United States

Department of

Agriculture

Forest Service

R5-MB-302

June 2017

Draft Record of Decision

Horse Creek Community Protection and 

Forest Restoration Project

Happy Camp/Oak Knoll Ranger District, Klamath National Forest

Siskiyou County, California

Abstract: This draft Record of Decision (ROD) documents the Deciding Officer’s decision

pertaining to the alternatives identified in the final EIS.

Lead Agency: USDA Forest Service

Cooperating Agencies: None

Responsible Official: Patricia A. Grantham, Forest Supervisor, Klamath National Forest

For Information Contact: Lauren McChesney, Environmental Coordinator, Klamath National

Forest Supervisor’s Office, 1711 South Main Street, Yreka, CA 96097, (530) 841-4483 or

laurendmcchesney@fs.fed.us
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TABLE OF CONTENTS

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

The Gap Fire...................................................................................................................................................1

Project Proposed in Response to the Gap Fire ..........................................................................................1

Location of the Project Area .........................................................................................................................3

Management Areas within the Project Area................................................................................................3

Purpose and Need.........................................................................................................................................7

2. DECISION....................................................................................................................... 7

The Selected Alternative................................................................................................................................7

EnvironmentallyPreferable Alternative......................................................................................................19

RegulatoryAgencyRequirements Prior to Implementation.....................................................................20

Project Monitoring.......................................................................................................................................21

3. REASONS FOR MY DECISION.................................................................................... 21

Management Areas of the Forest Plan ......................................................................................................22

Wildland Urban Interface ............................................................................................................................23

Burn Severity ...............................................................................................................................................26

Restoration Treatments ..............................................................................................................................28

4. OTHER ALTERNATIVES CONSIDERED...................................................................... 30

Alternatives Considered in Detail but not Selected..................................................................................30

Alternatives Considered through Tribal Consultation...............................................................................31

Alternatives Considered but Eliminated from Detailed Study ..................................................................33

5. PUBLIC INVOLVEMENT .............................................................................................. 34

Scoping ........................................................................................................................................................34

Draft EIS Comment Period ..........................................................................................................................35

6. LEGAL AND REGULATORY REQUIREMENTS .......................................................... 35

National Environmental Policy Act .............................................................................................................36

National Forest Management Act................................................................................................................36

Clean Air Act.................................................................................................................................................37

Clean Water Act............................................................................................................................................37

Endangered Species Act .............................................................................................................................37

Magnuson-Stevens Fishery Conservation Management Act....................................................................38

FloodplainManagement..............................................................................................................................38

National Historic Preservation Act..............................................................................................................39

EnvironmentalJustice.................................................................................................................................39

Prime Farmland, Rangeland and Forest Land............................................................................................39

Migratory Bird Treaty Act ............................................................................................................................40

InvasiveSpecies ..........................................................................................................................................40

Findings Related to Special Areas.............................................................................................................40

Implementation Date....................................................................................................................................41

Explanation of Negative Impacts of Implementation Delays ...................................................................42

Contact Information ....................................................................................................................................43

APPENDIX A: Vicinity Map and Selected Alternative Treatment Map....................... 44

APPENDIX B: Project Design Features and Best Management Practices for the Horse 

Creek Project ............................................................................................................... 46
—Draft Record of Decision—

Page 1

List of Tables

Table 1. Management areas found within the project boundary...................................................................4

Table 2. Treatment Types and Areas of the Selected Alternative.................................................................8

Table 3. Summary of Salvage Units...........................................................................................................13

Table 4. Wildland urban interface (WUI) acres with the project boundary by WUI zone. ........................23

Table 5. Burn Severity Acres by Land Ownership and RAVG Class.........................................................28

Table 6. Karuk Alternative compared to Forest Service action alternatives...............................................31

List of Figures

Figure 1. Alternative 2 proposed treatment map with WUI zones. ............................................................25

Figure 2. Gap Fire severity by RAVG class map........................................................................................27
—Draft Record of Decision—

Page 1

1. Background

The Gap Fire

The Horse Creek Community Protection and Forest Restoration Project was developed in 

response to conditions created by the Gap Fire, which began in the late afternoon of August 27, 

2016, from an unknown cause. Significantly hot and dry (above 90th percentile) conditions made 

initial fire control efforts difficult. Fire behavior was described as active with uphill runs, 

spotting, and active backing. The fire burned actively all thought the night of August 27th.

By Sunday morning (August 28th), the fire was under a mild inversion with reduced fire activity. 

At 2:40 p.m., an infrared scanning helicopter estimated fire size at 325 acres. As a northnorthwest to west-northwest wind began to blow later in the afternoon, the fire became aligned

with the east-west lay of the Horse Creek drainage. As wind aligned with the drainage, fire 

activity and spread increased. The fire spotted to the north side of Horse Creek and fire activity 

increased significantly, spreading rapidly in an easterly direction. Late afternoon to early evening 

spot fires were observed up to one half mile ahead of the advancing fire and quickly became 

greater than 100 acres. The rapidly moving fire spread into the community of Horse Creek 

sometime in the 6:30 p.m. to 7:00 p.m. time period, destroying homes, outbuildings and personal 

property. At 9:48 p.m. on August 28th, an infrared scanning airplane estimated the fire size at 

4,099 acres. In just over seven hours, the fire had burned almost 3,800 acres (over six square 

miles). Over the next several days, the fire continued to grow rapidly and by Tuesday morning, 

August 30th, it was over 8,800 acres, and had destroyed nine homes and 14 outbuildings and had 

forced the evacuations of the communities of Horse Creek and Hamburg, California. When the 

fire was officially declared contained on September 17th, it had burned 33,867 acres, impacting 

the nearby communities, private structures, national forest and private infrastructure, private 

timberlands, and natural resources.

Overly dense vegetation and fuels conditions, weather, and topography all played a role in the 

extreme fire behavior experienced on the Gap Fire. As weather conditions subsided (winds 

reduced and fuel moistures increased) along with surface inversions, less damaging fire behavior 

and effects occurred. A range of fire effects (or fire severity, a measure of how intensely a fire 

burns, related to the proportion of vegetation killed) can be found across the landscape. Within 

the 33,867-acre total Gap Fire perimeter, 21,580 acres of National Forest land burned –16,590 at 

low severity, 1,005 at low to moderate severity, 690 at moderate to high severity, and 3,295 at 

greater than high severity (see Chapter 1 of the FEIS for more details).

Project Proposed in Response to the Gap Fire

Fire plays a natural and important role within the Klamath Mountains ecosystem, and areas 

within the Gap Fire show positive effects from the fire such as reduced fuel loading and greater 

vegetative diversity through the creation of small canopy gaps. 

The intense fire that burned through the community of Horse Creek, destroying homes and 

private property, however, is horrific. The impact that this fire had on the community of Horse 

Creek was catastrophic. The Klamath National Forest Land and Resource Management Plan 
—Draft Record of Decision—

Page 2

(Forest Plan) discusses responding to catastrophic events (such as the Gap Fire as it relates to 

communities and some private lands) as follows:

Removal of trees killed by catastrophic events, such as fire, windthrow, drought, insects 

or disease (36CFR219.27(c)(1)), may be appropriate to promote the long term desired 

future condition of the Forest. Base the decision to salvage an area on an analysis of 

existing conditions following the disturbance and, at a minimum, shall include 

consideration of the economic, social and environmental consequence. (Forest Plan, 

Standard and Guideline 21-7, pp. 4-44 to 4-45)

It is important to note that this discussion relates to areas where timber harvest is not normally 

scheduled. The Forest Plan clearly foresaw the eventuality of catastrophic fire burning into areas 

not normally managed as part of the timber program and yet seeing that the salvage harvest of 

dead and dying trees was necessary.1 

It is easy to look back after an event such as the Gap Fire and apply hindsight in considering all 

of the conditions that contributed to the severity of the event and what could have potentially 

been done to prevent or lessen the tragic outcome. My predominant thought on looking back is 

how incredibly thankful I am that no one was hurt or killed in the fire. My commitment now is to 

working with the local community and all interested parties to implement recovery actions that 

will not only increase the safety of the community today, but will address hazards into the future. 

I carefully considered and appreciate all the comments received on the draft EIS for this recovery 

project. Many of the comments related to the positive effects of most of the area burned, in that 

fuels were reduced and natural, ecological processes were re-introduced. I agree with that 

viewpoint. I also agree with the viewpoint that the destruction caused by the Gap Fire within the 

community of Horse Creek was unacceptable. This recovery project now has the opportunity to 

implement post-fire treatments focused on private property and roads that will contribute to 

preventing another fire from causing similar destruction in the future. Ultimately, fire does not 

choose who it affects. When the Gap Fire burned over 33,000 acres, it didn’t care that it 

destroyed nine homes and forced the evacuation of 50 families. But I care. My obligation is to do 

my best to treat hazardous fuels conditions to keep this from happening again.

As this recovery project moves forward, the community has done likewise. Local residents have 

come together to form the Horse Creek Fire Safe Council. The Council is seeking funds for

treatment on private property and has embarked on community projects to help with cleaning up 

after the fire. Many of the private property potential projects are surrounded by National Forest 

System lands that burned at high severity, or are reached by Forest roads that are now 

surrounded by dead or dying hazard trees and have hazardous fuels built up along them. One of 

the many areas with tragically severe fire effects is the Horse Creek Special Interest Area, 

originally designated for its unique characteristic as an intact and highly diverse old-growth 

riparian ecosystem. The entirety of the Horse Creek Botanical Area was affected by the Gap 

Fire, with large losses of both overstory and ground vegetation especially in the area downstream 

of the confluence with Fish Gulch Creek. The Forest’s responsibility to our local communities, 

as well as our obligation to comply with applicable portions of the Forest Plan, requires us to 

work to complement actions the local community is undertaking on private lands. In addition to 

considering our local communities and regulations, we must consider the safety of the public 

 1 As with any project on the Forest, numerous specific standards and guidelines apply; please see the Forest Plan 

Consistency Checklist within the project record and on the project website for more information.
—Draft Record of Decision—

Page 3

overall as well as that of Forest employees and firefighters. This is why it is important to treat 

hazards along both roads open to the public and those only used with permission. While not 

negating any of the ecological benefits of the fire, I feel compelled to address areas that need 

additional assistance to get back on the trajectory towards desired conditions identified in our 

Forest Plan. 

Location of the Project Area

The project is located on National Forest System lands adjacent to the community of Horse 

Creek, California in Siskiyou County: Township 45 North, Range 10 West, Sections 5 and 

6; Township 45 North, Range 11 West, Section 2; Township 46 North, Range 10 West, 

Sections 2 to 11, 14 to 22, and 28 to 33; Township 46 North, Range 11 West, Sections 1 to 

4, 9 to 16, 21 to 28, and 35 to 36; Township 47 North, Range 9 West, Sections 18 to 19 and 

30; Township 47 North, Range 10 West Sections 9 to 17, 19 to 36; and Township 47 North, 

Range 11 West, Sections 26, 27 and 33 to 36; Mount Diablo Meridian. Private land 

accounts for about 15,238 acres within the project boundary, leaving about 25,596 acres 

that may be considered for treatment on National Forest System lands. Elevation ranges 

from 1,600 to 6,400 feet. It is located within the East Fork Horse Creek, Middle Horse 

Creek, Salt Gulch, Middle Creek, Buckhorn Creek, Lower Horse Creek, Kohl Creek, 

Collins Creek-Klamath River, Sambo Gulch-Klamath River, Middle Seiad Creek, Tom 

Martin Creek-Klamath River, Negro Creek, and Schutts Gulch-Klamath River 7th field 

watersheds. See Appendix A for vicinity and project treatment maps.

The 40,834-acres project area includes the area burned in the Gap Fire plus one-quarter 

mile around the fire perimeter to incorporate hazardous fuel reduction treatments and fuel 

breaks (also identified as “fuel management zones” in the final EIS) near structures on 

private property.

Management Areas within the Project Area

This project is our proposal to treat specific areas, based upon the management areas that burned 

within the Gap Fire. Each management area has a different goal that is pertinent to the project. 

Appendix A displays the different management areas and the preferred alternative treatments.

• Late successional reserves: The objective of late successional reserves is to protect and 

enhance conditions of late-successional and “old growth” forest ecosystems, which serve 

as habitat for late-successional and “old growth” related species including the northern 

spotted owl. These reserves are designed to maintain a functional, interacting, latesuccessional and “old growth” forest ecosystem.

• Special interest areas: Manage for ecological processes and the unique features for which 

the area was designated. Promote public use, education, interpretation, and enjoyment of 

the special interest values of the area when such activities do not harm the values for 

which the area was designated. Develop partnerships with local or regional groups to 

foster public education and enjoyment of these special resources and research 

opportunities where possible.

• Riparian reserves: Maintain and restore riparian-dependent structures and functions of 

intermittent streams. Provide benefits to riparian-dependent and associated species other 
—Draft Record of Decision—

Page 4

than fish, enhance habitat conservation for organisms that are dependent on the transition 

zone between upslope and riparian areas, improve travel dispersal corridors for many 

terrestrial animals and plants and provide for greater connectivity of the watershed. 

Provide connectivity corridors among the late successional reserves. Be consistent with 

aquatic conservation strategy goals.

• Retention visual quality: Provide a level of attractive, forested scenery by maintaining the 

areas in a natural or natural-appearing condition. Manage human activities so they are 

subordinate to the characteristic landscape. Also manage human activities so they are not 

evident to the casual Forest visitor. Manage for a programmed, sustained harvest of wood 

products in areas that are capable, available, and suitable for timber management. 

Maintain stand health, as well as resilience to wildland fire, insect, disease, and other 

damage.

• Designated and recommend recreational rivers: Preserve the recreational rivers in a freeflowing condition. Protect the rivers and their immediate environments for the benefit 

and enjoyment of present and future generations. Protect and enhance the outstandingly 

remarkable value(s) for which the river(s) are or would be designated, while providing 

for public recreation and resource uses that do not adversely impact or degrade those 

values. Management recreation activities to assure that the character and quality of 

recreation use would not cause adverse impacts on the resource values for which the 

rivers were designated or recommended.

• Partial retention visual quality: Provide an attractive, forested landscape where 

management activities remain visually subordinate to the character of the landscape. 

Manage human activities so they are subordinate to the character of the landscape. 

Manage for a sustained yield of wood products in areas capable, available, and suitable 

for timber production. Maintain stand health as well as resilience to wildland fire, insect, 

disease, and other damage.

• General forest: Provide a programmed, non-declining flow of timber products, 

sustainable through time. These levels may vary year to year, based on ecological 

processes. Maintain conifer stocking levels and high growth rates commensurate with the 

capability of the site to produce wood fiber. Intensively manage young regenerated stands 

to maximize growth potential. Maintain stand health, as well as resilience to wildland 

fire, insect, disease, and other damage. Emphasize salvage and restoration from 

catastrophic events. Reforest capable, but currently non-stocked, lands. Emulate 

ecological processes and stand and landscape patterns where possible. Within harvest 

units, maintain appropriate structure, composition, and ecological functioning of the area. 

Provide for snags and hardwood habitat to help maintain viable populations of wildlife 

species that require these structural components. Meet the visual quality objectives. 

Achieve less modified visual conditions when possible. Develop a transportation system 

to transport Forest commodities efficiently to available markets. Where possible, adjust 

planting levels to reduce pre-commercial thinning and fuel hazard costs in the future.

Management areas within the project area are shown in Table 1 below. 

Table 1. Management areas found within the project boundary.
—Draft Record of Decision—

Page 5

Management 

Area

Acres 

(percent) 

of 

Project 

Area

Pages 

in 

Forest 

Plan

Goals Pertinent to This Proposal

Management Area 

5 – Special 

Habitat – Late 

Successional 

Reserves

10,153 

(40)

4-82 to 

4-89

The objective of late successional reserves is to protect 

and enhance conditions of late-successional and “old 

growth” forest ecosystems, which serve as habitat for latesuccessional and “old growth”-related species including 

the northern spotted owl. These reserves are designed to 

maintain a functional, interacting, late-successional and 

“old growth” forest ecosystem.

Management Area 

7 – Special 

Interest Areas 

(Horse Creek 

Botanical Area 

and Condrey 

Mountain 

Blueschist 

Geologic Area)

362 (1) 4-97 to 

4-100

Manage for ecological processes and the unique features 

for which the area was designated.

Promote public use, education, interpretation, and 

enjoyment of the special interest values of the area when 

such activities do not harm the values for which the area 

was designated.

Develop partnerships with local or regional groups to 

foster public education and enjoyment of these special 

resources and research opportunities where possible.

Management Area 

10 – Riparian 

Reserves

6,492 

(25)

4-106 

to 4-

114

Maintain and restore riparian-dependent structures and 

functions of intermittent streams.

Provide benefits to riparian-dependent and associated 

species other than fish, enhance habitat conservation for 

organisms that are dependent on the transition zone 

between upslope and riparian areas, improve travel and 

dispersal corridors for many terrestrial animals and plants 

and provide for greater connectivity of the watershed. 

Provide connectivity corridors among the late 

successional reserves.

Be consistent with Aquatic Conservation Strategy goals.

Management Area 

11 – Retention 

Visual Quality 

Objective

1,536 (6) 4-115 

to 4-

116

Provide a level of attractive, forested scenery by 

maintaining the areas in a natural or natural-appearing 

condition. Manage human activities so they are 

subordinate to the characteristic landscape. Also manage 

human activities so they are not evident to the casual 

Forest visitor.

Manage for a programmed, sustained harvest of wood 

products in areas that are capable, available, and suitable 

for timber management.

Maintain stand health, as well as resilience to wildland fire, 

insect, disease, and other damage.
—Draft Record of Decision—

Page 6

Management 

Area

Acres 

(percent) 

of 

Project 

Area

Pages 

in 

Forest 

Plan

Goals Pertinent to This Proposal

Management Area 

13 – Designated 

and Recommend 

Recreational 

Rivers

1,220 (5) 4-120 

to 4-

122

Preserve the Recreational Rivers in a free-flowing 

condition. Protect the rivers and their immediate 

environments for the benefit and enjoyment of present 

and future generations.

Protect and enhance the outstandingly remarkable 

value(s) for which the river(s) are or would be designated, 

while providing for public recreation and resource uses 

that do not adversely impact or degrade those values.

Management recreation activities to assure that the 

character and quality of recreation use would not cause 

adverse impacts on the resource values for which the 

rivers were designated or recommended.

Management Area 

15 – Partial 

Retention Visual 

Quality Objective

4,939 

(19)

4-126 

to 4-

127

Provide an attractive, forested landscape where 

management activities remain visually subordinate to the 

character of the landscape. Manage human activities so 

they are subordinate to the character of the landscape.

Manage for a sustained yield of wood products in areas 

capable, available, and suitable for timber production.

