely burned soil with the top layer of mineral soil altered in color (usually to red) and the next 

1⁄2 inch blackened from organic matter charring.

• Plan and conduct land management activities so that soil loss from surface erosion and mass 

wasting, caused by activities will not result in an unacceptable reduction in soil productivity or 

water quality.

• Management activities shall be designed and implemented to retain sufficient ground vegetation 

and organic matter to maintain long-term soil and site productivity.

• Active slump and landslide area are considered unavailable for road construction. Areas with 

known landslide potential and lake sediments require special transportation planning and design, 

layout preconstruction, construction and maintenance techniques.

Federal Law

Multi-Use Sustainable Yield Act (1960)

The project with described mitigation and BMPs in place should be able to meet the intent and 

direction of the Sustained Yield Act. Sustained yield means achieving and maintaining into perpetuity 
Sunrise Vegetation and Fuels Project

172 Umatilla National Forest

a high-level annual or regular periodic output of renewable resources without impairment of the 

productivity of the land.

Clean Water Act

Project design features were developed for the protection and maintenance of soil productivity during 

and after the implementation of the Sunrise Project. Minimizing the risk of sedimentation as a result 

of large scale, high severity wildfire within the project area through the use of these design features to 

maintain soil stability would allow the Sunrise Project to meet the intent of the Clean Water Act.

Compliance with LRMP and Other Relevant Laws, Regulations, Policies and Plans 

For the proposed actions within this proposed project there would be 7 activity units under alternative

B and 5 activity units under alternative C expected to exceed DSC defined by the forest plan if project 

design features such as re-using existing skid trails and subsoiling are not implemented (see Soils 

report). Project design features were developed to allow needed vegetation management to occur in 

the Sunrise Project area while providing for restoration of soil productivity. 

The project with described mitigation and BMPs in place should be able to meet the intent and 

direction of the LRMP as it pertains to the soil resource. 

It is assumed that the project being able to meet LRMP and FSM will lead to a project that will be 

considered sustainable in the terms of the Sustained Yield Act.

Methodology

Remote Data – Soil Productivity (Erosion and Sediment) and Stability

First a query was done of the Terrestrial Ecosystem Unit Inventory soil survey data to determine the 

soil types present within the planning area. These soils have been previously mapped under contract 

with the Blue Mountain TEUI. This mapping is inspected by the Forest Service and NRCS as contract 

task orders are completed and the resulting survey is commensurate with NRCS county soil surveys. 

Some of the taxonomic information (texture, slope range, surface rock content) was used in the 

erosion analysis, along with estimated vegetation data. The erosion analysis was conducted to 

determine if the proposed activities would create a risk to either soil productivity (erosion) or water 

quality (sediment). Lastly the TEUI mapping was used to eliminate unstable locations. No units were 

altered by this stability analysis. 

The Water Erosion Prediction Project (WEPP, Elliott and Robichaud, 2001) has developed several 

modules that are used to estimate hillslope erosion and sedimentation: 

https://forest.moscowfsl.wsu.edu/fswepp/. WEPP simulates seasonal hydrology, surface hydrology 

and hydraulics, subsurface hydrology, vegetation growth and residue decomposition and sediment

detachment and transport from a hillslope using five major input variables: climate, slope, soil 

texture, rock content and management scenario. 

To evaluate erosion risk following a management action or wildfire, the model was run using a 

stochastic climate for 50 years of possible weather. The long term data were used to account for 

temporal variability of storm patterns occurring in different years. Average monthly precipitation data 

from the Spruce Springs SNOTEL site (located at the northwest corner of the project area) were 

manually entered into the climate model and adjusted slightly to represent an average precipitation 
Final Environmental Impact Statement

Pomeroy Ranger District 173

distribution in the upper North Fork Asotin Creek watershed, where most of the treatments would 

occur. A separate climate scenario was modelled for the lower elevation Lick Creek treatment units. 

The following activities were modelled: undisturbed forest, timber harvest with tractor logging, 

timber harvest with skyline logging, mastication fuels treatment, prescribed fire as a landscape burn, 

prescribed fire of activity fuels. Each activity affects ground cover and soil properties. In addition, 

low to high severity wildfire was modelled to estimate background hillslope sediment and evaluate 

effectiveness of proposed treatments at reducing sedimentation as a result of a wildfire burning under 

current fuel conditions (See Fuels Report for Modeling Summary). 

WEPP modeling included the range of slopes, soil textures and surface rock content characteristics 

identified in the TEU descriptions. This range of characteristics typify hillslopes that occur within or 

are contained by proposed treatment areas. WEPP uses two slope elements in the model. The upper 

slope element represents the disturbance activity (e.g. mechanical harvesting, mastication, burning), 

and a lower slope element which represents the sediment buffer to a waterway. The Soil report 

summarizes WEPP input variables and estimates of sedimentation (hillslope soil loss) due to groundbased yarding, skid trails, skyline yarding, and burn severity due to prescribed burning and wildland 

fire. 

Model results are summarized by the two major subwatersheds of the project area: Lick Creek and 

North Fork Asotin Creek. Approximately 249 treatment acres occur in 6 other subwatersheds (SWS): 

89 acres in the Charley Creek SWS, 5 acres in the First Creek SWS, 2 acres in the Headwaters Pataha 

Creek SWS, 50 acres in the headwaters Tucannon River SWS, 17 acres in the Menatchee Creek SWS 

and 86 acres in the South Fork Asotin Creek SWS. WEPP results for the North Fork Asotin Creek 

subwatershed would also be applicable to these treatment areas using the estimated erosion and 

sedimentation rate in tons/acre. 

Soil Productivity Influenced by Detrimental Soil Conditions (DSC)

Forest Plan standards and guidelines for management induced soil disturbance are described in terms 

of the amount of area of an activity unit (for example, a harvest unit) exceeding certain levels of 

effects to soil in degree and extent. Effects that are considered include compaction, displacement, 

rutting (puddling), and severe burning from prescribed fire. Changes from natural conditions from 

any permitted or management directed activity (e.g. livestock grazing) is included in assessments. 

Effects from compaction, displacement and puddling, in particular, tend to be persistent and last many 

years in this area. A study in central Idaho indicates that natural recovery of the soil may take 40 to 70 

years (Froehlich and McNabb 1983). 

The persistence of compacted soil over time, for example, determines its effect on stand response and 

the long-term effect on forest productivity. How long soils remain compacted is determined by natural 

recovery rates or tillage operations or both (Froehlich and McNabb 1983). As such, these effects from 

previous soil disturbing actions are often still observable. Not all soil disturbance is detrimental -

exceedance of certain threshold values triggers characterization of that disturbance as detrimental. For 

example, compaction is considered detrimental if bulk density is increased more than 20% for ash 

soils. 

Units were assessed for the extent and degree of previously impacted soil using aerial photo analysis, 

GIS mapping of prior harvest activities and field observation starting in the fall of 2014. Units with 

prior harvest history and the likelihood for greater existing effects were evaluated by the Forest Soil 

Scientist for quantitative assessment relative to Forest Plan standards and guidelines for detrimental 
Sunrise Vegetation and Fuels Project

174 Umatilla National Forest

soil condition. An estimate of DSC as a percentage of the areas was assigned for each activity unit to 

provide a consistent tracking measure. 

Potential effects to soil productivity would be created by the equipment used and methods employed 

to implement this project. Skid trails are pathways used to transport trees, logs, and other forest 

products from the forest to a deck, landing or roadside. Skid trails are usually for temporary use and 

may be used only once or equipment may make many passes. If they are not planned, constructed or 

used correctly or rehabbed when needed, skid trails can have long-lasting effects on soil productivity 

and water quality. Landings are locations where trees, logs or other forest products are removed and 

temporarily placed so they can be loaded onto trucks for transport. Because of the disturbance to 

exposed soil and repeated equipment traffic in a concentrated area, soils become compacted and have 

the potential to produce significant runoff and erosion. 

Remote Data – Soil Productivity Influenced by Detrimental Soil Conditions

Qualitative estimates are considered sufficient to meet assessment, analysis, and monitoring

objectives (FSM 2551.4). To provide an understanding of soil productivity within proposed units, and 

how past activities may have influenced the soil resource; remote observations were made to identify 

legacy impacts. These observations began as remote sensing of historic aerial photos and 

contemporary aerial photographs. Areas with assumed presence of legacy equipment disturbance or a 

noticeable change to current vegetative cover; were digitally mapped.

The presence (or absence), growth and development of trees in legacy roads and skid trails was 

considered to be a surrogate for soil productivity. Observations included a presence or absence of 

tracks (ruts), berms and/or apparent blading of the ground surface. The presence of ruts or berms is a 

sign of soil disturbing equipment traffic (soil molding). Although trails are expected to recover to 

natural soil conditions over time, it was assumed these changes in vegetation and soil structure are a 

signature of reduced soil productivity (i.e. DSC) within the prism of these mapped features. 

Signs of equipment traffic visible through the forest canopy using aerial photos available from the 

Forest Service database and Google Earth were used to digitize features. Historic aerial photos 

available on Google Earth were examined to identify and digitize locations of skid trails and landings, 

if they were not visible on more recent photography.

Estimates of DSC for previous harvest units that were not observable from aerial images are based on 

sampling for the Kahler Project (Archuleta 2013) which found that detrimental conditions 

corresponded to about 3% of an activity unit.

Field Observations – Soil Productivity (Erosion and Sedimentation), Stability and 

Detrimental Soil Conditions

Observations of soil conditions occurred during field reconnaissance in 2014 and 2016. Observations 

were made during field reconnaissance for soil stability and field examinations for these features do 

not conflict with completed soil mapping (TEUI). No signs of instability were observed and presence 

of erosion tended to be associated with localized occurrences. No areas identified as a chronic source 

of natural erosion that may be a source of sediment. There were some locations where overland flow 

could offer sediment, but due to the gentle slopes and minor scour of the exposed soil; it is assumed 

that this occurrence was likely within background erosion and sediment volumes.

Some units had roads that were decommissioned by: blocking the entrance and allowing natural 

regeneration; scarifying and seeding; subsoiling and seeding; and/or recontouring. Roads that were 
Final Environmental Impact Statement

Pomeroy Ranger District 175

subsoiled and recontoured are considered to have removed compaction and restored infiltration and 

percolation properties. Other methods have not effectively removed the traveled surface and are still 

considered to have legacy impacts and these roads are included in the calculation for DSC. New 

temporary access roads are not counted as DSC because they would be rehabilitated to break up 

compaction and seeded and mulched to restore ground cover. 

Affected Environment

Scale of Analysis

This analysis is spatially bound by the proposed vegetation treatment unit boundaries, temporary 

access routes to those units and landscape prescribed fire boundaries. The analysis is temporally 

bound by the timing of activities at the unit and landscape scale, which will inform when mitigation

measures would be implemented to maintain or restore soil productivity. 

The Umatilla NF Land and Resource Management Plan (LRMP) has soil productivity goals that are 

used as indicators of change, which will be grouped into four resource elements for this analysis. For 

this analysis, the observed change to vegetation (absence, conversion to grass/forb, reduced growth) 

due to compaction, puddling, displacement or severely burned soil as evidenced by the presence of 

non-system roads, presumed skid trails and landings is used as a surrogate for the four components of 

detrimental soil conditions (DSC).

Indicators for comparison purposes between alternatives are:

• Soil Mass Wasting –soil stability

• Erosion –soil productivity

• Sediment –water quality

• Change or Absence in Vegetation Growth – detrimental soil conditions

(as a result of old roads, landings, skid trails)

Existing Condition

Natural Development

Soils in the analysis area have been mapped with the Terrestrial Ecological Unit Inventory (TEUI). 

These taxonomic delineations result in polygons of various shapes and sizes across the landscape. 

Polygons are populated with either a soil consociation (single series) or soil complexes of various soil 

series. Some soil series have either been previously identified in another soil survey or newly 

identified within the TEUI mapping on the Umatilla NF. Soil complexes can have two to four soil 

series within a complex, the first series named in the complex is the dominant, with the remaining 

series placed in its place of dominance in the complex name. 

In the taxonomic description for each of the soil series, there is a soil order. Soil order information 

offers clues to the history of a given landscape and a better picture of the landscape environmental 

development. Within the project, three soil orders are identified by the soils mapped in proposed 

units. The soil orders within the project area range from slight (Andisols) to intermediate (Mollisols) 

in their degree of development (Brady and Weil 1999). 
Sunrise Vegetation and Fuels Project

176 Umatilla National Forest

Soil Complexes

The project area contains 21 individual soil series, which comprise the 38 soil complexes. A complex 

is composed of two or more soils series and/or a miscellaneous area (such as rock outcrop), plus 

allowable inclusions. Each complex has a dominant soil, which is the first series of the complex name 

(see Soils Resource Report).

Human Influences to the Soil Resource

As mentioned in Methodology, human influences have caused some change to the soil resource. 

Some of these influences have been recognized as having either beneficial, no effect, or detrimental 

effects to the soil resource. 

Previous NEPA decisions have determined that the current road system is needed to implement the 

multiple uses that occur on National Forest System lands within the Pomeroy Ranger District. The 

Sunrise Project contains about 140 miles of developed National Forest System roads, which has 

removed about 240 acres from vegetative production. Some of these roads occur within or adjacent to 

proposed treatment units. Following manual direction (FSM 2551.3, 2010), soil management 

standards and guidelines are generally not applied to administrative sites or dedicated use areas (such 

as roads, recreation sites). This report analyzes the effects of non-NFS roads, skid trails, landings and 

user created routes that occur within proposed treatments units, in addition to modelled hillslope 

erosion and sedimentation from proposed activities. 

The most direct and recognizable influence left on the Sunrise landscape is from past harvest

activities. Several studies reported that compaction and displacement effects associated with 

temporary roads and skid trail equipment traffic can detrimentally influence vegetation and their 

associated soil communities (Froehlich and McNabb 1983, Amaranthus et al, 1996, Bulmer and 

Simpson, 2010 and Miller et al, 2004). Often, effects from temporary roads, landings and skid trails 

do not prevent vegetation from growing seedlings, but these features can limit the opportunity of 

vegetation to reach maturity or result in loss of ecologic function and economic value. Additionally if 

left on the landscape without Effective Ground Cover (EGC) these features can cause erosion (Lane 

et al 1988). Depending upon the proximity of effects to surface water, they could serve as sediment

sources. At this time there are no observed hillslope sources of direct sediment input within the 

project area. Forest Plan standards for EGC after cessation of any soil-disturbing activity is shown 

Table 57. 

Table 57. Forest Plan Standards for Effective Ground Cover

Erosion Hazard Class

Minimum EGC

1st Year 2nd Year

Low (very slight, slight) 20-30% 30-40%

Medium (moderate) 30-45% 40-60%

High (severe) 45-60% 60-75%

Very High (very severe) 60-75% 75-90%

In the past, human ignited fire could be partially responsible for stand densities consistent with 

Mollisol soil development. In a general sense, it is assumed that maintenance burning would 

beneficially consume fuels, preventing the high intensity/long duration fire that can detrimentally heat 

alter the soil resource. Conversely, current human suppression of fire helps to build wildland fuel 

loads that may create detrimental effects to the soil resource (i.e. heat altered soil). Heat altered soil is 
Final Environmental Impact Statement

Pomeroy Ranger District 177

commonly associated with sterilization of the topsoil and the formation of hydrophobic layers that 

promote erosion and stream sediment.

Erosion and Sediment

Erosion and sedimentation from undisturbed forest floor conditions are low and often not 

measureable (Elliot and Miller, 2017). Baseline surface erosion and the sediment it may create were 

modeled with WEPP, for slopes and soil textures found within proposed harvest units. To generate 

baseline hillslope erosion and potential sedimentation (amount of sediment transported from a 

hillslope to a stream), the range of variables in units were populated in the model to test the greatest 

distance offered within the model (1200 ft.). This modeling showed a baseline that was low 

probability (0%) of sediment and low volumes of sediment (undetectable). 

A recent hillslope erosion study (Wondzell and Clifton 2005) within the Sunrise Project area 

measured very low background erosion rates ranging from 0.0001 – 0.003 tons/acre. The study also 

monitored erosion from fuels and harvest treatment and these data were used to improve WEPP 

model calibration at low erosion rates. Use of local data greatly improves the confidence of the model 

results to display differences between treatments and alternatives. Results of the Lick Creek study 

showed very little runoff due to the lack of large rainfall events. The study was only conducted for 4 

years, and therefore only captured a small sampling of weather conditions. Harris et al. (2007) 

concluded that without major storm events to drive extensive overland flow, the physical mechanism 

that would drive erosion and downslope sediment transport was lacking. 

A 12 year data set collected at the Umatilla Barometer Watershed High Ridge study site (Helvey and 

Fowler 1995) reported background sedimentation rate of 0.03 t/ac (19 t/mi2

), which is still a very low 

amount of erosion. Because of the larger dataset and longer period of record, the High Ridge data will 

be used to define baseline estimates for the Sunrise Project. Model results should be considered 

estimates only, and used as relative values for purposes of comparing fire effects and management 

scenarios. Because of natural variability in climate, soil types, cover, and other factors, and 

assumptions made to simplify modeling, results are at best plus or minus 50 percent (Elliot et al, 

1999). 

Resource Indicators and Measures

Table 58 summarizes the existing condition for the resource elements and indicators. Assessment of 

potential hillslope erosion and sedimentation were modeled using WEPP, as described under 

‘Methodology’ and results of WEPP modelling are in Appendix D of the specialist’s report available 

at the Pomeroy Ranger District. The Hydrology Report analyzes the effects of road-related sediment, 

therefore the Soils Report will only address potential sediment derived from proposed hillslope 

treatments. 

Table 58. Resource Indicators and Measures for the existing condition

Resource Element Resource Indicator Measure Existing 

Condition

1) Soil Stability Soil Mass Wasting Active areas identified (acres) 0

2) Soil Productivity Erosion tons (tons/acre) < 0.03

3) Water quality Sediment tons (tons/acre) < 0.03

4) Detrimental Soil 

Conditions (DSC)

Change or absence 

in vegetation growth

Legacy roads, trails, landings in project 

area (acres)* 150
Sunrise Vegetation and Fuels Project

178 Umatilla National Forest

*complete inventory is not available, assumed DSC at 3% of landscape previously harvested is based on intensive 

monitoring for other project areas on the Umatilla National Forest; these are acres outside of proposed treatment units

Resource Indicator or Measure 1

Aerial photo analysis for soil stability and observations made during field reconnaissance for these 

features do not conflict with completed soil mapping (TEUI) or add to known landslide features 

mapped on the Umatilla NF. Therefore this resource indicator of slope stability is not a factor in this 

analysis.

Resource Indicators and Measures 2 and 3 

The most productive part of the soil is often the closest to the mineral surface (Brady and Weil 1999). 

Erosion would either change the location of productive soil or be a loss of soil productivity to stream 

channels as sediment inputs. Additionally, it is assume that the network of legacy trails can offer 

means to route surface flow and sediment to streams. 

Field observations of forested areas appeared to be consistent with the low overall expected 

sedimentation rates measured during the Wondzell and Clifton (2005). Presence of widespread, 

management-induced active hillslope erosion and gullying were not observed during field 

reconnaissance. Small-scale gully-erosional features associated with sparsely vegetated non-forested 

openings were observed in several areas within the project area, such as near the Mount Misery 

Snowmobile Shelter. These type of non-forested areas would be avoided and therefore not be affected 

by proposed management actions. 

The WEPP model summarizes hillslope erosion and sedimentation in the same table, therefore these 

two indicators will be evaluated together for each subwatershed. The assumed background hillslope 

erosion and sedimentation rate is 0.03 tons/acre. Current condition modelled results for forested 

hillslopes of the Lick Creek and North Fork Asotin subwatersheds mirrored those reported by 

Wondzell and Clifton (2005), which showed essentially no measureable erosion or sedimentation. 

Grassland areas of the Lick Creek SWS also showed no erosion or sedimentation under conditions 

modeled. At the landscape scale, grassland areas of the NF Asotin subwatershed averaged 0.07 

tons/acre or about 143 tons of sediment from 2,042 acres. 

Sedimentation observed or measured in natural stream channels can originate from hillslope erosion

or from stream channel bed and bank erosion. The lower 4-5 miles of Lick Creek within the project 

boundary were deeply scoured during runoff events in the winter of 1996-97. This was most likely 

due to accelerated streamflow through the narrowly confined valley bottom, unconsolidated fill 

material and low amount of bank stabilizing riparian vegetation along non-perennial portions of the 

stream channel. Field reconnaissance in 2014 found that streambank stability along lower portions of 

Lick Creek are still below stability thresholds described by Rosgen (1996) for similar stream types. 

Reconnaissance along Cougar Canyon, Middle Branch of the North Fork and North Fork Asotin 

Creek in 2014 indicate that stream channel morphologies are stable for these stream types. Refer to 

the hydrology and fisheries reports for more detail on stream condition. 

Resource Indicator and Measure 4 

Without human intervention there are not many cases when the soil resource can be influenced. Thus 

the inhibition of the growth of trees and brush (FSM 2551.5, Figure 2 of the Soils Report) would be 

Legacy roads and trails and landings in 

proposed treatment units (miles/acres) 57/121

Legacy landings in proposed treatment 

units (acres) 21
Final Environmental Impact Statement

Pomeroy Ranger District 179

considered an expression of a detrimental change to the productivity of the soil resource. The 

presence of DSC was found in association with legacy roads, trails and landings. It is assumed that 

most of these trails were left from previous harvest activities, but some may have been created from 

unregulated recreation and firewood cutters in the area. Topography of the area is conducive to access 

for most forms of vehicles used in recreation activities. Estimates of DSC are based on GIS mapping 

of old roads, skid trails and landings, with some field verification of the presence of these features. 

For previously harvested units where linear features are not evident on aerial photos, an estimate of 

3% DSC is assumed based on intensive DSC mapping for the Kahler project (Archuleta 2013). 

Appendix E of the specialist report summarizes DSC by treatment unit. Overall, calculated DSC 

occurs on 141 acres within proposed treatment areas and currently exceeds Forest Plan Standards for 

Units 215 (30% or 1.9 acres) and 216 (24% or 1.5 aces). These trails appear to have inhibited 

vegetation growth and type of growth. Where site conditions allow, these areas would continue to 

recover toward a more natural state. 

Environmental Consequences

Past, Present, and Reasonably Foreseeable Activities Relevant to Cumulative 

Effects Analysis

All ground disturbing activities included in the list of past, present and reasonably foreseeable 

activities for the Sunrise project are relevant to cumulative effects analysis for DSC.

Direct and Indirect Effects

Alternative A (No Action)

Resource Indicator and Measure 1 

Soil mass movement was not identified in the area, therefore, the No Action alternative would not 

increase or decrease the potential slope instability.

Resource Indicators and Measures 2 and 3

If the project area were to continue unchanged by further disturbance from humans or natural events 

it would remain on its current soil developmental trajectory with no direct change to the resource 

indicators of erosion or sedimentation. Direct and Indirect effects to erosion and sedimentation are 

expected to be small, with no elevation above assumed background levels.

Resource Indicator and Measure 4 

This alternative would produce no increase or reduction in detrimental soil disturbance because 

logging operations and associated activities as proposed in other alternatives would not occur. No 

rehabilitation and native seeding of existing landings, skid trails, or unauthorized roads would occur 

to improve soil productivity on detrimentally altered sites. 

Cumulative Effects

Resource Indicator and Measure 1 

Cumulative effects are not expected from mass movement under normal weather conditions. NEPA is 

complete for the Asotin Prescribed Burn, which includes about 7,943 acres in the Sunrise project area. 
Sunrise Vegetation and Fuels Project

180 Umatilla National Forest

Table 7 of the specialist’s report shows how soil burn severity would change following a wildfire 

before and after the Asotin Prescribed Fire is implemented. 

After the Asotin Prescribed Burn is implemented, this portion of the Sunrise Project area would have 

a reduced risk to post wildfire hillslope failures because an expected reduction in soil burn severity

would maintain higher amounts of effective ground cover to protect mineral soils from wind and 

water erosion. 

Resource Indicators and Measures 2 and 3

The Asotin Prescribed Burn would occur on about 7,943 acres within the Sunrise Project area. The 

same modeling scenario described under direct and indirect Effects was run for the Asotin Prescribed 

Burn. Under the modeled wildfire scenario, there would be an additional 0.09 tons/acre from the Lick 

Creek subwatershed and 0.11 tons/acre from the North Fork Asotin subwatershed (see Fuels 

Specialist report). 

Erosion from hillslopes is expected to be localized unless influenced by a combination of high soil 

burn severity wildfire followed by high winds and runoff-producing rainfall events immediately after 

a fire. The potential duration of expected erosion risk would be for at least 3 years immediately 

following wildfire. The volumes of erosion under this risk are also influenced by the intensity and 

duration of precipitation events that occur during elevated erosion risk. 

Current equivalent clearcut area (ECA) values for Lick Creek and NF Asotin Creek subwatersheds 

are low and well below threshold values (see Hydrology Report). Based on model assumptions, 

management induced changes in water yield, timing of flow, or peak flow are currently negligible, 

which indicates that streambed and bank derived sedimentation rates are not being influenced by 

management activities at the subwatershed scale. The Asotin Creek Rx burn would increase the NF 

Asotin Creek ECA from 5.7% to 9.9% and Lick Creek would increase from 3.2% to 6.8%, which are 

below the threshold value of 20% that may result in changes to water yield and streamflow. Unless a 

large scale high severity fire burns within the Sunrise Project area and causes an increase in ECA 

above the threshold value due to the fire that results in streamflow increases, changes to the stream 

channel-derived sediment would not occur. 

Resource Indicator and Measure 4 

Detrimental Soil Conditions that are created by equipment traffic can be long-lived (>40 years). There 

are no cumulative effects to DSC for this alternative because there would be no additional land 

disturbing activities and areas of known DSC would not be rehabilitated to restore soil productivity. 

Common to All Action Alternatives (Alternative B and C)

The Sunrise Project has two distinct treatment types at two different scales: 1) harvest, thinning and 

fuels treatment of activity units and 2) landscape prescribed burning. WEPP analyses are therefore 

based on different hillslope areas. Harvest, thinning and mastication units that also have broadcast 

burning as part of the fuels treatment were not counted in the landscape fire scenario, so that acres 

were not double counted. 

Resource Indicator and Measure 1 

Soil mass movement was not identified in the project area nor within individual treatment units. 

Aerial photo examination of proposed treatment units and other previously harvest areas in the project 

area indicates that past vegetation treatments did not cause obvious hillslope failures. Therefore, the 
Final Environmental Impact Statement

Pomeroy Ranger District 181

direct and indirect effects of proposed treatments are presumed to also have no observable effect on 

mass movement. 

Resource Indicators and Measures 2 and 3 

Harvest

Soils in most of the units proposed for treatments have considerable volcanic ash content (ash soils) 

with susceptibility to compaction in both wet and dry condition, water erosion hazard, displacement 

and dry condition dusting (key concerns for these soil types). All soils in the area have at least some 

ash-influence in the surface layer. 

Utility of the harvester-forwarder system for ground-based harvest (or other silvicultural treatments) 

mitigates to great extent the potential for these adverse effects when adequate ground cover is present 

or can be generated by operations. Nearly all of the smaller branches and needles are left on site, 

where, even if later jackpot or underburned, would allow nutrient retention in the unit. Virtually no 

landings are needed because the short logs can be decked along the length of adjacent haul roads. 

Erosion hazard is all but eliminated in typical operations of this type, with only occasional areas of 

bare soil limited to short sections (typically less than 25 foot in length) with a mosaic pattern that is 

not conducive to concentrating water sufficient to move soil. 

Monitoring of other harvest activity on the Umatilla NF indicates cut-to-length processors and fullsuspension forwarders result in detrimental soil impacts (per Forest Plan definition) dominantly in the 

2 to 5% range (including fuels treatments in most cases, hence the slightly higher range than indicated 

above) with lesser compaction (in particular) on the shallower soil types. The residual soils, and those 

with thin volcanic ash mantles (10 inches or less), have high strength in dry conditions and do not 

compact easily. They are still susceptible to surface displacement. The deeper soils, most with high 

ash content, are still susceptible to compaction even when dry, as soil strength does not increase in 

ash soils to the same degree as in other parent materials.

The results with the in-woods processors (including the cut-to-length systems using forwarders) have 

been quite favorable in operations monitored on the Umatilla National Forest. The slash mats spread 

compressive forces while little to no displacement occurs as there is minimal turning forces or 

dragging of trees to move surface soil. Landings often overlap existing roads thereby limiting 

additional effects to unaffected soil areas, or logs are simply piled roadside with no scraping needed.

Feller-buncher plus skidding harvesting systems exposes more soil than does hand felling and cable 

systems. Tractor operations which skids logs across the surface create greater area of bare mineral soil 

subject to erosion. Skidding can also create “dusting-up” of volcanic ash soils if the soil is very dry 

and there is little surface duff and branches to buffer the surface. Control of operations during 

fluctuating moisture and freeze/thaw conditions (winter operations if utilized) is crucial. 

Tractor yarding of whole or partial-tree trees typically results in detrimental soil condition 

percentages in the 4 to 8% range in these soil types and vegetation conditions. Areas with large 

amounts of downed wood tend to have DSC in the lower end of the range as the downed wood 

reduces the degree of compaction, rutting, and bare mineral soil created. 

The previous discussion maintains the following assumptions: skid trails are perpendicular or oblique 

slope angle to drainages; main skid trails with multiple passes experience considerably more erosion

than feeder trails with fewer passes; skyline corridors have higher ground cover than skid trails; 

skyline corridors cause less ground disturbance but more dense than main skid trails; proposed 

treatments would reduce the severity of wildfire which would result in lower rates of sedimentation. 
Sunrise Vegetation and Fuels Project

182 Umatilla National Forest

Understanding the benefiting opportunities from fuel loading (slash) with yarding method may be an 

important factor to consider in the analysis. If harvest in a unit occurs before or as it transitions from 

moist to dry soil conditions; equipment may need to ride on slash to minimize DSC. 

Temporary Roads

All action alternatives would construct temporary roads to facilitate commercial timber harvest. The 

width of temporary roads and the number and size of turnouts would be limited to minimize 

disturbance to soils, vegetation, and root mats. Construction of temporary roads would cause direct 

effects in the form of compaction and displacement of soils. Erosion potential is the greatest during 

and immediately after temporary road construction. A maximum of 13.7 miles of temporary roads 

would be constructed to facilitate harvest on the various soils types. 

Factors that influence surface erosion on temporary roads include erodibility of soils and steepness of 

grade. All temporary roads are located on low to moderate gradient slopes outside of RHCAs. Ash 

derived soils are the predominant soil type where temporary roads would be constructed. Ash soils 

have high infiltration rates and high water holding capabilities that decrease erodibility. Due to 

location, low erodibility of the soils, slope gradient, and the use of Best Management Practices

(BMPs), the potential for sediment reaching streams is low. 

To reduce sediment potential the temporary roads would be decommissioned as soon as feasible after 

use. Decommissioning includes blocking, subsoiling, seeding, and possible mulching with emphasis 

to improve hydrologic, and soil function. Surface treatment (ripping or other tillage activity) would 

improve the infiltration, reduce or eliminate erosion hazard, and improve seed bed character upon 

completion, but remain in a reduced productive capacity if retained for future use. Soil structure 

should recover in the long term. Full obliteration would most fully return productive capacity over the 

long term. Monitoring of decommissioned temporary roads is important to assure erosion recovery is 

occurring and erosion is at a minimum. It is expected that decommissioning will prevent long term 

impacts. 

Prescribed Fire

Effects of concern from prescribed fire activity would be related to area of high soil burn severity

(indicated by fire intensity) and total exposed soil surface subject to potential erosion hazard. The 

prescription for underburning and pattern of heavy fuel concentrations are prime determining factors 

affecting the extent of high severity burn areas. Contemporary prescriptions for underburning rarely 

create severe burn conditions. Total area of severely burned soils is expected to be very small, usually 

< 5% in broadcast treatment; increasing up to 10% of treatment areas if there are numerous 

concentrations of heavy fuels loadings resulting from either harvest activity or down woody levels. 

Exposed soil would be expected to be scattered in a mosaic pattern similar to heavy fuel loading

patterns, rarely in continuous areas to become an erosion hazard. 

Mechanical Fuel Treatments

Use of mechanical fuel treatments adds additional equipment traffic while generally reducing the 

number of spots of severe burn intensity. Mastication (slash busting) equipment is proposed in some 

thinning or improvement cut harvest units to reduce created and existing slash, and protect the 

remaining stand which includes a considerable proportion of fire intolerant species. These are usually 

mounted on small-body excavator bodies with wide tracks. As such they have relatively low groundpressure and can work on top of downed logs and existing or created slash. Additional compaction

and some displacement can be created while turning. Operation on downed slash and other woody 

material and use of existing trails keeps additional compaction and displacement effects very low. 
Final Environmental Impact Statement

Pomeroy Ranger District 183

Rolling drum type masticators can cause more ground disturbance because they are generally pulled 

behind a tracked machine than cause additional compaction, rutting and displacement of soils. 

Monitoring of grapple-piling operations on the Umatilla NF indicates detrimental soil impacts in the 

0-2% range. 

Specific impacts will depend on what equipment is used during different stages of treatment. Overall, 

short-term impacts may range from minimal to substantial negative impacts. Long term, the 

magnitude of impacts will decrease with time but some moderate negative impacts may persist in 

areas of high compaction. 

Cumulative Effects

Previous management activities over the past several decades compound to produce the existing 

condition. Activities include road building, timber harvest, site preparation, livestock grazing, fire 

suppression activities and prescribed fire. The concern, from a soils standpoint, is whether additional 

effects to the soil resources resulting from proposed activities would accumulate adverse effects to 

soil characteristics sufficient to affect productivity. 

Existing soil disturbance is scattered across the project, concentrated on more level ground that is 

readily accessed. It is primarily in the form of old skid trails and access roads that were sufficiently 

disturbed at the time of their use. They remain in exceedance of criteria for detrimental disturbance 

levels. This existing detrimental soil condition is often referred to as legacy disturbance, and is 

factored into assessments of cumulative effects for new management actions. 

A certain amount of overlap occurs when logging activity happens on units with existing detrimental 

soil condition as machinery reuses some trails and landing sites. This tends to reduce the amount of 

added, new detrimental soil impacts. However, this was not used to reduce the estimated increase 

percentage in DSC in the assessment due to uncertainty on the extent of this effect on a specific unit. 

This would likely lead to some overestimation of total potential DSC in units with existing soil 

disturbance from previous activity. 

Cumulative effects relative to erosion hazard are not relevant within treatment units as surface 

recovery occurs rapidly enough to eliminate this as a cumulative concern. Data collected during a 

fuels treatment study (Wondzell and Clifton 2005) in the Sunrise Project area found that ground cover

was maintained to Forest Plan Standards. Results of the Lick Creek study showed very little runoff, 

however, the study was only conducted for 4 years, and therefore only captured a small sampling of 

weather conditions. A 12 year data set collected as part of the Umatilla Barometer Watershed study 

(Helvey and Fowler 1995) reported background sedimentation rate of 0.03 t/ac (19 t/mi2

). 

Soil rehabilitation of adverse soil conditions is expected to be necessary on several units with existing 

high levels of DSC (see Appendix E of the Soils Report). Obliteration of temporary roads, 

scarification/subsoiling of landings, and retention of as much organic matter as fire risk/fuel 

objectives would help ameliorate and rehabilitate site conditions for productive capacity and reduced 

erosion hazard.
Sunrise Vegetation and Fuels Project

184 Umatilla National Forest

Direct and Indirect Effects

Alternative B

The direct effects of implementing the Alternative B would be the removal of 26.5 MBF of timber 

from 5,520 acres (including development of skid trails, landings and 51 temporary road segments 

totaling 13.7 miles) and precommercial thinning of an additional 2,270 acres. Treatment of activity 

fuels would include mastication, lop and scatter, hand piling, grapple piling, pile burning, jackpot 

burning and/or broadcast burning. Prescribed fire is proposed for 14,055 acres of forest and grassland. 

Appendix D of the specialist’s report summarizes the results of the WEPP batch runs for the Lick 

Creek and North Fork Asotin Creek subwatersheds. 

Resource Indicator and Measure 1 

See Effects Common to All Action Alternatives. 

Resource Indicators and Measures 2 and 3

Actions under Alternative B that would have some effect on soil productivity (loss of soil through 

erosion) include ground disturbance from yarding operations (ground-based and skyline systems) and 

mastication, development of landings, development of temporary roads and prescribed burning. Each 

of these activities has an expected impact to the DSC (Reeves et al, 2011, Archuleta, 1997 and 1999, 

Siskiyou NF, 1997 and Bennett, 1982), which can influence erosion. During the implementation of 

activities, there would be some elevation of risk to erosion and sedimentation. However BMPs and 

project design criteria would mitigate or diminish if not all, most of the short term effects from 

erosion. 

Part of the purpose and need for this project is to implement actions that would facilitate restoration

and maintenance of the desired fire regime condition classes across the landscape. WEPP was used to 

model effects of proposed treatments at two scales: 1) effect of thinning, harvesting and fuels 

treatment units at the hillslope scale, within each subwatershed and 2) effect of prescribed burning at 

the subwatershed scale, which used the fire condition and behavior modeling results. 

The Disturbed WEPP program was used to model potential effects of the wildfire behavior simulation 

(see Fuels Report) as a basis to evaluate the effectiveness of proposed treatments at limiting the risk 

of hillslope soil loss. Elliott (2005) presents another method to compare fuels treatments at the 

landscape scale using the WEPP FuME Module. 

The WEPP model calculates erosion and sedimentation estimates for storm events that have a high 

probability of occurrence in a given year (2.5 year return interval) to a low probability (50 year return 

interval), with increasing amounts of precipitation that generate higher runoff that results in 

potentially more hillslope erosion and sedimentation. The data show that the majority of the sediment

is produced by lower frequency, higher precipitation events and ground cover becomes less of a factor 

at maintaining soil stability as the intensity and duration of precipitation increases. The model also 

assumes that BMPs for skidding and yarding would maintain ground cover at desired levels. 

Based on the model runs and assumed background levels, harvest and prescribed burning would result 

in less potential hillslope erosion and sedimentation than a high severity wildfire burning under 

current fuel conditions. Beneficial effects of treatments are expected to last for decades because of the 

reduced fuel loading from proposed treatments. 
Final Environmental Impact Statement

Pomeroy Ranger District 185

Treatment Units

Based on the model runs and assumed background levels, harvest and prescribed burning would 

produce lower sedimentation rates than a higher severity wildfire. Average sedimentation rates from 

mechanical thinning and prescribed fire in the Lick Creek subwatershed are similar to that reported by 

Wondzell and Clifton and this amount would be negligible. Sedimentation rates from thinning, 

harvesting and fuels treatments in the North Fork Asotin Creek subwatershed would also be low 

during the first year post-treatment, although both are higher than the background rate. EGC would 

remain within Forest Plan standards and based on the Lick Creek Study, expected to recover to preactivity levels within 2 years. 

The longer term benefit of treatments would be to reduce the severity of future wildfires 

commensurate with changes to desired condition classes, which would result in lower erosion and 

sedimentation rates. 

All treatment scenarios for the Lick Creek subwatershed indicate that on a weighted average basis, there 

is little difference between treatments (Table 59). The model runs for North Fork Asotin Creek (

Table 60) indicate that at both scales, wildfire effects burning under current conditions would be 

mitigated by implementing density management treatments. Examining the difference between 

erosion/sedimentation rates at the landscape and unit scale indicates units proposed for treatment have 

the potential to produce twice as much sediment as the landscape as a whole and thus there is a longer 

term benefit to implementing these treatments. 

Table 59. Resource Indicators and Measures for Alternative B – Lick Creek

Resource Element Resource Indicator Treatment Type Measure tons/ac

2) Soil Productivity

3) Water Quality

Erosion

Sedimentation

Landscape Rx < 0.03

Wildfire at Landscape scale 0.03

Harvest/thinning Units < 0.03

Rx Fire Units < 0.03

Wildfire at Unit scale 0.06

Table 60. Resource Indicators and Measures for Alternative B – NF Asotin Creek

Resource Element Resource Indicator Treatment Type Measure tons/ac

2) Soil Productivity

3) Water Quality

Erosion

Sedimentation

Landscape Rx 0.13

Wildfire at Landscape scale 0.47

Harvest/thinning Units 0.08

Rx fire Units 0.23

Wildfire at Unit scale 0.90

WEPP was also used to validate the recommended water bar spacing for skid trails and temporary 

roads on steeper slopes, as shown in Appendix F of the soil resource specialist report; Project Design 

Features.

Landscape Scale

A complimentary analysis using the broader scale WEPP FuME model indicates that in the first year 

post treatment the benefits of implementing the proposed actions in both subwatersheds is similar to 

the overall average from the more detailed Disturbed WEPP. Appendix D of the specialist’s report 
Sunrise Vegetation and Fuels Project

186 Umatilla National Forest

contains the summary outputs of the WEPP model runs for the vegetation components of the Lick 

Creek and North Fork Asotin Creek subwatersheds. 

The WEPP scenarios were run using a buffer of 100 feet, which is the minimum PACFISH buffer for 

Class IV (intermittent) streams. The project area contains Class I, II, III and IV streams with no 

thinning and no ignition buffers ranging from 100-300 feet. In addition, during the prescribed burn, 

project design criteria would implement a 600 ft. no ignition zone along Class I streams. For groundbased units, PDFs include water bar guidelines for skid trails. These practices would further limit 

potential for activity-generated sediment to enter into stream channels, therefore water quality would 

not be adversely affected. 

Resource Indicator and Measure 4 

The direct effect of Alternative B would be ground disturbance of approximately 3,312 acres from 

ground based harvesting equipment, 822 acres of noncommercial thinning from masticators and 2,207 

acres of skyline yarding. Not all ground disturbance would result in DSC, although each of the 

proposed mechanized treatment methods has a predicted impact to the DSC (Reeves et al, 2011, 

Archuleta, 1997 and 1999, Siskiyou NF, 1997 and Bennett, 1982), which can influence sediment. 

While Reeves offers a comprehensive list of expected detrimental effects, it appears these estimates 

may underestimate effects if certain conditions are present or absent. Twelve units would be near or 

exceed the 20% threshold under Alternative B. Restoration of DSC by subsoiling may be possible in 

units 62, 195, 208, 215 and 231 depending on the location of deeper soils. Suitability for subsoiling of 

deeper soils for the Mount Emily series for units 179 and 216 are based on hillslope gradients > 35%, 

so there may be opportunity to effectively subsoil portions of these units, based on field 

reconnaissance. GIS shows soil mapping unit 5776CN for units 187 and 217, however, the digital 

elevation model (DEM) indicates that only small portions of these units exceed 30% slopes, therefore 

portions of deeper soils can be effectively subsoiled. 

Units 174, 181 and 215 are mastication units only and further impacts to DSC can be mitigated by 

ensuring that enough slash is present to prevent further compaction or prescribing low ground 

pressure equipment. Existing DSC for unit 215 is 30% and the soil scientist would identify areas 

suitable for subsoiling after treatments are implemented. 

For ground based units currently below the 20% threshold, yarding would be restricted to existing 

skid trails and field reconnaissance by the soil scientist would identify areas suitable for subsoiling. 

Unit 216 is currently at 24% DSC and limiting skidding to existing trails would still not reduce DSC 

Unit 187 has inclusions of steeper slopes which would be avoided by ground based equipment. 

Digital elevation dataset indicates that unit 217 exceeds 35% gradient and therefore would not be 

suitable for ground-based harvest. An alternative harvest system would be needed for this unit. 

Detrimental impact to soils with low bearing strength can be mitigated by restricting equipment 

operations when soil moisture is less than field capacity (soil is allowed to drain after becoming 

saturated). These soils can also be damaged by multiple vehicle passes when too dry, due to high 

content of silts and clays, which causes loss of soil structure as soil is turned into ‘powder’. 

Understanding the benefiting opportunities from fuel loading (slash) with yarding method may be an 

important factor to consider in the analysis. If harvest in a unit occurs before or as it transitions from 

moist to dry soil conditions; equipment may need to ride on slash to minimize DSC. Provided all 

mitigating factors are implemented occurs, the anticipated DSC for a given unit can be reduced below 

the 20% DSC criteria.
Final Environmental Impact Statement

Pomeroy Ranger District 187

Log haul would occur on 90 miles of NFS roads. Alternative B would require an additional 38 haul 

routes totaling 13.7 miles. Temporary roads needed for access and log haul have been identified on 

5.8 miles of existing nonsystem roads and skid trails and approximately 7.9 miles of new temporary 

access routes are needed to access several units. 

Layout and staking of these routes in advance of vegetation treatments would occur with input from 

the soils scientist to avoid to the extent possible: meadows, lithosols, shallow soils, wet soils, soils 

with low bearing strength or other properties that would reduce the effectiveness of fully restoring 

productivity to these areas. 

Design criteria for reducing or eliminating DSC after temporary road use include ripping, subsoiling, 

pulling berms, mulching, seeding and blocking future motor vehicle access (see Design Features in 

Appendix F of the Soils Report). Temporary road segments T04 (0.1 mi), T05 (0.3 mi) and T49 (0.3 

mi) occur on shallow very shallow frigid, xeric soils where subsoiling is not a viable restoration

technique. Restoration of these routes may require the addition of soil amendments (e.g. topsoil, 

biochar) to restore long-term soil productivity. 

Beneficial effects to soil productivity from this alternative would occur when 5.8 miles of legacy 

roads and trails and 8.6 acres of landings are rehabilitated to reduce or eliminate compaction, improve 

infiltration and thereby reduce runoff and sedimentation. Some legacy trails would be used as 

temporary roads in the project and subject to removal per the forest plan. Contract provisions of the 

timber sale would include obliteration of roads and trails per administrative authority, otherwise, KV 

funds would be collected for road and trail decommissioning.

Cumulative Effects

Resource Indicator and Measure 1 

Cumulative effects are not expected from mass movement under normal weather conditions. The 

WEPP model indicates that a 50 year runoff event could increase erosion and sedimentation up to an 

order of magnitude regardless of hillslope treatment. Alternative B, when combined with the Asotin 

Prescribed Burn Project, would reduce the severity of wildfire as described in the Fuels Report. 

Effects of the modeled fire behavior would be reflected in lower soil burn severity, which would 

maintain higher amounts of ground cover, thus limiting soil exposure to post fire weather and 

reducing the potential for hillslope failures. 

Resource Indicators and Measures 2 and 3 

The Asotin Prescribed Burn would occur on about 7,943 acres within the Sunrise Project area. Under 

the modeled wildfire scenario, there would be a temporary addition of 0.09 tons/acre from the Lick 

Creek subwatershed and 0.11 tons/acre from the North Fork Asotin subwatershed. The combined 

effect of the Sunrise and Asotin Projects would reduce fuel loading and change fire regime condition 

class to desired levels at the subwatershed scale. Modelling indicates that the long term benefits of the 

combined Sunrise and Asotin Projects would result in a lower risk of large scale, high severity fire for 

decades, with a corresponding reduction in hillslope erosion and sedimentation as a result of future 

wildfires. 

Based on the assumptions of the hydrologic ECA model and the literature cited, the proposed harvest

and landscape burning would have a measurable effect to hydrologic functions (capture, storage, and 

release of water) when combined with the Asotin Prescribed Burn Project, assuming all activities 

occurred at the same time (see Hydrology Report). This combined effect may result in increased 

sedimentation as a result of streambank scour. In reality, commercial thinning and fuels treatments 
Sunrise Vegetation and Fuels Project

188 Umatilla National Forest

would occur asynchronously in time and space and these effects are not expected to be concurrently 

additive at the subwatershed scale, therefore streambed and bank derived sedimentation rates would 

not be measurably influenced by management activities at the subwatershed scale. 

Resource Indicator and Measure 4 

Proposed actions are designed with a considered balance between potential site impacts and the 

feasibility of operations. Previous management activities disturbed soils to varying degrees and 

extent, with some impacts still exceeding levels considered detrimental as described in the Forest Plan

and Regional Guides. 

Existing soil disturbance is scattered across the project, concentrated on more level ground that is 

readily accessed. It is primarily in the form of old skid trails and access roads that were sufficiently 

disturbed at the time of their use. They remain in exceedance of criteria for detrimental disturbance 

levels. This existing detrimental soil condition is often referred to as legacy disturbance, and is 

factored into assessments of cumulative effects for new management actions. 

Mentioned in the existing condition discussion there is existing DSC from past activities (see 

Appendix E of the specialist’s report). Detrimental soil conditions created by equipment traffic and 

landings would increase from 141 acres to 712 acres under Alternative B or about 9% of treatment 

units and 2% of the project area. Project design criteria such as subsoiling would occur on 

approximately 8.6 acres, thus there would be an overall reduction in DSC which would result in 

improved soil productivity. 

Direct and Indirect Effects

Alternative C

The direct effects of implementing the Alternative C would be the removal of 12.1 MBF of timber 

from 2,550 acres (including development of skid trails, landings and 30 temporary road segments 

totaling 8.4 miles) and precommercial thinning of an additional 2,270 acres. Treatment of activity 

fuels would include mastication, lop and scatter, hand piling, grapple piling, pile burning, jackpot 

burning and/or broadcast burning. Prescribed fire is proposed for 14,060 acres of forest and grassland. 

Appendix D summarizes the results of the WEPP batch runs for the Lick Creek and North Fork 

Asotin Creek subwatersheds. 

Resource Indicator and Measure 1 

See Effects Common to All Action Alternatives.

Resource Indicators and Measures 2 and 3

Treatment Units

Direct and indirect effects in the Lick Creek subwatershed would be the same as Alternative B 

because the proposed treatments are the same. 

Alternative C would treat approximately 2,970 acres less than Alternative B in the North Fork Asotin 

Creek subwatershed. Although the overall rate (tons/acre) of change in fire regime condition and 

erosion/sedimentation are similar to Alternative B, the amount of sediment (tons) would be less 

because fewer acres are treated. Initially, the potential sediment load from thinning and mastication 

areas would be less than Alternative B. The longer term benefit of treatments would be to reduce the 

severity of future wildfires commensurate with changes to desired condition classes, which would 
Final Environmental Impact Statement

Pomeroy Ranger District 189

result in lower erosion and sedimentation rates. However, the net long-term benefit of wildfire risk 

reduction would not be as much as alternative B because 1,700 fewer acres with moderate to high fire 

behavior would be treated under Alternative C. 

Effects in the Lick Creek subwatershed would be the same as Alternative B. All treatment scenarios 

for the Lick Creek subwatershed indicate that on a weighted average basis, there is little difference 

between treatments (see data in Appendix D of Soils Report). 

The model runs for North Fork Asotin Creek (Table 61) indicate that at both scales, wildfire effects 

burning under current conditions would be mitigated by implementing density management 

treatments. Examining the difference between erosion/sedimentation rates at the landscape and unit 

scale indicates units proposed for treatment have the potential to produce twice as much sediment as 

the landscape as a whole and thus there is still a longer term benefit to implementing these treatments. 

Table 61: Resource Indicators and Measures for Alternative C – NF Asotin Creek

Resource Element Resource Indicator Treatment Type Measure tons/ac

2) Soil Productivity

3) Water Quality

Erosion

Sedimentation

Landscape Rx 0.13

Wildfire at Landscape scale 0.47

Harvest/thinning Units 0.07

Rx fire Units 0.18

Wildfire at Unit scale 0.87

Landscape Scale

The landscape scale analysis using WEPP FuME produces the same results on a tons/acre basis as 

Alternative B because this model does not have an input for hillslope acres like the Disturbed WEPP 

batch model. However, as stated above for the mechanical treatments, fewer acres would be treated 

under Alternative C, and initially, there would be less potential sedimentation, but at the landscape 

scale, there would be a higher risk of moderate to high fire burn severity because less area is proposed 

for treatment under Alternative C. 

Resource Indicator and Measure 4 

The direct effect of Alternative C would be ground disturbance of approximately 1,641 acres from 

ground based harvesting equipment, 822 acres of noncommercial thinning from masticators and 912 

acres of skyline yarding. 

All units except 230 and 231 occur in Alternative C and the effects and rehabilitation of DSC 

described under Alternative B are the same for Alternative C. 

Log haul would occur on 84 miles of NFS roads (see Transportation Report). Alternative C would 

require an additional 30 haul routes totaling 8.4 miles. Temporary roads needed for access and log 

haul have been identified on 5.0 miles of existing nonsystem roads and skid trails and approximately 

3.4 miles of new temporary access routes are needed to access several units. 

Design criteria for reducing or eliminating DSC after temporary road use include ripping, subsoiling, 

pulling berms, mulching, seeding and blocking future motor vehicle access (see Appendix F of Soils 

Report; Project Design Features). Temporary road segments T04 (0.1 mi) and T49 (0.3 mi) occur on 

shallow very shallow frigid, xeric soils where subsoiling is not a viable restoration technique. 
Sunrise Vegetation and Fuels Project

190 Umatilla National Forest

Restoration of these routes may require the addition of soil amendments (e.g. topsoil, biochar) to 

restore long-term soil productivity. 

Beneficial effects to soil productivity from this alternative would occur when 4 miles of legacy roads 

and trails and 4.8 acres of landings are rehabilitated to reduce or eliminate compaction, improve 

infiltration and thereby reduce runoff and sedimentation. 

Cumulative Effects

Resource Indicator and Measure 1 

Cumulative effects would be similar to Alternative B. 

Resource Indicators and Measures 2 and 3 

Cumulative effects would be similar to Alternative B. 

Resource Indicator and Measure 4 

Proposed actions are designed with a considered balance between potential site impacts and the 

feasibility of operations. Previous management activities disturbed soils to varying degrees and 

extent, with some impacts still exceeding levels considered detrimental as described in the Forest Plan

and Regional Guides. 

Existing soil disturbance is scattered across the project, concentrated on more level ground that is 

readily accessed. It is primarily in the form of old skid trails and access roads that were sufficiently 

disturbed at the time of their use. They remain in exceedance of criteria for detrimental disturbance 

levels. This existing detrimental soil condition is often referred to as legacy disturbance, and is 

factored into assessments of cumulative effects for new management actions. 

Mentioned in the existing condition discussion there is existing DSC from past activities (see Soil 

Specialist Report). Detrimental soil conditions created by equipment traffic and landings would 

increase from 137 acres to 459 acres under Alternative C or about 9% of treatment units and 1% of 

the project area. Project design criteria such as subsoiling would occur on approximately 4.8 acres, 

thus there would be an overall reduction in DSC which would result in improved soil productivity. 

Table 62. Summary of Cumulative Detrimental Soil Condition (DSC) by Alternative

Alternative Activity Area Detrimental Soil Condition

0 to 10% 10 to 20% >20% Total Units/Acres

Alternative A

(Alternative B existing acres DSC) 123 14 4 141 acres

(Alternative C existing acres DSC) 119 14 4 137 acres

Alternative B - number of units 110 118 8 236 units

Total acres DSC 156 530 23 712 acres (9% of 7,789)

Alternative C - number of units 69 75 6 147 units

Total acres DSC 90 323 14 459 acres (9% of 4,823)
Final Environmental Impact Statement

Pomeroy Ranger District 191

Irreversible and Irretrievable Commitment of Resources

For all action alternatives (B and C) there would be no irreversible or irretrievable commitment of 

resources with implementation of proposed activities.

Final Environmental Impact Statement

Pomeroy Ranger District 193

3.12 Botany

A summary of the current conditions of the affected environment and the predicted effects of the 

Proposed Action and its alternatives are discussed in this section. Specific information on the 

methodologies, assumptions, and limitations of analysis and other details are contained in the Sunrise 

botany specialist’s report, incorporated herein by reference, and available to the public on the project 

webpage at http://www.fs.fed.us/nepa/fs-usda-pop.php/?project=45689. 

Introduction

The existing condition and an analysis of potential effects from proposed actions to plants that are 

federally-listed as threatened, endangered, or proposed for federal listing under the Endangered 

Species Act of 1973 as amended are summarized in this section. Vascular plants, non-vascular plants 

(mosses and liverworts), and lichens currently identified as sensitive by the Regional Forester of the 

Pacific Northwest Region are also discussed and analyzed. For the rest of this discussion, these 

species are collectively called sensitive plant species.

Regulatory Framework

Federal laws

Endangered Species Act 

The Endangered Species Act of 1973 (Public Law 93-2015, 1973) mandates all Federal departments 

and agencies to conserve listed species and to utilize their authorities in furtherance of the purposes of 

the ESA. Section 7(a) (2) directs all Federal agencies to insure that any action they authorize, fund, or 

carry-out does not jeopardize the continued existence of an endangered or threatened species or 

designated or proposed critical habitat. The Umatilla National Forest has one listed threatened plant, 

Spalding’s Catchfly (Silene spaldingii). Spalding’s catchfly is documented in the project area. 

National Forest Management Act

The National Forest Management Act of 1976 (Public Law 94-588, 1976) reorganized, expanded and 

otherwise amended the Forest and Rangeland Renewable Resources Planning Act of 1974, which 

called for the management of renewable resources on national forest lands. NFMA requires the 

Secretary of Agriculture to assess forestlands, develop a management program based on multiple-use, 

sustained-yield principles, and implement a resource management plan for each unit of the National 

Forest System. It is the primary statute governing the administration of national forests.

National Environmental Policy Act

The National Environmental Policy Act of 1969 (Public Law 91-190, 1969) directs federal agencies 

to “... insure that environmental information is available to public officials and citizens before 

decisions are made and before actions are taken” [40 CFR §1500.1(b)].
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194 Umatilla National Forest

Forest Service policy

Forest Service manual 2672.1 sensitive species management

Sensitive species of native plant and animal species must receive special management emphasis to 

ensure their viability and to preclude trends toward endangerment that would result in the need for 

Federal listing. There must be no impacts to sensitive species without an analysis of the significance 

of adverse effects on the populations, its habitat, and on the viability of the species as a whole (USDA 

Forest Service, Forest Service Manual FSM 2670-2671. Threatened, Endangered and Sensitive Plants 

and Animals, Amendment No. 2600-2005-1, 2005).

Forest Service manual 2672.4: Biological evaluation process

The Forest Service shall review all planned, funded, executed, or permitted programs and activities 

for possible effects on endangered, threatened, proposed, and sensitive species. The biological 

evaluation is the means of conducting the review and of documenting the findings. Document the 

findings of the biological evaluation in the decision notice. Where decision notices are not prepared, 

document the findings in Forest Service files. The biological evaluation may be used or modified to 

satisfy consultation requirements for a biological assessment of construction projects requiring an EIS

(Salwasser, Bosworth, & Lowe, 1995)

The objectives of the biological evaluation process are:

1. To ensure that Forest Service actions do not contribute to loss of viability of any native or 

desired non-native plant, or contribute to a trend towards Federal listing of any species.

2. To comply with the portion of the Endangered Species Act that requires that actions of 

Federal agencies not jeopardize or adversely modify critical habitat of federally listed species.

3. To provide a process and standard by which to ensure that threatened, endangered, proposed, 

and sensitive species receive full consideration in the decision making process.

Forest Service Manual 2070.2: Native plants policy objectives

1. Maintain, restore or rehabilitate native ecosystems so that they are self-sustaining, resistant to 

invasion by non-native invasive species and/or provide habitat for a broad range of species 

including, threatened, endangered, and rare species. 

2. Maintain adequate protection for soil and water resources, through timely and effective 

revegetation of disturbed sites that could not be restored naturally. 

3. Promote the use of native plant materials for the revegetation, rehabilitation and restoration of 

native ecosystems.

Forest Service Region Six revegetation policy

Use local native plant species to meet management objectives. Follow appropriate seed and plant 

movement guidelines.

Umatilla National Forest land and resource management plan

The Umatilla NF Land and Resource Management Plan (USDA Forest Service, 1990) includes the 

following goals, standards and guidelines for ecosystem diversity, threatened and endangered and 

sensitive species (TES), and wildlife habitat resources. 
Final Environmental Impact Statement

Pomeroy Ranger District 195

Forest plan goals

Forest Management Goal #6: Protect and perpetuate special areas and related resources for their 

unique values (page 4-2).

Forest Management Goal#11: Maintain or improve habitats for all threatened or endangered plant and 

animal species on the Forest, and manage habitats for all sensitive species to prevent the species from 

becoming threatened or endangered (page 4-2).

Forest Management Goal #13: Provide for a diversity of plant and animal communities and species 

consistent with overall multiple-use objectives. Maintain or enhance ecosystem functions to provide 

for the long-term integrity (stability) and productivity of biological communities (page 4-2).

Forest Management Goal #14: Provide areas for research and education purposes which are typical of 

unique natural ecosystems and are in undisturbed or nearly undisturbed condition (page 4-2).

Methodology

This section describes sensitive plant species, and their habitats, that are documented, or that may 

potentially occur in the planning area. Project design criteria (PDCs) are proposed to protect known 

sensitive plant populations, and to protect potential sensitive plant habitat. Potential direct, indirect, 

and cumulative effects of the alternatives on known sensitive plant populations, and potential 

sensitive plant habitat, are presented. Effects analysis determinations follow definitions as outlined in 

Forest Service Manual 2672.42.

Rather than evaluate effects to so many species individually, this analysis focuses on how potential 

activities may impact habitats that may support sensitive plant populations. Species documented in 

the project area are addressed individually.

Information sources 

A pre-field review determined the probability that sensitive plant populations, and potential sensitive 

plant habitat, are located within, or adjacent to, the project planning area. This information was used 

to determine the need for, and intensity of, botanical surveys.

