Smith River National Recreation Area 

Restoration and Motorized Travel 

Management

Final Environmental Impact Statement – 

Appendices

Forest

Service

Six Rivers

National Forest

Gasquet

Ranger District

R5-MB-290c 

December 2016 
Cover Photo: An unauthorized route (UAR 17N17.1) off the Wimer Road (County Road 305) on the 

Gasquet Ranger District/Smith River National Recreation Area. 

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Final Environmental Impact Statement – Appendices – i

Table of Contents

Appendix A. Alternative Tables ................................................................................................................3

Alternative 1..............................................................................................................................................3

Alternative 4............................................................................................................................................16

Alternative 5............................................................................................................................................39

Alternative 6............................................................................................................................................62

Appendix B. Monitoring Plan..................................................................................................................87

Water Quality Monitoring Plan...............................................................................................................87

Port-Orford-Cedar Monitoring Plan........................................................................................................89

Botanical Resources Monitoring Plan.....................................................................................................90

Recreation Monitoring Plan....................................................................................................................96

Noxious Weed Monitoring Plan .............................................................................................................96

Appendix C. Past, Present and Reasonably Foreseeable Activities....................................................101

Implementation Complete.....................................................................................................................101

Implementation Ongoing ......................................................................................................................102

Planned Activities.................................................................................................................................102

Appendix D. Mitigation Measures.........................................................................................................105

Resource Mitigations/Design Feature...................................................................................................107

USDA Forest Service – Region 5 BMPs OHV Use and Road Construction and Maintenance ...........111

USDA Forest Service National BMPs – Water Quality Management on NFS Lands (April 2012).....117

Invasive Plant Species and Aquatic Organisms BMPs.........................................................................133

Six Rivers Road Maintenance Project – 2016 to 2022..........................................................................139

Motorized Trail Maintenance................................................................................................................150

Appendix E. Cumulative Watershed Effects Analysis Using R-5 ERA Model .................................153

Assumptions and ERA Coefficients used for Travel Management Assessment...................................153

Appendix F. Law Enforcement..............................................................................................................159

Authority and Jurisdiction.....................................................................................................................159

Cooperation...........................................................................................................................................160

Implementation and Tracking ...............................................................................................................161

Assumptions..........................................................................................................................................162

Measure of Success...............................................................................................................................163

Appendix G. Response to Comments....................................................................................................165

Organizational Structure of Response to Comments............................................................................166

Project Development, NEPA and Implementation ...............................................................................167

Coordination with Del Norte County....................................................................................................168

Planning Process (including NEPA).....................................................................................................171

Impacts to Motorized Recreation Opportunities and Access to Dispersed Recreation.........................202
ii – Smith River National Recreation Area Restoration and Motorized Travel Management

Impacts to Non-Motorized Recreation..................................................................................................207

Impacts to Resources ............................................................................................................................210

Impacts to Specially Designated Areas.................................................................................................236

Health and Safety..................................................................................................................................243

Implementation .....................................................................................................................................253

Opinion or Position Statement ..............................................................................................................261

Maps......................................................................................................................................................267

Commenter Names, Organizations, and Letter Number.......................................................................268

Tables

Table A-1. Alternative 1 – Existing National Forest Transportation System (NFTS)..................................3

Table A-2. Alternative 1 – Inventoried Unauthorized Routes (UARs).......................................................12

Table A-3. Alternative 4. ............................................................................................................................16

Table A-4. Alternative 5. ............................................................................................................................39

Table A-5. Alternative 6. ............................................................................................................................62

Table B-1. Green-yellow-red water quality monitoring indicators.............................................................88

Table B- 2. Routes to be monitored – botany. ............................................................................................90

Table B-3. Management response thresholds. ............................................................................................95

Table B-4. Green-yellow-red botany monitoring indicators.......................................................................95

Table B-5. Cost per year. ............................................................................................................................95

Table B-6. Noxious weed sites to be monitored. ........................................................................................96

Table B-7. Green-yellow-red weed monitoring indicators. ........................................................................97

Table B-8. Cost. ..........................................................................................................................................97

Table B-9. Site effects and SRPM by alternative. ......................................................................................98

Table D-1. Mitigation measures by resource............................................................................................105

Table D-2. Additional analysis or new consultation required if motorized trail maintenance 

included in FEIS. ..............................................................................................................................151

Table E-1. Logging system ERA coefficient and recovery times.............................................................154

Table E-2. Road ERA coefficient and recovery times..............................................................................155

Table E-3. Wildfire equivalent roaded areas.............................................................................................155

Table E-4. Years to recover post-wildfire.................................................................................................156

Table E-5. Total percent ERAs by watershed...........................................................................................156

Table E-6. Existing %ERA compared to threshold of concern. ...............................................................158
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 3

Appendix A. Alternative Tables

Alternative 1

Table A-1. Alternative 1 – Existing National Forest Transportation System (NFTS).

Alternative 1 – Existing National Forest Transportation System

Road Number Total Miles Begin Mile 

Point End Mile Point Maintenance Level

13N27 1.60 0.00 1.60 2 - HIGH-CLEARANCE VEHICLES

13N35 6.15 0.25 6.40 2 - HIGH-CLEARANCE VEHICLES

13N35A 0.55 0.00 0.55 2 - HIGH-CLEARANCE VEHICLES

13N35B 0.63 0.00 0.63 2 - HIGH-CLEARANCE VEHICLES

13N35D 0.16 0.00 0.16 2 - HIGH-CLEARANCE VEHICLES

13N35E 0.27 0.00 0.27 2 - HIGH-CLEARANCE VEHICLES

13N35F 0.42 0.00 0.42 2 - HIGH-CLEARANCE VEHICLES

13N35G 0.39 0.00 0.39 2 - HIGH-CLEARANCE VEHICLES

13N35J 0.25 0.00 0.25 2 - HIGH-CLEARANCE VEHICLES

13N35K 0.28 0.00 0.28 2 - HIGH-CLEARANCE VEHICLES

13N35L 0.11 0.00 0.11 2 - HIGH-CLEARANCE VEHICLES

13N35M 0.07 0.00 0.07 2 - HIGH-CLEARANCE VEHICLES

13N37 2.00 0.00 2.00 2 - HIGH-CLEARANCE VEHICLES

13N37A 0.77 0.00 0.77 2 - HIGH-CLEARANCE VEHICLES

13N37B 0.27 0.00 0.27 2 - HIGH-CLEARANCE VEHICLES

14N01 4.61 9.60 14.21 3 - SUITABLE FOR PASSENGER CARS

14N01D 1.80 0.00 1.80 2 - HIGH-CLEARANCE VEHICLES

14N08 0.50 0.00 0.50 2 - HIGH-CLEARANCE VEHICLES

14N08T 0.11 0.00 0.11 1 - BASIC CUSTODIAL CARE (CLOSED)

14N15 0.50 0.00 0.50 2 - HIGH-CLEARANCE VEHICLES

14N18 1.00 0.00 1.00 1 - BASIC CUSTODIAL CARE (CLOSED)

14N29 1.60 0.00 1.60 2 - HIGH-CLEARANCE VEHICLES

14N32 1.70 0.00 1.70 2 - HIGH-CLEARANCE VEHICLES

14N33 1.78 0.00 1.78 2 - HIGH-CLEARANCE VEHICLES

14N33A 0.22 0.00 0.22 1 - BASIC CUSTODIAL CARE (CLOSED)

14N38 0.60 0.00 0.60 2 - HIGH-CLEARANCE VEHICLES

14N39 1.90 0.00 1.90 2 - HIGH-CLEARANCE VEHICLES

14N46 2.70 0.00 2.70 2 - HIGH-CLEARANCE VEHICLES

14N46B 0.37 0.00 0.37 1 - BASIC CUSTODIAL CARE (CLOSED)

15N01 18.30 0.00 18.30 5 - HIGH DEGREE OF USER COMFORT

15N01A 1.59 0.00 1.59 2 - HIGH-CLEARANCE VEHICLES

15N01B 0.57 0.00 0.57 2 - HIGH-CLEARANCE VEHICLES

15N01P 0.79 0.00 0.79 1 - BASIC CUSTODIAL CARE (CLOSED)

15N01Q 0.79 0.00 0.79 1 - BASIC CUSTODIAL CARE (CLOSED)

15N01R 0.10 0.00 0.10 1 - BASIC CUSTODIAL CARE (CLOSED)

15N01S 0.10 0.00 0.10 1 - BASIC CUSTODIAL CARE (CLOSED)

15N01U 0.70 0.00 0.70 1 - BASIC CUSTODIAL CARE (CLOSED)
Appendix A. Alternative Tables

4 – Smith River National Recreation Area Restoration and Motorized Travel Management

Alternative 1 – Existing National Forest Transportation System

Road Number Total Miles Begin Mile 

Point End Mile Point Maintenance Level

15N02 10.39 0.00 10.39 2 - HIGH-CLEARANCE VEHICLES

15N11 2.70 0.00 2.70 2 - HIGH-CLEARANCE VEHICLES

15N11A 1.70 0.00 1.70 1 - BASIC CUSTODIAL CARE (CLOSED)

15N11B 1.39 0.00 1.39 1 - BASIC CUSTODIAL CARE (CLOSED)

15N13 3.80 0.00 3.80 2 - HIGH-CLEARANCE VEHICLES

15N33 0.90 0.00 0.90 1 - BASIC CUSTODIAL CARE (CLOSED)

15N34 2.12 0.00 2.12 2 - HIGH-CLEARANCE VEHICLES

15N34 0.03 2.12 2.15 2 - HIGH-CLEARANCE VEHICLES

15N35 2.24 0.00 2.24 2 - HIGH-CLEARANCE VEHICLES

15N35A 0.24 0.00 0.24 2 - HIGH-CLEARANCE VEHICLES

15N35B 0.57 0.00 0.57 1 - BASIC CUSTODIAL CARE (CLOSED)

15N35C 0.57 0.00 0.57 1 - BASIC CUSTODIAL CARE (CLOSED)

15N36 1.36 0.00 1.36 3 - SUITABLE FOR PASSENGER CARS

15N36C 0.55 0.00 0.55 1 - BASIC CUSTODIAL CARE (CLOSED)

15N36N 2.60 0.00 2.60 1 - BASIC CUSTODIAL CARE (CLOSED)

15N38 2.90 0.00 2.90 2 - HIGH-CLEARANCE VEHICLES

15N38A 0.49 0.00 0.49 2 - HIGH-CLEARANCE VEHICLES

15N39 2.05 0.00 2.05 3 - SUITABLE FOR PASSENGER CARS

15N39A 1.20 0.00 1.20 1 - BASIC CUSTODIAL CARE (CLOSED)

15N39B 0.50 0.00 0.50 1 - BASIC CUSTODIAL CARE (CLOSED)

15N42 1.06 0.00 1.06 2 - HIGH-CLEARANCE VEHICLES

15N42A 0.44 0.00 0.44 1 - BASIC CUSTODIAL CARE (CLOSED)

15N45 1.27 1.23 2.50 1 - BASIC CUSTODIAL CARE (CLOSED)