Maintain stand health as well as resilience to wildland fire, 

insect, disease, and other damage.

Management Area 

17 – General 

Forest

3,442 

(14)

4-131 

to 4-

132

Provide a programmed, non-declining flow of timber 

products, sustainable through time. These levels may vary 

year to year, based on ecological processes. Maintain 

conifer stocking levels and high growth rates 

commensurate with the capability of the site to produce 

wood fiber. Intensively manage young regenerated stands 

to maximize growth potential.

Maintain stand health, as well as resilience to wildland fire, 

insect, disease, and other damage. Emphasize salvage 

and restoration from catastrophic events. Reforest 

capable, but currently non-stocked, lands.

Emulate ecological processes and stand and landscape 

patterns where possible. Within harvest units, maintain 

appropriate structure, composition, and ecological 

functioning of the area.

Provide for snags and hardwood habitat to help maintain 

viable populations of wildlife species that require these 

structural components.

Meet the visual quality objectives. Achieve less modified 

visual conditions when possible.

Develop a transportation system to transport Forest 

commodities efficiently to available markets.

Where possible, adjust planting levels to reduce precommercial thinning and fuel hazard costs in the future.
—Draft Record of Decision—

Page 7

Purpose and Need

Over the coming decades, snags (dead trees) created by the Gap Fire will break or fall and 

become ground fuels. As snags continue to decay, break, and fall, surface fuel loading and the 

severity and intensity of future fires will increase. Increased fire intensities and fallen snags will 

inhibit the effective control of future fires and put fire suppression crews at increased risk. Fallen 

hazard trees will also impact road access along miles of roadways, impairing fire suppression 

efforts and our flexibility to manage natural fire to reduce hazardous fuels. Local communities 

and residential enclaves are nestled within and adjacent to forests that are part of a larger fireadapted ecosystem. Hazardous trees and fuel conditions need to be abated where they exist 

within the wildland urban interface, especially within one-quarter mile of private property in 

burned areas, and areas identified as strategic. Strategic areas are where there is a greater 

likelihood that fires can be successfully contained or controlled in order to have better conditions 

for suppressing future fires. The goal is to protect the lives and properties of our local 

communities.

• Since the Gap Fire created unsafe conditions, the project will address the need for safety of 

the public, adjacent private landowners, forest workers, and firefighters.

• Within general forest and associated management areas, there is a need to recover timber 

volume from fire killed trees, reduce the probability and extent of future high-severity fire, 

and develop fire-resilient coniferous forests in severely burned areas.

• Within late-successional reserves and the Horse Creek Special Interest Area, there is a need 

for reduced fuels to decrease the risk of future large-scale high severity fire and loss of late 

successional habitat and for fire-resilient coniferous forest areas to meet the desired 

conditions described in the Forest Plan.

See the Chapter 1, Purpose and Need for Action section of the FEIS for more details. 

2. DECISION

The Selected Alternative

[This section may be updated prior to my decision in order to reflect the latest information.]

Based on the analysis presented in the final EIS, supporting documentation, and review of 

tribal, public, and other agency input, I have decided to implement Alternative 4 (the 

preferred alternative) as the draft selected alternative. Alternative 4 was developed 

internally to meet the purpose and need and further reduce the effects to the northern 

spotted owl. Project actions were adjusted or removed in this alternative in areas that are 

more likely to be used by northern spotted owls. Each northern spotted owl activity center 

was evaluated to determine if it was a high value activity center, meaning it was an activity 

center more likely to support reproduction and contribute towards the species’ recovery. 

Within high value activity center core use areas, this alternative removes salvage harvest, 

reduces roadside hazard along dead-end roads, reduces roadside fuels, and minimizes the 

fuel management zone footprint. This alternative also reduces the amount of roadside fuels 

treatments within suitable northern spotted owl habitat and removes salvage units within 

the high value core use areas.
—Draft Record of Decision—

Page 8

For a full description of this alternative and a detailed comparison with other alternatives 

considered, see Chapter 2 of the FEIS. See the treatment maps in Appendix A. The selected 

alternative incorporates the implementation of project design features and best management 

practices which are shown in Appendix B of this draft ROD and Chapter 2 and Appendix C

of the FEIS.

Table 2 below summarizes the acres by treatment type of the selected alternative. 

Table 2. Treatment Types and Areas of the Selected Alternative.

Treatment Type Area

Roadside Hazard Tree Removal 87 miles

Roadside Fuels 315 acres

Fuels Reduction Adjacent to Private Property 1,412 acres

Developing and Maintaining Fuels Management Zones 684 acres

Salvage Harvest with Site Preparation and Planting 1,680 acres

Site Preparation and Planting without Salvage 458 acres

Restoration Activities in the Horse Creek Special Interest 

Area

184 acres

Project implementation is scheduled to begin in fall 2017 and will last about ten years. To 

facilitate treatment prescriptions, less than five miles of temporary roads will be needed. 

Seven existing temporary roads (2.44 miles) and 10 new (2.18 miles) temporary roads will 

be needed for short-term access to the project. These will be hydrologically stabilized 

following project completion. Existing landings will be used to the extent possible.

Pursuant to 36 CFR 218, this project is subject to a pre-decisional administrative review (or 

objection) process. More information on the results of the objection resolution is provided in 

the Public Involvement section of this ROD. 

I chose the Selected Alternative because it meets all the elements of the Project’s purpose

and need (final EIS, Chapter 1, pp. 14-18) and is also the environmentally preferable 

alternative (as described below).

The Selected Alternative is intended to strike a balance between the needs to provide public 

safety, recover timber value to accomplish needed work, reduce hazardous fuels to 

decrease the probability and extent of future high-severity fire, reestablish fire-resilient 

coniferous forests in severely burned areas, restore ecological functions within the Horse 

Creek Botanical Area, and minimize possible short-term impacts of implementation on 

northern spotted owls.

Actions that are part of the Selected Alternative

1) Roadside Hazard Tree Removal (87 miles)

Trees adjacent to National Forest System roads or along county roads adjacent to National Forest 

System lands within the project area will be evaluated for hazards. Three different assessments 
—Draft Record of Decision—

Page 9

will be made to determine roadside hazard trees, and within riparian reserves, identified hazard 

trees will be further evaluated to determine if they are removed or felled and left on site, as 

described below.

First, we will identify any existing trees that pose a moderate or high risk hazard to the roadway 

using the criteria Report #RO-12-01 “Hazard Tree Guidelines for Forest Service Facilities and 

Roads in the Pacific Southwest Region” (Angwin et al. 2012). This report provides guidance on 

whether or not the tree is a hazard to a road. A tree can be fire-killed, green with a high hazard 

potential, or not fire affected but dead with a high hazard potential. Trees identified as having 

high hazard potential would be marked for cutting, and either removed or abated and left on site 

where necessary to meet the requirements of the Forest Plan. Trees identified as having a 

moderate hazard would be monitored and evaluated for possible future removal.

Second, for trees under 40 inches in diameter, we will identify any fire-injured trees that have a 

70 percent probability of dying in the next three to five years using the criteria in Report #RO11-01 “Marking Guidelines for Fire-Injured Trees in California” (Smith and Cluck, 2011). Those 

fire-injured trees that have 70 percent or greater probability of mortality would be considered 

potential hazards and would be marked for cutting, and either removed or abated and left on site 

if necessary to meet the requirements of the Forest Plan (e.g., for hazard trees within riparian 

reserves, as described below).

Third, for trees equal to or greater than 40 inches in diameter, we will identify any fire-injured 

trees that have a 90 percent probability of dying in the next three to five years using the criteria 

in Report #RO-11-01 “Marking Guidelines for Fire-Injured Trees in California” (Smith and 

Cluck, 2011). Those fire-injured trees that have 90 percent or greater probability of mortality 

would be considered potential hazards and would be marked for cutting, and either removed or 

left on site if necessary to meet the requirements of the Forest Plan (e.g., for hazard trees within

riparian reserves, as described below).

In stream course riparian reserves, all hazard trees will be felled according to the hazard 

evaluation described above; the difference is in what happens to a hazard tree once it has been 

felled. Within stream course riparian reserves, roadside hazard trees equal to or greater than 24 

inches diameter at breast height will be felled and left on site if the following criteria are met: 1) 

the faller can safely fell the hazard tree away from the road without causing excessive damage to 

residual tree crowns or boles; 2) removal would cause excessive soil disturbance such as 

gouging; 3) the tree does not lean towards the road; 4) once fallen the tree would not disrupt flow 

through a drainage structure; 5) where leaving the felled tree would not contribute to or cause 

excessive fuel loading (this threshold may be met sooner in areas identified for fuels reduction); 

and 6) felled trees that are the furthest from the road, below the road, and on steeper slopes 

below the road will be favored for leaving. Hazard trees in stream course riparian reserves where 

these criteria are not met, or that are less than 24 inches in diameter at breast height, will be 

felled and removed.

Removal of merchantable roadside hazard trees would include the use of ground-based and 

skyline logging systems. Non-merchantable trees would be cut and left when they are not along a 

road defined as strategic for fire suppression and needing fuels treatment. These nonmerchantable trees would be piled and burned where the treatment is along a strategic road for 

roadside fuels treatments, described below. Per agency policy, the public may obtain a permit to 

remove felled trees for firewood in accordance with permit requirements. The agency anticipates 
—Draft Record of Decision—

Page 10

the local public would remove firewood along roadways, especially near the communities of 

Horse Creek and Seiad Valley, California.

See the discussion in the FEIS of roadside hazard tree abatement in the Special Interest Area for 

additional criteria that apply to roadside hazard only in that land allocation. No roadside hazard 

tree removal is proposed within inventoried roadless areas.

Roadside hazards would be identified using the methods above, but some spur roads will not be 

treated as they are located in high valued core areas for the northern spotted owl. See the map in 

Appendix A for exact locations of treatments. 

Specific prescriptions for the selected alternative include:

Roadside Hazard 1 (39 miles)

• Hazards to the roads would be identified using both the mortality and hazard tree

guidelines. These hazards would be abated as proposed above.

Roadside Hazard 2 (48 miles)

• All hazards would be abated as proposed above, except that different criteria will be used 

within northern spotted owl critical habitat or late successional reserves to determine 

when to leave felled trees on site. Within these areas, all hazard trees 40 inches and 

greater in diameter or fire injured trees (using the 90 percent probability of mortality) will 

be left on site except where it would be unsafe for the faller to direct the tree away from 

the road or where the fallen tree presents a direct hazard to the road. There is no attempt 

in this design feature to leave identified hazards standing; the hazards must be abated.

2) Roadside Fuels Treatment (315 acres)

The National Forest System Road 46N60 would receive treatment within 150 feet on either side 

of the road. The 12 Road and 46N50 Road (part of the modified proposed action) would not 

receive this treatment. Treatments will still meet the purpose and need of the project but will 

reduce effects to the northern spotted owl in high valued core areas.

To maintain strategic ingress and egress roads and to decrease the amount of activity-generated 

fuels in hazard tree removal areas, we propose to remove dead vegetation up to 18 inches 

diameter at breast height as well as small diameter live understory vegetation including live 

conifer trees up to 8 inches diameter at breast height and live hardwoods up 6 inches in diameter. 

Pruning retained conifers up to seven feet high within these zones would increase canopy base 

height and reduce the potential for crown fire initiation. Activity-generated fuels would be 

disposed of by a variety of methods, including manual and mechanical treatments, to meet 

desired conditions. Every piece of ground will be different, but in general the fuels reduction 

would use a spacing of 15 feet, keeping the larger, healthier trees in place. Where roadside fuels 

treatment crosses riparian reserves, no vegetation that provides effective shade to the stream 

channel or floodplain will be cut.

Specific prescriptions include:

Roadside Fuels 1:

• 150 feet on either side of the road;
—Draft Record of Decision—

Page 11

• Cut dead trees up to 18 inches diameter at breast height and pile and burn fuels up to the 

size class that is possible given implementation methods;

• Cut live conifer trees up to 8 inches diameter at breast height with 15 foot spacing and 

pile and burn fuels;

• Cut hardwoods up to 6 inches diameter at breast height, maintaining 20 to 25 foot spacing 

between cut trees; and

• Prune retained conifer trees up to seven feet high.

3) Fuels Reduction Adjacent to Private Property (1,412 acres) 

Fuels reduction treatments are proposed within the 500 feet of National Forest System lands 

adjacent to private property with an existing structure or that had a structure that was affected by 

the fire. Treatment would include removing dead vegetation up to 14 inches in diameter at breast 

height and live understory vegetation, including conifer trees up to 12 inches in diameter at 

breast height, and live hardwoods up to 6 inches in diameter, to reduce fire behavior activity, 

specifically reduced flame length and crown fire potential and intensity, to meet desired 

conditions. Pruning retained conifers up to seven feet high within this zone is proposed to 

increase canopy base height and reduce the potential for crown fire initiation. Activity-generated 

fuels would be disposed of by a variety of methods, including manual and mechanical 

treatments, to meet the desired conditions. Every piece of ground will be different, but in general 

the fuels reduction would use a spacing of 20 to 25 feet, keeping the larger, healthier trees in 

place. Where fuel reduction adjacent to private property prescriptions cross riparian reserves, no 

vegetation that provides effective shade to the stream channel or floodplain will be cut.

The fuels reduction units adjacent to private property have three prescriptions throughout the 

project area. All three treatments will still meet the purpose and need of the project but will 

reduce effects to the northern spotted owl in high valued core areas.

Specific prescriptions include:

Private Property 1 (1,064 acres): same as above

Private Property 2 (329 acres):

• Cut live trees up to 8 inches diameter at breast height with 20 to 25 foot spacing, pile and 

burn fuels; and

• Cut dead trees up to 12 inches diameter at breast height, pile and burn fuels up to the size 

class that is possible given the implementation methods.

Private Property 3 (19 acres):

• Cut live trees up to 8 inches diameter at breast height with 15 foot spacing. Leave trees 

should be left in a clumped fashion over at least ten percent of the unit. Pile and burn the 

fuels; and

• Cut dead trees up to 10 inches diameter at breast height, pile and burn fuels.

4) Developing and Maintaining Fuels Management Zones (684 acres)

During the Gap Fire, strategic dozer lines built during the Beaver Fire in 2014 or from past 

wildfires were reopened. Strategic ridge systems, many containing historic firelines already in 
—Draft Record of Decision—

Page 12

place, would be maintained by removing dead vegetation up to 18 inches diameter at breast 

height and small diameter live understory vegetation including live conifer trees up to 12 inches 

diameter at breast height, and live hardwoods up to 6 inches in diameter. Pruning retained 

conifers up to seven feet high within these zones is proposed to increase canopy base height and 

reduce the potential for crown fire initiation. Activity-generated fuels would be disposed of by a 

variety of methods, including manual and mechanical treatments, to meet desired conditions. 

These treatments are located on ridgetops and should not intersect with riparian reserves, 

however, if fuel management zones cross riparian reserves, no vegetation that provides effective 

shade to the stream channel or floodplain will be cut.

The fuel management zone would be the same footprint as proposed above except for the fuels 

management zones between Hicks Gulch and Negro Creek. Although the same number of acres 

of fuels treatment would occur as in the proposed action, the fuels management zones between 

Hicks Gulch and Negro Creek are slightly shifted to position the fuels management zone more 

on the southern aspect. Each segment of the fuel management zones would receive one of three 

possible prescriptions (fuels zone 1, fuels zone 2, or fuels zone 3).

Specific prescriptions:

Fuels Zone 1 (342 acres): same as above

Fuels Zone 2 (319 acres):

• Cut live trees up to 8 inches diameter at breast height with 20 to 25 foot spacing, pile and 

burn fuels; and

• Cut up to 18 inches diameter at breast height. For dead trees up to 16 inches at breast 

height, pile and burn the fuels up to the size class that is possible given he 

implementation methods. Leave cut dead trees 16 inches to 18 inches at breast height on 

site as woody debris; leave whole when possible.

Fuels Zone 3 (23 acres):

• Prescription is applied only to the existing dozer line footprint for three fuel management 

zone segments; and

• In these three segments, the dozer line would be maintained by removing brush and trees 

up to 8 inches diameter at breast height. The fuels would be piled and burned.

5) Salvage Harvest with Site Preparation and Planting (880 acres Ground-based and 800 

acres Skyline (Cable)).

• To reduce potential effects on spotted owl habitat, 363 acres of salvage harvest units in 

certain spotted owl activity centers would be deleted from the project, and an additional 

52 acres of snag retention areas within remaining units would be added. Otherwise, this 

alternative is the same as that of the proposed action, below.

Standing dead trees 14 inches in diameter at breast height or greater would be considered for 

salvage using the guidelines in Report #RO-11-01 “Marking Guidelines for Fire-Injured Trees in 

California” (Smith and Cluck 2011). Fire-killed and fire-injured trees with a 70 percent or 

greater probability of dying within the next three to five years would be considered for salvage 

harvest. The “Marking Guidelines for Fire-Injured Trees in California” also addresses the 

evaluation of trees with signs of insect activity. Trees with this evidence will be removed as 
—Draft Record of Decision—

Page 13

described by the guidelines.

Trees identified as hazards using the “Hazard Tree Guidelines for Forest Service Facilities and 

Roads in the Pacific Southwest Region” along roads within salvage units will be felled to abate 

the hazard. 

Snags for wildlife will be retained based on 100-acre landscape areas according to numerical and 

diameter standards in the Forest Plan (p. 4-26). In any 100-acre area, snags within and outside 

salvage harvest units may contribute to these standards. Within harvest units, snags will be 

retained in all riparian reserves (stream and inner gorges) and in clumps in designated snag 

retention areas as necessary to meet these standards. Individual snags within harvest units will 

not be retained unless they have high quality habitat characteristics such as signs of decay and 

defect, cavities, broken or multiple tops, very large lateral branches and flattened canopy. In 

order to contribute to Recovery Action 12, very large snags that have these characteristics and 

are likely to persist until the next stand is capable of producing large snags should be retained 

wherever they occur, provided safety considerations can be addressed. If a wildlife snag must be 

felled for safety reasons, the entire tree will be left in place and shall not be bucked into smaller 

logs.

Salvage logging treatments would be accomplished by a combination of ground-based and 

skyline logging systems. Seventeen temporary roads (ten new (2.18 miles) and seven existing 

(2.44 miles)) will be needed to access salvage units. All salvage units would be reforested as 

described in the site-preparation and planting section below.

No salvage harvest is proposed within wilderness, backcountry, research natural areas, 

designated or recommended wild rivers, inventoried roadless areas, or riparian reserves. 

Proposed salvage units are shown in Table 3. Additional information about the logging systems 

used, please refer to the supplementary report on logging systems available in the project record.