The following sources of information were used to determine which species, and their respective 

habitats, may occur within, or adjacent to, the project planning area:

• Region 6 Regional Forester Special Status Species List (USFS, 2015)

• USFS GIS mapping layers (vegetation, streams and wetlands, aerial imagery)

• Project GIS layers showing potential activity units

• United States Department of Interior Fish and Wildlife Service (USDI-FWS) website. 

• Forest Service Natural Resource Manager database. This database includes information on where 

botanical surveys have been done on the forest in the past. It also contains information on sensitive

plant populations.

Project Specific Botanical Surveys

Botanical surveys for this project were conducted in accordance with Forest Service recommended 

procedures. Surveys were performed using the intuitive controlled method. This involves selecting 

survey areas based on the potential for ground disturbance, combined with an assessment of the 

potential habitat for rare plants in the areas deemed at greatest risk of habitat disturbance. 
Sunrise Vegetation and Fuels Project

196 Umatilla National Forest

Field surveys were conducted for this project in the summers of 2013 and 2014. Substantial additional 

surveys were conducted in the summer of 2017. Those surveys focused on areas where ground-based

logging and temporary road construction may be implemented. In 2018, additional surveys were done 

specifically in the areas where Spalding’s catchfly is documented near non-commercial thinning 

units.

Incomplete and unavailab+le information

It is impractical to conduct botanical surveys that cover 100% of potential sensitive plant habitat in 

any particular project area. Surveys for this project focused on areas that would experience activities 

that would use ground based heavy equipment. Several skyline based logging units, and most of the 

proposed landscape burn area were not surveyed specifically for this project. Historical surveys are 

not well documented, and the sensitive species list has changed significantly since many of those 

surveys were conducted. Therefore, it is possible that there may be undiscovered populations of 

sensitive plants in activity areas. 

There are very few empirical studies on the impacts of disturbance due to harvest, thinning, and 

burning to most sensitive plant species. The strategy for management of known populations has 

generally been avoidance of activities that may impact populations. Therefore, all discussion of 

potential impacts to sensitive plant populations and habitat is based upon general experience and 

inferred responses based upon personal observations and studies of more common species.

Direct and indirect effects boundaries

The scale of Analysis is the project area (33,150 acres). Since most plants do not move over large 

areas quickly, and no downstream effects are anticipated, it is not necessary to analyze effects to 

sensitive plants outside of the project area. The temporal context for effects analysis includes short 

term and long term effects. Short-term effects are considered to be one to two years after project 

implementation. These would generally be from direct effects such as destruction due to ground 

disturbance from heavy equipment, and incineration from burning. Long term effects for this analysis 

are considered to be more than two years after implementation of all activities. These effects would 

generally be from indirect effects such as changes in sunlight, erosion rates, hydrologic regimes, and 

changes in animal grazing patterns and intensity.

Cumulative effects boundaries

The spatial boundaries for analyzing the cumulative effects to botanical resources is also the project 

area. The temporal boundaries for analyzing the cumulative effects begin at the time of colonization 

by Europeans. The time frame for cumulative effects into the future is approximately 30 years from 

the time the project begins. This is the amount of time that the majority of the actions proposed will 

have been completed and the vegetation response to these actions has occurred.

Indicators used to analyze effects of the proposed actions:

Effects to threatened, endangered, and sensitive (TES) plant species

The United States Forest Service biological evaluation (BE) process was completed for plants by a 

supervisory botanist for this project. This process includes a pre-field review of existing information, 

botanical surveys to search for sensitive plants, and development of project design criteria to protect 

both known sensitive plant populations and sensitive plant habitat. Potential direct, indirect, and 
Final Environmental Impact Statement

Pomeroy Ranger District 197

cumulative effects to the federally listed plant, Spalding’s catchfly, were analyzed. Potential direct, 

indirect, and cumulative effects to Region six designated sensitive plants for Washington State were 

also analyzed. 

Effects Determinations for federally listed, proposed, and candidate species

The possible effect determinations for federally listed plants are outlined in the Section 7 process: 

No Effect (NE). Occurs when a project or activity will not have any “effect” on a listed species or 

critical habitat. Consultation with the USFWS is not required for projects that have no effect.

May Affect – Likely to Adversely Affect (LAA). If the determination in the biological assessment is 

that the project May Affect – Likely to Adversely Affect (LAA) a listed species or critical habitat, 

formal consultation must be initiated (50 CFR 402.12). Formal consultation must be requested in 

writing through the Forest Supervisor (FSM 2670.44) to the appropriate FWS Field Supervisor, or 

NOAA Fisheries office.

May affect – Not Likely to Adversely Affect (NLAA). If it is determined in the biological assessment 

that there are “effects” to a listed species or critical habitat, but that those effects are May affect – Not 

Likely to Adversely Affect (NLAA), then written concurrence by the FWS or NOAA Fisheries is 

required to conclude informal consultation (50 CFR 402.13).

Beneficial Effect (BE).

Effects Determinations for Forest Service sensitive species

The four effect determinations for sensitive plants are:

No Impact (NI). A determination of “No Impact” for sensitive species occurs when a project or 

activity will have no environmental effect on habitat, individuals, a population, or a species.

May Impact Individuals or Habitat, But Will Not Likely Contribute to a Trend Towards Federal 

Listing or Cause a Loss of Viability to the Population or Species (MIIH). Activities or actions that 

have effects that are immeasurable, minor, or are consistent with Conservation Strategies would 

receive this conclusion. 

Will Impact Individuals or Habitat with a Consequence that the Action May Contribute to a Trend 

Towards Federal Listing or Cause a Loss of Viability to the Population or Species (WIFV). Loss of 

individuals of habitat can be considered significant when the potential effect may be:

• Contributing to a trend toward Federal listing (C-2 or C-2 species)

• Results in a significantly increased risk of loss of viability for a species

• Results in a significantly increased risk of loss of viability for a significant population

Beneficial Impact (BI). Projects or activities that are designed to benefit, or that measurably benefit a 

sensitive species should receive this conclusion.
Sunrise Vegetation and Fuels Project

198 Umatilla National Forest

Affected Environment

The federally listed plant Spalding’s catchfly (Silene spaldingii) is documented in the project area. 

There are also five sensitive plant species documented in, or adjacent to, the project area. They are

Arthur’s milkvetch (Astragalus arthurii), green-banded mariposa lily (Calochortus macrocarpus var. 

maculosus), Rollin’s biscuit-root (Lomatium rollinsii), mountain buttercup (Ranunculus populago), 

and Idaho gooseberry (Ribes oxyacanthoides var. irriguum). Of these, only the green-banded 

mariposa lily has been found in areas where there are proposed activities (prescribed burning only).

Virtually every plant habitat has potential for supporting one or more sensitive plant species. The 

botanical report in the project file outlines the various plant communities and identifies which species 

are affiliated with each habitat type.

Environmental Consequences

Direct and Indirect Effects

Alternative A (No Action)

Under Alternative A, the No Action alternative, no new activities would be implemented in the project 

planning area. By definition, direct and indirect effects (40 CFR 1508.8), and cumulative effects (40 

CFR 1508.7) result from the proposed action, and thus are not germane to the No Action alternative.

If the No Action alternative is selected, there would be no direct or indirect effects to sensitive plant 

populations, or potential sensitive plant habitat. If Alternative A is selected, it would lead to an effects 

call of “No Effect” (NE) for the federally listed plant Spalding’s catchfly. There would also be “No 

Impact” (NI) to any Region 6 Washington listed sensitive plant species.

Alternatives B and C

Spalding’s Catchfly (Silene spaldingii)

For both action alternatives, all documented populations of Spalding’s catchfly would be protected 

from all proposed activities. Since the proposed landscape burning is in high potential habitat for 

Spalding’s catchfly, additional surveys would be done in the landscape burn areas before burning 

commences. Special focus would occur in areas where any fire-lines may be dug, and also any areas 

where vehicles may be driven off road for burning and activities.

Since no Spalding’s catchfly plants are within any proposed cutting units, and project design criteria 

would prevent burning or construction of fire-lines through the documented populations, 

implementation of the proposed action would have “No effect (NE)” to Spalding’s catchfly 

populations. In addition, there would be no cumulative effects between the proposed action, the Peola 

or Asotin grazing allotments, or the Asotin Creek prescribed fire project. Therefore, U.S. Fish and 

Wildlife Service (USFWS) consultation for Spalding’s catchfly is not necessary for this project. 

For both of the action alternative, there is no proposed tree cutting, or burning, in any populations of 

four of the documented sensitive species (Arthur’s milkvetch, Rollin’s biscuit-root, mountain 

buttercup, and Idaho gooseberry). Therefore, there would be “no impact (NI)” to documented 
Final Environmental Impact Statement

Pomeroy Ranger District 199

population of these species for either of the action alternatives. Since there is no overlap in time or 

space between any proposed activities and these populations, there would be no cumulative effects

from the action alternatives in relationship to other ongoing or planned activities in the project area. 

Green-banded Mariposa Lily (Calochortus macrocarpus var. maculosus)

Two small populations of green-banded mariposa lily occur in areas that are proposed for landscape 

burning. Implementation of fire in documented populations of the green-banded mariposa lily 

populations would be done in the fall, after the plants have gone dormant for the year. Therefore, 

there would be no, or minimal, direct impacts to the populations. Due to uncertainty of the indirect 

effects of burning (changes in grazing patterns and potential increases in competition from non-native 

invasives), and the many acres of potential habitat that are in areas slated for prescribed burning, it is 

determined that implementation of the proposed action may impact individuals or habitat (MIIH) of 

the green-banded mariposa lily, but will not likely contribute to a trend towards Federal listing or 

cause a loss of viability to the population or species. Since the two populations that occur in proposed 

burn areas overlap with permitted cattle grazing in the Peola allotment, there is a potential for 

minimal cumulative effects due to this project in relationship to ongoing activities. However, since 

these populations represent such a small proportion of the total number of plants in the project area, 

and across the forest and the rest of the species range, these cumulative effects are judged to be 

negligible.

For both action alternatives, the effects call for habitat and any undocumented populations of 

sensitive species affiliated with low to moderate elevation cliffs, rock outcrops, talus slopes, and 

riparian or wetland habitats is no impact (NI). This is because there are no ground disturbing activities 

proposed in these habitat types, and any fire that may occur would be low intensity, and would not 

negatively impact undiscovered populations that may be there. No heavy equipment would be used in 

aquatic and riparian dependent communities, and no mechanical slash piling would be allowed in 

those areas. 

For both action alternatives, the effects call for habitat and any undocumented populations of 

sensitive species affiliated with lithosols and grasslands is may impact individuals or habitat (MIIH), 

but will not likely contribute to a trend towards Federal listing or cause a loss of viability to the 

population or species Construction of temporary roads may occur in some of these upland nonforested habitats. Botanical surveys and PDCs to avoid impacts to known populations would protect 

any currently undocumented populations that would potentially be impacted by road construction 

activities. The uncertainty about potential indirect effects of the interactions of burning and nonnative invasive plants, and the inherent inability to survey 100% of proposed burn areas in grasslands, 

led to the overall call of MIIH, but will not likely contribute to a trend towards Federal listing or 

cause a loss of viability to the population or species for lithosol and grassland habitats.

The species with greatest risk due to project activities from both action alternatives are those that 

occur in upland coniferous communities. The effects call for all sensitive plant species that occur in 

these upland forested areas is MIIH, but would not likely contribute to a trend toward federal listing 

or cause a loss of viability to populations of sensitive plant species. The risk to upland coniferous 

communities is derived mostly from the use of heavy equipment. The ground disturbance associated 

with the use of equipment has a relatively high potential to negatively affect upland coniferous forest 

habitats and associated soils. In addition, indirect effects of altered hydrologic regimes, increased 

light, and changes in grazing patterns also contribute to the call of MIIH, but would not likely 

contribute to a trend toward federal listing or cause a loss of viability to populations of sensitive plant 

species. 
Sunrise Vegetation and Fuels Project

200 Umatilla National Forest

The calls for both action alternatives for each sensitive plant population and potential habitat are the 

same. However, the relative risk to the various habitats (especially the coniferous forest habitats) is 

less for Alternative C than for Alternative B. This is due to the fact that Alternative C proposes 

significantly less ground disturbance and changes in tree canopy cover than is proposed in Alternative 

B.

Cumulative Effects

Alternative B and C

The time scale for this cumulative effects analysis covers the span from 1880, coincident with when 

significant mining and sheep grazing began to alter the area, to 2045 – 30 years into the future. It is 

thought that the 30-year timeline into the future should account for the potential of increasing 

temperatures and reduced moisture that are expected to occur if climate change proceeds as predicted. 

With the exception of small-scale projects such as stream enhancements and local meadow restoration

efforts, it seems likely that for the next 30 years that this project would be the only landscape-scale 

project implemented by the Forest Service in the area. If a large wildfire were to impact the area, is 

likely that danger tree and possible salvage operations might be implemented. These activities would 

add an element of added disturbance, possibly significantly so, to some of the planning area. This is

in addition to the effects of the fire itself.

It is highly likely that historical activities, particularly intensive cattle and sheep grazing, and timber 

harvest, mining activities, road construction, and fire suppression activities have destroyed 

populations, and altered habitats for sensitive plants. Since records of rare plant populations have only 

been kept for the last thirty years, historical effects are not quantifiable.

Since 1990, protection and management of sensitive species and their habitats in the form of project 

design features, avoidance, or other mitigations have been included in nearly all projects. This is in 

accordance with forest planning documents and policy set forth in FSM 2670. These policies have, 

and would continue to, reduce the potential of cumulative effects to sensitive plant populations and 

supporting habitats. Although some unquantifiable amount of cumulative effects are likely, it is 

assumed that they won’t be of a magnitude that will contribute a trend towards federal listing of 

sensitive plants.

Determination of Effects to Threatened, Endangered or Sensitive Plant Species

Federally listed plant, Silene spaldingii

There are no cutting activities proposed within 100 feet of any Spalding’s catchfly plants. .In 

addition, there is not landscape burning proposed for this project in any populations of Spalding’s 

catchfly. Project design criteria also ensure that there will be no construction of fire-lines within 100 

feet of Spalding’s catchfly plants. Therefore, implementation of the proposed action would have “No 

effect” to Spalding’s catchfly populations. No consultation with the U.S. Fish and Wildlife Service is 

necessary for this project.
Final Environmental Impact Statement

Pomeroy Ranger District 201

Region 6 Washington sensitive Plants

A determination of “No effect” or “may impact individuals or habitat, but will not likely contribute to 

a trend towards Federal listing or cause a loss of viability to the population or species” was given for 

all documented and potential sensitive plant species for this project. 

Irreversible and Irretrievable Commitment of Resources

For all action alternatives (B and C) there would be no irreversible or irretrievable commitment of 

resources with implementation of proposed activities.

Final Environmental Impact Statement

Pomeroy Ranger District 203

3.13 Invasive Plants

Introduction

Flora not known to exist in the Pacific Northwest prior to Euro-American settlement, but which 

readily displace native vegetation in disturbed or undisturbed sites are considered “invasive” for 

purposes of project effects analysis. The analysis also utilizes two broad categories of invasive plants, 

each considered in a different manner. Higher-priority invasive plants are those which regularly 

receive treatment under the 2010 Invasive Plants Treatment Project Record of Decision. Those

species include rush skeletonweed, spotted and diffuse knapweed, high-density patches of yellowstar 

thistle, Canada, scotch, and bull thistle, gypsy flower, dalmatian toadflax, and sulfur cinquefoil. 

Lower-priority species do not receive regular control treatments due to low density, wide distribution

at present, low impacts on native flora and fauna, and/or difficulty of control. Lower-priority species 

include cheatgrass, medusahead, and ventenata. 

The relative risk of displacement and invasion brought about by higher-priority invasive plant 

introduction and/or site disturbance is broadly described in this section as “low,” moderate,” or 

“high.” In and of themselves, these terms do not quantitatively describe the exact probability that a 

particular species would become established as a result of human activities, because such 

quantification is essentially impossible. The intent of such classification, rather, is to allow 

comparison between alternatives and describe risk in qualitative but site-specific terms, and in ways 

useful to managers and decision-makers seeking to identify potential detrimental environmental 

effects and possible mitigation measures. 

Regulatory Framework

Invasive plants are defined as “a non-native plant whose introduction does or is likely to cause 

economic or environmental harm or harm to human health” (Executive Order 13122).

The 1999 Executive Order on invasive species (direction found in Forest Service Manual 2080), and 

the National and Regional strategies for noxious weed management identify prevention as the 

preferred strategy for managing invasive plant species on National Forest Service lands. 

The Sunrise project is intended to comply with the existing management direction, including the 

Invasive Plants Treatment Project EIS (decision July 2010). The portions applicable to the Sunrise 

project include prevention standards that are incorporated in Chapter 2 and found in the Invasive 

Plants specialist report.

Methodology

Treatment and monitoring are expected to be completed in conjunction with the activities included 

under Alternatives B and C. Treatment and monitoring would be conducted by the Noxious Weed 

Coordinator and other personnel on the Pomeroy Ranger District.

All of the known priority 1 noxious weed sites within the Sunrise project area were scheduled for 

herbicide treatment during 2015 and will have follow up treatments as prescribed in the Umatilla 

National Forest’s Invasive Plants Treatment Project (EIS), decision dated July 2010 and consistent 

with the 2005 Region 6 Invasive Plant ROD that amended the Umatilla Forest Plan in March 2006.
Sunrise Vegetation and Fuels Project

204 Umatilla National Forest

Inclusion of a number of design criteria in project activities will help to reduce the risk of invasive 

species introduction and spread. The criteria are intended to minimize ground disturbance and the 

exposure of mineral soils, reduce the introduction of weed seed into areas where ground disturbance 

is occurring, minimize the moving of any weed seed that already exists in planning area soils, and to 

re-establish weed-free ground cover as quickly as possible after any ground-disturbing activities. Past 

Forest Plan monitoring and annual evaluation reports have documented the effectiveness of these 

measures.

Affected Environment

Scale of Analysis

The geographic scale of this analysis is the 32,000-acre Sunrise project area. The temporal scale is 

bounded in the past by the earliest known period in which activities would have affected invasive 

plant establishment and distribution in ways that persist today (existing condition), and which have 

the potential to overlap in space and time with the direct and indirect effects of the activities included 

in Alternatives B and C. Because out-year planning efforts typically include a 5-year timespan, and 

harvest activities are expected to last 3 or more years, the temporal boundary of this analysis would 

also be approximately 8 years in the future (year 2025).

The majority of acres (30,720) in the Sunrise project area are currently at a low risk for noxious weed

invasion. Approximately 1,810 acres are at a moderate risk, and 760 acres are at high risk. Weed 

infestations planned for treatment in the Umatilla National Forest Invasive Plants Treatment Project 

Environmental Impact Statement and Record of Decision (July 2010) and currently documented in 

the national Natural Resource Inventory System (NRIS) database include 11 species occurring 

separately or in combination at 51 sites on Forest Service land within the Sunrise planning area, 

covering approximately 1,250 acres (Table 63). 

Table 63. Extent of higher-priority invasive plants known to occur within approximately 1 mile of the

Sunrise planning area. Lower priority species are assumed to be widely distributed across grassy sites 

within the project area. 

Common name Infested acres

Rush skeletonweed 260

Spotted knapweed 470

Diffuse knapweed 200

Canada thistle 65

Bull thistle 74

Scotch thistle 407

Gypsy flower 257

Dalmatian toadflax 32

St. Johnswort 38

Sulphur cinquefoil 253

Yellowstar thistle 280

Note: Acres are rounded to the nearest 10 acres. The acre total in this table differs from the total described above because 

inventory polygons may contain more than one species. 
Final Environmental Impact Statement

Pomeroy Ranger District 205

Environmental Consequences

Direct and Indirect Effects

Alternative A (No Action)

The No Action alternative does not include any activities related to the Sunrise project. The spread of 

invasive plants from currently existing populations and off-Forest seed sources is not expected to be 

extensive, as existing populations, both on and off-Forest, are relatively small and isolated. Although 

some species of lower-priority for treatment are extensive across the gransslands in the project area, 

invasive plant density is highly variable, ranging from trace populations to near-monocultures in 

small, isolated areas. See the botany section of this document for futher information on the relative 

abundance of native and non-native species in the project area.

Because there are no activities associated with Alternative A, there are no effects associated with 

activities. Nevertheless, failing to reduce existing fuels, in combination with reasonably foreseeable 

future fire suppression, means that future fires would burn at high intensity and severity in some 

areas, and likely to a greater extent than under Alternative A or B.

Direct and Indirect Effects

Alternatives B and C

Inspecting activity areas and haul routes before and during activities is expected to reduce any 

increase in weed infestations caused by the spreading of new seed, even if prevention measures are 

not 100% effective. These prevention measures would not affect spread of any older seed that may be 

present in the soil seedbank in the vicinity of pre-existing populations. It is not possible to calculate 

exact acreage reductions resulting from these weed treatments. However, the reductions in areas at 

risk would be proportional for each action alternative.

Invasion of an area by noxious weeds is known to be facilitated by ground disturbance, loss of plant 

cover, disruption of functioning native plant communities, and the presence of a weed seed source 

(Keeley 2004; R6 FEIS 2005). When addressing the spread of invasive plant species, it is impossible 

to accurately predict spread rates or exact locations of expanding weed populations; however, it is 

more feasible to assess the relative spread risk of various activities based on the degree of ground 

disturbance involved, and the proximity of existing weed populations that act as seed sources.

Using the methodology described above, levels of noxious weed infestation risk expected to occur as 

a result of implementing the activities included within action Alternatives B and C were allocated 

across the Sunrise planning area (Table 64). The purpose is not to predict the actual number of acres 

that may become infested, but to show the comparative risk of the different activities and alternatives.

The effects of implementing activities included under Alternative B or C on spatial distribution 

invasion risk-classes for non-native, higher-priority are indicated in Table 64 below. 

Table 64. Low, medium, and high levels of risk to noxious weed invasion for Alternatives B and C (acres). 

Risk Level Alternative A Alternative B Alternative C

Low 30,720 20,960 23,820

Moderate 1,810 10,440 8,090

High 760 1,890 1,390
Sunrise Vegetation and Fuels Project

206 Umatilla National Forest

Alternative B results in the highest number of moderate and high risk levels for higher-priority 

species, because the total area experiencing a ground disturbance is highest. Conversely, the extent of 

areas with a moderate and high risk level is lowest under Alternative A, because the total area 

experiencing a ground disturbance as a result of human activities is the least. 

A brief literature review of effects associated with ecosystems and activities included in Alternatives 

B and C for lower-priority species are summarized in Table 65. In general, Alternative B would have 

greatest risk of lower-priority species invasion, because burning activities are the same for each action 

alternative, but tree-cutting and related ground-disturbing activities are more extensive under 

Alternative B. Experience with long-term monitoring in similar grasslands suggests that the near-term 

consequences would be for the density and distribution of lower-priority species to wax and wane 

across the landscape as various species compete for resources prior to and following recurring 

disturbance events. 

Table 65. General effects of selected vegetation species in response to fire disturbance. 

Species Fire response Study Misc. Notes

Yellowstar thistle 

(Centaurea solstitialis)

Neutral Bushey 1995 Existing plants and seed on soil surface killed by 

heat, but able to quickly re-colonize

Yellowstar thistle 

(Centaurea solstitialis)

Negative Zouhar 2002; Roche and 

White 2000; Martin and 

Martin 1999

Repeated, early-season burns are required for 

successful depletion of seed bank and control.

Yellowstar thistle 

(Centaurea solstitialis)

Modest, 

sustained 

increase

USDA Forest Service Fire 

Effects Information System 

database: yellowstar 

thistle. Accessed February 

3, 2016.

A single mid or late-season fire usually kills most 

plants, but creates conditions for aggressive 

colonization and growth. Effects of heat on seed 

viability has not been studied.

Cheatgrass (Bromus 

tectorum)

Initial reduction, 

quickly reaches 

pre-burn levels

Youtie et al. 1998 Moderately intense fire; consumed cheatgrass 

and medusahead seeds. Natives were FEID and 

PSSP

Cheatgrass (Bromus 

tectorum)

Variable over 

space and time

USDA Forest Service Fire 

Effects Information System 

database: cheatgrass.

Accessed February 3, 

2016.

A single mid or late-season fire usually kills most 

plants, but creates conditions for aggressive 

colonization and growth. Cheatgrass is a 

particularly strong competitor in the post-fire 

environment and quickly increases to occupy 

growing space made available by the burn. If 

other species, including native bunchgrasses 

quickly re-occupy a site as well, cheatgrass would

not likely dominate.

Cheatgrass (Bromus 

tectorum)

Variable over 

space and time

USDA Forest Service Fire 

Effects Information System 

database: cheatgrass.

Accessed February 3, 

2016.

Cheatgrass response to fire depends on plant 

community and seed bank composition, density, 

and spatial distribution; season of burning; fire 

severity, frequency and patchiness; scale of 

consideration; post-fire management; and climatic 

conditions. Generalizations are difficult because 

each combination of climate, vegetation, and soil 

must be considered separately, as well as 

environmental differences at the time of burning 

and during subsequent plant reestablishment.
Final Environmental Impact Statement

Pomeroy Ranger District 207

Species Fire response Study Misc. Notes

Cheatgrass (Bromus 

tectorum)

Negative Antos 1983 Cheatgrass dominance may be avoided on sites 

that have sufficient cover of native perennials, 

proper management of livestock, and favorable 

climatic conditions for post-fire recovery. Three 

years after a severe wildfire on an ungrazed 

foothill mountain grassland in western Montana, 

cheatgrass cover was lower in burned patches 

than in unburned patches, and cheatgrass 

showed no indication of invading the burn. At that 

time Idaho fescue and bluebunch wheatgrass 

cover were similar to unburned levels, and rough 

fescue cover was slightly below unburned levels.

Medusahead rye

Taeniatherum caputmedusae

Temporary 

increase

No known studies in 

literature

Professional experience in the vicinity indicates 

that medusahead rye typically increases in 

density and site occupancy following fire, likely for 

an extended period of time, but studies describing 

long-term effects may be lacking. 

Spotted knapweed 

Diffuse knapweed 

(Centaurea spp.)

Data are 

insufficient to 

draw firm 

conclusions for

different burn 

seasons and 

severities.

USDA Forest Service Fire 

Effects Information System 

database: Spotted and 

diffuse knapweed. 

Plants readily re-sprout after fire and are 

aggressive colonizers.

Rush skeletonweed 

(Chondrilla juncacea)

Increase USDA Forest Service Fire 

Effects Information System 

database: rush 

skeletonweed. Accessed 

February 3, 2016.

Plants readily re-sprout after fire and are 

aggressive colonizers generally, but post-fire 

colonization is not well-understood.

St. Johnswort 

(Hypericum perforatum)

Temporary 

increase

USDA Forest Service Fire 

Effects Information System 

database: Common St. 

Johnswort. Accessed 

February 3, 2016.

Fire seems to benefit the species, but St. 

Johnswort often competes poorly against vigorous 

bunchgrasses

Prickly lettuce (Lactuca 

serrioloa)

Temporary 

increase

Haskins and Gehring 2004; 

Turner and others 1997; 

Armour and others 1984; 

Youngblood and others 

2006; Sutherland, 

unpublished data 2008; 

Floyd and others 2006

Successfully colonizes burned sites but most 

studies report decreases over 2-10 years.

Scotch cotton thistle 

(Onopordum acanthium)

Initial increase, 

generally 

decrease over 

time

Professional opinion; 

anecdotal observations

In isolated cases, known to successfully colonizes 

some burned sites and can persist for many 

years. Generally not an aggressive persistent 

invader in this area.

Sulfur cinquefoil 

(Potentilla recta)

Neutral or 

increase

Bushey 1995 Tap-rooted, long-lived perennial able to quickly resprout after fire. Able to quickly colonize a site.

Cumulative Effects

Alternative A (No Action)

For the No Action alternative, the Sunrise project would not be authorizing any actions; therefore it 

would not be adding anything to the effects of past, present, and reasonably foreseeable future 

actions. Based on the definition provided in the CEQ regulations (p. 3-1), there would be no 

cumulative effects for the No Action. 
Sunrise Vegetation and Fuels Project

208 Umatilla National Forest

Alternatives B and C

Existing infestations are a result of past ground disturbing activities with effects that overlap in space 

and time with the direct and indirect effects of the activities proposed under each of the action 

alternatives. Domestic livestock and wildlife can spread invasive plant seeds throughout the planning 

area. The project area includes an active cattle allotment (see Range section) with a season of use 

from mid-June through mid-October. As a result, cattle are within the planning area when seed 

maturity occurs and likely serve as a vector for seed spread. There would likely be some level of 

cumulative effects associated with cattle grazing and activities associated with this project. Those 

effects could include the spread of existing infestations and the establishment of new invasive species, 

but precise quantification of spread risk is very difficult and uncertainty is extremely high. 

Design criteria would reduce the cumulative effects, they would likely not be eliminated; however, 

grazing activities in Asotin and Peola C&H grazing allotments are managed to reduce detrimental 

impacts on soils and native plant communities and minimize opportunities for invasive plant 

establishment outside of road corridors. As a result, grazing activities in Asotin and Peola C&H 

grazing allotments are not likely to expand areas of moderate or high risk above and beyond what is 

expected to occur as a result of implementing actions included under any of the alternatives of the 

Sunrise project.

Low risk of spread does not equate to zero risk. The spread of invasive plants from currently existing 

populations and off-forest seed sources would continue at the current level. Animal and vehicle 

vectors would likely be the primary means of seed introduction into the planning area. The following 

past, present, and reasonably foreseeable future actions were considered, but, for the reasons cited, 

did not alter the calculations of acreages in the high and low risk categories for weed spread.

The following items may increase the potential for invasive plant species establishment and spread, 

but are not expected to cumulatively increase the amount of areas considered as high risk to invasive 

plant establishment because they occur along roadways, which are already classified as high risk. 

However, acreage placed at high risk from these activities is speculative, so are not evaluated 

numerically.

Larger vehicles traveling away from roadbeds can increase potential weed habitat by disturbing 

and/or compacting soils, and by damaging and weakening existing vegetation. They can also carry 

and disperse weed seed wherever they go. While system roads are mapped, and can be efficiently 

patrolled for detection and treatment of associated weed populations, any infestations along 

unauthorized, user-built roads are less likely to be rapidly found and treated. Acreage where this may 

be occurring is unknown.

The use of OHVs away from designated roadbeds or trails raises concern for invasive species spread, 

but these activities are not expected to occur outside areas currently mapped as high risk to invasive 

plant establishment. While OHVs cause less ground disturbance than larger vehicles such as pick-ups, 

they can access more varied terrain. If used for unauthorized cross-country travel they can act as 

wide-ranging seed dispersal vectors, potentially introducing weed infestations into remote and 

seldom-frequented sites. The amount of unauthorized land use by vehicles is unknown, but it is 

apparent that at least some such use occurs in portions of the planning area, increasing the risk of 

spreading invasive species to remote spots where they are not easily detected or treated.
Final Environmental Impact Statement

Pomeroy Ranger District 209

Irreversible and Irretrievable Commitment of Resources

For all action alternatives (B and C) there would be no irreversible or irretrievable commitment of 

resources with implementation of proposed activities.

Final Environmental Impact Statement

Pomeroy Ranger District 211

3.14 Visual Resources (scenery)

Introduction

The scenery resource report analyzes the project effects to the scenery resources that are comprised of 

the positive elements of the natural appearing and culturally valued landscape. The indicator used to 

measure the effects to scenery resources is visual quality. Visual quality is an indicator of the desired 

level of excellence based on the physical and sociological characteristics to an area and refers to the 

degree of acceptable alteration of the characteristic landscape. Visual alterations are those that detract 

from the natural appearing landscape such as straight linear features, geometric forms, and colors that 

contrast with the natural landscape. The effects that are measured are those that are visible from the 

viewing platform that is designated by the Forest Plan as a sensitive travel route. The PomeroyGrouse Flat Rd, Forest Road 40 is the viewing platform from which the scenery resource analysis is 

analyzed. 

Regulatory Framework

The National Environmental Policy Act of 1969 (NEPA) states that it is the “continuing responsibility 

of the Federal Government to use all practicable means to assure for all Americans, aesthetically and 

culturally pleasing surroundings.” NEPA also requires “A systematic and interdisciplinary approach 

which would insure the integrated use of the natural and social sciences and the environmental design 

arts into planning and decision-making which may have an impact on man’s environment.” To 

accomplish this, numerous Federal laws require all Federal land management agencies to consider 

scenery and aesthetic resources in land management planning, resource planning, project design, 

implementation, and monitoring. 

Integration off this scenery analysis assures the Sunrise project is consistent with scenery-related 

Forest Plan direction, Forest Service policies, and applicable elements of Forest Service Visual 

Management and Scenery Management systems. 

Methodology

The viewshed from FSRD 40 is analyzed to determine visibility from bare earth modeling. A 

viewshed analysis is utilized to determine visibility by using a digital terrain model to determine what 

is visible from points located on the route at 1⁄4 mile intervals. An offset from ground level of 6 feet is 

used to assimilate the height of a human standing on the road or riding in a tall vehicle. (Visibility 

acreages are determined by use of digital terrain modeling known as “bare earth modeling” that does 

not take into account and screening from remaining trees or shrubs. It is a worst case scenario and 

visual impacts will not occur on all visible acres. The acreages calculated for visibility will high and 

the visible acreage shows potential for impacts related to management activities, rather than visible 

acres of impact.) 

Google Earth, and field observation were also used, and it has been determined that there are very few 

opportunities to see into the project area from FSRD 40 due to terrain and vegetation in the 

foreground. 

Along with visibility, the discernibility of the impact from various distance zones is considered by use 

of distance zones: foreground (0 to 1⁄2 mile) fg, middleground (1/2 to 3 miles) mg, and background (3 

miles to 5 miles+) bg. There are other factors that affect discernibility such as the angle of view, and 

duration of view. 
Sunrise Vegetation and Fuels Project

212 Umatilla National Forest

Foreground impacts that expected to be discernible are impacts such as individual tree stumps and 

slash. From middleground distances, texture is normally characterized by the masses of trees in stands 

of uniform tree cover. Individual tree forms are usually only discernible in very open or sparse stands. 

From background distances, texture is difficult to discern in continuous forest landscapes. In very 

open or sparse timbers stands, texture is seen as groups of patterns of trees. Ground disturbance is 

apparent if seen from direct angles and are contiguous and linear. (Ag Handbook 462, pg. 7)

Visual Quality Objectives are used as measures of acceptable alteration within the Forest Plan

standards and guides. In this project area the visual quality objective for the foreground view is partial 

retention, and in middleground views, the visual quality objective (VQO) is modification. The Partial 

Retention VQO states that management activities remain visually subordinate to the characteristic 

landscape. It is expected that the project impacts meet the VQO within the first year following the 

conclusion of the project harvest activities. The Modification VQO states that management activities 

may be visually dominate the original characteristic landscape but must borrow from the naturally 

established form line color or texture.

The effects analysis considers the impacts of the vegetation management treatments and the harvest

activities that are utilized to carry out those treatments. 

Affected Environment

Scale of Analysis

The geographic area or spatial bounds for the cumulative effects to scenery resources is determined 

by typical experience of the viewers. There are local viewers who utilize the Sunrise project area for 

various recreation experiences and there are travelers who experience the area as they travel through 

via the Pomeroy-Grouse Rd, Forest Road 40. The visual experience is the forested setting of Sunrise 

project containing the entire Asotin Creek Inventoried Roadless Area (IRA) and is adjacent to 

Wenatchee and Tucannon IRAs. The project area is adjacent to private property on the eastern 

boundary and includes a section of land owned by the Washington Department of Natural Resources 

and portions of sections owned by Washington Department of Fish and Wildlife that are located 

within the project area (no activities are proposed on WDNR or WDFW land). This geographic 

boundary is determined by the viewing distance to which treatments can be visually discerned and the 

setting in which the project is within. 

The temporal bounds are related to the longevity of visual impacts of the reasonable and foreseeable 

activities in the geographic boundary. Visual impacts that can be discerned from a middleground to

background viewing distance are of such scale that the effects could overlap spatially therefore these 

are the visual impacts to be considered. Timber harvest that creates unnaturally shaped or sized 

opening via clearcutting or textural contrasts that are not in keeping with the historical range of 

variability are generally used as examples of harvest effects that may temporally overlap. Once an 

opening has revegetated and reached a height of 20 feet, the visual impact has been mitigated or 

restored. Within this area the height of 20 feet can be reached within 20 to 30 years depending on the 

topography, aspect and climate. Therefore, 30 years is the temporal bounds for the cumulative

analysis of effects.

The project area sits at the upper reaches of the Asotin River drainage that runs east, north east. The 

area covers the upper plateau and also drapes down into the draws of the Asotin River Drainage. The 

draws are timbered with views of previous harvest units being very apparent from secondary roads. 

Primarily viewed from Forest Road 40, the Pomeroy-Grouse Flat Road that runs along the eastern rim 
Final Environmental Impact Statement

Pomeroy Ranger District 213

of the Tucannon River drainage. However, the primary views are limited from Forest Road 40. 

Foreground timber and topography screen much of the middleground areas from view. Along the road 

there are some areas of open grassy areas while the timber stands are quite dense. In some views there 

is visual evidence of past harvest activity where units stand out as an unnatural appearing rectangular 

form and strong distinct edges. The visual quality ranges from partial retention to maximum 

modification from secondary views (views from routes that are designated as sensitive routes).

Visual Quality

Visual Quality is measured on the Umatilla National Forest through Visual Quality Objective levels 

defined by the USFS Visual Management System’s Chapter 1 USDA Handbook # 462. These levels 

and descriptors of how people perceive them are shown in Table 66. 

The existing visual quality varies from partial retention to modification. The area currently shows 

signs of harvest activity, much like a patchwork quilt with varying degrees of thinning and cutting of 

various sized and shaped units. The landscape topography is not a uniform canvas, but dissected by 

drainages that provide an array of slopes angling in various directions. 

Views within the foreground of the Forest Road 40 show some signs of harvest activities. There are 

stumps remaining visible from previous harvest activities, and there are remnants of skid trails in 

some units along the road, but the visible impact is minimal and do not detract from the natural 

appearance of the foreground views, meeting the visual quality objective of partial retention. 

Table 66. Visual Quality Objectives and definitions

Visual Quality Objective Visual Quality as people perceive it

Preservation Unaltered , visually complete or intact

Retention Unnoticeably altered

Partial Retention Slightly altered

Modification Moderately altered

Maximum Modification Heavily altered

Unacceptable Modification Unacceptably altered

Views from middleground distances show management activities that dominate the natural landscape. 

Slopes are often broken up visually by large harvest units reaching from the top of the ridge to the 

edge of the riparian buffer, and alternate with remaining timber stands from one end of the drainage to 

the other. Many of the previous harvest units have straight line edges that appear unnatural. The scale 

of many of the existing harvest units are larger than natural openings. These impacts dominate the 

natural appearing scenery, meeting modification.

Sensitive routes and areas

The route identified in the Forest Plan as a viewshed for visual concerns and potentially affected by 

the Sunrise project is Forest Road 40, the Pomeroy- Grouse Flat Road. The views from Grouse Flat 

Road are varied in foreground, and middleground and background views into the project from the 

road prism platform looking into the project area from the southern edge. Some views into the Asotin 

drainage are afforded where the road traverses the edge of the head of the draw. 
Sunrise Vegetation and Fuels Project

214 Umatilla National Forest

Age Class and Structural Stages within Partial Retention

The desired mix of age classes within foreground partial retention is 20% for each of the following 

age classes, as determined by the Forest Plan. The existing, extent and proportion of foreground area 

are shown in Table 67. 

Absent high-severity disturbances in the seen-area foreground, all age classes are trending towards 

desired conditions, except the 0-36 age class, which is roughly analogous to the stand initiation 

structural stage. 

Table 67. Seen foreground age classes with Partial Retention Visual Quality Objective

Age 

class

Existing 

acres

% of total

Long-term trends and causes

Existing Desired

0-36 211 16 20

Decreasing: more areas are expected to leave this class than enter it, 

over time, because a lack of high-severity disturbance prevents 

recruitment into the class. 

37-72 454 35 20

Decreasing: more areas are expected to leave this class than enter it, 

over time, because only about half the acres are available from the 0-

36 year class. 

73-108 631 48 20

Decreasing: more areas are expected to leave this class than enter it, 

over time, because only the pool of acres expected to recruit into this 

class are only about 60% of the acres expected to transition away 

from this class.

109-181 18 1 40

Increasing: existing forest ages in the analysis area suggest that many 

more acres would enter this class than leave it, absent high-severity 

disturbances. Most stands in the area are much less than 181 years 

old. 

Visibility

The visibility analysis is a detailed, site-specific look at the viewshed using “bare earth modeling,” 

without taking into account the vegetation that screens much of the area beyond foreground views. 

Table 68 shows the acres in the project are that are visible by Visual Quality Objective. 

Table 68. Visible Acres by Visual Quality Objective.

Visual Quality Objective Total 

Acres

Total 

Visible

Percent 

Visible

Partial Retention 7544 667 8%

Modification 9195 1905 20%

Maximum Modification 15398 1746 11%

 

The areas that are more likely to be seen are the foreground areas (707 acres). Of those foreground 

acres, 266 acres designated Partial Retention, and 426 are designated as Modification. Visible 

treatment acres will be disclosed by alternative in the Effects Analysis.

Created openings

Created openings were designated by identifying forest areas in the stand initiation structural stage. 

The stand initiation stage was used as an analogue for created openings because the dominant canopy
Final Environmental Impact Statement

Pomeroy Ranger District 215

height of forests in this stage are generally less than 20 feet, which is the standard for created 

openings for the A4 Management Area. The extent of visible (from Forest Road 40) created openings 

in the foreground and middleground with a Partial Retention Visual Quality Objective is described in

Table 69. The percentage of forest in created openings relative to total seen foreground and 

middleground areas managed with a Partial Retention Visual Quality Objective is described in Table 

70. 

Table 69. Created Openings

Area in created openings (acres)

Location Harvest acres

Acres of Partial Retention

in viewshed

Foreground 21 1,608

Middleground 9 2,931

Total 30

Table 70. Created Openings in Even and Uneven-aged Systems

Even and Uneven-aged Silvicultural Systems

Max percent harvest/decade

foreground 4

middleground 0.1

Max percent of area in 

created openings post-harvest

foreground 1

middleground 1

Environmental Consequences

In this section, the direct, indirect, and cumulative effects of Sunrise project management Alternatives 

on visual resources are discussed for Alternative A, and in combination for Alternatives B and C. Past, 

present, and reasonably foreseeable future activities are incorporated together in the assessment of 

existing conditions and effects associated with the Sunrise project.

Direct and Indirect Effects

Alternative A (No Action)

Because there are no activities associated with Alternative A, there would be no effects from the No 

Action Alternative. The indirect effects would include continued visual impacts that need to be 

rehabilitated where prior harvest units stand out against the surrounding timber stands. The age 

class/structural stage mix trends would continue to decrease in stand initiation and stem exclusion 

while understory reinitiation and old forest stages would likely increase slightly. The existing visual 

quality would remain at maximum modification to partial retention with visual elements that detract 

from the natural landscape and dominate views. 
Sunrise Vegetation and Fuels Project

216 Umatilla National Forest

Alternatives B and C

The visual quality objectives of the project area would be maintained by all alternatives. The project 

proposed harvest would help blend with prior harvest units and give the area a more natural 

appearance overall by treating areas adjacent to these prior harvest units in a manner that transitions 

the density of adjacent stands to reduce the stark line between clearing and dense forest. The project 

would meet the visual quality objectives of the Forest LRMP. The expected effects related to the 

vegetation treatments and harvest methods are described in general here, followed by brief discussion

of the visibility and effect analysis.

Intermediate vegetation treatments open stands up creating a texture difference in middleground 

views, making the units appear less dense, with clumps of trees of the preferred species, sizes, and 

crown condition. The effect is expected to create a natural-appearing mosaic with variable levels of 

residual density. Regeneration vegetation treatments create openings that create a larger scale mosaic 

while still appearing natural, but with more of a change from existing density and texture. Unit edges 

are scalloped and feathered to soften the edge appearance and avoid straight linear forms and 

shadows.

Logging systems result in varying visual impacts. Ground-based operations create ground 

disturbances such as duff and soil disturbance from tracked vehicles, skid trails and skyline corridors. 

Log landings are located in large openings that are used for continuous vehicular use, turning and 

moving to receive, stack, and load logs on trucks. Visual disturbances caused by harvest activity are 

expected to be reduced by design features addressing occurrences such as gouging by dragging logs. 

By suspending the butt end while dragging the logs, gouging in skid trails does not occur. Harvest 

activities are limited seasonally to times of dry soil conditions to avoid rutting from equipment. Slash, 

duff and biomass is retained to encourage vegetation recovery. Stumps are cut in foreground areas of 

Forest Road 40 are to be cut at a height less than 6”. These disturbances are primarily foreground 

impacts, discernible within 0-1/2 mile, and more extensively within the immediate foreground 

(300ft), lasting for a short duration. Past experience in nearby areas suggests that within one to two 

growing seasons, shrubs and forbs usually recover, breaking up the visual elements of linear 

disturbances and color contrast of exposed soils.

Fuels Treatments include prescribed burning, landing pile burning and grapple pile and burn. The 

expected burn unit affects are expected to be notable but appearing as natural occurrences, burning at 

varied severities, and creating small mosaics, primarily by underburning the ground layer vegetation 

and saplings with some small pockets of mortality. The expected effects for piling and burning are 

minimal, limited to the landing locations primarily, with a large pile burned within a year of the end 

of the harvest contract. This is a short term with positive visual effects on slash left by tree-cutting 

and pruning activities. Landings would not be visible from Forest Road 40. Some mastication is 

planned, however these areas would be in middleground and background viewing distances where it 

is not expected to be discernible.

The visibility from Forest Road 40 of the project area is limited primarily by local topography. The 

road travels along the rim looking down into the Tucannon River drainage to the west while the 

project area is to the east of the road. Often, ridges, knolls, and small hills limit views from the road 

into the project area. There are 7782 acres of proposed treatment units. Of those, 2073 acres are 

determined to be visible by the viewshed analysis using a bare earth digital terrain model. This model 

does not account for timber stands in the foreground that would screen most of the area beyond the 

foreground stands. 
Final Environmental Impact Statement

Pomeroy Ranger District 217

The views that provide visual access to middleground views are often of existing past harvest units 

that appear blocky and unnatural. Alternative B proposes units that are adjacent to many of these units 

and would create a more uniform appearance and reduce contrast between existing plantations and 

adjacent unharvested stands. Foreground views are a mix of timber stands and small openings with 

high plateau grasses. Alternative B is expected to reduce stand density in many locations and in some 

areas create small (generally less than 1⁄2 acre in size) openings, thereby creating diversity in the 

roadside views. 

The areas that are most likely to be viewed are the foreground acres along Forest Road 40, which are 

approximately 760 acres. These foreground acres would be opened up to varying degrees, addressing 

structural stage and species composition objectives. Harvests in the foreground would occur with 

variable levels of retention and sizes of retained trees, with an emphasis on retaining the largest trees 

of desirable species and crown characteristics. Tree-cutting activities would generally resemble a 

thinning with the foreground retaining a moderate density level in most areas, but small openings 

would be created in some units along Forest Road 40. Table 71 shows the breakdown of treatments 

by Visual Quality Objective for Alternative B. Table 72 shows the percentage of acres treated broken 

out by Visual Quality Objective for Alternative B. The majority of treatments are in Modification or 

Maximum Modification where the activity effects are expected to remain consistent with visual 

objectives. As described in Chapter 2, some regeneration units may resemble a thinning, where the 

intent is to retain moderate amounts of residual canopy and regenerate shade-tolerant species or small 

groups of shade-intolerant species. 

Table 71. Silvicultural Prescription Acres by Visual Quality Objective (Alt. B)

Silv. RX Retention Partial Retention Modification Max. Mod

Intermediate 0 325 2470 2859

Regeneration 0 99 930 1097

Table 72. Percentage of Acres Treated by Visual Quality Objective (Alt. B)

Retention Partial Retention Modification Max. Mod

Percent Treated 0% 5% 44% 50%

Table 73 shows the breakdown of treatments by Visual Quality Objective for Alternative C. Of total 

cutting acres under Alternative C, 1096 acres are determined to be visible from Forest Road 40 via 

the digital terrain modelling. However, the foreground acres are more likely to be visible.

Table 73. Silvicultural Prescription Acres by Visual Quality Objective (Alt. C)

Silv. RX Retention Partial Retention Modification Max. Mod

Intermediate 0 171 1383 2320

Regeneration 0 50 291 601

Table 74 shows the percentage of acres treated broken out by Visual Quality Objective. The majority 

of treatments are in Modification or Maximum Modification, where the activity effects would remain 

consistent with visual objectives. 
Sunrise Vegetation and Fuels Project

218 Umatilla National Forest

Table 74. Percentage of Acres Treated by Visual Quality Objective (Alt. C)

Retention Partial 

Retention Modification Max. Mod

Percent Treated 0% 4% 30% 60%

Alternatives B and C would directly and indirectly address some of the trends related to age class in 

foreground partial-retention areas. The desired mix of age classes is 20 percent of each of the 

following age class and structural stages in the Forest Plan, but the two oldest age classes in the 

Forest Plan have been lumped for this analysis, to allow for comparison to stand structural stages; 

thus, the objective for the 109-181 age class is 40% of seen area in the foreground. Short and longterm trends are displayed in Table 75 for existing conditions (Alt. A) and for action alternatives (Alts. 

B and C). Trends associated with each alternative are analogous to direct/indirect effects, to the extent 

that trends differ. For example, by creating some areas of stand initiation structural conditions, Alts B 

and C would for the short-term reverse a (currently) decreasing trend that would have occurred under 

the no-action alternative.

Table 75. Visible Foreground Age Class in Partial Retention and Trends by Alternative. 

Age 

class

Structural 

stage

Existing 

acres

% of total Extent trends over time relative to current 

conditions

Existing Desired Alt A short

and long-term

Alts B and C 

short-term

Alts B and C 

long-term

0-36 SI 211 16 20 Decreasing Increase Decreasing

37-72 SE 454 35 20 Decreasing Stable Stable

73-108 UR 631 48 20 Decreasing Decreasing Stable

109-181 Old Forest 18 1 40 Increasing Stable Increasing

Note: Structural stages listed include Stand Initiation (SI), Stem Exclusion (SE), Understory Reinitiation (UR), and Old Forest. 

Short-term effects are associated with a 0 to 20-year time frame, and long-term effects are associated 20 years or more. 

Under any alternative, age classes remain stable when roughly equal areas of forest enter and exit the 

age class over time. Forests enter the 0-36 age class through high severity disturbance—most often 

wildfires or tree-harvests. Under Alternative A, a lack of disturbances would cause the amount of 

forest in the 0-36 age class to gradually decrease over time. The relatively small extent of tree-cutting 

activities under Alternatives B and C would have an indirect effect of slightly decreasing the extent of 

the 0-36 age class in the short term, because it would not likely compensate for the overall amount of 

forest transitioning out of that age class over the long term. 

Under each alternative, forests that enter the 109-181 age class do so by persisting over long enough 

periods of time (greater than 109 years since stand origin). Alternative A would result in short and 

long-term increases of forest in this age class because endemic disturbances (insect, disease, or small 

wildfire) would likely be less extensive than the amount of forest transitioning into the 109 to 181-

year age class. Alternatives B and C would have the direct effect of stabilizing the extent of the age 

class over the short-term, because a roughly equal amount of forest would leave the class via 

landscape burning disturbances and enter the class through forest growth. Additionally, tree-cutting 

activities proposed under Alternatives B and C would not reduce the amount of forest in this class. 

Over longer periods of time, more areas of forest are expected to enter the 109 to 181-year age class 

than would leave it through disturbances. 
Final Environmental Impact Statement

Pomeroy Ranger District 219

For some age classes/stand structures Alternative B maintain a stable proportion of the landscape or 

move conditions toward the desired extent, because it would convert some forests in the overrepresented 37-27 (SE) and 73-108 (UR) age classes to the under-represented 0 to 36-year age class. 

This alternative would maintain the visual quality objectives, and potentially improve areas of 

maximum modification (areas of past harvest) for reasons explained elsewhere in this section. 

Alternatives B and C would meet the visual quality objectives, and potentially improve areas of 

maximum modification. Alternative C proposes the same treatment methods, but to a lesser degree in 

consideration of wildlife resource concerns. 

Alternative A indirectly allows existing trends to continue. Alternatives B and C address structural 

stages in similar ways, but to a differing extent, as described in Chapter 2. The proposed alternatives 

have very little differences between them as they relate to scenery resources overall. All proposed 

alternatives would meet the visual quality objectives established in the Forest Plan.

Past Activities are visible within the project area and in adjacent areas within the viewshed of Forest 

Road 40. Those that are within the project area do not presently dominate the viewshed as seen from 

Forest Road 40. Many of these effects would be reduced by the activities proposed by Alternative B 

and C, addressing prior units that are blocky and unnatural-appearing by softening edges between 

harvested and previously unharvested forest. There are units west of Forest Road 40, adjacent to the 

project area. Units are still evident from the Teal Salvage sale along the west of the Forest Road 40. 

Previous effects of the Teal timber sale are accounted for in the analysis of existing conditions and not 

expected to alter the degree of effects disclosed above for Alternatives B and C. 

There are present and foreseeable activities that are expected to create effects. Prescribed fire efforts 

in and around the project area would create small pockets of scorching and mortality. These effects 

are natural appearing and are expected to occur at a scale that is very minimal. Grazing, road and trail 

maintenance, and recreational uses are not expected to affect scenery resources to any measurable 

degree.

Irreversible and Irretrievable Commitment of Resources

For all action alternatives (B and C) there would be no irreversible or irretrievable commitment of 

resources with implementation of proposed activities.

Final Environmental Impact Statement

Pomeroy Ranger District 221

3.15 Inventoried Roadless Areas (IRA), Potential Wilderness 

Areas (PWA) and other Undeveloped Lands 

This section incorporates by reference the Sunrise Inventoried Roadless Areas, Potential Wilderness 

Areas and Undeveloped Lands Report contained in the project analysis file at Pomeroy Ranger 

District. Specific information on the methodologies, assumptions, and limitations of analysis and 

other details are contained in the report. A summary of the current conditions of the affected 

environment and the predicted effects of the Proposed Action and its alternatives are discussed in this 

section. 

Regulatory Framework

It is important to accurately define terminology found in this section, as a wide range of terms have 

been used by respondents during scoping, the courts, and the Forest Service itself. The terms and 

definitions below will be used in this site-specific analysis. The following four resource topics are 

based on current law, regulation, agency policy, and the Umatilla Land Resource Management Plan 

(Forest Plan), as amended. 

Wilderness

A wilderness area is designated by congressional action under the Wilderness Act of 1964 and other 

wilderness acts. Wilderness is undeveloped Federal land retaining primeval character and influence 

without permanent improvements or human habitation (Umatilla Forest Plan, page GL-45). There is, 

however, no congressionally designated wilderness within the project area, and no project activities 

are proposed in the wilderness. The proposed project would have no direct, indirect or cumulative 

effects on designated Wilderness areas; therefore there will be no further discussion of the effects to 

designated wilderness in this report.

Potential Wilderness Areas (PWA)

The Umatilla National Forest conducted a Potential Wilderness Area (PWA) inventory for forest plan 

revision and updated the inventory in 2010 (2010 PWAs) consistent with agency policy at that time. 

Only acres of land inventoried as PWA were carried forward into the forest plan revision evaluation 

and wilderness recommendation process. The forest plan draft EIS was released in 2014 and the 2010 

PWA inventory was used to evaluate, analyze, and recommend wilderness in the alternatives. 

Inventoried Roadless Areas (IRA) 

These areas were identified in the 2001 Roadless Area Conservation Rule in a set of inventoried 

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

Impact Statement, Volume 2, dated November 2000, which are held at the National headquarters 

office of the Forest Service, or any subsequent update or revision of those maps (36 CFR 294.11). 

These areas were set aside through administrative rulemaking and have provisions, within the context 

of multiple use management, for the protection of IRAs. Most IRA boundaries are substantially 

identical to those identified as “Roadless Areas” referred to in the 1982 planning rule (36 CFR 

219.17) and identified by the Forest Plan, FEIS, Appendix C; however some localized, minor 

differences in boundaries may exist.
Sunrise Vegetation and Fuels Project

222 Umatilla National Forest

Undeveloped Lands

Undeveloped lands are simply lands that do not have a history of management activity (see 

methodology), whether it is timber harvesting, road construction, or other trammels. These areas are 

not designated Wilderness, IRA or PWA , but rather identified as undeveloped, and are considered in 

the analysis of each action alternative. There are no forest-wide or management area standards 

specific to undeveloped lands in the Umatilla forest plan. All lands, including other undeveloped 

lands, are managed consistent with forest-wide standards and guidelines and by designated Forest 

Plan Management Area allocations. Undeveloped lands analysis does not reference the planning 

handbook (FSH 1901.12) or the Wilderness Act as they are not relevant to this analysis.

Methodology (Undeveloped Lands)

The identification of undeveloped lands was conducted through a sequence of GIS and database 

analyses, field verification, and application of professional judgment. The judgment applied was 

situational and instance by instance. The judgment applied was situational and instance by instance. 

Lands 300 feet on either side of the centerline of all maintenance level 1, 2, 3, 4, and 5 Forest Service 

roads and open County Roads are considered developed due to evidence of stumps from firewood 

cutting and hazard tree removal, dispersed campsites, and other activities allowed under the current 

Forest Plan. Examples of typical situations that required applications of professional judgment 

included, but are not limited to:

• Determining whether other improvements or evidence of past human activities are substantially 

noticeable.

• Extending placement of polygon boundaries to the edges of development for purposes of inclusion 

in the analysis.

Lands with substantially noticeable management were identified by creating a map that depicts past 

harvest and thinning from the FACTS and Legacy Harvest databases together with an orthophoto of 

the project area. This information was viewed both in terms of type of management and year of 

implementation. Where the orthophoto did not clearly indicate substantially noticeable management 

(i.e. a uniform change in tree crown size and height, consistently open tree spacing, skid trails, etc.) 

stand conditions were verified on the ground. Administrative sites, and developed recreation sites 

were also included in lands with substantially noticeable management.

Wilderness, Inventoried Roadless Areas, Potential Wilderness Areas, development associated with 

roads, and lands with substantially noticeable management were then subtracted from the Sunrise 

planning area acres and the remaining acres are considered undeveloped lands. All polygons less than 

one acre were dropped from detailed study because individual polygons this small could easily result 

from mapping error and they are too small to be meaningful. 

Indicators used for comparison purposes between alternatives are:

• Intrinsic physical and biological resources (soils, water, wildlife, recreation, fisheries, etc.)

• Intrinsic social values (apparent naturalness, solitude, remoteness)

• Change in acres of other undeveloped lands

Affected Environment

All undeveloped land acres are allocated to various management area strategies as disclosed in the 

Umatilla Forest Plan FEIS, Appendix C and described in the Record of Decision (page 6-9) for the 

FEIS. Some management area strategies were intended to retain the undeveloped roadless character 
Final Environmental Impact Statement

Pomeroy Ranger District 223

of the roadless area and some management area strategies were intended to develop the lands with 

timber harvest and road building activities; thus forgoing roadless character.

The Asotin Creek IRA and PWA Description: The Asotin Creek IRA (16,433 acres, which amounts 

to approximately 50 percent of the project area) and PWA (16,181 overlapping acres) includes the 

headwaters of the North Fork Asotin Creek. In some cases the PWA boundary extends beyond the 

IRA and in other cases it excludes portions of the IRA. See Map A-1. Almost the entire drainage is 

within the forest boundary. Bounded on the east by the Forest Boundary, this area may be accessed 

from numerous local roads emanating from Forest road 41 on the north side, Road 40 on the west 

side, and Road 44 on the south side. The trailhead for Trail 3125 is located five miles downstream on 

State lands.

Elevation varies from 2,450 feet from where the North Fork Asotin Creek leaves the Forest to 6,000 

feet on the Devils’ Tailbone Ridge on the southern boundary of the Roadless area. Two-thirds of this 

area is composed of slopes greater than 60% while only 2% is on slopes less than 30%. Topography 

is very mountainous with steep slopes and deeply incised canyons. North aspects are forested, 

primarily with grand fir and mixed conifer at the lower elevations and subalpine fir at the higher 

elevations; while south aspects are predominately forested stringer draws interspersed with grasslands 

on the upper slopes, giving way to stands of ponderosa pine and mixed conifer in the riparian area of 

the forks of the North Fork Asotin Creek.

Existing and Desired Conditions-Undeveloped Lands

Table 76 displays the acres of remaining undeveloped lands within the Sunrise project area along 

with reference to maps found in Appendix A. The Sunrise planning area (approximately 33,500 acres)

contains 4,527 acres identified as other undeveloped lands. 

Table 76. Undeveloped Lands; Map by Map Summary

Undeveloped Lands and Reference Map Approximate Acres within 

Sunrise Analysis Area

Total acres considered within analysis area* (Map A-1). 33,150

Lands that are not National Forest within the analysis area (i.e. private lands) 1,130

Existing Wilderness 0

Existing Inventoried Roadless Areas (Asotin Creek IRA)** 16,433

Existing Potential Wilderness Areas** 16,181

Acres of substantially noticeable timber harvest activities excluded (Map A-2) 9,670

Acres of ‘road improvements’ excluded (roads maintained to level 1, 2, 3, 4, 

or 5)*** (Map A-3).