15N52 0.14 0.00 0.14 3 - SUITABLE FOR PASSENGER CARS

15N53 0.15 0.00 0.15 2 - HIGH-CLEARANCE VEHICLES

15N54 0.10 0.00 0.10 2 - HIGH-CLEARANCE VEHICLES

15N55 0.23 0.00 0.23 2 - HIGH-CLEARANCE VEHICLES

15N56 0.16 0.00 0.16 2 - HIGH-CLEARANCE VEHICLES

15N57 0.20 0.00 0.20 2 - HIGH-CLEARANCE VEHICLES

15N58 0.27 0.00 0.27 2 - HIGH-CLEARANCE VEHICLES

15N59 0.44 0.00 0.44 3 - SUITABLE FOR PASSENGER CARS

15N63 0.30 0.00 0.30 2 - HIGH-CLEARANCE VEHICLES

16N02 0.81 0.89 1.70 3 - SUITABLE FOR PASSENGER CARS

16N02 3.21 1.70 4.91 3 - SUITABLE FOR PASSENGER CARS

16N02 4.58 4.91 9.49 3 - SUITABLE FOR PASSENGER CARS

16N02 0.89 0.00 0.89 3 - SUITABLE FOR PASSENGER CARS

16N02 8.31 9.49 17.80 3 - SUITABLE FOR PASSENGER CARS

16N02 3.50 17.80 21.30 3 - SUITABLE FOR PASSENGER CARS

16N02A 0.60 0.00 0.60 2 - HIGH-CLEARANCE VEHICLES

16N02D 0.61 0.00 0.61 2 - HIGH-CLEARANCE VEHICLES

16N02E 0.40 0.00 0.40 2 - HIGH-CLEARANCE VEHICLES

16N02F 0.10 0.00 0.10 2 - HIGH-CLEARANCE VEHICLES

16N02G 0.70 0.00 0.70 2 - HIGH-CLEARANCE VEHICLES

16N02H 0.40 0.00 0.40 1 - BASIC CUSTODIAL CARE (CLOSED)
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 5

Alternative 1 – Existing National Forest Transportation System

Road Number Total Miles Begin Mile 

Point End Mile Point Maintenance Level

16N02L 1.70 0.00 1.70 2 - HIGH-CLEARANCE VEHICLES

16N02P 0.40 0.00 0.40 2 - HIGH-CLEARANCE VEHICLES

16N02S 1.20 0.00 1.20 1 - BASIC CUSTODIAL CARE (CLOSED)

16N02T 0.50 0.00 0.50 1 - BASIC CUSTODIAL CARE (CLOSED)

16N03 14.43 0.00 14.43 2 - HIGH-CLEARANCE VEHICLES

16N03A 0.06 0.00 0.06 1 - BASIC CUSTODIAL CARE (CLOSED)

16N03B 0.80 0.00 0.80 2 - HIGH-CLEARANCE VEHICLES

16N03D 1.40 0.00 1.40 1 - BASIC CUSTODIAL CARE (CLOSED)

16N03F 0.70 0.00 0.70 2 - HIGH-CLEARANCE VEHICLES

16N03G 0.08 0.00 0.08 1 - BASIC CUSTODIAL CARE (CLOSED)

16N03H 0.30 0.00 0.30 2 - HIGH-CLEARANCE VEHICLES

16N03K 1.50 0.00 1.50 2 - HIGH-CLEARANCE VEHICLES

16N03L 0.20 0.00 0.20 1 - BASIC CUSTODIAL CARE (CLOSED)

16N04 0.19 0.00 0.19 4 - MODERATE DEGREE OF USER COMFORT

16N04A 0.05 0.00 0.05 4 - MODERATE DEGREE OF USER COMFORT

16N09 0.58 0.00 0.58 2 - HIGH-CLEARANCE VEHICLES

16N15 0.80 0.00 0.80 2 - HIGH-CLEARANCE VEHICLES

16N15A 0.17 0.00 0.17 2 - HIGH-CLEARANCE VEHICLES

16N16 2.10 0.00 2.10 2 - HIGH-CLEARANCE VEHICLES

16N18 4.12 0.00 4.12 2 - HIGH-CLEARANCE VEHICLES

16N18 4.88 4.12 9.00 2 - HIGH-CLEARANCE VEHICLES

16N18A 2.30 0.00 2.30 2 - HIGH-CLEARANCE VEHICLES

16N18B 0.50 0.00 0.50 2 - HIGH-CLEARANCE VEHICLES

16N18C 0.39 0.00 0.39 1 - BASIC CUSTODIAL CARE (CLOSED)

16N18E 0.96 0.00 0.96 2 - HIGH-CLEARANCE VEHICLES

16N18G 0.80 0.00 0.80 2 - HIGH-CLEARANCE VEHICLES

16N18K 1.10 0.00 1.10 1 - BASIC CUSTODIAL CARE (CLOSED)

16N19 2.70 0.00 2.70 2 - HIGH-CLEARANCE VEHICLES

16N19 4.10 2.70 6.80 2 - HIGH-CLEARANCE VEHICLES

16N19 1.48 6.80 8.28 2 - HIGH-CLEARANCE VEHICLES

16N19 0.00 8.28 0.00 2 - HIGH-CLEARANCE VEHICLES

16N19A 0.23 0.00 0.23 2 - HIGH-CLEARANCE VEHICLES

16N19B 1.40 0.00 1.40 2 - HIGH-CLEARANCE VEHICLES

16N19D 0.40 0.00 0.40 2 - HIGH-CLEARANCE VEHICLES

16N19E 0.95 0.00 0.95 2 - HIGH-CLEARANCE VEHICLES

16N19F 0.76 0.00 0.76 2 - HIGH-CLEARANCE VEHICLES

16N19G 0.23 0.00 0.23 2 - HIGH-CLEARANCE VEHICLES

16N21 3.69 0.00 3.69 2 - HIGH-CLEARANCE VEHICLES

16N21F 0.30 0.00 0.30 2 - HIGH-CLEARANCE VEHICLES

16N21F 1.50 0.30 1.80 2 - HIGH-CLEARANCE VEHICLES

16N23 7.40 0.00 7.40 2 - HIGH-CLEARANCE VEHICLES

16N24 1.10 0.00 1.10 2 - HIGH-CLEARANCE VEHICLES

16N24A 0.65 0.00 0.65 1 - BASIC CUSTODIAL CARE (CLOSED)

16N25 0.96 0.00 0.96 2 - HIGH-CLEARANCE VEHICLES
Appendix A. Alternative Tables

6 – Smith River National Recreation Area Restoration and Motorized Travel Management

Alternative 1 – Existing National Forest Transportation System

Road Number Total Miles Begin Mile 

Point End Mile Point Maintenance Level

16N27 0.50 0.00 0.50 1 - BASIC CUSTODIAL CARE (CLOSED)

16N30 0.24 0.00 0.24 1 - BASIC CUSTODIAL CARE (CLOSED)

16N31 0.35 0.00 0.35 1 - BASIC CUSTODIAL CARE (CLOSED)

16N31B 1.00 0.00 1.00 1 - BASIC CUSTODIAL CARE (CLOSED)

16N32 3.94 0.00 3.94 2 - HIGH-CLEARANCE VEHICLES

16N32A 0.08 0.00 0.08 1 - BASIC CUSTODIAL CARE (CLOSED)

16N32C 0.47 0.00 0.47 1 - BASIC CUSTODIAL CARE (CLOSED)

16N33 0.70 0.00 0.70 2 - HIGH-CLEARANCE VEHICLES

16N33 3.70 0.70 4.40 1 - BASIC CUSTODIAL CARE (CLOSED)

16N33A 0.21 0.00 0.21 1 - BASIC CUSTODIAL CARE (CLOSED)

16N34 0.90 0.00 0.90 2 - HIGH-CLEARANCE VEHICLES

16N34A 0.50 0.00 0.50 2 - HIGH-CLEARANCE VEHICLES

16N35 0.80 0.00 0.80 2 - HIGH-CLEARANCE VEHICLES

16N35 0.84 0.80 1.64 2 - HIGH-CLEARANCE VEHICLES

16N35A 0.14 0.00 0.14 1 - BASIC CUSTODIAL CARE (CLOSED)

16N35B 0.16 0.00 0.16 2 - HIGH-CLEARANCE VEHICLES

16N35C 0.12 0.00 0.12 2 - HIGH-CLEARANCE VEHICLES

16N36 1.20 0.00 1.20 2 - HIGH-CLEARANCE VEHICLES

16N36B 0.80 0.00 0.80 2 - HIGH-CLEARANCE VEHICLES

16N37 1.20 0.00 1.20 2 - HIGH-CLEARANCE VEHICLES

16N37B 0.17 0.00 0.17 2 - HIGH-CLEARANCE VEHICLES

16N38 1.60 0.00 1.60 2 - HIGH-CLEARANCE VEHICLES

16N39 0.58 0.00 0.58 1 - BASIC CUSTODIAL CARE (CLOSED)

16N39A 0.22 0.00 0.22 1 - BASIC CUSTODIAL CARE (CLOSED)

16N40 0.66 0.00 0.66 2 - HIGH-CLEARANCE VEHICLES

16N41 1.43 0.00 1.43 2 - HIGH-CLEARANCE VEHICLES

16N41A 0.17 0.00 0.17 2 - HIGH-CLEARANCE VEHICLES

16N41B 0.09 0.00 0.09 2 - HIGH-CLEARANCE VEHICLES

16N41C 0.89 0.00 0.89 2 - HIGH-CLEARANCE VEHICLES

16N55 0.50 0.00 0.50 1 - BASIC CUSTODIAL CARE (CLOSED)

16N71 0.70 0.00 0.70 2 - HIGH-CLEARANCE VEHICLES

17N01 0.70 0.00 0.70 2 - HIGH-CLEARANCE VEHICLES

17N03 1.20 0.00 1.20 1 - BASIC CUSTODIAL CARE (CLOSED)

17N04 7.89 0.00 7.89 3 - SUITABLE FOR PASSENGER CARS

17N04L 3.10 0.00 3.10 1 - BASIC CUSTODIAL CARE (CLOSED)

17N04R 0.59 0.00 0.59 1 - BASIC CUSTODIAL CARE (CLOSED)

17N04S 1.80 0.00 1.80 1 - BASIC CUSTODIAL CARE (CLOSED)

17N05 8.00 0.00 8.00 4 - MODERATE DEGREE OF USER COMFORT

17N05 0.50 8.00 8.50 4 - MODERATE DEGREE OF USER COMFORT

17N05 0.18 8.50 8.68 4 - MODERATE DEGREE OF USER COMFORT

17N05 1.06 8.68 9.74 4 - MODERATE DEGREE OF USER COMFORT

17N05A 1.04 0.00 1.04 2 - HIGH-CLEARANCE VEHICLES

17N05C 0.97 0.00 0.97 1 - BASIC CUSTODIAL CARE (CLOSED)

17N05E 0.71 0.00 0.71 1 - BASIC CUSTODIAL CARE (CLOSED)
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 7

Alternative 1 – Existing National Forest Transportation System

Road Number Total Miles Begin Mile 

Point End Mile Point Maintenance Level

17N05F 1.56 0.00 1.56 1 - BASIC CUSTODIAL CARE (CLOSED)

17N05G 0.67 0.00 0.67 1 - BASIC CUSTODIAL CARE (CLOSED)

17N05U 0.28 0.00 0.28 1 - BASIC CUSTODIAL CARE (CLOSED)

17N07 0.60 0.00 0.60 3 - SUITABLE FOR PASSENGER CARS

17N07 9.79 0.60 10.39 3 - SUITABLE FOR PASSENGER CARS

17N07G 1.67 0.00 1.67 2 - HIGH-CLEARANCE VEHICLES

17N07J 1.50 0.00 1.50 2 - HIGH-CLEARANCE VEHICLES

17N07K 0.80 0.00 0.80 2 - HIGH-CLEARANCE VEHICLES

17N07Q 0.22 0.00 0.22 2 - HIGH-CLEARANCE VEHICLES

17N07R 0.44 0.00 0.44 2 - HIGH-CLEARANCE VEHICLES

17N08 7.08 0.00 7.08 3 - SUITABLE FOR PASSENGER CARS

17N08A 0.50 0.00 0.50 1 - BASIC CUSTODIAL CARE (CLOSED)

17N13 0.70 0.00 0.70 2 - HIGH-CLEARANCE VEHICLES

17N13A 0.38 0.00 0.38 2 - HIGH-CLEARANCE VEHICLES

17N14 0.39 0.00 0.39 2 - HIGH-CLEARANCE VEHICLES

17N15 0.90 0.00 0.90 2 - HIGH-CLEARANCE VEHICLES

17N15A 0.13 0.00 0.13 1 - BASIC CUSTODIAL CARE (CLOSED)

17N16 0.65 0.00 0.65 2 - HIGH-CLEARANCE VEHICLES

17N17 0.60 0.00 0.60 1 - BASIC CUSTODIAL CARE (CLOSED)