Table 3. Summary of Salvage Units

Unit # Logging 

System

Temporary 

Roads Management Areas

Gross 

Area 

(acres)

Snag

Retention 

(acres)1

Net Area 

(acres)

115.31 Tractor N/A LSR 47 0 47

115.32 Cable N/A LSR, Riparian Reserve2 64 5 59

115.33 Cable N/A LSR, Riparian Reserve2 117 25 92

115.34 Tractor N/A LSR, Riparian Reserve2 130 9 121

115.35 Cable N/A LSR 85 1 84

115.36 Cable N/A LSR, Riparian Reserve2 52 5 47

116.49 Cable N/A

Partial Retention VQO, 

Recreational River, 

Retention VQO, Riparian 

Reserve2

144 12 132

116.50 Tractor N/A

General Forest, Partial 

Retention VQO, Riparian 

Reserve2

86 34 52

117.14 Tractor N/A General Forest, Retention 

VQO 25 0 25
—Draft Record of Decision—

Page 14

Unit # Logging 

System

Temporary 

Roads Management Areas

Gross 

Area 

(acres)

Snag

Retention 

(acres)1

Net Area 

(acres)

117.15 Cable New

General Forest, Partial 

Retention VQO, Retention 

VQO, Riparian Reserve2

57 1 56

117.16 Tractor New

General Forest, Partial 

Retention VQO, Retention 

VQO

34 0 34

117.17 Tractor N/A General Forest 39 0 39

117.18 Tractor N/A General Forest, Partial 

Retention VQO 14 0 14

117.19 Tractor N/A General Forest, Riparian 

Reserve2 30 1 29

117.20 Cable N/A

General Forest, Partial 

Retention VQO, Riparian 

Reserve2

28 16 12

117.21 Tractor N/A

General Forest, Partial 

Retention VQO, Riparian 

Reserve2

41 10 31

117.22 Tractor N/A General Forest, Partial 

Retention VQO 24 0 24

117.23 Tractor New

General Forest, Partial 

Retention VQO, Riparian 

Reserve2

180 33 147

117.24 Tractor Existing 

Roadbed

General Forest, Partial 

Retention VQO, Riparian 

Reserve2

61 5 56

118.03 Tractor New

Partial Retention VQO, 

Retention VQO, Riparian 

Reserve2

48 7 41

118.04 Cable New

Partial Retention VQO, 

Retention VQO, Riparian 

Reserve2

67 22 45

118.05 Cable Existing 

Roadbed

Partial Retention VQO, 

Retention VQO, Riparian 

Reserve2

33 1 32

118.06 Cable New

General Forest, Partial 

Retention VQO, Retention 

VQO, Riparian Reserve2

31 4 27

118.07 Tractor N/A

General Forest, Partial 

Retention VQO, Riparian 

Reserve2

44 4 40

118.09 Tractor N/A Partial Retention VQO 16 0 16

118.12 Cable New General Forest 13 0 13

118.26 Tractor Existing 

Roadbed

General Forest, Partial 

Retention VQO, Riparian 

Reserve2

32 6 26
—Draft Record of Decision—

Page 15

Unit # Logging 

System

Temporary 

Roads Management Areas

Gross 

Area 

(acres)

Snag

Retention 

(acres)1

Net Area 

(acres)

118.27 Tractor Existing 

Roadbed

General Forest, Partial 

Retention VQO, Riparian 

Reserve2

23 3 20

118.57 Cable N/A

General Forest, Partial 

Retention VQO, Riparian 

Reserve2

127 60 67

118.58 Tractor

Existing 

Roadbed 

and New

General Forest, Partial 

Retention VQO 149 0 149

118.59 Tractor New Partial Retention VQO, 

Riparian Reserve2 41 1 40

118.60 Tractor N/A Partial Retention VQO 24 0 24

118.62 Cable N/A Partial Retention VQO, 

Riparian Reserve2 28 4 24

118.63 Tractor N/A Partial Retention VQO 50 0 50

118.64 Cable N/A Partial Retention VQO, 

Riparian Reserve2 59 3 56

Totals: 2,043 272 1,771

• 1Snag retention is riparian reserves and geologic riparian reserves.

• 2Acres shown in riparian reserves are snag retention areas within the unit boundaries. There is no 

proposed salvage harvest in stream-related riparian reserves within salvage units. 

• VQO = Visual Quality Objective

6) Site Preparation and Planting (without salvage) (458 acres) 

Forest stands selected for site preparation and tree planting are predominately plantations 

composed of standing dead trees generally under 16 inches in diameter at breast height. Both 

manual and mechanical methods would be used to cut or masticate standing dead trees 

depending on slope steepness, accessibility, and feasibility. Dead vegetation within plantations 

will be strategically cut, piled, and burned to prepare the site for reforestation activities. Some 

dead vegetation may be left standing on harsh sites to improve survival of seedlings by creating 

shade. Hardwood species that resprout after being top-killed by fire will not be intentionally 

removed from the stand and seedlings will be planted outside of the dripline of the resprouting 

hardwoods. Resprouted shrubs may also be cut, piled, and burned for site preparation. Activitygenerated fuels would be treated using a variety of methods including piling and burning, 

underburning, or lop and scattering.

Reforestation would be accomplished by directly planting nursery-grown seedlings or by 

allowing natural regeneration. Tree species and spacing would depend on a variety of 

environmental factors, including considerations of climate change, elevation, slope steepness, 

slope position, aspect, and soil productivity. Reforestation would avoid creation of denselystocked plantations that would prevent the reintroduction of low-intensity prescribed fire at a 

later date by planting with variable densities to create highly textured stands with clumps and 

small openings. Seedling survival rates and competition from brush species will create a natural 

mosaic of species and stocking densities. Hardwoods would be considered when determining 

whether desired stocking objectives have been met.
—Draft Record of Decision—

Page 16

Conifer seedlings would be released in the season following planting; if necessary, additional 

release would occur to provide for establishment. Manual release would include clearing woody 

herbs and small brush in a radius around selected trees. If the site is south-facing or droughty, 

dead vegetation may be strategically left on the south-side of the tree to moderate heat stress, 

especially in the first release.

7) Restoration Activities in the Horse Creek Special Interest Area (184 acres) 

Treatment within the Horse Creek Special Interest Area includes hazard tree removal, placing 

trees with or without rootwads attached into the stream channel, and planting hardwood and 

conifers within the riparian reserves.

The Horse Creek Botanical Area is located on the main stem of Horse Creek between Crawfish 

Gulch and Hamburg Gulch. It parallels the creek, spanning both sides and encompassing the 

riparian zone and some of the adjoining hillside. It was selected for Administrative Withdrawal 

as a Special Interest Area (SIA) for its unique characteristic as an intact and highly diverse oldgrowth riparian ecosystem. Located near the community of Horse Creek, California, it is easily 

accessed by vehicle and little-to-no hiking is required for visitors to observe and appreciate the 

unique characteristics of the area. Prior to the Gap fire, the riparian zone was dominated by 

bigleaf maple and white alder, with large old-growth conifers interspersed throughout. Conifers 

in the SIA include Douglas-fir, ponderosa pine, sugar pine, incense-cedar, and white fir. Unlike 

most botanical areas, the Horse Creek Botanical Area is not known to contain any federallylisted or protected botanical species.

The entirety of the Horse Creek Botanical Area was affected by the 2016 Gap Fire. While the 

upstream half experienced only light to moderate fire severity, the downstream half below the 

confluence of Fish Gulch Creek was particularly impacted by the fire, with large portions 

experiencing moderate to high fire severity. The downstream area suffered large losses of both 

overstory and ground vegetation. Much of the conifer and riparian hardwood forest in the lower 

third of the Botanical Area has been lost. The resulting altered condition has triggered the need 

to initiate restoration efforts to allow the area to return to the condition for which it was 

designated a special interest area.

Forest Service Road 46N50 runs parallel to Horse Creek throughout the entirety of the Botanical 

Area. This road is crucial to the communities of Horse Creek and Seiad Valley as the main 

egress and ingress route for residents in Horse Creek and Seiad Valley if State Highway 96 

closes (due to wildfire, flooding, road damage, etc.) As a result of the widespread damage to 

trees caused by the 2016 Gap Fire, there is a need to reduce the hazard of dead trees falling on 

this frequently travelled route.

Under this proposed action hazard trees in the Horse Creek Botanical Area would first be 

identified and marked by the district foresters along the 46N50 and 47N77 roads. Specialists

(botanist, fisheries, and hydrologist) would then select which hazard trees would be the best 

candidates for use in restoration projects. The hazard trees selected by resource specialists would 

be used as 1) in-stream large woody debris; 2) forest coarse woody debris; or 3) stockpiled for 

future restoration work. Hazard trees not meeting these needs would either be removed as a 

forest product or moved to a cull deck to be used as firewood or burned. If needed, specific 

details such as directional falling and wood placement criteria will be determined by resource 

specialists.
—Draft Record of Decision—

Page 17

Selected hazard trees would be felled or uprooted and placed within the Botanical Area as part of 

the restoration effort. Hazard trees not uprooted would be felled in such a way as to disguise 

signs of felling. Where practical, explosives would be used for uprooting and falling trees as well 

as for stump obliteration. Hazard trees would not be uprooted where they are located on road fill 

slopes since such action would destabilize the road prism, potentially causing slope failure and 

sediment discharge into Horse Creek.

Within the Horse Creek Botanical Area, trees possessing either a combination of high quality 

wildlife habitat characteristics or having a minimum diameter at breast height of 40 inches will 

be subject to a 90 percent probability of mortality standard. Trees under 40 inches diameter at 

breast height will be subject to the 70 percent probability of mortality standard according to the 

roadside hazard tree removal treatment unless they demonstrate high quality wildlife habitat 

characteristics. For trees under 40 inches diameter at breast height to be subject to a 90 percent 

probability of mortality standard, at least two of the following high quality wildlife habitat 

characteristics must be present: 1) flat-topped crown that is not the result of mechanical damage; 

2) very thick bark (3 inches plus) with fissures closed over (for Douglas-fir, white fir, and red fir) 

or large flat bark plates at least 4 inches across (for ponderosa pine) or at least 2 inches across 

(for sugar pine); and 3) large limb size (8 inches plus in diameter).

Mainstem Horse Creek, including the section of mainstem that runs through the Special Interest 

Area, is critical habitat for federally-listed Southern Oregon/Northern California Coho salmon

Coho salmon critical habitat in mainstem Horse Creek is considered to be in poor condition due 

to very high road density in the Horse Creek watershed that has resulted in excess sediment 

delivery to the mainstem and reduced the amount of large trees and woody debris available for 

natural recruitment into the mainstem. Long periods of fire exclusion coupled with extensive 

stand-replacement forestry is also a principal factor for the lack of large woody debris in 

mainstem Horse Creek.

Under this proposal, many of the large dead hazard trees within the Special Interest Area that 

will need to be fallen for public safety will be placed into mainstem Horse Creek to restore the 

large woody debris component of Coho salmon critical habitat. Conifer species are preferred 

over hardwood species for placement into the stream because conifers have a much slower rate 

of decomposition in water. Uprooted or felled snags up to 30 feet in length, with a minimum 

diameter of 24 inches at breast height would be placed in the channel of Horse Creek to improve 

aquatic habitat conditions. These in-stream logs would be placed at a rate of 20 pieces per 

stream-mile, according to site potential of reference streams on the Forest. They would be 

positioned in a manner to secure them in place, minimizing risk to downstream properties in the 

event of a flood.

Outside of the streambeds, fallen trees with a minimum diameter of 12 inches diameter at breast 

height would be left on the ground, optimally in full contact with the soil if possible, at a rate of 

up to 20 pieces per acre. These trees would be placed with the intention of creating beneficial 

ecological conditions to aid in restoration, while avoiding the creation of large accumulations of 

fuels or hazards to people visiting the botanical area. In areas of bare or severely-burned soil, 

fine organic material (typically fine branches or boughs harvested from fallen trees) would be 

used to achieve a minimum cover of 50 percent.

Wherever possible, trees to be placed in-stream or on the ground would be sourced from the 

immediate area in order to minimize the disturbance caused by moving large trees. If the number 
—Draft Record of Decision—

Page 18

of hazard trees within the Botanical Area exceeds the need of the area, the excess hazard trees 

equal to or greater than 24 inches in diameter at breast height would be collected and staged offsite for use in future aquatic habitat restoration projects. Access to the restoration area by heavy 

equipment such as excavators or skidders would be restricted to the 46N50 road and landings, in 

order to minimize soil impacts. Excess trees less than 24 inches in diameter at breast height 

would be included in the timber sale to help offset the cost of implementation or moved to a cull 

deck to be used as firewood or burned. Activities generated material will be hand piled and 

burned where such concentrations would create hazardous fuels loading.

As part of the restoration effort, portions of the Botanical Area would be planted or seeded with 

native, locally-sourced vegetation. This would be carried out with the intent to aid in the 

recovery process by:

• Restoring native species diversity;

• Accelerating development of large trees that can provide shade to the mainstem;

• Providing future recruitment of large woody debris; and

• Deterring invasion by non-native invasive plant species.

The species used in planting would consist of mostly riparian hardwood, shrub, and forb species, 

with some conifers and grasses if deemed necessary or appropriate. Non-native invasive plants

located within or near the Horse Creek Botanical Area would be treated manually or 

mechanically in order to prevent their spread into or within the area. Treatments would occur 

prior to, during, and after project implementation, with yearly repeated treatments as deemed 

necessary to achieve restoration goals.

Connected Actions

Connected actions are those actions that are an interdependent part of the Horse Creek 

Community Protection and Forest Restoration Project, and would not occur unless the Horse 

Creek Project is implemented.

Road Access

Project access will require the use of National Forest System, State, and County roads. Forest 

System roads will be maintained as needed for implementation as part of the regular Forest Road 

Maintenance program. There will be no roads added to the Forest System as a result of this 

Project. Seventeen temporary roads (ten new (2.18 miles) and seven existing (2.44 miles)) will 

be needed to access salvage units. All salvage units would be reforested as described in the sitepreparation and planting section above.

Landings

Existing landings from previous timber harvests will be used where possible. Landing size will 

be commensurate with operational safety. Cable and ground based logging systems will use the 

existing road prism as landings for logs wherever possible. Estimated individual landing size is 

between 0.1 and 1 acre. See project design features for protections regarding landings and postimplementation conditions (Appendix B).
—Draft Record of Decision—

Page 19

EnvironmentallyPreferable Alternative

The environmentally preferable alternative is often interpreted as the alternative that causes the 

least damage to the biological and physical environment or the alternative which best protects 

and preserves historic, cultural, and natural resources. Other factors relevant to this 

determination are provided in Section 101 of NEPA (42 USC 4321) which states that it is the 

continuing responsibility of the Federal Government to:

• Fulfill the responsibilities of each generation as a trustee of the

environment for succeeding generations;

• Assure for all Americans safe, healthful, productive, and aesthetically and

culturally pleasing surroundings;

• Attain the widest range of beneficial uses of the environment without

degradations, risk to health of safety, or other undesirable and unintended 

consequences;

• Preserve important historic, cultural and natural aspects of our national 

heritage and maintain, wherever possible, an environment which supports

diversity and variety of individual choice;

• Achieve a balance between population and resource use which will permit high

standards of living and a wide sharing of life’s amenities; and,

• Enhance the quality of renewable resources and approach the maximum 

attainable recycling of depletable resources.

Based on my consideration of the factors listed above and the effects disclosed in the final EIS, I 

believe that the Selected Alternative is the Environmentally Preferred Alternative. Although 

Alternatives 1, 2, 3, and the Karuk Alternative each had aspects that were suggested to be 

environmentally preferable, I ultimately do not believe they are environmentally preferable 

compared to the Selected Alternative. Alternative 1 would have no direct impacts (as it proposes 

no treatments) but it would result in undesirable negative environmental impacts in the future. 

An example of future undesirable environmental impacts would be an increased probability of 

high severity fire across the landscape due to untreated dead and dying fuels created by the Gap 

Fire. Alternatives 2 and 3 were also less desirable from an environmentally preferred standpoint, 

as the mix of treatments included in each would not result in as great an overall environmental 

benefit as the selected alternative. Alternative 2 would treat an increased amount of fire-affected 

landscape, further reducing the probability of future high severity fire impacts, but this benefit 

would be tempered by short-term environmental effects to endangered species. Alternative 3 

would treat fewer acres of fire-affected landscape, which would not contribute as well to 

decreasing the probability of high severity fire impacts in the future. Although Alternative 3 

would have fewer impacts to Coho salmon, because of existing conditions after the Gap Fire, it 

would still have the same Likely to Adversely Affect determination as Alternatives 2, 4, and the 

Karuk Alternative. It also had greater short-term effects to northern spotted owls. The Karuk 

Alternative was also less desirable from an environmentally preferred standpoint, as it does not 

contribute as much as the selected alternative to reducing the probability of future high severity 

fire. It also has greater environmental effects to endangered species due to inclusion of increased 

treatments to “green” fuel break areas within critical habitat for the northern spotted owl, which 

are estimated to downgrade an additional 80 acres of critical habitat. The Karuk Alternative also 
—Draft Record of Decision—

Page 20

proposes a decreased amount of reforestation, thus achieving a reduced environmental benefit 

from the accelerated re-establishment of forested conditions in larger blocks of high severity fireaffected areas. 

For more specific information on each Alternative’s respective impacts, please refer to the

effects analysis for each resource within Chapter 3 of the FEIS. 

Reasons why Alternative 4 is Environmentally Preferable

In addition to consideration of the guidance above, I believe that Alternative 4 is the 

environmentally preferable alternative because it:

• Best provides for the long-term management of the project area in a manner

consistent with the Forest Plan of the Klamath National Forest.

• Removes hazard trees to provide for public safety and Forest Service employee

safety which includes firefighters accessing the area in possible future fires.

• Reduces the size and continuity of future fuels conditions, providing for more

resilient forested conditions and reduced high-severity wildfire fire risk for the

benefit of community protection and wildlife and watershed habitat.

• Includes salvage harvest treatments that complement proposed fuel reduction and

strategic fuel management zones as part of a landscape-scale strategy to reduce the

size and severity of future fires. Creates large blocks where fuel loads have been

reduced; in concert with ridgetop fuel breaks it provides control points for fire 

suppression and increases the likelihood that large fires could be contained along

watershed boundaries. Reduces the size and severity of future fires, serves to 

reduce risk to wildlife habitat and improves the likelihood of firefighting success.

Salvage harvest would also promote ecosystem sustainability by increasing the

likelihood and speed by which burned forested areas are reforested by opening 

areas for safe planting.

• Provides an excellent means of capturing economic value through salvage logging

in a cost-effective way while simultaneously providing for other important project

objectives. The actions implemented by this decision will generate revenues

through the sale of salvaged timber to offset the need for public expenditures

through Congressional appropriation to create a safe environment for current and

future public use.