7,681 (133 miles)

Acres of ‘other improvements’ excluded (summary of acres of substantially 

noticeable timber harvest, developed campgrounds, mines, administrative 

site, etc.) (Map A-4).

17

Acres of undeveloped land**** (Map A-5). 4,527

*This includes all acres contained within the Sunrise planning area.

**The IRA and Potential Wilderness Area substantially overlap one another 

***Some of these acres overlap with acres of substantially noticeable other improvements. 

****This number does not include polygons less than one acre in size. 
Sunrise Vegetation and Fuels Project

224 Umatilla National Forest

The table below is a summary of all the acres evaluated for for this project. Information summarized 

in this table can be found in Appendix A. Table 77 displays the total lands considered Wilderness. 

Potential Wilderness Areas, Inventoried Roadless Areas, acres of undeveloped land and acres of 

developed landscape.

Table 77. Summary of wilderness, PWAs, IRAs, undeveloped and developed landscape.

Acres of 

Wilderness

Acres of 

Potential

Wilderness 

Areas

Acres of 

Inventoried 

Roadless 

Areas

Acres of 

undeveloped 

lands

Acres of developed 

lands with 

substantially 

noticeable past 

harvest, roads, etc.

Non-federal 

land within 

Project Area

(i.e. state and 

private land)

0 16,181 16,433 4,527 11,335* 1,130

*This number contains acres that overlap. For instance, acres associated with roads may overlap with acres past harvest, 

developed recreation, or administrative sites, or other developments such as powerline. Also acres of past harvest may 

overlap with other noticeably developed activities.

Undeveloped lands comprise approximately 14% of the Sunrise project planning area. Undeveloped 

lands within the project planning area are typically located in drainage bottoms and on steep slopes 

with timbered stringers and grassy ridgetops that are not timbered. The Asotin Creek IRA, PWA and 

undeveloped lands make up approximately 50 percent of the planning area.

The majority of the 4,527 acres of undeveloped lands within the project area are allocated to Forest 

Plan management areas C3-Big Game Winter Range, C4-Wildlife Habitat and C3A-Sensitive Big 

Game Winter Range. Any areas with unique ecological values within the Sunrise project area are 

currently maintained for those values with Forest Plan standards and guidelines for management area 

allocations. Table 78 displays allocated acres by management area.

Table 78. Other undeveloped lands within the Sunrise project area by MAs.

Management Area Acres of Other Undeveloped 

Lands located in each MA 

within the project area

Percent of Other 

Undeveloped Lands in each 

MA within the project area

A4- Viewshed 2 109 2.4

A6- Developed Recreation 6 0.1

C1-Dedicated Old Growth 405 9

C3- Big Game Winter Range 519 11.5

C3A- Sensitive Big Game Winter Range 967 21.4

C4-Wildlife Habitat 2296 51

C5-Riparian (Fish and Wildlife) 198 4.4

C8-Grass Tree Mosaic 27 0.6

Total 4,527 100%

More than 74 of the 83 Polygons of other undeveloped lands are from one to 100 acres in size (See 

Appendix A). These relatively smaller polygons make up about 22% of the undeveloped lands within 

the project area. They are typically very dissected and scattered throughout the project area. The two 

largest polygons, polygon #1 (1,303 acres) and polygon #2 (845 acres) make up about 47% of the 

undeveloped lands within the project area.

Polygon #1 is located in the lower portions of the upper reach of North Fork Asotin Creek and a 

tributary to NF Asotin creek-in Cougar Canyon. The polygon is mostly in the creeks bottoms and on 

timbered side slopes that have not been previously harvested. The creeks bottoms are in Management 
Final Environmental Impact Statement

Pomeroy Ranger District 225

Area C-5-Riparian, and most of the rest of the polygon is in management area C-4-Wildlife habitat.

Much of the polygon is part of a patchwork of past harvest areas. 

Polygon #2 is located in the northeast portion of the project area mostly along Lick Creek and the 

Cabin Gulch tributary to Lick Creek. Most of the acres in polygon 2 are in management area C-9-

Sensitive Big Game Winter Range. This polygon is typical of the lower, drier portions of the project 

area being comprised of grassy ridgetops and stringers of timber on steep side slopes.

Human influences have had limited impact to long-term ecological processes within the undeveloped 

lands. Disturbance by insects and fire has been and most likely would continue to be the factors with 

the most potential to impact the area.

Soils in vegetated areas that have not been previously effected by activities described above are 

generally more productive and promote better vegetation growth than in other areas (see Soils Report, 

project file). 

Most streams and aquatic habitat in the project area, including those that occur in other undeveloped 

lands, have been effected by past harvest, roads, etc., resulting in sedimentation, lack of large woody 

debris, and increased water temperature.

Plant communities, particularly habitat for threatened, endangered, and sensitive species, would be 

mostly unimpaired by human activities. Areas effected by past management activities and 

maintenance level 1 roads have altered plant communities progressing through various stages of 

succession. Noxious weeds have fewer transport venues in undeveloped areas and less opportunity to 

become established. However noxious weeds have many vectors, such as wind and wildlife, and 

infestations in remote areas not often visited likely go undetected and untreated.

Wildlife habitat on undeveloped lands varies widely in structure, composition, and density. These 

stands provide habitat for a wide range of wildlife species dependent on open canopy forest, closed 

canopy forest, grasslands, shrublands, early successional stages, dead wood, and other features. This 

variation in structure, composition, density, and other habitat features (including snags and downed 

wood) are the result of multiple factors including historic disturbance regimes, topographical features 

(aspect, slope position, moisture gradients, etc.), past management (harvest, fire suppression, etc.), 

and other factors. Areas where there have been no timber management activities often provide snag 

densities that exceed those expected based on data from reference stands. Where no road building, 

past timber management, or natural disturbance events have occurred, snag and downed wood 

dynamics and stand structure, composition, and density (which contribute to habitat quality for a wide 

suite of wildlife species) are similar to what would have been expected historically and show no 

impairment by humans. Larger blocks of other undeveloped lands (areas 1,000 acres or more) would 

serve as movement corridors for many wildlife species. Where moisture and other factors allow, 

undeveloped lands and those areas where management activities are no longer noticeable (in terms of 

stand structure) provide higher quality and better distributed cover habitat for elk and dense dry 

upland forest stands for species like the pileated woodpecker. 

Recreation in other developed lands within the project area provides recreation opportunities that are 

similar to those which occur throughout the rest of project area. Dispersed camping, hunting, 

horseback riding and hiking likely occur though there are few designated hiking trails. These 

activities occur within closer proximity to evidence of past harvest, roads, and other developed areas. 

Opportunities for a feeling of remoteness are limited due to the small size, odd shapes and scattered 

distribution of most of the undeveloped polygons. Distance and topographic screening are also factors 
Sunrise Vegetation and Fuels Project

226 Umatilla National Forest

in creating such opportunities. Nearby, sights and sounds of roads and timber harvest can be heard 

and often seen from within undeveloped lands. 

Visual quality within many other undeveloped lands would be high in the foreground, but views of 

managed landscapes could intrude within the smaller polygons, depending on the amount of 

screening provided by topography and tree cover.

No additional special or unique values in other undeveloped lands associated with the Sunrise 

analysis area have been identified by project resource specialists.

The existing condition of all remaining 11,335 acres of land within the Sunrise project area that are 

not IRAs, PWAs other undeveloped lands present a landscape that has been managed and is generally 

developed in nature. These lands contain evidence of past harvest and maintenance level 1 or higher 

forest roads. Past management actions and current conditions reflect the multiple-use intent and 

decisions made in the Forest Plan (1990 as amended), and reflects consistency with Forest Plan 

management area allocations.

Environmental Consequences

Inventoried Roadless Areas (IRA)

No Action Alternative

Direct Effects:

There would be no direct effects to the Asotin IRA because no activities would occur in this area. The 

affected environment would remain unchanged, except by natural process and ongoing management 

activities (see description of affected environment for a full list of resources considered). Biological 

and ecosystem function would continue. 

Cumulative Effects:

For the No Action alternative, the Sunrise project would not be authorizing any actions; therefore it 

would not be adding anything to the effects of past, present, and reasonably foreseeable future 

actions. Based on the definition provided in the CEQ regulations there would be no cumulative 

effects for the No Action Alternative.

Effects Common to All Action Alternatives (B and C)

Direct and Indirect Effects:

No cutting units are proposed under either of the action alternatives. Landscape prescribed fire is 

proposed on approximately 14,055 acres within the Sunrise project area. Under both action 

alternatives about 6,335 acres of landscape burning would take place within the Asotin Creek IRA 

(approximately 39% of the IRA). Maps A-6 and A-7 show the relationship between proposed 

prescribed landscape burning and the Asotin Creek IRA.

This treatment would reintroduce fire over a 10 year period to a fire-dependent ecosystem to lessen 

the impact of a future uncharacteristic wildfire and improve forage quality for big game (Management 

area direction for C3, C3A, C4, and C8). In the majority of the project area, fire intensities would be 

kept low by keeping fire out of the overstory and burning mainly surface fuels. Consistent with the 
Final Environmental Impact Statement

Pomeroy Ranger District 227

mixed-severity fire regimes which have long characterized some parts of the project area, individual 

tree and group torching would likely occur in areas where there is sufficient ladder fuels and in timber 

stands with high occurrences of mistletoe. Upon completion, the landscape could be described as a 

mosaic of unburned, lightly burned, moderately burned, and intensely burned patches.

Prescribed fire activities could include incidental cutting of trees within the IRA to facilitate the 

effectiveness of control lines. Tree cutting would be infrequent, scattered and likely not noticeable. 

Prescribed fire activities would result in minor short term effects including the sight and smell of 

smoke and the sight of burned vegetation. Long term effects to roadless characteristics from 

prescribe landscape would be positive as fire dependent ecosystems become more resilient to impacts 

from wildfire.

Cumulative Effects:

Cumulative effects to soil, water quality, air quality; plant and animal communities; habitat for 

threatened, endangered, and sensitive species; recreation; noxious weeds; and cultural resources on 

undeveloped lands within the project area are disclosed in previous sections of this chapter and are 

not reiterated here. 

Outside the treated areas, the conditions described in the affected environment would remain 

unchanged except by natural processes and ongoing activities such as grazing and hunting. 

Potential Wilderness Areas (PWA)

No Action Alternative

Direct and Indirect Effects: 

For the No Action alternative the Sunrise project would not be authorizing any actions. All 16,181 

acres of the Asotin PWA would remain as described in the Affected Environment section. The area 

would continue to appear predominately natural. Selecting this alternative would not affect any 

future wilderness decision associated with a forest plan revision.

Cumulative Effects:

For the No Action alternative, the Sunrise project would not be authorizing any actions; therefore it 

would not be adding anything to the effects of past, present, and reasonably foreseeable future 

actions. Based on the definition provided in the CEQ regulations there would be no cumulative 

effects for the No Action Alternative. 

Effects Common to All Action Alternatives (B and C)

Direct and Indirect Effects:

Landscape prescribed fire is proposed on approximately 14,055 acres within the Sunrise project area. 

Under both action alternatives about 6,139 acres of landscape burning would take place within the 

Asotin Creek PWA (approximately 38% of the PWA). Maps A-6 and A-7 show the relationship 

between proposed prescribed landscape burning and the Asotin Creek PWA.

This treatment would reintroduce fire over a 10 year period to a fire-dependent ecosystem to 

lessen the impact of a future uncharacteristic wildfire and improve forage quality for big 

game (Management area direction for C3, C3A, C4, and C8). In the majority of the project 

area, fire intensities would be kept low by keeping fire out of the overstory and burning 
Sunrise Vegetation and Fuels Project

228 Umatilla National Forest

mainly surface fuels. Consistent with the mixed-severity fire regimes which have long 

characterized some parts of the project area, individual tree and group torching would likely 

occur in areas where there is sufficient ladder fuels and in timber stands with high 

occurrences of mistletoe. Upon completion, the landscape could be described as a mosaic of 

unburned, lightly burned, moderately burned, and intensely burned patches.

Prescribed fire activities could include incidental cutting of trees within the PWA to facilitate the 

effectiveness of control lines. Tree cutting would be infrequent, scattered and likely not noticeable. 

Prescribed fire activities would result in minor short term effects including the sight and smell of 

smoke and the sight of burned vegetation. Long term effects to roadless characteristics from 

prescribe landscape would be positive as fire dependent ecosystems become more resilient to impacts 

from wildfire. 

Proposed Cutting Units: Under Alternative B approximately 186 acres of the Asotin Creek PWA 

would be affected by cutting units and about 26 acres would be affected in Alternative C.

Table 79. Potential Wilderness in the Sunrise Project Area by Alternative displays how much of the 

PWA would remain unaffected by proposed cutting activities. Most of the harvest and precommercial thinning activities would occur along existing roads and at the edges of the PWA in close 

vicinity to past harvest areas. No cutting activities extend into portions of the PWA that are also IRA 

under either alternative. 

Table 79. Potential Wilderness in the Sunrise Project Area by Alternative

Alternative Acres of Potential 

Wilderness Area in the 

Project Area Prior to 

Activity

Acres of Potential 

Wilderness Area in 

the Project Area

Affected/ (%)

Acres of Potential 

Wilderness Area 

Remaining in the Project 

Area After Implementation

Alternative A 16,181 0 / (0%) 16,181

Alternative B 16,181 186/ (1.1%) 15,995

Alternative C 16,181 29/ (0.2%) 16,152

Maps A-6 and A-7 show the relationships between cutting units proposed in Alternatives B and C 

respectively and the Asotin PWA.

Evidence of activity would be apparent to varying degrees in treatment areas. About 186 acres would 

be directly affected in Alternative B and 29 acres would be affected in Alternative C. The natural 

appearance of the landscape would be reduced following treatment activities. Stumps, skid trails and 

slash would be evident where tree cutting activities occur. Tree density would be reduced which 

would result in more open stands compared with neighboring untreated areas. Some stands would 

likely be opened to the point that the skyline of the forest canopy appears highly manipulated to the 

casual observer.

The sense of remoteness, opportunities for solitude, and primitive recreation would be reduced as the 

sights and sounds of management would intrude into outer portions of the PWA. These effects would 

be confined to relatively small portions of the edges of the PWA. The vast majority of the PWA would 

retain the characteristics for which it was established. 

Prescribed fire activities would result in short term effects including the sight and smell of smoke and 

the sight of burned vegetation. These effects are short term. In the long term, 10 years or longer, the 
Final Environmental Impact Statement

Pomeroy Ranger District 229

prescribed burned areas would appear natural. Therefore, there would be no reduction in PWA due to 

prescribed fire activities.

Effects to soils, water, fish and wildlife are described in detail in individual specialist reports in the 

project file and respective sections in Chapter 3 of the EA.

Under Alternative B approximately 186 acres of the Asotin PWA would be affected by cutting and 

associated activities (such as new temporary road. construction). Under Alternative C about 29 acres 

would be affected. These acres would no longer meet PWA inventory criteria because timber harvest 

and creation of stumps would make them appear developed. The resulting effect for Alternative A 

would by about a 1% reduction to the PWA. Under Alternative C there would be less than a quarter of 

1 percent reduction to the PWA.

The vast majority of the PWA (99% or more) would remain intact. However, selection of either of the 

action alternatives could affect a future wilderness decision associated with a forest plan revision: the 

only difference between the alternatives would be the number of acres affected.

Cumulative Effects:

Cumulative effects to soil, water quality, air quality; plant and animal communities; habitat for 

threatened, endangered, and sensitive species; recreation; noxious weeds; and cultural resources on 

undeveloped lands within the project area are disclosed in previous sections of this chapter and in 

specialist reports and are not reiterated here. 

Outside the treated areas, the conditions described in the affected environment would remain 

unchanged except by natural processes and ongoing activities such as grazing and hunting. 

Direct and Indirect Effects:

Undeveloped Lands

Alternative A (No Action)

There would be no direct or indirect effects to undeveloped lands because no activities would occur in 

these areas. The affected environment would remain unchanged, except by natural processes and 

ongoing management activities (see description of affected environment for a full list of resources 

considered). Biological and ecosystem functions would continue. 

Alternatives B and C

Landscape prescribed fire is proposed on approximately 14,055 acres within the Sunrise project area. 

Under Alternative B about 767 acres of landscape burning would take place over a 10 year period 

within undeveloped lands that are not affected by proposed cutting. In Alternative C about 1,115

acres of undeveloped lands outside of proposed cutting units would be affected. Maps A-6 and A-7 

show the relationship between proposed prescribed landscape burning and undeveloped lands.

This treatment would reintroduce fire to a fire-dependent ecosystem to lessen the impact of a future 

uncharacteristic wildfire and improve forage quality for big game (Management area direction for C3, 

C3A, C4, and C8). In the majority of the project area, fire intensities would be kept low by keeping 

fire out of the overstory and burning mainly surface fuels. Consistent with the mixed-severity fire 

regimes which have long characterized some parts of the project area, individual tree and group 

torching would likely occur in areas where there is sufficient ladder fuels and in timber stands with 

high occurrences of mistletoe. Upon completion, the landscape could be described as a mosaic of 

unburned, lightly burned, moderately burned, and intensely burned patches.
Sunrise Vegetation and Fuels Project

230 Umatilla National Forest

Prescribed fire activities could include incidental cutting of trees within the undeveloped lands to 

facilitate the effectiveness of control lines. Tree cutting would be infrequent, scattered and likely not 

noticeable. Prescribed fire activities would result in minor short term effects including the sight and 

smell of smoke and the sight of burned vegetation. Long term effects to undeveloped lands 

characteristics from prescribe landscape would be positive as fire dependent ecosystems become 

more resilient to impacts from wildfire. 

Table 80 displays the acres of treatment activities proposed within undeveloped lands by alternative

and the amount of other undeveloped lands that would remain after implementation. Evidence of 

activity would be apparent to varying degrees in treatment areas. The natural appearance of the 

landscape would be reduced following treatment activities. Stumps, skid trails and slash would be 

evident where tree cutting activities occur. Tree density would be reduced which would result in more 

open stands compared with neighboring untreated areas. Some stands would likely be opened to the 

point that the skyline of the forest canopy appears highly manipulated to the casual observer. Overall, 

project activities would reduce undeveloped lands within the project area in Alternative B by 2,252 

acres (50%) and 1,318 acres (29%) in Alternative C. 

Table 80. Summary of undeveloped lands in the Sunrise project area by alternative.

Alternative Acres of Undeveloped 

Lands in the Project Area 

Prior to Activity

Acres of Undeveloped 

Lands in the Project 

Area Affected/ (%)

Acres of Undeveloped Lands 

Remaining in the Project Area 

After Implementation

Alternative A 4,527 0 / (0%) 4,527

Alternative B 4,527 2,252/ (50%) 2,275

Alternative C 4,527 1,318 (29%) 3,209

The two largest undeveloped lands polygons, polygon #1(1,303acres) and polygon #2 (845 acres) 

make up about 47% of the undeveloped lands within the project area. Table 81. Acres of proposed

treatment in each polygon for each alternative displays the acres of treatment (prescribed landscape 

burning and thinning activities) proposed in each polygon for each alternative.

Table 81. Acres of proposed treatment in each polygon for each alternative

Undeveloped

Polygons 

Acres Affected by 

Proposed Cutting 

Activities

Alternative B

Acres Affected by 

Proposed Cutting 

Activities

Alternative C

Acres Affected 

by Proposed 

Landscape Burning

Alternative B

Acres Affected 

by Proposed 

Landscape Burning 

Alternative C

Polygon #1

1,303 acres

735 (56%) 427(33%) 291 (22%) 291 (22%)

Polygon #2

845 acres.

387 (46%) 387 (46%) 406 (48%) 406 (48%).

Under Alternative B, approximately 56 percent of Polygon #1 and 46 % of Polygon #2 would be 

affected by pre-commercial or commercial thinning activities and be considered developed after 

implementation.

Under Alternative C, approximately 33 percent of the polygon #1 and 46 % of Polygon #2 would be 

affected by pre-commercial or commercial thinning activities and be considered developed after 

implementation.
Final Environmental Impact Statement

Pomeroy Ranger District 231

Prescribed landscape burning in Polygons #1 and #2 would have short term effects from 

implementation such as appearance of burned trees and shrubs but the polygons would retain their 

undeveloped character.

Effects to the intrinsic physical and biological resources of other undeveloped lands within the 

Sunrise planning area (soils, water, wildlife, recreation, aquatic habitat, etc.) are disclosed in the 

applicable resource sections of the EIS and only briefly summarized here. 

Soils: Where management would occur within other undeveloped lands, soils would be exposed to 

compaction and displacement from heavy equipment and erosion due to soil surface exposure during 

skidding or road construction/reconstruction. However, given the design criteria, a minimum of 80 

percent of an activity area would remain in a condition of acceptable productivity potential consistent 

with Forest Plan standards. 

Water Quality: The action alternatives have the potential to effect surface water quality and 

groundwater. However, the project contains site-specific Best Management Practices which are 

designed to prevent further impairment to water quality and to protect groundwater. These Best 

Management Practices would also prevent effects on fish. In addition, the potential for high intensity

wildfire in the riparian areas would be reduced. 

Plant Communities: Design criteria would protect threatened, endangered, or sensitive plants. Areas 

of disturbed soil would be open to colonization by noxious weeds.

Wildlife habitat: For Forest Plan indicator species such as elk, Alternative B and C, HEI would 

remain within forest plan standards. While forage may decrease due to prescribed burning activity in 

the short-term, activities such as burning and thinning are expected to improve forage in the longterm. There are many species, including primary and secondary cavity nesters, which rely on snags

and dead and down for habitat. While both alternatives temporary effect the number and amount of 

snags and dead and down, Forest plan guidelines would be followed concerning the retention and 

recruitment of this habitat. The project area has documented instances of threatened, endangered, or 

sensitive (TES) species, as well as possible populations of TES species (see wildlife specialist report). 

For all documented and potential TES species, as well as other species of interest that are not TES, 

there is either a finding of no impact, or may impact but not likely cause a loss of viability of the 

species, for both alternatives. For all indicators, the No Action alternative is not expected to have any 

direct and indirect as well as cumulative effects. Current conditions are expected to persist outside the 

desired range.

Recreation: Recreation would change slightly, adding dispersed camping, motorized sports, and 

gathering forest products to the potential uses within other undeveloped lands. The quality of the 

hunting experience would be reduced if elk are displaced. Where treatment occurs within 

undeveloped lands, there would be a loss of apparent naturalness. Recreationists seeking a primitive 

experience or a sense of remoteness would have less area available due to harvest in the large 

polygons of other undeveloped lands (polygons #1 and number2) whereas the small polygons have 

already been infringed upon by adjacent sights and sounds of management and human presence prior 

to implementation. The Asotin Creek IRA/PWA (16,000+ acres) comprises about 50% of the project 

area and would still provide opportunities for a primitive experience or a sense of remoteness and 

solitude. The 166,000 Wenaha-Tucannon Wilderness Area and the Wenatchee Creek and Upper 

Tucannon IRAs/PWAs are all located just outside the Sunrise project area. These areas provide 

outstanding opportunities for a primitive recreation experience and solitude.
Sunrise Vegetation and Fuels Project

232 Umatilla National Forest

On acres treated by commercial or noncommercial thinning, management activities would be 

substantially noticeable for up to 50 years, depending on the rate of stump decay and recovery of 

disturbed soils. Prescribed fire would have little effect on undeveloped lands characteristics in that the 

majority of the treated area would still appear natural, with some fire control lines and periodic 

stumps related to removal of hazardous snags. Pile burning would appear less natural, as blackened 

circles spaced somewhat regularly on the ground, but vegetation regrowth would begin to disguise 

this in one year, and by three years only burn scars on trees should be noticeable.

Visual quality: within undeveloped lands where management occurs would still meet Forest Plan

standards, although views would no longer be pristine. There are several cultural resource sites within 

these other undeveloped lands, however no effects are expected on known cultural resources since all 

would be avoided by project activities. All of the proposed activities would not affect the historic 

integrity or historic character of these sites.

Environmental effects to resources in undeveloped lands due to the implementation of proposed 

project activities would be consistent with applicable laws, regulations, and Forest Plan management 

area standards and guidelines (see applicable sections of the EIS for Findings of Consistency for each 

resource). 

All action alternatives propose some level of activity within undeveloped lands, varying only by the 

number of acres (see Table 80). Refer to the Appendix A and associated maps to see the location of 

activity units and other undeveloped lands and the EIS Chapter 2 for a listing of harvest activity units 

and logging method. 

Cumulative Effects

Alternative A (No Action)

For the No Action alternative, the Sunrise project would not be authorizing any actions; therefore it 

would not be adding anything to the effects of past, present, and reasonably foreseeable future 

actions. Based on the definition provided in the CEQ regulations (p. 3-1), there would be no 

cumulative effects for the No Action. 

Effects Common to All Action Alternatives—Alternatives B and C

The cumulative effects geographic boundary is the Sunrise analysis area (33,150 acres). The types of 

direct and indirect effects expected to occur as a result of the Sunrise project are not expected to 

interact with any similar effects from past, present and reasonably foreseeable future actions that 

might occur elsewhere within the analysis area of the project area.

The temporal boundary for this cumulative effects analysis is 50 years. This timeframe is appropriate 

because that is how long it would take harvest and temporary road construction to no longer be 

substantially noticeable (based on field observations of other past management in the Sunrise analysis 

area). 

Within the Sunrise project area, project related activities such as tree cutting, construction of 

temporary roads, re-opening of closed roads and prescribed burning would have an incremental effect 

on undeveloped lands where other past, present and ongoing activities such as grazing, dispersed 

camping, and vehicle use on roads also occur. Apparent naturalness, solitude and remoteness in these 

undeveloped lands within the project area would be reduced by noises and sounds from mechanized 

equipment, visibility of stumps or evidence of temporary roads, and smoke from prescribed burning. 

Those effects are expected to remain cumulatively minor due to their relatively short term (10 years) 

nature. Overall, cumulative effects from these activities on apparent naturalness, solitude and 
Final Environmental Impact Statement

Pomeroy Ranger District 233

remoteness are very small (not measurable/indistinguishable from those effects described in direct 

and indirect effects). 

Cumulative effects to soil, water quality, air quality; plant and animal communities; habitat for 

threatened, endangered, and sensitive species; recreation; noxious weeds; and cultural resources on 

undeveloped lands within the project area are disclosed in other sections of this chapter and are not 

reiterated here.

Outside the treated areas, the conditions described in the affected environment would remain Visual 

Resource (Scenery)

Specific information on the methodologies, assumptions, and limitations of analysis and other 

scenery-related details are contained in the resource report contained in the project file. A summary of 

the current conditions of the affected environment and the predicted effects of the Proposed Action 

and its alternatives are discussed in this section. 

Irreversible and Irretrievable Commitment of Resources

For all action alternatives (B and C) there would be no irreversible or irretrievable commitment of 

resources with implementation of proposed activities.

The 4,527 acres of undeveloped lands identified within the project area would continue to not be 

designated potential wilderness area, inventoried roadless area or wilderness area. However none of 

the activities proposed on undeveloped lands would necessarily preclude congress from considering 

these lands for future wilderness designation. The proposed activities on undeveloped lands are 

consistent with management direction for the Forest Plan Management Areas in which they are found.

Final Environmental Impact Statement

Pomeroy Ranger District 235

3.16 Recreation

A summary of the current conditions of the affected environment and the predicted effects of the 

Proposed Action and its alternatives are discussed in this section. Specific information on the 

methodologies, assumptions, and limitations of analysis and other details are contained in the Sunrise 

recreation specialist’s report, incorporated herein by reference, and available to the public on the 

project webpage at http://www.fs.fed.us/nepa/fs-usda-pop.php/?project=45689. 

Introduction

The recreation opportunities available on National Forest lands broadly benefit users. For many 

Americans, public lands provide the only means of experiencing outdoor recreation. The settings and 

experiences of these lands are important to an overall healthy lifestyle of the American public. 

Managing recreation resources includes the analysis of projects in regard to how the activities will 

affect developed and undeveloped recreation sites, uses and activities, as well as recreation settings in 

which the user experience is presented. 

Regulatory Framework

The Umatilla Forest Land and Resource Management Plan (LRMP) establishes goals related to 

specific resources by management area. The Forest Service issues a nationally recognized 

classification system called the Recreation Opportunity Spectrum (ROS) to describe different 

recreation settings, opportunities and experiences to help guide recreation management activities 

(USDA Forest Service 1986). The LRMP has recognized the importance of recreation settings. Each 

Management Area (MA) is assigned a desired ROS.

Methodology

ArcMap geographic information systems (GIS) was used to analyze the proposed activities in regards 

to recreation use and facilities, dispersed recreation sites and the recreation opportunity spectrum 

(ROS) classes assigned to the area. 

Indicators for comparison purposes between alternatives are:

• Developed and Dispersed Camping: recreation experiences and availability

• Access and Dispersed Recreation Activities: travel access, safety, and desired use

• Recreation Opportunity Spectrum: level of development and settings: characteristics consistent 

with Recreation Niche Statement

• Sense of Place Characteristics consistent with Recreation Niche Statement (See Umatilla Forest 

Recreation Niche Statement in the Forest Plan)
Sunrise Vegetation and Fuels Project

236 Umatilla National Forest

Affected Environment

Existing Condition 

The existing condition for recreation resources is considered in terms of facilities, travel and access, 

recreation opportunity spectrum and sense of place. 

Developed and Dispersed Recreation 

Developed Campgrounds: 

There are no developed campgrounds located within the Sunrise project area. There are however two 

campgrounds located nearby. 

Wickiup Campground is situated adjacent to the project area on FS road 43 near its junction with FS 

road 44 along the southeastern boundary. The campground is most heavily utilized during the late 

summer and fall hunting seasons

Misery Campground is located just south of the southern boundary of the project area on FS road 

4030020. Like Wickiup campground, it is most heavily utilized during the late summer and fall 

hunting seasons. 

In addition to the two developed campgrounds, there are two other developed site: Misery Warming 

Shelter and Clearwater Big House Rental. While both of these are not within the project area, they are 

in proximity to roads that will be utilized by the Sunrise project. Misery Warming Shelter is utilized 

during the winter months, while Clearwater Big House Rental is available for rent year round.

Undeveloped Campsites:

There is no inventory of undeveloped campsites in the project area; however there are a number of 

traditional dispersed campsites scattered throughout. A generic description of a dispersed campsite 

consists of a user-made area that is generally adjacent to a developed road. 

Other popular recreation activities:

There are a number of popular recreation activities in the area besides camping that occur year around 

including: 

• Hiking

• Horseback Riding

• All-Terrain Vehicle (ATV) Riding

• Mushroom and Berry Picking

• Hunting

• Sight Seeing

• Snowmobiling

Travel/Access 

During the spring summer and fall months, there are 84 miles of roads that provide access for hiking, 

ATV riding, hunting, berry picking and sightseeing. Most routes are closed at different times of the 

year to certain types of vehicles for various reasons including for wildlife protection, improving big 

game hunting, facilitating winter recreation and erosion control. Portions of FS roads 40, 41, 42, 44 
Final Environmental Impact Statement

Pomeroy Ranger District 237

and their spurs are closed to motor vehicle travel except for snowmobiles travel from December 1st to 

April 1st. Between FS roads 40 and 44, there are approximately 15 miles of groomed snowmobile 

routes within the project area. Currently, there are a few miles of FS roads 41 and 4206 within the 

project area that remain open to the public year around. 

Approximately 25 miles of motorized and non-motorized system trails (trails 3115, 3125, 3128, 3131, 

3285 and 3286) are located within the project area, providing access to North Fork of Asotin Creek, 

Hard-To-Get-To Ridge and other more remote areas.

Recreation Opportunity Spectrum (ROS)

Currently the recreation opportunity is classified as shown in the table below. The classifications 

provide an understanding of the recreation setting in terms of access, remoteness, naturalness, 

facilities, social encounters, visitor impacts and visitor management. 

Table 82. Acres by ROS Classification

ROS Classification Acreage Percent of Total

Roaded Modified 16,553 50

Roaded Natural 9,656 29

Semi-Primitive Non-Motorized 5,789 17

Non-NFS Lands 1,152 4

Mapping Error 22 -

Total 33,150 100

The area is divided into ROS classifications primarily by the available roads, facilities and expected 

social encounters. The semi-primitive Non-Motorized management area is located primarily within 

the heart of the Asotin Creek IRA/PWA. This area is very remote with trail access only. The roaded 

natural area is found within portions of the Asotin IRA/PWA, Lick Creek area and Bear Ridge-Spruce 

Springs areas. It’s also found around the Wickiup Campground, Misery Campground and Misery 

Warming Shelter areas. The roaded modified area captures the remaining acres that are roaded 

including the Clearwater Big House rental and hardy Ridge road complex. 

Sense of Place

The sense of place that currently exists in this area is a remote working landscape. The area is utilized 

as a backcountry hunting/dispersed recreation experience. 

Environmental Consequences 

Direct and Indirect Effects

Alternative A (No Action)

The No Action alternative would perpetuate the existing management of the setting, facilities and 

access. Developed and dispersed site campers and cabin renters would remain undisturbed by noise, 

smoke, or traffic. Dispersed campsite use patterns would remain the same. 
Sunrise Vegetation and Fuels Project

238 Umatilla National Forest

Travel and access would see no effects by the No Action alternative. The recreation opportunity 

spectrum would not be affected by the No Action alternative. The sense of place would see no effects 

by the No Action alternative.

For the No Action alternative, the Sunrise project would not be authorizing any actions; therefore it 

would not be adding anything to the effects of past, present, and reasonably foreseeable future 

actions. Based on the definition provided in the CEQ regulations (p. 3-1), there would be no 

cumulative effects for the No Action alternative.

Alternative B and C

Developed and Dispersed Recreation

The campgrounds, rental cabin and some dispersed campsites would experience an increase in dust 

and noise during harvest and thinning activities, and by an increase of stand treatment related traffic 

on haul routes.

Effects to the recreation resources are primarily related to the harvest and prescribed fire activities 

and the disturbance that these activities create. These activities would create local, adverse, short term

effects to the timbered portion of the landscape. For further description of these effects, see the 

scenery resource report. 

Some recreationists could be displaced from their desired dispersed campsite, but again, the effects 

would be limited to a small number of sites at one time (local, adverse and short term) and would 

cease as soon as treatment of the adjacent unit is complete (generally 1-2 weeks as work is occurring). 

Hunters may be displaced from their favorite dispersed camping site for one season during the 

prescribed burning window. Numerous alternative dispersed campsites would continue to be 

available. 

Wickiup Campground, Misery campground, Misery Warming Shelter and Clearwater Big House 

recreation rental cabin would remain available during and after stand treatments, but the 

campgrounds, rental cabin and disperse campsites could also be affected by smoke from prescribed 

burning. This could coincide with some of the more popular camping periods (fall hunting season) 

because conditions during late fall area generally the best times for conducting prescribed burning. 

Late fall campers (primarily hunters) would be most likely affected. Again, these effects are short 

term and local.

Travel and Access 

Under Alternatives B and C many of the roads that are open for public travel would be utilized to 

access cutting units and to serve as haul routes. Some open roads or portions of open roads may be 

temporarily closed during project activities and would be re-opened as soon as possible after work is 

completed, especially during hunting season. Open roads would generally be expected to remain open 

to the public during log haul. 

There would be no changes to the existing travel system after treatment. Existing roads and trails that 

are open to the public would continue to be available. Increased vehicle traffic during harvest and 

thinning activities may deter localized recreational user activities. 

Portions of some roads that are currently groomed during the winter for snowmobiles may be needed 

for winter haul. Under these circumstances a single lane would be plowed for log haul with grooming 

continuing to take place on the other side of the road or an alternative route would be groomed. This 
Final Environmental Impact Statement

Pomeroy Ranger District 239

practice has been successful in a number other project areas in years past. While snowmobiling on 

groomed routes would continue to take place, the presence of a plowed route and truck traffic may 

negatively affect a visitor’s sense of remoteness.

Trails: Treatment activities would take place near or adjacent to many portions of the trail system. 

Harvest and thinning activities may deter localized recreational user activities. Under both action 

alternatives the trail system would continue to be available during and after treatment activities. There 

would be no changes to the trail system.

Recreation Opportunity Spectrum 

The alternatives do not propose actions that would alter effects to the recreation opportunity 

spectrum. No camping facilities would be altered and the existing road and trail system would remain 

unchanged following project activities. Some undeveloped campsites may be altered by treatment but 

these changes would not alter the opportunities to a degree that would change the ROS classifications. 

Maps 12 and 13 show proposed cutting units by alternative in relation to ROS settings.

Sense of Place

The project is not expected to make any significant effects that are inconsistent with the Forest niche 

statement that describes the desired sense of place. The usage and settings are expected to remain 

consistent. 

Cumulative Effects

Alternative A (No Action)

Based on the definition provided in the CEQ regulations (p. 3-1), there would be no cumulative 

effects for the No Action alternative.

Alternative B and C

Considering past, present and foreseeable future actions, it is believed there would be no 

accumulative effects associated with recreation opportunities from either action alternatives. 

Irreversible and Irretrievable Commitment of Resources

For all action alternatives (B and C) there would be no irreversible or irretrievable commitment of 

resources with implementation of proposed activities.

Final Environmental Impact Statement

Pomeroy Ranger District 241

3.17 Air Quality

A summary of the current conditions of the affected environment and the predicted effects of the 

Proposed Action and its alternatives are discussed in this section. Specific information on the 

methodologies, assumptions, and limitations of analysis and other details are contained in the Sunrise 

air quality specialist’s report, incorporated herein by reference, and available to the public on the 

project webpage at http://www.fs.fed.us/nepa/fs-usda-pop.php/?project=45689. 

Introduction

The implementation of either action alternative has the potential to impact the health and safety of 

local residents and those utilizing public lands by increased smoke in the area. Either through 

inaction, Alternative A and the continued risk of large wildfires, or through prescribed fire, air quality

was identified as a resource that should be analyzed for potential impacts. 

Regulatory Framework

Currently, all prescribed burning that occurs on the Pomeroy Ranger District adheres to Washington 

State and Federal Air Quality Regulations (see Air Quality Report p. 2-5 for specific regulations). All 

prescribed burning is regulated by Washington State Department of Natural Resources (DNR) as 

defined by the Washington State Clean Air Act and is done in accordance with the Washington State 

DNR Smoke Management Plan. 

Methodology 

Prescribed burning must be, and is, approved on a day-by-day basis by the DNR smoke management 

meteorologist. By using current and predicted air quality conditions, current and forecasted weather 

conditions, knowledge of the local topography, wind patterns, and BlueSky Rains Smoke Dispersion 

modeling the DNR meteorologist determines if prescribed burning projects would meet State smoke 

management guidelines on any given day. Pomeroy Ranger District personnel also monitor for effects 

from smoke produced, and if negative effects occur they notify DNR and discontinue ignition. 

Outdoor air quality in Washington is influenced predominately by smoke from agricultural and 

outdoor burning, woodstoves and motor vehicles (EPA, 2011). It is monitored utilizing Air Quality 

Index (AQI) levels. The higher the AQI, the greater the level of air pollution and the higher the health 

concerns (see Air Quality report). Wildfires are not considered as a cause for violations of air quality 

standards or visibility protection goals because they are consider natural events, but prescribed fires 

are considered active management so the smoke produced is considered as an impact on air quality 

and visibility standards.

The below cited references are from “Smoke Management Guide for Prescribed and Wildland Fire” 

published by the National Wildfire Coordination Group. This Forest Service publication is comprised 

of multiple papers that serve as a handbook for smoke management. 

A prescribed fire is a combustion process that has no pollution control devices to remove pollutants 

(Achtemeier 2001). CO2 and water (H20) make up 90 percent of total emissions from wildfire and 

prescribed fire (Ottmar and Reinhardt 2001). The other 10 percent is made up of CO, hydrocarbons 

(HC), nitrogen oxides (NOx), which includes NO2 and PM (PM2.5 and PM10) (Ottmar and Reinhardt 

2010). CO and PM are the chief inhalation hazards to the public and fireline personnel when exposed 

to smoke (Ottmar and Reinahrdt). Over 90 percent of particulate matter produced by wildland fires is 
Sunrise Vegetation and Fuels Project

242 Umatilla National Forest

less than 10 microns in diameter and over 80-90 percent of this is less than 2.5 microns in diameter 

(Ottmar 2001). Particles less than 2.5 micrometers in diameter (PM2.5) are referred to as "fine" 

particles and are believed to pose the largest health risks. 

Smoke intrusions and visibility reduction may also result from the direct impact of the smoke plume. 

Intrusions of smoke can cause numerous nuisance impacts, as well as specific safety hazards. The 

vast majority of prescribed burns occur without negative smoke impacts (Achtemeier 2001). 

Prescribed fires produce smoke, but less smoke is generated for the same acre than for a wildfire. 

Prescribed fire smoke, unlike wildfire smoke is regulated. Table 83 estimates smoke emissions for 

PM2.5 and CO during prescribed fire and wildfire in dry, moist and cold forest types and grass/shrub 

fuel types. These fuel types are all common in the Sunrise planning area. The table below is to show 

that smoke emissions from wildfire exceed smoke emissions from prescribed fire. 

Table 83. Estimated Smoke Emissions (lbs. /acre)

Forest Type Smoke Emission Type Wildfire Prescribed Fire1

Dry Forest (Interior 

Ponderosa Pine)

PM 2.5 327 296

CO 3969 3551

Moist Forest (Interior 

Douglas Fir)

PM 2.5 581 524

CO 7391 6592

Cold Forest (Engelmann 

Spruce – Subalpine fir)

PM 2.5 1816 N/A

CO 23795 N/A

Grass/Shrub (Idaho Fescue) PM 2.5 8 8

CO 17 17

1 Any prescribed fire in cold forest type would be incidental and would only be included to provide secure holding locations. 

Table 84. Estimated PM2.5 and CO emissions by burn type in the Sunrise Planning area (acres)

Alternative Activity Fuels Burning

PM2.5 = 1699lbs/ac

CO = 21146lbs/ac

Natural (Landscape) Fuels Burning

PM2.5 = 1295lbs/ac

CO = 16,787lbs/ac

A 0 0

B 878 14,055

C 599 14,055

Affected Environment

The analysis area for air quality impacts includes Class I areas, “designated” or nonattainment areas, 

and sensitive areas that may likely be affected by smoke intrusion from prescribed burning activities 

in the sunrise planning area. These areas may include:

• Class I Federal area, Hells Canyon Wilderness, approximately 55 air miles to the southeast of the 

project area. 

• Class I Federal area, Eagle Cap Wilderness, approximately 50 air miles to the south of the project 

area.

• Sensitive areas, Clarkston, Washington (approximate population 19,866) and Lewiston, Idaho 

(approximate population 32,544) being the largest population centers located 15 air miles to the 

northeast of the project area.

• Sensitive area, Asotin, Washington (approximate population 1251) is located four air miles to the 

west of the project area.
Final Environmental Impact Statement

Pomeroy Ranger District 243

• Sensitive area, Wenaha-Tucannon Wilderness which is located two air miles to the southwest of 

the project area.

There are no “designated” or nonattainment areas as designated by the Washington Department of 

Ecology within or near the project area. The areas designated as sensitive are listed due to their 

proximity to the project areas and/or location in alignment of general wind patterns of the area.

Differences in alternatives will be displayed by carbon monoxide (CO) and fine particulate matter 

(PM2.5) produced by fuel treatments.

Environmental Consequences 

Direct and Indirect Effects

Alternative A (No Action)

This alternative would have no immediate direct, short or long term adverse effect on local air quality

as no action would be taken. The No Action alternative would mean only burn prescriptions already 

approved, and outside the project area, would commence. 

While there should be no direct effects from the No Action alternative, indirect consequences would 

include wildfires that typically burn with a higher intensity and burn more acres creating emissions 

that are higher than that of prescribed fire. Consumption is also higher during wildfires than 

prescribed fires contributing to the greater production of emissions. Wildfires may also occur under 

weather conditions which limit smoke dispersal.

Smoke concentrations can increase during the night due to inversions, but may decrease during the 

afternoons due to dispersion. Wildfire smoke may last for several weeks depending on fire behavior

and meteorology. 

In 2000, wildfire smoke concentrations in Montana were many times higher than monitored 

previously. PM2.5 concentrations ranged between 100 and 600 μg/m3 (24-hour average) up to 100 

miles from the fire. 

There is a potential for indirect adverse short term local effects to air quality if due to a lack of fuels 

management, wildfires are able to grow in intensity. 

Alternatives B and C

The Sunrise project proposes to treat approximately 14,055 of landscape prescribed fire (natural 

fuels) in both alternatives, and approximately 878 acres of activity fuels burning in Alternative B and 

599 in Alternative C. Estimated amount of smoke emissions produced during prescribed burning is 

depicted in Table 84Prescribed fire treatments and the associated smoke emissions in the Sunrise 

project area would occur over an extended period of time. PM2.5 and CO produced would vary by size 

and environmental conditions at the time of implementation. For example, a 30 acre activity fuels 

burn would produce approximately 30,600 pounds of PM2.5 and 378,720 pounds of CO emissions. 

This would occur primarily during the day of ignition, becoming significantly less each day until the 

burn is out. Therefore, for both action alternatives there would be a short term, adverse direct impact 

in the form of smoke exposure in the project area.
Sunrise Vegetation and Fuels Project

244 Umatilla National Forest

Current fuel load estimates in proposed timber sale units are 7 to 30 tons per acre. Predicted fuel loads 

after timber harvest is estimated to be 25 to 65 tons per acre. The estimated amount of fuel consumed 

during prescribed burning in activity units would average about 15 to 39 tons per acre. Estimated fuel 

loads in natural fuels units is .95 to 29 tons per acre. Estimated amount consumed during burning 

would average 0.75 to 17.4 tons per acre. The fuel component consumed in all activities includes 

litter, woody material, duff, herbaceous material, shrubs, crown foliage, and crown branchwood27. 

The indirect effects of the action alternatives would be adverse, short term smoke exposure to the 

local area. There is however, the potential for the long term beneficial effect of less smoke exposure 

in the local area from a reduction in fuel and a lessening of potential wildfire severity form the action 

alternatives.

Mitigation Measures

Prescribed burning must be, and is, approved on a day-by-day basis by the DNR smoke management 

meteorologist. By using current and predicted air quality conditions, current and forecasted weather 

conditions, knowledge of the local topography, wind patterns, and BlueSky Rains Smoke Dispersion 

modeling the DNR meteorologist determines if prescribed burning projects would meet State smoke 

management guidelines on any given day.

Cumulative Effects

Alternative A

Activities considered for cumulative effects are those that further modify indicators used in this 

analysis. The indicators utilized to measure changes in conditions for this analysis are pounds of 

PM2.5 and CO. Past actions were considered and addressed in the current conditions section of this 

document. For an activity to be considered as contributing to cumulative effects, the effects of that 

action must overlap in space and time with the prescribed burning proposed under one of the action 

alternatives in this analysis. 

Prescribed burning (silvicultural burning) by the US Forest Service in Washington State must be 

approved by a Washington State Department of Natural Resource smoke management meteorologist 

(if smoke produced exceeds 100 tons) on each day of a planned ignition. This approval process sets 

priorities within the State and between competing airsheds to minimize smoke impacts on Federal 

class I areas, non-attainment areas and sensitive areas. Therefore, prescribed burning would not likely 

be approved if smoke produced from silvicultural burning would cause the NAAQS to be exceeded.

Because no direct or indirect effects would occur with implementing Alternative A, there are no 

cumulative effects.

There would continue to be wildfires in the project area. Smoke from wildfire is not considered as a 

cause for violations of air quality standards or visibility protection goals because they are considered 

natural events; however, effects of smoke from a large wildfire could influence AQI. 

 

27 Fuel loadings and particulate emissions were estimated using FOFEM version 6.3.1.
Final Environmental Impact Statement

Pomeroy Ranger District 245

Alternatives B and C 

Smoke from prescribed burning is short term; therefore, effects of the proposed action from smoke 

emissions are not likely to have cumulative effects with other activities. The Washington DNR Smoke 

Management Plan permits burning only when atmospheric stability allows for good smoke 

dispersion. They also regulate the daily amount of burning to reduce impacts and negative effects of 

smoke. Prescribed burning competes with other burning in the airshed. The Washington DNR is 

responsible for managing all burn activities on a given day. The Forest Service is responsible for 

establishing burn priorities for its actions. If air quality is predicted to exceed thresholds when 

proposed activities are scheduled to occur, implementing any of these alternatives may result in some 

delays in burning as a result of this increased demand for “air space.”

Irreversible and Irretrievable Commitment of Resources

For all action alternatives (B and C) there would be no irreversible or irretrievable commitment of 

resources with implementation of proposed activities.

Final Environmental Impact Statement

Pomeroy Ranger District 247

3.18 Range

A discussion of the current conditions of the affected environment and the predicted effects of the 

Proposed Action and its alternatives, prepared by the range specialist, is presented in it’s entirety in 

this section.

Introduction

Gazing and grazing permitting continues to be an important aspect of management of the Umatilla 

National Forest, and is therefore a resource of interest for analysis. The effects of grazing itself on the 

project area, as well as the effects to grazing quality and availability are analyzed in this section. 

Regulatory Framework

This document incorporates the requirements and guidelines as set forth in the Final Environmental 

Impact Statement (FEIS) and Record of Decision (ROD) for the Umatilla National Forest Land and 

Resource Management Plan (LRMP) which was signed March 8, 1991 as amended by the 

continuation of Interim Management Direction Establishing Riparian, Ecosystem, and Wildlife 

Standards for Timber Sales (hereafter referred to as “eastside screens”, (Lowe, 1995)).The Interim 

Strategies For Managing Anadromous Fish-Producing Watersheds on Federal Lands in Eastern 

Oregon, Washington, Idaho, and Portions of California (PACFISH), which was signed February 24, 

1995. 

Methodology

The Sunrise Vegetation and Fuels Management project planning area is located within portions of the 

Asotin and Peola C&H grazing allotments (see Map A-8). For the purpose of discussing domestic 

livestock grazing, those portions of the above listed allotments that are within the project planning 

area will be analyzed, while the portions of the allotments that are outside the analysis area will not be 

discussed in detail. 

The indicator for comparison purposes between alternatives are environmental effects of this project 

from livestock grazing. They will be discussed in relation to how each alternative affects management 

of livestock distributions in uplands and riparian community types.

The main concern associated with range and grazing is the effect of livestock on the ecosystem. 

Livestock can contribute to soil compaction, water quality issues, erosion, and streambank instability. 

These concerns are identified by the Forest Service as a result of spot checks of allotments, along 

with analysis of data collected on established monitoring transects. 

Within the Sunrise project area there are seven established monitoring transects. 

The Asotin Allotment has one transect within the Sunrise project area:

• Round Prairie—an upland transect located outside the area proposed activity. It is read preseason, mid-season and post-season by Forest Service range personnel.

The Peola Allotment has six transects within the Sunrise project area:

• Upper Sourdough—a riparian transect located outside the area of proposed activity. The area 

has been in resource protection since 2006 due to populations of Silene spaldingii (Spalding's 
Sunrise Vegetation and Fuels Project

248 Umatilla National Forest

catchfly), listed as a threatened species under the Endangered Species Act.

• Dick Trail—a riparian transect located near the boundary of the project area, and outside the 

area of proposed activity. It is read pre-season, mid-season and post-season by Forest Service 

range personnel.

• Lick Creek 2—a riparian transect located outside the area of proposed activity. The riparian 

area has been fenced to exclude cattle since approximately 2009. The transect is read preseason, mid-season, and post-season by Forest Service range personnel. Additional data has 

been collected as part of the PACFISH/INFISH Biological Opinion (PIBO) monitoring 

program.

• Pinkham—an upland transect located within an area of proposed activity. It is read mid-season 

and post-season. Vehicle access to the area is subject to seasonal closure until July 1 of each 

year.

• Warner—an upland transect located within an area of proposed activity. It is spot checked by 

Forest Service range personnel when cattle utilize the area.

• North Fork Asotin Creek—a riparian transect located outside the area of proposed activity. 

It is spot checked by Forest Service range personnel when cattle utilize the area.Scale of 

Analysis

Affected Environment

Asotin allotment is located in the eastern portion of Pomeroy Ranger District, mainly in the Asotin 

Watershed, about twelve miles west of Anatone, Washington. The entire area of the allotment 

encompasses approximately 39,400 total acres, but only 1,136 acres are in the planning area. The 

Asotin C&H Allotment currently permits approximately 2,204 AUMs (Animal Unit Months). The 

allotment is a cattle (cow/calf) permit for a total of 413 pair from June 10th to October 10th annually. 

There is one permit holder and approximately four water developments and one wildlife guzzler 

within the project area.

Asotin C&H Allotment is divided into four pastures: Park/Cook, Hogback, George and Wenatchee. 

The Park/Cook and Hogback pastures are the only two pastures that lie within the project area, and is 

the only pasture that will have acres burned. A total of 1,136 acres will be burned out of 14,286

acres— which is 8% of the pastures and 4% of the entire allotment.

The Peola C&H Allotment currently permits approximately 1,948 AUMs (Animal Unit Months). The 

allotment is cattle (cow/calf) permit for a total of 333 pair from June 3rd to October 7th and 22 pair 

from June 5th to October 4th annually. There are two permit holders and approximately 13 miles of 

fence, 41 water developments (consisting of troughs and ponds combined) and 4 wildlife guzzlers 

within the project area. 

Peola C&H Allotment is divided into eleven pastures: Cottonwood, Dick, Dick Trail, Lower 

Sourdough, Upper Sourdough, North Fork, Lick, Charley, Abels, Lower Pataha and Upper Pataha 

pastures. The Project area lies within the North Fork, Lower Sourdough, Upper Sourdough, Lick and 

Charley pastures, but only Lick and Charley pastures are currently in use. Both Lick and Charley

pastures will be burned for a total of approximately 5,905 acres, or 15% of the entire allotment. 

• Lick—A total of 4,514 acres will be burned out of 7,460 acres within Lick pasture, which is

61% of the pasture. All burned area within the Lick pasture will be divided into 1,500 to 

2,000 acre burn blocks over a five year period. No more than one burn block will be burned 

per pasture, per year. 
Final Environmental Impact Statement

Pomeroy Ranger District 249

• Charley—A total of 1,391 acres will be burnined out of 8,346 acres within Charley pasture, 

which is 17% of the pasture. 

Environmental Consequences

Direct Effects and Indirect Effects

Alternative A (No Action)

Livestock grazing distribution would likely stay the same or continue to slowly decrease as stocking 

in timber stands grows denser and wood continues to accumulate on the ground. Livestock access 

would stay the same or continue to slowly decrease due to down wood, continuous regeneration of 

trees, and the resulting reduction in visibility. Forage would also stay the same or continue to slowly 

decrease due to the gradual reduction of sunlight on the forest floor reducing forest floor vegetation. 

In the context of NEPA, 40CFR 1508.8 states that effects arise from taking an action, and therefore 

with the No Action alternative there would be no direct or indirect effects. 

Alternatives B and C

Both action alternatives would increase livestock distribution on the Peola and Asotin C&H 

Allotments by increasing access and or increasing available forage for livestock. This would have a 

short term local beneficial effect to available livestock forage by spreading utilization of vegetation 

more evenly through the allotment and reduce soil and vegetation disturbance in areas of concentrated 

use. 

Proposed burning would reduce the amount of forage in a one to two-year period, however, after that 

time period forage would be expected to be higher than the existing condition due to the reduction in 

competition from small tress and or shrubs, and would therefore have a short term local beneficial 

effect.

Proposed non-commercial thinning, commercial thinning, removal of danger trees, fuels reduction 

projects, and harvest would increase the amount of sunlight on the forest floor, stimulating grass 

growth and increasing the amount of available forage (transitory range28) for domestic livestock and 

would therefore have a short term local beneficial effect.

Management of livestock would improve with all action alternatives due to increased visibility and 

access for livestock herding, and due to short term local beneficial increases in forage. An increase in 

distribution of livestock could decrease the amount of use on riparian areas. 

 

28 Transitory Range –Land that is suitable for grazing use of a non-enduring nature over a period of time; often found in the 

openings create d timber harvesting activities. 
Sunrise Vegetation and Fuels Project

250 Umatilla National Forest

Cumulative Effects

The analysis area for cumulative effects is the project planning area, and the duration is the duration

of current grazing permits.

Alternative A (No Action)

For the No Action alternative, the Sunrise project would not be authorizing any actions; therefore it 

would not be adding anything to the effects of past, present, and reasonably foreseeable future 

actions. Based on the definition provided in the CEQ regulations (p. 3-1), there would be no 

cumulative effects for the No Action.

Alternatives B and C

Proposed treatments in all action alternatives, non-commercial thinning and landscape prescribed 

burns, could result in long-term benefits to forage and increased accessibility for livestock. But these 

benefits must be maintained through continued prescribed burns. 

Irreversible and Irretrievable Commitment of Resources

For all action alternatives (B and C) there would be no irreversible or irretrievable commitment of 

resources with implementation of proposed activities.
Final Environmental Impact Statement

Pomeroy Ranger District 251

3.19 Economic Analysis

A summary of the current conditions of the affected environment and the predicted effects of the 

Proposed Action and its alternatives are discussed in this section. Specific information on the 

methodologies, assumptions, and limitations of analysis and other details are contained in the Sunrise 

econimic specialist’s report, incorporated herein by reference, and available to the public on the 

project webpage at http://www.fs.fed.us/nepa/fs-usda-pop.php/?project=45689.

Introduction

The management of the Umatilla National Forest has the potential to affect local economies. This 

section presents the economic effects of the project, including the project feasibility, financial 

efficiency, and effects to jobs and income. Economics was identified as a component of the purpose 

and need of the Sunrise project. Specifically, a need was identified to contribute wood products to 

local and regional economies. This analysis discusses the revenues and costs of the commercial, noncommercial, and restoration activities proposed in the Sunrise alternatives.

Regulatory Framework

This document incorporates the requirements and guidelines as set forth in the Final Environmental 

Impact Statement (FEIS) and Record of Decision (ROD) for the Umatilla National Forest Land and 

Resource Management Plan (LRMP) which was signed March 8, 1991, as amended by the 

continuation of Interim Management Direction Establishing Riparian, Ecosystem, and Wildlife 

Standards for Timber Sales (hereafter referred to as “eastside screens”, (Lowe, 1995)).The Interim 

Strategies For Managing Anadromous Fish-Producing Watersheds on Federal Lands in Eastern 

Oregon and Washington, Idaho, and Portions of California (PACFISH), which was signed February 

24, 1995. 

Section 16 USC 1604(g)(3)(E)(iv) requires that timber will be harvested from National Forest lands 

only where the harvest system to be used is not selected primarily because it will give the greatest 

dollar return or the greatest unit output of timber. Executive Order 12898, issued in 1994 orders 

Federal Agencies to identify and address any adverse human health and environmental effects of 

agency programs that disproportionately impact minority and low-income populations. The Order 

also directs agencies to consider patterns of subsistence hunting and fishing when an agency action 

may affect fish or wildlife. 

The geographic scope of the economic analysis includes Columbia, Asotin and Garfield Counties, 

Washington, and Nez Perce County, Idaho. Nez Perce County is included in the analysis as most of 

the wood products production would take there, and should be included in the effects on local 

economies. The economic effects of the project is expected to occur over the next 10 years, 

establishing the temporal scale for the project. Indicators for Comparison purposes between 

alternatives are:

• Alternative efficiency –net present value (NPV)

• Sale Viability –volume (MBF), stumpage, and costs

• Benefits to regional economy –number of jobs, personal income
Sunrise Vegetation and Fuels Project

252 Umatilla National Forest

Affected Environment

Forest products have been an economic mainstay for over a century in the Sunrise project area. Over 

the last 15 to 20 years, the supply of timber products from the Agency to the local communities has 

been greatly reduced. 

Existing Conditions

Total Volume

According to the Washington Department of Natural Resources and US Forest Service Sale Detail 

Reports (2006-2015), timber harvest across the three Washington counties averaged 26.2 MMBF per 

year from 2006 to 2015 with 13.2 MMBF (50.3%) of that from Forest Service lands. At the peak in 

2006, the counties supported a 101.9 MMBF timber harvest, 40.4 MMBF from Forest Service lands.

The low in timber harvest occurred in 2012 with 4.8 MMBF harvested, 4.7 MMBF Forest Service 

lands.

Harvest Cost, Harvest Revenue, and Stumpage 

Average log prices have rebounded significantly from 2008-2009 recession values. According to 

Oregon Department of Forestry data, the average log price for Douglas-fir has increased 208% from a 

low in the second quarter of 2009 until the fourth quarter of 2015. This increase allows for greater 

stumpage values (stumpage value is the logging/hauling costs subtracted from the delivered log 

price), an improved forest-sector economy, and a greater likelihood of timber sales being 

economically feasible, financially efficient, and salable to local purchasers.

Additional Activity Cost

The existing conditions and need for action relevant to each of the additional project activities is 

addressed in the specialist report for the related resource. See the specialist report associated with 

each additional project activity for more information. See the economic specialist report for existing 

conditions related to non-timber production activities.

Net Present Value

Net Present Value was estimated using the Region 6 approved R6_TEAEcon program. Values were 

estimated using a 2% discount rate with harvest activities occurring over 5 years starting one year 

from now. Other associated activities would begin in the following year, and occur over a five year 

span.