17N18 0.70 0.00 0.70 3 - SUITABLE FOR PASSENGER CARS

17N18 2.94 0.70 3.64 3 - SUITABLE FOR PASSENGER CARS

17N18 0.71 3.64 4.35 3 - SUITABLE FOR PASSENGER CARS

17N18 2.92 4.35 7.27 3 - SUITABLE FOR PASSENGER CARS

17N18 0.39 7.27 7.66 3 - SUITABLE FOR PASSENGER CARS

17N18A 0.39 0.00 0.39 1 - BASIC CUSTODIAL CARE (CLOSED)

17N18A 0.55 0.39 0.94 1 - BASIC CUSTODIAL CARE (CLOSED)

17N18C 0.67 0.00 0.67 2 - HIGH-CLEARANCE VEHICLES

17N18E 0.42 0.00 0.42 1 - BASIC CUSTODIAL CARE (CLOSED)

17N18F 0.07 0.00 0.07 1 - BASIC CUSTODIAL CARE (CLOSED)

17N19 0.50 0.00 0.50 1 - BASIC CUSTODIAL CARE (CLOSED)

17N20 0.19 0.00 0.19 2 - HIGH-CLEARANCE VEHICLES

17N21 2.00 0.00 2.00 3 - SUITABLE FOR PASSENGER CARS

17N21 1.80 2.00 3.80 3 - SUITABLE FOR PASSENGER CARS

17N21A 0.20 0.00 0.20 2 - HIGH-CLEARANCE VEHICLES

17N21A 0.30 0.20 0.50 2 - HIGH-CLEARANCE VEHICLES

17N21B 0.31 0.00 0.31 2 - HIGH-CLEARANCE VEHICLES

17N21C 0.20 0.00 0.20 2 - HIGH-CLEARANCE VEHICLES

17N22 1.50 0.00 1.50 3 - SUITABLE FOR PASSENGER CARS

17N22 2.89 1.50 4.39 3 - SUITABLE FOR PASSENGER CARS

17N22A 0.79 0.00 0.79 2 - HIGH-CLEARANCE VEHICLES

17N22B 0.63 0.00 0.63 2 - HIGH-CLEARANCE VEHICLES

17N22C 0.16 0.00 0.16 2 - HIGH-CLEARANCE VEHICLES

17N22D 0.08 0.00 0.08 2 - HIGH-CLEARANCE VEHICLES

17N22G 0.29 0.00 0.29 2 - HIGH-CLEARANCE VEHICLES
Appendix A. Alternative Tables

8 – Smith River National Recreation Area Restoration and Motorized Travel Management

Alternative 1 – Existing National Forest Transportation System

Road Number Total Miles Begin Mile 

Point End Mile Point Maintenance Level

17N22J 0.12 0.00 0.12 2 - HIGH-CLEARANCE VEHICLES

17N23 2.80 0.00 2.80 1 - BASIC CUSTODIAL CARE (CLOSED)

17N24 1.00 0.00 1.00 2 - HIGH-CLEARANCE VEHICLES

17N25 0.49 0.00 0.49 1 - BASIC CUSTODIAL CARE (CLOSED)

17N26 0.25 0.00 0.25 2 - HIGH-CLEARANCE VEHICLES

17N26A 0.37 0.00 0.37 2 - HIGH-CLEARANCE VEHICLES

17N27 1.70 0.00 1.70 3 - SUITABLE FOR PASSENGER CARS

17N27 2.29 1.70 3.99 3 - SUITABLE FOR PASSENGER CARS

17N27A 0.50 0.00 0.50 1 - BASIC CUSTODIAL CARE (CLOSED)

17N27B 0.40 0.00 0.40 1 - BASIC CUSTODIAL CARE (CLOSED)

17N27C 0.40 0.00 0.40 1 - BASIC CUSTODIAL CARE (CLOSED)

17N28 0.20 0.00 0.20 1 - BASIC CUSTODIAL CARE (CLOSED)

17N29 1.00 0.00 1.00 2 - HIGH-CLEARANCE VEHICLES

17N29B 0.20 0.00 0.20 2 - HIGH-CLEARANCE VEHICLES

17N30 1.30 0.00 1.30 2 - HIGH-CLEARANCE VEHICLES

17N30A 0.40 0.00 0.40 2 - HIGH-CLEARANCE VEHICLES

17N31 1.60 0.00 1.60 2 - HIGH-CLEARANCE VEHICLES

17N32 3.40 0.00 3.40 2 - HIGH-CLEARANCE VEHICLES

17N32B 0.80 0.00 0.80 2 - HIGH-CLEARANCE VEHICLES

17N32F 1.00 0.00 1.00 2 - HIGH-CLEARANCE VEHICLES

17N32G 2.00 0.00 2.00 2 - HIGH-CLEARANCE VEHICLES

17N35 0.50 0.00 0.50 2 - HIGH-CLEARANCE VEHICLES

17N36 2.50 0.00 2.50 2 - HIGH-CLEARANCE VEHICLES

17N36B 1.00 0.00 1.00 2 - HIGH-CLEARANCE VEHICLES

17N36C 0.43 0.00 0.43 1 - BASIC CUSTODIAL CARE (CLOSED)

17N36F 1.20 0.00 1.20 1 - BASIC CUSTODIAL CARE (CLOSED)

17N37 0.14 0.00 0.14 2 - HIGH-CLEARANCE VEHICLES

17N39 2.19 0.00 2.19 2 - HIGH-CLEARANCE VEHICLES

17N39A 0.95 0.00 0.95 1 - BASIC CUSTODIAL CARE (CLOSED)

17N39B 0.51 0.00 0.51 1 - BASIC CUSTODIAL CARE (CLOSED)

17N39C 0.12 0.00 0.12 1 - BASIC CUSTODIAL CARE (CLOSED)

17N40 1.00 0.00 1.00 2 - HIGH-CLEARANCE VEHICLES

17N40B 0.53 0.00 0.53 2 - HIGH-CLEARANCE VEHICLES

17N40C 0.51 0.00 0.51 2 - HIGH-CLEARANCE VEHICLES

17N40D 0.18 0.00 0.18 1 - BASIC CUSTODIAL CARE (CLOSED)

17N41 4.25 0.00 4.25 2 - HIGH-CLEARANCE VEHICLES

17N41A 0.30 0.00 0.30 1 - BASIC CUSTODIAL CARE (CLOSED)

17N41G 0.95 0.00 0.95 2 - HIGH-CLEARANCE VEHICLES

17N41H 0.90 0.00 0.90 2 - HIGH-CLEARANCE VEHICLES

17N42 1.51 0.00 1.51 2 - HIGH-CLEARANCE VEHICLES

17N42A 1.28 0.00 1.28 2 - HIGH-CLEARANCE VEHICLES

17N43 1.00 0.00 1.00 2 - HIGH-CLEARANCE VEHICLES

17N45 0.70 0.00 0.70 2 - HIGH-CLEARANCE VEHICLES

17N46 1.20 0.00 1.20 2 - HIGH-CLEARANCE VEHICLES
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 9

Alternative 1 – Existing National Forest Transportation System

Road Number Total Miles Begin Mile 

Point End Mile Point Maintenance Level

17N46A 0.16 0.00 0.16 1 - BASIC CUSTODIAL CARE (CLOSED)

17N48 1.66 0.00 1.66 2 - HIGH-CLEARANCE VEHICLES

17N48C 0.47 0.00 0.47 1 - BASIC CUSTODIAL CARE (CLOSED)

17N49 0.66 0.00 0.66 3 - SUITABLE FOR PASSENGER CARS

17N49 1.16 0.66 1.81 3 - SUITABLE FOR PASSENGER CARS

17N49 0.03 1.81 1.84 3 - SUITABLE FOR PASSENGER CARS

17N49 0.52 1.84 2.36 3 - SUITABLE FOR PASSENGER CARS

17N49 0.06 2.36 2.42 3 - SUITABLE FOR PASSENGER CARS

17N49 0.54 2.42 2.96 3 - SUITABLE FOR PASSENGER CARS

17N49 0.10 2.96 3.06 3 - SUITABLE FOR PASSENGER CARS

17N49 0.37 3.06 3.43 3 - SUITABLE FOR PASSENGER CARS

17N49 0.04 3.43 3.47 3 - SUITABLE FOR PASSENGER CARS

17N49 0.10 3.47 3.57 3 - SUITABLE FOR PASSENGER CARS

17N49 0.06 3.57 3.63 3 - SUITABLE FOR PASSENGER CARS

17N49 2.31 3.63 5.93 3 - SUITABLE FOR PASSENGER CARS

17N49 0.11 5.93 6.05 3 - SUITABLE FOR PASSENGER CARS

17N49 1.02 6.05 7.07 3 - SUITABLE FOR PASSENGER CARS

17N49 0.09 7.07 7.16 3 - SUITABLE FOR PASSENGER CARS

17N49 0.10 7.16 7.25 3 - SUITABLE FOR PASSENGER CARS

17N49 0.16 7.25 7.42 3 - SUITABLE FOR PASSENGER CARS

17N49 0.19 7.42 7.61 3 - SUITABLE FOR PASSENGER CARS

17N49 0.24 7.61 7.85 3 - SUITABLE FOR PASSENGER CARS

17N53 0.30 0.00 0.30 4 - MODERATE DEGREE OF USER COMFORT

17N53A 0.30 0.00 0.30 2 - HIGH-CLEARANCE VEHICLES

17N62 0.37 0.00 0.37 4 - MODERATE DEGREE OF USER COMFORT

17N62A 0.41 0.00 0.41 4 - MODERATE DEGREE OF USER COMFORT

17N62B 0.24 0.00 0.24 4 - MODERATE DEGREE OF USER COMFORT

17N63 0.30 0.00 0.30 2 - HIGH-CLEARANCE VEHICLES

17N64 0.09 0.00 0.09 4 - MODERATE DEGREE OF USER COMFORT

17N64A 0.25 0.00 0.25 5 - HIGH DEGREE OF USER COMFORT

17N64B 0.08 0.00 0.08 4 - MODERATE DEGREE OF USER COMFORT

17N69 0.04 0.00 0.04 2 - HIGH-CLEARANCE VEHICLES

17N69 0.72 0.18 0.90 2 - HIGH-CLEARANCE VEHICLES

17N69 2.00 0.90 2.90 2 - HIGH-CLEARANCE VEHICLES

17N70 0.18 0.00 0.18 4 - MODERATE DEGREE OF USER COMFORT

17N70A 0.09 0.00 0.09 4 - MODERATE DEGREE OF USER COMFORT

17N70B 0.09 0.00 0.09 4 - MODERATE DEGREE OF USER COMFORT

17N71 0.20 0.00 0.20 2 - HIGH-CLEARANCE VEHICLES

17N92 1.52 0.00 1.52 1 - BASIC CUSTODIAL CARE (CLOSED)

18N01 0.10 0.00 0.10 1 - BASIC CUSTODIAL CARE (CLOSED)

18N01 0.06 0.10 0.16 1 - BASIC CUSTODIAL CARE (CLOSED)

18N02 2.00 0.00 2.60 3 - SUITABLE FOR PASSENGER CARS

18N03 1.91 0.00 1.91 1 - BASIC CUSTODIAL CARE (CLOSED)

18N04 5.35 0.00 5.35 2 - HIGH-CLEARANCE VEHICLES
Appendix A. Alternative Tables

10 – Smith River National Recreation Area Restoration and Motorized Travel Management

Alternative 1 – Existing National Forest Transportation System

Road Number Total Miles Begin Mile 

Point End Mile Point Maintenance Level

18N04B 0.83 0.00 0.83 2 - HIGH-CLEARANCE VEHICLES

18N04E 0.86 0.00 0.86 2 - HIGH-CLEARANCE VEHICLES

18N05 2.00 0.00 2.00 1 - BASIC CUSTODIAL CARE (CLOSED)