• Includes additional protective measures beyond the minimum required by the

Forest Plan and agency policy for the protection of watershed conditions and

federally-listed species. This alternative is designed to strike a reasonable balance 

between minimizing short-term impacts on some species and long-term

conservation of the same and other species, including the northern spotted owl and

Coho salmon.

Regulatory Agency Requirements Prior to Implementation

Requirements of the North Coast Regional Water Quality Control Board

After decision but prior to implementation of the project, the Forest Service will meet all the 

relevant conditions for the Non-point Source Sediment Discharge Waiver of Waste Discharge 
—Draft Record of Decision—

Page 21

Requirements for Nonpoint Source Discharges Related to Certain Federal Land Management 

Activities on National Forest System Lands in the North Coast Region (Order No. R1‐2015‐

0021; hereinafter “Waiver”). The North Coast Regional Water Quality Control Board (Water

Board) may require treatment of a number of existing “legacy sites” as conditions for enrolling

the Horse Creek Project under the Waiver. This will meet the requirements for the Clean Water 

Act, the Total Maximum Daily Load and the Basin Plan. The Standards and Guidelines in the 

Forest Plan are met through project design and analysis (see the Forest Plan Consistency 

Checklist in the project record and the Hydrology Resource Report, available on the project 

website).

The Water Board was informed about progress on the project and the Forest Service responded 

to their scoping comments (see Horse Creek Scoping Outcome Summary on the project website) 

and comment period comments (see Response to Comments on the project website). 

Project Monitoring

Project monitoring will occur during and after implementation to ensure that the objectives of the 

project are achieved, and where necessary, additional actions are taken. Monitoring elements 

include:

• Continued protocol surveys for northern spotted owls known to be in the project area.

• Sample effectiveness monitoring of water quality BMPs. This determines whether the 

measures taken to protect water quality worked as designed.

• Project implementation and contract administration by Forest Service timber sale 

administrators to ensure that the terms of timber sale contracts are followed, project 

design features are implemented as planned, and water quality BMPs are adhered to.

• Follow-up surveys after tree planting is completed. This validates whether reforestation 

was successful. If necessary, sites will be replanted to meet stocking objectives.

• Follow-up surveys of new and known noxious weed populations. The Forest Noxious 

Weed Detection and Treatment Program will continue to monitor for new infestations of 

invasive plant species that may be introduced or spread throughout the project area and 

Forest lands.

• Follow-up surveys of planting of native species in the Horse Creek Special Interest Area.

• Surveys of at-risk historic properties and cultural resources during implementation to 

ensure the effectiveness of resource protection measures pursuant to the Regional 

Programmatic Agreement.

3. REASONS FOR MY DECISION

My thanks to all the people, organizations, governments, tribes and agencies who took the time 

to submit comments, attend field trips and public meetings, or otherwise engage in helping 

inform my decision on this important restoration project. It is a testament to the amazing 

characteristics of the Klamath that so many people, both those who call this place home and 

those who live far away, care so deeply about its future. All of my decisions as Forest Supervisor 

are enriched by these perspectives and the information that is shared with us during the 
—Draft Record of Decision—

Page 22

development of projects. 

This breadth of interest also means that there are often opposing and conflicting viewpoints of 

how projects should be planned and accomplished. Everyone brings a different lens to their view. 

For some, the lens is tinted with “10,000 years of traditional ecological knowledge.” For others,

it’s affected by seeing the effects of 100 years of fire suppression. For some, the lens focuses on 

burned houses or the effects of smoke on an asthmatic child. For others, it’s only influenced by 

an online blog claiming that the Forest Service is planning to clearcut old growth forests again, 

and that the agency is disregarding local tribal interests.

2 While each (and others) of these lenses 

are valuable in understanding how the world is viewed, none of them individually can capture 

the world in its entirety. The “count” of similar or identical comments, therefore, does not drive 

decisions. Decisions are based upon considering all of these shared perspectives through the lens 

of the Forest Service mission “to sustain the health, diversity, and productivity of the nation’s 

forests and grasslands to meet the needs of present and future generations.” It is our 

responsibility to consider all these voices and come to a single decision “to provide the greatest 

amount of good for the greatest amount of people in the long run.” 

After fire suppression efforts on the Gap Fire reached containment, the decision on what to 

propose (if anything) in response to the fire-created conditions on the landscape was initially not 

an easy one. The Klamath is an active Forest with many projects at various stages of planning, 

implementation, and post-implementation monitoring. Even prior to the Gap Fire, our resource 

specialists and other employees were already stretched thin working on multiple simultaneous 

projects and often covering multiple positions to fill in for staff vacancies. Many of us had 

already spent long hours working through the Salmon Salvage Project (2014) and the Westside 

Fire Recovery Project (2016) and were reluctant to take on another large project, especially one 

that would require meeting an accelerated timeline. I also knew that putting forth a post-fire 

project would mean putting other “green” projects on hold, potentially risking having other areas 

burn in the future that could have been treated had we not reallocated resources for this project. 

In the end, our decision on whether to propose a post-fire project was made by listening to the 

communities affected by the Gap Fire. After meeting with individuals and families affected by 

the fire, and seeing how much the community pulled together to improve post-fire conditions on 

private lands, we could not in good conscience walk away from doing our part to complement

and secure their efforts. We will no doubt continue to have areas of the Forest that would benefit 

from pre-fire treatments, but at this time, my decision is to treat the immediate hazards that exist 

on the landscape created by the Gap Fire and improve conditions to reduce the chances of a 

future fire creating a high severity burn.

Management Areas of the Forest Plan

Once the decision to propose a post-fire project was made, our next step was to consider the 

entire area of the burn and compare that with our management areas laid out in our Forest Plan, 

which gives us overall objectives and standards and guidelines for managing resources within 

those specific areas. In this case, late successional reserves, riparian reserves, partial retention 

visual quality objective, and general forest management areas combined cover the vast majority 

 2 As we noted in the glossary of the FEIS, clear-cut logging, or clearcutting, is “An even-aged management 

silvicultural system applied to green (emphasis added) forest stands for the purpose of regenerating a new age class. 

Trees are selected and removed in groups up to 40 acres in size followed by artificial or natural regeneration.”
—Draft Record of Decision—

Page 23

of the project area (98 percent, not accounting for overlap of riparian reserves with other 

management areas). See Management Areas within the Project Area section above and the 

treatment map with management areas in Appendix A for more specific details.

Wildland Urban Interface

Although not a management area within our Forest Plan, the wildland urban interface (WUI) 

within the project area strongly shaped our proposed treatments for the Horse Creek Project. The 

wildland urban interface is divided into three zones:

1. Home Ignition Zone (Zone 1): This is a 100-foot zone around structures as identified by 

State of California Public Resource Code 4291. The goal of this zone is to have no crown 

fire and for flame lengths to be less than two feet, and “Fuels shall be maintained in a 

condition so that a wildfire burning under average weather conditions would be unlikely 

to ignite the structure” on 100 percent of the land base (State of California Public 

Resource Code 4291).

2. Defense Zone (Zone 2): This is a quarter mile buffer around structures and other human 

developments. The goal of this zone is to create an environment where firefighters can 

safely and effectively suppress wildfires by treating fuels and vegetation to reduce flame 

heights below four feet and have no crown fire under 90th percentile weather conditions 

on 100 percent of the land base (USDA USDI 2001b, Nowicki 2002)

3. Threat Zone (Zone 3): This is a 1.5 mile buffer around structures and other human 

developments. The goal of this zone is to treat fuels and vegetation to reduce crown fire 

to a surface fire before reaching the community fire defense zone under 90th percentile 

weather conditions (USDA USDI 2001b). Research suggests (Finney 2007, Schmidt et al. 

2008) that at least 20 percent of the land base should be strategically treated to increase 

landscape level fire resilience.

Table 4. Wildland urban interface (WUI) acres with the project boundary by WUI zone.

WUI Zone Federal 

Acres

Private 

Acres

Total 

Acres

Percent 

Federal

Home Ignition 

Zone 0 75 75 0

Defense Zone 1,025 3,075 4,100 25

Threat Zone 16,215 9,700 25,915 63

Flame length potential may be used as a proxy for community safety or resilience to wildfire. 

Nowicki (2002) states “The protection of houses and communities from the threat of forest fire 

depends upon the proper treatment of the wildland-urban interface, the area directly adjacent to 

houses and communities. The protection of the house depends entirely on treatment of the home 

ignition zone regardless of what treatments are implemented in the adjacent forest.” Cohen 

(2008) also notes that the home ignition zone principally determines a home’s ignition potential.

Lowering flame lengths to a level conducive to safe and effective firefighting is the main goal of 

fuel reduction in the wildland urban interface. In order to reduce both direct flame impingement 

and resulting home ignition, as well as to provide space for firefighters to suppress the fire 

directly, the 100-foot home ignition zone should have flame lengths of two feet or less. In the 
—Draft Record of Decision—

Page 24

surrounding quarter mile defense zone, flame lengths of four feet or less are essential in 

providing an extra buffer for firefighter safety, and lessen the chances of firebrands from nearby 

vegetation igniting structures. Fuel reduction in the outlying 1.5 mile threat zone can help to 

lower the intensity of an approaching front into the defense zone, but does not have a noticeable 

effect on reducing home ignitions. Strategically based treatments, such as on ridgelines and 

roads, help reduce fire behavior in areas often utilized by fire suppression resources. In addition, 

roads serve as important ingress and egress routes during emergencies such as wildfire and may 

serve as alternative routes for safety and evacuation if needed.

The interdisciplinary team designed the project around the wildland urban interface. Figure 1

shows the three different WUI zones and the proposed treatments as scoped. 
—Draft Record of Decision—

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Figure 1. Alternative 2 proposed treatment map with WUI zones.
—Draft Record of Decision—

Page 26

Burn Severity

After considering the management areas within the burn area and wildland urban interface, our 

next questions were: what are the areas most affected by the fire? Where would potential 

treatments create the most benefit for public safety and hazardous fuels reduction? Where is it 

best to leave small, natural gaps where there are plenty of seed sources nearby for natural 

regeneration? These questions were informed in large part by the fire severity map shown in 

Figure 2 and contrasted in Table 5 below. The majority of high-severity fire occurred right 

around the community, which helped us focus the location of our treatments to propose. 
—Draft Record of Decision—

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Figure 2. Gap Fire severity by RAVG class map.
—Draft Record of Decision—

Page 28

Table 5. Burn Severity Acres by Land Ownership and RAVG Class

Land Owner

Low: less than 

25 percent 

severity

Low to 

Moderate: 25 to 

50 percent 

severity

Moderate to 

High: 50 to 75 

percent severity

Greater than 

High: greater 

than 75 percent 

severity

Total*

Klamath National 

Forest (acres) 16,590 1,005 690 3,295 21,580

Klamath National 

Forest (percent) 77 5 3 15 100

Private Lands 

(acres) 10,050 485 350 1,565 12,450

Private Lands 

(percent) 81 4 3 12 100

All Ownership 

acres 26,640 1,490 1,040 4,860 34,030

All Ownership 

percent 78 4 3 15 100

High severity patch size ranged from less than one acre to 1,050 acres. Numerous contiguous 

patches of over 100 acres occurred within the project boundary. It is important to note that 

previous wildfires in the area (e.g., 2014 Beaver Fire, 2014 Happy Camp Complex Fire, 2012 

Goff Fire, 2008 Klamath Theatre Fires) have shown significant increases in delayed mortality 

over time. The Happy Camp Complex Fires of 2014 increased severity by an estimated 10 

percent after the first year and delayed mortality is still occurring. In other words, severity in 

Table 5 is anticipated to increase from delayed mortality (e.g. delayed fire effects, drought, 

stress, and insects) by at least seven to 12 percent or higher resulting in increased high severity 

patch sizes. In addition, many of these patch sizes are uncharacteristically large compared to the 

historic fire regime of the Klamath Mountains described by Skinner et al. 2006.

Restoration Treatments

Ultimately, the proposal to treat around the community was relatively straightforward, but the 

question remained regarding what to do within the rest of the burn area. After any fire, a lot of 

the comments we receive advocate for us to leave the entire burn area without treatment and to 

rely solely on natural regeneration to return the area to forested conditions. People talk of 

“natural fire regimes” and the increased biodiversity following a fire as new species move in to 

the burned areas and rates of growth are fastest without competition. Although the percentages of 

burn severity might be relatively within the normal range for local fire regimes, the distribution 

of high-severity patches is not. In the Gap Fire, high severity patch size ranged from less than 1 

acre to 1,050 acres. Many of these patch sizes are uncharacteristically large compared to the 

historic fire regime of the Klamath Mountains described by Skinner et al. 2006 (see the Fire and 

Fuels Report for more details).

The Klamath National Forest contains 381,100 acres allocated to wilderness, where management 

goals are to manage for wilderness characteristics, natural conditions, and ecological processes. 

No wilderness exists within the Gap Fire area. Instead, the fire burned areas where our Forest 

Plan directs us to take action on the landscape. Wherever conflicts between standards and 

guidelines exist, it is my duty as Forest Supervisor to make the determination of which standards 

and guidelines apply at the project level. 
—Draft Record of Decision—

Page 29

In this project, it was discussed internally and in public comments whether the project should 

include treatments within the Horse Creek Special Interest Area and also within the Siskiyou 

Crest area. Generally, the proposed restoration treatments within the Horse Creek Botanical Area 

were widely accepted by interested parties, including by the Karuk Tribe and the Environmental 

Protection Agency. Treatments within the Siskiyou Crest, however, were vigorously discussed, 

even before the Gap Fire. 

In the Horse Heli 2006 EIS, the existing conditions for the Siskiyou Crest units (which were 

dropped from the Horse Heli Project) state that 

fire suppression kept wildfires out of these stands, so survival was high for young 

trees that normally would have been thinned out by repeated ground fires or crowded 

out by large trees, resulting in high stand densities. Stand density index (defined as 

the number of trees per acre with an average stand diameter of 10 inches) is used to 

measure stand densities (Zhang et al. (2005) found a strong correlation between 

stand density index values and tree mortality in red fir. As stand densities increase, so 

does competition for water and nutrients. Trees become stressed and weakened with 

limited nutrients to go around, leading to slower growth rates and increased 

susceptibility to insects and disease. Trees on the Siskiyou Crest are infested with 

dwarf mistletoe, Cystospora, and Annosus root disease. Many Siskiyou Crest stands 

are declining due to the combined impacts of disease, drought stress, and fir engraver 

beetles. Mortality is beginning to outpace growth. Late-successional forest 

characteristics are disappearing as canopy closure is lost and large trees succumb to 

disease. Openings of 5 to 25 acres are being created. (Silviculture section Horse Heli 

EIS) High disease and mortality rates are increasing fuel loading, causing significant 

accumulations of fine and coarse fuels. This is particularly severe in the red fir 

stands, which cover 80 percent of the Horse Heli EIS area and have not experienced 

a fire in over 100 years. Due to the vegetation and location, fire behavior (the way a 

fire reacts to fuels, weather, and topography) will likely be driven more by fuels and 

weather than topography. The Horse Creek Ecosystem Analysis, fuel surveys and 

field visits done during the Horse Heli project, indicate that the project area is at 

substantial risk of a stand-replacing wildfire from the effects of drought, disease, 

pests, overcrowding, and fire exclusion. (Fuels section Horse Heli EIS)

Several commenters expressed the need to maintain habitat connectivity along the Siskiyou Crest 

to allow species to migrate and to adapt to changing climate. Land allocations in the Klamath 

Forest Plan are intended to maintain habitat and connectivity for species dependent on late 

successional and old growth forests by providing large reserves (the late successional reserves) 

to maintain species meta populations and dispersal corridors (the riparian reserves) to allow 

migration and movement. At the project scale, elements such as green tree retention, retention of 

coarse woody debris, snag retention, the Survey and Manage requirements to protect rare species 

and their habitats, and consultation with regulatory agencies under the Endangered Species Act 

provide additional protections. These strategies are not inconsistent with those identified by 

Olson et al (2012). We also agree that logging and road building can adversely affect habitat if 

these circumstances are not considered. By following the strategies outlined in the Klamath 

Forest Plan, and consulting with regulatory agencies, we believe we are minimizing those 

impacts to habitat connectivity. While the comments cite a recent journal article on refugia 

(Olson et al, 2012), commenters provide no evidence that the land allocations and management 
—Draft Record of Decision—

Page 30

prescriptions in the Klamath Forest Plan are incongruent with Olson et al. (2012) or that the 

Horse Creek Project is not consistent with the direction in the Forest Plan with respect to species 

conservation.

In alternatives 2 and 4, proposed salvage units near the Siskiyou Crest are in matrix lands in 

patches of high severity burn where most, if not all, of the trees are dead. There are no salvage 

units along the Siskiyou Crest in late successional reserves in any of the action alternatives. 

Riparian reserves are flagged out of any salvage unit and will remain uncut. Snag retention areas 

have also been designated where needed to provide connectivity. Coarse woody debris will be 

retained in the amounts specified in the Forest Plan. Alternative 3 was developed to be 

responsive to comments and drops all salvage harvest near the Siskiyou Crest.

Alternatives 2 and 4 have the highest probability of restoring habitat connectivity along the 

Siskiyou Crest. They will reestablish coniferous forests decades sooner than large severely 

burned areas that are not planted because alternatives 2 and 4 reduce the risk of future high 

severity fires and accelerate the development of late successional forests. Alternative 3 would 

have the same effect as "no action." In alternative 3, these large patches of high severity burn 

near the Siskiyou Crest are likely to become semi-permanent brushfields that are maintained by 

high-severity fire (FEIS pg. 218). This trajectory is not likely to provide the refugia or 

connectivity that is the concern of the commenters. For these reasons, I have decided to include 

the Siskiyou Crest units within the draft decision, as I believe that our proposed treatments would 

be more consistent with our Forest Plan and the basis of concerns raised by the public than 

would leaving the area untreated.

4. OTHER ALTERNATIVES CONSIDERED

The following sections present the other alternatives considered in detail but not selected and the 

alternatives considered but eliminated from detailed study.

Alternatives Considered in Detail but not Selected

Alternative 1

Alternative 1, the alternative to take no action, was not selected because it failed to address the 

purpose and need of the Project. Hazard trees would not be abated from roads, fuels would not 

be treated along roadways and boundaries with private property containing structures (or that had 

a structure before the Gap Fire), and fuel management zones would not be developed or 

maintained. Salvage harvest, site preparation, and planting would not occur. Finally, restoration 

treatments would not occur in the Horse Creek Special Interest Area. For this reason, in my

opinion this option is unacceptable. 