Effect on Local Economies 

According to Headwaters Economics the current employment for the four counties was estimated at 

1,751 jobs with an average salary of $43,177 for the natural resources sector (headwaters.org).

For a breakdown of proposed treatments and activities for each alternative see Table 2-3. 
Final Environmental Impact Statement

Pomeroy Ranger District 253

Environmental Consequences 

Direct and Indirect Effects

Alternative A (No Action)

Under the No Action alternative, no commercial timber harvest, pre-commercial thinning, or fuel 

reduction activities associated with the Sunrise project would occur. Except for the Agency’s 

planning costs, Alternative A would incur no costs, produce no revenue, and would not change the 

conditions or level of economic activity in the surrounding counties. This alternative may, however, 

contribute to a decline in the local timber industry and local economy, since it would keep federal 

timber from the market. Additionally, since Alternative A would allow further departure from historic 

conditions in the Sunrise area, it is possible that costs could be incurred in the future to remediate 

issues such as insects, disease, and wildfires that could have been less costly if an action alternative 

had been chosen.

Alternative B

Alternative Efficiency and Sale Viability (Direct and Indirect Effects)

The total volume from this alternative is expected to be 25.6 MMBF of which 80% would likely be 

saw log based on past experience from similar stands.

Harvest Costs

Logging systems proposed for Alternative B of the Sunrise Project include ground-based and skyline.

Approximately 60% of proposed harvest acres would be yarded with a ground-based system; and 

40% yarded with a skyline system.

Table 85. Alternative B Harvest Cost for Commercial Timber Treatments

Logging System Stump to 

Truck 

($/MBF)

Hauling 

($/MBF)

BD/Temp 

Roads/EC 

($/MBF)

Total 

($/MBF)

Volume/Acre 

(MBF)

Total 

($/Acre)

Ground-based $140 $68 $14 $222 4.2 $932

Skyline $250 $68 $19 $337 5.4 $1,820

Logging costs were developed using LOGCOST version 15.0 and the hauling costs were developed using Haul Cost 

Appraisal version 15.0. Other cost were developed using nearby sales.

Gross Revenue 

Gross revenue is the price offered for delivered logs from area mills. Listed values reflect prices as of 

February, 2017. See Table 86 for projected gross revenue for ground-based and skyline units.

Table 86. Alternative B Gross Revenue of Timber Resources

Logging System Average Product 

Value ($/MBF)

Volume/A

cre

Product Value 

($/Acre)

Net 

Acres

Total 

Revenue

Ground-based $343 4.2 $1,441 3320 $4,784,120

Skyline $382* 5.4 $2,063 2210 $4,559,230

Total 5,530 $9,343,350

*Higher stumpage results from no removal of green bio convertible.
Sunrise Vegetation and Fuels Project

254 Umatilla National Forest

Stumpage Value 

Stumpage value is the logging/hauling costs subtracted from the delivered log price. See the Table 87

for projected stumpage values for ground-based and skyline units.

Table 87. Alternative B Stumpage Value

Additional Activities 

The total cost of implementing the Sunrise project are $3.1 million. Costs were obtained from each 

specialist and are shown in Table 88

Table 88. Alternative B Additional Activity Costs

Treatment Acres Cost/Acre Total Cost

Timber Marking 5,530 $70 $387,100

Reforestation 2,130 $725 $1,544,250

Non-Commercial Thinning 2,270 $325 $737,750

Landscape Burning 14,055 15 $210,825

Grapple Piling and Burning of Activity Fuels 1,068 140 $149,520

Prescribed burning of Activity Fuels 877 120 $105,240

Total $3,134,685

Net Present Value

Present value for the stumpage and additional costs for this alternative were $2.09 million and $2.89 

million for a net present value of negative (-) $800,000.

Regional Economies 

At the volume estimated and approximately 8.85 jobs created per million board feet the estimate for 

this alternative would produce 234 jobs for a gross income of $10.1 million in salary over the life of 

the project.

There is the potential for a direct localized, short-term benefit to the local economy from

implementation of alternative B. Indirect effects are more qualitative in nature and related to the 

effects of those dollars on the local economy. 

Mitigation Measures

Mitigation measures do not apply to this resource.

Logging 

System

Product 

Value 

($/Acre)

Harvest

Costs 

($/Acre)

Stumpage 

Value 

($/Acre)

Volume/Acre 

(MBF)

Stumpage 

Value 

($/MBF)

Net 

Acres

Total 

Stumpage

Groundbased$1,441 (-$932) $509 4.2 $121 3,320 $1,689,880

Skyline $2,063 (-$1,820) $243 5.4 $47 2,210 $537,030

Total 5530 $2,226,910
Final Environmental Impact Statement

Pomeroy Ranger District 255

Alternative C 

Alternative Efficiency and Sale Viability (Direct and Indirect Effects)

The total volume from this alternative is expected to be 12.1 MMBF of which 80% would likely be 

saw log based on past experience from similar stands. 

Harvest Costs

Logging systems proposed for Alternative B of the Sunrise Project include ground-based and skyline.

Approximately 60% of proposed harvest acres would be yarded with a ground-based system; and 

40% yarded with a skyline system.

Table 89. Harvest Cost for Commercial Timber Treatments

Logging 

System

Stump to 

Truck 

($/MBF)

Hauling 

($/MBF)

BD/Temp 

Roads/EC 

($/MBF)

Total 

($/MBF)

Volume/Acre 

(MBF)

Total 

($/Acre)

Ground-based $143 $68 $14 $225 4.0 $904

Skyline $229 $68 $19 $316 6.0 $1,905

Logging costs were developed using LOGCOST version 15.0 and the hauling costs were developed using HaulCost 

Appraisal version 15.0. Other cost were developed using nearby sales.

Gross Revenue 

Gross revenue is the price offered for delivered logs from area mills. Listed values reflect prices as of 

February, 2017. See the table below for projected gross revenue for ground-based and skyline units.

Table 90. Alternative C Gross Revenue of Timber Resources

Logging 

System

Average 

Product 

Value 

($/MBF)

Volume/Acre Product Value 

($/Acre)

Net Acres Total Revenue

Ground-based $343 4.0 $1,372 1,650 $2,263,800

Skyline $382* 6.0 $2,292 910 $2,085,720

Total 2,560 $4,349,520

*Higher stumpage results from no removal of green bio convertible

Stumpage Value 

Stumpage value is the logging/hauling costs subtracted from the delivered log price. See Table 91 for 

projected stumpage values for ground-based and skyline units.

Table 91. Alternative C Stumpage Value

Logging 

System

Product 

Value 

($/Acre)

Harvest

Costs 

($/Acre)

Stumpage 

Value 

($/Acre)

Volume/Acre 

(MBF)

Stumpage 

Value 

($/MBF)

Net 

Acres

Total 

Stumpage

Groundbased$1,372 (-$904) $468 4 $117 1,650 $772,200

Skyline $2,292 (-$1,905) $387 6 $65 910 $352,170

Total 2560 $1,124,370
Sunrise Vegetation and Fuels Project

256 Umatilla National Forest

Benefits

The total cost of implementing Alternative C of the Sunrise project is $1.9 million. Costs were 

obtained from each specialist and are shown in Table 92.

Table 92. Alternative C Additional Activity Costs

Treatment Acres Cost/Acre Total Cost

Timber Marking 2,560 70 $179,200

Reforestation 940 725 $681,500

Non-Commercial Thinning 2,270 325 $737,750

Landscape Burning 14,055 15 $210,825

Grapple Piling and Burning of Activity Fuels 329 140 $46,060

Prescribed burning of Activity Fuels 599 120 $71,880

Total $1,927,215

Net Present Value 

Present value for the stumpage and additional costs for this alternative were $1.06 million and $1.78 

million for a net present value of (-) $720,000.

Regional Economies 

At the volume estimated and approximately 8.85 jobs created per million board feet the estimate for 

this alternative would produce 107 jobs for a gross income of $4.6 million in salary over the life of 

the project.

Cumulative Effects

Alternative A (No Action) 

For the No Action alternative, the Sunrise project would not be authorizing any actions; therefore it 

would not be adding anything to the effects of past, present, and reasonably foreseeable future 

actions. Based on the definition provided in the CEQ regulations (p. 3-1), there would be no 

cumulative effects for the No Action. 

Alternatives B and C

Many factors influence and affect the local economies, including changes to industry 

technologies, economic growth, international trade, and the economic diversity and 

dependency of the counties. This project in connection with other projects is not likely to add 

to any short term (either beneficial or adverse) effects to local economies. However, the jobs 

and income associated with the action alternatives may bring the local economy some 

increased relative stability during the life of the project.

Irreversible and Irretrievable Commitment of Resources

For all action alternatives (B and C) there would be no irreversible or irretrievable commitment of 

resources with implementation of proposed activities.
Final Environmental Impact Statement

Pomeroy Ranger District 257

3.20 Climate Change

All analyzed alternatives could affect up to approximately 7,800 acres of forest by commercially 

thinning smaller trees from the stand, and prescribed fires associated with the Sunrise and Asotin burn 

decision could affect up to 21,800 of forest and grassland. Although such activities are noticeable at 

the watershed scale, this scope would be minor relative to the amount of forested land in the states of 

Oregon and Washington as a whole. Climate change is a global phenomenon because major 

greenhouse gasses (GHG) mix well throughout the planet’s lower atmosphere (IPCC 2013). 

Considering emissions of GHG in 2010 was estimated at 49 ± 4.5 gigatonnes29 globally (IPCC 2014) 

and 6.9 gigatonnes nationally (US EPA, 2015), a project of this magnitude makes an infinitesimal 

contribution to overall emissions. Therefore, at the global and national scales, this proposed action’s 

direct and indirect contribution to greenhouse gasses and climate change would be negligible. 

In addition, because the direct and indirect effects would be negligible, the proposed action’s 

contribution to cumulative effects on global greenhouse gasses and climate change would also be 

negligible. 

The Intergovernmental Panel on Climate Change has summarized the contributions to climate change 

of global human activity sectors in its Fifth Assessment Report (IPCC 2014). In 2010, anthropogenic 

(human-caused) contributors to greenhouse gas emissions came from several sectors:

• Industry, transportation, and building – 41% 

• Energy production – 35% 

• Agriculture – 12%. 

• Forestry and other land uses – 12% 

There is agreement that the forestry sector contribution has declined over the last decade (IPCC, 

2014; Smith et al., 2014; FAOSTAT, 2013). The main activity in this sector associated with GHG 

emissions is deforestation, which is defined as removal of all trees, most notably the conversion of 

forest and grassland into agricultural land or developed landscapes (IPCC 2000). 

The Sunrise project does not fall within any of these main contributors of greenhouse gas emissions. 

Forested land would not be converted into a developed or agricultural condition. In fact, forest stands 

are being retained and thinned to maintain a vigorous condition that supports trees, and sequesters 

carbon long-term. US forests sequestered 757.1 megatonnes30 of carbon dioxide after accounting for 

emissions from fires and soils in 2010 (US EPA, 2015). However there is growing concern over the 

impacts of climate change on US forests and their current status as a carbon sink. There is strong 

evidence of a relationship between increasing temperatures and large tree mortality events in forests 

of the western US. There is widespread recognition that climate change is increasing the size and 

frequency of droughts, fires, and insect/disease outbreaks, which would have major effect on these 

forests’ role in the carbon cycle (Joyce et al. 2014).

The project is in line with the suggested practice of reducing forest disturbance effects found in the 

National Climate Assessment for public and private forests (Joyce et al. 2014). Here specifically, the 

project proposes to modify stand density, species composition, structural stage, and/or fuel loading. 

This project falls within the types of options presented by the IPCC for minimizing the impacts of 

climate change on forest carbon, and represents a potential synergy between adaptation measures and 

 

29 A gigatonne is one billion metric tons of CO2; equal to about 2.2 trillion pounds. 30 A megatonne is one million metric tons of CO2; equal to about 2.2 billion pounds.
Sunrise Vegetation and Fuels Project

258 Umatilla National Forest

mitigation. Actions aimed at enhancing forest resilience to climate change by reducing the potential 

for large-scale, catastrophic disturbances such as wildfire of high intensity and resulting in permanent 

losses of productivity also prevents release of GHG and enhances carbon stocks (Smith et al. 2014). 

As described in the direct and indirect sections above, the proposed action reflects the rationale 

behind these recommendations because it would increase the extent of stand densities, species 

compositions, and stand structures more resistant to insect, disease, and wildfire disturbances. 

Timber management projects can influence carbon dioxide sequestration in four main ways: (1) by 

increasing new forests (afforestation), (2) by avoiding their damage or destruction (avoided 

deforestation), (3) by manipulating existing forest cover (managed forests), and (4) through 

transferring carbon from the live biomass to the harvested wood product carbon pool. Land-use 

changes, specifically deforestation and regrowth, are by far the biggest factors on a global scale in 

forests’ role as sources or sinks of carbon dioxide, respectively (IPCC, Intergovernmental Panel on 

Climate Change, 2000). Projects like the proposed action and other alternatives that create forests or 

improve forest conditions and capacity to grow trees are positive factors in carbon sequestration. 

The Sunrise project is compliant with Eastside Screens, a plan amendment that requires retention of 

all large trees greater than 21 inches in dbh. The largest trees within the project area will therefore be 

retained; and the conversion of Old Forest Multistory Strata to Old Forest Single Story strata will 

remove undergrowth, thus encouraging vigor and carbon storage in the remaining trees. Treatments in 

some other forest types may result in a loss of some carbon storage, but it is expected in the long term 

that treatment will result in increased vigor and growth, thereby increasing total carbon storage over 

the long term.
Final Environmental Impact Statement

Pomeroy Ranger District 259

3.21 Findings of Consistency

Activities must be consistent with the letter and intent of the Act itself, and the National Forest 

Management Act (NFMA; Public Law 94-588; 16 U.S.C. 1600) requires specific findings to be made 

and documented when considering the implementation of certain management practices on National 

Forest System lands. A review of all activities proposed for the Sunrise project and activity direct, 

indirect, and cumulative effects found that such activities are consistent with the NFMA. The basis 

and rationale for this consistency finding is described in this section. 

Forest Plan and Amendments

Forest Plan Goals, Objectives, Standards and Guidelines

Forest-wide standards and guidelines (pages 4-47 to 4-93) guide implementation of management 

actions and pertain to all National Forest System lands located within the Umatilla National Forest, 

including the Sunrise project planning area. All Forest-wide standards and guidelines pertinent to live 

and dead forest vegetation are incorporated by reference into both the Management Direction section 

of this document, as well as project design criteria utilized during any implementation of activities 

that may occur. Standards and Guidelines that prescribe management activities are incorporated by 

reference into the design criteria of the Sunrise Project. The project is consistent with the Forest Plan

because the activities of the project—or characteristics of those activities—are described and 

constrained by the Plan itself. 

Consistency with Eastside Screens

In 1993, the Natural Resources Defense Council (NRDC) petitioned the U.S. Forest Service (Pacific 

Northwest Region) to halt all timber harvest activity in old growth forest occurring on national forest 

lands located east of the Cascade Mountain crest in Oregon and Washington.

That year a group of university and U.S. Forest Service research scientists released an “Eastside 

Forest Ecosystem Health Assessment” in draft form. In response to the NRDC petition and the 

collaborative draft, the Pacific Northwest Region of the U.S. Forest Service issued direction requiring 

that timber sales prepared and offered by Eastside National Forests be evaluated to determine their 

potential impact on riparian habitat, historical vegetation patterns, and wildlife fragmentation and 

connectivity. Commonly referred to as the Eastside Screens, this direction is amended to the Umatilla 

Forest Plan and was followed in this project. 

Compliance with the Eastside Screens for all silviculture activities can be found in Appendix C. 

Fire and Fuels Management

Implementation of Alternatives B or C complies with the Forest Plan and desired condition for fire 

and fuels as outlined in the report. 

The Umatilla National Forest Land and Resource Management Plan (USDA Forest Service 1990) 

provides the overall direction of management activities on the Forest (see Chapter 1). Forest-wide 

management goals, as well as management area direction, represent the desired future condition that 

management actions are designed to achieve. Table 93 displays the Forest goal and management area 

direction for the project relative to fire and fuels management. 
Sunrise Vegetation and Fuels Project

260 Umatilla National Forest

Table 93. Forest Plan goals and management area direction relative fire and fuels management.

Management 

Area

Management Area Description

A4 – Viewshed 2 The Desired Future Condition (DFC) for Viewsheds is to maintain or create a near 

natural landscape. Management activities will be done with sensitivity to people’s 

concern for scenic quality, with vegetative manipulation conducted so that Forest 

management activities remain visually subordinate in foregrounds of selected travel 

routes and sites. All timber management practices and intensities shall be permitted 

consistent with achieving the primary visual quality goals. Prescribed low intensity fire 

with minimal scorch is acceptable. 

A6 – Developed 

Recreation

This Management Area is managed to provide recreation opportunities that are 

dependent on the development of structural facilities for user conveniences. Trees will 

be managed on a nonscheduled basis to meet recreation objectives and to reduce the 

risk of public injury from hazardous trees or vegetation. Slash resulting from hazard tree 

removal will be available for firewood to campground users. 

C1 – Dedicated 

Old Growth

This MA is managed to provide and protect sufficient suitable habitat for wildlife species 

dependent upon mature and/or overmature forest stands, and promote a diversity of 

vegetative conditions for such species. Timber management and harvest activities will 

not be scheduled or permitted. Natural fuel treatments are permitted to maintain or 

enhance old growth habitat characteristics or reduce the potential for a high number of 

and/or severely burned acres. Prescribed burning is the preferred method of fuel 

treatment.

C3 – Big Game

Winter Range

The Desired Future Condition (DFC) for this MA is a mosaic pattern of managed forests, 

brush patches and large grasslands. The management goal is to provide a high level of 

potential habitat effectiveness and high quality forage for big game. Emphasis will be on 

cover, forage, and road management. Timber management is on a scheduled basis with 

emphasis on uneven-aged management. All types of prescribed fire may be used 

including broadcast burning, underburning, or range burning.

C4 - Wildlife 

Habitat

This MA is managed to provide high levels of potential habitat effectiveness for big game

and other wildlife species with emphasis on size and distribution of habitat components. 

Unique wildlife habitats and key use areas will be retained or projected. DFC for the MA 

is a mosaic of even-aged and uneven-aged stands dispersed in a manner to create a 

pattern of forage, and marginal satisfactory cover for big game. All timber management 

practices and intensities consistent with achieving the primary wildlife habitat 

management goals will be permitted. All types of prescribed fire may be used to 

accomplish management objectives. 

C5 – Riparian 

(Fish and Wildlife)

This MA is managed to maintain or enhance water quality, and produce a high level of 

potential habitat capability for all species of fish and wildlife within the designated 

riparian habitat areas while providing for a high level of habitat effectiveness for big 

game. DFC for this MA A near natural setting will predominate adjacent to the stream, 

with a wide variety of plant communities of various species, sizes, and age classes. In 

forested riparian zones, a continuous high tree canopy layer will be present and the 

forest will appear denser than in the surrounding land. Upper and mid-level conifer and 

hardwood canopy structure and lower shrub level will provide desired levels of stream 

surface shading, streambank stability, and satisfactory cover for big game. Timber will be 

managed on a scheduled basis with exceptions (see Forest Plan for exceptions). 

Prescribed fire may be used, consistent with riparian objectives. 

C8 – Grass-Tree 

Mosaic

Managed to remain natural appearing with predominant view of patches or stringers of 

timber occurring on open, generally steep hillsides. Many forest stands will appear as 

mature timber with some having multi-layered canopies. Some stands will be more open 

as result of management activities designed to improve big game habitat. Forage will be 

abundant and improved through management. All types of prescribed fire may be used

including broadcast burning, underburning, or range burning.
Final Environmental Impact Statement

Pomeroy Ranger District 261

Management 

Area

Management Area Description

E2 – Timber and 

Big Game

Manage forest lands to emphasize production of wood fiber (timber), 

Encourage forage production, and maintain a moderate level of big game and other 

wildlife habitat. DFC is to manage for timber production, domestic livestock, big game 

and other wildlife habitat. Forest will contain a mosaic of even-aged and uneven-aged 

stands dispersed in a manner creating patterns of tree cover for big game and openings 

providing forage. Timber will be managed on a scheduled basis. All timber management 

practices and intensities will be permitted. Prescribed fire may be used to accomplish a 

variety of timber and forage production objectives. 

Asotin Creek 

Inventoried 

Roadless Area

The Asotin Creek Inventoried Roadless Area is overlaid with Umatilla Forest Plan

Management Allocation Designations. Primary allocations are C3, C3A and C8 

(described above) and all allow the use of prescribed fire for management activities. 

Table 94 further compares fuels treatments by management area for each action alternative.

Table 94. Fuels treatments by management area.

Alternative B Alternative C

Management Area Grapple 

Pile

Jackpot 

Burn

NonCommercial 

(Hand 

and/or 

Mechanical)

Landscape 

Prescribed 

Fire

Grapple 

Pile

Jackpot 

Burn

NonCommercial 

(Hand 

and/or 

Mechanical)

Landscape 

Prescribed 

Fire

A4 - Viewshed 2 483 - - 306 201 - - 306

A6 - Developed Recreation 17 - - 19 - - - 19

C1 - Dedicated Old Growth - - - 596 - - - 596

C3A - Sensitive Big Game Winter Range - - 776 878 - - 776 878

C3 - Big Game Winter Range - 67 1272 3172 - 49 1272 3172

C4 - Wildlife Habitat 564 810 171 5444 128 549 171 5444

C5 - Riparian (Fish and Wildlife) - - - 240 - - - 240

C8 - Grass-Tree Mosaic - - - 3238 - - - 3238

E2 - Timber and Big Game 4 - 37 160 - - 37 160

Overall Goal - Provide and execute a fire protection and fire use program that is cost efficient and 

responsive to land and resource management goals and objectives. 

Specific to fuels management – Levels and methods of fuels treatment will be guided by the 

protection and resource objective of the management area. Emphasis will be on intensive utilization 

of wood residues using a marketing strategy to reduce fuel loadings; and prescribed fire will be 

utilized to meet management objectives and maintain fuel profiles in all ecosystems. 

Other applicable regulatory framework that guides fuel activities is located in the Fuels specialist’s 

report.

Wildlife species 

All alternatives would be consistent with Forest Plan standards and guidelines, because they would 

meet project design criteria set for the project, meet standards and guidelines for affected land 

management allocations, and provide for viable populations of wildlife species. All alternatives would 

provide for diversity of plant and animal communities in the Sunrise project area, based on the 

suitability and capability of the land therein. 
Sunrise Vegetation and Fuels Project

262 Umatilla National Forest

A biological evaluation (BE) was completed for federally listed and proposed endangered and 

threatened species, and for animal species currently listed as sensitive on the Regional Forester's 

Sensitive Species List (project file). Determinations were made that none of the proposed project 

activities would adversely affect, contribute to a trend toward federal listing, nor cause a loss of 

viability to listed animal populations or species. 

All project alternatives are consistent with the Endangered Species Action, Migratory Bird Treaty Act, 

Bald and Golden Eagle Protection Act, and Facilitation of Hunting Heritage and Wildlife 

Conservation Executive Order (see statements on page 3-224).

Fish species

All of these alternatives would be consistent with Forest Plan direction regarding native fish 

populations. None of the potential effects of timber harvest, fire/fuels management and associated 

activities, under any of these alternatives, would be expected to retard progress towards PACFISH

Riparian Management Objectives. Application of PACFISH direction would maintain or improve fish 

habitat conditions in the analysis area. 

For redband trout, a Forest management indicator species, no alternatives would result in any direct, 

indirect or cumulative population level effects nor a negative habitat trend at either the watershed or 

Forest scale. Project design criteria and BMP monitoring would ensure that the probability and 

magnitude of those effects remain both unlikely and immeasurable to the extent they occur. 

As a result, the proposed activities under these alternatives would not affect the viability of redband 

trout at the watershed scale

For steelhead, a Forest management indicator species, the overall direct and indirect effects of any of 

this project’s action alternatives would limit effects to steelhead and their habitat at the project scale 

and thus at the forest scale, due to distance from project activities, and due to project design criteria 

and BMP monitoring that would ensure any effects from activities, to the fish habitat indicators, 

would be unlikely and immeasurable. No alternatives would reduce population viability or result in a 

negative habitat trend at either the watershed or Forest scale.

During the 5-year ESA status review of the Snake River Basin steelhead, it was determined that the 

Asotin Creek summer steelhead population remains not viable mainly due to the lack of data on adult 

spawners and productivity (NMFS, 2011). This project would not retard recovery of populations in 

the Lower Snake River. The project is consistent with the Forest Plan as amended by PACFISH; none 

of the project alternatives would retard recovery of Snake River Basin steelhead within NFS lands; 

they are all consistent with relevant standards and guidelines for the various activities.

First Foods

The Sunrise Vegetation and Fuels Management Project alternatives would not impact fisheries 

resources, which are one of the First Foods within the analysis area. These resources are valued by 

Native American tribal members, who hunt and gather salmonid species in their usual and 

accustomed areas. The effects determination made for the Sunrise Vegetation and Fuels Management 

project was that it “May effect, but not likely to adversely affect” Snake River Basin steelhead or their 

designated critical habitat and “will not adversely affect” Essential Fish Habitat for salmon. The 

project “may effect, but not likely to adversely affect” SR Chinook salmon or their designated critical 

habitat due to the distance between the project activities and historically occupied habitat and through

the implementation of Design criteria and BMPs. 
Final Environmental Impact Statement

Pomeroy Ranger District 263

Hydrology

The Umatilla National Forest Land and Resource Management Plan (LRMP) provides standards and 

guidelines. Implementation of design criteria and best management practices as described above, 

Umatilla National Forest Road Use Rules, as well as standard Umatilla NF timber sale contract 

specifications or the corresponding stewardship contract specifications would constitute compliance 

with the Umatilla National Forest Land and Resource Management Plan for hydrologic and water 

quality components. 

Neither action alternative would have direct or indirect effects to hydrologic function, floodplains, 

water temperature, sediment, or water yield, as all actions will not take place in, let alone near 

RHCAs, and any potential effects to water resources from supporting activities such as haul road 

traffic will be mitigated. 

Soils

Multi-Use Sustained Yield Act of 1960, directs the agency to manage resources (outdoor recreation, 

range, timber watershed and fish) in combination that best meets the needs of the American people. 

Sustained yield means achieving and maintaining into perpetuity a high-level annual or regular 

periodic output of renewable resources without impairment of the productivity of the land.

Forest Service Manual (FSM) 2500 has the objective (FSM 2551.02) to determine if land 

management practices need adjustments to sustain or restore soil quality.

The FSM 2551.5 further states that the use of soil quality indicators ultimate goal is to provide 

information on the health of the soil. For example; when an indicator (i.e. tree growth), is altered by 

management practices. This type of alteration to soil indicators is considered an expression of a 

detrimental change to the productivity of the soil resource.

The Desired Future Condition in the 1990 Forest Plan for water/soil is to maintain soil productivity

(Forest Plan p. 4-9). The plan further states that Standards and Guidelines are to maintain a minimum 

of 80 percent of an activity area in a condition of acceptable productivity potential. Acceptable 

productivity is defined as:

• Less than 20% increase in bulk density of volcanic soil or a less than 15 percent increase in soil 

bulk density for other forest soils.

• Soil disturbance of less than 50 percent of the topsoil humus enriched A1 and or AC horizons from 

an area 100 sq. ft. (i.e. 5ft by 20ft)

o Molding of the soil in vehicle tracks that are rutted to a depth less than 6 inches.

• Severely burned soil with the top layer of mineral soil altered in color (usually to red) and the next 

1⁄2 inch blackened from organic matter charring.

• Plan and conduct land management activities so that soil loss from surface erosion and mass 

wasting, caused by activities would not result in an unacceptable reduction in soil productivity or 

water quality.

• Management activities shall be designed and implemented to retain sufficient ground vegetation 

and organic matter to maintain long-term soil and site productivity.

• Active slump and landslide areas are considered unavailable for road construction. Areas with 

known landslide potential and lake sediments require special transportation planning and design, 

layout preconstruction, construction and maintenance techniques.
Sunrise Vegetation and Fuels Project

264 Umatilla National Forest

A certain amount of overlap occurs when logging activity happens on units with existing detrimental 

soil condition as machinery reuses some trails and landing sites. This tends to reduce the amount of 

added, new detrimental soil impacts. However, this was not used to reduce the estimated increase 

percentage in DSC in the assessment due to uncertainty on the extent of this effect on a specific unit. 

This will likely lead to some overestimation of total potential DSC in units with existing soil 

disturbance from previous activity. 

Cumulative effects relative to erosion hazard are not relevant within treatment units as surface 

recovery occurs rapidly enough to eliminate this as a cumulative concern. Data collected during a 

fuels treatment study (Wondzell and Clifton 2005) in the Sunrise Project area found that ground cover

was maintained to Forest Plan Standards (Figure 4). The study monitored hillslope erosion for three 

treatments: prescribed fire; commercial timber yarding followed by prescribed burning; and yarding 

of all fuels (> 3” dbh) followed by prescribed burning. 

Soil rehabilitation of adverse soil conditions is expected to be necessary on several units with existing 

high levels of DSC (see Soils report). Obliteration of temporary roads, scarification/subsoiling of 

landings, and retention of as much organic matter as fire risk/fuel objectives will help ameliorate and 

rehabilitate site conditions for productive capacity and reduced erosion hazard.

Botany

This project is consistent with Forest Plan goals (p. 4-7) and Forest-wide standards and guidelines 

(pp. 4-89 to 4-90). As required, a Biological Evaluation for plant species is available and located in 

the project analysis file. 

Invasive plants

The proposed Sunrise project is consistent with the Forest Plan, as amended, with respect to noxious 

weeds. This finding is based on the the above discussions of existing condition, the mechanisms of 

invasive species spread, and the inclusion of prevention measures included in Chapter 2, which are 

identical to those described in the Forest Plan.

Visual Resources (scenery)

Alternatives B and C would remain compliant with the Forest Plan standards and guides for Visual 

Quality Objectives and Scenery Management, because analyzed activities would result in site-specific 

conditions consistent with Forest Plan allocations. 

Inventoried Roadless Areas (IRA), Potential Wilderness Areas (PWA) and other 

Undeveloped Lands 

All 4,527 acres of undeveloped lands identified within the analysis area would not qualify as a 

Potential Wilderness area, Inventoried Roadless Area, or a designated Wilderness area. This outcome 

is consistent with the intent of the land allocation decisions made in the Forest Plan.

Recreation

All action alternatives would be in compliance with the Forest Plan, forest wide standards and 

guidelines for recreation.
Final Environmental Impact Statement

Pomeroy Ranger District 265

Air quality

Implementation of any action alternative would remain consistent with the Forest Plan management 

goal #18 –to maintain air quality at a level adequate for protection and use of forest resources and 

which meets or exceeds applicable Federal and state standards (Forest Plan p. 4-2). Air quality 

standards would be maintained at a level to meet Washington State and Federal standards (Clean Air 

Act) through coordination and compliance with Washington State DNR guidelines and approval 

process. Available predictive and management methods and models would be used to minimize the 

effects of smoke on any smoke sensitive areas. 

Range

All action alternatives would be consistent with Forest Plan objectives to manage grazing resources to 

maintain and improve vegetative conditions compatible with protecting and maintaining use of the 

Asotin and Peola C&H Allotments.

Forest products

The Forest Plan provides standards and guidelines for the production of forest products. All action 

alternatives comply with this plan by providing wood products for local communities.

National Forest Land Suitability

Finding: As described in the Management Direction section of this report, all silvicultural activities 

would be implemented only on lands meeting the definition of forest land (16 U.S.C. 1604) and 

designated as suitable for timber production by the Forest Plan (USDA Forest Service 1990), as 

amended.

Appropriateness of Even-aged Management

Finding: All proposed even-aged management is considered an appropriate method to achieve the 

identified objectives and other Forest Plan components such as desired future conditions. All stands 

where even-aged management is prescribed would have generally reached culmination of mean 

annual increment (see project design criteria). Implementation of the proposed regeneration

silvicultural activities would result in created openings, as defined by Forest-wide direction in the 

Forest Plan, but none of the created openings would exceed 40 acres in size.

Optimality of Clearcutting

Finding: Any silvicultural prescriptions designating a clearcutting activity would only do so if such 

an activity is found to be the optimal silvicultural activity (see project design criteria). This 

determination would be made using criteria provided in the Forest Plan: “stand condition and 

structure; insect and disease problems; silvics of the tree species concerned; plant community; 

logging method feasibility and probability of success; site characteristics; regeneration difficulty; 

economics; and other factors all in the context of meeting the resource objectives for that 

management area portrayed in the Forest Plan” (USDA Forest Service 1990, page 4-68).

All silvicultural prescriptions recommending a clearcutting activity would do so only if it is found to 

be an activity of last resort –only proposed when no other intermediate or regeneration cutting 

method to meet stand management objectives would be appropriate or compatible with existing stand 

conditions. A major factor in this determination would likely be the presence or absence or a 

sufficient number of acceptable seed trees. This means that clearcutting would be proposed only when 
Sunrise Vegetation and Fuels Project

266 Umatilla National Forest

the silvicultural prescription for a given stand shows a clearcutting method would accomplish Forest 

Plan objectives that cannot be accomplished through other cutting methods.

Finding: To the extent practicable, clearcut units would be shaped and blended to emulate the 

analysis area’s natural terrain (see project design criteria).

Vegetation Manipulation

Finding: Tree stand manipulation complies with requirements found in 16 U.S.C. 1604:

1. The proposed silvicultural activities are well suited to the multiple-use goals and objectives 

established for the Sunrise planning area when considering the potential environmental 

impacts associated with their implementation.

2. There is ample assurance that lands proposed for regeneration cutting (created openings in the 

context of the Forest Plan) would be adequately restocked within five years after final 

harvest, because no activities would be conducted in locations in which the silvicultural 

prescription does not amply demonstrate the capacity for restocking (see project design 

criteria).

3. The proposed silvicultural prescriptions were not chosen primarily because they would give 

the greatest dollar return or the greatest output of timber, although these factors were 

considered when evaluating whether a proposed silvicultural activity was economically 

feasible.

4. The potential implementation effects on residual trees and adjacent stands were considered 

when developing the silvicultural proposals.

5. No permanent (e.g., irreversible) impairment of site productivity is expected as a result of the 

proposed silvicultural activities, and the project’s design criteria, management requirements, 

and best management practices ensure conservation of soil, slope, and other watershed

conditions.

6. Riparian Habitat Conservation Areas (RHCAs) would be specifically designated on the 

ground in such a way as to exclude their full extent from any adjacent upland forest area 

selected for silvicultural treatment. 

7. Silvicultural activities proposed for implementation in the Sunrise Vegetation and Fuels 

Management Project are expected to provide desired effects with respect to water quantity 

and quality, wildlife and fish habitat, regeneration of desirable tree species, forage

production, recreation uses, aesthetic values, and other resource yields.

8. Silvicultural activities proposed for implementation in the Sunrise Vegetation and Fuels 

Management Project are considered practical in terms of transportation and harvesting 

requirements, and total financial costs of project preparation, timber harvest, and sale 

administration.

Endangered Species Act

Determination have been made that the proposed actions would not result in irreversible or 

irretrievable commitment of resources that foreclose formulation or implementation of reasonable or 

prudent alternatives. 

This project complies with present Federal regulations (ESA) pertaining to the management of 

Threatened, Endangered, and Sensitive plant species.

Consultation on the Sunrise Vegetation and Fuels Management Project, with NOAA Fisheries and U. 

S. Fish and Wildlife Service, occurred in August of 2018. The project determination was May Affect, 

Not Likely to Adversely Affect ESA listed Snake River Basin steelhead and Columbia River bull trout 
Final Environmental Impact Statement

Pomeroy Ranger District 267

and their DCH (letter and analysis on file). Besides those just mentioned, there would be no effects to 

other listed fish and their designated critical habitats or sensitive species and their habitats. 

Consultation for Canada lynx and yellow-billed cuckoo is not necessary since a determination has 

been made that the proposed activities would have no effect to these species. Conferencing for 

wolverine is not necessary since a determination was made that there would be not likely to 

jeopardize the continued existence of wolverine.

Migratory Bird Treaty Act

All action alternatives are consistent with the 1918 Migratory Bird Treaty Act (MBTA) and the 

Migratory Bird Executive Order 13186. The Forest Service supports the conservation intent of the 

migratory bird conventions by integrating bird conservation principles, measures, and practices into 

agency activities and by avoiding or minimizing, to the extent practicable, adverse impacts on 

migratory bird resources when conducting agency actions. Some specific examples for this project 

include retaining snags, retention of large trees, avoiding riparian areas, protecting raptor nests, and 

not burning during nesting season. Specific species of concern were considered and the Conservation 

Strategy for Landbirds (Altman 2000) was reviewed for effects disclosures. 

Bald and Golden Eagle Protection Act

All action alternatives comply with the National Bald Eagle Management Guidelines (USFWS 2007) 

and the Bald and Golden Eagle Protection Act. Use of the area by eagles is sporadic, and no nesting 

or roosting habitat would be affected by the proposed activities. 

Facilitation of Hunting Heritage and Wildlife Conservation Executive Order

Both action alternatives meet the intent of the Facilitation of Hunting Heritage and Wildlife 

Conservation Executive Order, specifically by proposing enhancements to elk winter range and 

bighorn sheep habitat.

Clean Water Act of 1972 

The Clean Water Act of 1972 and amendments require the restoration and maintenance of the 

chemical, physical, and biological integrity of the nation’s waters. All of the activities proposed in 

this project were designed to be consistent with the Clean Water Act and State of Washington Water 

Quality Standards.

Floodplains, Executive Order 11988

E.O. 11988 requires the Forest Service to avoid “to the extent possible the long and short term 

adverse impacts associated with the ... occupation ... or modification of floodplains...” The E.O. also 

provides direction to restore and preserve the natural and beneficial values served by floodplains. 

Actions proposed in the Sunrise Project would preserve the beneficial values of floodplains within the 

project area and for this reason, the Sunrise Project is consistent with this EO. 

Wetlands, Executive Order 11990

E.O. 11990 requires the Forest Service to "avoid to the extent possible the long and short term 

adverse impacts associated with the ... destruction or modification of wetlands." The Sunrise Project 

does not propose to destroy or modify any wetland. For this reason, the Sunrise Project is consistent 

with this EO. 
Sunrise Vegetation and Fuels Project

268 Umatilla National Forest

Wetlands, Executive Order 12898

Executive Order 12898, issued in 1994 orders Federal Agencies to identify and address any adverse 

human health and environmental effects of agency programs that disproportionately impact minority 

and low-income populations. The Order also directs agencies to consider patterns of subsistence 

hunting and fishing when an agency action may affect fish or wildlife. None of the alternatives 

restrict or alter opportunities for subsistence hunting and fishing by Native American tribes. Tribes 

holding treaty rights for hunting and fishing on the Umatilla National Forest are included on the 

project mailing list and have the opportunity to provide comments on this project. More employment 

and income opportunities would be created by each action alternative than by Alternative 1 (no 

action). Implementation of either action alternative would not likely adversely affect minority or lowincome populations.

Municipal Watersheds

There are no designated municipal watersheds in the Sunrise Project area.

Treaty Resource Protection 

In this analysis, the primary focus of the federal government Trust Responsibility is the protection of 

the treaty rights and interests that tribes reserve on land included in this project. The Nez Perce Tribe 

has treaty rights and interests in the South George area. 

A government-to-government scoping letter was sent to staff members of the Nez Perce Tribe and 

Confederated Tribes of the Umatilla Indian Reservation on December 14, 2014, informing them of 

the Sunrise proposed project and requesting any comments or concerns regarding the project. The 

Pomeroy District Ranger presented the District Program of Work to Nez Perce tribal staff members on 

in the spring of 2015, 2016, and 2017, and continued to update the Nez Perce tribal staff members at 

subsequent opportunities. At these meetings, projects are presented and the District Ranger solicits 

questions, comments, or requests for additional information. Several field trips were also organized 

with tribal staff members on June 29, 2015, December 08, 2015, and October 24, 2016 to view the 

project area, discuss potential treatments, answer any questions and address any concerns. No specific 

comments or concerns for South George project were presented by tribal staff members after the 

government to government consultation scoping letter or Program of Work meetings. Tribal staff 

members have identified for similar past projects the rights they believed most at risk. Of major 

concern are potential effects on Treaty rights, fish habitat and populations, water quality, and 

protection of archaeological sites, traditional cultural properties, and first foods resources.

Cultural Resource surveys were conducted to locate cultural sites and gather the information 

necessary to evaluate historic properties. Identified sites and any newly recorded sites would be 

protected from all project activities associated with the Sunrise Vegetation and Fuels Management 

Project (Chapter 2, Table 2-5). A Project Review for Heritage Resources under the terms of the 1997 

Programmatic Agreement between ACHP, SHPO, and USFS R6, has been completed (2/14/12). A No 

Adverse Effect (with stipulations) determination was made. 

Timber harvest has the potential to negatively affect water quality and thus indirectly aquatic habitat. 

The effects of harvest and associated activities on water quality are discussed in the Hydrology 

section in this chapter. It was found that effects of the action alternatives would not adversely or 

measurably affect water quality. 

The action alternatives were designed to prevent damage to RHCAs. Riparian and channel

components that protect water quality would be maintained over the long run. 
Final Environmental Impact Statement

Pomeroy Ranger District 269

Other design criteria and BMPs would control disturbance that could lead to erosion and 

sedimentation.

The effects of harvest and associated activities on aquatic species and habitats are found in the 

Fisheries section. It was determined that action alternatives may effect – not likely to adversely affect 

threatened species and may impact some sensitive species (see Table 3-15). Based on the information 

summarized above, it is reasonable to assume that treaty rights would be protected during 

implementation of the proposal.

3.22 Short-term Uses and Long-term Productivity

NEPA requires consideration of “the relationship between short-term uses of man’s environment and 

the maintenance and enhancement of long-term productivity” (40 CFR 1502.16). As declared by the 

Congress, this includes using all practicable means and measures, including financial and technical 

assistance, in a manner calculated to foster and promote the general welfare, to create and maintain 

conditions under which man and nature can exist in productive harmony, and fulfill the social, 

economic, and other requirements of present and future generations of Americans (NEPA Section 

101).

3.23 Unavoidable Adverse Effects

Effects that cannot be avoided due to constraints in alternatives. These effects do not have to be 

avoided by the planning agency, but they must be disclosed, discussed, and mitigated, if possible (40 

CFR 1500.2(e).

Other than Soil resources, there are no effects that will not be mitigated through basic forest 

guidelines or implementation of BMPs

Concerning soils, as it may apply to temporary roads placed on shallow soils, some effects may be 

irreversible depending upon the depth of impact, organic matter present in the soil and the depth of 

the soil itself. These areas are of minimal importance to timber production, but have a multitude of 

other resource values. These impacts over time may be colonized by noxious weeds and other pioneer 

species suited to such undeveloped conditions; which may lead to other resource damage. Therefore 

these types of impacts are expected to minimize to reduce the occurrence of irreversible damage to 

the soil resource.

3.24 Irreversible and Irretrievable Commitments of Resources

Irreversible commitments of resources are those that cannot be regained, such as the extinction of a 

species or the removal of mined ore. Irretrievable commitments are those that are lost for a period of 

time such as the temporary loss of timber productivity in forested areas that are kept clear for use as a 

power line rights-of-way or road.

For all action alternatives (B and C) there would be no irreversible or irretrievable commitment of 

resources with implementation of proposed activities.

3.25 Other Required Disclosures

This section describes how the action alternatives comply with applicable state and Federal laws, and 

Forest Service policies and regulations.
Sunrise Vegetation and Fuels Project

270 Umatilla National Forest

National Historic Preservation Act –Heritage surveys have been completed. State Historic 

Preservation Office consultation was conducted under the Programmatic Agreement among the 

United States Department of Agriculture, Forest Service, Pacific Northwest Region (Region 6), the 

Advisory Council on Historic Preservation, and Washington State Historic Preservation Officer 

regarding Cultural Resource Management on National Forests dated April 1997. Identified sites and 

any newly recorded sites are protected from all project activities associated with Sunrise Vegetation 

and Fuels Management Project. Because heritage resources would not be affected by proposed 

activities under any action alternative, there would be no effect to any historic property listed in or 

eligible to the National Register of Historic Places.

Endangered Species Act and Regional Forester's Sensitive Species - The Endangered Species Act 

requires protection of all species listed as "Threatened" or "Endangered" by Federal regulating 

agencies (Fish and Wildlife Service and National Marine Fisheries Service). The Forest Service also 

maintains through the Federal Register a list of species which are proposed for classification and 

official listing under the Endangered Species Act, species which appear on an official State lists, or 

that are recognized by the Regional Forester as needing special management to prevent their being 

placed on Federal or State lists. Biological Evaluations have been completed for all TE&S plant, 

aquatic and terrestrial wildlife. Details are found in the Fisheries, Botany, and Wildlife sections of this 

chapter, and relevant appendices.

Wild and Scenic River Act – There are no Wild and Scenic Rivers within the project area. No 

designated or potential wild and scenic river sections would be affected by implementation of any 

alternative.

Prime Farmland, Range Land, and Forest Land - No adverse effects on any prime farmland, range 

land, and forest land not already identified in the Final DEIS for the Forest Plan would be expected to 

result from implementation of any alternative.

Civil Rights, Women, and Minorities - No adverse effects on civil rights, women, and minorities 

not already identified in the DEIS for the Forest Plan would be expected to result from 

implementation of any alternative. Alternatives B and C would be governed by Forest Service 

contracts, which are awarded to qualified contractors and/or purchasers regardless of race, color, sex, 

religion, etc. Such contracts also contain nondiscrimination requirements. 

National Forest Management Act Compliance – The National Forest Management Act of 1976 

(P.L. 94-588), including its amendments to the Forest and Rangeland Renewable Resources Planning 

Act of 1974 (P.L. 93-378), states that when trees are cut to achieve timber production objectives, the 

cuttings shall be made in such a way that “there is assurance that such lands can be adequately 

restocked within 5 years after harvest” (P.L. 93-378, Sec. 6, (g), (3), (E), (ii)). See Appendix C, pp. C9 to C-10.

This reforestation policy is based specifically on language from the National Forest Management Act

of 1976 (P.L. 94-588), including its amendments to the Forest and Rangeland Renewable Resources 

Planning Act of 1974 (P.L. 93-378): “Sec. 3 (d) (1) It is the policy of the Congress that all forested 

lands in the National Forest System be maintained in appropriate forest cover with species of trees, 

degree of stocking, rate of growth, and conditions of stand designed to secure the maximum benefits 

of multiple use sustained yield management in accordance with land management plans.” 

Treaty Trust Responsibilities - In this analysis, the primary focus of the federal government Trust 

Responsibility is the protection of the treaty rights and interests that tribes reserve on land included in 

this project. The Nez Perce Tribe has treaty rights and interests in the Sunrise project area. 
Final Environmental Impact Statement

Pomeroy Ranger District 271

A government to government scoping letter was sent to tribal staff members of the Nez Perce Tribe 

and Confederated Tribes of the Umatilla Indian Reservation on December 14, 2014, informing them 

of the Sunrise proposed project and requesting any comments or concerns regarding the project. The 

Pomeroy District Ranger presented the District Program of Work to Nez Perce tribal staff members on 

in the spring of 2015, 2016, and 2017, and continued to update the Nez Perce tribal staff members at 

subsequent opportunities. At these meetings, projects are presented the District Ranger solicits 

questions, comments, or requests for additional information. Several field trips were also organized 

with tribal staff members on June 29, 2015; December 08, 2015; and October 24, 2016 to view the 

project area, discuss potential treatments, answer any questions and address any concerns. 

Cultural Resource surveys were conducted to locate cultural sites and gather the information 

necessary to evaluate historic properties. Identified sites and any newly recorded sites would be 

protected from all project activities associated with the Sunrise Vegetation and Fuels Management 

Project. A Project Review for Heritage Resources under the terms of the 1997 Programmatic 

Agreement between ACHP, SHPO, and USFS R6, is underway. 

Timber harvest has the potential to negatively affect water quality and thus indirectly aquatic habitat. 

The effects of harvest and associated activities on water quality are discussed in the Hydrology 

section in this chapter. It was found that effects of the action alternatives would not adversely or 

measurably affect water quality. The action alternatives were designed to prevent damage to RHCAs. 

Riparian and channel components that protect water quality would be maintained. Other design 

criteria and BMPs would control disturbance that could lead to erosion and sedimentation.

The effects of harvest and associated activities on aquatic species and habitats are found in the 

Fisheries section. It was determined that action alternatives may effect – not likely to adversely affect 

threatened species and may impact some sensitive species.

Based on the information summarized above, it is reasonable to assume that treaty rights would be 

protected during implementation of the proposal.

Roads Analysis - A Forest-wide Roads Analysis was completed in March 2004 on the Umatilla 

National Forest. The forest scale analysis addressed only those National Forest System Roads 

maintained for passenger car traffic, arterial, and collector roads. The Sunrise project planning area 

has arterial, collector, and local roads. These roads are seasonally opened or are closed system roads. 

A site-specific project Roads Analysis containing a road risk value for each road was completed for 

this project and is located in the project file. This project analysis also includes maps showing the risk 

value for each road and the operational maintenance level of each road in the project planning area. A 

summary list of miles of roads used as haul routes for each alternative and other proposed road 

activity such as temporary road construction, and proposed decommissioning of roads in Alternative 

C is found in Table 2-11. No new system road construction is proposed for this project.

Floodplains, Executive Order 11988 – Executive Order (EO) 11988 requires the Forest Service to 

avoid “to the extent possible the long and short term adverse impacts associated with the occupation 

or modification of floodplains...” The proposed alternatives would avoid all floodplains and affects 

to floodplains and is consistent with this EO.

Wetlands, Executive Order 11990 - Executive Order (EO) 11990 requires the Forest Service to 

“avoid to the extent possible the long and short term adverse impacts associated with the destruction 

or modification of wetlands.” The proposed alternatives would avoid all wetlands and affects to 

wetlands and is consistent with this EO.
Sunrise Vegetation and Fuels Project

272 Umatilla National Forest

Municipal Watersheds - There is no de-facto or designated municipal watershed in the Sunrise

project planning area. 

Energy Requirements - No adverse effects on energy requirements would be expected to result from 

implementation of any alternative.

Public Health and Safety - Public health and safety would be improved with Alternatives B and C 

removing danger trees along open forest routes, haul routes, developed recreation sites, and 

administrative sites within the Sunrise project planning area. 

Environmental Justice – No local minority or low income populations were identified during 

scoping or environmental effects assessment. No minority or low-income populations are expected to 

be affected by implementation of any of the alternatives, in accordance with Executive Order 12898.

3.26 Cumulative Impacts

Detailed findings for issues pertaining to the project purpose and need, as well as issues driving 

alternatives are described below. Findings and conclusions are discussed in comparative format 

between management alternatives. Additional findings for other resource issues are then briefly 

discussed. Alternatives B and C would meet the project purpose and need elements discussed in 

Chapter 1 to some degree, with Alternative B doing so more than Alternative C. Because the purpose 

and need elements would trend away from desired conditions under Alternative A, it does not meet 

the project purpose and need at all. 

Forest Vegetation Composition, Structure, and Density

The direct, indirect, and cumulative effects of the action alternatives would not result in changes of 

species cover types in all locations, but changes that would occur generally would involve a shift 

from currently overrepresented cover types dominated by late seral species to currently 

underrepresented cover types dominated by early seral species. Under Alternative B, planned 

activities would reduce the extent of Douglas-fir, grand fir, and subalpine fir-spruce cover types by 

approximately 3900, 1560, and 1940 acres, respectively. Under Alternative C, planned activities 

would reduce the extent of Douglas-fir, grand fir, and subalpine fir-spruce cover types by 

approximately 3260, 870, and 1060 acres, respectively. Each of these respective cover types would 

generally be converted to a “mix” cover type (e.g., grand fir / mix).

A cover type with the term “mix” added is a cover type with the named shade-tolerant species present 

along with a plurality of early seral/shade-intolerant species such as western larch, lodgepole pine, or 

ponderosa pine. The expected changes in extent indicate that Alternative B results in the greatest area 

converted to a cover type in which an early seral conifer species constitutes a majority and/or 

plurality of the overstory forest canopy. 

Although it is not possible to evaluate conversions to a “mix” cover type relative to desired ranges of 

single-species cover types, both action alternatives would increase the relative abundance of currently 

underrepresented early seral species. Alternative B would increase the relative abundance to a greater 

degree than alternative C, and Alternative A (the no-action alternative) would fail to do so at all. 

The direct, indirect, and cumulative effects of the action alternatives would not result in changes of 

forest structural stage in all locations, but changes that would occur generally would involve a shift 

from currently overrepresented structural stages (understory reinitiation and/or old forest multi-strata) 

to currently underrepresented structural stages (stand initiation, stem exclusion, and/or old forest 
Final Environmental Impact Statement

Pomeroy Ranger District 273

single-strata). Under Alternative B, planned activities would reduce the extent of stands in the 

understory reinitiation and old forest multi strata stages by approximately 2020 and 4,570 acres, 

respectively. Activities planned as part of Alternative B would increase the extent of stands in the 

stand initiation, stem exclusion, and old forest single stratum stands by approximately 668, 1860, and 

4,065 acres, respectively. Under Alternative C, planned activities would reduce the extent of stands in 

the understory reinitiation and old forest multi strata stages by approximately 810 and 3,330 acres, 

respectively. Activities planned as part of Alternative C would increase the extent of stands in the 

stand initiation, stem exclusion, and old forest single stratum stands by approximately 330, 990, and 

2,820 acres, respectively. Stands currently in the old forest multi strata stage would remain old forest, 

but be converted to the old forest single stratum stage. The expected changes in extent indicate that 

Alternative B would result in the greatest area converted from currently overrepresented structural 

stages (generally understory reinitiation and old forest multi strata) to currently underrepresented 

stages (generally stand initiation, stem exclusion, and old forest single strata). 

Forest Density is defined as the measure of the amount of tree vegetation per unit of land area. The 

direct, indirect, and cumulative effects of the action alternatives would not result in changes of 

density class in all locations, but changes that would occur generally would involve a shift from 

stands currently in the moderate and high classes to low and moderate classes, respectively. Under 

Alternative B, planned activities would reduce the extent of stands in the high density class by 

approximately 9,450 and 4,570 acres, respectively. Activities planned as part of Alternative B would 

increase the extent of stands in the low and moderate classes by approximately 4,130 and 5,320 acres, 

respectively. Under Alternative C, planned activities would reduce the extent of stands in the high 

density class by approximately 7,000 acres. Activities planned as part of Alternative C would increase 

the extent of stands in the low and moderate density classes by 1,850 and 5,150 acres, respectively. 

The expected changes in extent indicate that Alternative B would result in the greatest area converted 

from currently overrepresented high density classes to currently underrepresented low and moderate 

density classes. 

Fire Regime Condition Class

The proposed treatments would affect FRCC by moving landscape conditions (fuel load, canopy base 

height, stand structure and composition) toward HRV represented by Condition Class 1 from 

Condition Classes 2 and 3. Recommended treatments would reduce fuel loading and ladder fuels, 

increase canopy base height, reduce canopy bulk density and favor fire tolerant species. Treatment 

under all action alternatives would serve to emulate some stand conditions anticipated under the 

historical fire regime. Alternative B would do this to a greater degree than Alternative C, and both 

much more so than Alternative A. 

Timber Production

A component of the purpose and need of the Sunrise project is to make available forest products to 

the region and local communities. Both action alternatives will undergo silviculture treatments which 

include commercial timber harvesting. Alternative B would include harvests across approximately 

5,530 acres, providing an estimated 25.6 million board-feet, while Alternative C would include 

harvests that provide approximately 12.1 million board-feet across 2,560 acres.

Wildlife Habitat

During the scoping process, the need to manage and maintain wildlife habitat was restated. The 

wildlife specialist report addresses potential impacts and findings for each alternative for all 

indicators considered, primarily focusing on management indicator species (MIS).
Sunrise Vegetation and Fuels Project

274 Umatilla National Forest

For all indicators, the No Action alternative is not expected to have any direct/indirect as well as 

cumulative effects. Current conditions are expected to persist outside the desired range. 

Alternatives B and C would both maintain the area within forest plan standards for elk. Activities 

such as burning and thinning are expected to improve forage. It is expected that all MIS species 

including American marten, pileated woodpecker, and Northern three-toed woodpecker would 

continue to have viable populations on the forest. Snag and down wood habitat guidelines will be 

followed. 

Additional Findings

Soil condition. All alternatives would be consistent with Forest Plan Standards and Guidelines for 

achieving soil quality maintenance objectives, including detrimental soil condition and effective 

ground cover.

Water quality and quantity. Effects of proposed actions would not adversely or measurably affect 

water temperature. The proposed project is in compliance with the Clean Water Act, and meets or 

exceeds all Forest Plan Standards and Guidelines for Direct, Indirect, or Cumulative Effects to 

vegetation, wildlife, cultural, and recreation resources. 

Threatened, Endangered and Sensitive species. Depending on the species and location, the 

activities would have no effect or may affect, but are not likely to adversely affect all applicable 

and/or affected Threatened, Endangered, Proposed, and Sensitive fish, wildlife and plant species.

Invasive plants. Within the Sunrise project boundary, the primary difference in effects to invasive 

plant species from each project alternative is shown by the differing numbers of acres that are placed 

at high risk of noxious weed spread. Alternative B creates the most acreage at high vulnerability for 

weed infestation, due to the slightly larger amount of ground disturbing activities proposed. The 

smaller area of ground disturbance in Alternative C results in slightly fewer acres at high risk. There 

is potential for an increase in noxious weed infestation within the planning area due to existing 

conditions and the types of activities analyzed. Invasive weeds, however, are already present in the 

project area, and will be treated regardless of alternative selected. 

Developed recreation. Proposed harvest activities would create short term effects which could 

potentially alter the recreation setting. However, the proposed activities do not alter the setting 

enough to measurably affect the recreation experience. 

Economics and forest products. Alternative B was found to be economically viable, and has a 

higher present net value (PNV) than Alternative C.

Visual quality. It is expected that all of the activities proposed in all of the action Alternatives would 

meet the visual quality objectives of the Forest Plan. The impacts would not exceed the limits of 

visual impacts defined by modification and partial retention. Characteristics of scenic integrity and 

stability are expected to be maintained or enhanced. 

Potential Wilderness Areas (PWAs). For the Asotin Creek PWA activities proposed in or near the 

PWA under Alternatives B and C, smells, sounds and possible sighting of mechanical activities and 

fuel treatment activities, would reduce a sense of solitude and remoteness in the short-term, during 

project activity. Activities adjacent to PWAs would not preclude the PWAs from being retained in the 

PWA inventory.
Final Environmental Impact Statement

Pomeroy Ranger District 275

Roadless Area characteristics. The only activity slated for Inventoried Roadless Area (IRA) is 6,335 

acres of prescribed fire. Under both Alternatives B and C there would be no direct effects to the 

Asotin Creek IRA. Indirect effects are predicted to be positive as biological and ecosystem functions 

are believed to improve under each action alternative as fire will be reintroduced to a fire-dependent

ecosystem. The sounds, air quality, and possible sighting of mechanical activities and fuel treatment 

activities occurring within and areas adjacent to the IRA would reduce a sense of solitude and 

remoteness in the short-term, during project activity. In the long-term, however, there would be no 

change to the availability of solitude or primitive recreation.

Other Undeveloped Lands. All treated units would remain forested after harvest although skid trails, 

stumps, and landings could be evident. Stand structure would change, therefore, diversity of plant and 

animal communities may shift from current patterns but ecological diversity would remain (Chapter 

3, Vegetation section). Impacts to natural integrity and sense of naturalness would likely be evident 

until stumps and vegetation canopies are no longer substantially recognizable (about 75 to 100 years). 

The increased numbers of stumps and the open nature of the forest stand would likely be the most 

apparent visual change resulting from implementation. The sounds of machinery from active units 

would reduce a sense of naturalness and solitude during project operations but would not persist in 

the long term. All proposed activities within Undeveloped Lands will be consistent with Forest Plan

guidelines and project design criteria will help reduce impacts to soils, plants, habitat, recreation, and 

water quality.

Final Environmental Impact Statement

Pomeroy Ranger District 277

Chapter 4. Public, Governmental and Tribal 

Involvement; List of Preparers; and 

Distribution of the Environmental Impact 

Statement

4.1 Public, Governmental and Tribal Involvement

A notice of intent to prepare an EIS was published in the Federal Register on November 28th, 

2014 (79 FR70844). In addition, as part of the public involvement process, the agency sent 

letters on December 12, 2014 describing the project to interested individuals, organizations, and 

other agencies that have indicated an interest in this type of project in the recent past. Using the 

comments from the public, other agencies, and the CTUIR and Nez Perce Tribe, the 

interdisciplinary team developed a list of issues to address and can be found in Section 1.1. of 

the EIS. 

A draft environmental impact statement (DEIS) was published for review and comment on June 

1st, 2018. A list of agencies, organizations, and people who received copies can be found below. 

Mailings were also provided to the Tribes and interested parties list to notify them of the 

comment period. Nine comments were received in response to the request for comment on the 

draft EIS. Comments were summarized and pooled for response, and additions, updates and 

corrections made to the FEIS as appropriate. Response to comments can be found in Appendix 

D of the FEIS, and comment letters are available from the Pomeroy district office as part of the 

project record. 