18N06 0.88 0.00 0.88 2 - HIGH-CLEARANCE VEHICLES

18N06 0.45 0.88 1.33 2 - HIGH-CLEARANCE VEHICLES

18N06A 0.18 0.00 0.18 1 - BASIC CUSTODIAL CARE (CLOSED)

18N07 8.00 0.00 8.00 3 - SUITABLE FOR PASSENGER CARS

18N07 5.53 8.00 13.53 3 - SUITABLE FOR PASSENGER CARS

18N08 12.38 0.00 12.38 3 - SUITABLE FOR PASSENGER CARS

18N08F 1.80 0.00 1.80 2 - HIGH-CLEARANCE VEHICLES

18N08G 1.12 0.00 1.12 1 - BASIC CUSTODIAL CARE (CLOSED)

18N08M 1.00 0.00 1.00 1 - BASIC CUSTODIAL CARE (CLOSED)

18N09 5.10 0.00 5.10 2 - HIGH-CLEARANCE VEHICLES

18N09 6.93 5.10 11.00 1 - BASIC CUSTODIAL CARE (CLOSED)

18N10 1.42 0.00 1.42 2 - HIGH-CLEARANCE VEHICLES

18N11 1.91 0.00 1.91 2 - HIGH-CLEARANCE VEHICLES

18N11 3.79 2.28 6.07 2 - HIGH-CLEARANCE VEHICLES

18N11A 0.80 0.00 0.80 1 - BASIC CUSTODIAL CARE (CLOSED)

18N11B 0.19 0.00 0.19 1 - BASIC CUSTODIAL CARE (CLOSED)

18N11C 0.20 0.00 0.20 1 - BASIC CUSTODIAL CARE (CLOSED)

18N11D 0.46 0.00 0.46 1 - BASIC CUSTODIAL CARE (CLOSED)

18N12 1.10 0.00 1.10 2 - HIGH-CLEARANCE VEHICLES

18N12A 0.43 0.00 0.43 1 - BASIC CUSTODIAL CARE (CLOSED)

18N13 7.51 0.24 7.75 1 - BASIC CUSTODIAL CARE (CLOSED)

18N13 0.24 0.00 0.24 2 - HIGH-CLEARANCE VEHICLES

18N14 1.00 0.00 1.00 1 - BASIC CUSTODIAL CARE (CLOSED)

18N15 1.20 0.00 1.20 2 - HIGH-CLEARANCE VEHICLES

18N15A 0.60 0.00 0.60 2 - HIGH-CLEARANCE VEHICLES

18N15D 0.23 0.00 0.23 2 - HIGH-CLEARANCE VEHICLES

18N16 5.33 0.00 5.33 2 - HIGH-CLEARANCE VEHICLES

18N16B 0.55 0.00 0.55 2 - HIGH-CLEARANCE VEHICLES

18N16E 0.38 0.00 0.38 1 - BASIC CUSTODIAL CARE (CLOSED)

18N16F 0.78 0.00 0.78 2 - HIGH-CLEARANCE VEHICLES

18N16G 0.70 0.00 0.70 1 - BASIC CUSTODIAL CARE (CLOSED)

18N16J 0.99 0.00 0.99 2 - HIGH-CLEARANCE VEHICLES

18N16W 0.17 0.00 0.17 2 - HIGH-CLEARANCE VEHICLES

18N17 5.90 0.00 5.90 2 - HIGH-CLEARANCE VEHICLES

18N17 2.20 5.90 8.10 2 - HIGH-CLEARANCE VEHICLES

18N17A 0.21 0.00 0.21 2 - HIGH-CLEARANCE VEHICLES

18N17B 0.87 0.00 0.87 2 - HIGH-CLEARANCE VEHICLES

18N17C 1.18 0.00 1.18 2 - HIGH-CLEARANCE VEHICLES

18N17D 0.25 0.00 0.25 2 - HIGH-CLEARANCE VEHICLES

18N17E 0.90 0.00 0.90 2 - HIGH-CLEARANCE VEHICLES

18N17F 0.54 0.00 0.54 2 - HIGH-CLEARANCE VEHICLES
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 11

Alternative 1 – Existing National Forest Transportation System

Road Number Total Miles Begin Mile 

Point End Mile Point Maintenance Level

18N17G 0.12 0.00 0.12 2 - HIGH-CLEARANCE VEHICLES

18N17H 0.15 0.00 0.15 2 - HIGH-CLEARANCE VEHICLES

18N18 1.43 0.00 1.43 2 - HIGH-CLEARANCE VEHICLES

18N18A 0.20 0.00 0.20 1 - BASIC CUSTODIAL CARE (CLOSED)

18N18B 0.15 0.00 0.15 1 - BASIC CUSTODIAL CARE (CLOSED)

18N18C 0.08 0.00 0.08 1 - BASIC CUSTODIAL CARE (CLOSED)

18N18D 0.13 0.00 0.13 1 - BASIC CUSTODIAL CARE (CLOSED)

18N19 3.44 0.00 3.44 2 - HIGH-CLEARANCE VEHICLES

18N19A 0.22 0.00 0.22 1 - BASIC CUSTODIAL CARE (CLOSED)

18N19B 0.20 0.00 0.20 1 - BASIC CUSTODIAL CARE (CLOSED)

18N19C 0.17 0.00 0.17 1 - BASIC CUSTODIAL CARE (CLOSED)

18N20 1.00 0.00 1.00 2 - HIGH-CLEARANCE VEHICLES

18N20A 0.40 0.00 0.40 2 - HIGH-CLEARANCE VEHICLES

18N21 0.10 0.00 0.10 2 - HIGH-CLEARANCE VEHICLES

18N22 2.00 0.00 2.00 2 - HIGH-CLEARANCE VEHICLES

18N22D 0.62 0.00 0.62 2 - HIGH-CLEARANCE VEHICLES

18N22E 0.14 0.00 0.14 2 - HIGH-CLEARANCE VEHICLES

18N23 0.10 0.00 0.10 1 - BASIC CUSTODIAL CARE (CLOSED)

18N24 1.10 0.00 1.10 1 - BASIC CUSTODIAL CARE (CLOSED)

18N26 1.75 0.00 1.75 1 - BASIC CUSTODIAL CARE (CLOSED)

18N26A 0.15 0.00 0.15 1 - BASIC CUSTODIAL CARE (CLOSED)

18N26B 0.08 0.00 0.08 1 - BASIC CUSTODIAL CARE (CLOSED)

18N27 0.10 0.00 0.10 3 - SUITABLE FOR PASSENGER CARS

18N28 0.30 0.00 0.30 3 - SUITABLE FOR PASSENGER CARS

18N30 0.03 0.00 0.03 2 - HIGH-CLEARANCE VEHICLES

18N30 2.74 0.03 2.77 2 - HIGH-CLEARANCE VEHICLES

18N30A 0.28 0.00 0.28 1 - BASIC CUSTODIAL CARE (CLOSED)

18N30B 0.46 0.00 0.46 1 - BASIC CUSTODIAL CARE (CLOSED)

18N31 0.60 0.00 0.60 1 - BASIC CUSTODIAL CARE (CLOSED)

18N46 0.39 0.00 0.39 2 - HIGH-CLEARANCE VEHICLES

18N47 0.44 0.00 0.44 1 - BASIC CUSTODIAL CARE (CLOSED)

18N48 0.31 0.00 0.31 1 - BASIC CUSTODIAL CARE (CLOSED)

18N50 0.24 0.00 0.24 2 - HIGH-CLEARANCE VEHICLES

18N51 0.70 0.00 0.70 1 - BASIC CUSTODIAL CARE (CLOSED)

18N56 0.88 0.00 0.88 2 - HIGH-CLEARANCE VEHICLES

18N57 0.56 0.00 0.56 1 - BASIC CUSTODIAL CARE (CLOSED)

18N58 0.86 0.00 0.86 2 - HIGH-CLEARANCE VEHICLES

18N58 0.45 0.86 1.31 1 - BASIC CUSTODIAL CARE (CLOSED)

18N58B 0.25 0.00 0.25 1 - BASIC CUSTODIAL CARE (CLOSED)

19N01 1.60 0.00 1.60 2 - HIGH-CLEARANCE VEHICLES

19N01E 0.47 0.00 0.47 2 - HIGH-CLEARANCE VEHICLES
Appendix A. Alternative Tables

12 – Smith River National Recreation Area Restoration and Motorized Travel Management

Table A-2. Alternative 1 – Inventoried Unauthorized Routes (UARs).

Alternative 1 – Inventoried UARs

Route Number Miles

13N35.5 0.14

13N37.1 0.11

14N15.1 3.80

14N32.1 0.26

14N33.3 0.52

14N46.2 0.13

15N01.102 0.29

15N01.102 0.19

15N01A.1 0.10

15N01A.2 0.05

15N01A.4 3.84

15N01U.1 0.58

15N02.101 0.81

15N02.103 0.58

15N02.106 0.48

15N02.107 0.42

15N02.108 1.14

15N02.108A 0.59

15N02.2 0.24

15N02.4 0.49

15N02.5 0.90

15N02.5A 0.05

15N11.2 0.32

15N11A.1 0.25

15N13.100 0.49

15N13.100 0.48

15N36.1 0.62

15N36N.1 0.90

15N36N.1A 0.16

15N36N.1B 0.21

15N36N.1C 0.03

15N39A.1 0.18

15N45.100 0.22

15N45.101 0.12

16N02.1 0.10

16N02.2 0.87

16N02.5 0.21

16N02S.1 0.21

16N02T.1 0.12

16N03.100 0.10

16N03.2 0.87

16N10.1 0.14

16N10.2 0.21

16N18.1 1.04

16N18.3 0.49

Alternative 1 – Inventoried UARs

Route Number Miles

16N18.4 0.67

16N18B.1 0.66

16N19.1 0.05

16N19.2 0.08

16N19.3 0.30

16N19.4 0.87

16N19.5 0.19

16N19E.1 0.41

16N21.1 0.15

16N21.2 0.10

16N21F.1 0.09

16N23.100 0.64

16N23.2 0.22

16N23.4 0.69

16N23A.1 1.90

16N31A.1 0.22

16N31B.2 0.13

16N36.1 0.11

16N36.1 0.69

16N55.1 0.16

17N01.1 0.21

17N01.100 2.49

17N01.1A 0.02

17N01.1B 0.03

17N01.1C 0.09

17N01.1D 0.13

17N01.2 0.30

17N01.2B 0.03

17N01.3 0.13

17N01.3A 0.07

17N04.1 0.12

17N04.2 0.35

17N04.3 0.97

17N05.100 0.88

17N05.101 0.06

17N05.4 0.32

17N05.4A 1.36

17N05.5 0.14

17N07.1 0.25

17N07.101 0.09

17N07.102 3.07

17N07.2 0.51

17N07.4 0.21

17N07.5 0.32

17N07.5A 0.15
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 13

Alternative 1 – Inventoried UARs

Route Number Miles

17N07.6 0.75

17N07.7 0.30

17N07R.1 0.16

17N07R.1A 0.25

17N08.3 0.30

17N16.1 0.17

17N16.100 0.07

17N17.1 1.98

17N18.2 0.39

17N18.3 0.74

17N18.4 0.15

17N21.1 0.41

17N22A.1 0.21

17N22A.2 0.25

17N22W.1 0.46

17N23C.1 2.24

17N23C.2 0.59

17N27A.1 0.21

17N27D.1 0.36

17N29.100 0.04

17N31.3 0.17

17N31A.1 0.36

17N32.1 0.31

17N32.2 0.17

17N35.100 0.35

17N36B.1 0.26

17N40B.1 0.19

17N40C.1 0.20

17N41.1 0.74

17N41.2 0.02

17N41G.1 0.17

17N41H.100 0.06

17N42A.100 0.48

17N43.1 0.04

17N48.1 0.33

17N48.3 0.16

17N48.4 0.46

17N49.1 0.04

17N49.100 4.00

17N49.100A 0.21

17N49.101 1.17

17N49.102 0.87

17N49.102A 0.71

17N49.102B 0.17

17N49.102C 0.20

Alternative 1 – Inventoried UARs

Route Number Miles

17N49.103 0.26

17N49.104 4.66

17N49.104A 0.05

17N49.104B 0.08

17N49.105 1.43

17N49.105A 0.12

17N49.106 0.32

17N49.107 0.64

17N49.108 0.31

17N49.11 4.49

17N49.11M 0.17

17N49.11N 0.23

17N49.11P 0.21

17N49.12 2.10

17N49.13 0.30

17N49.14 0.54

17N49.15 0.62

17N49.15A 0.24

17N49.2 0.20

17N49.3 0.23

17N49.4 2.04

17N49.4A 1.06

17N49.7 3.35

17N49.7A 0.82

17N49.8 0.39

17N85 0.00

18N02.1 0.14

18N02.2 0.28

18N02.3 0.02

18N04.2 0.11

18N05.1 0.20

18N05.100 2.16

18N05.2 0.53

18N07.11 0.06

18N07.12 0.04

18N07.14 0.05

18N07.2 0.13

18N07.3 0.08

18N07.6 0.25

18N07.8 0.38

18N08.2 0.03

18N09.100 0.27

18N09.100A 0.16

18N09.101 0.16

18N09.102 1.84
Appendix A. Alternative Tables

14 – Smith River National Recreation Area Restoration and Motorized Travel Management