Alternative 2

Alternative 2 was the refined proposed action, and treated the most acres of any of the action 

alternatives. Alternative 2 was not selected primarily because of the potential impacts on 

northern spotted owls and their habitat. 
—Draft Record of Decision—

Page 31

Alternative 3

Alternative 3 was developed in response to concerns raised in scoping about the potential effects 

of salvage harvest along the Siskiyou Crest and temporary road construction. This alternative 

would have eliminated treatment in 18 units (14 within the Siskiyou Crest, and four additional 

units that proposed use of new or existing temporary roads). Alternative 3 would have the same 

effect as "no action" within the Siskiyou Crest. In alternative 3, these large patches of high 

severity burn near the Siskiyou Crest are likely to become semi-permanent brushfields that are 

maintained by high-severity fire (FEIS p. 218). This trajectory is not likely to provide the refugia 

or connectivity that is the concern of the commenters, which is why the alternative was not 

selected. In addition, the proposed treatments in areas outside of the Siskiyou Crest would not 

have the protections put in place to minimize effects to northern spotted owls.

Alternatives Considered through Tribal Consultation

Eight days prior to the close of the 30-day comment period (which closed on December 23, 

2016), we started receiving form letters requesting we “work with communities, scientists, and 

the Karuk tribe” and “to listen to and respect native people, in this case the Karuk Tribe.” On 

January 29, 2017, we received final scoping comments from the Karuk tribe. The tribe’s 

comments (including a proposed alternative, referred to as the Karuk Alternative) were 

incorporated into the draft EIS.

Several commenters pointed out that they were confused about how we considered the Karuk 

Tribe’s alternative proposal, since we did not clearly categorize it in the draft EIS under 

“alternatives considered in detail” or “alternatives considered but eliminated from detailed

study.” Rather, we created a new section between those two, entitled “Alternative Developed as 

a Result of Tribal Consultation with the Karuk Tribe (Karuk Alternative).” We determined this 

was the best approach to describe our analysis of the Karuk Alternative. We incorporated 

comments on the draft EIS into the final EIS to clarify that we considered the Karuk Alternative 

but that it was eliminated from further detailed study for reasons described below.

The central theme in the Karuk Alternative is taking action that, according to the Karuk Tribe, 

facilitates returning low and moderate severity fire to the landscape, while providing for public 

safety. The Karuk Alternative contains some degree of all of the elements of the proposed action 

except reforestation of salvage units and burned plantations. Acres treated or specifications differ 

from the proposed action described by the Forest Service in some treatment types, as shown in 

Table 6.

Table 6. Karuk Alternative compared to Forest Service action alternatives.

Action (Unit of Measure) Alternative 

2

Alternative 

3

Alternative 

4

Karuk 

Alternative

Karuk 

Alternative 

Actions in 

Proposed 

Action

Karuk 

Alternative 

Actions 

not in 

Proposed 

Action

1) Roadside Hazard Tree 

Removal (miles) 103 103 87 102 102 0

2) Roadside Fuels 

Treatments (acres) 688 688 315 797 688 109*
—Draft Record of Decision—

Page 32

Action (Unit of Measure) Alternative 

2

Alternative 

3

Alternative 

4

Karuk 

Alternative

Karuk 

Alternative 

Actions in 

Proposed 

Action

Karuk 

Alternative 

Actions 

not in 

Proposed 

Action

3) Fuels Reduction 

Adjacent to Private 

Property (acres) 1,412 1,412 1,412 1,616 1,412 204*

4) Fuels Management 

Zones (acres) 733 733 702 773 733 40*

5a) Salvage with Site 

Preparation and PlantGround-Based Yarding 

(acres) 1,137 488 880 70 70 0

5b) Salvage with Site 

Preparation and PlantCable Yarding (acres) 905 704 800 34 34 0

6) Site Preparation and 

Plant without Salvage 

(acres) 458 458 458 0 0 0

7) Horse Creek Special 

Interest Area (acres) 184 184 184 184 184 0

Temporary Roads (miles) 4.6 0 3.6 0 0 0

*See specific treatment types below for descriptions of why these additional acres were not included in the proposed 

action.

The Karuk Alternative is generally in agreement with the following actions or principles found in 

the Forest Service proposed action: 

1. Fuels reduction adjacent to private property (500 foot buffer);

2. Roadside fuels treatment (150 foot buffer, each side of the road);

3. Fire fighter safety; and

4. Protection of private property.

The primary differences between the Karuk Alterative and Alternative 2 (originally the Proposed 

Action) are an increase in the acres of roadside fuels, fuels reduction adjacent to private property, 

and fuel management zones; and a decrease in the acres of salvage harvest (see Chapter 2, pp. 

63-70 of the FEIS for more details on the Karuk Alternative and its differences from the 

proposed action). Except for the Special Interest Area, the Karuk alternative proposes no site 

preparation and planting within high fire severity burned forested areas such as those proposed in 

Alternative 2 (i.e. plantations or salvage harvest units). Proposed treatments within the Karuk 

Alternative for roadside hazard tree removal and for restoration activities in the Horse Creek 

Special Interest Area are not substantially different from the proposed action and therefore were 

not analyzed in detail in a separate alternative. Roadside fuels treatments proposed in the Karuk 

Alternative did substantially differ from our proposed action by adding 109 acres. The location 

of this addition within LSR and critical habitat for northern spotted owl would lead to 

downgrading about 80 additional acres of suitable habitat. Since roadside hazards would be 

abated in this area without the additional treatment, we are unwilling to accept the additional toll 
—Draft Record of Decision—

Page 33

on northern spotted owl critical habitat and this proposed treatment is not further considered in 

detail. Fuels reduction adjacent to private property is only different in the Karuk Alternative 

because the Karuk proposal added areas that are already under approved NEPA and a current 

service contract or that does not have a current or pre-fire structure to protect; since this is not 

substantially different from the proposed action, it is not analyzed in detail in a separate 

alternative. Similarly, the only difference for the fuels management zones is that the Karuk 

Alternative proposed incorporation of an area that is already covered under previous NEPA, and

thus it is not analyzed in detail in a separate alternative.

The main difference between Alternative 2 and the Karuk Alternative is a reduction of salvage, 

site preparation, and planting. The Karuk Alternative has a reduction of approximately 2,460 

acres of these combined treatments when compared to Alternative 2. These areas would no 

longer benefit from treatments described in Alternative 2, and would resemble the No Action 

Alternative. As a result, there would be an increase in flame length potential, fireline intensity, 

and resistance to control. Desired conditions would no longer be met in the mid- to long-term 

within or adjacent to the areas removed from treatments in the Karuk Alternative. This includes 

areas adjacent to the private property buffer to the community of Horse Creek. This would 

decrease community and firefighter safety and reduce the effectiveness of private property buffer 

treatments in the event of future wildfire, thereby not meeting the purpose and need of the 

project. 

One of the primary threats to the NSO recovery is the loss of habitat which includes habitat 

burned by high severity wildfire. NSO have been reported to use areas affected by high severity 

fire in the short-term, but as the high severity patches start to deteriorate and the standing snags 

that provided cover for NSO start to fall over, NSO use of these areas is likely to decline. Using 

this information, the Horse Creek Project attempts to minimize effects on NSO habitat including 

habitat affected by high severity fire by balancing the short-term effects to NSO habitat with the 

longer-term threat of future high severity fire. Although the Karuk Alternative reduces salvage 

by 1,940 acres, these retained acres may not be used by NSO at the same level as the areas 

avoided in project design that was used to create Alternative 2. Generally, the Karuk Alternative 

would affect a slightly larger number of NSO suitable habitat acres as compared to those 

presented for Alternative 2, but it retains about 1,940 acres of higher severity burned forest that 

would be harvested in alternative 2. These salvage units could provide for NSO foraging use in 

the short-term but in the long-term, these retained 1,940 acres of burned forest may contribute to 

future NSO habitat loss to high severity fire. This concern for long-term habitat conditions for 

northern spotted owls, as well as not meeting our purpose and need for community protection, 

led to the Karuk Alternative’s proposal to remove all but about 100 acres of salvage being 

eliminated from detailed study. 

Avoiding all replanting was fully analyzed in our No Action Alternative, and similar to removing 

all salvage treatments, would not meet our purpose and need or Forest Plan objectives. For all 

these reasons, the Karuk Alternative was eliminated from further detailed study.

Alternatives Considered but Eliminated from Detailed Study

NEPA requires that federal agencies rigorously explore and objectively evaluate all reasonable 

alternatives and briefly discuss the reasons for eliminating any alternatives that were not 

developed in detail (40 CFR 1502.14). In response to public comments during scoping, we 
—Draft Record of Decision—

Page 34

developed and considered three alternatives that were eliminated from detailed study. Public 

comments received in response to the proposed action provided suggestions for alternative 

methods for achieving the purpose and need. Some of these alternatives may have been outside 

the scope of the need for the proposal, duplicative of the alternatives considered in detail, or 

determined to be components that would cause unnecessary environmental harm. Therefore, a 

number of alternatives were considered but eliminated from detailed consideration for reasons 

summarized in Chapter 2 of the final EIS (pp. 71-74).

5. PUBLIC INVOLVEMENT

This section will be updated prior to decision in order to reflect the latest information.]

Scoping

On November 18, 2016 a scoping letter was sent to local tribes, and on November 22, 2016 a 

scoping letter was sent to other interested and affected parties, including other public agencies, 

adjacent property owners, and interested groups and individuals. On November 22, 2016 a legal 

notice of scoping was published in the Siskiyou Daily Newspaper and the Notice of the Intent 

was published in the Federal Register on November 23, 2016 beginning the formal scoping 

process that guides the development of the DEIS. The project was first published to the Forest 

website in mid-December 2016 and to the Schedule of Proposed Actions on January 1, 2017.

Scoping identified concerns about the long-term project impacts of logging roads and landings, 

post-fire logging on the Siskiyou Crest, the impacts on northern spotted owls, and the effects of 

the project on amenity resources such as recreation opportunities and visual quality 

characteristics. These concerns led to the creation of Alternatives 3, 4, and project design 

features for Recreation and Scenic Resources, as described in the Scoping Outcome Summary on 

the project website and the Issues from Scoping section in Chapter 1 of the draft and final EISs. 

The Happy Camp/Oak Knoll Ranger District (District) held meetings with individual groups 

before, during, and after scoping and comment periods. On April 28, 2017, the district hosted a 

public meeting including a field trip. Several members of the Horse Creek community and fire 

safe council came, along with Fish and Wildlife, California Water Board, and a member from the 

neighboring forest. On May 17, 2017, Klamath Siskiyou Wildlands Center (KS Wild), 

Environmental Protection Information Center (EPIC), and the Karuk Tribe joined the District on 

a field trip of the project area. On June 1, 2017, American Forest Resource Council (AFRC) 

joined the District on a field trip of the project area. Due to snow levels, the District plans to host 

a field trip out to the Siskiyou Crest and Buckhorn areas of the project in July 2017 for anyone 

involved or interested in the project. A field trip with the Pacific Crest Trail Association is also 

planned for late June or early July, to discuss the different proposed actions with the group.

The District has had the opportunity to speak with the Karuk Tribe and Karuk Resource 

Advisory Board, Horse Creek Fire Safe Council, Seiad Fire Safe Council, KS Wild, Shasta Tribe 

Inc., and Shasta Nation. This has allowed the Forest to present the project and for these groups to 

share their individual concerns.
—Draft Record of Decision—

Page 35

Draft EIS Comment Period

On April 28, 2017, the draft EIS and supporting documents were posted to the project’s 

webpage. Email notifications and letters for the draft EIS comment period were sent to interested 

and affected parties, including other public agencies, tribes, adjacent property owners, and 

interested groups and individuals. On April 28, 2017, a Notice of Availability was published in 

the Federal Register and a legal notice was published in the Siskiyou Daily News, beginning the 

45-day comment period. Comments received by June 13, 2017, were considered timely.

The comment period for the draft EIS resulted in the receipt of 995 comment letters, including 

19 unique letters, 718 form letters, and 24 form letters that included additional information (234 

letters were duplicates). Comments were identified in these letters regarding issues and concerns 

raised by the author. These comments were then categorized according to the primary topics of 

their content. Within these topics areas, comments were grouped together and summarized 

together with similar comments. The interdisciplinary team then responded to these summary 

statements to address the issue or concern identified, or clarify where more information was 

requested. If a comment was unique in its subject from any other comments, it was addressed 

individually. Any comments that provided substantive new information were considered and 

necessary revisions made to the final EIS and supporting documents or addressed in this draft 

Record of Decision. Responsible scientific literature provided that was not previously considered 

was reviewed by resource specialists and considered in their final analysis where applicable. A 

report of the comments received, including a list of commenters, and responses to them is 

included as Appendix D, which is available in the project record and on the project website.

I recognize that because of the need to stick to an accelerated timeline in order to have an 

implementable project, some of our commenters may be concerned that their comments were not 

fully considered by the time of this draft record of decision. I appreciate this concern, but would 

like to take this opportunity to alleviate it by explaining our process. Early this spring, we 

estimated that in order to have an implementable project, we would need to reach a signed 

decision by late September. After getting the DEIS released for comment, we recognized that 

this would mean ending the DEIS comment period on June 13 and beginning the objection 

period and review of the FEIS on June 23rd. Because of this challenge, we intentionally focused 

our resources on reviewing comments as they were received and incorporating changes from 

additional public meetings, field trips, and comment letters into the FEIS throughout the 45-day 

comment period on the DEIS. Evidence of how comments were incorporated into the FEIS can 

be seen in the FEIS section on Modifications or Clarifications between Draft and Final 

Document, on pages 1-4, and incorporated throughout the entire FEIS. One of the largest 

changes to highlight is that in the FEIS, in response to concerns raised by the public and our 

consulting agencies, I identified Alternative 4 as the Preferred Alternative, rather than 

Alternative 2, which had been the proposed action in the DEIS. Responses to specific comments 

can be found in the Response to Comments appendix, available on the project website. 

Any objections received will be considered and addressed in the final record of decision. 

6. LEGAL AND REGULATORY REQUIREMENTS

[This section will be updated prior to decision in order to reflect the latest information.]

My decision complies with the laws, policies and executive orders listed below and
—Draft Record of Decision—

Page 36

described in the final EIS. The selected alternative will be located entirely on National 

Forest System lands and is not in conflict with planning objectives for Siskiyou County. 

The Horse Creek Community Protection and Forest Restoration Project was prepared in 

accordance with the following laws and regulations.

National Environmental Policy Act

I find the selected alternative is consistent with the National Environmental Policy Act of

1969 (NEPA). The final EIS fulfills the requirements for environmental analysis found in 

NEPA and in the Council on Environmental Quality implementing regulations at 40 CFR, 

Parts 1500-1508. The selected alternative will not result in irreversible damage to soils or 

other watershed characteristics such as detrimental soil loss, blockage of waterways, or 

riparian habitat. NEPA requires that all major federal actions significantly affecting the

human environment be analyzed to determine the magnitude and intensity of those

impacts and that the results be shared with the public and the public given opportunity to 

comment. The regulations implementing NEPA further require that, to the fullest extent 

possible, agencies shall prepare EISs concurrently with and integrated with environmental

analyses and related surveys and studies required by the Endangered Species Act of 1973, 

the National Historic Preservation Act of 1966, and other environmental review laws and

executive orders. Other laws and regulations that apply to this project are described

below.

National Forest Management Act

I find the selected alternative to be consistent with the provisions of the National Forest

Management Act (NFMA) of 1976, which sets forth the requirements for Land and

Resource Management Plans for the National Forest System. The selected alternative was 

designed to conform to the Klamath National Forest Land and Resource Management Plan 

goals, to meet or move toward desired conditions, and to comply with standards and 

guidelines for forest-wide management direction (Forest Plan, pp. 4-3 through 4-66) and the 

direction specific to several individual management areas as described above. 

The selected alternative is consistent with the Aquatic Conservation Strategy objectives 

(Forest Plan, pp. 4-6 and 4-7). The Forest Plan requires that projects meet, or not prevent

attainment of, the objectives of the Aquatic Conservation Strategy (Forest Plan pp. 4-6, 4-

106). To address this requirement in the Horse Creek Project, an Aquatic Conservation 

Strategy Report (see project record) was prepared (final EIS pp. 82-88). Based on this 

review, I find that the Horse Creek Project would not retard or prevent attainment of

Aquatic Conservation Strategy Objectives found in the Forest Plan of the Klamath 

National Forest.

The Forest Plan Consistency Checklist document in the project record identifies the Forest

Plan Standards and Guidelines applicable to this project and provides related information 

about compliance with the Forest Plan. Based on my review of that document and other

information in the project record, I determined that the selected alternative is consistent

with the Forest Plan and all other requirements of the National Forest Management Act.
—Draft Record of Decision—

Page 37

Clean Air Act

The Clean Air Act of 1970 provides for the protection and enhancement of the nation’s air

resources. No exceeding of the federal and state ambient air quality standards is expected to

result from any of the alternatives. The Clean Air Act makes it the primary responsibility of

states and local governments to prevent air pollution and control air pollution at its source. 

The selected alternative is compliant with the Clean Air Act and the Conformity Rule (final

EIS pp. 79 and 85).

Clean Water Act

The Clean Water Act of 1948 (as amended in 1972 and 1987) establishes federal policy for

the control of point and non-point pollution, and assigns the states the primary

responsibility for control of water pollution. The Clean Water Act regulates the dredging 

and filling of freshwater and coastal wetlands. Section 404 (33 USC 1344) prohibits the

discharge of dredged or fill material into waters (including wetlands) of the United States 

without first obtaining a permit from the U.S. Army Corps of Engineers. Wetlands are

regulated in accordance with federal Non-Tidal Wetlands Regulations (Sections 401 and

404). We have applied for a Section 401 permit to cover the restoration activities (placing 

trees in streams) within the Horse Creek Special Interest Area, and will comply will all 

terms of that permit. 

Hydrology effects are disclosed in the final EIS (pp. 189-200). The selected alternative

complies with the Clean Water Act through use of best management practices, which were 

designed to minimize or prevent the discharge of both point and non-point source 

pollutants from Forest roads, developments, and activities. The Project is also consistent 

with the California Porter- Cologne Water Quality Act, the North Coast Regional Water 

Quality Control Board Basin Plan and the mid-Klamath total maximum daily load 

(TMDL). Following this decision, we will apply to the Water Board to secure the

appropriate regulatory approval for this Project prior to implementation. See the 

Requirements of the North Coast Regional Water Quality Control Board section above.

Endangered Species Act

The selected alternative complies with the Endangered Species Act (ESA) [16 U.S.C. 1531 

et seq.], which outlines the procedures for Federal interagency cooperation to conserve

federally-listed species and designated critical habitats. Consistent with the requirements

of the Act, and its enabling regulations (50 CFR 402), the Forest Service has been actively

engaged with the appropriate federal regulatory agencies responsible for implementation of

the Act throughout development of the Horse Creek Project. However, thorough analyses 

of federally-listed species and consultation with the USDI Fish and Wildlife and National 

Marine Fisheries Service (19 U.S.C. 1526(c)) and the National Marine Fisheries Service 

are still ongoing at the time of this draft record of decision.