Tribal Consultation & Coordination

A government to government scoping letter was sent to tribal staff members of the Nez Perce 

Tribe and Confederated Tribes of the Umatilla Indian Reservation on December 14, 2014, 

informing them of the Sunrise proposed project and requesting any comments or concerns 

regarding the project. The Pomeroy District Ranger presented the District Program of Work to 

Nez Perce tribal staff members on in the spring of 2015, 2016, and 2017, and continued to 

update the Nez Perce tribal staff members at subsequent opportunities. At these meetings, 

projects are presented, and the District Ranger solicits questions, comments, or requests for 

additional information. Several field trips were organized with tribal staff members (June 29, 

2015; December 08, 2015; and October 24, 2016) to view the project area, discuss potential 

treatments, answer any questions and address any concerns. Government to government 

consultation letters were sent to the tribes on May 24, 2018 announcing the opening of the 

comment period for the draft EIS. The Nez Perce responded with a comment letter, the contents 

of which were incorporated into our response to comments in this final EIS. 

4.2 List of Preparers

The following Interdisciplinary Team members are USDA Forest Service employees who 

participated and contributed in the development of the project’s purpose and need, proposed 
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278 Umatilla National Forest

action, and alternatives. They undertook the field studies, resource report preparation, and 

analyses of impacts. The section includes information regarding the names of those IDT

members, with their qualifications (expertise, experience, professional disciplines), who were 

primarily responsible for preparing the draft or final environmental impact statement and/or 

significant background papers, (§1502.6 and 1502.8).

Arnold, Alison

Umatilla National Forest, Pomeroy Ranger District, Environmental Coordinator

Contribution: NEPA oversite and review, editor.

Brooks, Paula J.

Umatilla National Forest, Forest Botanist

Contribution: Botany Analysis and TES plants 

Bassett, Jill (Retired)

Umatilla National Forest, Forest Archeologist

Contribution: Heritage Resources

Collin, Johnny

Umatilla National Forest, North Zone TMA

Contribution: Economics Analysis

Dixon, Donna

Umatilla National Forest, GIS Specialist

Contribution: GIS and Map Products

Dowdy, William

Umatilla National Forest, Fisheries Biologist

Contribution: Fisheries Analysis

Druffel, Angela S.

Umatilla National Forest, Pomeroy Ranger District, Range Technician

Contribution: Range Analysis

Fujishin, Monte

Umatilla National Forest, Pomeroy Ranger District, District Ranger

Contribution: Line officer providing management, guidance and oversight

Harris, Holly

Umatilla National Forest, North Zone Wildlife Biologist

Contribution: Wildlife Analysis

Hickman, Tracii

Umatilla National Forest, ESA Consultation Biologist

Contribution: Oversight of TES process and consultation requirements

Justice, Donald C.

Umatilla National Forest, Vegetation Analyst 

Contribution: Data Analyses/Vegetation Modeling

Mackleit, Tara

Umatilla National Forest, Pomeroy Ranger District, Fire/Fuels Technician

Contribution: Fuels and Air Quality Analysis

Mandersheid, John

Umatilla National Forest, Roads and Trails Manager

Contribution: Transportation Analysis 

Marquardt, William

Umatilla National Forest, Pomeroy Ranger District, North Zone Archeologist

Contribution: Heritage Resources
Final Environmental Impact Statement

Pomeroy Ranger District 279

Mattson, Donna

Wallowa-Whitman, Malheur, and Umatilla National Forest, Tri-Forest 

Landscape Architect

Contribution: Scenery/visuals Analysis.

Napkora, Zigmund

Umatilla National Forest, North Zone Hydrologist

Contribution: Hydrology/Water Quality Analysis, Soils Analysis

Pfeifer, Eric

Umatilla National Forest, North Zone Forester, Noxious Weed Coordinator

Contribution: Invasive Plant Analysis, Forest Vegetation Analysis, Visuals 

Analysis. 

Randall, Larry

Umatilla National Forest, Recreation and Wilderness Program Manager

Contribution: Recreation, Inventoried Roadless Area and Potential Wilderness 

Area Analysis.

Richardson, Katherine

Umatilla National Forest, Environmental Coordinator

Contribution: NEPA Oversight and Review

Taylor, Leslie

Umatilla National Forest, South Zone Environmental Coordinator

Contribution: NEPA Oversight and Review

Trick, Brian

Umatilla National Forest, Pomeroy Ranger District, Writer/Editor

Contribution: Document Revision, Writer/Editor

4.3 Distribution of the Environmental Impact Statement

An electronic or hardcopy of this Final Environmental Impact Statement will be provided to 

those specifically requesting copies by postal mail or email. In addition, the FEIS and all related 

documents are available on the Forest Webpage, as well as published in the Umatilla NF 

Schedule of Proposed Actions (SOPA) for official public distribution to whomever is interested 

or affected by the proposed action.

Commenters to the Draft EIS

Veronica Warnock, Conservation Director

Greater Hells Canyon Council

Mike Petersen, Executive Director

The Lands Council

Dick Artley

Irene K. Jerome, Consultant

American Forest Resource Council

Linday Warness, Forest Policy Liaison

Boise Cascade
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280 Umatilla National Forest

Mark Wachtel, Habitat Program Manager

Washington Dept. of Fish and Wildlife

Shannon F. Wheeler, Chairman

Nez Perce Tribal Executive Committee

Paula Hood, co-Director

Blue Mountains Biodiversity Project

Jill A. Nogi, Manager

U.S. Environmental Protection Agency

Region 10, Office of Environmental Review and Assessment

Environmental Review and Sediment Management Unit

Tribes

Confederated Tribes of the Umatilla Reservation 

Gary Burke

Eric Quaempts

Carl Scheeler

Teara Farrow

Audie Huber

Gary James

Jeremy Wolf

Kathryn Brighan

Aaron Ashley

Sully Kosey

Rosenda Shippentower

Woodrow Star 

Niimpuu (Nez Perce Tribe)

Mary Jane Miles

McCoy Oatman

Casey Mitchell

Shannon Wheeler

Elizabeth Arthur-Attao

Bill Picard

Samuel Penny

Arthur Broncheau

Quintin Ellenwood

Nakia Williamson

Patrick Baird

Amanda Rogerson

Dave Johnson

Aaron Miles, Sr.

Emmit Taylor 
Final Environmental Impact Statement

Pomeroy Ranger District 281

Federal, State, and Local Agencies 

Federal Agencies: 

Deputy Director, USDA APHIS PPD/EAD

US Fish and Wildlife Service

Director, Office of Environmental Policy and Compliance, U.S. Department of the 

Interior 

Director, Planning and Review, Advisory Council on Historic Preservation

Division Administrator, Federal Highway Administration (WA)

Environmental Protection Agency, Region 10, EIS Review Coordinator 

National Marine Fisheries Service, Habitat Conservationists Division, Northwest Region

Natural Resources Conservation Service, National Environmental Coordinator, U.S. 

Department of Agriculture

NOAA Office of Policy and Strategic Planning, NEPA Coordinator

Northwest Mountain Region, Regional Administrator, Federal Aviation Administration

Northwest Power Planning Council

U.S. Army Engr. Northwestern Division

U.S. Coast Guard (USCG), Environmental Management CG-443

U.S. Department of Energy, Director, Office of NEPA Policy and Compliance

U.S. Department of the Interior, Office of Environmental Policy and Compliance

USDA, National Agricultural Library, Head, Acquisitions & Serials Branch 

Washington and Oregon State Government and Agencies:

Asotin County Board of Commissioners

Columbia County Board of Commissioners

Garfield County Board of Commissioners

Oregon Dept. of Environmental Quality

Oregon Dept. of Fish and Wildlife

Oregon Dept. of Forestry

Union County Board of Commissioners

Washington Dept. of Fish and Wildlife

Washington Wildlife Commission

Washington State Noxious Weed Control Board

Non-governmental Organizations

Groups:

Alliance for the Wild Rockies, Michael Garrity

American Forest Resource Council, Irene Jerome

Blue Mountains Biodiversity Project, Karen Coulter

Hells Canyon Preservation Council, David Mildrexler, Jennifer Schwartz 

Oregon Wild, Doug Heiken

Sierra Club, René Voss

The Lands Council, Mike Petersen, Jeff Juel

Commercial Enterprises:

Boise Cascade, LLC, Lindsay Warness
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Boise Building, John Fullerton

Guy Bennett Lumber Company, Dave Fritts, Resource Manager

Idaho Forest Group, Bill Higgins

Individuals specifically requesting Information: 

Richard Artley

Jeremy Cox

Dean Gaiser

John Geddie

Robert Budig

Bret Harting

Tom and Kim Hendrickson

Sam Ledgerwood

Richard Isaacson

Shirley Muse

Erik Ryberg

Mark Sater

Les Chapman

Phil Herman

David Hunt

Lyle Jensen

Dave Price

Joe Zellerhoff

Jean Public

Michael Krochta

Library Copies: 

Pendleton Library – Electronic and hard copy

Asotin Library - Electronic and hard copy

Lewiston Library - Electronic and hard copy

Walla Walla Library - Electronic and hard copy
Final Environmental Impact Statement

Pomeroy Ranger District 283

Glossary

Abbreviations

AQI Air Quality Index

ATV All-Terrain Vehicle

BA Biological Assessment

BMP Best Management Practice

BIO Biological Opinion

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

CTUIRConfederated Tribes of the Umatilla Indian Reservation

CVS Continuous Vegetation Surveys

CY Calendar year

DBH Diameter at Breast Height

DEQ Department of Environmental Quality

DFC Desired Future Condition

DSC Detrimental Soil Condition

EA Environmental Analysis

EGC Effective Ground Cover

EIS Environmental Impact Statement

EPA Environmental Protection Agency

ESA Endangered Species Act

ESD Emergency Situation Declaration

FR Forest Road

FRCC Fire Regime Condition Class

FSEIS Final Supplement Environment Impact Statement

FSH Forest Service Handbook

FSM Forest Service Manual

FY Fiscal Year

GIS Geographic Information System

HEI Habitat Effectiveness Index

HRV Historic Range of Variability

HUC Hydrologic Unit Code

LRMP Land and Resource Management Plan
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MA Management Area

MBF Thousand Board Feet

MIS Management Indicator Species

MMBF Million Board Feet

MOU Memorandum of Understanding

NEPA National Environmental Policy Act

NF National Forest

NFMA National Forest Management Act

NFS National Forest System

NMFS National Marine Fisheries Service

NOI Notice of Intent

OFSS Old Forest Single Stratum 

PAG Plant Association Group

RD Ranger District

RHCA Riparian Habitat Conservation Area

RNA Research Natural Area

ROD Record of Decision

S&G Standard and Guideline

TES Threatened, Endangered or Sensitive

TEUI Terrestrial Ecosystem Unit Inventory

TMDL Total Maxim Daily Load

UMA Umatilla National Forest

USFS United States Forest Service

USFWS United State Fish and Wildlife Service

VQO Visual Quality Objective

WDFW Washington Department of Fish and Wildlife

WEPP Water Erosion Prediction Program
Final Environmental Impact Statement

Pomeroy Ranger District 285

Definition of Terms

A

Activity fuels – Fuels generated or altered by a management activity.

Adfluvial individuals – are those which emigrate as juveniles from spawning 

tributaries, maturing and overwintering in lakes and reservoirs.

Affected environment - Natural environment that exists at the present time in the area 

being analyzed.

Age class - A group of trees that started growing (regenerated) within the same time frame, 

usually 20 years. A single age class would have trees that are within 20 years of the same 

age, such as 1-20 years or 21-40 years.

Air quality – The composition of air with respect to quantities of pollution therein; used 

most frequently in connection with “standards” of maximum acceptable pollutant 

concentrations.

Airshed - A geographic area that, because of topography, meteorology, and climate, shares 

the same air.

Allotment (range allotment) - Area designated for use by a prescribed number of livestock 

for a prescribed time period.

Alternative – In an EIS, one of a number of possible options for responding to the purpose 

and need for action.

Anadromous fish – Fish that hatch in fresh water, migrate to the ocean, mature there, and 

return to fresh water to reproduce; for example, salmon and steelhead.

Aspect - The direction a surface faces. A hillside facing east has an eastern aspect.

B

Bankfull width – The width of a stream channel measured between the tops of the most 

prominent banks on either side of the stream. Also refers to the width of the stream at the 

normal flood flow.

Basal area - The area of the cross-section of a tree trunk near its base, usually 4 1/2 feet 

above the ground. Basal area is a way to measure how much of a site is occupied by 

trees. The term basal area is often used to describe the collective basal area of trees per 

acre.

Beneficial uses – Any of the various uses which may be made of water including, but 

not limited to, domestic water supplies, industrial water supplies, agricultural water 

supplies, navigation, recreation in and on the water, wildlife habitat, and aesthetics. The 

beneficial use is dependent upon actual use, the ability of the water to support a nonexisting use either now or in the future, and its likelihood of being used in a given 
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manner. The use of water for the purpose of wastewater dilution or as a receiving water 

for a waste treatment facility effluent is not a beneficial use.

Best Management Practices (BMPs) – A practice or combination of practices that is 

the most effective and practical means (including technological, economic, and 

institutional considerations) of preventing or reducing negative environmental impacts to 

water pollution that may result from resource management activities.

Big game - Large mammals, such as deer and elk, that are hunted for sport.

Big game summer range – A range usually at higher elevations, used by deer and elk

during the summer. Summer ranges are usually much more extensive than winter ranges.

Big game winter range – A range usually at lower elevation used by migratory deer and 

elk during the winter months; usually more clearly defined and smaller than summer 

range.

Biological diversity - The number and abundance of species found within a common 

environment. This includes the variety of genes, species, ecosystems, and ecological 

processes that connect everything in a common environment.

Biological Assessment (BA) – A document prepared by a federal agency for the purpose 

of identifying any endangered or threatened species that is likely to be affected by an 

agency action. This document facilitates compliance with the Endangered Species Act.

Biophysical – The combination of biological and physical components in an ecosystem.

Board foot (bf) - A measurement term for lumber or timber. It is the amount of wood 

contained in an unfinished board 1 inch thick, 12 inches long, and 12 inches wide. Often 

expressed as MBF (thousand board feet) or MMBF (million board feet).

Broadcast burn - A prescribed fire that burns forest fuels as they are, with no piling or 

windrowing.

Browse - Twigs, leaves, and young shoots of trees and shrubs that animals (such as deer 

and elk) eat.

Buffer - A land area designated to block or absorb impacts to the area beyond the buffer.

For example, a streamside buffer is often retained to reduce impacts of a harvest unit.

C

Canopy - In a forest, the branches of the uppermost layer of foliage. It can also be used 

to describe lower layers in a multistoried forest.

Canopy closure – The amount of ground surface shaded by tree canopies as seen from 

above. Used to describe how open or dense a stand of trees is, often expressed in 10 

percent increments.

Capability – The potential of an area or land/or water to produce resources, supply 

goods and service, and allow resource uses under a specified set of management 

practices and at a given level of management intensity. 
Final Environmental Impact Statement

Pomeroy Ranger District 287

Catastrophic wildfire – An especially intense and widespread fire that usually, but not 

always, occurs in forests that are outside the historical range of variability in terms of 

forest structure and forest fuels due to fire suppression.

Classified road – See Road Definitions.

Cavity - A hole in a tree often used by wildlife species, usually birds, for nesting, 

roosting, and reproduction.

CCF - One hundred cubic feet (see CF).

CF - A measurement term for lumber or timber. It is the amount of wood contained in an 

unfinished block of wood 12 inches thick, 12 inches long, and 12 inches wide. Often 

expressed as CCF (hundred cubic feet).

CFR – Code of Federal Regulations. A codification of the general and permanent rules 

published in the Federal Register by the Executive departments and agencies of the 

federal government.

Channel (stream) – The deepest part of a stream or riverbed through which the main 

current of water flows.

Climax - The stage of plant development in which vegetation is thought to be stable, 

self-sustaining, and self-replicating.

Clearcutting - A regeneration harvest method that removes all merchantable trees in a 

single cutting except for wildlife trees or snags. A “clearcut” is an area from which all 

merchantable trees have been cut.

Closed system road – Classified system road closed to public use. Opened to 

administrative use. Not decommissioned.

Commercial thinning – Any type of tree thinning that produces merchantable material 

at least equal in value to the direct costs of harvesting.

Community - A group of species of plants or animals living and interacting at a 

particular time and place; a group of people residing in the same place under the same 

government.

Compaction – Making soil hard and dense, decreasing its ability to support vegetation 

because the soil can hold less water and air and because roots have trouble penetrating 

the soil.

Conifer - A tree that produces cones, such as a pine, spruce, or fir tree.

Consultation – A process required by Section 7 of the Endangered Species Act whereby 

federal agencies proposing activities in a listed species habitat confer with governing 

agencies about the impacts of the activity on the species. Consultation may be informal, 

and thus advisory, or formal, and thus binding.

Connectivity (of habitats) - The arrangement of habitats that allows organisms and 

ecological processes to move across the landscape; patches of similar habitats are either 
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288 Umatilla National Forest

close together or linked by corridors of appropriate vegetation. The opposite of 

fragmentation.

Corridor - Elements of the landscape that connect similar areas. Streamside vegetation 

may create a corridor of willows and hardwoods between meadows where wildlife feed.

Cover - Any feature that conceals wildlife or fish, sometimes referred to as "hiding 

cover." Cover may be dead or live vegetation, boulders, or undercut stream banks.

Animals use cover to escape from predators, rest, or feed.

Critical habitat - Areas designated for the survival and recovery of federally listed 

threatened or endangered species.

Crown - The part of a tree containing live foliage; treetops.

Crown fire – A forest fire that advances through the crown fuel layer normally in direct 

conjunction with a surface fire.

Cultural resource - The remains of sites, structures, or objects used by people in the 

past (at least 50 years old); this can be prehistoric or historical.

Cumulative effects - Effects on the environment that result from the incremental 

impacts of an action when added to other past, present, and reasonably foreseeable 

actions. Cumulative effects can result from individually minor but collectively 

significant actions taking place over a period of time.

D

DBH (diameter at breast height) - The diameter of a tree 4 1/2 feet above the ground 

measured on the uphill side of the tree.

Danger Tree – A danger tree is considered to be any tree that is likely to fail within one 

and one-half tree lengths of an open class 3 or higher system road, any road designated 

for hauling, developed recreation or administrative site.

DecAid – An advisory tool that provides guidance to land managers evaluating effects of 

forest conditions and existing or proposed management activities on organisms that use 

snags, downwood, and other wood decay elements. DecAid is a statistical summary of 

empirical data from published research on wildlife and deadwood. Data provided in 

DecAid allows the user to relate the abundance of deadwood habitat for both snags and 

logs to the frequency of occurrence of selected wildlife species that require dead wood 

habitat for some part of their life cycle.

Decommission – Activity that results in the stabilization and restoration of unneeded 

roads to a more natural state. Removes the road segment from the Forest road inventory 

system. Decommissioning can involve: closing entrances; scarifying road surfaces, or 

decompacting (sub-soiling) to establish vegetation and reduce run-off.; seeding to 

control erosion; partial to full restoration of stream channel by removing culverts and 

fills; and removing unstable portions of embankments. 

Desired future condition - A vision of the long-term conditions of the land.
Final Environmental Impact Statement

Pomeroy Ranger District 289

Direct effects – Impacts on the environment that are caused by the action and occur at 

the same time and place.

Disturbance - Any event, such as flood, wildfire, insect infestations, or timber harvest, 

that alters the structure, composition, or functions of terrestrial or aquatic habitats.

Diversity - The distribution and abundance of different plant and animal communities 

and species within the area covered by a land and resource management plan.

Duff – Organic matter in various stages of decomposition on the floor of the forest.

E

Early forest succession - The stage of vegetation or wildlife that inhabits an area 

immediately following removal or destruction of vegetation. For instance, grasses may 

be the first plants to grow in an area that was burned.

Eastside Screens – Regional Forester’s Forest Plan Amendment (June 1995) designed to 

maintain options for old growth related and other species. Interim management direction 

establishing riparian, ecosystem, and wildlife standards for timber sales. 

Ecological approach - An approach to natural resource management that considers the 

relationships among all organisms, including humans, and their environment.

Ecology - The interrelationships of living things to one another and their environment or 

the study of these interrelationships. From the Greek Oikos meaning "house" or "place to 

live."

Ecosystem - A complete interacting system of living organisms and the land and water 

that make up their environment; the home places of all living things, including humans.

Ecosystem health – A condition where the parts and functions of an ecosystem are 

sustained over time and where the system’s capacity for self-repair is maintained, such 

that goals for uses, values, and services of the ecosystem are met.

Edge (habitat) - The margin where two or more vegetation patches meet, such as a 

meadow opening next to a mature forest stand or a ponderosa pine stand next to an aspen 

stand.

Elk Security Area – areas 250 acres or larger at least one half mile from an open road.

Endangered species - A plant or animal that is in danger of extinction throughout all or 

a significant portion of its range. Endangered species are identified by the Secretary of 

the Interior in accordance with the Endangered Species Act of 1973.

Environmental analysis - An analysis of alternative actions and their predictable long 

and short-term environmental effects. Environmental analyses include physical, 

biological, social, and economic factors.

Environmental Impact Statement (EIS) - A statement of environmental effects of a 

proposed action and alternatives. The Draft EIS is released to other agencies and the 

public for comment and review. A Final EIS is issued after consideration of Public and 
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agency comments. A Record of Decision (ROD) is based on the information and 

analysis in the Final EIS.

Ephemeral streams - Streams that flow only as the direct result of rainfall or snowmelt.

They have no permanent flow.

Erosion - The wearing away of the land surface by wind, water, ice, gravity, or other 

geological activities. Erosion can be intensified by human activities (such as road 

building) that may reduce the stability of soils or slopes.

ETA – Equivalent Treatment Acres –is a watershed cumulative effects model that 

calculates the acres of created openings in forested areas based on harvest prescription or 

other mortality. It is used as an index to represent the potential for increased water yield

and peak flows as a consequence of reducing water loss by interception and 

evapotranspiration, or by changing snow distribution and melt rates.

Even-aged management - Method of forest management in which trees, usually the 

same species, are maintained at the same age and size and harvested all at once so a new 

stand may grow.

Even-aged stands – Stands of trees of approximately the same age. Silvicultural 

methods that generate even-aged stands include clearcutting, shelterwood, and seed tree.

Exotic - A plant or animal species introduced from a distant area; not native to the area, 

often particularly aggressive.

F

Fauna - The vertebrate and invertebrate animals of an area or region.

Fine fuels – Fast-drying fuels, generally with a comparatively high surface area-tovolume ratio, which are less than 1⁄4 -inch in diameter and have a time lag of one hour or 

less. These fuels readily ignite and are rapidly consumed by fire when dry.

Fire behavior – How fire reacts to the influences of fuel, weather, and topography.

Fire-dependent - Forests, grasslands, and other ecosystems historically composed of 

species that evolved with and are maintained by periodic fire.

Fire-intolerant – Species of plants that do not grow well or die from the effects of too 

much fire. Generally these are shade-tolerant species.

Fire regimes – The ecological effects of frequency, intensity, extent, season, and 

synergistic interactions with other disturbances, such as insects and disease, classified 

into generalized levels of fire severity.

Fire severity or Burn severity –Severity describes the fire-caused damage to the soil.

The severity ratings (high, moderate, and low) are based on standards in Forest Service 

Handbook 2509.13.

Fire-tolerant – Species of plants that can withstand certain frequency and intensity of 

fire. Generally these are shade–intolerant species. 
Final Environmental Impact Statement

Pomeroy Ranger District 291

Flora - The vegetation of an area.

Fluvial individuals – are those which emigrate as juveniles from spawning tributaries, 

maturing and overwintering in large rivers.

Forage - Vegetation (both woody and non-woody) eaten by animals, especially big game

and livestock.

Forage area – All areas that do not meet the definition of either satisfactory cover or 

marginal cover.

Forb - A broadleaf plant that has little or no woody material in it, including plants 

commonly called wildflowers and weeds.

Foreground - The part of a scene or landscape that is nearest the viewer.

Forest health – The condition in which forest ecosystems sustain their complexity, 

diversity, resiliency, and productivity while providing for human needs and values. It is a 

useful way to communicate about the current condition of the forest, especially with 

regard to resiliency, a part of forest health that describes the ability of the ecosystem to 

respond to disturbances. Forest health and resiliency can be described, in part, by species 

composition, density, and structure.

Forest Plan (Umatilla Land and Resource Management Plan) – A document that 

guides natural resource management and establishes standards and guidelines for a 

National Forest; required by the National Forest Management Act.

Fragmentation - The breakup of a large land area (such as a forest) into smaller patches 

that are isolated from the original area. Fragmentation can occur naturally (as by 

stand-replacing wildfire) or from human activities (such as road building).

Fuel(s) – Combustible material that includes vegetation such as grass, leaves, ground 

litter, plants, shrubs, and trees. Includes both living plants; dead, woody vegetative 

materials; and other vegetative materials which are capable of burning.

Fuel break – A zone in which fuel quantity has been reduced or altered to provide a 

position for suppression forces to make a stand against a wildfire. Fuel breaks are 

designated or constructed before the outbreak of a fire. Fuel breaks may consist of one or 

a combination of the following: natural barriers, constructed fuel breaks, man-made 

barriers.

Fuel ladder - Shrubs, small trees, and low growing branches that allow fire to move 

from the ground to the tree crowns.

Fuel load – The dry weight of combustible materials per unit area; usually expressed as 

tons per acre.

Fuels management - The treatment of fuels that would otherwise interfere with 

effective fire management or control. For instance, prescribed fire can reduce the amount 

of fuels that accumulate on the forest floor before the fuels become so heavy that a 

natural wildfire in the area would be explosive and impossible to control.
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Fuel Model 1 (Short Grass) - Surface fires that move rapidly through the continuous, 

cured or nearly cured herbaceous fuels. Surface fuel loading, less than 3 inches in 

diameter, is less than .74 tons per acre. Surface fuel bed depth is 1.0 foot.

Fuel Model 2 (Timber, Grass and Understory) - Fire spread is primarily through the 

fine fuels, such as grass and pine needles. The stand is open where larger pine and 

Douglas-fir cover one-to two-thirds of the area. Surface fuel loading, less than 3 inches 

in diameter, averages 4 tons per acre. Surface fuel bed depth is 1 foot.

Fuel Model 5 (Low Brush) - Fire is generally carried in the surface fuels that are made 

up of litter cast by the shrubs and the grasses or forbs in the understory. The fires are 

generally less intense because surface fuel loads are light. Surface fuel loading, less than 

3 inches in diameter, averages 3.5 tons per acre. Surface fuel bed depth is 2.0 feet. 

Fuel Model 8 (Timber, Closed Timber Litter) - A typical stand includes a closed 

canopy of short-needled conifers, such as Douglas-fir. The compact litter layer consists 

of needles, leaves and occasional twigs. Surface fuel loading, less than 3 inches in 

diameter, averages 5 tons per acre. Surface fuel bed depth is 0.2 feet. 

Fuel Model 10 (Timber, Litter and Understory) - Fires burn in the surface and ground 

fuels with greater fire intensity than the other timber litter models. Fuels in this model 

include greater quantities of dead and down material 3 inches and greater. Crowning, 

spotting and torching are more frequent in this fuel situation. Surface fuel loading, less 

than 3 inches in diameter, averages 12.0 tons per acres. Surface fuel bed depth is 1.0 

feet.

Function - The processes within an ecosystem through which the elements interact, such 

as succession, the food chain, fire, weather, and the hydrologic cycle.

G

Geographic Information System (GIS) – Computer software that provides database 

and spatial analytic capabilities.

Ground fire - A fire that burns along the forest floor and does not affect trees with thick 

bark or high crowns.

Ground fuels – All combustible materials below the surface litter layer. These fuels may 

be partially decomposed, such as forest soil organic layers (duff), dead moss and lichen 

layers, punky wood and deep organic layers (peat), or may be living plant material, such 

as tree and shrub roots. 

Groundwater - Water that sinks into the soil and is stored in slowly flowing and slowly 

renewed underground reservoirs called aquifers.

H

Habitat - The place where a plant or animal finds what it needs to survive, either 

year-round or seasonally.

Habitat capability - The ability of a habitat to support a given species of wildlife.
Final Environmental Impact Statement

Pomeroy Ranger District 293

Habitat type - A way of defining land areas potentially capable of producing similar 

plant communities at climax. In Forestry, habitat types are named for the predominant 

climax tree species.

For example, the Pinus Ponderosa habitat type series is habitat that typically supports 

climax Ponderosa Pine. A number of other habitat features can be identified using 

habitat types, such as aspect, elevation, climate, and use by wildlife species.

Harvest – (1) Felling and removal of trees from the forest; (2) removal of game animals 

or fish from a population, typically by hunting or fishing.

Headwaters – Beginning of a watershed; unbranched tributaries of a stream.

Hiding area/cover - Vegetation capable of hiding 90 percent of an adult elk or deer from 

a human's view at a distance of 200 feet or less.

Historical Range of Variability (HRV) – The natural fluctuation of components of 

healthy ecosystems over time. In this EIS, it refers to the range of conditions and 

processes that are likely to have occurred prior to settlement of the project area by 

people of European descent (approximately the mid-1800s), which would have varied 

within certain limits over time.

Hydrologic Unit Code (HUC) – An area of land upstream from a specific point on a 

stream (designated as the mouth) that defines a hydrologic boundary and includes all of 

the source areas that could contribute surface water runoff directly and indirectly to the 

designated outlet point.

Hydrology - The study of water on the surface of the land, in the soil and underlying 

rocks, and in the atmosphere.

I

Indicator species - A plant or animal species that is presumed to be sensitive to habitat

change. Its presence indicates specific habitat conditions are also present. Population 

changes in an indicator species can indicate the effects of land management activities.

Indirect effects – Impacts on the environment that are caused by the action and are later 

in time or farther removed in distance, but are still reasonably foreseeable.

Individual tree selection - The removal of certain size and age classes of individual 

trees from a stand. Regeneration is allowed to naturally occur and an uneven-aged stand

is maintained.

Intensity (fire intensity) - The rate of heat release for an entire fire at a specific time.

Interdisciplinary team (IDT) - A team of individuals with skills from different 

disciplines that focuses on the same task or project, referred to as ID Team.

Intermediate harvest - The removal of trees from a stand between the time of its 

formation and harvest cutting. Thinning, liberation, and improvement cuts are all types 

of intermediate harvest. Sometimes salvage harvests and sanitation harvests are termed 

intermediate.
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Intermittent stream - A stream that flows only at certain times of the year when it 

receives water from streams or some surface source, such as melting snow.

Irretrievable – A category of impacts that applies to losses of production or 

commitment of renewable natural resources.

Irreversible – A category of impacts that applies to non-renewable resources, such as 

minerals and archaeological sites. Losses of these resources cannot be reversed.

Irreversible effects can also refer to effects of actions on resources that can be renewed 

only after a very long period of time, such as the loss of soil productivity.

Issue – A matter of controversy, dispute, or general concern over resource management 

activities or land uses. To be considered a “significant “ EIS issue, it must be well 

defined, relevant to the proposed action, and within the ability of the agency to address 

through alternative management strategies. 

L

Ladder fuels – Fuels which provide vertical continuity between strata. Fire is able to 

carry from the surface fuels by convection into the crowns with relative ease.

Landing - Any place where cut timber is collected before further transport from the 

timber sale area.

Landscape - All the natural features such as grasslands, hills, forest, and water, which 

distinguish one part of the earth's surface from another; usually that portion of land 

which the eye can comprehend in a single view, including all its natural characteristics.

Late forest succession - The stage of forest succession in which most of the trees are 

mature or overmature.

Litter (forest litter) - The freshly fallen or only slightly decomposed plant material on 

the forest floor. This layer includes foliage, bark fragments, twigs, flowers, and fruit.

M

Mainstem – The main channel of the river in a river basin, as opposed to the streams 

and smaller rivers that feed into it.

Management action - Any activity undertaken as part of the administration of the 

National Forest.

Management area – An aggregation of capability areas that have a common 

management direction, and may be dispersed over the Forest.

Marginal cover – A stand of coniferous trees 10 or more feet tall with an average 

canopy closure equal to or more than 40 percent but less than 70 percent and generally 

capable of obscuring at least 90 percent of a standing elk from the view of humans at a 

distance of 200 feet..

Merchantable timber - Timber that can be bought or sold.
Final Environmental Impact Statement

Pomeroy Ranger District 295

MIS (management indicator species) - A wildlife species selected by a land 

management agency to indicate the health of the ecosystem in which it lives and, 

consequently, the effects of forest management activities on that ecosystem (see 

"indicator species").

Mitigation - Measures designed to counteract environmental impacts or make impacts 

less severe.

Mixed stand - A stand consisting of two or more tree species.

MBF - Thousand Board Feet (see board foot).

MMBF - Million Board Feet (see board foot).

Monitoring - A process of collecting information to evaluate whether or not objectives 

of a project and its mitigation activities are being realized.

Mortality - The loss of a population due to all lethal causes, often referring to the rate of 

death of a species in a given population or community.

Mosaic - A pattern of vegetation in which two or more kinds of plant communities are 

interspersed in patches, such as a meadow between stands of old growth.

Multiple-use management – The management of public lands and their various 

resource values so they are used in the combination that best meets the present and 

future needs of the American people.

N

Natural regeneration – Reforestation of a site by natural seeding from surrounding 

trees. Natural regeneration may or may not be preceded by site preparation.

Natural resource - Water, soil, wild plants and animals, air, minerals, nutrients, and 

other resources produced by the earth's natural processes.

NEPA (National Environmental Policy Act) - An act of Congress passed in 1969 

declaring a national policy to encourage productive and enjoyable harmony between 

people and their environment. Section 102 of the NEPA requires a statement of possible 

environmental effects be released to

the public and other agencies for review and comment.

NFMA (National Forest Management Act) - A law passed in 1976 requiring the 

preparation of Regional Guides and Forest Plans and regulations to guide that 

development.

No Action alternative - The most likely condition expected to exist in the future if 

management practices continue unchanged.

Non-system road/unclassified road – Any continuous set of wheel tracks that exist for 

more than one season, and does not belong to the transportation system. 
Sunrise Vegetation and Fuels Project

296 Umatilla National Forest

Noxious weed - A weed that causes disease or has other adverse effects on man or his 

environment and, therefore, is detrimental to public health and the agriculture and 

commerce of the United States. Noxious weeds are often aggressive and difficult to 

manage and non-native, new, or not common to the United States.

O

Old growth - Old forests often containing several canopy layers, variety in tree sizes 

and species, decadent old trees, and standing and dead woody material.

Ongoing actions – Actions that have been implemented, or have contracts awarded or 

permits issued.

Open system road – Classified system road, open to public use.

Overmature timber - Trees that have attained full development, particularly in height, 

and are declining in vigor, health, and soundness.

Overstory - The upper canopy layer; the plants below comprise the understory.

P

PACFISH – Interim strategies for managing Pacific anadromous fish-producing 

watersheds in eastern Oregon and Washington, Idaho, and portions of California.

Park-like structure - Stands with large scattered trees, few or no understory trees, and 

open growing conditions, usually maintained by frequent ground fires.

Patch - An area of uniform vegetation that differs in structure and composition from 

what surrounds it.

Perennial stream - A stream that flows throughout the year from its source to mouth.

Pre-commercial thinning - Removing some of the trees from a stand that are too small 

to be sold for lumber or house logs so the remaining trees will grow faster.

Predator - An animal that captures and feeds on parts or all of an organism of another 

species.

Preferred alternative – The alternative identified in a draft environmental impact 

statement which has been initially selected by the agency as the most acceptable 

resolution to the problems identified in the purpose and need.

Prescribed fire - The intentional use of fire under specified conditions to achieve 

specific management objectives.

Prescription – Measurable criteria that define conditions under which a prescribed fire

may be ignited, guide selection of appropriate management responses, and indicate other 

required actions. Prescription criteria may include safety, economic, public health, and 

environmental, geographic, administrative, social, or legal considerations. 

Present net value (PNV) [also called present net worth] - The measure of the economic 

value of a project when costs and revenues occur at different times. Future revenues and 
Final Environmental Impact Statement

Pomeroy Ranger District 297

costs are "discounted " to the present by an interest rate that reflects the changing value 

of a dollar over time. The assumption is that dollars today are more valuable than dollars 

in the future. PNV is used to compare project alternatives that have different cost and 

revenue flows.

Public involvement - The use of appropriate procedures to inform the public, obtain 

early and continuing public participation, and consider the views of interested parties in 

planning and decision making.

R

Range of variability - The fluctuation, over time, in the population, size, and 

components of healthy ecosystems.

Rangeland (range) - Land on which the principle natural plant cover is composed of 

native grasses, forbs, and shrubs that are valuable as forage for livestock and big game.

Reforestation - The restocking of an area with forest trees by either natural or artificial 

means such as planting.

Regeneration - The process of establishing a new tree crop on previously harvested 

land. The term also refers to the young crop itself.

Regeneration harvest - A silvicultural treatment intended to regenerate a stand of trees.

Shelterwood and seed tree harvests are forms of regeneration treatments.

Resilient, resiliency -The ability of a system to respond to disturbances. Resiliency is 

one of the properties that enable the system to persist in many different states or 

successional stages 

Restoration (of ecosystems) - Actions taken to modify an ecosystem to achieve a 

desired, healthy, and functioning conditions and processes. Generally refers to the 

process of enabling the system to resume its resiliency to disturbances.

Revegetation - Establishing or reestablishing desirable plants on a site where they are 

absent or in few numbers. Revegetation can be accomplished through natural or artificial 

reseeding or transplanting.

Riparian area - The area along a watercourse or around a lake or pond. Area with 

distinctive soil and vegetation between a stream or other body of water and the adjacent 

upland; includes wetlands and those portions of floodplains and valley bottoms that 

support riparian vegetation.

Riparian Habitat Conservation Area (RHCA) – Portions of watershed where ripariandependent resources receive primary emphasis, and management activities are subject to 

specific standards and guidelines. RHCAs include traditional riparian corridors, 

wetlands, intermittent headwater streams, and other areas where proper ecological 

functioning is crucial to maintenance of the stream's water, sediment, woody debris and 

nutrient delivery systems.

Runoff - The portion of precipitation that flows over the land surface or in open 

channels.
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298 Umatilla National Forest

S

Salvage – Salvage timber harvest is defined as "the removal of dead trees or trees 

damaged or dying because of injurious agents other than competition, to recover 

economic value that would otherwise be lost" (Helms 1998). When a fire front passes a 

tree, some of the resulting heat is transferred to the vascular cambium, foliage and roots.

If the temperatures are high enough and the flame residence time is long enough, these 

tissues are killed. When a high proportion of the cambium, crown or fine roots are killed, 

the whole tree dies. Lower temperatures or shorter residence times will injure tissues 

rather than kill them (Dickinson and Johnson 2001).

Satisfactory cover – A stand of coniferous trees 40 or more feet tall with an average 

canopy closure equal to or more than 70 percent. Umatilla Forest Plan defines it as cover

used by animals to ameliorate the effect of weather.

Scoping - The early stages of preparation of an environmental analysis to determine public 

opinion, receive comments and suggestions, and determine issues during the 

environmental analysis process. It may involve public meetings, telephone conversations, 

or letters.

Seasonally Closed Road – Classified system road closed to public use for part of the year.

Sediment – Solid materials, both mineral and organic, in suspension or transported by 

water, gravity, ice, or air; may be moved and deposited away from their original position 

and eventually will settle to the bottom.

Sensitive species - A sensitive species is one that has been designated by the Regional 

Forester because of concern for population viability. Indications for concern include 

significant current or predicted downward trends in population numbers or density or in 

habitat capability that would reduce an existing species distribution.

Seral - Refers to the sequence of transitional plant communities during succession. Early 

seral refers to plants that are present soon after a disturbance or at the beginning of a new 

successional process (such as seedling or sapling growth stages in a forest); mid-seral in a 

forest would refer to pole or medium saw timber growth stages; late or old seral refers to 

plants present during a later stage of plant community succession (such as mature or old 

forest stages).

Shade-intolerant species - Species of plants that do not grow well in the shade of others.

They are species that develop on a site soon after a major disturbance. Ponderosa pine and 

western larch are shade-intolerant tree species.

Shade-tolerant species - Species of plants that grow well in the shade of others.

Douglas-fir is a relatively shade-tolerant tree.

Shelterwood harvest - A regeneration cut designed to establish a new crop of trees under 

the protection of the old. This type of harvest typically occurs in stages with a second entry 

following the first after regeneration has occurred.

Silvicultural system - The cultivation of forests; the result is a forest of a distinct form.

Silvicultural systems are classified according to harvest and regeneration methods and the 

type of forest that results.
Final Environmental Impact Statement

Pomeroy Ranger District 299

Silviculture - The practice of manipulating the establishment, composition, structure, 

growth, and rate of succession of forests to accomplish specific objectives.

Site potential – A measure of resource availability based on interactions among soils, 

climate, hydrology, and vegetation.

Site preparation - The general term for removing unwanted vegetation, slash, roots, and 

stones from a site before reforestation. Naturally-occurring wildfire as well as prescribed 

fire can prepare a site for natural regeneration.

Slash - The residue left on the ground after timber cutting or after a storm, fire, or other 

event. Slash includes unused logs, uprooted stumps, broken or uprooted stems, branches, 

bark, etc.

Smolt – Young salmon or trout migrating to the ocean and undergoing biological changes 

to enable them to move from freshwater streams to saltwater.

Snag - A standing dead tree.

Soil compaction - The reduction of soil volume. For instance, the weight of heavy 

equipment on soils can compact the soil and thereby change it in some ways, such as in its 

ability to absorb water.

Soil productivity - The capacity of a soil to produce a specific crop. Productivity depends 

on adequate moisture and soil nutrients as well as favorable climate.

Species – A population or series of populations of organisms that can interbreed freely 

with each other but not with members of other species.

Stability – Ability of a living system to withstand or recover from externally imposed 

changes or stresses.

Stand - A group of trees in a specific area that are sufficiently alike in composition, age, 

arrangement, and condition so as to be distinguishable from the forest in adjoining areas.

Stand composition – The vegetative species that make up the stand.

Stand density – Refers to the number of trees growing in a given area, usually expressed 

in trees per acre.

Stand replacement - Fire that kills upwards of 70 percent of overstory trees.

Stand structure –The mix and distribution of tree sizes, layers, and ages in a forest. Some 

stands are all one size (single-story), some are two-story, and some are a mix of trees of 

different ages and sizes (multi-story).

Standards and guidelines - Requirements found in a Forest Plan which impose limits on 

natural resource management activities, generally for environmental protection.

Stream morphology – The study of the form and structure of streams.
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300 Umatilla National Forest

Succession - The predictable, natural replacement of one plant community with another 

over time. The different stages in succession are often referred to as seral stages (see 

"seral").

Successional stage - A stage of development of a plant community as it moves from bare 

ground to climax. The grass-forb stage of succession precedes the woody shrub stage (see 

"seral").

Suitability - The appropriateness of certain resource management practices for an area of 

land. Suitability can be determined by environmental and economic analysis of 

management practices.

Sustainability – (1) Meeting the needs of the present without compromising the abilities 

of future generations to meet their needs; emphasizing and maintaining the underlying 

ecological processes that ensure long-term productivity of goods, services, and values 

without impairing productivity of the land. (2) In commodity production, refers to the 

yield of a natural resource that can be produced continually at a given intensity of 

management.

T

Thinning - A cutting made in an immature stand of trees to accelerate growth of the 

remaining trees or to improve the form of the remaining trees.

Threatened species - Those plant or animal species likely to become endangered 

throughout all or a specific portion of their range within the foreseeable future as 

designated by the US Fish and Wildlife Service under the Endangered Species Act of 

1973.

Tiering – In an EIS, refers to incorporating by reference the analyses in an EIS of a 

broader scope. For example, a Forest Service project-level EIS could tier to the analysis 

in a Forest Plan EIS; a Forest Plan EIS could tier to a Regional Guide EIS.

Total cover – All coniferous tree cover 10 or more feet tall and with a canopy closure of 

equal to or greater than 40 percent (i.e. satisfactory cover plus marginal cover).

Tractor logging - A logging method that uses tractors to carry or drag logs from the 

stump to a landing.

Transitory Range – Land that is suitable for grazing use of a non-enduring nature over 

a period of time; often found in the openings created by timber harvesting activities. For 

example, on particularly disturbed lands, grass may cover the area for a period of time 

before being replaced by trees or shrubs not suitable for forage. 

U

Unauthorized or Temporary Road – Formerly also referred to as unclassified road.

These are defined as Roads on National Forest System lands that are not managed as 

part of the forest transportation system, such as unplanned roads, abandoned traveled 

way, and off-road vehicle track that have not been designated and managed as a trail; 

and those roads that were once under permit or other authorization and were not 
Final Environmental Impact Statement

Pomeroy Ranger District 301

decommissioned upon the termination of the authorization. Roads not authorized or 

necessary for long-term resource management.

Underburn - A burn by a surface fire that can consume ground vegetation and ladder 

fuels.

Understory - The trees and woody shrubs growing beneath the overstory.

Uneven-aged management - Method of forest management in which trees of different 

species in a given stand are maintained at many ages and sizes to permit continuous 

natural regeneration. Selective cutting is one example of an uneven-aged management 

method.

Uneven-aged stand – Stand of trees in which there are considerable differences in the 

ages of individual trees.

V

Vegetation management - Activities designed primarily to promote the health of forest 

vegetation for multiple-use purposes.

Vertical diversity - The diversity in a stand that results from the different layers or tiers 

of vegetation.

Viable population - The number of individuals of a species sufficient to ensure the 

long-term existence of the species in natural, self-sustaining populations that are 

adequately distributed throughout their range.

W

Water yield - The runoff from a watershed including groundwater outflow.

Watershed - The entire region drained by a waterway (or into a lake or reservoir). More 

specifically, a watershed is an area of land above a given point on a stream that 

contributes water to the stream flow at that point.

Wetlands - Areas that are permanently wet or intermittently covered with water.

Wetlands generally include swamps, bogs, seeps, wet meadows, and natural ponds.

Wildfire - A human or naturally caused wildland fire that does not meet land 

management objectives.

Winter range - That portion of big game's range where animals congregate for the 

winter.

X, Y, Z

Yarding – Hauling timber from the stump to a collection point. 
Sunrise Vegetation and Fuels Project

302 Umatilla National Forest

Index

Activity Fuels, iv, 25, 34, 39, 42, 80, 82, 159, 161, 163, 

173, 184, 188, 242, 243, 254, 256, 285

Adfluvial individuals, 285

Affected Environment, 17, 47, 51, 53, 57, 69, 87, 151, 

171, 193, 221, 229, 233, 235, 241, 247, 285

Age Class, 23, 49, 214, 215, 218, 219, 260, 285, 293

Air Quality, viii, 26, 46, 69, 233, 241, 242, 243, 244, 

245, 265, 275, 278, 283, 285, 317, 335

Airshed, 245, 285

Allotment, 53, 55, 92, 156, 164, 167, 199, 208, 248, 

249, 285, 308

Alternative, 3, iv, v, vi, vii, viii, 17, 25, 31, 33, 34, 35, 

36, 41, 42, 51, 57, 61, 62, 63, 64, 65, 66, 68, 69, 

79, 80, 81, 82, 83, 84, 88, 90, 93, 111, 113, 114, 

115, 116, 117, 118, 119, 120, 121, 122, 123, 125, 

126, 127, 131, 134, 141, 146, 147, 148, 149, 157, 

158, 159, 161, 162, 163, 164, 165, 168, 169, 172, 

179, 180, 184, 185, 186, 187, 188, 189, 190, 198, 

200, 205, 206, 207, 214, 215, 217, 218, 219, 222, 

229, 230, 231, 232, 237, 238, 239, 241, 242, 243, 

244, 247, 249, 250, 251, 252, 253, 254, 255, 256, 

261, 263, 265, 268, 270, 271, 272, 273, 274, 275, 

285, 289, 294, 295, 296, 345, 346, 347, 348, 356, 

357, 371

Anadromous Fish, 27, 57, 247, 251, 285, 296, 321, 

337

Aspect, 212, 225, 247, 285, 293

Bankfull width, 44

Bankful Width, 285

Basal Area, 37, 49, 72, 107, 152, 285

Beneficial Uses, 153, 162, 163, 285

Best Management Practices, 43, 50, 146, 147, 149, 

151, 155, 159, 160, 161, 162, 164, 167, 169, 171, 

172, 182, 184, 231, 262, 263, 266, 269, 271, 283, 

286, 324, 325, 337, 357

Big Game, i, iii, 18, 20, 21, 22, 23, 24, 39, 53, 69, 85,

89, 90, 91, 92, 118, 128, 160, 224, 225, 236, 260, 

261, 286, 291, 297, 301

Biological Assessment, 283, 286, 307, 308

Biological Diversity, 286, 315

Biophysical, ii, iii, iv, 18, 19, 20, 29, 47, 58, 60, 61, 63, 

64, 65, 66, 93, 286, 320, 355, 356

Board Foot, 254, 256, 284, 286, 295

Broadcast Burn, iv, 33, 34, 54, 161, 163, 180, 184, 

188, 260, 286

Browse, 286

Buffer, 47, 173, 181, 186, 213, 286, 322

Burn Severity, 36, 120, 124, 159, 165, 166, 173, 180, 

182, 187, 189, 290

Canopy, iii, iv, v, vi, 19, 20, 23, 25, 34, 36, 38, 39, 40, 

48, 57, 66, 67, 71, 73, 74, 75, 76, 77, 80, 81, 90, 

94, 100, 102, 106, 107, 109, 118, 120, 125, 126, 

131, 132, 152, 157, 158, 159, 160, 174, 200, 214, 

217, 225, 230, 260, 272, 273, 286, 292, 294, 296, 

298, 300, 356

Canopy Closure, 48, 67, 90, 107, 286, 294, 298, 300, 

356

Capability, 135, 261, 286, 294

Catastrophic Wildfire, 287

Cavity, 23, 87, 89, 95, 96, 99, 112, 124, 125, 231, 287

Channel, 43, 44, 133, 138, 148, 149, 152, 154, 157, 

158, 159, 162, 163, 164, 165, 167, 178, 180, 268, 

271, 285, 287, 288, 294, 323

Classified Road, 287

Clearcutting, 36, 42, 212, 265, 287, 290, 357

Closed System Road, 26, 40, 41, 271, 287

Code of Federal Registrar, iv, 26, 33, 34, 52, 53, 193, 

198, 221, 269, 283, 287, 321

Commercial Thinning, 31, 54, 68, 82, 118, 151, 187, 

249, 250, 254, 256, 287

Community, 29, 36, 67, 206, 247, 265, 287, 295, 298, 

300

Compaction, 24, 43, 173, 175, 176, 181, 182, 183, 

186, 187, 190, 231, 287, 339, 340

Connectivity, v, 27, 32, 36, 41, 47, 48, 63, 65, 67, 87, 

156, 259, 287, 356, 357

Consultation, 17, 28, 46, 152, 194, 198, 266, 267, 

268, 270, 277, 278, 287, 307, 308, 324

Corridor, 120, 288, 356

Cover, 2, ii, iii, v, vi, viii, 18, 19, 20, 21, 23, 24, 32, 35, 

36, 41, 46, 47, 53, 57, 58, 59, 62, 63, 64, 65, 66, 

67, 74, 75, 77, 80, 81, 83, 89, 90, 91, 92, 94, 99, 

102, 104, 107, 108, 110, 111, 113, 114, 115, 116, 

117, 118, 119, 120, 125, 126, 127, 128, 131, 132, 

148, 152, 157, 160, 162, 163, 165, 166, 173, 174, 

175, 176, 177, 180, 181, 183, 184, 187, 200, 204, 

205, 207, 212, 225, 226, 258, 260, 261, 264, 270, 

272, 274, 283, 288, 292, 293, 297, 298, 300, 313, 

319, 324, 355, 357

Critical Habitat, 28, 135, 137, 138, 140, 141, 142, 143, 

146, 147, 193, 194, 262, 267, 288

Crown, vi, 39, 69, 71, 72, 74, 77, 78, 79, 80, 81, 82, 

83, 84, 85, 111, 113, 123, 128, 129, 216, 217, 222, 

244, 288, 298, 310, 311

Crown Fire, vi, 39, 69, 71, 72, 74, 77, 78, 79, 80, 81, 

82, 83, 84, 85, 111, 113, 123, 128, 129, 288, 310, 

311

Cubic Feet, 287

Cultural Resources, 26, 28, 29, 30, 46, 51, 87, 135, 

232, 233, 262, 267, 268, 270, 271, 274, 278, 288, 

308

Cumulative Effects, vii, 17, 32, 33, 51, 52, 53, 58, 61, 

66, 68, 84, 87, 122, 125, 138, 146, 147, 148, 149, 

152, 164, 165, 166, 167, 168, 179, 180, 183, 187, 

188, 190, 195, 197, 198, 199, 200, 207, 208, 212, 

215, 221, 231, 232, 233, 238, 239, 244, 245, 250, 
Final Environmental Impact Statement