Alternative 1 – Inventoried UARs

Route Number Miles

18N09.103 0.04

18N09.104 0.05

18N09.105 0.12

18N09.106 0.02

18N09.107 0.01

18N09.108 0.03

18N10.1 0.70

18N11D.1 1.75

18N11D.2 0.25

18N11D.3 0.29

18N11D.4A 0.73

18N11D.5 2.11

18N13.100 0.21

18N13.101 0.08

18N16.100 2.60

18N16F.1 0.16

18N17.100 1.01

18N17.100A 0.08

18N17.101 0.05

18N17.102 0.06

18N17.103 0.21

18N17.104 0.20

18N17.104A 0.02

18N17C.1 0.05

18N20.100 0.28

18N20.100A 0.08

18N20.101 0.12

18N20.102 0.47

18N26A.2 0.06

18N30.100 0.04

18N31.1 0.16

18N31.2 0.23

18N31.3C 0.18

18N31.4 1.25

18N51.100 1.45

18N51.100A 0.46

18N56.100 0.04

18N58.1 0.13

199.102 0.13

199.103 0.10

199.104 0.11

199.105 0.03

199.106 0.18

199.107 0.10

199.108 0.24

Alternative 1 – Inventoried UARs

Route Number Miles

199.109 0.10

199.111 0.09

199.111A 0.07

199.112 0.29

199.113 0.07

305.100 0.57

305.101 1.08

305.101A 0.04

305.101B 0.50

305.102 0.15

305.103 0.14

305.104 0.14

305.105 0.22

305.106 0.21

305.107 1.25

305.108 0.06

305.109 2.43

305.109A 1.02

305.113 0.12

305.114 0.63

305.115 1.74

305.115A 0.18

305.118 0.80

305.119 0.22

305.120 0.04

305.121 0.63

305.121A 0.28

305.121B 1.03

305.123 0.63

305.124 1.20

305.125 1.44

305.125A 0.21

305.126 1.56

305.128 0.70

305.129 0.40

305.130 1.72

305.131 0.09

305.132 0.04

305.133 0.01

305.134 0.14

314.1 1.21

314.102 0.80

314.107 0.26

314.108 0.06

315.100 1.68
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 15

Alternative 1 – Inventoried UARs

Route Number Miles

315.102 0.48

315.103 0.26

315.104 0.82

315.106 0.25

315.107 0.30

315.108 0.46

315.109 0.50

315.110 0.07

315.111 0.03

315.2 0.51

315.3 0.98

315.3A 0.24

315.9A 1.22

316.1 0.26

316.10 0.03

316.11 0.04

316.12 0.03

316.2 0.20

316.3 0.08

316.4 0.07

316.5 0.03

316.6 0.03

Alternative 1 – Inventoried UARs

Route Number Miles

316.7 0.02

316.7A 0.02

316.8 0.05

316.9 0.06

316.9A 0.05

324.100 0.13

405.10 0.74

405.100 0.11

405.101 0.17

405.103 3.47

405.9 0.05

411.101 0.30

411.102 0.17

427.101 0.15

427.103 0.32

427.104 0.30

427.105 0.29

427.106 0.13

427.107 0.05

427.108 0.09

427.108A 0.04

Total 154.82
16 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 4

Table A-3. Alternative 4.

Alternative 4

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 4: Proposed Actions

13N35.5 0.14 0.00 0.14 UAR Restore Barricade.

13N35K 0.10 0.18 0.282 Decommission Remove from system.

13N37 2.00 0.00 2.0021

Remove or repair road drainage features as needed to improve resource 

protection. Waterbars/rolling dips as needed and barricade. Downgrade 

to OML 1.

13N37.1 0.11 0.00 0.11 UAR Restore Barricade.

13N37A 0.77 0.00 0.772 Decommission Remove from system. Remove culverts and associated fill as needed.

Waterbars as needed and barricade.

13N37B 0.27 0.00 0.272 Decommission Remove from system. Remove culverts and associated fill as needed.

Waterbars as needed and barricade.

14N01 4.61 9.60 14.2133 POC Mitigation: seasonal gate closure.

14N01D 1.80 0.00 1.8022 Maintain, repair, or replace each culvert; improve surface drainage. POC 

Mitigation: seasonal gate closure.

14N08 0.50 0.00 0.5022 POC Mitigation: year-round gate closure.

14N08T 0.11 0.00 0.111 Decommission Remove from system. Remove all culverts and associated fill. Waterbars 

as needed and barricade.

14N15 0.50 0.00 0.5022 Maintain, repair, or replace each culvert; improve surface drainage. POC 

Mitigation: proposed seasonal gate on 14N01 restricts access.

14N15.1 3.80 0.00 3.80 UAR2 Add to road system. OML 2. Replace culverts and repair road surface.

14N32.1 0.26 0.00 0.26 UAR Restore Barricade.

14N33 1.60 0.18 1.782 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars and barricade.

14N33.3 0.52 0.00 0.52 UAR Restore Remove culverts and associated fill from stream channels as on 14N33.

Waterbars as needed.

14N33A 0.22 0.00 0.221 Decommission Remove from system. Remove all culverts and associated fill. Waterbars 

as needed and barricade.

14N38 0.41 0.00 0.4122 Improve surface drainage and maintain as OML 2. POC Mitigation

:

seasonal gate closure at beginning of road.

14N38 0.19 0.41 0.602 Decommission Decommission past water source. Remove culverts. Waterbar as needed 

and barricade.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 17

Alternative 4

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 4: Proposed Actions

14N46 2.70 0.00 2.7021 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars as needed and barricade. Downgrade to OML 1.

14N46.2 0.13 0.00 0.13 UAR Restore Waterbar and barricade.

14N46B 0.37 0.00 0.371 Decommission Remove from system. Waterbars as needed and barricade.

15N01.102 0.29 0.00 0.29 UAR2 Add to road system.

15N01.102 0.19 0.29 0.48 UAR2

Add to road system. OML 2. POC Mitigation: seasonal closure– gate at 

right spur (milepost 0.09). Barricade last 50' of southern fork, located 

about 500' from 15N01.

15N01A.1 0.10 0.00 0.10 UAR Restore Barricade.

15N01A.2 0.05 0.00 0.05 UAR Restore Barricade.

15N01A.4 3.84 0.00 3.84 UAR2 Add as OML 2. POC Mitigation

: seasonal gate before approach to first 

POC stand about 2.2 miles from start.

15N01P 0.09 0.79 0.881 Decommission Remove from system. Remove all culverts and associated fill. Waterbars 

as needed and barricade.

15N01Q 0.50 0.00 0.501 Motorized Trail Convert to motorized trail to Marlow Campsite.

15N01R 0.10 0.00 0.1011 Waterbar as needed and barricade.

15N01S 0.10 0.00 0.1011 Waterbar as needed and barricade.

15N01U 0.70 0.00 0.701 Decommission Remove from system. Remove all culverts and associated fill. Waterbars 

as needed and barricade.

15N01U.1 0.58 0.00 0.58 UAR Restore Barricade.

15N02 11.10 0.00 11.1022 Replace 3 priority culverts. POC Mitigation:gravel at culverts and wet areas.

15N02.101 0.51 0.00 0.51 UAR Motorized Trail Add to trail system. Motorized trail.

15N02.101 0.30 0.51 0.81 UAR Restore Barricade.

15N02.103 0.58 0.00 0.58 UAR Motorized Trail Add to trail system. Motorized trail.

15N02.106 0.48 0.00 0.48 UAR Motorized Trail Add to trail system. Motorized trail.

15N02.107 0.42 0.00 0.42 UAR Motorized Trail Add to trail system. Motorized trail. Barricade at milepost 0.37, about 

0.05 mile before end of road.

15N02.108 1.14 0.00 1.14 UAR Restore Barricade.

15N02.108A 0.59 0.39 0.98 UAR Restore Barricade.

15N02.2 0.24 0.00 0.24 UAR Restore Barricade.

15N02.4 0.49 0.00 0.49 UAR Motorized Trail Add to trail system. Motorized trail.

15N02.5 0.71 0.19 0.90 UAR Restore Waterbar or rolling dips as needed and barricade.

15N02.5 0.19 0.00 0.19 UAR Motorized Trail Add as motorized trail.
18 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 4

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 4: Proposed Actions

15N02.5A 0.05 0.00 0.05 UAR Motorized Trail Add as motorized trail.

15N11.2 0.32 0.00 0.32 UAR Restore Barricade.

15N11A 1.70 0.00 1.701 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

15N11A.1 0.25 0.00 0.25 UAR Restore Remove all culverts and associated fill from stream channels. Waterbars 

as needed.

15N11B 1.39 0.00 1.391 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars and barricade.

15N13 3.80 0.00 3.8022 Improve maintenance or repair/replace all culverts and drainage structures 

as needed. Manage as OML 2. POC Mitigation: seasonal gate closure.

15N13.100 0.49 0.62 1.11 UAR Restore Year round gate closure southern terminus adjacent to private landholding.

15N13.100 0.48 1.74 2.22 UAR Restore Year round gate closure northern terminus adjacent to private landholding.

15N33 0.90 0.00 0.901 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

15N35A 0.24 0.00 0.242 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

15N35B 0.57 0.00 0.571 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

15N35C 0.57 0.00 0.571 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

15N36.1 0.62 0.00 0.62 UAR Restore Remove 3 culverts and associated fill from stream channels. Waterbars 

as needed and barricade.

15N36C 0.55 0.00 0.551 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

15N36N 1.30 0.00 1.3012 Upgrade first 1.3 miles. Maintain, repair, or replace each culvert. Improve 

surface drainage with waterbars and rolling dips as needed.

15N36N 1.30 1.30 2.601 Decommission Decommission from 1.3 to 2.6

15N36N.1 0.90 0.00 0.90 UAR2

Add to road system. OML 2. Access to Blackhawk Bar. Keep, maintain, 

repair, or replace each culvert. Improve surface draining with water bars 

and rolling dips as needed. POC Mitigation: add gravel at drainage 

crossings and along area with POC.

15N36N.1A 0.16 0.00 0.16 UAR Motorized Trail Add as motorized trail.

15N36N.1B 0.21 0.00 0.21 UAR2 Add as OML 2. POC Mitigation: rock/gravel as needed.

15N36N.1C 0.03 0.00 0.03 UAR Motorized Trail Add as motorized trail.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 19

Alternative 4

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 4: Proposed Actions

15N38 2.90 0.00 2.9022

Improve surface drainage and install culvert at stream ford on road near 

private land. POC Mitigation:barricade last 300' of road, before bottom of 

POC stand.

15N39A 1.20 0.00 1.201 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Barricade.

15N39A.1 0.18 0.00 0.18 UAR Restore Barricade.