The Forest Service made a determination of Likely to Adversely Affect for the northern 

spotted owl and its designated critical habitat and submitted a Biological Assessment to the 

FWS on June 13, 2017. We await a Biological Opinion from the US Fish and Wildlife 

Service prior to signing a decision. The Forest Service will adjust the project as needed to 
—Draft Record of Decision—

Page 38

comply with any terms and conditions of the final biological opinion. 

The Aquatic Resources Biological Assessment is being prepared in accordance with legal 

requirements set forth under Section 7 of the ESA of 1973, as amended (16 U.S.C. 1531 et. 

Seq. 50 CFR 402). The determination for Coho salmon and its critical habitat is May 

Affect, Likely to Adversely Affect. We await a Biological Opinion from the National Marine 

Fisheries Service prior to signing a decision. The Forest Service will adjust the project as 

needed to comply with any terms and conditions of the final biological opinion.

Forest Service Policy (FSM 2670), and Forest Plan Standards and Guidelines for Sensitive plant 

species have been met by managing populations for continued viability (final EIS p. 99-102). 

Effects to botanical threatened, endangered, proposed, or candidate species were disclosed in 

the final EIS (final EIS pp. 96, 99). There are no known populations of any threatened, 

endangered, proposed, or candidate species present in the project area. The project area contains 

suitable habitat for Fritillaria gentneri; however, no populations are currently known in the 

project area. Any populations of threatened, endangered, proposed, or candidate species that are 

located will be protected through the implementation of project design features (Botany 1, 3, 4, 

and 8; final EIS pg. 53-54).

Magnuson-Stevens Fishery Conservation Management Act

The Project complies with the Magnuson-Stevens Fishery Conservation Management Act

(MSA). Section 305(b) of the MSA directs Federal agencies to consult with National

Marine Fisheries Service on all actions or proposed actions that may adversely affect

essential fish habitat (EFH). The MSA (section 3) defines EFH as “those waters and

substrate necessary to fish for spawning, breeding, feeding, or growth to maturity.” Section 

305(b) also requires NMFS to recommend measures that can be taken by the action

agency to conserve EFH. The final EIS discloses the effects on essential fish habitat for the

SONCC Coho salmon and the Pacific salmon as required by the Magnuson-Stevens

Fishery Conservation and Management Act (final EIS pp. 138-174). Although 

consultation with the National Marine Fisheries Service has not concluded, we expect a 

determination that the proposed project would adversely affect Essential Fish Habitat 

(EFH) for Pacific Coast salmon. However, the proposed Project contains adequate 

measures to avoid, minimize, mitigate, or otherwise offset the adverse effects to EFH.

Therefore, we do not expect NMFS to recommend additional conservation measures, 

pending the final biological opinion.

Floodplain Management

Executive Order 11988 requires Agencies to evaluate any activities that may occur in floodplain 

and to avoid adverse impacts. Activities that could directly influence floodplain inundation are 

dam installation and removal, large water diversions, and modification of streams channels and 

floodplains by dredging, infilling, and channel relocation. None of these activities are being 

proposed in this project; the Horse Creek Project, therefore, has no influence on floodplain 

inundation. Project effects to peak flow are discussed in detail in the Aquatic Conservation 

Strategy Assessment (final EIS pp. 85-91) and are anticipated to be indistinguishable from 

increases due to the 2016 wildfires. Landslides and debris flows may also affect floodplains 

although these events are a natural part of floodplain processes. Watershed monitoring after the 
—Draft Record of Decision—

Page 39

Gap Fire has revealed high flows in streams draining severely burned watersheds, and damage to 

roads and a few small debris flows (such as Hamburg Gulch). Damages began with the storms of 

October, 2016 and subsequent heavy precipitation produced near record totals for the winter of 

2016-2017 in this part of the Forest. As a result, many slumps and earthflows were activated in 

the project area, and some of these damaged or temporarily closed roads (FEIS, p. 178). The 

selected alternative would slightly increase the risk ratio of a landslide event in three 7th field 

watersheds (Buckhorn, Lower Horse, and Middle Creek), but the increase is too small to warrant 

a change in the likelihood category compared to existing condition (final EIS pp. 180-181). No 

adverse effects to floodplains are anticipated as a result of the Horse Creek Project.

National Historic Preservation Act

Section 106 of the National Historic Preservation Act (NHPA) requires Federal agencies to take 

into account the effects of their undertakings on historic properties and to provide the Advisory 

Council on Historic Preservation (ACHP) with a reasonable opportunity to comment. In addition, 

Federal agencies are required to consult on the effects of their undertakings with any Indian 

tribes that attach religious and cultural significance to the project area.

Both federally recognized and non-federally recognized tribes were contacted early in the project 

planning and were engaged throughout the planning process, in accordance with the National 

Historic Preservation Act, National Environmental Policy Act, and other laws, regulations and 

policy. Tribal engagement is summarized in chapter 1 of the final EIS under Public Involvement. 

Consultation was conducted with the Karuk Tribe, Quartz Valley Indian Reservation, and the 

Confederated Tribes of Siletz Indians. The Forest conferred with the Shasta Indian Nation and 

Shasta Nation, Inc.

Written and verbal comments received during tribal consultation were considered when refining 

the proposed action and while developing project alternatives; many tribal concerns were 

incorporated in these alternatives. Consultation with the tribes regarding the proposed project is 

on-going.

Environmental Justice

Executive Order 12898 relating to Environmental Justice requires an assessment of whether

implementation of this decision would disproportionately affect minority or low income

populations. The socio-economic analysis evaluated economic impacts on local communities

(final EIS pp. 226-234; see also Forest Plan compliance checklist in the project record). There is 

no reason to suspect that any impacts would have disproportionately high adverse effects on 

minority or low-income populations.

Prime Farmland, Rangeland and Forest Land

The selected alternative is in accordance with the Secretary of Agriculture Memorandum

1827 for prime farmland, rangeland, and forest land. The project area does not contain

any prime farmland or rangeland. Prime forest land is a term used only for non-Federal

land which will not be affected by proposed activities under any alternative.
—Draft Record of Decision—

Page 40

Migratory Bird Treaty Act

The selected alternative will not adversely impact migratory species or their associated

habitats. The habitat affected by the Project will still provide habitat for many migratory

bird species. Potential impacts to migratory species will be minimized through the

adherence to Forest Plan standards and guidelines for snags and downed woody debris, 

riparian reserve buffers, limited ground disturbance, and maintenance of canopy closure.

Specific project design features will be used to minimize negative impacts include 

retaining snags within treatment units which include riparian reserves, and retaining trees 

with high quality wildlife habitat characteristics and snags mixed in with green trees.

Additional cull logs will be left on site from the operation as well. The Project complies

with the Migratory Bird Treaty Act Memorandum of Understanding (final EIS pg. 268).

Invasive Species

The selected alternative complies with Executive Order 13112, which directs federal

agencies to prevent the introduction of invasive species; detect and respond rapidly to and

control such species; not authorize, fund, or carry out actions that the agency believes are

likely to cause or promote the introduction or spread of invasive species unless the agency

has determined and made public its determination that the benefits of such actions clearly

outweigh the potential harm caused by invasive species; and take all feasible and prudent

measures to minimize the risk of harm in conjunction with the actions. The requirements of

this executive order are met through project design features that minimize or eliminate

negative environmental effects as disclosed in the Botanical Resources and Non-Native

Invasive Plants section in Chapter 3 of the final EIS.

Findings Related to Special Areas

Late Successional Reserves

The Forest-wide LSR Assessment for the Forest provides criteria for risk reduction, including 

salvage, in the LSR land allocation. A review by the Regional Ecosystem Office (REO), a 

coordinating body for implementation of the Northwest Forest Plan, determined that projects 

consistent with the recommendations of the KNF LSR assessment are not subject to further review 

by the REO, and may be implemented as designed. All of the action alternatives meet the criteria for 

risk-reduction salvage in the LSR assessment, and are not subject to further review by the REO.

Inventoried Roadless Areas

The project area includes 17 acres in the Condrey Mountain Inventoried Roadless Area, but 

no treatments are proposed in this area and therefore no effects to the Inventoried Roadless 

Area are expected. The selected alternative will comply with the Roadless Area 

Conservation Rule and applicable Forest Plan standards (pg. 4-38 of the Forest Plan). 

Special Interest Areas

There are 362 acres of special interest areas within the project area, including the Horse Creek 

Botanical Area and the Condrey Mountain Blueschist Geologic Area. 

The Horse Creek Botanical Area was selected for Administrative Withdrawal as a Special 
—Draft Record of Decision—

Page 41

Interest Area for its unique characteristic as an intact and highly diverse old-growth riparian 

ecosystem. The entirety of the Horse Creek Botanical Area was affected by the Gap Fire. 

Some areas were severely burned in the Gap Fire, with a large amount of the canopy 

compromised or killed. Many burned trees pose a hazard to the Horse Creek Road. 

Understory was completely killed in some areas and may not naturally regenerate in time to 

prevent invasion by non-native plant species. Restoration of ecological functions to reflect 

the unique characteristics of the Horse Creek Botanical Area is part of the purpose and need 

of the project (FEIS, pg. 18). This will be done through replanting the Horse Creek Botanical 

Area with upland and riparian vegetation, as well as trees, where appropriate, and placing 

some of the hazard trees into reaches of the Horse Creek that support Coho salmon and their 

habitat. The resulting altered condition after the fire has triggered the need to initiate 

restoration efforts to allow the area to return to the condition for which it was designated a 

special interest area.

The Condrey Mountain Blueschist Geologic Special Interest Area contains an assemblage of 

minerals such as glaucophane and crossite. Aside from roadside hazard tree removal, no 

activities are planned in the Condrey Mountain Blueschist Geologic Special Interest Area, 

and there will be no effect to the character of the area.

Wild, Scenic, and Recreation Rivers

The Selected Alternative complies with the Wild and Scenic Rivers Act as disclosed in the

final EIS. The final EIS disclosed effects to areas designated or recommended as wild,

scenic, or recreational rivers (final EIS pp. 249-254). There are two designated or

recommended Wild and Scenic Rivers within the project area. The Klamath Wild and 

Scenic River was designated by the Secretary of Interior in 1981 for its outstandingly

remarkable anadromous fisheries values. The portions of the Klamath Wild and Scenic 

River that are within the project area are classified as “Recreational.” A small portion of the 

Scott Wild and Scenic River also exists within the project boundary, but project activities 

will not affect this river corridor. Free flowing conditions, water quantity and quality, and

identified outstandingly remarkable value(s) will be protected (final EIS pp. 252-254). 

River classifications will be maintained. The desired future conditions for both scenic and

recreational rivers will be met; scenic river areas and shorelines will remain largely

primitive and undeveloped, and recreational river waterways will remain generally natural

and riverine in appearance (final EIS pp. 252-254). One unit with salvage treatments 

proposed would likely not meet the retention and partial retention visual quality objective 

within three years’ time, especially because a majority of the eastern-facing slope, which is 

visible from the river, was affected by moderate to high severity fire. The Forest Plan allows 

an exception under Visual Resource Management Standards and Guidelines 11-7 that allows

recovery time beyond three years in the case of catastrophic events such as the Gap Fire 

(FEIS, pg. 253). 

Implementation Date

[This section may be updated prior to decision in order to reflect the latest information.]

Timing of my decision is pursuant to 36 CFR 218.12:

(a) The responsible official may not sign a ROD or DN subject to the provisions of this part 
—Draft Record of Decision—

Page 42

until the reviewing officer has responded in writing to all pending objections (see § 

218.11(b)(1)). (b) The responsible official may not sign a ROD or DN subject to the 

provisions of this part until all concerns and instructions identified by the reviewing officer 

in the objection response have been addressed. (c) When no objection is filed within the 

objection filing period (see §§ 218.26 and 218.32): (1) The reviewing officer must notify the 

responsible official. (2) Approval of the proposed project or activity documented in a ROD 

in accordance with 40 CFR 1506.10, or in a DN may occur on, but not before, the fifth 

business day following the end of the objection filing period.

Implementation of this project can begin immediately following my decision. My intention is 

to implement this project through service contracts, timber sale contracts, and possibly 

stewardship contracts.

Project activities will be seasonally restricted, as described in Table 9 of the final EIS. 

Seasonal restrictions mainly apply to activities relating to the northern spotted owl and its 

critical habitat.

Explanation of Negative Impacts of Implementation Delays

Although this project has been planned on an accelerated timeline in order to treat the burned 

area while the project is still implementable, we have made every effort possible to encourage 

public participation and input into the planning stages. We recruited additional resources so that 

we could meet our accelerated timeline without minimizing any public comment opportunities, 

because we know that any delay in implementing the project will have negative impacts on the 

communities and resources affected by the Gap Fire. 

In the Horse Creek Project, the great majority of fire-affected dead and dying trees are 

relatively small diameter. After dying, trees this size decompose rapidly. The project needs 

to be implemented as soon as possible in order to capture the already limited value of these 

small diameter dead and dying trees before they lose their merchantability and economic 

value. Wanting to implement while the dead and dying trees still have some economic 

value is not the same as making a profit off the fire; it is the difference between the agency 

needing to use scarce public funds to pay for the hazard trees to be cut and removed to 

reduce fuels near communities, versus that same dead or dying material being purchased 

and cut and removed to achieve that same goal. We are not expecting a profit from this 

project, but that does not negate the need for the project. The work needs to happen 

whether it is profitable or not, but we can minimize costs to the American taxpayers if the 

project can be implemented by fall 2017. Contrary to some public opinions, it is not about 

serving any “corporate masters.” Every tool at the agency’s disposal is needed to get the 

critical work done that needs to happen, and those tools include selling dead or dying trees, 

contracting with service providers to accomplish work, and, in some cases, using agency 

employees for implementation. I hope to use all of those tools in getting the critical hazard 

reduction and restoration work of the Horse Creek Project accomplished as soon as 

possible. 
—Draft Record of Decision—

Page 43

Contact Information

For additional information concerning this decision or objections, please contact: Lauren 

McChesney, Environmental Coordinator, Klamath National Forest Supervisor’s Office, 

1711 South Main Street, Yreka, CA 96097; by phone at 530-841-4483, or by email at 

laurendmcchesney@fs.fed.us.

[This is a DRAFT document only. The signature and date are purposefully omitted until the 

final record of decision is signed.]
—Draft Record of Decision—

Page 44

APPENDIX A: Vicinity Map and Selected Alternative Treatment Map
—Draft Record of Decision—

Page 45
APPENDIX B: Project Design Features and Best Management Practices for the Horse Creek 

Project

Project 

Design 

Feature

Description Type of 

activity

Applicable Alternatives 

and Units (if variable)

Rationale or 

Applicable Standard

or Guideline or Best 

Management 

Practice (BMP)

Wildlife 1 No project actions that modify Northern Spotted Owl (NSO) nesting/roosting 

or foraging habitat, or that occur within an NSO activity center core, will 

occur from February 1st to September 15th. If surveys result in determining 

no NSO nesting is occurring, this restricted project actions may be lifted for 

the year.

Limited 

Operating 

Period

All action alternatives; 

applied to all salvage 

harvest, fuels management 

zone (except northern have 

of unit in section 33), fuels 

adjacent to private land 

(except center and 

northwest unit in section 2, 

southern unit in section 10 

and 6, and northwest unit in 

section 14), roadside 

hazard (except 46N29Y, 

portion of 46N60 between 

the middle of section 15 to 

middle of section 14, and 

portion of 47N65 in section 

34), roadside fuels (except 

portion between the middle 

of section 15 to the middle 

of section 14), and 

temporary roads.

Consultation with 

FWS

Wildlife 2 No project actions that create loud and/or continuous noise within 0.25 mile 

of nesting/roosting or foraging habitat or that occur within an NSO activity 

center core, will occur from February 1st to July 9th. If surveys result in 

determining no NSO nesting is occurring, the restriction on project actions

may be lifted for the year. This project design feature is not intended to be 

applied to motor vehicle travel on roadways.

Limited 

Operating 

Period

All action alternatives; 

applied to project actions 

(salvage harvest, site prep 

and plant, Fuel 

management zones, 

roadside hazard, roadside 

fuels, fuels adjacent to 

private property , temporary 

roads, or special interest 

area)

Consultation with 

FWS
Project 

Design 

Feature

Description Type of 

activity

Applicable Alternatives 

and Units (if variable)

Rationale or 

Applicable Standard

or Guideline or Best 

Management 

Practice (BMP)

Wildlife 3 Goshawk surveys will be conducted prior to project implementation. No 

project activities that modify habitat will occur from March 1st to August 31st 

within the primary nest zone. If surveys determine no nesting activity, this 

restricted project activities may be lifted for the year.

Limited 

Operating 

Period

All action alternatives; 

Salvage harvest units 

(117.19, 117.20, 117.21, 

117.22, and 118.2), 

roadside hazard (section 

18, 26, 24, northeast 

portion of section 36, 

southern half of section 32, 

and southwest portion of 

section 33, and southeast 

portion of section 13), 

roadside fuels (section 18 

and 26, and southeast 

portion of unit 13), fuel 

management zones (south 

of 46N60 in sections 13 

and 24).

Standard and 

Guideline 8-20

Wildlife 4 Goshawk surveys will be conducted prior to project implementation. No loud 

and/or continuous noise within 0.25 mile of active goshawk nest sites from 

March 1st to August 31st. This restricted project activity time period may be 

lifted for the year, if surveys determine no nesting activity. This project 

design feature is not intended to be applied to motor vehicle travel on 

roadways.

Limited 

Operating 

Period

All action alternatives; 

Roadside hazard (47N99 in 

section 24, 47N65 in 

section 26, 47N90 in

section 32 and 33, 47N69B 

in section 36, 46N55 and 

46N60 in section 18), 

roadside fuels (46N60 in 

section 18)

Standard and 

Guideline 8-20

Wildlife 5 Avoid ground disturbing activities within areas identified as possibly 

occupied Survey and Manage mollusk and salamander sites.

Preimplementation 

Survey

All action alternatives; 

known site in salvage 

harvest unit 115.33

Standard and 

Guideline 6-17

Wildlife 6 Retain existing down woody debris larger than 30” dbh that was present 

prior to the Gap Fire to the greatest extent possible from disturbance during 

treatment (e.g. slash burning and yarding).

Operations All action alternatives; all 

salvage harvest units 

Standard and 

Guideline 6-16
Project 

Design 

Feature

Description Type of 

activity

Applicable Alternatives 

and Units (if variable)

Rationale or 

Applicable Standard

or Guideline or Best 

Management 

Practice (BMP)

Wildlife 7* No project activities that create noise above ambient levels (e.g. chainsaw 

or heavy equipment) within 0.25 mile of a bald eagle nest from January 1 to 

August 31. If surveys determine the nest site is not active, then seasonal 

restriction may be lifted for the year. 