Pomeroy Ranger District 303

256, 257, 259, 262, 264, 272, 273, 274, 288, 290, 

312, 323, 324

Danger Tree, iv, v, 26, 31, 34, 35, 40, 55, 119, 121, 

160, 161, 200, 249, 272, 288, 320

DecAid, 288

Decommission, 161, 163, 288

Desired Future Condition, iii, 20, 21, 22, 23, 24, 29, 

37, 69, 171, 259, 260, 263, 265, 283, 288

Diameter at Breast Height, iv, 25, 33, 34, 35, 36, 37, 

39, 47, 48, 67, 93, 95, 119, 283, 288

Direct Effect, 62, 63, 64, 65, 66, 158, 161, 163, 182, 

184, 186, 188, 189, 196, 218, 243, 249, 275, 289

Disturbance, ii, iii, vi, vii, 18, 20, 23, 25, 38, 43, 45, 46, 

47, 49, 50, 59, 61, 64, 65, 66, 67, 68, 73, 77, 79, 

84, 91, 102, 105, 108, 111, 112, 122, 127, 132, 

134, 148, 157, 158, 160, 161, 162, 164, 166, 171, 

173, 174, 179, 181, 182, 183, 184, 186, 188, 189, 

190,196, 199, 200, 203, 204, 205, 206, 208, 212, 

214, 216, 218, 225, 238, 249, 257, 263, 264, 269, 

271, 274, 289, 298, 314, 316, 318, 322, 340, 341, 

355, 357

Diversity, iii, iv, 20, 21, 22, 23, 27, 49, 89, 120, 128, 

135, 194, 195, 217, 256, 260, 261, 275, 289, 291, 

301, 339

Duff, 36, 39, 45, 72, 77, 181, 216, 244, 289, 292

Early Forest Succession, 289

Eastside Screens, ii, 18, 19, 27, 57, 62, 64, 66, 87, 93, 

107, 124, 125, 259, 289, 332, 355, 356

Ecological Approach, 289

Ecology, 100, 110, 153, 243, 289, 308, 309, 311, 312, 

313, 314, 315, 316, 317, 318, 319, 320, 323, 325, 

335, 336, 338, 340

Ecosystem, iii, iv, 19, 20, 21, 25, 27, 28, 29, 57, 79, 93, 

133, 138, 160, 171, 172, 194, 195, 229, 247, 251, 

259, 275, 284, 286, 289, 291, 292, 295, 297, 309, 

312, 314, 315, 316, 317, 319, 321, 322, 323, 336, 

338, 355

elk, v, vi, 21, 23, 32, 36, 41, 53, 55, 63, 65, 87, 88, 89, 

90, 91, 92, 105, 111, 114, 117, 118, 119, 120, 126, 

128, 225, 231, 267, 274, 286, 293, 294

Elk Security, 111

Endangered Species, 29, 33, 84, 87, 102, 105, 135, 

137, 141, 152, 193, 194, 262, 266, 270, 283, 286, 

287, 288, 289, 300, 307, 323, 324, 336

Environmental Analysis, 32, 37, 283, 289, 298

Environmental Impact Statement, 1, 3, 17, 26, 27, 28, 

29, 32, 41, 51, 52, 88, 122, 124, 125, 164, 194, 

203, 204, 221, 231, 232, 247, 251, 278, 281, 283, 

285, 289, 293, 294, 296, 300, 324, 337, 338, 341

Ephemeral Streams, 160, 290

Equivalent Treatment Acres, 53, 165, 168, 290

Erosion, 44, 45, 55, 148, 149, 152, 155, 156, 159, 160, 

161, 162, 164, 165, 166, 171, 172, 173, 174, 175, 

176, 177, 178, 179, 180, 181, 182, 183, 184, 185, 

187, 188, 189, 196, 231, 236, 263, 264, 269, 271, 

284, 288, 290, 322, 323, 325, 339, 340

ETA, 371

Even-aged Management, 265, 290, 357

Even-aged Stands, 47, 290

Fauna, 203, 290, 337

Fine Fuels, 75, 76, 290, 292

Fire Behavior, 71, 75, 76, 77, 158, 164, 166, 187, 189, 

243, 290, 309, 310

Fire Intensity, iii, iv, v, 19, 21, 25, 34, 35, 38, 51, 52, 

70, 71, 74, 75, 77, 79, 80, 113, 114, 128, 133, 157, 

159, 166, 176, 180, 182, 184, 195, 196, 199, 205, 

231, 243, 258, 260, 286, 290, 292, 293, 300

Fire Regimes, iii, 19, 20, 22, 39, 47, 67, 69, 70, 71, 72, 

74, 75, 76, 79, 80, 81, 82, 83, 84, 85, 162, 164, 

166, 184, 187, 188, 273, 290, 309, 310, 311, 314, 

356

Fire Severity, iii, 19, 74, 79, 157, 159, 166, 206, 290, 

316, 320

Fire-dependent, iv, 20, 39, 160, 275, 290

Fire-intolerant, 47, 67, 72, 74, 111, 290, 356

Fire-tolerant, iv, 20, 25, 39, 40, 72, 77, 80, 290

Flora, 203, 291, 312

Fluvial Individuals, 291

Forage, iii, v, viii, 20, 21, 23, 24, 35, 39, 46, 55, 85, 89, 

90, 91, 92, 105, 111, 113, 118, 127, 128, 160, 167, 

231, 249, 250, 260, 261, 266, 274, 291, 297, 300, 

357

Forb, viii, 59, 175, 291, 300, 338, 339

foreground, 49, 211, 212, 213, 214, 215, 216, 217, 

218, 226

Foreground, 212, 213, 215, 217, 218, 291

Forest Health, 291, 315, 317, 321

Forest Plan, 3, ii, iii, iv, 17, 18, 19, 20, 21, 22, 27, 29, 

31, 33, 37, 43, 45, 46, 47, 48, 49, 51, 55, 57, 62, 

64, 66, 67, 69, 87, 89, 90, 91, 92, 93, 94, 96, 101, 

111, 117, 119, 122, 135, 137, 151, 160, 162, 171, 

172, 173, 175, 176, 179, 181, 183, 185, 188, 190, 

203, 204, 211, 212, 213, 214, 216, 218, 219, 221, 

222, 224, 226, 231, 232, 235, 247, 251, 259, 260, 

261, 262, 263, 264, 265, 266, 270, 274, 275, 283, 

289, 291, 295, 298, 299, 300, 321, 325, 355, 356, 

357

Forest Plan Amendment, 332

Fragmentation, 93, 101, 259, 288, 291, 356

Fuel Break, 40, 291

Fuel Ladder, iii, 19, 25, 36, 38, 39, 71, 72, 75, 77, 81, 

113, 123, 128, 129, 159, 160, 273, 291, 294, 301

Fuel Load, iii, v, vi, 19, 33, 34, 50, 69, 73, 74, 75, 76, 

80, 81, 111, 162, 176, 182, 184, 186, 187, 244, 

257, 261, 273, 291, 292

Fuel Model, 75, 76, 77, 292, 309, 310

Fuels Management, 51, 55, 146, 147, 160, 243, 259, 

260, 261, 262, 291

Function, iii, vi, 19, 32, 39, 70, 71, 79, 90, 148, 149, 

154, 156, 157, 158, 159, 160, 161, 162, 163, 165, 

167, 176, 182, 263, 292, 316

Geographic Information System, v, 34, 53, 69, 88, 

138, 143, 154, 173, 179, 186, 195, 222, 235, 278, 

283, 292, 325

Ground Fire, 292, 296
Sunrise Vegetation and Fuels Project

304 Umatilla National Forest

Ground Fuels, 35, 36, 38, 39, 72, 73, 75, 76, 77, 113, 

128, 160, 292, 294

Groundwater, 154, 159, 165, 231, 292, 301, 324

Habitat, 3, iii, iv, v, vi, 20, 21, 22, 23, 24, 25, 27, 28, 

30, 32, 33, 35, 36, 41, 43, 44, 47, 48, 53, 55, 57, 

63, 65, 66, 67, 69, 85, 87, 88, 89, 90, 91, 93, 94, 

95, 96, 97, 99, 100, 101, 102, 103, 104, 105, 106, 

107, 108, 109, 110, 111, 112, 113, 114, 117, 119, 

120, 121, 122, 123, 124, 125, 126, 127, 129, 130, 

131, 132, 133, 134, 135, 137, 138, 140, 141, 142, 

143, 144, 145, 146, 147, 148, 155, 160, 165, 194, 

195, 196, 198, 199, 200, 201, 208, 224, 225, 231, 

233, 259, 260, 261, 262, 266, 267, 268, 271, 273, 

274, 275, 281, 283, 284, 285, 287, 288, 289, 292, 

293, 298, 311, 312, 318, 320, 322, 325, 335, 336, 

337, 341, 357

Habitat Capability, 23, 103, 260, 292, 298

habitat effectiveness index, 329

Habitat Type, 22, 89, 96, 97, 99, 105, 143, 199, 293

Harvest, 3, iii, iv, 19, 20, 24, 25, 29, 31, 35, 36, 37, 38, 

39, 41, 42, 43, 45, 47, 50, 66, 67, 68, 73, 76, 80, 

81, 82, 90, 91, 93, 94, 96, 105, 108, 114, 117, 118, 

122, 123, 125, 127, 128, 129, 132, 133, 146, 148, 

151, 152, 155, 158, 159, 160, 162, 163, 165, 166, 

168, 173, 174, 176, 177, 179, 180, 181, 182, 183, 

184, 185, 186, 187, 189, 200, 204, 212, 213, 215, 

216, 217, 219, 222, 223, 224, 225, 226, 231, 232, 

238, 239, 244, 249, 251, 252, 253, 254, 255, 259, 

260, 262, 266, 268, 269, 270, 271, 274, 275, 286, 

289, 290, 293, 298, 323, 324, 325, 335, 339, 340, 

341, 349, 355, 356, 357

Headwaters, 2, 94, 138, 153, 173, 223, 252, 293, 335

Hiding Area, 293

Historical Range of Variability, i, ii, iii, 18, 19, 20, 47, 

53, 66, 69, 71, 72, 74, 79, 80, 81, 83, 84, 95, 96, 

273, 283, 293, 315, 355, 356

Hydrologic Unit Code, 138, 139, 142, 147, 152, 283, 

293

Indicator Species, v, 89, 231, 293, 295

Indirect Effects, 61, 65, 79, 82, 84, 87, 114, 146, 148, 

149, 157, 158, 159, 161, 162, 163, 164, 166, 179, 

181, 184, 188, 196, 198, 199, 204, 205, 208, 215, 

218, 229, 232, 233, 237, 243, 244, 249, 253, 254, 

255, 257, 262, 263, 275, 293

Individual Tree Selection, 293

Interdisciplinary Team, 3, 31, 32, 33, 43, 52, 278, 293

Intermediate Harvest, 293

Intermittent Stream, 43, 154, 294

Irretrievable, 68, 85, 149, 169, 191, 201, 209, 219, 

233, 239, 245, 250, 256, 266, 269, 294

Irreversible, 68, 85, 149, 169, 191, 201, 209, 219, 

233, 239, 245, 250, 256, 266, 269, 294

Issue, v, 32, 41, 88, 90, 294, 309, 311, 325, 336

Landing, 38, 39, 42, 44, 46, 174, 183, 216, 264, 294, 

300, 339, 350, 351, 352, 353, 354

Late Forest Succession, 294

Litter, 72, 75, 77, 113, 128, 157, 244, 291, 292, 294

Mainstem, 140, 142, 147, 294

Management Area, iii, 20, 21, 22, 24, 32, 46, 55, 57, 

69, 87, 89, 91, 92, 93, 114, 115, 116, 117, 122, 

215, 222, 224, 225, 226, 232, 235, 237, 259, 260, 

261, 265, 284, 294, 343

Management Indicator Species, 32, 87, 88, 89, 94, 

100, 101, 137, 262, 273, 274, 284, 295

Marginal Cover, 90, 114, 291, 294, 300

Merchantable Timber, 294

Mitigation, 31, 46, 51, 66, 84, 169, 171, 172, 175, 

203, 244, 254, 258, 295, 312, 315, 319

Mixed Stand, 295

Monitoring, 31, 33, 46, 47, 50, 92, 103, 137, 138, 146, 

147, 149, 158, 167, 174, 178, 181, 182, 183, 203, 

204, 206, 211, 262, 295, 312, 324, 325, 337, 338, 

339, 341

Mortality, ii, 18, 36, 39, 50, 62, 64, 70, 71, 72, 75, 96, 

106, 112, 120, 122, 123, 125, 126, 130, 157, 216, 

219, 257, 290, 295, 317

Mosaic, 21, 22, 23, 24, 25, 48, 49, 69, 88, 90, 92, 118, 

124, 181, 182, 216, 224, 260, 261, 295

Multiple-Use Management, 295

National Environmental Policy Act, 17, 26, 27, 29, 51, 

52, 58, 84, 176, 179, 193, 211, 249, 269, 279, 281, 

284, 295, 307, 312

National Forest Management Act, 29, 37, 87, 89, 137, 

193, 259, 270, 284, 291, 295, 307

Natural Regeneration, 37, 174, 295, 299, 301

No Action Alternative, 3, iv, v, vi, 33, 34, 61, 65, 68, 

79, 80, 84, 111, 126, 146, 148, 157, 158, 165, 179, 

198, 205, 207, 215, 229, 231, 232, 237, 238, 239,

243, 249, 250, 253, 256, 274, 295

Non-System Road, 157, 175, 295

Noxious Weeds, 46, 203, 204, 205, 225, 231, 233, 

264, 269, 274, 296, 338

Old Growth, 22, 87, 89, 93, 94, 100, 101, 102, 110, 

259, 260, 289, 295, 296, 356

Ongoing Actions, 166, 296

Open System Road, 40, 41, 296

Overmature, 260, 294, 296

Overstory, 19, 37, 54, 61, 63, 64, 65, 70, 71, 72, 75, 

77, 90, 148, 157, 158, 166, 272, 296, 299, 301, 357

PACFISH, iv, 24, 27, 28, 33, 34, 35, 43, 47, 57, 133, 

137, 138, 159, 160, 186, 247, 251, 262, 296, 325,

337, 371

Patch, 296

Perennial Stream, 144, 154, 159, 160, 166, 178, 207, 

296

Pre-Commercial Thinning, 161, 253, 296

Preferred Alternative, 34, 296

Prescribed Fire, iv, 23, 25, 31, 34, 36, 38, 39, 40, 43, 

45, 47, 50, 55, 67, 68, 69, 76, 81, 84, 85, 91, 92,

97, 122, 125, 126, 127, 128, 129, 130, 146, 147, 

148, 157, 158, 159, 160, 161, 163, 164, 165, 166, 

167, 168, 173, 175, 180, 182, 183, 184, 185, 188, 

198, 219, 232, 238, 241, 242, 243, 257, 260, 261, 

264, 275, 286, 291, 296, 299, 307, 308, 321, 323, 

325, 340, 341
Final Environmental Impact Statement

Pomeroy Ranger District 305

Prescription, 42, 50, 125, 131, 159, 182, 217, 266, 

290, 296, 357

Present Net Value, 274, 296

Public Involvement, 30, 297

Range, 3, i, ii, iii, v, vi, viii, 17, 18, 19, 20, 23, 24, 26, 

32, 33, 34, 36, 40, 49, 53, 54, 59, 60, 69, 70, 71, 

72, 74, 79, 80, 87, 89, 90, 92, 93, 94, 95, 96, 97, 

99, 100, 101, 102, 104, 106, 107, 108, 109, 119, 

124, 125, 127, 133, 148, 154, 155, 165, 172, 173, 

175, 177, 181, 183, 194, 199, 208, 212, 221, 224, 

225, 231, 247, 260, 263, 265, 270, 274, 278, 283, 

285, 286, 287, 289, 293, 297, 300, 301, 308, 309, 

311, 313, 314, 315, 316, 317, 318, 319, 320, 322, 

339, 355

Range of Variability, i, ii, iii, v, vi, 18, 26, 34, 53, 69, 

70, 71, 74, 79, 80, 95, 96, 124, 125, 212, 287, 297, 

311, 317, 319

Reforestation, 31, 37, 49, 68, 254, 256, 270, 295, 297, 

299, 316, 319

Regeneration, 24, 34, 35, 36, 37, 38, 39, 41, 42, 47, 

74, 100, 118, 119, 122, 131, 216, 217, 249, 265, 

266, 287, 293, 295, 297, 298, 350, 351, 352, 353, 

354, 356, 357

Regeneration Harvest, 24, 100, 118, 119, 287, 297

Resiliency, i, iv, vi, 18, 20, 75, 81, 83, 85, 124, 125, 

291, 297

Restoration, 27, 28, 105, 108, 132, 137, 151, 172, 

184, 186, 187, 189, 194, 200, 251, 267, 288, 297, 

312, 313, 314, 316, 325, 338, 339, 340

Revegetation, 163, 194, 297

Riparian Area, 27, 89, 105, 114, 131, 132, 133, 149, 

167, 231, 249, 297, 336

Riparian Habitat Conservation Area, 24, 26, 40, 43, 

44, 45, 50, 57, 156, 158, 159, 266, 284, 297, 325

Runoff, 149, 152, 157, 160, 163, 164, 166, 174, 177, 

178, 180, 183, 184, 187, 190, 293, 297, 301, 322

Salvage, 54, 96, 101, 102, 105, 200, 219, 293, 298, 

316, 325

Satisfactory Cover, 23, 36, 90, 114, 260, 291, 298, 300

Scoping, 3, v, 17, 24, 30, 31, 32, 33, 34, 50, 88, 221, 

268, 271, 272, 273, 277, 298

Seasonally Closed Road, 298

Sediment, 44, 50, 133, 142, 148, 149, 152, 154, 155, 

156, 158, 159, 160, 162, 163, 164, 166, 167, 172, 

173, 174, 175, 176, 177, 178, 180, 182, 184, 185, 

186, 188, 189, 263, 297, 298, 322, 323, 324, 340

sensitive, vi, vii, 23, 46, 47, 48, 49, 88, 101, 103, 105, 

109, 110, 114, 133, 134, 135, 137, 143, 144, 146, 

193, 194, 195, 196, 198, 199, 200, 201, 211, 213, 

225, 231, 233, 242, 243, 244, 262, 265, 267, 269, 

271, 293, 298

Sensitive, 22, 23, 32, 87, 88, 90, 95, 102, 103, 109, 

113, 127, 137, 143, 144, 146, 194, 200, 213, 224, 

225, 242, 243, 261, 262, 266, 270, 274, 284, 298, 

308, 337

Seral, i, iii, 18, 20, 24, 34, 35, 36, 37, 38, 58, 61, 62, 

64, 65, 66, 74, 77, 100, 111, 112, 119, 272, 298, 

300, 318, 356

Shade-Intolerant, 59, 119, 217, 272, 298

Shade-Tolerant, iii, 19, 36, 59, 66, 74, 217, 272, 290, 

298

Shelterwood Harvest, 36, 298

Silvicultural System, 298

Silviculture, iv, v, 35, 36, 57, 58, 60, 69, 74, 75, 77, 88, 

93, 111, 112, 165, 259, 273, 299, 310, 311, 341, 

355, 357

Site Potential, 48, 67, 158, 299, 356

Site Preparation, 160, 166, 183, 295, 299

Slash, 38, 39, 42, 43, 44, 45, 46, 47, 49, 67, 161, 181, 

182, 186, 199, 212, 216, 230, 260, 299, 338, 339, 

340

Smolt, 299

Snag, v, 23, 27, 29, 32, 41, 47, 48, 50, 67, 80, 87, 88, 

89, 93, 95, 96, 97, 99, 100, 101, 102, 104, 106, 

107, 108, 112, 119, 120, 122, 123, 124, 125, 127, 

129, 130, 131, 132, 225, 231, 232, 274, 287, 288, 

299, 357

Soil Compaction, 299

Soil Productivity, 171, 172, 173, 174, 175, 177, 178, 

179, 180, 184, 185, 187, 188, 189, 190, 263, 294, 

299

Stability, viii, 21, 23, 100, 142, 158, 159, 160, 167, 

172, 174, 175, 177, 178, 184, 195, 245, 256, 260, 

274, 290, 299, 315

Stand Composition, i, 18, 299

Stand Density, vi, 20, 39, 47, 60, 61, 63, 64, 65, 66, 

67, 71, 75, 217, 257, 299, 312, 318, 319, 357

Stand Replacement, 299

Stand Structure, 35, 62, 64, 65, 80, 88, 122, 124, 126, 

131, 219, 225, 258, 273, 275, 299, 338, 355

Standards and Guidelines, 160, 171, 259, 263, 274, 

284, 299

Stream Morphology, 299

Succession, 36, 59, 61, 65, 68, 74, 111, 148, 158, 165, 

225, 292, 294, 298, 299, 300, 318, 338

Successional Stage, 89, 225, 297, 300

Suitability, 27, 135, 186, 261, 265, 300, 357

Sustainability, 95, 300, 317

Temporary Road, vii, 26, 31, 41, 44, 49, 117, 120, 

123, 129, 149, 151, 161, 162, 163, 164, 166, 176, 

182, 183, 184, 185, 187, 188, 189, 199, 232, 264, 

269, 271, 300, 339

Thinning, 24, 25, 34, 35, 36, 39, 42, 43, 48, 49, 54, 72, 

75, 80, 82, 118, 119, 120, 122, 123, 124, 126, 127, 

129, 131, 132, 133, 134, 146, 159, 160, 162, 163, 

164, 180, 182, 184, 185, 186, 188, 189, 213, 217, 

222, 231, 232, 238, 239, 249, 257, 274, 287, 293, 

300,312, 313, 316, 322, 349, 350, 351, 352, 353, 

354

threatened species, 102, 193, 262, 269, 271, 286, 300

Tier, 26, 300

Total Cover, 90, 114, 300

Tractor Logging, 173, 300

Transitory Range, 249, 300

Unauthorized, 157, 179, 208, 300

Underburn, 54, 301
Sunrise Vegetation and Fuels Project

306 Umatilla National Forest

Understory, ii, iii, 18, 19, 20, 25, 35, 36, 39, 47, 60, 

61, 62, 63, 65, 67, 75, 90, 102, 107, 118, 120, 124, 

126, 127, 128, 131, 166, 215, 218, 272, 292, 296, 

301, 338, 357

Uneven-Aged Management, 260, 301

Uneven-Aged Stand, 23, 24, 90, 260, 261, 293, 301

Vegetation Management, 24, 57, 166, 172, 212, 301

Vertical Diversity, 24, 301

Viable Population, 89, 135, 261, 274, 301

Water Yield, vii, 148, 152, 154, 157, 158, 159, 160, 

162, 163, 164, 165, 166, 167, 168, 180, 263, 290, 

301, 324

Watershed, i, iii, 18, 28, 53, 55, 87, 96, 97, 99, 123, 

124, 138, 139, 143, 146, 149, 155, 157, 162, 163, 

166, 167, 173, 177, 183, 248, 257, 262, 263, 266, 

272, 290, 293, 297, 301, 308, 322, 323, 324, 336, 

339, 340, 355

Wetlands, 43, 57, 128, 142, 151, 154, 155, 158, 159, 

165, 166, 167, 195, 267, 268, 271, 297, 301

Winter Range, 22, 23, 24, 41, 69, 85, 89, 90, 92, 117, 

224, 225, 260, 261, 267, 286, 301

Yarding, 24, 25, 38, 42, 45, 46, 54, 173, 181, 182, 184, 

186, 189, 264, 301, 341, 349
Final Environmental Impact Statement

Pomeroy Ranger District 307

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342 Umatilla National Forest

Appendix A: Project Maps

Map A-1: Vicinity Map
Final Environmental Impact Statement

Pomeroy Ranger District 343

Map A- 2: Management Area Map
Sunrise Vegetation and Fuels Project

344 Umatilla National Forest

Map A- 3: Subwatershed Area Map
Final Environmental Impact Statement

Pomeroy Ranger District 345

Map A- 4: Alternative B Vegetation Treatment Map
Sunrise Vegetation and Fuels Project

346 Umatilla National Forest

Map A- 5: Alternative C Vegetation Treatment Map
Final Environmental Impact Statement

Pomeroy Ranger District 347

Map A- 6: Alternative B Fuels Treatment Map
Sunrise Vegetation and Fuels Project

348 Umatilla National Forest

Map A- 7: Alternative C Fuels Treatment Map
Final Environmental Impact Statement

Pomeroy Ranger District 349

Appendix B: Cutting Unit Activities for Action

Alternatives

Cutting 

Unit

Alt B 

(acres)

Alt C 

(acres)

Timber 

harvest/

yarding

system

Primary 

Silvicultural 

cutting 

method

Primary fuels treatment

1 56 56 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

2 38 38 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

3 34 34 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

4 44 44 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

5 22 22 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

6 22 22 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

7 13 13 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

8 57 57 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

9 74 74 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

10 58 58 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

11 99 99 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

13 20 20 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

14 67 67 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

15 66 66 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

16 69 69 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

18 7 7 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

19 13 13 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

20 15 15 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

21 34 34 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

22 24 24 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

23 17 17 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

24 53 53 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

25 25 25 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

26 17 17 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn
Sunrise Vegetation and Fuels Project

350 Umatilla National Forest

Cutting 

Unit

Alt B 

(acres)

Alt C 

(acres)

Timber 

harvest/

yarding

system

Primary 

Silvicultural 

cutting 

method

Primary fuels treatment

27 40 40 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

28 25 25 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

30 45 45 None Intermediate Mechanical thinning

(mastication) and landscape burn

31 163 163 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

32 57 57 None Intermediate Mechanical thinning

(mastication) and landscape burn

33 32 32 None Intermediate Mechanical thinning

(mastication) and landscape burn

34 8 8 None Intermediate Mechanical thinning

(mastication) and landscape burn

35 59 59 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

36 104 104 None Intermediate Mechanical thinning

(mastication) and landscape burn

37 34 34 None Intermediate Mechanical thinning

(mastication) and landscape burn

38 21 21 None Intermediate Mechanical thinning

(mastication) and landscape burn

39 8 8 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

40 47 47 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

41 18 18 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

44 49 49 None Intermediate Mechanical thinning

(mastication) and landscape burn

45 6 6 None Intermediate Mechanical thinning

(mastication) and landscape burn

46 24 24 None Intermediate Mechanical thinning

(mastication) and landscape burn

47 118 0 Skyline Intermediate Landing-pile and landscape burn

48 43 43 Ground-based Intermediate Landing-pile and landscape burn

49 38 0 Skyline Intermediate Landing-pile and landscape burn

50 63 63 Skyline Intermediate Landing-pile and landscape burn

51 7 0 Ground-based Intermediate Landing-pile and landscape burn

52 25 25 Skyline Intermediate Landing-pile and landscape burn

54 31 31 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

55 40 23 Ground-based Intermediate Landing and/or grapple-pile burn

56 21 21 Ground-based Regeneration Landing-pile and landscape burn

57 22 22 Ground-based Regeneration Landing and/or grapple-pile burn

58 29 0 Ground-based Regeneration Landing and/or grapple-pile burn

60 79 79 Ground-based Regeneration Landing-pile burn

61 105 0 Ground-based Regeneration Landing and/or grapple-pile burn

62 10 10 Ground-based Regeneration Landing and/or grapple-pile burn

63 64 64 Ground-based Regeneration Landing-pile burn

64 111 95 Ground-based Combination/b

oth

Landing-pile burn

65 10 10 Skyline Regeneration Landing-pile burn

66 35 0 Skyline Combination/b

oth

Landing-pile burn

67 67 60 Skyline Intermediate Landing-pile burn
Final Environmental Impact Statement

Pomeroy Ranger District 351

Cutting 

Unit

Alt B 

(acres)

Alt C 

(acres)

Timber 

harvest/

yarding

system

Primary 

Silvicultural 

cutting 

method

Primary fuels treatment

69 4 0 Skyline Regeneration Landing-pile burn

70 6 0 Skyline Regeneration Landing-pile burn

71 141 99 Ground-based Combination/b

oth

Landing-pile burn

72 8 4 Skyline Combination/b

oth

Landing-pile burn

73 8 0 Skyline Regeneration Landing-pile burn

74 19 19 Skyline Intermediate Landing-pile burn

75 15 15 Skyline Intermediate Landing-pile burn

76 52 0 Skyline Intermediate Landing-pile burn

77 91 0 Skyline Intermediate Landing-pile burn

78 53 53 Ground-based Intermediate Landing-pile burn

79 46 0 Skyline Intermediate Landing-pile burn

80 87 0 Ground-based Combination/b

oth

Landing and/or grapple-pile burn

81 7 0 Skyline Intermediate Landing-pile burn

82 83 0 Skyline Intermediate Landing-pile burn

83 52 0 Ground-based Intermediate Landing and/or grapple-pile burn

84 10 0 Skyline Regeneration Landing-pile burn

85 8 0 Skyline Intermediate Landing-pile burn

86 54 0 Ground-based Intermediate Landing and/or grapple-pile burn

87 16 0 Skyline Intermediate Landing-pile burn

88 2 0 Ground-based Regeneration Landing and/or grapple-pile burn

89 55 55 Ground-based Intermediate Landing and/or grapple-pile burn

90 13 13 Skyline Intermediate Landing-pile burn

91 33 33 Skyline Intermediate Landing-pile burn

92 41 0 Skyline Combination/b

oth

Landing-pile burn

93 13 0 Ground-based Intermediate Landing-pile burn

94 91 0 Ground-based Intermediate Landing-pile burn

95 12 12 Skyline Intermediate Landing-pile burn

96 160 0 Ground-based Combination/b

oth

Landing-pile burn

97 59 59 Skyline Intermediate Landing-pile burn

98 18 0 Skyline Intermediate Landing-pile burn

99 16 0 Ground-based Intermediate Landing-pile burn

100 53 0 Skyline Intermediate Landing-pile burn

101 46 0 Skyline Intermediate Landing-pile burn

102 113 78 Skyline Intermediate Landing-pile burn

103 19 0 Skyline Intermediate Landing-pile burn

104 41 41 Skyline Intermediate Landing-pile burn

105 52 0 Skyline Intermediate Landing-pile burn

106 39 0 Ground-based Regeneration Landing-pile burn

107 9 0 Skyline Intermediate Landing-pile burn

108 23 0 Ground-based Intermediate Landing-pile burn and 

mechanical thinning

(mastication)

109 27 0 Skyline Intermediate Landing-pile burn

110 5 0 Ground-based Regeneration Landing-pile burn

111 93 0 Skyline Intermediate Landing-pile and landscape burn

112 40 0 Skyline Combination/b

oth

Landing-pile burn

113 41 41 Skyline Intermediate Landing-pile burn

114 18 17 Ground-based Intermediate Landing-pile burn

116 83 59 Skyline Combination/b

oth

Landing-pile and landscape burn
Sunrise Vegetation and Fuels Project

352 Umatilla National Forest

Cutting 

Unit

Alt B 

(acres)

Alt C 

(acres)

Timber 

harvest/

yarding

system

Primary 

Silvicultural 

cutting 

method

Primary fuels treatment

117 58 35 Skyline Intermediate Landing-pile and landscape burn

118 18 0 Skyline Combination/b

oth

Landing-pile and landscape burn

119 12 12 Skyline Intermediate Landing-pile and landscape burn

120 240 16 Ground-based Combination/b

oth

Landing and/or grapple-pile burn

121 42 0 Ground-based Intermediate Landing-pile burn

122 54 0 Skyline Intermediate Landing-pile burn

123 11 11 Skyline Intermediate Landing-pile burn

124 45 0 Skyline Intermediate Landing-pile burn

125 37 37 Ground-based Regeneration Landing-pile burn

126 9 9 Skyline Regeneration Landing-pile burn

127 90 90 Ground-based Regeneration Landing-pile and landscape burn

128 15 0 Skyline Regeneration Landing-pile and landscape burn

129 24 0 Skyline Intermediate Landing-pile and landscape burn

130 21 21 Skyline Regeneration Landing-pile and landscape burn

131 79 77 Ground-based Regeneration Landing and/or grapple-pile burn

132 7 7 Skyline Intermediate Landing-pile burn

133 35 35 Ground-based Combination/b

oth

Landing and/or grapple-pile burn

134 43 0 Ground-based Combination/b

oth

Landing-pile burn

135 54 0 Ground-based Intermediate Landing-pile and landscape burn

136 35 0 Skyline Intermediate Landing-pile and landscape burn

137 19 0 Skyline Intermediate Landing-pile and landscape burn

138 70 44 Ground-based Combination/b

oth

Landing-pile burn

139 53 53 Ground-based Regeneration Landing-pile burn

140 12 12 Ground-based Intermediate Landing-pile and landscape burn

141 20 0 Ground-based Intermediate Landing-pile and landscape burn

142 5 5 Ground-based Intermediate Landing-pile and landscape burn

143 8 8 Ground-based Intermediate Landing-pile and landscape burn

144 8 8 Ground-based Intermediate Landing-pile and landscape burn

145 35 35 Ground-based Intermediate Landing-pile and landscape burn

146 104 88 Ground-based Regeneration Landing and/or grapple-pile burn

147 5 5 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

148 8 8 Skyline Intermediate Landing-pile and landscape burn

149 16 16 Ground-based Regeneration Landing and/or grapple-pile burn

150 57 57 Ground-based Intermediate Landing-pile and landscape burn

151 7 0 Skyline Intermediate Landing-pile and landscape burn

152 8 8 Skyline Intermediate Landing-pile and landscape burn

153 41 0 Ground-based Regeneration Landing and/or grapple-pile burn

154 7 7 Ground-based Regeneration Landing and/or grapple-pile burn

155 34 34 Ground-based Intermediate Landing-pile and landscape burn

157 6 0 Ground-based Intermediate Landing-pile and landscape burn

158 46 46 Ground-based Intermediate Landing-pile and landscape burn

159 56 0 Ground-based Intermediate Landing-pile and landscape burn

160 47 0 Skyline Intermediate Landing-pile and landscape burn

161 43 0 Ground-based Combination/b

oth

Landing and/or grapple-pile burn

162 44 0 Ground-based Regeneration Landing and/or grapple-pile burn

163 38 0 Ground-based Regeneration Landing and/or grapple-pile burn

164 38 0 Ground-based Regeneration Landing and/or grapple-pile burn

165 31 31 Skyline Regeneration Landing-pile and landscape burn

166 26 26 Skyline Regeneration Landing-pile and landscape burn
Final Environmental Impact Statement

Pomeroy Ranger District 353

Cutting 

Unit

Alt B 

(acres)

Alt C 

(acres)

Timber 

harvest/

yarding

system

Primary 

Silvicultural 

cutting 

method

Primary fuels treatment

167 11 11 Ground-based Regeneration Landing-pile and landscape burn

168 27 27 Ground-based Regeneration Landing-pile and landscape burn

169 26 26 Ground-based Intermediate Landing-pile and landscape burn

170 9 9 Skyline Intermediate Landing-pile and landscape burn

171 18 0 Skyline Intermediate Landing-pile and landscape burn

172 7 7 Ground-based Intermediate Landing-pile and landscape burn

173 7 7 Skyline Intermediate Landing-pile and landscape burn

174 5 5 None Intermediate Mechanical thinning

(mastication) and landscape burn

175 42 42 None Intermediate Mechanical thinning

(mastication) and landscape burn

176 34 34 None Intermediate Mechanical thinning

(mastication) and landscape burn

177 4 4 None Intermediate Mechanical thinning

(mastication) and landscape burn

178 24 24 Skyline Intermediate Landing-pile burn and 

mechanical thinning

(mastication)

179 12 12 Ground-based Intermediate Landing-pile burn and 

mechanical thinning

(mastication)

180 25 25 Ground-based Intermediate Mechanical thinning

(mastication)

181 7 7 None Intermediate Mechanical thinning

(mastication)

182 45 45 None Intermediate Mechanical thinning

(mastication) and landscape burn

183 7 7 None Intermediate Mechanical thinning

(mastication) and landscape burn

184 18 18 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

185 28 28 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

186 17 17 Skyline Intermediate Landing-pile burn

187 13 13 Ground-based Intermediate Landing-pile burn

188 8 8 Ground-based Intermediate Landing and/or grapple-pile burn

189 24 24 None Intermediate Mechanical thinning

(mastication)

190 17 17 Ground-based Intermediate Landing and/or grapple-pile burn

191 1 0 Ground-based Intermediate Landing and/or grapple-pile burn

192 6 6 Skyline Intermediate Landing-pile burn

193 3 0 Ground-based Intermediate Landing-pile burn

194 7 7 None Intermediate Mechanical thinning

(mastication)

195 11 11 Ground-based Intermediate Landing-pile burn

196 56 56 Ground-based Intermediate Landing-pile and landscape burn

197 8 8 Skyline Intermediate Landing-pile burn

198 11 11 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

199 15 15 Ground-based Intermediate Landing-pile and landscape burn

200 18 18 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

201 15 15 Ground-based Intermediate Landing-pile and landscape burn

202 12 12 Ground-based Intermediate Landing-pile burn

203 15 15 Skyline Intermediate Landing-pile burn

204 17 17 Ground-based Intermediate Landing-pile burn
Sunrise Vegetation and Fuels Project

354 Umatilla National Forest

Cutting 

Unit

Alt B 

(acres)

Alt C 

(acres)

Timber 

harvest/

yarding

system

Primary 

Silvicultural 

cutting 

method

Primary fuels treatment

205 22 22 Skyline Intermediate Landing-pile burn

206 21 21 Ground-based Intermediate Landing-pile burn

207 7 7 None Intermediate Mechanical thinning

(mastication) and landscape burn

208 57 57 Ground-based Intermediate Landing-pile burn

209 10 10 Ground-based Intermediate Landing-pile burn

210 20 20 Ground-based Intermediate Landing-pile and landscape burn

211 2 0 Ground-based Intermediate Landing-pile burn

212 18 18 Ground-based Intermediate Landing-pile burn

213 2 0 Ground-based Intermediate Landing-pile burn

214 20 20 None Intermediate Mechanical thinning

(mastication) and landscape burn

215 7 7 None Intermediate Mechanical thinning

(mastication)

216 6 6 Ground-based Intermediate Landing-pile burn and 

mechanical thinning

(mastication)

217 7 7 Ground-based Intermediate Landing-pile burn

218 16 16 Skyline Intermediate Landing-pile burn

219 10 10 Skyline Intermediate Landing-pile burn

220 5 0 Ground-based Intermediate Landing-pile and landscape burn

221 6 0 Ground-based Intermediate Landing and/or grapple-pile burn

223 3 0 Ground-based Regeneration Landing-pile and landscape burn

226 116 0 Ground-based Combination/b

oth

Landing-pile burn

227 30 0 Ground-based Regeneration Landing-pile burn

228 12 0 Ground-based Regeneration Landing-pile and landscape burn

229 27 27 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn

230 20 0 Ground-based Regeneration Landing-pile burn

231 18 0 Ground-based Regeneration Landing-pile burn

232 31 31 Skyline Regeneration Landing-pile and landscape burn

233 47 47 Skyline Intermediate Landing-pile and landscape burn

235 208 208 None Intermediate Manual (hand) thinning, pruning, 

and landscape burn
Final Environmental Impact Statement

Pomeroy Ranger District 355

Appendix C: Consistency with Eastside Screens

General Standards (Items 1-3 in Plan Amendment #11)

The Sunrise project action alternatives are consistent with the Screens general standards because 

they are designed to incorporate the interim ecosystem and wildlife standards as discussed 

below, and incorporate the riparian standard by avoiding any tree-cutting activities within 

Pacfish-designated RHCAs. Items 2 and 3 are not pertinent because the Sunrise project is not 

claimed as an exception to Item 1. 

Ecosystem Standard (Item 5 in Plan Amendment #11)

The Sunrise project action alternatives are consistent with the Screens ecosystem standards for 

reasons described below, with reference to the applicable required component in the Eastside 

Screens. 

• Item 5a: Proposed timber-harvest activities were assessed relative to their associated 

watershed for patterns of stand structure by biophysical environment, and comparisons were 

made to the Historic Range of Variability (Martin 2010). The HRV used was developed for 

large landscapes across which forest types, environmental settings, and disturbance regimes 

are relatively uniform (Powell 2014b). The component watershed used for the sunrise 

analysis has a range of conditions broadly reflective of the range of conditions for which the 

HRV was developed (interior Pacific Northwest montane forest ecosystems). Quantified 

vegetation analysis was limited to National Forest System lands within the Lick Creek and 

North Fork Asotin watersheds. Approximately 500 acres were classified on private and stateowned lands within the watershed from adjacent Forest Service lands and using aerial 

photographs. The distribution of structural stages appears similar to analogous Forest 

Service lands, with a heavy dominance of high density old forest multi-strata forests, of 

Douglas-fir, grand fir, and ponderosa pine cover types. Thus, their inclusion into the 

quantified ecosystem analysis of this report would not noticeably alter findings, activity 

types, or project consistency with Forest Plan requirements. 

• Item 5b: To characterize forest ecosystems relevant to the Sunrise silviculture analysis, HRV

was determined in Powell 2014b (and references therein) using the first 3 steps outlined in 

the Screens for Item 3b. Powell 2014b is incorporated by reference into this analysis. Step 4 

of Item 3b was mapped for the project analysis, and structural stage abundance was 

calculated by biophysical setting.

• Item 5c: Differences between percent composition of structural stages between HRV and 

current conditions are also reported in Section 3.6. Structural conditions and biophysical

environment combinations outside of HRV conditions were assessed to determine potential 

treatment areas. 

Wildlife Standard (Item 6 in Plan Amendment #11)

The Sunrise project action alternatives are consistent with the Screens wildlife standards for 

reasons described below, with reference to the applicable required component in the Eastside 

Screens. 

• Item 6a: Multi-strata with Large Trees (OFMS) and Single Strata with Large Trees (OFSS) 

were assessed for all biophysical environments within the Sunrise project area. 

• Item 6b: LOS stages (OFMS and OFSS) were calculated separately for each biophysical
Sunrise Vegetation and Fuels Project

356 Umatilla National Forest

environment, and Scenario A was chosen as the applicable scenario for all three biophysical 

environments (Most, Cold, and Dry Upland Forest). 

• Item 6c: The Sunrise analysis is not claiming an exemption from consideration of HRV, so 

this item does not apply. 

Item 6d (Scenario A): None of the proposed timber harvest would result in a net loss of LOS 

from any of the three upland-forest biophysical environments in the Sunrise planning area. There 

are no timber harvest activities planned under any action alternative in LOS stages below HRV. 

• Some tree-cutting activities are included under Alternatives B and C for areas in LOS stages 

within or above HRV and are designed as intermediate or individual-tree selection31 cutting 

treatments. Such treatments are designed to maintain or enhance LOS within the pertinent 

biophysical environment by converting a stage above HRV (OFMS) to one currently within 

or below HRV (OFSS), and/or by altering density and/or species composition to improve 

residual tree vigor, size, and/or longevity. 

• Other tree-cutting activities included under Alternatives B or C are planned in areas outside 

of LOS with the intent to maintain and/or enhance LOS components as appropriate to meet 

HRV by adhering to all standards listed in the Screens amendment. These items are directly 

related to silvicultural design criteria related to the Eastside Screens Forest Plan amendment, 

described previously in this report.

o All remnant late and old seral and/or structural live trees >21” dbh that currently exist 

within stands proposed for harvest activities would be maintained

o Structure that does not meet LOS conditions would be manipulated in a manner that 

moves it towards these conditions as appropriate to meet HRV. Any areas treated in 

such a manner to move them away from LOS (e.g. seed-tree regeneration cutting 

activities) are included only because LOS conditions elsewhere are expected to meet 

HRV as a result of overall project effects. 

o Where open, park-like conditions occurred historically (areas characterized by frequent, 

low-severity fire regimes), all treatments will be designed to maintain, or reestablish,

such conditions by implementing intermediate thin-from-below treatments and/or 

emphasize the removal of fire-intolerant species. A sufficient number of seedlings, 

saplings, and poles will be maintained to allow for the development of future stands. 

a) Connectivity would be maintained and/or enhanced and fragmentation avoided 

because the project adheres to the following standards: 

b) Stands serving the purpose of connecting LOS stands and Forest Plan designated 

“old growth/MR” habitats would be maintained. These items are directly related to 

silvicultural design criteria related to the Eastside Screens Forest Plan amendment, 

described previously in this report.

1) Activity units and prescriptions for both action alternatives were explicitly 

designed in such a manner that LOS stands and MR/Old Growth habitats 

would be connected to each other in a contiguous network from at least 2 

different directions.

2) Any activities that may occur in a connectivity corridor would be designed 

such that following implementation, medium and larger trees would remain 

common, canopy closures would remain within the top one-third of site 

potential, and stands would remain >400’ wide at their narrowest point.

 

31 Individual-tree selection cutting is classified as a regeneration method—not an intermediate treatment.
Final Environmental Impact Statement

Pomeroy Ranger District 357

3) Length of connection corridors is as short as possible 

4) Harvests included under either action alternative and occurring within 

connectivity corridors would occur only if the above criteria are met, and if 

some amount of understory (if any occurs) is left in patches or scattered to 

assist in supporting stand density and cover. 

c) Stands that do not currently meet LOS but are located within, or surrounded by, 

blocks of LOS stands are not considered for even-aged regeneration or group 

selection. 

o Wildlife-related items:

a) Design criteria pertaining to Snags, Green Tree Replacements, and Down Logs are 

included in the silvicultural design criteria section above. Snags and green 

replacement trees >21 inches dbh (or whatever smaller representative dbh of the 

overstory layer) would be retained at levels prescribed by the project biologist. A 

consistency finding and rationale is also included in the project wildlife specialist 

report.

b) Every known active and historically used goshawk nest-site would be protected 

from disturbance. 30 acres of the most suitable nesting habitat surrounding all 

active and historical nest trees would be deferred from harvest. A consistency 

finding rationale for goshawks is also included in the project wildlife specialist 

report. 

Other, Non-Screens Consistency Findings

Concerning National Forest Land Suitability, all silvicultural activities would be implemented 

only on lands meeting the definition of forest land (16 U.S.C. 1604) and designated as suitable 

for timber production by the Forest Plan (USDA Forest Service 1990), as amended. Furthermore, 

even-aged management components are considered to comply with Forest Plan objectives, and 

are restricted to 40 acres or less. All silvicultural prescriptions recommending a clearcutting

activity would do so only if it is found to be an activity of last resort –only proposed when no 

other intermediate (preferred) or regeneration cutting method to meet stand management 

objectives would be appropriate or compatible with existing stand conditions. This method of 

determination is amenable with the Forest Plan. 

Vegetation manipulation must comply with the requirements found in 16 U.S.C. 1604. These 

include compliance with multiple-use goals and objectives under each action alternative, acres 

prescribed as regeneration cutting are replanted within five years, assuring the assigned 

prescription is chosen for the greatest positive ecological impact and not on dollar value, 

consideration of effects to residual trees and adjacent stands from silvicultural prescription 

implementation, consideration of effects to site productivity and RHCAs by utilizing BMPs, and 

that action alternative silviculture activities are both practical and would provide the desired 

effects with respect to water quantity and quality, wildlife and fish habitat, regeneration of 

desirable tree species, forage production, recreation uses, aesthetic values, and other resource 

yields.
Sunrise Vegetation and Fuels Project

358 Umatilla National Forest

Appendix D: Responses to Comments on the 

Draft Environmental Impact Statement

The purpose of this appendix is to respond to comments received on the Draft Environmental 

Impact Statement. We received comments from 9 entities (individuals, organizations, agencies,

and Tribes). We followed a systematic process of reading, coding, and summarizing the 

comments. This process ensured that every comment was read, analyzed, and considered. Each 

commenter was assigned a commenter code and each unique comment was numbered 

sequentially and paraphrased into a concern statement to focus on issues. Similar comments were 

grouped and combined into “concern statements.” Therefore, while not every comment is listed 

in the appendix exactly as written by each respondent, each comment was considered 

individually. Concern statements were then sorted by topic and arranged alphabetically 

according to resource and topic. 

All comments received, and the content analysis used to review, code and sort comments, are 

located in the project record.

The interdisciplinary team prepared responses for each comment based on its merits, regardless 

of the source or whether expressed by many or by one. Responses to comments focus on the 

following (40 CFR 1503.4):

• Modifying alternatives including the proposed action.

• Developing and evaluating alternatives not previously given serious consideration by the 

agency.

• Supplementing, improving, or modifying the analysis.

• Making factual corrections.

• Explaining why the comments do not warrant further agency response.

Commenters

Code Name of Commenter & Organization Affiliation Date Attachment

01 Veronica Warnock, Conservation Director

Greater Hells Canyon Council

PO Box 2768

La Grande, OR 97850

07/06/2018 N

02 Mike Petersen, Executive Director

The Lands Council

25 West Main, Suite 222

Spokane, WA 99201

07/06/2018 N

03 Dick Artley 07/12/2018 Y

04 Irene K. Jerome, Consultant

American Forest Resource Council

408 SE Hillcrest Rd.

John Day, OR 97845

07/12/2018 N

05 Lindsay Warness, Forest Policy Liaison

Boise Cascade

1917 Jackson Ave. 

La Grande, OR 97850

07/13/2018 N

06 Mark Wachtel, Habitat Program Manager

Washington Dept. of Fish and Wildlife

Eastern Region, Region 1

2315 North Discovery Place

Spokane Valley, WA 99216-1566

07/15/2018 Y
Final Environmental Impact Statement

Pomeroy Ranger District 359

Code Name of Commenter & Organization Affiliation Date Attachment

07 Shannon F. Wheeler, Chairman

Nez Perce Tribal Executive Committee

P.O. Box 305

Lapwai, Idaho 83540

07/16/2018 N

09 Paula Hood, co-Director

Blue Mountains Biodiversity Project

Portland Office

5622 7th Ave.

Portland, OR 97211

07/16/2018 Y

10 Jill A. Nogi, Manager

U.S. Environmental Protection Agency

Region 10, Office of Environmental Review and Assessment

Environmental Review and Sediment Management Unit

1200 Sixth Ave., Suite 155

Seattle, WA 98101-3140

07/24/2018 Y

Comments & Responses

The concern statements and responses below are sorted by topic and numbered sequentially. The 

commenter code with unique comment number appears to the right.

Alternatives

1. Concern Statement: The Forest Service should:

• Drop all commercial-size logging in suitable goshawk habitat, suitable marten 

habitat, suitable and active Pileated woodpecker habitat, and suitable

blackbacked and American three-toed woodpecker habitat; with no overstory 

canopy reduction in these areas. 

• Drop the proposed prescribed burning of pileated woodpecker source habitat to 

benefit the viability of both pileated and goshawks. 

• Not burn in suitable or active pileated woodpecker and marten habitat as 

burning destroys habitat suitability for both species—decayed snags and logs 

for pileated, and abundant down wood for marten. 

• Not burn in moister PAGs or during the spring reproductive season. 

• Not burn areas designated for pileated or marten, both of which need abundant 

down wood and snags. 

• Not implement prescribed burning in the spring reproductive season to avoid 

impacts to the reproductive success of woodpecker species, neotropical 

migratory songbirds, and goshawks, as well as to better protect seeding of 

sensitive plants, protect young mammals in burrows, and retain higher soil 

moisture levels for the dry season. 

• Drop the proposed prescribed burning in the best northern goshawk habitat in 

the Sunrise area, as well as to sensitive-listed fringed myotis bat roosting 

habitat, and to already beleaguered (at risk) redband trout and Columbia spotted 

frog, both sensitive-listed species. 

• Leave undeveloped lands, inventoried and uninventoried roadless areas, and 

Potential Wilderness Areas in a natural state to serve wildlife needs, headwaters 

protection, and as reference condition landscapes for scientific study, as well as 

for recreation in a natural setting. They represent some of the best and last big 

09-26
Sunrise Vegetation and Fuels Project

360 Umatilla National Forest

blocks of intact, high security habitat left for fish species, wide-ranging 

keystone predators, native ungulates, and other wildlife species.

• Drop all commercial-size logging in wildlife connectivity corridors. 

• Drop any suitable Pacific fisher habitat from logging and fuel reduction. 

• Drop planned "temporary" roads as these often remain on the landscape and 

increase access for illegal firewood (often large snag) cutting and fur trappers 

and reduce re-opening of closed roads. 

• Reduce road density to at least the Forest Plan standards and objectives for elk. 

• Drop units in Blue Mountains Biodiversity Project’s survey sheet priority drop 

sale units for MIS, sensitive, or special-status species, plus Forest Service 

mapping of any additional known suitable habitat for these species in 

commercial logging sale units.

Response: Thank you for your input. The range of alternatives chosen for the 

Sunrise project environmental analysis allows for the selection (in a final Record of 

Decision) of an alternative that includes the above modifications. Such an 

alternative would have direct, indirect, and cumulative effects within the scope and 

scale of those analyzed and disclosed in the DEIS.

Best Available Science

2. Concern Statement: The Forest Service should include on pg. 3-83 of the DEIS a 

reference to the elk research conducted by the Washington Department of Fish and 

Wildlife within the project area (McCorquodale et al. 2010). This research project 

evaluated the impacts roads have on elk survival, finding that hunters harvested 

marked elk closer to roads than unharvested marked elk were found during the 

hunting season. The higher the road density, the harder it is for elk to get away from 

hunters, resulting in higher mortality of elk.

Response: This reference has been added to the FEIS. 

06-11

3. Concern Statement: The Forest Service should include some documents from the 

opposing views science attachments provided by the commenter in the 

References/Literature Cited section of the NEPA document.

Response: References to opinions and general-interest articles in magazines, 

newspapers, newsletters, blogs, etc., are appreciated, as they give the Responsible 

Official a general sense of various views and beliefs. References to new sources of 

credible, peer-reviewed scientific research relevant to the analysis of this project 

were reviewed by specialists to determine if and how they would change the effects 

analysis. Any changes to the FEIS as a result of this review are noted in the FEIS.

03-22

4. Concern Statement: The Forest Service must respond to each opposing view 

incorporated by reference in the commenter’s letter.

Response: References to opinions and general-interest articles in magazines, 

newspapers, newsletters, blogs, etc., are appreciated, as this gives the Responsible 

Official a general sense of various views and beliefs. References to new sources of 

credible, peer-reviewed scientific research relevant to the analysis of this project 

03-25
Final Environmental Impact Statement

Pomeroy Ranger District 361

were reviewed by specialists to determine if and how they would change the effects 

analysis. Any changes to the FEIS as a result of this review are noted in the FEIS.

5. Concern Statement: The Forest Service should reconsider its reliance on Riggs et 

al. 2000 to state that intense ungulate herbivory has potentially caused the loss of 

shrubs (DEIS pg.2-33). This reference is not in the Literature Cited section of the 

DEIS and may not be a relevant reference for the loss of shrubs. Particularly with 

the very low density of deer using National Forest lands, the primary browser of 

shrubs.

Response: This statement is not specific to the Sunrise Project area and has been 

removed from the FEIS.

06-05

6. Concern Statement: The Forest Service should use the full range of best available 

science, and consider considerable scientific and public controversy regarding the 

assumptions and issues raised in the DEIS. There are a number of areas of concern, 

including: 

• The Forest Service is failing to use the full range of best available science in 

claiming that more carbon is released by wild fire than by logging.

• We see a lot of inaccurate use of the science re: judging fire regime and wildfire 

'risk' by silvicultural assessment of the tree density and multiple canopy layers 

alone, when most fires are primarily weather-driven, not fuel driven.

• Protected forests with little or no logging are not more likely to experience 

higher severity wildfire. 

• Fires, including high-severity fires, are good for forests.

• Thinning is likely not needed, effective, nor ecologically beneficial in moist 

mixed-conifer forest to prevent fire, does not mimic the complex natural fire 

regime and threatens to increase fire risk.

• Large fires are climatically driven and fuels reduction treatments can be 

insignificant to prevent fire spread under these conditions. Post-fire habitat is 

significantly degraded by the logging that happens in the name of fuels 

reduction prior to the fire. 

• Current forest management is unnecessarily putting firefighters at risk by 

focusing on remote areas, contrary to peer-reviewed science or common sense. 

Gibbons et al. (2010) found that defensible space work within 40 meters [about 

131 feet] of individual homes effectively protects homes from wildland fire, 

even intense fire.

• Multiple convergent lines of evidence suggest that mixed-severity fire, which 

included large patches of high-severity fire, dominated most western forested 

landscapes. In addition, many forests were more dense than commonly 

recognized by agencies such as the Forest Service.

• Logging is not practical or cost effective, and does not make communities safer.

• The short-term and temporary nature of the perceived fuels reduction benefits 

from most logging projects are not likely to result in meaningful changes to fire 

intensity, size, or severity.

• Growing scientific evidence shows that numerous species are at much lower 

risk from wildfire than previously thought, and some of these species may be 

more negatively affected by thinning than by wildfire.

09-37
Sunrise Vegetation and Fuels Project

362 Umatilla National Forest

Response: The Forest Service has a long history of science-based decision making. 

Using the best science provides the responsible official with the knowledge, 

methods, and expert review needed to make an informed decision. The agency has 

taken into account the best available science, and used it to conduct the analysis of 

the Sunrise project. These sources are cited throughout the DEIS and the specialist’s 

reports. The References section of the DEIS (pg. R-1) lists the necessary 

information for the public to find and review these sources, if they so desire. All 

references to new sources of credible, peer-reviewed scientific research provided by 

commenters have been reviewed by specialists to determine if and how they would 

change our analysis of the Sunrise project. Any changes to the FEIS as a result of 

this review are noted in the FEIS.

Climate Change

7. Concern Statement: The Forest Service should address the effects to carbon 

storage and contribution to climate change from the heavy logging that is being 

practiced at an unprecedented scale and pace on the Blue Mountains. The Forest 

Service should not ignore the science saying it is imperative to leave mature forest 

and protect carbon storage and this project could contribute to climate change.

Response: The Sunrise project is compliant with Eastside Screens, a plan 

amendment that requires retention of all large trees greater than 21 inches in dbh. 

The largest trees within the project area will therefore be retained; and the 

conversion of Old Forest Multistory Strata to Old Forest Single Story strata will 

remove undergrowth, thus encouraging vigor and carbon storage in the remaining 

trees. Treatments in some other forest types may result in a loss of some carbon 

storage, but it is expected in the long term that treatment will result in increased 

vigor and growth, thereby increasing total carbon storage over the long term. (This 

information has been added to section 3.20 of the FEIS).

The assertion that “heavy logging... is being practiced at an unprecedented scale 

and pace on the Blue Mountains is contrary to the fact that logging within the Blue 

Mountains and on the Umatilla National Forest has decreased demonstrably since 

the 1980s.

09-34

Content Required in EIS

8. Concern Statement: The Forest Service should discuss three items required to be 

in the EIS per 40 CFR 1502.6:

(e) Energy requirements and conservation potential of various alternatives and 

mitigation measures. 

(f) Natural or depletable resource requirements and conservation potential of 

various alternatives and mitigation measures. 

(g) Urban quality, historic and cultural resources, and the design of the built 

environment, including the reuse and conservation potential of various alternatives 

and mitigation measures.

03-23
Final Environmental Impact Statement

Pomeroy Ranger District 363

Response: Discussion of these items can be found on the following pages of the 

FEIS: 

(e) pg. 3-236—Energy Requirements

(f) pg. 3-233—Irreversible and Irretrievable Commitments of Resources

(g) pg. 3-234—National Historic Preservation Act, and pg. 3-215—Economic 

Analysis.

Cumulative Effects

9. Concern Statement: The Forest Service should disclose cumulative effects of 

potential repeat entries into the forest stands of the Sunrise project area.

Response: Impacts from prior management activities are incorporated into the 

baseline discussed in the Affected Environment. Repeat entries such as maintenance 

treatments and burning may occur although they are not proposed in this project. 

When proposed, a separate NEPA document would be prepared. This document 

would address the direct, indirect and cumulative effects of the proposed 

maintenance treatment and/or burning. 

09-09c

10. Concern Statement: The Forest Service should analyze the long-term or largescale effects of early seral treatments that focus on fuels reduction in the project or 

cumulatively across watersheds and the landscape. Regional trends for logging 

prescriptions regarding historic range of variability should be vetted or analyzed for 

effects on the human or ecological environments across the landscape.

Response: An analysis of subbasin or basin-scale effects of activities is outside the 

scope and scale of the Sunrise project and effects analysis.

09-12a

Economic Analysis

11. Concern Statement: The Forest Service should address the effects to carbon 

storage and contribution to climate change from the heavy logging that is being 

practiced at an unprecedented scale and pace on the Blue Mountains. The Forest 

Service should not ignore the science saying it is imperative to leave mature forest 

and protect carbon storage and this project could contribute to climate change.

Response: The Sunrise project is compliant with Eastside Screens, a plan 

amendment that requires retention of all large trees greater than 21 inches in dbh. 

The largest trees within the project area will therefore be retained; and the 

conversion of Old Forest Multistory Strata to Old Forest Single Story strata will 

remove undergrowth, thus encouraging vigor and carbon storage in the remaining 

trees. Treatments in some other forest types may result in a loss of some carbon 

storage, but it is expected in the long term that treatment will result in increased 

vigor and growth, thereby increasing total carbon storage over the long term. (This 

information has been added to section 3.20 of the FEIS).

02-10
Sunrise Vegetation and Fuels Project

364 Umatilla National Forest

The assertion that “heavy logging... is being practiced at an unprecedented scale 

and pace on the Blue Mountains is contrary to the fact that logging within the Blue 

Mountains and on the Umatilla National Forest has decreased demonstrably since 

the 1980s.

12. Concern Statement: The Forest Service should explain why Alternative B has a 

larger net present value than Alternative C. Is it due to the higher road construction 

in Alt B?

Response: Alternative B ($-800,000) has a lower net present value than Alternative 

C ($-720,000). This difference is due to increased reforestation costs associated 

with Alternative B. These numbers do not take into account economic benefit to the 

local communities.

02-11

13. Concern Statement: The Forest Service should explain why the following research 

does not apply to the Umatilla National Forest. Dr. Power makes the following 

conclusions from his research findings: "Even within relatively isolated areas, 

such as the northeastern tier of counties, there was considerable economic vitality 

despite the declines in federal timber harvests." "The relatively high 

unemployment rates in many of the eastern Washington counties adjacent to 

National Forests cannot be attributed to the decline in federal harvests. Those 

counties had even higher unemployment rates at the time of peak harvests in the late 

1980s."

Response: The Forest Service has a long history of science-based decision making. 

Using the best science provides the responsible official with the knowledge, 

methods, and expert review needed to make an informed decision. The agency has 

taken into account the best available science, and used it to conduct the analysis of 

the Sunrise project. These sources are cited throughout the DEIS and the specialist’s 

reports. The References section of the DEIS (pg. R-1) lists the necessary 

information for the public to find and review these sources, if they so desire. All 

references to new sources of credible, peer-reviewed scientific research provided by 

commenters have been reviewed by specialists to determine if and how they would 

change our analysis of the Sunrise project. Any changes to the FEIS as a result of 

this review are noted in the FEIS.

03-15

14. Concern Statement: The Forest Service should be concerned about local 

community stability and local job creation by offering this sale as an SBA sale to 

prevent a large timber corporation from logging it using their own labor. This would 

prevent the logs from being hauled many miles to be processed at a mill far 

removed from the small communities you claim need economic help.

Response: This project is planned to include at least one SBA timber sale. Specifics 

of timber sale procedures are beyond the scope of this analysis.

03-17

15. Concern Statement: The Forest Service should consider the economic viability of 

the project and make sure that it is designed in a way that makes sense for the 

market. This is not the same thing as maximizing economic value of the project. 

This viability is tied to both the volume and type of timber products sold and the 

04-05
Final Environmental Impact Statement

Pomeroy Ranger District 365

manner in which these products are permitted to be delivered from the forest to the 

mills.

Response: Thank you for your comment. Specifics of timber sale procedures are 

beyond the scope of this analysis.

16. Concern Statement: The Forest Service should explain why the agency's planning 

costs are not included in the economic analysis. It is important to acknowledge the 

investment that the agency has already put into the landscape.

Response: Given that employee time is split between implementation and planning 

on multiple projects, determining the cost planning related to this project would be 

difficult.

05-14a

17. Concern Statement: The Forest Service should explain why it is planning to mark 

timber under both Alternative B and Alternative C. There are new congressional 

tools that would allow the FS not mark these units and save some funding.

Response: Thank you for your comment. New tools are being proposed every day 

that can change how we prepare timber sale contracts and designate vegetation for 

removal. We will be attempting some of these new tools for the Sunrise project. 

Designation by Prescription is one tool we hope to utilize. On the other end of the 

Timber Contracting scale, we are considering advertisement and award of these 

projects utilizing weight scale instead of tree measurement. This would allow us 

much more flexibility on the cruising work and costs. However, specifics of timber 

sale procedures are beyond the scope of this analysis.

05-14b

Effects Analysis

18. Concern Statement: The Forest Service’s NEPA document should include the 

beneficial effects that the implementation of this project will have.

Response: The direct, indirect, and cumulative effects of alternatives disclosed in 

the FEIS include both beneficial and adverse effects, even if they are not always 

explicitly described as such.

05-16

19. Concern Statement: The Forest Service should reconsider and reanalyze The "No 

Action" alternative because it was not seriously considered or analyzed, as 

evidenced by the USFS downplaying or ignoring the myriad of ecological benefits 

associated with not logging these areas. The USFS also cherry picked studies to 

overstate potential negative effects associated with wildfire.

Response: Your opinion is appreciated, as this gives the Responsible Official a 

general sense of various views and beliefs. 

09-03
Sunrise Vegetation and Fuels Project

366 Umatilla National Forest

Fisheries

20. Concern Statement: The Forest Service’s determinations of "Not Likely to 

Adversely Affect" ESA-listed salmonids and their habitat are arbitrary and 

capricious, and lack adequate direct, indirect, and cumulative impacts analyses.

Response: The DEIS Fisheries section on Environmental Consequences begins on 

pg. 3-122 with Direct and Indirect Effects discussion beginning on pg. 3-131. 

Cumulative Effects discussion for fisheries begins on pg. 3-133.

09-29

21. Concern Statement: The Forest Service should not dismiss the population of 

Snake River spring/summer Chinook salmon that are found within and adjacent to 

the Sunrise project. The DEIS notes that "[t]hey are known to occupy 

approximately 5.4 miles of NF Asotin Creek within the Project boundary and can 

also be found in downstream of the project area in NF Asotin Creek and mainstem 

Asotin Creek. Due to few adult spawners returning to Asotin Creek, the Interior 

Columbia Technical Review Team considers the Asotin Spring Chinook population 

to be functionally extinct." It is very convenient to relegate this small and struggling 

population, which the USFS was at least partly responsible for decimating, and 

which it ostensibly has a responsibility to protect, to non-existence despite the fact 

that it continues to persist in the face of historic abuses and degradation.

Response: The population is not being dismissed by the USFS. The statement you 

are referring to is one of fact and the current condition/state of the existing 

population in the Asotin Creek drainage. The Snake River Spring/Summer Chinook 

salmon will be given all the protections required by ESA and Forest Service 

direction. 

09-30

Forest-Wide Monitoring

22. Concern Statement: Forest-wide monitoring reports have not been published on 

the Forest's website since the 1991 - 2001 report. 

Response: Available monitoring reports can be found on our planning website: 

https://tinyurl.com/y7m6mxv3 .

07-25

Fuels

23. Concern Statement: The Forest Service should build the following components 

into the prescriptions for mesic and moist forest to allow the post-harvest prescribed 

fire and the post-fire condition to more closely emulate and reflect the stand's 

historic fire regime; where fire was less frequent, understory fuels typically more 

abundant, and mortality of overstory trees significantly higher: 

• Variation of patch size 

• Variation of patch shape

02-05
Final Environmental Impact Statement

Pomeroy Ranger District 367

• Variation of patch edges (more feathering, less edge effect)

• Untreated patches 

• Consideration of the function of slope, aspect, and valley orientation on fire 

behavior 

• Retention of significant biomass (both live and dead) in mesic stands prior to 

prescribed fire 

• Unless there are significant extenuating circumstances, do not utilize "pile and 

burn" slash treatment

Response: Thank you for your input. There is 14,055 acres of prescribed fire 

proposed in the Sunrise project, of which, approximately 2,500 acres is in moist 

forest, mix-severity. There is also another 878 acres of activity fuels jackpot 

burning proposed in Alternative B, and 599 acres in Alternative C. The range of 

alternatives chosen for the Sunrise project environmental analysis allows for the 

selection (in a final Record of Decision) of an alternative including the measures 

suggested. Such an alternative would have direct, indirect, and cumulative effects 

within the scope and scale of those analyzed and disclosed in the DEIS.

24. Concern Statement: The Forest Service should include the (commenter’s) 

Opposing Views Science Attachments in an Appendix and cite them in the body of 

the NEPA document, because there is scientific uncertainty between the 

independent science presented in the (commenter’s) attachments and the claims 

made in this DEIS. These attachments present quotes authored by experts showing 

why: 

• Logging to reduce fuels does not affect fire intensity and rate of spread. 

• Fire benefits some resources in the forest and should be suppressed only after a 

careful examination of the situation.

Response: Created slash associated with logging may increase fire behavior and/or 

intensity in the short term but activity fuels treatments are proposed for both in 

Alternative B and C. (DEIS, 2-34). This projects is not intended to reduce or 

eliminate wildfire. It is intended to reduce fuels (both standing and ground) so that 

if fire were to occur it would more closely emulate fire intensity and severity that 

occurred historically. There is 14,055 acres of landscape prescribed fire proposed 

for the Sunrise project area (DEIS, 2-35).

The Forest Service has a long history of science-based decision making. Using the 

best science provides the responsible official with the knowledge, methods, and 

expert review needed to make an informed decision. The agency has taken into 

account the best available science, and used it to conduct the analysis of the Sunrise 

project. These sources are cited throughout the DEIS and the specialist’s reports. 