15N39B 0.50 0.00 0.501 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Barricade.

15N42 1.06 0.00 1.0622 Manage as OML 2. POC Mitigation: seasonal gate on 16N18.

15N42A 0.44 0.00 0.441 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

15N45 1.13 0.00 1.1311 Remove or repair road drainage features as needed to improve resource 

protection. Barricade.

15N45.100 0.22 0.00 0.22 UAR Restore Barricade.

15N45.101 0.12 0.00 0.12 UAR Restore Barricade.

15N63 0.30 0.00 0.3022 Manage as OML 2.

16N02.1 0.10 0.00 0.10 UAR2 Add to road system. OML 2. Bear Basin water source

16N02.2 0.87 0.00 0.87 UAR Restore Barricade.

16N02.5 0.21 0.00 0.21 UAR Restore Waterbar or rolling dips as needed and barricade.

16N02D 0.61 0.00 0.612 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

16N02H 0.40 0.00 0.4011 Waterbar or rolling dips as needed.

16N02L 1.70 0.00 1.7022 Upsize culverts, install waterbars or rolling dips. POC Mitigation

: current 

seasonal gate restricts access.

16N02S 1.20 0.00 1.201 Decommission Remove from system. Remove culverts and associated fill as needed.

Waterbars and barricade.

16N02S.1 0.21 0.00 0.21 UAR Restore Barricade.

16N02T 0.50 0.00 0.501 Decommission Remove from system. Remove culverts and associated fill as needed.

Waterbars as needed and barricade.

16N02T.1 0.12 0.00 0.12 UAR Restore Barricade.

16N03.100 0.10 0.00 0.10 UAR Restore Barricade.

16N03.2 0.87 0.00 0.87 UAR Restore Remove 3 culverts and associated fill from stream channels. Waterbar as 

needed and barricade.

16N03A 0.06 0.00 0.061 Motorized Trail Convert to motorized trail for access to a small peak on Hurdygurdy Butte.
20 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 4

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 4: Proposed Actions

16N03D 1.40 0.00 1.4012 Upgrade to OML 2.

16N03F 0.70 0.00 0.7021 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars as needed and barricade. Downgrade to OML 1.

16N03G 0.08 0.00 0.081 Decommission Remove from system. Waterbar landing as needed and barricade.

16N03H 0.30 0.00 0.302 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

16N03K 1.50 0.00 1.5022 Repair culverts at milepost 1.08 and 1.14. POC Mitigation

: current 

seasonal gate restricts access.

16N03L 0.20 0.00 0.201 Decommission Remove from system. Remove culverts and associated fill as needed.

Waterbars as needed and barricade.

16N10.1 0.14 0.00 0.14 UAR Restore Barricade.

16N10.2 0.21 0.00 0.21 UAR Restore POC Mitigation

: route extends from non-motorized trail. No motorized 

access. Barricade as needed.

16N15A 0.17 0.00 0.172 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

16N16 1.50 0.00 1.5022 Repair or replace plugged culverts.

16N16 0.60 1.50 2.1021 Remove all 4 culverts and associated fill. Waterbars and barricade.

16N18.1 1.04 0.00 1.04 UAR Restore Barricade.

16N18.3 0.49 0.00 0.49 UAR Restore Barricade.

16N18.4 0.67 0.00 0.67 UAR Restore Barricade.

16N18A 1.35 0.00 1.3522 Repair or replace 8 culverts on section up to milepost 1.35 at bridge. 

POC Mitigation:gravel and install culverts creek crossings.

16N18A 0.95 1.35 2.302 Decommission Remove 5 culverts, and decommission and barricade.

16N18B.1 0.66 0.00 0.66 UAR Restore Barricade.

16N18C 0.39 0.00 0.391 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

16N18E 0.96 0.00 0.962 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

16N18K 1.10 0.00 1.1011 Waterbar or rolling dips as needed.

16N19 8.28 0.00 8.2822

Improve maintenance on, repair, or replace each of the 17 culverts. POC Mitigation: reinforce creek crossings with gravel and sections of road with 

POC 0.29-0.46 miles west of 16N19E intersection as needed.

16N19.1 0.05 0.00 0.05 UAR2 Add to road system. OML 2. Water source. POC Mitigation: rock/gravel 

length of road as needed.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 21

Alternative 4

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 4: Proposed Actions

16N19.2 0.08 0.00 0.08 UAR2 Add as OML 2 for access to Coon Creek. POC Mitigation: rock/gravel 

length of road as needed.

16N19.3 0.30 0.00 0.30 UAR Restore Barricade.

16N19.4 0.87 0.00 0.87 UAR Restore Barricade.

16N19.5 0.19 0.00 0.19 UAR Restore Remove fill from culvert. Barricade.

16N19A 0.23 0.00 0.232 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

16N19B 1.40 0.00 1.4021 Waterbar as needed and barricade. Downgrade to OML 1.

16N19E 0.95 0.00 0.9521 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars as needed and barricade. Downgrade to OML 1.

16N19E.1 0.41 0.00 0.41 UAR Restore Barricade.

16N19F 0.76 0.00 0.762 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

16N19G 0.23 0.00 0.232 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

16N21.1 0.15 0.00 0.15 UAR Restore Waterbar or rolling dips as needed and barricade.

16N21.2 0.10 0.00 0.10 UAR Restore Barricade.

16N21F.1 0.09 0.00 0.09 UAR Restore Barricade.

16N23 7.40 0.00 7.4022 Improve road drainage at all culverts. POC Mitigation

: seasonal gate 

closure and add gravel in areas with POC within 50' of road.

16N23.100 0.64 0.00 0.64 UAR Motorized Trail Add to trail system. Motorized trail.

16N23.2 0.22 0.00 0.22 UAR Motorized Trail Add to trail system. Motorized trail. POC Mitigation: Gravel and rock 

route as needed.

16N23.4 0.69 0.00 0.69 UAR Motorized Trail Add to trail system. Motorized trail.

16N23A.1 1.90 0.00 1.90 UAR Motorized Trail Add to trail system. Motorized trail.

16N24A 0.65 0.00 0.651 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

16N27 0.50 0.00 0.501 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

16N30 0.24 0.00 0.241 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and Barricade.

16N31 0.35 0.00 0.3512 Upgrade to OML 2.

16N31A.1 0.22 0.00 0.22 UAR Restore Barricade.

16N31B 1.00 0.00 1.001 Motorized Trail Convert to motorized trail.
22 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 4

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 4: Proposed Actions

16N31B.2 0.13 0.00 0.13 UAR Restore Barricade.

16N32 3.12 0.82 3.9422 Improve maintenance, repair, or replace each of the 16 culverts. POC 

Mitigation: current seasonal gate restricts access.

16N32A 0.08 0.00 0.081 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

16N32C 0.47 0.00 0.471 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed. POC Mitigation:barricade.

16N33 0.70 0.00 0.7022 POC Mitigation

: seasonal gate closure. Rock/gravel POC crossing as 

needed.

16N33 3.70 0.70 4.4011 POC Mitigation:barricade.

16N34 0.60 0.00 0.6022 Add culvert at milepost0.34.

16N34 0.30 0.60 0.9021 Downgrade to OML 1. Remove last culvert at milepost

0.9 switchback. 

POC Mitigation:barricade.

16N34A 0.50 0.00 0.5021 Waterbar as needed and barricade. Downgrade to OML 1.

16N35A 0.14 0.00 0.141 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

16N35C 0.12 0.00 0.122 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Barricade.

16N36 1.20 0.00 1.2022 Improve maintenance, repair, or replace each of the culverts.

16N36.1 0.11 0.69 0.80 UAR Restore Barricade.

16N36.1 0.69 0.00 0.69 UAR2 Add to NFTS as OML 2, repair or replace each of the culverts.

16N36B 0.82 0.00 0.8222 Clean blocked culverts and install 2 additional culverts.

16N37 1.20 0.00 1.2022 Improve maintenance, repair, or replace each of the 6 culverts. POC 

Mitigation:Ggravel culverted creek crossings.

16N37B 0.17 0.00 0.172 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

16N38 1.32 0.28 1.6022 POC Mitigation

:reinforce POC crossing with gravel, about 170' west of 

16N21 junction.

16N39A 0.22 0.00 0.221 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

16N41 1.43 0.00 1.4322 Replace culvert at milepost

0.56. POC Mitigation:reinforce POC crossing 

with gravel and install culvert, about 200' east of 16N37 junction.

16N41A 0.17 0.00 0.172 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 23

Alternative 4

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 4: Proposed Actions

16N41B 0.09 0.00 0.092 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

16N55 0.50 0.00 0.5012 Upgrade to OML 2. Existing gate on 16N33.

16N55.1 0.16 0.00 0.16 UAR Restore Barricade.

17N01 0.70 0.00 0.7022 POC Mitigation:rock/gravel road as needed.

17N01.1 0.21 0.00 0.21 UAR2 Add to road system. OML 2. POC Mitigation: rock/gravel length of road 

as needed.

17N01.100 2.49 0.00 2.49 UAR Restore Remove all culverts and associated fill from stream channels. Barricade.

17N01.1A 0.02 0.00 0.02 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel as needed.

17N01.1B 0.03 0.00 0.03 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel as needed.

17N01.1C 0.09 0.00 0.09 UAR Restore Waterbars as needed. Barricade.

17N01.2 0.30 0.00 0.30 UAR2 Add as OML 2. POC Mitigation: rock/gravel entire length as needed.

17N01.2B 0.03 0.00 0.03 UAR Motorized Trail Add as motorized trail.

17N01.3 0.13 0.00 0.13 UAR Motorized Trail Add as motorized trail. Rolling dips as needed. POC Mitigation

:

rock/gravel as needed.

17N01.3A 0.07 0.00 0.07 UAR Restore Barricade.

17N03 1.20 0.00 1.201 Motorized Trail Convert to motorized trail.

17N04.1 0.12 0.00 0.12 UAR Restore Barricade.

17N04.3 0.97 0.00 0.97 UAR Restore Remove culvert and associated fill. Rolling dips as needed and barricade.

17N04L 3.10 0.00 3.1012 Upgrade to OML 2.

17N04S 1.80 0.00 1.801 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

17N05.100 0.88 0.00 0.88 UAR Restore Barricade.

17N05.101 0.06 0.00 0.06 UAR Restore Barricade.

17N05.4 0.32 0.00 0.32 UAR Restore Barricade.

17N05.4A 1.36 0.00 1.36 UAR Restore Waterbar or rolling dips as needed and barricade.

17N05.5 0.14 0.00 0.14 UAR Restore Waterbar or rolling dips as needed and barricade.

17N05C 0.97 0.00 0.971 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

17N05F 1.56 0.00 1.5612 Upgrade to OML 2.

17N05G 0.67 0.00 0.671 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.
24 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 4

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 4: Proposed Actions

17N05U 0.28 0.00 0.281 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

17N07 10.39 0.00 10.3932 Downgrade to OML 2. POC Mitigation

: rock/gravel as needed at wet 

areas, draws and areas with POC.

17N07.1 0.25 0.00 0.25 UAR Restore Waterbar or rolling dips as needed and barricade.

17N07.102 3.07 0.00 3.07 UAR Restore Road not stable; failing. Remove all culverts and associated fill from 

stream channels. Barricade.

17N07.2 0.51 0.00 0.51 UAR Restore Waterbar or rolling dips as needed and barricade.

17N07.4 0.21 0.00 0.21 UAR Restore Waterbar as needed. Barricade.

17N07.5 0.32 0.00 0.32 UAR Restore Barricade.

17N07.5A 0.15 0.00 0.15 UAR Restore Barricade.

17N07.6 0.75 0.00 0.75 UAR Restore Barricade.

17N07.7 0.30 0.00 0.30 UAR Restore Barricade.

17N07G 1.67 0.00 1.6722 POC Mitigation

:rock/gravel stretch with infected POC as needed, 

approx. milepost 0.2 to 0.22.

17N07J 1.64 0.00 1.6422 Repair culvert at milepost 1.25. POC Mitigation

: rock/gravel as needed at 

wet areas, draws and areas with POC.