Limited 

Operating 

Period

Fuel management zone: 

portion along the ridge of 

Hick’s Gulch from 46N32 to 

western edge of section 25

Roadside hazard: portion of 

46N31 (occurring south of 

46N32) and 46N31C 

Bald and Golden 

Eagle Protection Act; 

Bald Eagle 

Management 

Guidelines and 

Standards and 

Guidelines

Geology 1 If existing temporary roads are found to cross unstable land riparian 

reserves, effective mitigation measures will be developed to prevent 

landslides or sediment delivery to streams. Where mitigation is not feasible, 

such sites will be avoided.

Temporary 

roads

All units where applicable/ 

all alternatives

BMP 2.2

Standard and 

Guideline 2.3

Geology 2 Naturally occurring asbestos is known to occur in some existing rock 

quarries in the project area, and rock from these quarries was used in the 

past to surface nearby roads. The following Project Design Features will be 

applied.

Rock from the ultramafic quarries in the Middle Creek Watershed will not be 

used as road aggregate.

Direction from the Regional Forester (2009a) addressing naturally occurring 

asbestos will be followed.

Project activities which will occur on rock which often contains natural 

asbestos (ultramafic rock) will be identified by a GIS overlay process and 

maps showing the overlap will be made available internally and to 

contractors working on the project. 

Appropriate dust mitigation measures and measures to limit exposure as 

identified in the Regional Foresters direction of 2009a will be applied.

Rock quarries All units where 

applicable/all alternatives

Regional Forester 

direction (2009a); 

Forest Plan pg. 4-20, 

2-5, and 1.6

Geology 3 There will be no commercial salvage harvesting, or heavy equipment 

operation on unstable land component of riparian reserves. Site preparation 

and planting on these lands will be done manually.

Operations 118.26, 118.93 Standard and 

Guideline 2.2

Geology 4 Avoid building new temporary roads on unstable land riparian reserves, and 

also on ground steeper than 40 percent slope gradient, unless a resource 

geologist conducts a site investigation and provides formal approval to the 

Sale Administrator prior to any earthwork.

Temporary 

Roads

All units where 

applicable/all alternatives
Project 

Design 

Feature

Description Type of 

activity

Applicable Alternatives 

and Units (if variable)

Rationale or 

Applicable Standard

or Guideline or Best 

Management 

Practice (BMP)

Geology 5 Proposed new landings will not be built on the following types of ground: 

Unstable land Riparian Reserves; Sites where erosion from the landing 

could deliver sediment directly to streams.

New landings will not be built on slopes steeper than 20% gradient, and cuts 

and fills will not exceed five feet in height, unless a resource geologist 

conducts a site investigation and provides formal approval to the Sale 

Administrator prior to any earthwork.

Landing fill will not be left perched on slope breaks where surface erosion or 

landslides could deliver sediment to a stream due to steeper slopes below. 

Log decks will not be left on the margins of landing fills during the wet 

season where the weight of the logs could destabilize the fill.

Landings Some specific units 

include, but are not limited 

to: 117.20, 117.23, 117.24, 

118.3, 118.04, 118.05, 

115.32, 118.57, 115.33, 

115.34, 115.35.

Forest Plan page 4-

19, 2-1, BMP Veg-6 

LMP 2-3.

Watershed 

1

Maintain 20 pieces of large wood (40 cubic feet or larger) per 1,000 lineal 

feet within 3rd to 5th order channels, or as identified in the ecosystem 

management process at the watershed level.

Coarse Woody 

Debris

All units where 

applicable/all alternatives

Forest Plan page 4-

113, S&G MA10-56

Watershed 

2

No more than 15 percent of a harvest unit should have detrimental 

disturbance by tractor equipment, cable corridors, swing trails, and landings.

Detrimental disturbance is considered to be complete removal of the O and 

A horizon of, or a 10 percent or more reduction in soil porosity (compaction) 

of the surface soil over natural conditions.

Operations All units where 

applicable/all alternatives

Forest Plan: Pp. 5-11,

Pp. 4-21 3-5

FSH 2409.15

Watershed 

3

Mechanized harvesting equipment will be restricted to:

If Soil Texture is Loam or finer

Slopes less than 45 percent.

If Soil Texture is Sandy Loam or Coarser

Slopes less than 35 percent.

Restrict all ground-based equipment to slopes less than 35 percent in units 

with granitic soils.

Mechanized harvesting equipment will be restricted to travelling in straight 

up and down patterns on slopes above 35 percent.

In stands where tractor skidding is used and, where practical, logs should be 

placed in bundles on slopes less than 35 percent. 

Mechanized harvesting equipment will be allowed to travel in straight up and 

down patterns on slopes above 35 percent for short steeper slopes 

regardless of texture when necessary.

Operations Tractor Units

Tractor Units Limited to 35

percent slope: 118.63 and 

115.34

BMP 2.13

BMP 1.3

BMP 1.9

BMP 1.10

BMP 1.17

FSH 2409.15
Project 

Design 

Feature

Description Type of 

activity

Applicable Alternatives 

and Units (if variable)

Rationale or 

Applicable Standard

or Guideline or Best 

Management 

Practice (BMP)

Watershed 

4

Skid trails that connect benches separated by short steep slopes (broken 

ground) can have minor portions of the skid trails on slopes greater than 35 

percent.

Skid trails All units where applicable/ 

all alternatives

National BMP Veg-4, 

R5 BMP 5-2; BMP 

1.17

BMP 1.10

BMP 1.9

Watershed 

5

On existing skid trails that are over 35 percent slope equipment will be 

restricted to the skid trail and logs yarded to the skid trail.

Skid trails All units where applicable/ 

all alternatives

National BMP Veg-4, 

R5 BMP 5-2; BMP 

1.3

BMP 1.10

Watershed 

6

Skid and swing trails will be:

Waterbarred to prevent concentrated surface runoff and to prevent runoff 

from entering swing trails. 

At project completion:

Permanent operating water bars will be installed and/or repaired as 

necessary on all skid and swing trails.

Slash scattered on all skid and swing trails to achieve the soil cover 

guidelines or a minimum of 50 percent cover, where enough material is 

available.

Skid trails All units where applicable/ 

all alternatives

National BMP Veg-4, 

R5 BMP 1-17; Forest 

Plan: Pg. 4-21 3-4

FSH 2409.15

Watershed 

7

At project completion temporary and permanent take-offs of skid and swing 

trails that intersect forest system roads will be effectively blocked to vehicle 

access following unit treatment.

Skid trails All units where applicable/ 

all alternatives

National BMP Veg-4, 

R5 BMP 1-17; 

BMP1.21,2.7

FSH 2409.15

Watershed 

8

Slash or water bars will be applied to corridors where necessary to minimize 

the concentration of surface runoff and to keep ground cover at least 50 

percent where enough material is available.

Cable 

Corridors

All units where applicable/ 

all alternatives

National BMP Veg-2, 

Forest Plan: Pg 4-21 

3-4

FSH 2409.15
Project 

Design 

Feature

Description Type of 

activity

Applicable Alternatives 

and Units (if variable)

Rationale or 

Applicable Standard

or Guideline or Best 

Management 

Practice (BMP)

Watershed 

9

Where enough material is available:

Soil Cover Guidelines for Projects Should be used.

Soil Cover Guidelines for Projects

Soil Texture 

Class

Slope

(percent)

Minimum 

Total Soil 

Cover*

(percent)

Guidelines for Projects Using Tractors:

Sandy Loam 

or Coarser

0-25

26-35

70

80

Loam or Finer 0-35 70

Guidelines for Prescribed Burning:

Sandy Loam 

or Coarser

0-25

26-45

46+

60

70

80

Loam or Finer 0-35

36-60

61+

50

60

70

* Soil cover consists of low growing live 

vegetation (12 inches high), rock fragments 

(greater than 1⁄2 inch in diameter), Slash 

(any size) and fine organic matter (charred 

or not) that is in contact with the soil 

surface. Fine organic matter refers to the

duff, litter and twigs less than 3 inches in 

diameter.

If the soil cover guidelines cannot be met a minimum of 50 percent soil 

cover should be maintained where material is available. If 50 percent cover 

cannot be achieved, consult a Forest Botanist to determine if seeding with 

native grass seed is appropriate.

Ground-based 

logging; 

Prescribed 

burning

All units where applicable/ 

all alternatives

Forest Plan: Pg 4-21 

table 4-2,3-4

BMP 2.13

BMP 1.17

FSH 2409.15

Watershed 

10

Appropriate road watering will be implemented as roads dry to maintain road 

fines on site and to minimize the potential for introducing natural asbestos 

fibers into the air on roads surfaced with ultramafic rock.

Operations All units where applicable/ 

all alternatives

R5 BMP 2-23
Project 

Design 

Feature

Description Type of 

activity

Applicable Alternatives 

and Units (if variable)

Rationale or 

Applicable Standard

or Guideline or Best 

Management 

Practice (BMP)

Watershed 

11

Use temporary roads on existing roadbeds instead of constructing new 

temporary roads except:

when temporary roads on existing roadbeds are located within streamcourse riparian reserves (unless the only way to access the unit will be to 

use a stream crossing on an existing roadbed); or 

When temporary roads on existing roadbeds are located on highly erosive 

soils, unstable areas, wetlands or meadows (excluding small springs and 

seeps).

Temporary 

Roads

All units where applicable/ 

all alternatives

National BMP Road5, R5 BMP 2-1.

Watershed 

12

Following use, all temporary roads (new or existing) will have takeoffs from 

system roads obliterated or blocked to avoid unauthorized use.

Temporary 

Roads

All units where applicable/ 

all alternatives

National BMP Road5, R5 BMP 2-1.

Watershed 

13

During reconstruction of any landings, sidecasting of material will be 

minimized. Mitigation such as straw or mulch material will be used if needed 

to stabilize any sidecast material.

Landings All units where applicable/ 

all alternatives

BMP1.6

BMP 1.16

FSH 2409.15

Watershed 

14

Operate according to the Forest’s Wet Weather Operation Standards 

(USDA Forest Service 2002).

Operations All units where applicable/ 

all alternatives

National BMP Veg-2, 

R5 BMP 1-5

Watershed 

15

At project conclusion, landings will be configured for long term drainage and 

stability by reestablishing natural runoff patterns. All landings within riparian 

reserves will be covered with at least 80 percent effective soil cover at the 

end of season use. Use of certified weed free materials including straw, 

wood chips, or mulch may be used where on site material is insufficient. 

On areas of landings where soil is left uncovered and has a slope of greater 

than 20 percent but less than 60 percent at project completion.

Site to be treated with effective soil cover to achieve at least a 50 to 70 

percent cover where applicable.

Seeded with weed free grass seed where applicable.

Following use, all landings will be properly closed where practical, 

configured for long-term drainage and stability, subsoiled where practical, 

seeded with weed free native grass seed where applicable, and natural 

runoff patterns re-established.

Landings All units where applicable/ 

all alternatives

S&G 10-51
Project 

Design 

Feature

Description Type of 

activity

Applicable Alternatives 

and Units (if variable)

Rationale or 

Applicable Standard

or Guideline or Best 

Management 

Practice (BMP)

Watershed 

16

Existing landings will be used to the extent possible. Existing landings within 

50 feet of the slope break to a stream channel or inner gorge will not be 

used without review by a watershed specialist and mitigation measures will 

be developed. If mitigation is not feasible, such sites will be avoided.

Landings Units 115.33, 115.34, 

115.36, 117.20, 118.57, 

and 118.07

BMP 1.6

BMP 1.12

FSH 2409.15

Forest Plan pages 4-

113, S&G MA 10-51, 

National BMP Veg-6. 

Landings LMP 2-3

Watershed 

17

Where logs cannot be adequately suspended for yarding, gouging in 

corridors will be waterbarred and covered with at least 50 percent logging 

slash where available and as needed to mitigate erosion and concentration 

of surface runoff.

Cable Logging All units where applicable/ 

all alternatives

National BMP Veg-2, 

R5 BMP 1-14

Watershed 

18

All skyline yarding operations will require:

One end suspension. 

Full suspension will be required for any yarding across or over streams and 

riparian reserves where possible.

Some end lining will be implemented on steeper slope (greater than 35

percent).

Skyline All units where applicable/ 

all alternatives

Veg-5., R5 BMP 1-11

FSH 2409.15

Watershed 

19

No new full bench skid trails will be constructed. Existing full bench skid 

trails can be used where they will not introduce sediment to streams (Full 

bench skid trails have the entire skid trail cut into the hill slope).

Skid trails All units where applicable/ 

all alternatives

National BMP Veg-4, 

R5 BMP 1-10

BMP 1.6

Watershed 

20

Ground-based skidding will require front-end suspension of logs on skid 

trails.

Skid trails All units where applicable/ 

all alternatives

National BMP Veg-4, 

R5 BMP 1-10

Watershed 

21

Existing skid trails will be reused whenever possible.

Use existing skid and swing trails instead of building new skid trails unless 

using existing skid trails will have greater negative effects than building new.

Use no existing skid trails in areas:

In which ground-based mechanical equipment is excluded. Such as highly 

erosive soils, unstable areas, wetlands, or meadows (excluding small 

springs and seeps).

Skid trails All units where applicable/ 

all alternatives

National BMP Veg-4, 

R5 BMP 1-10, 

BMP 1.18

BMP 1.6

FSH 2409.15
Project 

Design 

Feature

Description Type of 

activity

Applicable Alternatives 

and Units (if variable)

Rationale or 

Applicable Standard

or Guideline or Best 

Management 

Practice (BMP)

Watershed 

22

Tractors and mechanical harvesters will be excluded from:

Unstable land component of riparian reserves including:

Active landslides, 

Toe zones of landslides, 

Inner gorges.

Steep-dissected granitic ground.

Operations All units where applicable/ 

all alternatives

R5 BMP 1-6

BMP1.18

Watershed 

23

Cable corridors will avoid ground disturbance or standing trees on unstable 

land component of riparian reserves.

Cable corridor All units where applicable/ 

all alternatives

Soil and Water 

Conservation 

Handbook, Chapter 

10 – Water Quality 

Management 

Handbook pg. 53 

BMP 1.6

Watershed 

24

Following use, all temporary roads will be hydrologically stabilized and 

natural runoff patterns re-established. This includes removal of temporary 

culverts and fills at stream crossings, out-sloping of road surfaces where 

appropriate, subsoiling where practical, seeding with native grass seed 

where appropriate, and proper construction of water bars. Use of certified 

weed free materials including straw, wood chips, or mulch may also be used 

for erosion control. Any modification to temporary road alignments during 

the implementation phase of the project (not analyzed in the planning phse) 

will be reviewed by an earth scientist.

Temporary 

roads

All units where applicable/ 

all alternatives

BMP 2.7, National 

BMP Road-5. 

Temporary Roads, 

Forest Plan page 4-

113, S&G MA10-51, 

LMP 2-3

Watershed 

25

Mechanized heavy equipment will not be used in riparian reserves except 

on existing system roads, existing landings, or existing non-system 

roadbeds.

Operations, 

Landings

All units where applicable/ 

all alternatives

Forest Plan MA10-42

Heritage 1 Any project activities within site boundaries will follow approved Standard 

Resource Protection Measures established by the Regional Programmatic 

Agreement and will be approved through documentation by the district 

archaeologist and/or heritage program manager.

All units where 

applicable/all alternatives

Standards and 

Guidelines 24-7; 24-

8; 24-20.

Heritage 2 All sites within the area of potential effects will be clearly identified prior to 

implementation. This includes but is not limited to flagging site boundaries.

Preimplementation 

surveys

All units where 

applicable/all alternatives

Standards and 

Guidelines 24-8 and 

24-20.

Heritage 3 When any changes in proposed activities are necessary to avoid cultural 

resource sites (e.g., project modifications), these changes will be completed 

prior to issuance of the Decision.

Preimplementation 

surveys

All units where 

applicable/all alternatives

Standards and 

Guidelines 24-3 and 

24-7.
Project 

Design 

Feature

Description Type of 

activity

Applicable Alternatives 

and Units (if variable)

Rationale or 

Applicable Standard

or Guideline or Best 

Management 

Practice (BMP)

Heritage 4 No skid roads, road improvements, landings or burn pile areas will occur 

within archeological sites without documented approval from the district 

archaeologist and/or heritage program manager.

Operations All units where 

applicable/all alternatives

Standards and 

Guidelines 24-8 and 

24-20.

Heritage 5 Conduct heritage resource surveys to determine presence of resources 

within the area of potential effects following the provisions outlined in the 

Regional Programmatic Agreement prior to issuance of the Decision.

Preimplementation 

surveys

All units where applicable/ 

all alternatives

Standards and 

Guidelines 24-3.

Heritage 6 If any late discoveries of new heritage resources, including human remains 

or archeological sites not previously recorded are identified during project 

implementation, all activities within in the vicinity (150 feet) will stop, except 

for within roads, and the district archeologist and/or heritage program 

manager will be contacted. No activities within 150 feet of the resource shall 

continue until clearance is provided by the district archeologist or the 

heritage program manager.

Discovered 

cultural 

resource

All units where applicable/ 

all alternatives

Standards and 

Guidelines 24-7 and 

24-8.

Botany 1

Forest Service botanist will flag for avoidance appropriate populations of 

federally threatened and endangered and Forest Service sensitive species. 

Yellow and black striped flagging will be used to delineate population 

boundaries. Some specific areas may also require a limited operating period 

(LOP) to minimize impacts to plants.

Preimplementation 

survey

All units where applicable/ 

all alternatives

6-7, 6-17

Botany 2

Populations protected under Survey and Manage guidelines will be flagged 

for avoidance. Yellow and black striped flagging will be used to delineate 

population boundaries.

Preimplementation 

survey

All units where applicable/ 

all alternatives

NWFP 2001 ROD 

S&G pages 6-14

Botany 3

Hazard trees adjacent to flagged populations of TES and Survey and

Manage species will be directionally felled away from the flagged area to 

avoid disturbing the population. Directionally felled trees may only be 

removed if it causes no ground disturbance within the flagged area. Yellow 

and black striped flagging will be used to delineate population boundaries.

Operations All units where applicable/ 

all alternatives

FSM 2670, KNF S&G 

6-17, 7-4, NWFP 

2001 ROD S&G 

pages 6-14

Botany 4

Hazard trees located within the flagged population boundary for TES or 

Survey and Manage species may be felled, but must be left on-site to avoid 

ground disturbance. Yellow and black striped flagging will be used to 

delineate population boundaries.