The References section of the DEIS (pg. R-1) lists the necessary information for the 

public to find and review these sources, if they so desire. All references to new 

sources of credible, peer-reviewed scientific research provided by commenters have 

been reviewed by specialists to determine if and how they would change our 

analysis of the Sunrise project. Any changes to the FEIS as a result of this review 

are noted in the FEIS.

03-13

25. Concern Statement: The Forest Service should explain why over 3,600 acres of 

Fire Regime-2 will be left in condition class 3 under Alternative B (as shown in In 

05-07
Sunrise Vegetation and Fuels Project

368 Umatilla National Forest

Table 3-17 of the DEIS). Why doesn’t the Sunrise Project propose to treat these 

additional acres to return them to their historic fire regime?

Response: Fire Regime-2 is grassland. Much of the Fire Regime-2 acres are 

located within the Sunrise Planning Area, but are not part of the Sunrise Project. 

Instead, they will be treated under the previously authorized Asotin Creek 

Prescribed Fire Project. This is addressed in the Sunrise DEIS on pg. 3-78. More 

information about the Asotin Creek Prescribed Fire Project is available online at 

https://tinyurl.com/yczbrelk .

26. Concern Statement: The Forest Service should not convert mature mixed-conifer 

forests to early seral species composition, particularly if there is evidence of 

important wildlife use and/or historical dominance or co-dominance by later seral 

species. Logging does not mimic fire in terms of ecosystem function and processes.

Response: The DEIS does not state that logging perfectly “mimics” all aspects of 

wildfire disturbances on forest ecosystem form or processes, but silvicultural 

practices such as those included in the action alternatives can partially reproduce 

forest structural, compositional, and density-related ecosystem components 

expected under some fire regimes. Mature mixed-conifer greater than 21 inches 

will be retained, as required by the amended Forest Plan.

09-13b

27. Concern Statement: The Forest Service should adequately consider the ecological 

significance of high-severity fires, and adequately analyze the current role played 

by mixed- and high-severity fires in reference to evolving landscape dynamics 

accompanying climatic changes.

Response: The ecological significance of high-severity fires is not within the 

purpose and need of this project. The Fuels purpose and need is to modify forest 

stands in Condition Class 2 and 3 in Fire Regimes 1, 2 and 3. The recent history of 

fires and fire suppression within the project area has been incorporated into the 

Affect Environment.

09-16

28. Concern Statement: The Forest Service should take into consideration that mixedseverity fire, including high-severity fire is necessary for many species.

Response: The Pomeroy Ranger District recognizes that mixed and high severity 

fire could occur at any time. The purpose and need of the Sunrise project is not to 

prevent such fires, but to allow better management of wildfire when it does occur. 

The objective is firefighter safety and protection of values at risk.

09-38

29. Concern Statement: The Forest Service should acknowledge that the short-term 

and temporary nature of the perceived fuels reduction benefits from most logging 

projects are not likely to result in meaningful changes to fire intensity, size, or 

severity. In terms of possible future reentry of forests for logging under the guise of 

'fuels reduction'—what is the USFS's plan for the many thousands of acres of 

logged areas? Will re-entries be planned across the landscape if wildfire or 

prescribed fire does not burn the area within 10-35 years? If treatments are only 

good for 10-15 years, then either re-entry will be needed or logging is a very costly 

and short- term endeavor that is not effective. It is not feasible to thin the entire 

09-41b
Final Environmental Impact Statement

Pomeroy Ranger District 369

landscape every 10-35 years, and if we could accomplish such a misguided feat, it 

would likely have unacceptable ecological impacts and not be economically viable.

Response: We fully realize the benefits of any treatment has an expiration date. 

That expiration date, however, depends on the intensity of the treatment, vegetation 

type, etc. Maintenance is not proposed in this document. When maintenance 

treatments are proposed another environmental document will be prepared to 

address direct, indirect and cumulative effects of such treatments.

Hydrology

30. Concern Statement: The Forest Service should conduct a spatially explicit 

watershed scale aquatic assessment that considers the inclusion of: 

• LiDAR data rectification of stream network. 

• LiDAR data rectification of transportation network, including all nonauthorized roads. 

• Stream habitat surveys to fill any data gaps using USFS required methodology. 

Shall include assessment of instream habitat, floodplain condition, and riparian 

functions and dynamics (including impacts/impairments). 

• Geomorphic assessment to fill data gaps, including evaluation of effects of 

human modifications on stream geomorphology and process (e.g., road-stream 

interactions); channel morphology and evolution trends; substrate analysis; 

channel, floodplain, and habitat dynamics; and large woody debris functions. 

• Fish densities/population characteristics and biological processes (food webs, 

predation, etc.) 

• Sediment transport and storage, including contributions/impacts from roads and 

land use practices (e.g., timber harvest, grazing, etc.). The analysis will likely 

include GIS-based raster analysis, hydraulic modeling, and/or appropriate 

alternative methodology. 

• Watershed hydrologic regime and influencing factors (e.g., snowpack, water 

withdrawals, landscape features, groundwater dynamics, etc.), which may 

include hydraulic modeling/simulation. 

• Water quality evaluation, including potential impacts and impairments. 

• Wetland distribution and function. 

• Beaver habitat enhancement potential, including evaluating the feasibility of 

beaver relocation using Beaver Restoration Assessment Tool (BRAT) (or 

similar) and application of Beaver Dam Analogs to facilitate stream process 

restoration, habitat enhancement, and water storage. 

• Climate change assessment, including impacts on watershed processes and 

habitat. 

• Reach-based Ecosystem Indicators (REI) metric calculations for additional 

areas of habitat and geomorphic surveys (i.e., areas not covered by recent 

surveys).

Response: Thank you for your input. Our resource indicators and measures, 

methodology, and scale of analysis are described in the DEIS on pages 3- 136, 3-

138, 3-155 to 157; and in the Hydrology Report on pages 5 to 8 and in the Soils 

02-04
Sunrise Vegetation and Fuels Project

370 Umatilla National Forest

Report on pages 1 to 6, available on the project website: 

https://tinyurl.com/y7mboqgh .

31. Concern Statement: Is evapotranspiration a concern for this area? It would appear 

that by leaving the project area denser under Alternatives A and C, there would be 

less water absorbed into the system.

Response: A local study at the High Ridge Evaluation Area on the Umatilla NF 

(1967-1995) reported a positive relationship between average annual precipitation 

and transpiration (which could have been caused by trees transpiring more in wet 

than dry years and perhaps by a greater amount of deep seepage during wetter 

years). In addition, the data show that by the 3rd and 13th years after clearcut 

treatments (partial and final harvest occurred in the same stands ten years apart), 

soil moisture (at 3 ft. depth) of clearcut areas mirrored that of uncut forest areas and 

this trend continued for at least 8 years (until the study ended). This indicates that 

at least in the short term, soil moisture (as a surrogate for Et) use rates by old and 

new stands were similar (see Figure 10 on page 31 of Helvey and Fowler 1995).

05-11

32. Concern Statement: The Forest Service should adequately analyze the direct, 

indirect and cumulative effects of industrial scale logging practices on steamflow.

Response: Timber harvest would be used to move stands toward desired historical 

conditions for species composition, structural diversity, stand density and fuel 

loadings. As such, the activity’s effect on the evapotranspiration would be within 

the expected range of variability across the landscape. Therefore, any changes to 

summer steam flows would also be within the range of variability for the forest 

types within the North Fork Asotin and Lick Creek subwatersheds. In addition, the 

project is compliant with PACFISH/INFISH standards and guidelines and the 

Umatilla National Forest LRMP standards and guidelines. See the Sunrise Fisheries 

Specialist Report and Biological Evaluation for details; it is available on the project 

website: https://tinyurl.com/y7mboqgh .

09-10

33. Concern Statement: The Forest Service should seriously analyze and address the 

cumulative impacts of climate change and logging on streamflow, stream 

temperatures and sensitive aquatic species.

Response: There will be no direct or indirect effects to water yield or peak flows 

from either action alternative. With PACFISH buffers in place, no silvicultural 

actives will occur in the RHCAs, and prescribed burning will only be allowed to 

back into the RHCA. Therefore, there are no anticipated effects to stream 

temperature from this project. Current the effects of the proposed action on stream 

temperature and listed fish populations can be found in the DEIS, sections 3.9 and 

3.10.

09-11a

34. Concern Statement: The Forest service should disclose the effects of heavy 

logging across the project area and the effects on hydrology, particularly in areas 

with proposed logging on steep slopes. Leaving a few sparse trees on a steep 

hillside is very likely to introduce erosion and sedimentation into streams and 

increase peak flows, resulting in bank instability, changes in channel morphology, 

09-27
Final Environmental Impact Statement

Pomeroy Ranger District 371

decreases in dissolved oxygen levels, and further elevation of temperatures in the 

creek.

Response: Direct, Indirect and Cumulative effects to hydrology are described in the 

DEIS at 3-145 to 3-153.

35. Concern Statement: The Forest Service should not allow temperature increases in 

impaired streams. While the USFS states that there are no 303d listed streams in the 

project area, it is clear from Table 12 in the Hydrology Resource Report (pg. 19) 

that NF Asotin Creek in particular is suffering from high stream temperatures that 

exceed state standards.

Response: Proposed harvest/thinning and associated activity fuels treatments 

would not occur inside of interim PACFISH RHCAs, therefore the canopy density 

in RHCAs and shading would be maintained along all perennial streams. Because 

shade would not be changed, water temperature changes due to increased solar 

loading would not occur from this project. 

Alternative B would not adversely affect water temperature because harvest, 

thinning and burning would not measurably remove the shade component along 

any stream channel. Because there would be no change to shade, there would be no 

adverse effect to beneficial uses and no effect on the 303(d) listing status of 

streams. In addition, no adverse changes to channel condition from silvicultural 

treatments are predicted because water yield and peak flow would not be affected, 

therefore, morphological channel changes which could affect stream temperature 

would not occur. 

Alternative C would not adversely affect water temperature because harvest, 

thinning and burning would not measurably remove the shade component along 

any stream channel. Because there would be no change to shade, there would be no 

adverse effect to beneficial uses and no effect on the 303(d) listing status of 

streams. In addition, no adverse changes to channel condition from silvicultural 

treatments are predicted because water yield and peak flow would not be.

Current ECA values for Lick Creek and North Fork Asotin Creek subwatersheds 

are low compared to threshold value of 20% and suggest that there is no 

measurable difference between current conditions and those with no harvest. 

Vegetative recovery through time would continue to reduce ECA values. Current 

values of ECA when added to the Asotin Prescribed Fire Project (DEIS Table 3-

49) indicate that there would continue to be no measurable increase in water yield 

or peakflows. 

DEIS Table 3-49. Equivalent Clearcut Area Modeling Summary

Subwatershed Current ETA Asotin Rx Total ECA

Lick Creek 3.2% 4.2% 7.4%

NF Asotin Creek 1.5% 3.4% 4.9%

See DEIS pg. 3-143, paragraph 7, 3-146 paragraph 5, 3-148 paragraph 1. See also 

Hydrology Report pg. 34 paragraph 3, pg. 36 paragraph 5, pg. 39 paragraph 6, 

available on the project website: https://tinyurl.com/y7mboqgh .

09-28a
Sunrise Vegetation and Fuels Project

372 Umatilla National Forest

36. Concern Statement: The Forest Service should adequately protect small tributaries 

because they contribute significantly to the overall condition and water quality 

throughout the watershed and in larger creeks.

Response: Field reconnaissance has identified numerous perennial streams not 

previously mapped. All streams, whether previously identified or that are identified 

during layout and marking, will be buffered following PACFISH guidelines. 

09-28b

Invasive Plants

37. Concern Statement: The Forest Service should change the FEIS to clearly indicate 

"herbicides that contain glyphosate will not be used anywhere, at any time, for any 

reason as part of this timber sale."

Response: The Umatilla National Forest Invasive Plants Treatment FEIS (2010) is 

used as a guide when deciding what chemicals/active ingredients will be used for 

invasive treatments. This document is available online at 

https://tinyurl.com/ya4rjwr4 ; it is consistent with our Region 6 Invasive Plant 

FEIS (2005), available online at https://tinyurl.com/y9q3avgs .

03-03

38. Concern Statement: The Forest Service should substantiate its claim that there is a 

low risk for problems with invasive plants due to the Sunrise project. There are 

numerous examples of infested sites listed in the DEIS.

Response: The Umatilla National Forest Invasive Plant Treatment FEIS (2010) 

includes guidelines and direction that is followed in our ongoing invasive plant 

prevention, monitoring and treatment activities. The referenced infested sites have 

been, are, and will continue to be treated and/or monitored. Additionally, there are 

several Project Design Criteria in the Sunrise DEIS (pg. 2-41) to control and 

prevent invasive plant infestations from known sites and outside sources during 

project implementation. 

09-36

Project Design Criteria

39. Concern Statement: The Forest Service should consider that there are several 

ways to properly harvest any piece of ground, and certain restrictive language can 

limit some potential operators. Though some of the proposed area is planned for 

skyline harvest, there are opportunities to use certain ground equipment such as 

feller bunchers and processors in the units to make skyline yarding more efficient. 

Allowing the use of processors and feller bunchers throughout these units can 

greatly increase its economic viability, and in some cases decrease disturbance by 

decreasing the amount of skyline corridors, reduce damage to the residual stand, 

and provide a more even distribution of woody debris following harvest. It is 

absolutely critical that all units that contain skyline yarding be identified as 

"skyline/tractor" in contracts and be analyzed for both skyline and ground-based 

logging during the environmental analysis to provide maximum flexibility during 

implementation. This flexibility allows operators to work with Forest Service 

04-06
Final Environmental Impact Statement

Pomeroy Ranger District 373

personnel to achieve the best environmental results on the ground and will 

maximize the returns to the agency for timber removed.

Response: On pg. 2-41 of the DEIS, project design criteria SOIL-8 limits groundbased equipment to 35% slope. The skyline and ground-based units were 

determined using this criteria as a guide.

40. Concern Statement: The Forest Service should move the Project Design Criteria to 

an appendix because they are standard best management practices and are required 

on all contracts and fully described therein.

Response: We appreciate your comment, but prefer to keep project design criteria 

in the body of the document to reflect their importance to the effects analysis.

04-10

41. Concern Statement: The Forest Service should incorporate design or mitigation 

measures to limit possible concurrent activities that may spread noxious weeds, 

damage planted seedlings, or degrade resource conditions.

Response: Section 2.4 of the DEIS (pg. 2-39) lists the project design criteria and 

best management practices incorporated into the project to address these and other 

environmental and resource concerns.

07-20c

Public Involvement

42. Concern Statement: The Forest Service should make technical documents 

supporting the analysis and conclusions of the DEIS available online for the public 

to review.

Response: The specialist reports were made available on the public website during 

the DEIS comment period at https://tinyurl.com/y7mboqgh . Hardcopies are 

available upon request. 

03-24

Purpose & Need

43. Concern Statement: The Forest Service should not take action to create vigorous 

trees, because doing so will damage other resources. 

Response: Action is needed to improve forest health, vigor and resilience by 

moving stands toward their historical conditions for species composition, structural 

diversity, stand density and fuel loadings. (See pg. 1-16 of the DEIS, Section 1.4, 

Vegetation.) Chapter 3 of the DEIS (pg. 3-47) analyzes both beneficial and adverse 

effects that would result from implementing the proposed action and alternatives. In 

addition, the proposed action is consistent with the Forest Land and Resource 

Management Plan standards and guidelines, and other relevant environmental 

protection laws, regulations and policies; (see section 3.21, Findings of 

Consistency, on pg. 3-223 of the DEIS).

03-04
Sunrise Vegetation and Fuels Project

374 Umatilla National Forest

44. Concern Statement: The Forest Service should modify the purpose and need 

statement for the project to describe goals that can be achieved by different 

actions—specifically actions that don’t include timber harvest.

Response: Action is needed to improve forest health, vigor and resilience by 

moving stands toward their historical conditions for species composition, structural 

diversity, stand density and fuel loadings. (See pg. 1-16 of the DEIS, Section 1.4, 

Vegetation). Timber harvest is the most reasonable tool used to accomplish these 

objectives, and allows us the most flexibility and control of the outcome.

03-21, 

09-04

45. Concern Statement: The Forest Service should tighten up and streamline the 

wording of the project’s purpose and need statement for clarity.

Response: Thank you for your comment. Some clarification has been made 

regarding the purpose and need (Section 1.4 on pg. 1-16 of the FEIS.)

04-02

46. Concern Statement: The Forest Service should emphasize the three legs of the 

stool in creating this project, economic, ecological, and social concerns. Many 

times, the economic and social concerns are treated as secondary issues/outcomes 

and in doing so, we find that the projects are constrained and thus they fall short of 

meeting social and economic needs. Human uses are a part of the landscape.

Response: Thank you for your comment. Social and economic impacts are not 

expected to be significant.

05-15

47. Concern Statement: The Forest Service should not focus narrowly on "restoring" 

species composition to Historic Range of Variability (HRV) and other loggingbased strategies, because it fails to address the most important and primary stressors 

reflecting true ecosystem health and integrity which include: high stream 

temperatures, degraded soil conditions, struggling listed fish populations, and 

deficiencies in large tree structure. Publically and scientifically vetted legal 

protections such as those in the Endangered Species Act, Clean Water Act, and 

Forest Plan standards and guidelines prioritize protections regarding issues such as: 

maintaining cool stream temperatures, avoiding detrimental soil impacts, and 

avoiding critical habitat degradation 

Response: The need for action arose from an evaluation by an interdisciplinary 

team of Forest Service resource specialists of the differences between existing and 

desired conditions within the Sunrise project area. Desired conditions are defined by 

the Umatilla Forest Land and Resource Management Plan’s Forest-wide and 

management area goals. (See section 1.5, Management Direction, on pg. 1-17 of the 

DEIS.) Existing conditions for each resource were assessed by Forest Service 

specialists. (See the Affected Environment sections for soils, hydrology, fisheries, 

endangered species and other resources in the DEIS, Chapter 3.) 

Historical Range of Variability (HRV) is a measurement commonly used by land 

managers as a benchmark to represent the conditions that fully describe functional 

ecosystems. It was used in the assessment of the Sunrise project area’s vegetation. 

Species composition, stand density, structural diversity, and fuel loadings were 

found to have deviated from their HRV due to past forest management practices, 

including fire suppression. For more information about methodologies and findings, 

09-06
Final Environmental Impact Statement

Pomeroy Ranger District 375

see the silvicuture specialists report available on the project website: 

https://tinyurl.com/y7mboqgh .

The proposed action would move these conditions toward their HRV so that 

ecosystem processes are more resilient and self-sustaining. Commercial timber 

harvest is one of the tools necessary to accomplish this objective. For a description 

of this and other tools that would be used, see vegetation treatments description in 

section 2.3 of the DEIS, pg. 2-31. 

The proposed action is consistent with the Endangered Species Act, the Clean 

Water Act, and Forest Land and Resource Management Plan standards and 

guidelines; and all other pertinent environmental laws, regulations and policies, as 

disclosed in section 3.21 of the DEIS. Current conditions and the effects of the 

proposed action on stream temperature and listed fish populations can be found in 

the DEIS in sections 3.9 and 3.10, soil conditions in section 3.11, and large tree 

structure in section 3.6.

Range

48. Concern Statement: The Forest Service should put protective measures in place 

before any negative impacts from fuels treatment in approximately 240 acres of 

RHCA results in cattle being drawn into the newly established forage areas near 

water. 

Response: There are no proposed riparian fuels treatments in the Sunrise project. A 

paragraph erroneously describing such treatment appears in section 3.18 of the 

DEIS; it has been removed in the FEIS. We apologize for the confusion this error 

caused.

Prescribed fire will not be ignited in RHCAs but will be allowed to back into 

RHCAs (Project Design Criteria, RHCA-3, pg.2-39 of DEIS). When they occur, 

such backing fires are low intensity, and our experience tells us that they do not 

facilitate changes in livestock usage. 

02-12

49. Concern Statement: The Forests Service should make available the project range 

report referenced in the DEIS. 

Response: The range report was published in its entirety in section 3.18 of the 

DEIS. A separate range report was not prepared, and the reference to it in the DEIS 

was an error. We apologize for the confusion this error caused.

06-19

50. Concern Statement: The Forest Service should defer livestock grazing in timber 

harvest and burn units until desired vegetative conditions have been met.

Response: There is no Forest Service policy on the amount of time between project 

activity and return of grazing. The timeframe is determined by Forest Service 

personnel based on past experience, professional judgement, severity of the 

disturbance, and observation of onsite conditions. Management of livestock grazing 

is beyond the scope of this project. 

07-20b
Sunrise Vegetation and Fuels Project

376 Umatilla National Forest

51. Concern Statement: The Forest Service should add to the FEIS the condition and 

trend and/or ecological site condition data for the allotments in the project area; and 

monitor upland ecological site conditions prior to, during, and after implementation.

Response: Section 3.18 of FEIS has been updated to include the following 

information about monitoring:

The main concern associated with range and grazing is the effect of livestock on the 

ecosystem. Livestock can contribute to soil compaction, water quality issues, 

erosion, and streambank instability. These concerns are identified by the Forest 

Service as a result of spot checks of allotments, along with analysis of data 

collected on established monitoring transects. 

Within the Sunrise project area there are seven established monitoring transects. 

Data from these locations are available upon request from the Pomeroy Ranger 

District office.

The Asotin Allotment has one transect within the Sunrise project area:

Round Prairie—an upland transect located outside the area proposed activity. It is 

read pre-season, mid-season and post-season by Forest Service range personnel.

The Peola Allotment has six transects within the Sunrise project area:

Upper Sourdough—a riparian transect located outside the area of proposed 

activity. The area has been in resource protection since 2006 due to populations of 

Silene spaldingii (Spalding's catchfly), listed as a threatened species under the 

Endangered Species Act.

Dick Trail—a riparian transect located near the boundary of the project area, and 

outside the area of proposed activity. It is read pre-season, mid-season and postseason by Forest Service range personnel.

Lick Creek 2—a riparian transect located outside the area of proposed activity. The 

riparian area has been fenced to exclude cattle since approximately 2009. The 

transect is read pre-season, mid-season, and post-season by Forest Service range 

personnel. Additional data has been collected as part of the PACFISH/INFISH 

Biological Opinion (PIBO) monitoring program.

Pinkham—an upland transect located within an area of proposed activity. It is read 

mid-season and post-season. Vehicle access to the area is subject to seasonal 

closure until July 1 of each year.

Warner—an upland transect located within an area of proposed activity. It is spot 

checked by Forest Service range personnel when cattle utilize the area.

North Fork Asotin Creek—a riparian transect located outside the area of proposed 

activity. It is spot checked by Forest Service range personnel when cattle utilize the 

area.

07-20a

52. Concern Statement: The Forest Service should address in the Sunrise DEIS the 

negative impacts of grazing, particularly in combination with climate change. 

Please see our provided survey sheets for evidence of extensive impacts due to 

grazing.

09-11b
Final Environmental Impact Statement

Pomeroy Ranger District 377

Response: The Sunrise project area’s existing conditions were assessed by Forest 

Service specialists. This assessment did not indicate that impacts due to grazing 

would result as a major issue to be considered in by this effects analysis. Our 

analysis of the project’s effects on climate change meets Forest Service Region 6 

standards. The survey sheets provided are appreciated; our review of this 

information, however, did not reveal any new information that would alter our 

analysis of the need for action or the effects of the proposed action.

Recreation

53. Concern Statement: The Forest Services should disclose the project’s effects on 

recreation revenue. The public is less likely to recreate near areas that have been 

logged, thus logging diminishes recreation revenue. Since recreationists avoid areas 

that have been logged the many "ma and pa" businesses that depend on recreation & 

tourism dollars are harmed.

Response: Impacts to recreationists from project activities were considered. Please 

refer to the Recreation analysis in section 3.16 of the DEIS.

03-16

Roads

54. Concern Statement: The Forest Service should not log any areas that need 

temporary roads to access them, especially where those areas overlap with 

undeveloped lands, or moist or cold forests. This is necessary to avoid impacts to 

Snake River Basin steelhead, Bull trout, Snake River Spring/Summer Chinook 

salmon and their designated critical habitats, salmon essential fish habitat, water 

quality, and soils; and to prevent the spread of invasive weeds. Any temporary 

roads that are built must be removed from the landscape directly following project 

activities so they cannot be travelled. These areas should be monitored for 

unauthorized use and detrimental aquatic impacts post project implementation.

Additionally, the re-opening of closed or unclassified roads for access, and then reclosure following treatment activities has very serious ecological impacts. Extensive 

and intensive road reconstruction greatly increase road impacts on watershed 

systems. The elevated sedimentation they cause is already a ubiquitous water 

quality problem throughout the West and a major cause of the loss of aquatic 

biodiversity. 

Response: All temporary roads would occur in upland areas, above the point on the 

landscape in which snowmelt or rainfall runoff enters into a defined channel. 

Stream density would remain in the low risk category and there would be no new 

road crossings that would extend the stream network farther into upland areas. 

There would be no changes to the road system in the Lick Creek subwatershed. As 

a result, there would be no measureable increase in streamflow at the subwatershed 

scale. Therefore there would be no direct or indirect effect to water yield or peak 

flows from these actions. See DEIS Section 3.10. Also see Hydrology Report pg. 

35: 

01-10
Sunrise Vegetation and Fuels Project

378 Umatilla National Forest

Project design criteria for the protection of soil, water and aquatic resources are 

included as provisions and clauses in the timber sale contract. Timber sale contracts 

are administered by the sale administrator who verifies that all provisions and 

clauses in the contract are completed for Forest Service standards before the sale is 

closed.

Closed roads are part of the National Forest Service Road System and are managed 

as Maintenance Level 1 (ML1). Road management level 1 is defined in FSH 

7709.59, sec. 62.32 as: “These are roads that been placed in storage between 

intermittent uses. The period of storage must exceed 1 year. Basic custodial 

maintenance is performed to prevent damage to adjacent resources and to 

perpetuate the road for future resource management needs. Emphasis is normally 

given to maintaining drainage facilities and runoff patterns. Planned road 

deterioration may occur at this level.”

55. Concern Statement: The Forest Service should limit constructed temporary roads 

to less than 1⁄2 mile in length to reduce the potential impact to aquatic resources and 

wildlife. 

Response: The range of alternatives chosen for the Sunrise project environmental 

analysis allows for the selection (in a final Record of Decision) of an alternative 

including the measures suggested. Such an alternative would have direct, indirect, 

and cumulative effects within the scope and scale of those analyzed and disclosed in 

the DEIS.

02-03a

56. Concern Statement: The Forest Service should disclose how temporary roads will 

be decommissioned and/or obliterated and describe the subsequent monitoring 

protocol.

Response: Project design criteria for the protection of soil, water and aquatic 

resources are specified in the DEIS beginning on pg.2-39. Design Criteria WQ-9 

(pg.2-40) discusses road obliteration/decommissioning. Project design criteria are 

included as provisions and clauses in the timber sale contract. Timber sale contracts 

are administered by the sale administrator who verifies that all provisions and 

clauses in the contract are completed for Forest Service standards before the sale is 

closed.

02-03b

57. Concern Statement: The Forest Service should consider unauthorized roads in the 

minimum road analysis due to their potential detrimental impacts on the watershed. 

And the Forest Service should disclose how many miles of road currently exist 

within the project area including system roads, temporary roads, and unauthorized 

roads.

Response: DEIS Table 3-47 (pg. 3-140) identifies miles of system and nonsystem 

roads in the Lick Creek and NF Asotin Creek subwatersheds. Temporary roads are 

discussed in the DEIS at 3-146 to 3-148, 3-151. Another 53 miles of non-system 

roads, skid trails and user created routes were analyzed in the Soils Report to assess 

detrimental soil condition related to proposed treatment units (see Soils Report, 

Appendix E for calculation of DSC) available on the project website, 

https://tinyurl.com/y7mboqgh ). And see the Soils Methodology section (DEIS pg. 

3-155-157 and Soils Report pp. 2-6).

02-03c
Final Environmental Impact Statement

Pomeroy Ranger District 379

58. Concern Statement: The Forest Service should add alternatives that do not include 

road construction, thereby eliminating the resource damage caused by road 

construction.

Response: Action is needed to improve forest health, vigor and resilience by 

moving stands toward their historical conditions for species composition, structural 

diversity, stand density and fuel loadings. (See pg. 1-16 of the DEIS, Section 1.4, 

Vegetation.) Timber harvest and associated temporary roads are tools used to 

accomplish these objectives. 

03-02

59. Concern Statement: The Forest Service should not include temporary roads in the 

Sunrise project because these roads are constructed and located by employees 

working for the purchaser. Their goal is to minimize cost—not reduce aquatic 

damage by eliminating the possibility that sediment might enter streams. 

Response: All temporary roads would occur in upland areas, above the point on the 

landscape in which snowmelt or rainfall runoff enters into a defined channel (DEIS 

pg. 3-147).

Project design criteria for the protection of soil, water and aquatic resources are 

included as provisions and clauses in the timber sale contract. Timber sale contracts 

are administered by the sale administrator who verifies that all provisions and 

clauses in the contract are completed to Forest Service standards before the sale is 

closed. The project design criteria are disclosed in the DEIS, beginning on pg. 2-39. 

Effects from new temporary roads are disclosed in DEIS on pp. 3-147 to 3-151, pp. 

3-164-165, and pg. 3-169.

03-18

60. Concern Statement: The Forest Service should include a hydrologist and fisheries 

biologist on the interdisciplinary team (IDT); had these specialists been available 

they would have explained the concept of obliteration to the deciding official and 

how frequent, continued sediment production from "temporary roads" at each 

precipitation event will inflict major long-term aquatic harm. The Forest Service 

should fully obliterate temporary roads after they are no longer needed for this 

project in order to achieve the stabilization and restoration of unneeded roads to a 

more natural state and protect the aquatic environment. The final NEPA document 

should include a road obliteration monitoring plan to assure the sediment is being 

reduced as expected.

Response: The interdisciplinary team (IDT) for the Sunrise project includes a 

hydrologist and a fisheries biologist, as well as many other resource specialists 

(DEIS pg. 4-1). Effects from new temporary roads on fisheries, hydrology, and soils 

are disclosed in DEIS on pp. 3-133 to 3-134, pp.3-146 to 3-151, pp. 3-164-165, and 

pg. 3-169. Specialist reports are available on the project website: 

https://tinyurl.com/y7mboqgh .

All temporary roads would occur in upland areas, above the point on the landscape 

in which snowmelt or rainfall runoff enters into a defined channel (DEIS pg. 3-

147).Project Design Criteria for the protection of soil, water and aquatic resources 

are included as provisions and clauses in the timber sale contract. Timber sale 

contracts are administered by the sale administrator who verifies that all provisions 

and clauses in the contract are completed to Forest Service standards before the sale 

is closed. The project design criteria are disclosed in the DEIS, beginning on pg. 2-

03-19
Sunrise Vegetation and Fuels Project

380 Umatilla National Forest

39. Road decommissioning would be accomplished in accordance with FSM 7700 -

Transportation System.

61. Concern Statement: The Forest Service should utilize existing road beds and 

closed roads for temporary road construction required to access the Sunrise Project 

area whenever possible.

Response: Thank you for your input. The range of alternatives chosen for the 

Sunrise project environmental analysis allows for the selection (in a final Record of 

Decision) of an alternative including the measures suggested. Such an alternative 

would have direct, indirect, and cumulative effects within the scope and scale of 

those analyzed and disclosed in the DEIS.

04-08a

62. Concern Statement: The Forest Service should not decommission roads and 

remove them from the system as these roads are often necessary for future access 

and management activities. Utilizing other methods to prohibit use of these roads, 

such as gates and barriers, is a much better use of limited dollars while providing 

flexibility for unknown future needs on the landscape. Closing roads in this area is 

extremely difficult because of the flat terrain, which begs the question how will the 

Forest prevent the public from establishing new roads? Especially after the 

management of the project is complete and the landscape is much more open.

Response: Roads to remain closed but remain on the landscape will be barricaded 

as part of our standard specifications in the contract package. It is the operator’s 

responsibility to restrict public access throughout the course of a project. Any 

public use of roads not showing as open on the motor vehicle use maps (MVUM) is 

illegal. If we know that issues are occurring, corrective action can be taken through 

sale administration and law enforcement.

04-08b

63. Concern Statement: On pg. 3-146, it states that the FS plans to install culverts and 

remove them after completion of silvicultural treatments. Please explain why it is 

necessary to remove the culverts? Wouldn't this increase sediment into the riparian 

areas?

Response: Culverts would be installed on ML1 roads, which have previously had 

the culverts removed as part of the process to hydrologically stabilize roads. 

Because ML1 road use is temporary, the culverts would be removed to restore the 

natural drainage patterns. As with any ground disturbing action, sediment may be 

mobilized if it rains enough to dislodge soil particles before ground cover becomes 

established. Effects are disclosed and BMPs are described in Hydrology Report on 

pp. 33, 35 and 53.

05-10

64. Concern Statement: The Forest Service should stipulate that temporary roads and 

currently closed roads in the project area will remain closed to the public 

throughout the length of the project. This should be done because opening of closed 

roads and establishment of temporary roads could increase elk mortality from 

hunting and affect condition of elk due to increase of disturbance during key times 

of the year.

Response: Roads to remain closed but remain on the landscape will be barricaded 

as part of our standard specifications in the contract package. It is the operator’s 

06-02
Final Environmental Impact Statement

Pomeroy Ranger District 381

responsibility to restrict public access throughout the course of a project. Any 

public use of roads not showing as open on the motor vehicle use maps (MVUM) is 

illegal. If we know that issues are occurring, corrective action can be taken through 

sale administration and law enforcement. 

65. Concern Statement: The Forest Service should enforce the road closures described 

in the EIS; it is very important for wildlife management that closed roads remain 

closed to the public during operations. Historically, public access has increased 

dramatically if gates were not in place or were left open during and after operations 

(recent activities on the 42 road for example).

Response: Roads to be closed, but remain on the landscape, will be barricaded as 

part of our standard specifications in the contract package. It is the operator’s 

responsibility to restrict public access throughout the course of a project. Any 

public use of roads not showing as open on the motor vehicle use maps (MVUM) is 

illegal. If we know that issues are occurring, corrective action can be taken through 

sale administration and law enforcement. 

06-10a

66. Concern Statement: The Forest Service should consider the effectiveness of 

proposed road management to provide big game security. With only a single 

seasonal closure (Alternative C), road management to provide big game security 

may have limited effectiveness.

Response: The Umatilla forest has a long standing access management plan that 

resulted in extensive miles of closed roads. Approximately 50 miles of roads have 

already been closed in the project planning area and will remain closed. There may 

be opportunities to increase security with additional road closures, however we 

chose not to propose any with this EIS.

06-14

67. Concern Statement: The Forest Service should close all temporary roads to the 

public at all times, and make closure of the roads a high priority upon completion of 

the harvesting activities (gates at a minimum). Historically, this has been an issue 

with USFS Vegetation Management projects. The public quickly starts using these 

roads and have significant impacts to elk distribution.

Response: Temporary roads will be used for project only. Public access is not 

allowed on non-system or temporary roads. Upon completion of any project, a 

temporary road must be removed from the landscape and made impassable.

06-21

68. Concern Statement: The Forest Service should monitor temporary roads and 

implement control measures when necessary because of the association of new 

temporary roads with increased sedimentation, increased soil compaction and 

displacement, loss of security cover and old forest, and the establishment of 

invasive plant species.

Response: Project design criteria for the protection of soil, water and aquatic 

resources are included as provisions and clauses in the timber sale contract. Timber 

sale contracts are administered by the sale administrator who verifies that all 

provisions and clauses in the contract are completed for Forest Service standards 

before the sale is closed. The project design criteria are disclosed in the DEIS, 

07-12
Sunrise Vegetation and Fuels Project

382 Umatilla National Forest

beginning on pg. 2-39. Effects from new temporary roads are disclosed in DEIS on 

pp. 3-146 to 3-151, pp. 3-164-165, and pg. 3-169.

69. Concern Statement: The Forest Service should remove as much road and older 

road templates from the landscape as possible. Roads should be decommissioned 

and fully re-contoured whenever possible.

Response: Road management for the Sunrise project is described on pg. 2-36 of the 

DEIS. It does not include the decommissioning of existing system roads; such 

action would be beyond the scope of the Sunrise project.

07-13

70. Concern Statement: The Forest Service should include an alternative that does not 

reopen closed roads or build temporary roads. Road-related impacts are among the 

most detrimental to forest health and include negative effects on wildlife, wildlife 

habitats, water quality, and fish. Roads are directly responsible for a suite of 

damaging impacts on Big Game, Wildlife and their habitats, fish and water quality, 

and all of the other emphases for management units within the project. Deviation 

from HRV has not been shown to have nearly the same scale or negative impact on 

ecosystem health as high road density.

Response: Thank you for your input. The range of alternatives chosen for the 

Sunrise project environmental analysis allows for the selection (in a final Record of 

Decision) of an alternative lacking road reopening/road reconstruction. Such an 

alternative would have direct, indirect, and cumulative effects within the scope and 

scale of those analyzed and disclosed in the DEIS.

09-02

71. Concern Statement: The Forest Service should include additional discussion of 

potentially needed changes in road management. For example, we recommend the 

FEIS identify whether any of the roads in the project area are included in the 

Forest's Travel Analysis Report Documents, such as the "Amended List of roads 

likely not needed." https://tinyurl.com/y84j7mxv .

Response: A detailed roads analysis is outside the scope of this document. The 

Sunrise DEIS is consistent with the individual District Travel Management Plans.

10-02

Threatened, Endangered, & Sensitive Species

72. Concern Statement: The Forest Service should ensure viability of Sensitive-listed 

species, species of concern, and other at-risk on the Forest, including: Rocky 

Mountain tailed frog, North American wolverine, Fringed myotis bat, Northern 

goshawk, and neotropical migratory songbirds (particularly Olive-sided 

flycatchers). In addition, we are very concerned about species such as black-backed 

woodpeckers, Lewis' woodpeckers, flammulated owls, bat species, and wolves. We 

are also very concerned about additional Threatened, Endangered, and Sensitive 

Listed species that may occur within or near the project area, including: Canada 

lynx, Preble's shrew, Rocky Mountain bighorn sheep, Townsend's big-eared bat, 

little brown myotis,lald eagles, great grey owls, green-tailed towhees, mountain 

quail. We are particularly concerned about aquatic ESA-listed species in or near the 

project area such as Snake River Basin (SR) steelhead, Bull trout, Snake River 

09-18, 

09-19
Final Environmental Impact Statement

Pomeroy Ranger District 383

Spring/Summer Chinook salmon, and their designated critical habitats and salmon 

essential fish habitat. Other ESA-listed Sensitive species may also be affected, 

including fir pinwheel, Columbia Gorge oregonian, pristine springsnail, humped 

coil, thinlip tightcoil, shiny tightcoil, salmon coil, Great Basin fritillary, Johnson's 

hairstreak, western bumblebee, and others. 

In addition, native ESA-listed plants are present in the project area, and potential 

negative impacts to these plants were not adequately analyzed or avoided. They 

include, as mentioned in the DEIS: "Spalding's catchfly (Silene spaldingii) is 

federally listed as threatened and documented in the project area. Additionally, 

there are five sensitive plant species documented in, or adjacent to, the project area. 

They are Arthur's milkvetch (Astragalus arthurii), green-banded mariposa lily 

(Calochortus macrocarpus var. maculosus), Rollin's biscuit-root (Lomatium 

rollinsii), mountain buttercup (Ranunculus populago), and Idaho gooseberry (Ribes 

oxyacanthoides var. irriguum)." 

Closely associated with our concerns about the above species are our concerns 

about protecting valuable and high quality habitats such as snag and dead wood 

habitat, connectivity (both terrestrial and aquatic), large core habitat blocks such as 

undeveloped lands, Inventoried and uninventoried roadless areas, Potential 

Wilderness Areas, mixed-conifer forests, complex and multi-strata forests, late seral 

and old growth forests, and soil condition to support ecological integrity.

Response: Your concerns are noted.

Botanical resources—Section 3.12 of the DEIS discloses the existing condition of 

sensitive populations and habitats, and analyzes the potential effects from the 

proposed activities to those resources, as does the Botanical Resources report and 

Biological Evaluation for Plants which is available on the project website: 

https://tinyurl.com/y7mboqgh . In areas of occupied Spalding’s catchfly (federally 

listed species) habitat, non-commercial thinning unit boundaries were modified to 

ensure a 100 foot buffer from tree cutting activities. Implementation of either action 

alternative would have no effect to the populations of Spalding’s catchfly in the 

project area. Therefore, consultation with the USFWS is not necessary for this 

project.

Fisheries—Section 3.9 of the DEIS discloses the existing condition of sensitive 

populations and habitats, and analyzes the potential effects from the proposed 

activities to those resources, as does the Fisheries Specialist Report and Biological 

Evaluation which is available on the project website: https://tinyurl.com/y7mboqgh

.

Wildlife—Section 3.8 of the DEIS discloses the existing condition of sensitive 

populations and habitats, and analyzes the potential effects from the proposed 

activities to those resources, as does the Wildlife Specialist Report which is 

available on the project website: https://tinyurl.com/y7mboqgh .

Tribal Role – Treaty Rights

73. Concern Statement: The Forest Service should ensure it’s planning and 

implementation actions are consistent with its obligations to the Nez Perce Tribe.

07-14
Sunrise Vegetation and Fuels Project

384 Umatilla National Forest

Response: Section 1.8 of the DEIS (pg. 1-25) Describes how the Forest Service is 

obligated to consult, cooperate , and coordinate with Indian Tribes in developing 

and planning management decisions regarding resources on National Forest system 

land that may affect tribal rights. Section 1.9 of the DEIS (pg. 1-26) lists the Forest 

Service’s consultation, cooperation and coordination, including the dates of all 

letters, program of work meetings, and field visits that were conducted with the 

Tribe. Additional discussion with the Nez Perce tribe was held after receipt of this 

comment.

Undeveloped Lands

74. Concern Statement: The Forest Service should analyze all lands within the project 

area using the updated FSH Chapter 70 directives or some other methodology that 

that conforms with the Wilderness Act. The PWA analysis for the project used the 

forest plan revision PWA evaluation to determine PWA lands within the project 

area. The forest plan draft 2010 PWA inventory is flawed because the revision team 

used old Forest Service Handbook directives.

Response: The Umatilla National Forest conducted a Potential Wilderness Area 

(PWA) inventory for forest plan revision and updated the inventory in 2010 (2010 

PWAs) consistent with agency policy at that time. Only acres of land inventoried as 

PWA were carried forward into the Forest Plan revision and evaluation process. 

The Forest Plan DEIS was released in 2014 and the 2010 PWA inventory was used 

to evaluate, analyze, and recommend wilderness in alternatives.

The PWAs from the 2010 inventory and 2014 Forest Plan DEIS are considered and 

site specific effects to them analyzed in this Sunrise site-specific project FEIS.

01-03a

75. Concern Statement: The Forest Service should redo the "other undeveloped lands" 

analysis is along with the PWA analysis and the two should be harmonized. Further, 

the methodology and justification for ruling out ML 1 roads should be provided in 

the DEIS or Wilderness, IRA, PWA, and other Undeveloped Lands Report. The 

Forest Service erroneously removed areas within 300 feet of a road and areas 

containing "closed roads" from its undeveloped lands analysis. Lands 300 feet on 

either side of the centerline of all ML 1, 2, 3, 4, and 5 Forest Service roads and open 

County Roads are considered developed by the draft Sunrise EIS due to evidence of 

stumps from firewood cutting and hazard tree removal, dispersed campsites, and 

other activities allowed under the current Forest Plan. However, review of images 

from google earth show that most of the areas adjacent to roads are not developed 

and contain intact undeveloped forests or grasslands. These areas should have been 

looked just like the other undeveloped lands: where the orthophoto did not clearly 

indicate substantially noticeable management conditions should have been verified 

on the ground.

Response: Undeveloped Lands are defined for this project as lands that do not 

contain development such as roads and noticeable past timber harvest and exist 

outside or congressionally designated Wilderness, Inventoried Roadless Areas 

(IRAs) and PWAs. Details of the methodology for determining undeveloped lands 

01-03b
Final Environmental Impact Statement

Pomeroy Ranger District 385

are found in Appendix A: Sunrise Project: Undeveloped Lands Analysis Report, 

available on the project website: https://tinyurl.com/y7mboqgh .

• Indicators used for comparison purposes between alternatives are:

• Intrinsic physical and biological resources (soils, water, wildlife, recreation, 

fisheries, etc.)

• Intrinsic social values (apparent naturalness, solitude, remoteness)

• Change in acres of other undeveloped lands

Section 3.15 of the FEIS provides additional detail on the effects of the proposed 

project on the two largest undeveloped lands polygons (polygon #1- 1,303 acres and 

#2-846 acres).

The 4,527 acres of identified undeveloped lands would continue to not be 

designated potential wilderness area, inventoried roadless area or wilderness area. 

However, none of the activities proposed on undeveloped lands would necessarily 

preclude congress from considering these lands for future wilderness.

76. Concern Statement: The Forest Service should incorporate the best available 

science on roadless forests. Scientific research clearly enumerates the many reasons 

why remaining roadless areas should be protected. 

Response: The Forest Service has a long history of science-based decision making. 

Using the best science provides the responsible official with the knowledge, 

methods, and expert review needed to make an informed decision. The agency has 

taken into account the best available science, and used it to conduct the analysis of 

the Sunrise project. These sources are cited throughout the DEIS and the specialist’s 

reports. The References section of the DEIS (pg. R-1) lists the necessary 

information for the public to find and review these sources, if they so desire. All 

references to new sources of credible, peer-reviewed scientific research provided by 

commenters have been reviewed by specialists to determine if and how they would 

change our analysis of the Sunrise project. Any changes to the FEIS as a result of 

this review are noted in the FEIS.

01-03c

77. Concern Statement: The Forest Service should drop all cutting units in polygons 1 

and 2. Polygon 1 is located in the lower portions of the upper reach of North Fork 

Asotin Creek and a tributary to NF Asotin creek-in Cougar Canyon and is has been 

identified as 1,303 acres but it appears that it is actually be larger. The polygon is 

mostly in the creek bottoms and on forested side slopes that have not been 

previously harvested. Polygon 2 is located in the northeast portion and is comprised 

of grassy ridge tops and stringers of timber on steep side slopes. There has been no 

management in this area. Sunrise Project Wilderness, IRA, PWA, and other 

Undeveloped Lands Report pp. 11-12. 

Response: Thank you for your input. The range of alternatives chosen for the 

Sunrise project environmental analysis allows for the selection (in a final Record of 

Decision) of an alternative including the measures suggested. Such an alternative 

would have direct, indirect, and cumulative effects within the scope and scale of 

those analyzed and disclosed in the DEIS.

01-03d
Sunrise Vegetation and Fuels Project

386 Umatilla National Forest

78. Concern Statement: The Forest Service should consider the environmental 

impacts of the proposed project on all roadless areas including inventoried and noninventoried, as required by NEPA. The agency must analyze the attributes of such 

areas, including water resources, soils, wildlife habitat, and recreation opportunities, 

and discuss the effects of the proposed logging on these attributes. Smith v. U.S. 

Forest Service, 33 F.3d 1072 (9th Cir. 1994); National Audubon Society v. United 

States Forest Service, 46 F.3d 1437 (9th Cir. 1993) Additionally, the agency is 

required to discuss a project's impacts on areas of "sufficient size" for future 

wilderness designation, not just those over 5000 acres in size. Lands Council v. 

Martin 529 F.3d 1219, 1231, citing 16 U.S.C. § 1131(c).

Response: The effects to Inventoried Roadless Areas (IRA’s), Potential Wilderness 

Areas (PWAs), and other Undeveloped Lands are analyzed in section 3.15 of the 

FEIS. This section has been updated to provide additional detail on the effects of 

the proposed project on the two largest undeveloped lands polygons: #1 (1,303 

acres) and #2 (846 acres).

01-12

79. Concern Statement: The Forest Service should clarify why the IRA and PWA 

have different acreages and why 186 acres under Alternative B and 29 acres under

C would be impacted - when it seems road construction or timber harvest will not 

take place in the IRA. 

Response: The PWA/IRA discussion has been updated in section 3.15 of the FEIS 

to clarify the why there are differences in acreages between the Asotin Creek IRA 

and PWA. While the IRA and PWA largely overlap, in some cases the PWA 

boundary extends beyond the IRA boundary and in other cases if it excludes 

portions of the IRA. See Map A-1.

02-06a

80. Concern Statement: The Forest Service should maintain and manage all roadless 

and potential wilderness areas in a manner that does not preclude them for inclusion 

in the National Wilderness Preservation System (NWPS). 

Response: Your opinion is appreciated, as it gives the Responsible Official a 

general sense of various views and beliefs.

02-06b

81. Concern Statement: The Sunrise timber sale will take away more undeveloped 

National Forest acres from the legacy the unborn kids of the future should inherit.

Response: Comment noted. The impacts to undeveloped lands are discussed in the 

EIS.

03-28

82. Concern Statement: The Forest Service should explain how undeveloped lands fit 

into the Forest Plan. What is the direction of the Forest Plan with regards to how 

these lands are to be managed within the landscape? These "undeveloped" lands 

should be managed according to the management area they are under in the Forest 

Plan. Since these lands do not have any special designation in the Forest Service 

Handbook or under the Forest Plan "undeveloped" should not have any special 

connotation or require analysis. 

Response: The public has expressed concerns regarding effects to lands that have 

not yet been developed regardless of whether they are officially recognized as 

05-13a
Final Environmental Impact Statement

Pomeroy Ranger District 387

Wilderness, Inventoried Roadless Area or Potential Wilderness area. As a result, 

undeveloped lands that exist outside of Wilderness, IRAs or PWAs have been 

determined using the methodology descried in section 3.15 of the FEIS and impacts 

to intrinsic values of undeveloped areas were analyzed and disclosed. There are no 

Forest-wide management standards specific to undeveloped lands. All lands, 

including undeveloped lands, are managed consistent with Forest-wide standards 

and guidelines, Forest Plan Management Area Allocations, as well as regional and 

national policy.

83. Concern Statement: The Forest Service should treat undeveloped lands on the 

landscape to address the purpose and need. It is important that these landscapes be 

used for multiple use purposes. Treating these landscapes will also enhance the 

recreational values, such as hunting and gathering on this landscape. 

Response: Comment noted.

05-13b

84. Concern Statement: The Forest Service should include projects beyond the 

Sunrise project area boundary in its analysis of cumulative effects on undeveloped 

lands. The USFS's decision to artificially and narrowly limit the spatial and 

temporal cumulative effects of other projects, which would clearly affect the 

cumulative impacts to undeveloped lands and their ecological benefits, renders the 

USFS's determinations of insignificance of affects to be arbitrary and capricious.

Response: For each resource, including undeveloped lands, the interdisciplinary 

team followed guidance provided by the CEQ and US Forest Service Handbook 

1909.15 to identify spatial and temporal boundaries for discernible cumulative 

effects. In the case of undeveloped lands, the Sunrise project area was determined to 

be the appropriate spatial boundary, and fifty years the appropriate temporal 

boundary for determining cumulative effects to their apparent naturalness, solitude 

and remoteness (section 3.15 of the DEIS). Spatial and temporal boundaries for 

cumulative effects to ecological resources on undeveloped lands are described 

separately in each section of Chapter 3 of the DEIS. 

09-09b

85. Concern Statement: The Forest Service should disclose and adequately analyze 

the many critical functions of Potential Wilderness Areas, inventoried roadless 

areas, and undeveloped lands. The Effects Analysis for PWAs does not consider 

any of these factors and is entirely non-substantive. In addition the Forest Service 

should drop from its proposal logging or road building within Potential Wilderness 

Areas, inventoried roadless areas, and undeveloped lands. They should be left in a 

natural state to serve wildlife needs, headwaters protection, and as reference 

condition landscapes for scientific study, as well as for recreation in a natural 

setting. They represent some of the best and last big blocks of intact, high security 

habitat left for fish species, wide-ranging keystone predators, native ungulates, and 

other wildlife species.

Response: Your opinion is appreciated, as this gives the Responsible Official a 

general sense of the various views and beliefs. The effects to Inventoried Roadless 

Areas (IRA’s), Potential Wilderness Areas (PWAs), and other Undeveloped Lands 

are analyzed in section 3.15 of the FEIS. This section has been updated to provide 

09-33, 

09-35, 

09-31, 

09-26 
Sunrise Vegetation and Fuels Project

388 Umatilla National Forest

additional detail on the effects of the proposed project on the two largest 

undeveloped lands polygons: #1 (1,303 acres) and #2 (846 acres). 

Undeveloped Lands are defined for this project as lands that do not contain 

development such as roads and noticeable past timber harvest and exist outside 

congressionally designated Wilderness, Inventoried Roadless Areas (IRAs) and 

PWAs. Details of the methodology for determining undeveloped lands are found in 

the Undeveloped Lands Analysis Report for the Sunrise project. 

Indicators used for comparison purposes between alternatives are:

• Intrinsic physical and biological resources—(soils, water, wildlife, recreation, 

fisheries, etc.

• Intrinsic social values—apparent naturalness, solitude, and remoteness.

• Change in acres of other undeveloped lands

Vegetation

86. Concern Statement. The Forest Service should incorporate the research cited by 

the commenter in the effects analysis because there is substantial scientific evidence 

that thinning in the moist and cold forests can increase the risk of wildfire, and 

logging can exacerbate fire risk by removing fire-resistant trees, putting more fine 

fuels on the ground, and increasing fuel loading by spring the rapid growth of small 

shrubs and trees. There is also evidence that fires may burn more severely in early 

seral vegetation and burn less severely in closed canopy forests.

Response: The Forest Service has a long history of science-based decision making. 

Using the best science provides the responsible official with the knowledge, 

methods, and expert review needed to make an informed decision. The agency has 

taken into account the best available science, and used it to conduct the analysis of 

the Sunrise project. These sources are cited throughout the DEIS and the specialist’s 

reports. The References section of the DEIS (pg. R-1) lists the necessary 

information for the public to find and review these sources, if they so desire. All 

references to new sources of credible, peer-reviewed scientific research provided by 

commenters have been reviewed by specialists to determine if and how they would 

change our analysis of the Sunrise project. Any changes to the FEIS as a result of 

this review are noted in the FEIS.

01-06a

87. Concern Statement: The Forest Service should drop harvest units in moist forests 

especially in areas where they overlap with undeveloped lands or where there is a 

need to construct a temporary road segments to reach them.

Response: The range of alternatives chosen for the Sunrise project environmental 

analysis allows for the selection (in a final Record of Decision) of an alternative 

including the measures suggested. Such an alternative would have direct, indirect, 

and cumulative effects within the scope and scale of those analyzed and disclosed in 

the DEIS.

01-06b

88. Comment: The Forest Service should focus project activities on supporting forest 

resiliency to future conditions, rather than restoring HRV. It should also take a hard 

01-07
Final Environmental Impact Statement

Pomeroy Ranger District 389

look at the literature cited in this comment and incorporated it into the effects 

analysis of the proposed activities.

Response: The Sunrise project is not designed to emulate historical ranges of 

variation per se, but also to develop patterns of forest density, species composition, 

and structure that are better adapted to current and anticipated future climatic 

conditions. This involves increasing the amount of resources available to individual 

trees by reducing the extent of high-density stands; by promoting drought-tolerant 

and disease-resistant species better adapted to a warmer, drier climate; by reducing 

(not eliminating) the extent of multi-strata structural conditions so that grand fir and 

Douglas-fir mature forests (mentioned in this comment) are less susceptible to 

mistletoe, bark beetle, and defoliation-related damage and mortality; by reducing 

the amount of down fuel in some locations so that planned and unplanned wildfires 

do not permanently impair soil productivity or biological diversity. 

With respect to mature forests, tree-cutting activities in the Sunrise project are 

designed to generally promote the development of mature forests by conducting 

intermediate treatments where activities would accelerate the development of 

mature forests, or increase the likelihood of mature forests developing by reducing 

the likelihood of disturbances killing medium-size to large, old trees. In other 

locations where existing species composition is not expected to allow the 

development of a mature forest (such as subalpine fir-dominated stands affected by 

the balsam wooly adelgid--a impactful, nonnative insect with no local resistance or 

predators), regeneration cutting methods would be used to promote relatively 

resistant, vigorous species capable of developing (or developing more quickly than 

would occur under no-action) into a future mature forest.

The Sunrise project action alternatives are designed to promote structural 

heterogeneity at a watershed scale by providing a less skewed and more balanced 

distribution of possible structural stages and density classes. They give attention 

and priority to the retention of large, old trees, particularly because they are 

consistent with Scenario A and related provisions of the Eastside Screens (DEIS 

section 3.21).

The fact that multi-strata forests may be at elevated risk to high-severity disturbance 

does not automatically render them desirable relative to single-stratum forests, or 

suitably distributed with other structural stages on the landscape. The desired 

distribution of structural stages is utilized because it better allows for a full 

complement of habitats and spatial diversity of landscape-scale disturbance effects.

All references to new sources of credible, peer-reviewed scientific research 

provided by commenters have been reviewed by specialists to determine if and how 

they would change our analysis of the Sunrise project. Any changes to the FEIS as a 

result of this review are noted in the FEIS.

89. Concern Statement: The Forest Service should take a hard look at the full 

spectrum of effects of converting OFMS to OFSS, because there is a high level of 

uncertainty with respect to the long-term ecological consequences of the Forest 

Service's strategy of converting old forest multi-story (OFMS) to old forest single 

story (OFSS). And the commenter remains unconvinced that converting OFMS 

forest to OFSS stands is the appropriate solution, particularly when deficiencies 

01-08
Sunrise Vegetation and Fuels Project

390 Umatilla National Forest

exist in both forest types and the latter is simply more severe. This logic is akin to 

"robbing Peter to pay Paul." 

Response: The Sunrise action alternatives do not presume that over the long-term, 

the only pathway to promoting and expanding the extent of OFSS is a conversion 

from OFMS; however, it certainly is in the near-term, because it is impossible to 

quickly render a young forest into an old one. Over longer time scales, abundant, 

reasonable, and sufficient empirical evidence supports the assumption that 

silvicultural activities have and will likely continue to increase the rate and 

probability of young forests developing into mature forests. The project includes 

cutting methods and prescribed burning in a variety of stands in stem exclusion and 

understory re-initiation structural stages in order to accelerate and/or increase the 

likelihood of old forest development by making additional light, water, and nutrient 

resources available to residual trees. This effect is noted on pg. 3-59 of the DEIS 

but additional clarification is provided section 2.3 of the FEIS). Uncertainties 

regarding these assumptions are described in the silviculture resource report 

included in the project file, and were added to section 3.6 of the FEIS.

The Sunrise project analysis indicates that with respect to OFMS, a deficiency of 

this structural stage does not, in fact, exist for dry, moist, and old upland forests in 

the vegetation analysis area. 

It is not clear what constitutes a “full spectrum” of effects with respect to converting 

OFMS stands to OFSS, but information was added to the FEIS in section 3.6 to 

provide additional clarification that many activities/locations of the action 

alternatives will include the direct-effects conversion of OFMS from OFSS from 

mixed-severity burning, and indirect effects of converting UR and SE stands to 

OFMS over mid and long-term time scales, and the reconversion of OFSS 

immediately post-decision to OFMS over time as a result of mixed-severity 

disturbances. Although the overall effect of the project is expected to be an increase 

in OFSS in the near-term, such a transition is not expected to occur in all locations 

over all times.

90. Concern Statement: The Forest Service should explain how the areas for logging 

were selected and project prescriptions designed. We also request an explanation of 

how these areas and treatments are the appropriate ones for restoring these forests. 

The project would include mechanical tree cutting activities across approximately 

7,790 acres under Alternative B and 4,800 acres under Alternative C. Sunrise 

Silviculture Report pg. 23. For Alternative B includes this includes 5,520 acres of 

commercial logging including 2130 acres of regeneration cutting and over 3000 

acres of old forest conversion from OFMS to OFSS. For Alternative C this includes 

2,550 acres of commercial logging including 940 acres of regeneration harvest and 

880 acres of old forest conversion. These seems like prescriptions designed to 

maximize the extraction of commercial forest products instead of improving forest 

health and resiliency—which is the main stated goal for this project.

Response: Some of the acres converted from OFMS to OFSS under Alternatives B 

and/or C are expected to do so as a result of landscape prescribed fire.

Units including tree-cutting activities under Alternatives B and/or C were delineated 

and/or selected as part of an interdisciplinary deliberative process balancing 

competing or complimentary objectives primarily pertaining to: aquatic and 

01-09
Final Environmental Impact Statement

Pomeroy Ranger District 391

terrestrial habitat; water quality and quantity; vegetation composition, structure, and 

density; Roadless Area characteristics, and financial and/or operational viability. 

Unit locations were selected to avoid all Riparian Habitat Conservation Areas 

(RHCAs) and Inventoried Roadless Areas. Excluding RHCAs from tree-cutting 

activities as “skips” met an additional objective to maintain existing OFMS 

structural stages in many areas. Additional areas were excluded from tree-cutting 

activities in order to preserve high-density forests and maintain terrestrial wildlife 

habitat—to a greater extent under Alternative C than Alternative B. Areas included 

for tree-cutting activities under Alternatives B or C were included in order to 

provide forest products and move the analysis area closer to desired conditions for 

vegetation fuel loading, composition, structure, and/or density. 