17N07K 0.80 0.00 0.8021 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars as needed and barricade. Downgrade to OML 1.

17N07Q 0.22 0.00 0.222 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

17N07R 0.44 0.00 0.442 Decommission Remove from system. Remove culvert and associated fill. Barricade.

17N07R.1 0.16 0.00 0.16 UAR Restore Barricade.

17N07R.1A 0.25 0.00 0.25 UAR Restore Barricade.

17N08.3 0.30 0.00 0.30 UAR Restore Barricade.

17N08A 0.50 0.00 0.501 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

17N13 0.70 0.00 0.7022 POC Mitigation

:rock/gravel POC crossing as needed, approx. milepost

0.30 to 0.43.

17N13A 0.38 0.00 0.3821 Waterbar as needed and barricade. Downgrade to OML 1.

17N14 0.39 0.00 0.3922 POC Mitigation: rock/gravel infested POC site, as needed, approx.

milepost 0.14 to 0.16.

17N15 0.90 0.00 0.9021 Waterbar as needed and barricade. Downgrade to OML 1.

17N15A 0.13 0.00 0.131 Decommission Remove from system. Waterbars as needed and barricade.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 25

Alternative 4

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 4: Proposed Actions

17N16 0.65 0.00 0.6522 Manage as OML 2. Rolling dips as needed.

17N16.1 0.17 0.00 0.17 UAR Restore Barricade.

17N16.100 0.07 0.00 0.07 UAR Restore Waterbars or rolling dips as needed and barricade.

17N17 0.60 0.00 0.601 Decommission Remove from system. Remove culvert and associated fill from stream 

channel. Waterbars as needed and barricade.

17N17.1 1.98 0.00 1.98 UAR Restore Closed by barricade on 17N17.

17N18.2 0.39 0.00 0.39 UAR Restore Remove 2 culverts and associated fill from stream channels. Waterbars 

as needed and barricade.

17N18.3 0.74 0.00 0.74 UAR Restore Barricade.

17N18.4 0.15 0.00 0.15 UAR Restore Barricade.

17N18A 0.94 0.00 0.9412 Upgrade to OML 2.

17N18C 0.67 0.00 0.6722 Improve maintenance, repair, or replace each of the 3 culverts. POC 

Mitigation: rock/gravel length of road as needed.

17N18E 0.42 0.00 0.421 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

17N18F 0.07 0.00 0.071 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

17N20 0.19 0.00 0.1922 Improve maintenance, repair, or replace each of the 3 culverts.

17N21.1 0.41 0.00 0.41 UAR Restore Waterbars or rolling dips as needed and barricade.

17N22A 0.79 0.00 0.7922 Improve maintenance on, repair, or replace culvert at milepost 0.7.

17N22A.1 0.21 0.00 0.21 UAR Restore Waterbars or rolling dips as needed and barricade.

17N22A.2 0.25 0.00 0.25 UAR Restore Barricade.

17N22D 0.08 0.00 0.082 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

17N22J 0.12 0.00 0.1222 Waterbar or rolling dips as needed.

17N22W.1 0.46 0.00 0.46 UAR Restore Waterbar as needed. Barricade.

17N23 1.30 1.50 2.801 Decommission Remove from system. Waterbars as needed, remove culverts, barricade.

17N23 1.15 0.35 1.501 Decommission Remove from system.

17N23C.1 1.04 0.05 1.09 UAR1 Add to road system. OML 1.

17N23C.1 0.05 0.00 0.05 UAR1 Add to road system. OML 1.

17N23C.1 1.15 1.09 2.24 UAR1 Add to road system. OML 1.

17N23C.2 0.59 0.00 0.59 UAR1 Add to road system. OML 1.
26 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 4

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 4: Proposed Actions

17N26 0.25 0.00 0.2522 POC Mitigation: rock/gravel entire length of road as needed.

17N26A 0.37 0.00 0.3722 POC Mitigation: rock/gravel entire length of road as needed, infested POC.

17N27B 0.40 0.00 0.401 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

17N27C 0.40 0.00 0.401 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

17N27D.1 0.36 0.00 0.36 UAR Restore Waterbar or rolling dips as needed and barricade.

17N28 0.20 0.00 0.201 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

17N29 1.00 0.00 1.0022 Pull fill back from landing. Proposed seasonal gate on network

17N29B 0.20 0.00 0.202 Decommission

Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade. Proposed seasonal gate 

on network.

17N30 0.89 0.00 0.8921 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars as needed. Downgrade to OML 1.

17N30 0.55 0.89 1.442 Decommission Remove from system. Waterbars as needed.

17N30A 0.40 0.00 0.4021 Downgrade to OML 1.

17N31 1.60 0.00 1.6022 Manage as OML 2. Rolling dips as needed.

17N31.3 0.17 0.00 0.17 UAR Restore Barricade.

17N31A.1 0.36 0.00 0.36 UAR Restore Barricade.

17N32 2.22 0.00 2.2222 POC Mitigation: seasonal gate closure. Rock/gravel POC crossing as 

needed.

17N32.1 0.31 0.00 0.31 UAR Restore Barricade.

17N32B 0.80 0.00 0.802 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

17N32F 1.00 0.00 1.002 Decommission

Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade. Proposed seasonal gate 

on network 17N32.

17N32G 1.20 0.00 1.2022 Improve maintenance, repair, or replace culverts. Proposed seasonal 

gate on network.

17N35 0.50 0.00 0.502 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

17N35.100 0.35 0.00 0.35 UAR Restore Barricade.

17N36 2.50 0.00 2.5022 Improve maintenance, repair, or replace each of the 14 culverts. POC 

Mitigation: seasonal gate near 17N04.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 27

Alternative 4

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 4: Proposed Actions

17N36B.1 0.26 0.00 0.26 UAR Restore Barricade.

17N36C 0.43 0.00 0.431 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

17N36F 1.20 0.00 1.2012 Upgrade to OML 2.

17N39 2.19 0.00 2.1922

Improve maintenance, repair, or replace each of the 25 culverts. POC 

Mitigation: rock/gravel stretch with infected POC as needed, from 

junction with 411 to approx. milepost 0.65

17N39A 0.95 0.00 0.951 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

17N39B 0.51 0.00 0.511 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Barricade.

17N39C 0.12 0.00 0.121 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

17N40 0.35 0.65 1.0021 Waterbars as needed, barricade, and downgrade to OML 1.

17N40 0.65 0.00 0.6522 POC Mitigation: seasonal gate closure.

17N40B 0.53 0.00 0.532 Motorized Trail Convert to motorized trail.

17N40B.1 0.19 0.00 0.19 UAR Restore Barricade.

17N40C.1 0.20 0.00 0.20 UAR Restore Barricade.

17N40D 0.18 0.00 0.181 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

17N41 4.25 0.00 4.2522

Improve maintenance on, repair, or replace/upgrade each of the 13 

culverts and waterbar as needed. POC Mitigation: rock/gravel with 

infected POC, from junction with 411 to approx. milepost 1.05.

17N41A 0.30 0.00 0.3011 POC Mitigation: barricade.

17N41G.1 0.17 0.00 0.17 UAR Restore Waterbar or rolling dips as needed and barricade.

17N41H 0.90 0.00 0.9022 POC Mitigation: rock/gravel stretch with infected POC as needed, first 

0.23 mile.

17N42A.100 0.48 0.00 0.48 UAR Motorized Trail Add as motorized trail.

17N43 1.00 0.00 1.0022 POC Mitigation: 

rock/gravel stretch with infected POC as needed, 

approx. milepost 0.47 to 0.68.

17N46 1.20 0.00 1.2022 POC Mitigation: seasonal gate on 17N40 closes access to this route.

17N46A 0.16 0.00 0.161 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

17N48 1.66 0.00 1.6622 POC Mitigation: rock/gravel entire length of road as needed, infested 

POC throughout.
28 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 4

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 4: Proposed Actions

17N48.1 0.33 0.00 0.33 UAR Restore Barricade.

17N48.3 0.16 0.00 0.16 UAR Restore POC Mitigation: barricade.

17N48.4 0.46 0.00 0.46 UAR Restore Rolling dips as needed and barricade.

17N48C 0.47 0.00 0.471 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Barricade.

17N49 1.75 2.96 4.7132

Downgrade to OML 2. POC Mitigation: rock/gravel stretch with infected 

POC, as needed, approx. milepost 3.8, just north of 17N49.101 junction, 

for 100'.

17N49 0.90 5.15 6.0532 Downgrade to OML 2.

17N49 0.44 4.71 5.1532 Downgrade to OML 2.

17N49 1.80 6.05 7.8532 Downgrade to OML 2.

17N49.100 0.12 0.00 0.12 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.100 3.66 0.12 3.78 UAR Motorized Trail Add as motorized trail.

17N49.100 0.22 3.78 4.00 UAR Restore Barricade.

17N49.100A 0.21 0.00 0.21 UAR Restore Barricade.

17N49.101 1.17 0.00 1.17 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.102 0.87 0.00 0.87 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.102A 0.71 0.00 0.71 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.102B 0.17 0.00 0.17 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.102C 0.20 0.00 0.20 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.103 0.26 0.00 0.26 UAR Restore Waterbar or rolling dips as needed and barricade.

17N49.104 3.82 0.00 3.82 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.104 0.86 3.82 4.68 UAR Motorized Trail Add as motorized trail.

17N49.104A 0.05 0.00 0.05 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.104B 0.08 0.00 0.08 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.105 1.43 0.00 1.43 UAR Restore Barricade.

17N49.105A 0.12 0.00 0.12 UAR Restore Barricade.

17N49.106 0.32 0.00 0.32 UAR Restore Barricade.

17N49.107 0.64 0.00 0.64 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.108 0.31 0.00 0.31 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.11 1.94 0.00 1.94 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 29

Alternative 4

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 4: Proposed Actions

17N49.11 2.55 1.94 4.49 UAR Motorized Trail

Add to trail system. Motorized trail. Delineate route. POC Mitigation: 

seasonal gate closure, gate mid-slope near longitude 124.0119W and 

latitude 41.88593. Seasonal POC gate (approx. 124.00726W 41.88399N 

(NAD83)).

17N49.11M 0.17 0.00 0.17 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.11N 0.23 0.00 0.23 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.11P 0.18 0.00 0.18 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route. POC Mitigation: 

proposed seasonal gates on 17N49.11 and 17N49.7 restrict access.

17N49.11P 0.03 0.18 0.21 UAR Restore POC Mitigation: barricade.

17N49.12 2.10 0.00 2.10 UAR Motorized Trail Add as motorized trail. POC Mitigation: seasonal gate closure at beginning.

17N49.13 0.30 0.00 0.30 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.14 0.54 0.00 0.54 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.15 0.62 0.00 0.62 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.15A 0.24 0.00 0.24 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.4 1.29 0.00 1.29 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.4 0.75 1.29 2.04 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route. POC Mitigation: 

seasonal closure, just to east of 17N49.102.

17N49.4A 1.06 0.00 1.06 UAR Restore Gate. Permanent closure.

17N49.7 2.15 0.91 3.06 UAR Motorized Trail

Add to trail system. Motorized trail. Repair road drainage at spring area 

and 2 culverts. Delineate route. POC Mitigation: seasonal closure, gate 

north of 17N49.15.

17N49.7 0.29 3.06 3.35 UAR Restore Barricade.

17N49.7 0.91 0.00 0.91 UAR Motorized Trail Add to trail system. Motorized trail. Repair road drainage at spring area 

and 2 culverts. Delineate route and gravel areas with POC.

17N49.7A 0.82 0.00 0.82 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.8 0.39 0.00 0.39 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N63 0.30 0.00 0.3022 POC Mitigation: rock/gravel entire length of road as needed.

17N85 1.20 0.00 1.20 UAR1 Add to NFTS as OML 1. Remove or repair road drainage features as 

needed to improve resource protection. POC Mitigation: barricade.

18N01 0.10 0.00 0.1022 Maintain as OML 2.