Operations

All units where applicable/ 

all alternatives

FSM 2670, KNF S&G 

6-17, 7-4, NWFP 

2001 ROD S&G 

pages 6-14

Botany 5 Meadows adjacent to treatment units shall not be used for landings or 

staging areas.

Landings TBD 6-7, 8-42
Project 

Design 

Feature

Description Type of 

activity

Applicable Alternatives 

and Units (if variable)

Rationale or 

Applicable Standard

or Guideline or Best 

Management 

Practice (BMP)

Botany 6 No canopy- or ground-disturbing activity may occur in areas flagged for 

avoidance with yellow and black botany flagging unless otherwise allowed 

by project design features in this document or in consultation with a Forest 

botanist.

Operations All units where 

applicable/all alternatives

6-7, 6-17

Botany 7 Cultural botanical resources (fern beds in riparian zones) will be flagged for 

avoidance. Yellow and black striped flagging will be used to delineate 

population boundaries.

Preimplementation 

survey

All units where applicable/ 

all alternatives

Forest Plan S&G 6-

21, 21-44

Botany 8 Areas identified as potential habitat for threatened, endangered, or 

candidate botanical species must be surveyed or be determined unsuitable 

habitat by a Forest Botanist prior to work beginning in these areas.

Operations Units 118.63, 116.49. 

Roadside fuels on 46N31 

and 46N60 roads. Private 

Property Buffer fuels 

treatments in Sections 6 

and 8 of T.46N. R.11W.

ESA LRMP 6-7, 6-17

NNIS 1 Equipment and vehicles that leave the established road surface will be 

cleaned of soil, seeds, vegetative matter, and other debris that could contain 

noxious weed seeds prior to entering and before leaving the project area. 

Areas appropriate for cleaning equipment prior to leaving the project area 

will be designated as appropriate.

Equipment 

cleaning

All equipment where 

applicable

21-53, FSM 2080

NNIS 2 Equipment, vehicles, and personnel will avoid working within flagged 

noxious weed sites. Orange/black flagging labeled with “INVASIVE 

SPECIES” will be used to delineate population boundaries.

Operations All units where applicable/ 

all alternatives

21-53, FSM 2080

NNIS 3 If potential landings, staging areas, swing or skid trails are infested with 

noxious weeds, consult a Botanist about appropriate methods for containing 

and/or managing the infestation. Methods may include blading infested soil 

away from activity zone and covering this soil; or adding a barrier to the 

landing so seed banks cannot be transported.

Landings All landings where 

applicable: to be 

determined.

21-53, FSM 2080

NNIS 4 Any straw or seed placed within the project area must be documented as 

California certified weed free. Other materials where State inspection 

protocol does not exist (gravel, wood chips) used as mulch in the project 

area, should be inspected by a Forest Service representative to determine 

the potential for spread of noxious weeds.

Operations All materials where 

applicable

6-11, 21-53, FSM 

2080

NNIS 5 Any facility that provides material such as rock, gravel, or boulders to be 

used in the project area should be inspected and determined to have limited 

potential for the spread of noxious weeds from stored material. Material 

stockpiles must be noxious weed free.

Operations All facilities where 

applicable

21-53, FSM 2080
Project 

Design 

Feature

Description Type of 

activity

Applicable Alternatives 

and Units (if variable)

Rationale or 

Applicable Standard

or Guideline or Best 

Management 

Practice (BMP)

NNIS 6 If determined necessary by a Forest Botanist, to prevent NNIS invasion 

temporary roads, landings, skid and swing trails will be seeded with native 

grass seed after use. This should occur after any hydrologic stabilization 

such as water-barring.

Operations All units where applicable/ 

all alternatives

6-7, 6-11, 21.53

Fuels 1 Site specific burn plan prior to implementation would be completed to 

identify desired fire behavior and weather conditions to meet prescribed fire 

and resource objectives along with protection measures to avoid impacts to 

both cultural and natural resources within the burn area.

Burning All alternatives and units. FSM 5140

Fuels 2 All burning activities would adhere to pertinent air quality regulations. Smoke 

emissions would be minimized by following Best Available Control Measures 

(BACM). A smoke permit administered by the local County Air Resource 

Agency would accompany burn plans.

Burning All alternatives and units. FSM 5140

Fuels 3 All fire lines would follow the established guidelines for water bar 

construction as outlined in the Best Management Practices. Upon 

completion of burning, the visible character of the firelines would be 

disguised by spreading pine needles, brush, etc. where they intersect roads 

or trails in order to reduce the likelihood of the firelines becoming unwanted 

trails.

Fuel breaks All alternatives and units. Contract 

specifications

Fuels 4 Piles will be covered to keep piles dry for ignition and consumption during 

wet periods.

Pile 

construction

All alternatives and units. Contract 

specifications

Fuels 5 Planting utilizing a clumping pattern with variable spacing to minimize 

surface fuel loadings and break the continuity of the fuel beds to maintain 

desired low fire hazard conditions.

Planting All alternatives and units. Contract 

specifications

Fisheries 1 Instream work will be implemented only between May 1 and October 1. In-stream 

actions

SIA To prevent direct 

adverse effects to 

spawning salmonids 

and incubating 

salmonid eggs.

Fisheries 2 New and reconstructed culverts, bridges and other stream crossings shall 

be designed and constructed to accommodate at least the 100-year flood, 

including associated bedload and debris. Crossings will be constructed or 

reconstructed and maintained to prevent diversion of streamflow out of the 

channel and down the road in the event of crossing failure.

Road 

construction

All existing and planned 

roads to be used in the 

project

MA10-44
Project 

Design 

Feature

Description Type of 

activity

Applicable Alternatives 

and Units (if variable)

Rationale or 

Applicable Standard

or Guideline or Best 

Management 

Practice (BMP)

Fisheries 3 Fall roadside safety hazard trees. Allow the removal of felled hazard trees 

where large woody debris requirements have been met; where fuel loads 

are excessive; where leaving the tree would threaten the function of a 

drainage structure or cause stream diversion; or where leaving the tree 

would present a safety hazard. In agreement with the NMFS, target level of 

LWD for properly functioning streams is 20 pieces of LWD per mile that are 

at least 24 inches dbh and 50 feet long.

Hazard Tree

Abatement

riparian reserves MA10-53

MA10-56

[criteria for LWD for 

properly functioning 

streams - agreement 

between the NMFS 

and the KNF]

Fisheries 4 Draft water only at sites designated by the Forest Service. Decisions related 

to where water drafting occurs will be coordinated with a Forest Service 

fisheries biologist so that potential impacts to anadromous fish, and the 

thermal refugia they rely upon, are sufficiently minimized.

Sites that are not likely to have rearing Coho salmon present will be 

prioritized for use, such as mainstem sites on the Klamath River and 

existing water drafting sites that are not fish-bearing. Priority will also be 

given to sites that involve drafting relatively warmer waters in mainstem 

rivers. Drafting from tributaries and colder water sources, especially in their 

lower reaches, will be avoided particularly during late summer and early fall 

(when flows are low and fish survival is dependent upon thermal refugia). 

Water storage facilities such as existing non-fish-bearing spring-fed drafting 

ponds and portable foldable tanks are encouraged. Project-related water 

drafting will be monitored, and shifted away from streams if their baseflows 

will no longer sustain drafting-related water withdrawal consistent with

project design features. Additional applicable specifications:

• There will be no modification or improvement of drafting sites in Coho 

Critical Habitat.

• Water drafting by more than one truck per site shall not occur 

simultaneously

• Water drafting from streams in the Horse Creek watershed will cease 

altogether if flows in the mainstem become critically low for Coho salmon

survival. Critically low flows in the lower mainstem often occur in late 

summer/early fall due to excessive water diversions for private lands.

Water Drafting Surface Waters Prevent adverse 

effects to Coho 

salmon and other 

aquatic organisms. 
Project 

Design 

Feature

Description Type of 

activity

Applicable Alternatives 

and Units (if variable)

Rationale or 

Applicable Standard

or Guideline or Best 

Management 

Practice (BMP)

Recreation 

and Scenic 

Resources 

1

To the degree practicable, minimize visibility of new landings from Highway 

96. Minimize visibility of existing landings from Highway 96, the Horse Creek 

community, the Horse Creek SIA, and all Level 1 and Level 2 Roads (47N81 

and 40S01, 8F001 and 8F003) by retaining screening trees where practical 

during operations, and by burning slash piles within three years after dead 

tree removal.

Landings Alternatives 2, 3, and 4. 

Unit 116.49, 115.33, 

115.34, 115.35, 118.93, 

117.15, 118.05, 118.03, 

118.04, 118.06, 118.07.

11-1, 11-3, 11-4, 11-

7, Response to public 

comment.

Recreation 

and Scenic 

Resources 

2

Where practical, minimize the visibility of new temporary roads through the 

retention of screening tree cover where it exists as seen from open areas 

along the Pacific Crest National Scenic Trail, and Level 1 and 2 Roads 

(47N81 and 40S01).

Temporary 

Roads

Alternatives 2, 3, and 4. 

Units 117.5, 118.05, 

118.03, 118.04, 118.06, 

118.12, 118.26.

11-1, 11-3, 11-4, 11-

7, Response to public 

comment.

Recreation 

and Scenic 

Resources 

3

If, 2-3 years after harvest, brush ingrowth has not hidden stump 

concentrations in high severity fire areas that are in full retention VQO areas 

within 150 feet of the road, visible stumps will be reduced in height. (Level 1 

and 2) roads in the Project area: 47N81, 40S01, 46N50 (within the Horse 

Creek SIA boundary), and County Road 8F003.

Stump 

treatments

Alternatives 2, 3, and 4. All 

proposed treatments 

(Roadside hazard tree 

removal, roadside fuels 

treatments, and Private 

Property fuel buffer 

treatments). Unit 115.35, 

Unit 117.15, Unit 118.12.

11-1, 11-3, 11-4, 11-

7, Response to public 

comment.

Recreation 

and Scenic 

Resources 

4

Ensure, where practical, to minimize edge line contrasts, as seen from the 

Klamath Wild and Scenic River, California State Route 96 (Klamath River 

National Forest Scenic Byway), Rocky Point River Access, and the 

community of Horse Creek.

Treatment 

boundaries

Alternatives 2, 3, and 4. All 

proposed treatments. Units 

116.49, 116.50, 115.33, 

115.34, 118.63.

11-1, 11-3, 11-4, 11-

7, Response to public 

comment.

Recreation 

and Scenic 

Resources 

5

Mark cut trees only for a depth of 100 feet from the edge of the following 

High and Moderate Sensitivity (Level 1 and 2) roads in the Project area: 

47N81, 40S01, 46N50 (within the Horse Creek SIA boundary), and County 

Road 8F003.

Marking Alternatives 2, 3, and 4. All 

proposed treatments 

(Roadside hazard tree 

removal, roadside fuels 

treatments, and private 

property fuel buffer 

treatments). Unit 115.35, 

Unit 117.15, Unit 118.12. 

11-1, 11-3, 11-4, 11-

7, Response to public 

comment.

Recreation 

and Scenic 

Resources 

6

Provide visitor information about area/road/trail closures, or other recreation 

setting changes caused by project activities in news releases, on-site, and 

on the Forest website.

Closures Alternatives 2, 3, and 4. All 

proposed treatments. 

12-3
Project 

Design 

Feature

Description Type of 

activity

Applicable Alternatives 

and Units (if variable)

Rationale or 

Applicable Standard

or Guideline or Best 

Management 

Practice (BMP)

Recreation 

and Scenic 

Resources 

7

Repair or replace recreational signing, or other facilities and trail settings if 

damaged during project implementation.

Recreation 

Resource 

Repairs

Alternatives 2, 3, and 4. All 

proposed treatments.

12-3, Response to 

public comment.

Recreation 

and Scenic 

Resources 

8

Provide safety signing along trails, rivers, or roads, as well as trail closures 

in active project areas to provide for public safety.

Closures Alternatives 2, 3, and 4. All 

proposed treatments.

12-3

Recreation 

and Scenic 

Resources 

9

Activity-generated slash created within 150 feet of the Pacific Crest National 

Scenic Trail, Forest Road 47N81, 40S01, 46N50 (within the Horse Creek 

SIA boundary), and County Road 8F003 will be piled and burned, or 

removed within one year from the date of project completion. Piles will be 

located a minimum of 100 feet from trails, trailheads, or viewing locations.

Slash 

treatment

Alternatives 2, 3, and 4. 

Forest Road 47N81, Alex 

Hole Overlook, Motor 

Vehicle Use Map 

Dispersed Camp 51D006, 

Unit 115.35, Unit 117.15, 

Unit 118.12.

11-1, 11-2, 11-3, 11-

4, Response to public 

comment.

Recreation 

and Scenic 

Resources 

10

Protect the Pacific Crest National Scenic Trail from damage during the 

implementation of roadside hazard tree activities.

Recreational 

Trails

Forest Road 47N81 

roadside hazard tree 

abatement.

Response to public 

comment.

Recreation 

and Scenic 

Resources 

11

Ensure skyline and/or cable yarding corridors are minimized through green 

tree retention, snag retention and riparian reserve areas by limiting corridor 

widths in retention areas to 12-15 feet. 

Cable corridor Alternatives 2, 3, and 4. 

Units 115.33, 115.35, 

116.49, 117.15, 118.4, 

118.5, 118.57, 118.6.

11-1, 11-2, 11-3, 11-

4, 11-7, Response to 

public comment.

Recreation 

and Scenic 

Resources 

12

Temporary road access to be blocked with boulders placed in an irregular 

pattern, and replanted with trees, brush, and or grasses in an irregular 

pattern.

Temporary 

roads

Units 118.3, 118.4, 118.06, 

118.12, 118.26, 117.15, 

118.05.

11-1, 11-2, 11-3, 11-

4, 11-7, Response to 

public comment.

*Wildlife 7 has been added since publication of the final environmental impact statement to add protection for a newly discovered bald 

eagle nest that is within the project area but outside of all treatment units. Potential effects to bald eagles were analyzed in the draft 

Wildlife Resource Report and draft Biological Evaluation, as one bald eagle nest was already known to occur along highway 96 in the 

project area. Those reports have been updated since the FEIS was printed to reflect the additional nest. With the added project design 

feature, the cumulative effects for Alternatives 2, 3, and 4 is the same as in the original reports for noise (low level of possible 

disturbance), but changed from “no effect” to “low level of risk” to current or future nest trees, as reflected in the updated reports.
—Draft Record of Decision—

Page 61

Best Management Practices, taken from the “USDA National Best Management Practices 

for Water Quality Management on National Forest System Lands, Vol. 1 National Core 

BMP Technical Guide” to be implemented for the Horse Creek Project.

BMP Number BMP Description

Fire-2. Use of Prescribed 

Fire

Avoid, minimize, or mitigate adverse effects of prescribed fire and 

associated activities on soil, water quality, and riparian resources that 

may result from excessive soil disturbance as well as inputs of ash, 

sediment, nutrients, and debris.

Road-2. Road Location and 

Design

Locate and design roads to avoid, minimize, or mitigate adverse effects to 

soil, water quality, and riparian resources.

Road-3. Road Construction 

and Reconstruction

Avoid or minimize adverse effects to soil, water quality, and riparian 

resources from erosion, sediment, and other pollutant delivery during 

road construction or reconstruction.

Road-4. Road Operations 

and Maintenance

Avoid, minimize, or mitigate adverse effects to soil, water quality, and 

riparian resources by controlling road use and operations and providing 

adequate and appropriate maintenance to minimize sediment production 

and other pollutants during the useful life of the road.

Road-5. Temporary Roads Avoid, minimize, or mitigate adverse effects to soil, water quality, and 

riparian resources from the construction and use of temporary roads.

Road-6. Road Storage and 

Decommissioning

Avoid, minimize, or mitigate adverse effects to soil, water quality, and 

riparian resources by storing closed roads not needed for at least 1 year 

(Intermittent Stored Service) and decommissioning unneeded roads in a 

hydrologically stable manner to eliminate hydrologic connectivity, restore 

natural flow patterns, and minimize soil erosion.

Road-7. Stream Crossings Avoid, minimize, or mitigate adverse effects to soil, water quality, and 

riparian resources when constructing, reconstructing, or maintaining 

temporary and permanent water-body crossings.

Road-9. Parking and 

Staging Areas

Avoid, minimize, or mitigate adverse effects to soil, water quality, and 

riparian resources when constructing and maintaining parking and 

staging areas.

Road-10. Equipment 

Refueling and Servicing

Avoid or minimize adverse effects to soil, water quality, and riparian 

resources from fuels, lubricants, cleaners, and other harmful materials 

discharging into nearby surface waters or infiltrating through soils to 

contaminate groundwater resources during equipment refueling and 

servicing activities.

Veg-2. Erosion Prevention 

and Control

Avoid, minimize, or mitigate adverse effects to soil, water quality, and 

riparian resources by implementing measures to control surface erosion, 

gully formation, mass slope failure, and resulting sediment movement 

before, during, and after mechanical vegetation treatments.

Veg-3. Aquatic 

Management Zones

Avoid, minimize, or mitigate adverse effects to soil, water quality, and 

riparian resources when conducting mechanical vegetation treatment 

activities in the AMZ.

Veg-4. Ground-Based

Skidding and Yarding 

Operations

Avoid, minimize, or mitigate adverse effects to soil, water quality, and 

riparian resources during ground-based skidding and yarding operations 

by minimizing site disturbance and controlling the introduction of 

sediment, nutrients, and chemical pollutants to waterbodies.

Veg-5. Cable and Aerial 

Yarding Operations

Avoid, minimize, or mitigate adverse effects to soil, water quality, and 

riparian resources during cable and aerial yarding operations by 

minimizing site disturbance and controlling the introduction of sediment, 

nutrients, and chemical pollutants to waterbodies.

Veg-6. Landings Avoid, minimize, or mitigate adverse effects to soil, water quality, and 

riparian resources from the construction and use of log landings.

Veg-8. Mechanical Site 

Treatment

Avoid, minimize, or mitigate adverse effects to soil, water quality, and 

riparian resources by controlling the introduction of sediment, nutrients, 
—Draft Record of Decision—

Page 62

BMP Number BMP Description

chemical, or other pollutants to waterbodies during mechanical site 

treatment.

BMPs that address timber harvesting, vegetation management and fuels reduction, streamside 

management zones, forest roads, prescribed burning, and landings taken from the “R5 FSH 

2509.22 - SOIL AND WATER CONSERVATION HANDBOOK” (USDA Forest Service 2011)

were also considered in the effects analysis for the three action alternatives proposed for the 

Horse Creek Project. This document can be found in the hydrology planning record.

There is overlap between the “USDA National Best Management Practices for Water Quality 

Management on National Forest System Lands, Vol. 1 National Core BMP Technical Guide” 

and the “R5 FSH 2509.22 - SOIL AND WATER CONSERVATION HANDBOOK.” We 

considered both documents in planning this project.