Silvicultural prescriptions for tree-cutting, prescribed burning, fuels treatment, and 

tree-planting were designed for reasons and in a manner described in the DEIS in 

section 2.3. Landscape burn units were located in areas with a moderate or high 

degree of departure from conditions characteristic of the natural fire regime, taking 

into consideration logistical considerations pertaining to ignition patterns, fire 

containment and personnel safety. 

The term “restoration” as used in this comment is not well-defined, making it 

difficult to provide a precise response. The Sunrise Vegetation and Fuels project 

uses the term “management” in the project title in order to avoid confusion or 

ambiguity over what precisely constitutes forest “restoration.” Not all areas and 

treatments described in the DEIS were designed to perfectly re-create all presettlement or pre-anthropogenic conditions and/or processes in all locations. As 

described in the DEIS, the treatments are designed to promote desired vegetation 

and fuels conditions; maintain desired levels of wildlife habitat over a variety of 

time scales; avoid, minimize, and/or mitigate for adverse effects, and provide forest 

products for local and regional use. 

The areas and activities are considered appropriate for meeting the project purpose 

and need because they are consistent with direction provided by the Forest Plan, reintroduce or approximate (if imperfectly) native ecosystem processes, and have 

outcomes that are generally predictable, acceptable, describable, and measurable. 

The activities are logistically and financially feasible, sufficiently safe, and are 

widely utilized to meet the types of objectives described in the DEIS. Tree-cutting 

and removal activities are the only known means of providing timber products—

one component of the project purpose and need.

91. Concern Statement: The Forest Service should provide a detailed explanation of 

how the landscape evaluation was applied as a diagnostic tool for this project, 

because we are very concerned that the prescriptions may not be appropriate for this 

watershed, and contribute to future problems. 

Specifically, we ask that you detail how the landscape assessment was used to 

develop the following in succession: Landscape Prescriptions, Potential Treatment 

Areas, Unit Boundaries and subsequently the Unit Prescriptions. If the procedure 

deviated from the appropriate usage of landscape evaluations, we ask that you 

include a description as to why as well as an in-person meeting to discuss the 

matter.

02-01
Sunrise Vegetation and Fuels Project

392 Umatilla National Forest

Response: It is not clear what is meant by the terms “appropriate” and “future 

problems” as used in this comment. The Forest Service considers the prescriptions 

appropriate for the watershed because they respond to and/or are consistent with 

direction provided in the Forest Plan for the applicable watershed, forest types, and 

Management Areas (section 3.21 of the DEIS). 

Unit locations were selected for analysis using a process described in our response 

to comment No.90. 

Large-scale patterns of vegetation structure and composition were considered in a 

manner described in section 3.6 of the DEIS. 

Patterns and processes of forest disturbance, tree regeneration, structure, density, 

and composition discussed in Churchill et al. (2013a, 2013b) were considered and 

incorporated into the project in the analysis of effects resulting from activities 

described in Chapter 2.

Expected and desired outcomes were considered and re-considered in light of 

insights provided by Churchill et al. Final prescriptions and objectives developed to 

implement the project would be informed by ICO concepts, if not implemented 

using the formal ICO methodology itself.

A watershed-scale assessment was used to develop the following items mentioned 

in the comment: 

• Landscape Prescriptions: Existing conditions, desired conditions, and 

watershed-scale prescription elements are described in sections 1.3 and 1.4 of 

the DEIS, as well as section 3.6. 

• Potential Treatment Areas were identified using a process discussed in response 

to comment No. 90.

• Unit Boundaries were identified using a process discussed in response to 

comment No.90, as well as on-the-ground reconnaissance, analysis of aerial 

imagery and topography in a geographic information system (GIS). Boundaries 

were also delineated using vegetation classification standards on file at the 

Walla Walla Ranger District (Powell 2014d, cited in DEIS) and methodology 

described in Justice (2016, cited in DEIS). 

Additional information pertaining to uncertainty associated with the vegetation 

assessment and analysis methodology is presented in section 3.6 of the FEIS. 

Unit prescriptions were developed using a diagnosis and prescription methods 

described in Forest Service Manual 2470 (Silvicultural Practices) and Forest 

Service Handbook 2409.17 (Silvicultural Practices), Chapter 8 (Silvicultural 

Examinations, Prescriptions, and Evaluations), as well as Chapter 8 Regional 

Supplement R6/PNW Supplement No.: 2409.17-2011-2. In addition, the procedure 

for development of single-stand or multi-stand tree-cutting and landscape burning 

activities is described in Section 2.3 of the DEIS. This procedure is considered an 

appropriate usage of landscape evaluation because it follows direction provided by 

the Ecosystem Standard of the Eastside Screens Forest Plan Amendment (DEIS 

Appendix C) direction provided by Powell (2014b, cited in DEIS) and Martin 

(2010, cited in DEIS).

92. Concern Statement: The Forest Service should consider using the Individuals, 

Clumps, and Openings (ICO) approach (Larson & Churchill 2012) for silvicultural 

02-02
Final Environmental Impact Statement

Pomeroy Ranger District 393

prescriptions, because we believe it would better achieve the objectives of 

restoration, while increasing heterogeneity and increasing protection for many 

species of wildlife.

Response: The ICO approach was considered during development of the Sunrise 

action alternatives, and outcomes characteristic of the ICO approach are expected 

for spatial pattern of tree retention and regeneration in many locations. Such 

locations include areas receiving improvement, liberation, single-tree selection, 

group-selection, and irregular shelterwood tree-cutting activities, as well as 

landscape prescribed burning. 

Tree-cutting prescriptions will generally utilize species, vigor, or size-based 

designations. Professional experience in similar stands indicates that such 

designations tend to result more variable spacing than seed-tree regeneration, 

clearcutting regeneration, or intermediate cutting with wide (>20’) inter-tree 

spacing. Professional experience also leads to the expectation that prescribed 

burning at large scales would result in highly variable tree mortality and retention, 

creating a diverse mosaic of within-stand patterns consistent with objectives 

described in Larson and Churchill (2012) and Hessburg et al. (2015). Retention of 

no-cut patches (“skips”) for purposes of RHCA, cultural heritage, visual, or other 

resource protection has the added effect of further contributing to intra-stand and 

within-stand heterogeneity. 

Variable-density regeneration and intermediate silvicultural treatments best achieve 

management objectives for many stands in the project area; and cutting or burning 

methods broadly consistent with the ICO approach would be applied to the large 

majority of acres in the Sunrise action alternatives. The proportion of the project 

area where clearcutting methods may be considered the only available method to 

achieve stand objectives is expected to be negligible. 

93. Concern Statement: The Forest Service should analyze insect & disease 

disturbances through the landscape evaluation process for this project. In the 

landscape evaluation process, the levels of insect and disease disturbances on the 

landscape are compared to the historical range of variability.

Response: A landscape analysis of insect and disease infestation relative to the 

historic range of variability of insect and disease infestation was not conducted. In 

an effort to move vegetation towards a desired future condition though 

implementation opportunities, our agency specialists in these areas conducted field 

surveys and provided recommendations (see Forest Health Protection Blue 

Mountains Forest Insect and Disease Service Center report dated June 1, 2015--an 

appendix to the Sunrise Silviculture Report, available on the project website: 

https://tinyurl.com/y7mboqgh . As part of the project file, we included their detailed 

field inspections and analysis of representative units portraying various vegetation 

types and recommendations to implement that would allow those stands to meet the 

purpose and need statement relative to healthy resilient forests.

02-07

94. Concern Statement: The Forest Service should present monitoring data showing 

there is a shortage of vigorous trees in the sale area. And it should present data 

showing why and how increasing the percentage of vigorous trees will enhance the 

03-05
Sunrise Vegetation and Fuels Project

394 Umatilla National Forest

health of the countless natural resources in the area. A man-made forest will never 

contain natural biodiversity.

Response: On pg. 3-52 of the DEIS, the methodology discussion references the 

project silviculture report, which discusses that aerial photo imagery and on-theground surveys were used to assess forest vegetation conditions, including live/dead 

tree status, tree condition and growth rates, and insect/disease damage.

Additional information pertaining to uncertainty associated with the vegetation 

assessment and analysis methodology is presented in section 3.6 of the FEIS.

95. Concern Statement: The Forest Service should tell the public why spending their 

tax money to take action to create fast growing, vigorous trees is more important 

than letting the trees grow at their own rate which provides biodiversity. Also, 

identify the flora and fauna in the forest that thrive in decadent slow-growing forest 

conditions and how these species will be harmed in Chapter 3.

Response: The 1990 Umatilla Land and Resource Management Plan includes a 

number of goals, conditions, management objectives, and Forest-wide standards and 

guidelines that call for the maintenance and provision of healthy, productive trees in 

many locations. Allowances are made in the Forest Plan for expected levels of 

disturbances and succession that provide for mature, slower-growing (“decadent”) 

forests as well. The consistency of activities included in Alternatives B and C with 

Forest Plan is discussed in section 3.21 of the DEIS.

03-06

96. Concern Statement: The Forest Service should acknowledge that there are 

alternatives to clearcuts. Regeneration success should not dictate anything. Even 

though shelterwood is not the optimum regeneration method, it will be more 

pleasing to the public and still comply with NFMA's reforestation requirement.

Reply: If a silvicultural cutting method is deemed appropriate to meet management 

objectives and is compatible with existing stand conditions, it would be preferred 

over a clearcutting method, and selected. This is disclosed on pg. 3-229 of the 

DEIS.

03-07

97. Concern Statement: The Forest Service should eliminate all proposed clearcut 

units, use a partial cut RX, and consider restoring the area to what it was before it 

was logged by planting the same on-site species.

Response: Your opinion is appreciated, as it gives the Responsible Official a 

general sense of various views and beliefs. 

03-09

98. Concern Statement: The Forest Service should provide data and text 

demonstrating that soil, slope, or other watershed conditions will not be irreversibly 

damaged by seedtree and sheltewood silvicultural prescriptions.

Response: Direct, indirect and cumulative effects to soil productivity, slope 

stability and watershed conditions are disclosed in the DEIS, pg. 3-135 to 3-173; 

and in detail in the hydrology and soils reports available on the project website: 

https://tinyurl.com/y7mboqgh .

03-10
Final Environmental Impact Statement

Pomeroy Ranger District 395

99. Concern Statement: The Forest Service should provide data and text 

demonstrating that seedtree and shelterwood silvicultural prescriptions are 

appropriate to meet the objectives and requirements of the relevant land 

management plan.

Response: The Forest Plan lists cutting methods considered appropriate for 

Management Areas included in the Sunrise project. As described on pg. 3-223 of 

the DEIS, all prescribed cutting methods would be consistent with the Forest Plan 

because they are incorporated by reference into the design criteria of the project. 

03-11

100. Concern Statement: The Forest Service should Tell the public which resource(s) 

in the sale area are unhealthy and (using independent science) explain how logging 

and road construction creates conditions where these same resources are functioning 

properly again after the area is "treated." And the Forest Service should provide 

honest, believable, science based examples of how your timber sale "treatments" 

will deliver public "values and services like clean air and water, scenic beauty, 

habitat for wildlife, and opportunities for outdoor recreation" in and downstream 

from the sale area.

Response: The term “unhealthy” is not clearly defined in this comment, so a 

precise response is not possible, nor is it feasible to describe which resources would 

apply.

Chapter 3 (Environmental Consequences) describes existing and future (postimplementation) conditions for the listed natural resources and other aspects of the 

environment.

03-14

101. Concern Statement: The Forest Service should allow removal of trees greater than 

21-inches in diameter, because it is imperative that the seed source be removed 

from the overstory to effectively promote early seral species.

Response: Removing the seed source of undesirable species enhances the long-term 

effectiveness of promoting desired species, but we do not agree that it is imperative 

to remove the entire seed source of undesired species. The effectiveness of 

promoting early seral species is related to a number of factors (including seed 

source, and/or artificial regeneration); all were considered in the development and 

analysis of the action alternatives.

04-03

102. Concern Statement: The Forest Service should look for ways to maximize 

treatment where it is proposed and to avoid deferring units or setting aside portions 

of units for what is often referred to as "skips." Skips within these watersheds are 

plentiful, what is not plentiful are openings. The individual, clumps and openings 

(ICOs) will develop naturally in a relatively short amount of time without the "over 

engineering" that is currently taking place with extremely complex marking guides.

Response: The need for action arose from an evaluation by an interdisciplinary 

team of Forest Service specialists of the differences between existing and desired 

conditions within the Sunrise project area. Desired conditions are defined by the 

Umatilla Forest Land and Resource Management Plan’s Forest-wide and 

management area goals. (See section 1.5, Management Direction, on pg. 1-17 of the 

DEIS.) The Sunrise project is intended to accomplish the Forest Plan’s diverse 

goals and objectives, and provide a resilient array of forest types with well04-04
Sunrise Vegetation and Fuels Project

396 Umatilla National Forest

distributed characteristics of species cover type, structural stages, and density 

classes.

103. Concern Statement: The Forest Service should consider proactive management in 

riparian reserves/riparian conservation areas, because the overstocked and uniform 

stand characteristics that exist in the uplands also exist in the riparian areas. It has 

been well documented that thinning in riparian areas accelerates the stand's 

trajectory to produce large conifer trees and has minimal effect on stream 

temperature with adequate buffers. Removal of small diameter suppressed trees has 

an insignificant short-term effect on down wood, and ultimately a positive effect on 

long-term creation of large down woody debris and large in stream wood, which is 

what provides the real benefit to wildlife and stream health. 

In addition, the Forest Service should treat riparian areas, because leaving these 

areas overstocked and treating the upland acres would seem to disconnect the 

function of the riparian areas from that of the upland forests.

Response: The Umatilla Forest Plan, as amended, includes guidelines that we 

utilize when implementing projects relative to Riparian Habitat Conservation Areas 

(RHCAs). Embedded in those guidelines are Project Design Criteria (PDCs) that 

allow us flexibility in implementing projects around RHCAs–but not within them. 

As more information becomes available related to activities and effects in RHCAs, 

the opportunity to treat them may become more viable in the future.

Concern Statement: The Forest Service should treat riparian areas, because 

leaving these areas overstocked and treating the upland acres would seem to 

disconnect the function of the riparian areas from that of the upland forests.

Response: The Umatilla Forest Plan, as amended, includes guidelines that we 

utilize when implementing projects relative to Riparian Habitat Conservation Areas 

(RHCAs). Embedded in those guidelines are Project Design Criteria (PDCs) that 

allow us flexibility in implementing projects around RHCAs–but not within them. 

As more information becomes available related to activities and effects in RHCAs, 

the opportunity to treat them may become more viable in the future.

04-09, 

05-03

104. Concern Statement: The Forest Service should disclose the effects of reducing 

density and changing the species composition have on the function of the areas that 

are receiving no treatment (such as the Inventoried Roadless Areas). It would 

appear that there will be less likelihood of an insect and disease epidemic as well as 

the ability to better manage in the project area.

Response: Susceptibility of forest vegetation to insect and disease disturbances 

and/or damage is included in the Sunrise DEIS in section 3.6. 

2,500 acres of landscape burning in the Sunrise Planning area are proposed for in 

the Asotin Creek Inventoried Roadless area. Another 8,000 acres of burning is 

scheduled to occur in the Asotin Creek Inventoried Roadless Area under the Asotin 

Creek Prescribed Fire Project CE which is in Cumulative Effects section of the 

Sunrise DEIS. Effects are also analyzed in DEIS. Effects in untreated areas would 

have same effects as No Action as described in the DEIS.

05-01b
Final Environmental Impact Statement

Pomeroy Ranger District 397

105. Concern Statement: The Forest Service should explain the differences in 

susceptibility to future insect and disease disturbance between the two alternatives, 

because it is important that we understand whether one alternative will have a 

greater effect on the reduction in susceptibility than the other.

Response: A discussion about differences in susceptibility to future insect and 

disease disturbance between the two alternatives has been added to Section 3.6 of 

the FEIS.

05-04

106. Concern Statement: The Forest Service should better explain the difference in 

cumulative effects between Alternative B and Alternative C in DEIS section 3.6, 

Vegetation Management. Alternative C calls for approximately one-half of the 

management of Alternative B, therefore it would appear that there would be 

different cumulative effects. Specifically, under Alternative C the landscape would 

accumulate fuels at a higher rate; and the amount of late seral species and structures 

would not be reduced to the degree necessary to effect change.

Response: Information has been added to section 3.2 (Effects and Impacts) and 

3.26 (Cumulative Impacts) of the FEIS.

05-06

107. Concern Statement: The current scale and pace of commercial logging on the Blue 

Mountains Forests is completely unsustainable and will inevitably harm many other 

forest values that require protection.

Response: Your opinion is appreciated, as it gives the Responsible Official a 

general sense of various views and beliefs. It is, however, beyond the scope and 

scale of the Sunrise project. Your concerns are better suited to the scope and scale 

of:

• Blue Mountains Forest Resiliency Project https://tinyurl.com/y7br2s6a .

• Revised Blue Mountains Forest Plans https://tinyurl.com/yd86sgf5 .

09-05

108. Concern Statement: The Forest Service should explain how commercial size tree 

logging would achieve the stated desired conditions and meet the purpose and need; 

there is no proof that logging reduces stand replacing wildfire or enhances control 

of insects and disease. 

Response: Past forestry practices and regeneration techniques were originally 

developed as part of classic silvicultural systems that were primarily concerned with 

producing and harvesting mature crops of timber products. Modern approaches to 

forest management now view timber harvest and other silvicultural techniques also 

as restoration tools that can be used to modify stand structures, species composition, 

stand density, landscape patterns and potential fire behavior. This approach is 

sometimes referred to as “ecological forestry,” or “emulation of natural 

disturbance,” as it attempts to fully incorporate an understanding of natural 

disturbance and stand development processes. This concept of using forest 

management to emulate natural disturbance has been discussed within a growing 

body of science literature and is often recommended as a technique to help restore 

resilient forest conditions. 

Removal of commercial-size trees would, in part, meet the aspect of the project 

purpose and need that includes the provision of timber products (DEIS pg. 1-16). 

09-08
Sunrise Vegetation and Fuels Project

398 Umatilla National Forest

Removal of commercial-size trees also contributes to meeting aspects of the project 

purpose and need relating to the alteration of forest vegetation composition, 

structure, and density, as described on pg. 1-16 of the DEIS. Evidence for this is 

presented in the analysis beginning on pg. 3-55, with additional literature citations 

provided in the silviculture resource report on file. Anticipated silvicultural 

treatments will generally be prescribed to maintain, regenerate, or enhance the vigor 

of large, fire-resistant trees. 

Expected effects of analyzed activities on susceptibility to insect and disease 

damage is disclosed in section 3.6 of the DEIS. In general, the premise that 

increasing resources available to trees increases individual tree physiological vigor 

and thus tree resistance to insect and disease disturbances is supported by a 

substantial body of empirical observations, professional judgement, and scientific 

research. (In-text citations of Forest Service technical documents were added to 

section 3.6 of the FEIS). Similarly, the citations support the conclusion that 

silvicultural activities can alter stand susceptibility to insect or disease disturbances 

when activities convert areas from tree species susceptible to certain types or 

species of damage agents, to species that are not. And once again, the citations 

support the conclusion that silvicultural activities can alter stand susceptibility to 

insect or disease disturbances when activities that covert structural conditions from 

those susceptible to attack (e.g., multi-layered canopies for defoliators) to 

conditions that are less so (single-layer canopies). 

Expected effects of analyzed activities on potential fire behavior is disclosed in 

section 3.7 of the DEIS. Generally the analyzed activities would retain fire-resistant 

trees; such trees would generally be protected, promoted, and enhanced as a result 

of the project. Commercial harvest and subsequent fuels treatments would greatly 

reduce the crown fire hazard by decreasing stem and crown densities, and reducing 

surface fuel loadings. Ladder fuels are greatly reduced through timber harvest and 

non-commercial thinning.

Impacts to soils are disclosed in section 3.11 of the DEIS.

109. Concern Statement: The Forest Service should provide the site-specific evidence, 

adequate analysis, or best science needed to support any supposed ecological 

benefit from the logging proposed in the Sunrise project.

Response: Direct, indirect, and cumulative effects of analyzed activities on forest 

vegetation resources are described in section 3.6 of the DEIS.

09-12b

110. Concern Statement: The Forest Service should not convert moist old forest multi 

strata to single strata forests; particularly as the project area clearly supports moist, 

productive, dense, and multi-strata forests naturally. 

Response: Your opinion is appreciated, as it gives the Responsible Official a 

general sense of various views and beliefs. Action is needed to improve forest 

health, vigor and resilience by moving stands toward their historical conditions for 

species composition, structural diversity, stand density and fuel loadings. (See pg. 

1-16 of the DEIS, Section 1.4, Vegetation.) 

09-13a
Final Environmental Impact Statement

Pomeroy Ranger District 399

111. Concern Statement: The Forest Service should include representations of 

maximum and minimum event ranges in its analysis surround the range of historical 

conditions. 

Response: As stated in the DEIS on pg. i: “HRV uses a range of reference 

conditions pertaining to the previous several centuries prior to the pre-settlement 

era...” Because it allows for a recognition that ecosystems are complex and 

experience a range of conditions across which processes are resilient and selfsustaining, this is considered a reasonable, appropriate scale of time to be using for 

the Sunrise project given recent, present, and anticipated near-future conditions.

09-14

112. Concern Statement: The Forest Service’s assessment of current forested species 

composition and degree of departure from historic forested species composition 

relies on inaccurate science and represents a failure to use professional integrity. 

The reliance on coarse-scale Potential Vegetation Group classification to assess 

historic conditions and determine departure in current stands represents a failure of 

professional integrity to use best management practices. Coarse-scale filters fail to 

account for the effects of landform and topographic impacts, soil, and regional 

gradients on site productivity, and result in misclassification of stands and improper 

assessment of current conditions and management needs. Failing to discriminate 

between early-seral stands dominated by shade-intolerant species, and late-seral 

stands that include mixtures of long-lived shade-intolerant species with shadetolerant species, and the differences in successional pathways and potential climax 

conditions that exist between different PVGs, will produce homogenized targets for 

species assemblages and shade tolerance classes.

Response: The Potential Vegetation Group classification contained in the project 

vegetation database includes landform and topographic considerations, and soilrelated gradients on site productivity. The vegetation database was derived from a 

wide variety of sources, including stand examinations, geographic information 

systems, aerial photo interpretation, and professional on-the-ground validation. 

Misclassification of stands and imperfect assessment of current conditions is 

possible, and possible error sources are discussed in the project silviculture report, 

which is referenced in the DEIS discussion of methodology in the section 3.6. 

Risks are considered minimal in terms of failing to discriminate between early-seral 

stands dominated by shade-intolerant species, and late-seral stands that include 

mixtures of long-lived shade-intolerant species with shade-tolerant species, and the 

differences in successional pathways and potential climax conditions that exist 

between different PVGs. All tree-cutting activities would be directed by stand 

diagnosis and certified prescriptions based on assessments made in the field in 

combination with other sources of data. Landscape prescribed fire treatments are 

not expected to generally favor fire-tolerant and fire-adapted species, but not 

produce “homogenized targets for species assemblages and shade tolerance classes” 

because ignition patterns and effects are expected to vary within units due to local 

weather, fuels, and topographical conditions. 

09-17

113. Concern Statement: The Forest Service should take into consideration that large 

trees are essential for wildlife habitat for numerous species, regardless of the age of 

trees. The USFS categorizes trees less than 150 years old are "young", and argues 

that they do not have to adhere to current Forest Plan prohibitions on logging large 

09-42b
Sunrise Vegetation and Fuels Project

400 Umatilla National Forest

trees if they are "young". To determine if large trees are less than 150 years old, the 

USFS uses the Van Pelt guidelines. However, the Van Pelt guidelines are wholly 

inadequate for determining the age of Grand fir, as they do not contain guidance 

that can be used in the field to reliably identify Grand fir older than 150 years. It is 

large trees that are necessary for wildlife habitat, and those are in extreme deficit 

across the region due to logging— regardless of age.

Response: The DEIS does not categorize trees less than 150 years old as “young.” 

Van Pelt (2008) is listed in the Sunrise bibliography, but this citation should not be 

interpreted as an indication that only grand fir trees >150 years of age would be 

considered “old” for existing conditions and activity effects analysis. Trees larger 

than 21” in diameter will be retained regardless of estimated age, in accordance 

with the Forest Plan as amended.

114. Concern Statement: The Forest Service should consider retaining large old trees 

occurring within the proposed harvest units to provide structure to the forest 

landscape and an anchor point for establishing species and spatial heterogeneity. 

Widely distributed large, old trees provide a critical backbone to dry pine and dry to 

mesic mixed- conifer forest landscapes. Although there will be variation in terms of 

retention across the landscape, a broad body of science supports the notion that presettlement density of trees in mixed-conifer patches was frequently 50 to 100 trees 

per hectare (20 to 40 trees per acre).

Regarding the need to introduce spatial heterogeneity at multiple scales, from 

ecoregion to tree neighborhood scales, the following reference provides seven core 

principles to consider.

Hessburg, Paul F.; Churchill, Derek J.; Larson, Andrew J.; Haugo, Ryan D.; Miller, 

Carol; Spies, Thomas A.; North, Malcolm P.; Povak, Nicholas A.; Belote, R. 

Travis; Singleton, Peter H.; Gaines, William L.; Keane, Robert E.; Aplet, Gregory 

H.; Stephens, Scott L.; Morgan, Penelope; Bisson, Peter A.; Rieman, Bruce E.; 

Salter, R. Brion; Reeves, Gordon H. 2015. Restoring fire- prone Inland Pacific 

landscapes: seven core principles. Landscape Ecology. 30(10): 1805-1835

Response: The Forest Service considered retaining large old trees occurring within 

the proposed harvest units by planning the project under Scenario A of the Eastside 

Screens Forest Plan Amendment (Appendix C of the DEIS). As part of this 

scenario, no trees with stems >21 inches in diameter at breast height would be 

harvested, and units within or surrounded by old forests would be treated in such a 

manner as to promote or accelerate the development of old forest characteristics 

(including large trees) over time. 

The Hessburg et al. paper cited above is a condensed version of a detailed 

assessment and set of recommendations provided by Stine et al., which was 

considered in the DEIS and a bibliographic citation is listed on pg. R-14.

10-01a

115. Concern Statement: The Forest Service should carefully consider where the 

“Individuals, Clumps and Openings” or ICO approach can and should be applied to 

establish individual openings. In general, this approach recommends a mix of 

openings ranging from less than half an acre to an acre. 

10-01b
Final Environmental Impact Statement

Pomeroy Ranger District 401

The Forest Service should consider the following available tools and approaches for 

incorporating spatial reference patterns into silvicultural prescriptions, including the 

application of the ICO approach across the harvest units.

• Churchill, D.J., A.J. Larson, S.M.A. Jeronimo, P.W. Fischer M.C. Dalhgreen, 

and J.F. Franklin. 2016. The ICO approach to quantifying and restoring forest 

spatial pattern: Implementation guide. Version 3.3 Stewardship Forestry and 

Science, Vashon, Washington, USA. Available at: https://tinyurl.com/yc7dxl8u

.

• Churchill, D.J., A.J. Larson, S.M.A., M.C. Dalhgreen, and J.F. Franklin. 2013. 

The ICO approach to quantifying and restoring forest spatial pattern: 

Implementation guide. Version 2.0. Stewardship Forestry, Vashon, Washington, 

USA

• Churchill, D.J., A.J. Larson, M.C. Dalhgreen, J.F. Franklin, Hessburg, P.F., and 

James A. Lutz. Restoring forest resilience: From reference spatial patterns to 

silvicultural prescriptions and monitoring. Forest Ecology and Management 291 

(2013) 442-457

Response: The ICO approach was considered for the Sunrise project, and would be 

applied across the majority of areas for each action alternative, such that opening 

sizes range from 1⁄2-to-1 acre in size for most units. The first two citations listed 

above are nearly identical, and the second was cited in the DEIS on pg. R-6. The 

third citation listed above was cited in the DEIS on pg. R-6 as well.

116. Concern Statement: The Forest Service should give consideration to where 

planting can be avoided or delayed in order to promote the development of complex 

early seral habitat.

Recently disturbed patches tend to support high plant productivity, and often exhibit 

a particularly high diversity of plant and animal species. Early successional habitats 

are also important for ungulate summer forage, and several species of migratory 

songbirds. The full expression of early seral habitat may be cut short by planting 

coniferous species shortly after harvest. While we recognize the existing seed bank 

may necessitate planting in order to ensure the re-establishment of desired tree 

species, we recommend consideration be given to where planting can be avoided or 

delayed in order to promote the development of complex early seral habitat. 

The following references provide insight:

• Franklin, J.F., K.N. Johnson, D.J. Churchill, K. Hagmann, D. Johnson, and J. 

Johnston. 2013. Restoration of dry forests in Eastern Oregon: a field guide. The 

Nature Conservancy, Portland, OR. 202 p.

• Stine, Peter; Hessburg, Paul; Spies, Thomas; Kramer, Marc; Fettig, Christopher 

J.; Hansen, Andrew; Lehmkuhl, John; O’Hara, Kevin; Polivka, Karl; Singleton, 

Peter; Charnley, Susan; Merschel, Andrew; White, Rachel. 2014. The ecology 

and management of moist mixed-conifer forests in eastern Oregon and 

Washington: a synthesis of the relevant biophysical science and implications for 

future land management. Gen. Tech. Rep. PNW-GTR-897. Portland, OR: U.S. 

Department of Agriculture, Forest Service, Pacific Northwest Research Station. 

254 p.

• USDA General Technical Report NRS-19 “Natural Disturbance and Stand 

Development Principles for Ecological Forestry”5

10-01c
Sunrise Vegetation and Fuels Project

402 Umatilla National Forest

• Larson, A.J., Churchill, D. 2012. Tree spatial patterns in fire-frequent forests of 

western North America, including mechanisms of pattern formation and 

implications for designing fuel reduction and restoration treatments. Forest 

Ecology and Management, 267 (2012) pp 74-92

Response: Under all action alternatives described in the Sunrise DEIS, treeplanting would be avoided, unless artificial regeneration is necessary to provide 

adequate reforestation, as required by the National Forest Management Act of 1976, 

or if silvicultural objectives include promoting species diversity in the stand beyond 

that provided by natural regeneration alone. Due to the high financial and logistical 

costs of tree-planting, planting will be delayed as long as possible and legally 

allowable, in order to assess the species composition of natural regeneration and 

whether such composition is consistent with silvicultural objectives. The Sunrise 

action alternatives also include the application of prescribed landscape burning 

across over 10,000 acres, which will provide additional early-seral 

vegetation/habitat patches. The references listed above were all considered during 

the development of action alternatives, and describe patterns and processes 

generally consistent with the application of landscape fire, tree-cutting, and treeplanting activities included in the action alternatives.

Wildlife

117. Concern Statement: The Forest Service should discuss how various alternatives 

will affect the viability of current populations of listed, sensitive, MIS, cornerstone, 

and focal species. The DEIS discusses survey data taken over 25 years ago.

Response: The Forest manages habitat that supports these species. For example, 

habitat analysis indicates that the project planning area could reasonably support 8 

pair of pileated woodpeckers (DEIS pg. 3-92). 

The 1992 reference is indicative of the effectiveness of providing protected habitat 

(Dedicated Old Growth areas) to maintain populations.

Habitat improvements for some species are mentioned on pp. 3-102 to 3-121 of the 

DEIS; for example white-headed woodpecker and bighorn sheep.

02-08

118. Concern Statement: When will the goshawk survey mentioned on pg. 3-99 of 

DEIS take place?

Response: Some areas have been visited and surveys will continue in the spring of 

2019. Efforts are made each year to complete goshawk surveys in our various 

planning areas, and at any stage of a project adjustments can be made to protect 

nesting areas. See DEIS pg. 3-99 and 2-43.

02-09

119. Concern Statement: The Forest service should retain all snags larger than 20" 

DBH during the project (unless they pose a significant safety risk). Old snags are 

rare on the landscape and provide habitat for numerous species of wildlife. Large 

old snags will eventually become large downed woody debris, which create more 

habitat for wildlife and microclimates for plant species. Many animals evolved with 

higher levels of snags on the landscape while timber management and fire 

02-13
Final Environmental Impact Statement

Pomeroy Ranger District 403

suppression have decreased the abundance of snags. The adequate number of snags 

per acre for wildlife species is variable and highly dependent upon the surrounding 

landscape pattern. However, DecAID, the Decayed Wood Advisor for Managing 

Snags, Partially Dead Trees, and Down Wood for Biodiversity in Forests of 

Washington and Oregon (https://tinyurl.com/yca9gt96) can be used to determine an 

estimate. For example, DecAID recommends 6 -17 snags per acre >20" DBH in a 

post-fire structural type in the Eastside Mixed Conifer Forest N Cascades/Rocky 

Mountains as a 50% tolerance level.

Response: All snags larger than 20 inches DBH are being retained, see the first line 

on pg. 2-44 of DEIS. The appropriate table to use is Eastside Mixed Conifer East 

Cascades / Blue Mountains. It is not appropriate to use a post fire habitat type in 

this project. Please refer to snag density information on pg. 3-89 of DEIS.

120. Concern Statement: The Forest Service should identify the birds that exist in and 

near the project area that are protected under the Migratory Bird Treaty Act and 

discuss how these birds will be protected during burning and timber harvest 

operations.

Response: The Forest Service supports the conservation intent of the migratory bird 

conventions by integrating bird conservation principles, measures, and practices 

into agency activities and by avoiding or minimizing, to the extent practicable, 

adverse impacts on migratory bird resources when conducting agency actions. 

(DEIS pg. 3-115). Some specific examples for this project include retaining snags, 

protecting raptor nests, and not burning during nesting season.

03-12

121. Concern Statement: The Forest Service should explain how logging 12.2 square 

miles and building 14 miles of road will improve wildlife habitat. The Purpose & 

Need statement you authored at pg. 1-17 says "Wildlife Habitat - There is a need to 

continue to provide and manage, over time, for wildlife habitat, as it is required to 

meet Forest Plan goals and management area standards and guidelines."

Response: The purpose and need statement does not state that habitat for all species 

would be improved. Improvements for some species are expected, for example 

white-headed woodpecker and bighorn sheep. Predicted effects to wildlife habitat 

are discussed extensively on pp. 3-102 to 3-121 of the DEIS.

03-26

122. Concern Statement: The Forest Service should explain this statement on pg. 3-59 

of the EIS: "Alternative C favors providing wildlife habitat by disturbing fewer 

acres in the short-term." Does disturbing acres through management make them 

unusable as habitat? Or would it be a habitat conversion where the landscape would 

favor a different species?

Response: This statement has been deleted from the vegetation section in the FEIS. 

In answer to the question, the processes involved in timber harvest and other actions 

can cause immediate disturbance to wildlife. Short-term disruption of long-used 

areas may occur, and connectivity between habitat patches may be lost.

05-05

123. Concern Statement: The Forest Service should explain why it is only proposing to 

close the Devil's Tailbone Road early under alternative C? What would be the 

05-08
Sunrise Vegetation and Fuels Project

404 Umatilla National Forest

benefit of keeping it open vs. closing it early? It seems that closing it under 

alternative B would help in the HEI score.

Response: The change in timing of the road closure on Devil’s Tailbone Road 

would improve elk security (DEIS 3-109) and is included in Alternative C as part of 

the elk habitat issue. There is no effect to HEI because the road will remain open 

part of the year. There is no change to open roads densities in either action 

alternative (DEIS 3-108).

124. Concern Statement: The Forest Service should address the possible negative 

effects this project may have on elk distribution and habitat availability due to 

decreased cover on a landscape with higher road densities. In addition to cover 

impacts, removal of vegetation, particularly at higher elevations, will negatively 

affect an important late- summer nutrition source. 

Response: This concern has been addressed, in part by Alternative C. See 

description on DEIS pg. 2-37; see also the effects analysis on pg.3-106.

Most forested stands affected by timber harvest do not contain much elk forage. 

And in those that do, it would be a short term impact that would reverse as stands 

are opened up and more light is available to grow forage species. There are 

extensive foraging areas outside of harvest units.

06-01

125. Concern Statement: The Forest Service should clarify the meaning of the term 

“marginal” on pg. 2-31 of the DEIS: “...”high-retention" areas will be treated to 

maintain marginal or satisfactory wildlife cover and/or satisfactory cover for 

wildlife connectivity corridors.” This does not specify "elk cover", which is defined 

within the document.

Response: Both cover categories are defined in the document at pg. 3-83 of the 

DEIS as well as in the glossary. The terms ‘tree cover’ and ‘elk cover’ are 

synonymous in the wildlife analysis.

06-04

126. Concern Statement: The Forest Service should consider that habitat currently not 

used by bighorn sheep, because of high canopy cover, will now be opened up. This 

could lead to increased use of higher elevation habitat. Effects will likely be 

increased herd home range size, increased probability of interherd movement 

between the Asotin herd and the Tucannon, Wenaha, and Mountain View herds. 

This increased movement between herds will improve genetic flow, but also 

increase the probability of disease transmission between these herds. Disease 

transmission between herds can theoretically threaten the viability of a bighorn 

sheep herd.

Response: The DEIS states that the project may impact bighorn sheep. See Table 

3-40 on pg. 3-121. Based on our risk of contact models completed for the Umatilla 

National Forest Plan, the reduction in cover and change to horizontal visibility in 

this project will not likely change the risk of contact between bighorn sheep herds 

and domestic sheep allotments. Further information is provided in the FEIS.

06-13

127. Concern Statement: The Forest Service should clarify the following information 

from the Wildlife Report, pg. 9: “MA-C4 open road density is 1.2 miles per square 

06-16
Final Environmental Impact Statement

Pomeroy Ranger District 405

mile. Parts of this MA-C4 are within the Asotin Creek Roadless Area.” What 

percentage is located in the roadless area and what road densities would be without 

its inclusion? This information will allow for more accurate analysis of the potential 

impacts to elk.

Response: Approximately one-third of the MA-C4 is roadless.

128. Concern Statement: The Forest Service should provide post activity estimates of 

HEI in Table 3 on pg. 9 of the Wildlife Report.

Response: Post activity values for elk habitat are on pg. 13 of the Wildlife Report 

and in Table 3-36 of the DEIS, pg. 3-109. HEI standards are based on Forest Plan 

management areas, which include roadless areas. Removing the roadless areas 

would reduce the MA-C4 below the 5,000 acre threshold for the HEI model.

06-17

129. Concern Statement: The Forest Service should provide HEI values both with and 

without roadless areas included in the calculations. Documents associated with the 

analysis of this project recognize the potential of skewing the data by including 

roadless areas in calculating HEI. We believe that there is value to including both 

HEI values with roadless areas and without roadless areas. We request that this 

information be provided in the EIS.

Response: HEI standards are based on Forest Plan management areas, which 

include roadless areas. Removing the roadless areas would reduce the MA-C4 

below the 5,000 acre threshold for the HEI model.

06-18

130. Concern Statement: The Forest Service should clarify the methods used to arrive 

at the estimates in Table 7, on pg. 14 of the Wildlife Report. MA-C4 HEI for 

Alternative C does not show post treatment change and Alternative B only 

decreases by 2 percent. This seems to be counter intuitive.

Response: HEI is not a good indicator of elk habitat when open road densities do 

not change. Changes in cover often do not affect the model results significantly.

06-20

131. Concern Statement: The Forest Service should consider that additional monitoring 

may be appropriate to detect negative vegetation effects from ungulates and bovines 

for the first 10-15 years post-harvest. The opening of large areas of forest may 

affect ungulate and bovine distribution during the summer months, potentially 

concentrating use into the remaining high crown cover areas, i.e. riparian. Elk may 

move into these areas to avoid road use and find more nutritious vegetation during 

the drier months, while cattle may use these areas for thermal relief.

Response: Thank you for your comment. Monitoring of bovine activities by 

permittees will address movement in or out of riparian areas following project 

activities.

06-23

132. Concern Statement: The Forest Service should estimate the amount of habitat (i.e., 

acreage) impacted by the Project for the Birds of Conservation Concern listed in the 

DEIS.

07-06
Sunrise Vegetation and Fuels Project

406 Umatilla National Forest

Response: General effects to birds of conservation concern are provided in DEIS 

Table 3-39 on pg. 3-115. Some updates have been made to the FEIS. Estimates of 

habitat for many of these species is impossible because we do not have fine-scale 

data such as amount of meadow edge or alder thickets. Estimates for Lewis and 

white-headed woodpecker are given on pg. 3-118 of the DEIS. 

133. Concern Statement: The Forest Service should disclose cumulative effects at the 

project, watershed, and Forest scales for: MIS (management indicator species), 

species of concern, vulnerable and sensitive species, ESA (Endangered Species 

Act)-listed species, and other species. This should include: quantification of habitat 

and an analysis of quality of habitat; quantification of percent of affected habitat at 

the project and watershed scale for most species; quantification of the 

amount/percentages of high quality habitat for species; and a full consideration of 

specific past, present, and reasonably foreseeable actions.

Response: Cumulative effects statements found in the Wildlife Specialist Report 

were erroneously omitted from the body of the DEIS; they have been added to 

section 3.8 of the FEIS. Quantification of affected habitats for MIS species is 

provided on pp. 3-106 to 3-114 of the DEIS and in other sections where appropriate. 

A forest-wide assessment of wildlife MIS species was recently completed for the 

forest plan revision and those findings are cited in the DEIS pg. 3-87 and pg. 3-93.

We believe the forest scale is an appropriate scale for analysis of effects to MIS 

species. 

09-09a

134. Concern Statement: The Forest Service should demonstrate that the viability of 

Management Indicator and Sensitive species (MIS) would be ensured with project 

implementation.

Response: The viability of Management Indicator Species is addressed on pp. 3-

112 to 3-115 of the DEIS. Some key pieces of information were omitted from the 

DEIS, and this is corrected in the FEIS. See also pp. 23-24 of the Wildlife Specialist 

Report which is available on the project website: https://tinyurl.com/y7mboqgh .

09-18

135. Concern Statement: The Forest Service has legal responsibilities to protect the 

viability of Management Indicator species, but not to move forest structure toward a 

theoretical Historic Range of Variability (HRV) as an over-riding goal. It is also not 

justifiable to plan for continued impacts and cumulative potential loss of species 

viability for a Management Indicator species based on long¬ term theoretical regrowth of suitable habitat eventually, as the species' viability may be lost before the 

habitat can grow back-especially given likely planned similar timber sales in the 

same area in the future, and the 100+ years suitable habitat would take to redevelop. 

Response: The viability of Management Indicator Species is addressed on pp. 3-

112 to 3-115 of the DEIS, and in more depth in the Wildlife specialist report which 

is available on the project website: https://tinyurl.com/y7mboqgh . Some 

corrections have been made to the FEIS. A description of how the action 

alternatives comply with the Endangered Species Act and the Regional Forester’s 

Sensitive Species can be found in section 3.25 of the DEIS (pg. 3-234).

09-20
Final Environmental Impact Statement

Pomeroy Ranger District 407

136. Concern Statement: The Forest Service should stop claiming that unquantified 

speculative future ecological benefits to woodpeckers will necessarily offset 

immediate impacts to already vulnerable species. Cumulative reduction of habitat 

for black-backed woodpeckers due to many projects and fire suppression efforts 

across the landscape and in the project area constitute a severe blow to this species' 

viability in the project area. The DEIS simply implies that other habitat exists 

outside of the project area, but does no actual analysis or quantification of 

cumulative impacts or remaining available habitat across the landscape or the 

project area. Pileated woodpeckers need a minimum of 40% canopy closure for 

foraging and at least 60% canopy closure for nesting, so variable density logging 

isn't likely to retain active pileated habitat use. Industrial scale logging will destroy 

available habitat, as will conversion of historic mature mixed-conifer forests to 

early seral pine plantations. We have similar concerns about other woodpecker 

species in the project area.

Response: The project effects to snag habitat in general, and specifically for MIS 

species pileated and three-toed woodpecker are addressed on pp. 3-113 to 3-115 of 

the DEIS. 

Black-backed woodpeckers are not considered an MIS species for the Umatilla 

National Forest, and are not on the Regional Forester’s sensitive species list. Table 

3-28 of the DEIS indicates that snag densities are within the habitat needs of black 

backed woodpeckers and meet the 50% tolerance level for pileated woodpeckers. 

All large snags will be retained unless hazardous to workers and snag will be 

created through prescribed burning (DEIS 3-114). The figures that are related to 

Table 3-28 were not included in the DEIS, but have been added to the FEIS. See 

Figures 6 and 7 of the Wildlife Report pp 28-29, which is available on the project 

website: https://tinyurl.com/y7mboqgh .

The watershed scale of analysis is appropriate to show effects to snag habitat. The 

DEIS indicates that cumulatively with the South George timber sales, less than 1 

percent of forested areas are affected at the forest scale (DEIS 3-113).

09-21

137. Concern Statement: The Forest Service’s conclusion of no negative cumulative 

impacts from any of the proposed Sunrise DEIS action alternatives for goshawk 

does not address the full range of best available science for goshawk habitat needs. 

The USFS's failure to disclose Greenwald et al (2005) and many other scientists' 

findings that goshawk need denser mature forest habitat and that this should not be 

logged in order to ensure goshawk viability is conspicuously lacking in this biased 

presentation of the science regarding goshawk habitat needs.

Response: There is no “conclusion of no negative cumulative impacts” in the 

DEIS. See pg. 3-118. The project may have an effect on up to 700 acres, leaving an 

unaffected area of approx. 7,000 acres of goshawk habitat. 

The Forest Service has a long history of science-based decision making. Using the 

best science provides the responsible official with the knowledge, methods, and 

expert review needed to make an informed decision. The agency has taken into 

account the best available science, and used it to conduct the analysis of the Sunrise 

project. These sources are cited throughout the DEIS and the specialist’s reports. 

The References section of the DEIS (pg. R-1) lists the necessary information for the 

public to find and review these sources, if they so desire. All references to new 

09-22
Sunrise Vegetation and Fuels Project

408 Umatilla National Forest

sources of credible, peer-reviewed scientific research provided by commenters have 

been reviewed by specialists to determine if and how they would change our 

analysis of the Sunrise project. Any changes to the FEIS as a result of this review 

are noted in the FEIS.

138. Concern Statement: The Forest Service must do a better job in analyzing and 

avoiding impacts to olive-sided flycatcher in the Sunrise project and others. The 

Robertson and Hutto study and the precipitous declines in population trends for the 

olive-sided flycatcher strongly suggest this. The Robertson and Hutto study stated 

that "Human activities that closely mimic the appearance but not the fundamental 

quality of natural habitats could attract animals to settle whether or not these 

habitats are suitable for their survival or reproduction...”

Response: The study cited is about ‘artificially created post-disturbance habitat.’ It 

is characterized as private timber land with patches of thinned forest interspersed 

with unharvested patches. It is doubtful that the thinned areas in the study are 

comparable to the Sunrise project. For instance, the Sunrise project will retain many 

large trees and snags, which is not normally what private timber companies do.

The DEIS also states that landscape burning would enhance habitat. In addition, 

recent large wildfires have created an abundance of burned forest and edge habitat 

on the Pomeroy Ranger District.

09-24

139. Concern Statement: The Forest Service should protect the viability of marten; and 

not contribute to downward population trends for this species, particularly in 

combination with other projects. The should adequately analyze the quantity and 

quality of marten habitat that would be affected by the Sunrise project. In project 

areas where selective logging is planned, trees> 21 inches DBH would not be 

removed in these areas, but modifications to the stand structure would make them 

unsuitable for marten denning in the short and mid-term. Clearcutting or 

"regeneration" logging would also in occur marten habitat. Thousands of acres of 

marten habitat would be destroyed or degraded by the Sunrise project. After 

logging, remaining habitat in that area would occur in smaller blocks and would be 

less contiguous. The DEIS states that "[i]n the remainder of the project area, nearly 

all marten habitat that is not protected by MA-Cl (Dedicated Old Growth, MA-CS 

(Riparian) and Asotin Creek Roadless Area designations would be affected by 

cutting activity proposed in Alternative B. Within MA-C4, 100 percent of the 

marten habitat would be affected by tree cutting (1,950 acres)." 

Response: Some key pieces of information were omitted from the DEIS. Please 

refer to pg. 23-24 of the Wildlife Specialist Report. This has been corrected in the 

FEIS.

Although a seemingly large amount of potential marten reproductive habitat is 

affected, it is only 2% of the marten habitat on the forest. That said, the DEIS 

recognizes the impact to marten habitat, and points to Alternative C as a better 

balance between maintaining marten habitat and moving stands towards HRV.

09-25

140. Concern Statement: The Forest Service should take into consideration that 

growing scientific evidence shows that numerous species are at much lower risk 

from wildfire than previously thought, and some of these species may be more 

09-42a
Final Environmental Impact Statement

Pomeroy Ranger District 409

negatively affected by thinning than by wildfire. Example include olive-sided 

flycatchers, Canadian lynx, Pacific fisher, Northern spotted owls, flying squirrels, 

and others (Bond 2015; Bond et al. 2012; Hanson 2015; Moriarty et al. 2016; 

Manning et al. 2012; Robertson and Hutto 2007). Such research strongly suggests 

that a greater abundance of caution is needed when considering logging in 

important wildlife corridors such as riparian areas.

Response: It is true that wildfire creates important wildlife habitat. Mixed and 

severe wildfire could occur at any time given the right conditions. Past history has 

demonstrated the Blue Mountains has had numerous incidents. In addition, 

prescribed fire is a large part of the District program of work, and provides many 

acres of burned landscape each year that contribute to those species needing those 

conditions to survive (DEIS pg. 3-115). Regarding the olive-sided flycatcher, 

please see response to comment No. 138. Please note that no logging is proposed in 

riparian areas.

Wildlife: Elk

141. Concern Statement: The Forest Service should select Alternative C (with 

modifications to address issues raised by the Greater Hells Canyon Council) 

because it is much better for elk and would better meet one of the projects stated 

purposes: "given the Forest Plan management area allocations for big game and 

wildlife habitat goals (C3, C3A, and C4), there is a need to continue to provide and 

manage wildlife habitat and its components (cover and forage) in the Sunrise 

project planning area."

Response: Your opinion is appreciated, as it gives the Responsible Official a 

general sense of various views and beliefs.

01-04

142. Concern Statement: The Forest Service should explain why it is proposing to 

leave the majority of elk cover in the moist forests. Isn't moist forest where elk need 

additional forage during the late summer, because all the other forage is too dry? It 

seems that leaving additional cover in the moist forest would be counterintuitive to 

keeping the elk on the National Forests during late summer/early fall.

Response: Due to past forest management and large fires, there is an extensive 

amount of forage available in the area. In moist forest within MA-C4, there are 

approximately equal amounts of cover and forage.

05-09

143. Concern Statement: The Forest Service should analyze the potential cumulative 

effects of other recent projects in Charley Creek and George Creek that are adjacent 

to the Sunrise project area, because the impacts to elk within the Asotin Watershed 

may be much greater when cumulative effects are considered.

Response: The Standards for big game set forth in the Umatilla National Forest 

Land and Resource Management Plan were met for all projects in the Asotin 

Watershed. See pg. 1-17 and pg 3-82 of the DEIS for more information about the 

big game management direction provided in the Forest Plan. In order to eliminate 

repetition and focus on site-specific analysis, the DEIS is tiered to the Umatilla 

National Forest Land and Resource Management Plan FEIS and Record of Decision 

06-03
Sunrise Vegetation and Fuels Project

410 Umatilla National Forest

(ROD) dated June 11, 1990 and all subsequent NEPA analysis for amendments. See 

pg. 1-22 of the DEIS: Tiering and Incorporating by Reference.

144. Concern Statement: The Forest Service should not use amount of habitat as the 

major indicator for determining effects to ungulates number of factors influence the 

"usability or availability" of that habitat. For example, elk habitat availability is 

directly correlated with the proximity to open roads and security cover. Habitat is 

not used at the rate it is available when disturbance is close. The majority of the 

proposed vegetation management portion of this project (non-prescribed fire 

activities) are located in close proximity to headwater streams and high elevation 

meadows, which are a primary source of nutrition during the later summer months. 

These critical habitats will be heavily impacted by the proposed activities and the 

effects will last for many years (reduced security cover, open roads adjacent to 

primary food sources). 

Alternative C would reduce the impact to this elk subherd by limiting vegetation 

removal (in comparison to Alt B). Additionally, targeted seasonal road closures 

(Aug 1 - Dec 1) would also be beneficial in the areas of remaining elk security 

cover as mapped in Alternative C. 

Elk cover in the headwaters of Asotin Creek would be extremely limited by 

selecting Alternative B. This herd is already declining for a number of reasons. The 

high road density outside of the inventoried roadless areas will limit the availability 

of necessary habitat and hinder the recovery of this elk population.

Response: The EIS does not focus solely on elk cover. Several measures are used 

to indicate effects to elk, including open road densities (DEIS 3-109 to 3-111). 

Alternative C is responsive to the elk issue. 

The Umatilla National Forest has a long standing access management plan that 

resulted in extensive miles of closed roads. Approximately 50 miles of roads have 

already been closed in the project planning area and will remain closed. There may 

be opportunities to increase security with additional road closures, however we 

chose not to propose any with this EIS.

06-06

145. Concern Statement: The Forest Service should restrict any activities on elk winter 

range from Dec 1-March 30 and the calving closure until June 30. Further, it should 

close Devils Tailbone Road (4000-360) whether Alternative B or C is selected.

Response: The range of alternatives chosen for the Sunrise project environmental 

analysis allows for the selection (in a final Record of Decision) of an alternative 

including the measures suggested. Such an alternative would have direct, indirect, 

and cumulative effects within the scope and scale of those analyzed and disclosed in 

the DEIS.

06-08

146. Concern Statement: The Forest Service should consider the impact of reduced elk 

security. There are numerous statements about no impact to the elk population. This 

may not be true with reduced security cover in an area with high road densities. 

Direct mortality of elk through harvest would have a negative impact to this 

population, which is currently struggling with poor recruitment. Any increase in 

mortality would be a direct impact to this population.

06-10-

b
Final Environmental Impact Statement

Pomeroy Ranger District 411

Response: Nowhere does the DEIS say no impact to elk. 

Direct effects are defined as “caused by the action and occur at the same time and 

place” (DEIS pg. G-6). In other words, they are immediate. Vegetation 

management does not cause direct elk mortality in the same way that hunting 

predation, and auto collisions do, for example. 

Indirect effects to elk from forest management are acknowledged on pg. 3-110: 

“Alternative B would result in a slightly negative habitat trend”. 

We understand your interest in the Washington portion of the forest, however our 

references are to the Forest-wide population of elk, as directed by the National 

Forest Management Act.

147. Concern Statement: The Forest Service should analyze road density in MA-C4 

with the Inventoried Roadless Area removed. It is stated on pg. 3-84 of the DEIS 

that the road density in MA-C4 is low (1.2 mi. per mi2). This may be misleading 

due to the roadless area included in this analysis. If the roadless area was not 

included, the MA-C4 area would have much higher road density, highlighting the 

lower value this habitat, within the working project area, has for elk. 

By including the roadless area, the numbers are diluted in the area being logged. 

This is dilution is referred to on the same pg.: 

"MA-C4 HEI value is 70, which is above the minimum forest plan standard of 60. 

Although this value is high, it does not reflect the poor distribution of cover in much 

of the C4 analysis area. The roadless area has good cover and no open roads, which 

brings up the overall HEI value". 

The more valuable summer/fall habitat for elk is the area being focused on for 

vegetation manipulation (headwaters, meadows, higher elevations). This is the area 

being impacted the most with the proposed project, but the effects of roads is being 

diluted by including adjacent habitat that is of lower nutritional value during key 

summer months.

Response: In general, all forest standards include roadless areas, and the road 

density standard is forestwide. There is no standard to compare against for road 

densities outside of unmanaged areas.

We have normally looked at open road densities as a component of HEI, for which 

standards vary by forest plan management area. 

Because the road density is in compliance with the forest plan, and no increase in 

open road density is proposed, there is no need to further analyze the existing 

condition. 

06-12

148. Concern Statement: The Forest Service’s use of Inventoried Roadless Area is 

diluting the effects to the proposed project area. The most desirable elk habitat is 

located within the primary area proposed for forestry activities.

Response: This is acknowledged in the DEIS on pg. 3-107. In Figure 3-6 the 

roadless area is removed from the image to visually show the effects of Alternative 

B in the roaded portion. 

06-15
Sunrise Vegetation and Fuels Project

412 Umatilla National Forest

Outside of roadless, MA-C4 has 20 % elk cover. The Forest Plan was designed to 

include roadless area as part of this measure.

149. Concern Statement: The DEIS evaluates impacts to elk summer range using the 

Habitat Effectiveness Index (Thomas et al. 1988) which is outdated and developed 

for winter range. At a minimum the Forest Service should evaluate impacts to elk 

summer range using the full Habitat Effectiveness Index model by also including 

quality and quantity of forage.

Response: Forage quality and quantity varies greatly across the landscape, in 

relation to livestock grazing, between months and between years. This variability 

makes it very difficult to estimate the quantity and quality of forage for use in 

habitat effectiveness modeling. To our knowledge, the forage variable has rarely, if 

ever, been used in the HEI model. Generally, there are large grassland foraging 

areas in the project area which will be improved with prescribed fire and utilization 

monitoring. See response to comment No. 51 for more information about 

monitoring. 

07-07-

a

150. Concern Statement: The Forest Service should evaluate the project’s impacts at 

the scale to which the actions will be implemented. The DEIS underestimates the 

actual road densities where activities will occur, because inventoried roadless areas 

are incorporated into the road density calculations. This makes it difficult to assess 

the project’s impacts to elk and other wildlife species.

Response: All Forest Plan standards include roadless areas, and the road density 

standard is Forest-wide. There is no standard to compare against for road densities 

outside of unmanaged areas. We have normally looked at open road densities as a 

component of HEI, for which standards vary by Forest Plan management area. 

Because the road density is in compliance with the Umatilla Forest Plan, and no 

increase in open road density is proposed, there is no need to further analyze the 

existing condition. 

07-07-

b

151. Concern Statement: The Forest Service should evaluate the impact of increased 

use and distribution of livestock grazing on elk distribution and habitat across the 

Project area after implementation.

Response: We manage livestock use periods and residual forage within range 

standards and will continue to monitor livestock forage utilization.

07-07-

d

152. Concern Statement: The Forest Service should evaluate the project’s impacts to 

elk and elk habitat from disturbance from motorized travel, silvicultural 

prescriptions, livestock grazing and other activities.

Response: The FEIS provides additional information on elk security. The Standards 

for big game set forth in the Umatilla National Forest Land and Resource 

Management Plan were met for all projects in the Asotin Watershed. See pg. 1-17 

and pg 3-82 of the DEIS for more information about the big game management 

direction provided in the Forest Plan.

07-08
Final Environmental Impact Statement

Pomeroy Ranger District 413

153. Concern Statement: The Forest Service should analyze the project’s impacts on 

elk and elk habitat in MA-C3A independent of MA-C3.

Response: MA-C3 (4,280 acres) and C3A (3,255 acres) were combined because the 

Forest plan Standards are the same and this provided a large enough area to use the 

HEI model. Elk cover is distributed throughout both areas. MA-C3A has 34% total 

cover and 19% satisfactory cover which is within forest plan standards. Alternative 

B and C reduce satisfactory cover to 15%, which is above the minimum of 10%. 

Roads are closed in both areas in the winter, so the values do not change in MAC3A.

07-7-c

154. Concern Statement: The Forest Service should retain more overall tree density and 

deer and elk cover-especially by dropping sale units in cool moist and cold dry 

habitat and in microhabitat patches where greater density would naturally occur, 

such as at higher elevations, on North to Northeast aspect slopes, and within 

riparian corridors (RHCAs).

Response: Thank you for your comment. Alternative C responds to concerns about 

elk cover. See DEIS pg. 2-37.

09-23

Comment Letters

All comment letters can be viewed on the Sunrise project webpage (http://www.fs.fed.us/nepa/fsusda-pop.php/?project=45689). Due to the voluminous nature of the combined total pages of 

comments received, only those received from State and Federal agencies, and the local Tribe are 

presented here. 
Sunrise Vegetation and Fuels Project

414 Umatilla National Forest
Final Environmental Impact Statement

Pomeroy Ranger District 415
Sunrise Vegetation and Fuels Project

416 Umatilla National Forest
Final Environmental Impact Statement

Pomeroy Ranger District 417
Sunrise Vegetation and Fuels Project

418 Umatilla National Forest
Final Environmental Impact Statement

Pomeroy Ranger District 419
Sunrise Vegetation and Fuels Project

420 Umatilla National Forest
Final Environmental Impact Statement

Pomeroy Ranger District 421
Sunrise Vegetation and Fuels Project

422 Umatilla National Forest
Final Environmental Impact Statement

Pomeroy Ranger District 423
Sunrise Vegetation and Fuels Project

424 Umatilla National Forest
Final Environmental Impact Statement

Pomeroy Ranger District 425
Sunrise Vegetation and Fuels Project

426 Umatilla National Forest
Final Environmental Impact Statement

Pomeroy Ranger District 427
Sunrise Vegetation and Fuels Project

428 Umatilla National Forest
Final Environmental Impact Statement

Pomeroy Ranger District 429
Sunrise Vegetation and Fuels Project

430 Umatilla National Forest
Final Environmental Impact Statement

Pomeroy Ranger District 431
Sunrise Vegetation and Fuels Project

432 Umatilla National Forest
Final Environmental Impact Statement

Pomeroy Ranger District 433
Sunrise Vegetation and Fuels Project

434 Umatilla National Forest
Final Environmental Impact Statement

Pomeroy Ranger District 435