18N01 0.06 0.10 0.162 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.
30 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 4

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 4: Proposed Actions

18N02 2.60 0.00 2.6033

POC Mitigation: rock/gravel as needed the road segment 100' either side 

of Sanger Lake outlet, and the road segment through the POC stand 

south of the 18N07 intersection.

18N02.1 0.14 0.00 0.14 UAR Restore Barricade.

18N02.2 0.08 0.00 0.08 UAR Motorized Trail Add as motorized trail.

18N02.3 0.02 0.00 0.02 UAR Motorized Trail Add as motorized trail. POC Mitigation: 

rock/gravel length of route as 

needed.

18N03 1.91 0.00 1.911 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N04E 0.21 0.65 0.862 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars or rolling dips as needed and barricade.

18N05 2.00 0.00 2.001 Motorized Trail Convert to motorized trail.

18N05.1 0.20 0.00 0.20 UAR Restore Remove culverts and associated fill from stream channels. Waterbars as 

needed. Barricade.

18N05.100 2.16 0.00 2.16 UAR Restore Remove culverts and associated fill from stream channels. Waterbars as 

needed. POC Mitigation: barricade.

18N05.2 0.53 0.00 0.53 UAR Restore Remove culverts and associated fill from stream channels. Waterbars as 

needed. Barricade.

18N06A 0.18 0.00 0.181 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N07 0.05 0.00 0.0533Bridge repair/replacement

18N07.12 0.04 0.00 0.04 UAR Motorized Trail Add as motorized trail.

18N07.14 0.05 0.00 0.05 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel as needed.

18N07.2 0.13 0.00 0.13 UAR2 Add as OML 2.

18N07.3 0.08 0.00 0.08 UAR2 Add to road system. Manage as OML 2. POC Mitigation: 

rock/gravel 

entire route as needed.

18N07.6 0.25 0.00 0.25 UAR Restore Remove culverts and associated fill from stream channels. Waterbars as 

needed. Barricade.

18N07.8 0.38 0.00 0.38 UAR Restore Remove culverts and associated fill from stream channels. Waterbars as 

needed. POC Mitigation: barricade.

18N08.2 0.03 0.00 0.03 UAR2 Add to road system. OML 2

18N08F 1.10 0.70 1.8021

Downgrade to OML 1. Remove or repair road drainage features as 

needed to improve resource protection. Waterbars as needed. POC 

Mitigation: barricade.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 31

Alternative 4

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 4: Proposed Actions

18N08G 1.12 0.00 1.121 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N09 5.10 0.00 5.1022 POC Mitigation: seasonal gate closure.

18N09.100 0.21 0.00 0.21 UAR Motorized Trail Add as motorized trail.

18N09.100 0.06 0.21 0.27 UAR Restore Waterbars/rolling dips as needed and barricade at 18N09.

18N09.100A 0.16 0.21 0.37 UAR Restore Waterbar as needed and barricade.

18N09.101 0.16 0.00 0.16 UAR Motorized Trail Add as motorized trail. POC Mitigation: gravel last 100' of route.

18N09.102 1.84 0.00 1.84 UAR Restore Barricade.

18N09.103 0.04 0.00 0.04 UAR Restore Waterbar or rolling dips as needed and barricade.

18N09.104 0.05 0.00 0.05 UAR Restore Barricade.

18N09.105 0.12 0.00 0.12 UAR Restore Barricade.

18N09.106 0.02 0.00 0.02 UAR Motorized Trail Add as motorized trail.

18N09.107 0.01 0.00 0.01 UAR Motorized Trail Add as motorized trail.

18N09.108 0.03 0.00 0.03 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel as needed.

18N11 1.92 4.15 6.0722 Replace culvert at milepost 5.78.

18N11A 0.80 0.00 0.801 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N11B 0.19 0.00 0.191 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N11C 0.20 0.00 0.201 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N11D 0.46 0.00 0.461 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N11D.2 0.25 0.00 0.25 UAR Restore Remove culverts and associated fill from stream channels. Waterbars as 

needed. Barricade.

18N11D.3 0.29 0.00 0.29 UAR Restore Remove culverts and associated fill from stream channels. Waterbars as 

needed. Barricade.

18N11D.4A 0.73 0.00 0.73 UAR Restore Barricade.

18N11D.5 2.11 0.00 2.11 UAR Restore Remove culverts and fill from stream channels. Waterbars as needed. 

POC Mitigation: barricade.

18N12A 0.43 0.00 0.431 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N15 1.20 0.00 1.2022 Resource 

risk mitigation:delineate route near milepost0.01. Upsize 

culverts, install waterbars or rolling dips.
32 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 4

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 4: Proposed Actions

18N15D 0.23 0.00 0.232 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N16 5.33 0.00 5.3322 POC Mitigation: rock/gravel first 0.28 miles within infected POC as needed.

18N16.100 2.60 0.00 2.60 UAR Restore Barricade.

18N16E 0.38 0.00 0.381 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N16F.1 0.16 0.00 0.16 UAR Restore Barricade.

18N16W 0.17 0.00 0.172 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N17 8.10 0.00 8.1022

Improve maintenance on, repair, or replace/upgrade each of the 19 

culverts and outslope or waterbars as needed. POC Mitigation: current 

seasonal gate.

18N17.100 1.01 0.00 1.01 UAR Restore Barricade.

18N17.100A 0.08 0.00 0.08 UAR Restore Barricade.

18N17.103 0.21 0.00 0.21 UAR Restore Barricade.

18N17.104 0.20 0.00 0.20 UAR Restore Barricade.

18N17B 0.87 0.00 0.8722 Install culvert at milepost 0.5. POC Mitigation: seasonal gate on 18N17.

18N17C 1.18 0.00 1.1822

Replace culverts at milepost 0.35 and 0.77; and maintain, repair or 

upgrade remaining 4 culverts and improve surface drainage. POC 

Mitigation: existing seasonal gate on 18N17 restricts access.

18N17G 0.12 0.00 0.122 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N17H 0.15 0.00 0.152 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N18A 0.20 0.00 0.201 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N18B 0.15 0.00 0.151 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N18C 0.08 0.00 0.081 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N18D 0.13 0.00 0.131 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N19A 0.22 0.00 0.221 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 33

Alternative 4

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 4: Proposed Actions

18N19B 0.20 0.00 0.201 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N19C 0.17 0.00 0.171 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N20 1.00 0.00 1.0021 Downgrade to OML 1. Remove or repair road drainage features as 

needed to improve resource protection. Waterbars as needed and gate.

18N20.100 0.28 0.00 0.28 UAR Restore Barricade.

18N20.100A 0.08 0.00 0.08 UAR Restore Remove culverts and associated fill from stream channels. Waterbars as 

needed. Barricade.

18N20.101 0.12 0.00 0.12 UAR Restore Barricade.

18N20.102 0.47 0.00 0.47 UAR Restore Remove culverts and associated fill. Waterbars as needed. Barricade

18N20A 0.40 0.00 0.402 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N22 2.00 0.00 2.0021

Remove or repair road drainage features as needed to improve resource 

protection. Waterbars/rolling dips as needed and barricade. Downgrade 

to OML 1.

18N22D 0.62 0.00 0.622 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N22E 0.14 0.00 0.142 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N23 0.10 0.00 0.101 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N24 1.10 0.00 1.101 Motorized Trail Convert to motorized trail.

18N26 1.75 0.00 1.751 Motorized Trail Convert to motorized trail.

18N26A 0.15 0.00 0.1511 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars/rolling dips as needed and barricade.

18N26B 0.08 0.00 0.0811 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars/rolling dips as needed and barricade.

18N30A 0.28 0.00 0.281 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N30B 0.46 0.00 0.461 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N31 0.60 0.00 0.601 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Barricade.

18N31.2 0.23 0.00 0.23 UAR Restore Waterbar or rolling dips as needed and barricade.
34 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 4

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 4: Proposed Actions

18N31.3C 0.18 0.00 0.18 UAR Restore Waterbar or rolling dips as needed and barricade.

18N31.4 1.25 0.00 1.25 UAR Restore Waterbar or rolling dips as needed and barricade.

18N46 0.39 0.00 0.392 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N47 0.44 0.00 0.441 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N48 0.31 0.00 0.311 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N51 0.27 0.00 0.2712 Upgrade to OML 2.

18N51 0.43 0.27 0.7012 Upgrade to OML 2.

18N51.100 1.45 0.00 1.45 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

18N51.100A 0.46 0.00 0.46 UAR Restore Barricade.

18N56 0.88 0.00 0.8822 Replace culverts; install rolling dips as needed. POC Mitigation: rock/gravel 100' either side of infected creek crossing near milepost 0.15.

18N57 0.56 0.00 0.561 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

18N58.1 0.13 0.00 0.13 UAR Restore Barricade.

18N58B 0.25 0.00 0.251 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

199.102 0.13 0.00 0.13 UAR2 Add to road system. OML 2. Existing surface well graveled.

199.103 0.10 0.00 0.10 UAR3 Add to road system. OML 3. Griffin Bridge. POC Mitigation: 

rock/gravel 

entire route of infected POC as needed.

199.104 0.11 0.00 0.11 UAR3 Add to road system. OML 3, Madrona Campground. POC Mitigation: rock/gravel entire route of infected POC as needed.

199.105 0.03 0.00 0.03 UAR3 Add to road system. OML 3. Darlingtonia Trailhead access.

199.106 0.18 0.00 0.18 UAR3 Add to road system. OML 3. Eighteen

-mile river access site. POC 

Mitigation: rock/gravel entire route of infected POC as needed.

199.108 0.24 0.00 0.24 UAR Restore Barricade.

199.109 0.10 0.00 0.10 UAR Restore Barricade to allow parking at turnout and hiking access to river.

199.111 0.07 0.02 0.09 UAR Restore Barricade.

199.111 0.02 0.00 0.02 UAR2 Add to road system. Add road to creek as OML 2. POC Mitigation: rock/gravel entire route of infected POC as needed.

199.111A 0.07 0.00 0.07 UAR Restore Closed by barricade on 199.111.

199.113 0.07 0.00 0.07 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel as needed.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 35

Alternative 4

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 4: Proposed Actions

19N34 1.95 0.00 1.951 Decommission Remove from system. Remove culvert and associated fill as needed.

Waterbars as needed and barricade.

19N34A 0.28 0.00 0.281 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

19N34B 0.29 0.00 0.291 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

19N34C 0.08 0.00 0.081 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

305.100 0.57 0.00 0.57 UAR Restore Barricade.

305.101 1.08 0.00 1.08 UAR Restore Barricade.

305.101A 0.04 0.00 0.04 UAR Restore Barricade.

305.101B 0.50 0.00 0.50 UAR Restore Barricade.

305.102 0.15 0.00 0.15 UAR Restore Barricade.

305.103 0.14 0.00 0.14 UAR Restore Barricade.

305.104 0.14 0.00 0.14 UAR Restore Barricade.

305.105 0.22 0.00 0.22 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

305.106 0.21 0.00 0.21 UAR Restore Barricade.

305.107 1.25 0.00 1.25 UAR Restore Barricade.

305.108 0.06 0.00 0.06 UAR Restore Barricade.

305.109 2.43 0.00 2.43 UAR Motorized Trail

Add to trail system. Motorized trail. POC Mitigation: install drains gravel 

at wet areas to keep vehicles on roadway (near milepost1 and 1.5), 

install culvert. Improve surface drainage, route delineation(place 

boulders strategically), increase enforcement.

305.109A 1.02 0.00 1.02 UAR Restore Barricade.

305.113 0.12 0.00 0.12 UAR Restore Barricade.

305.114 0.63 0.00 0.63 UAR Restore Waterbar or rolling dips as needed and barricade.

305.115 1.74 0.00 1.74 UAR Restore Waterbar or rolling dips as needed and barricade.

305.115A 0.18 0.00 0.18 UAR Restore Waterbar or rolling dips as needed and barricade.

305.118 0.80 0.00 0.80 UAR Motorized Trail

Add to trail system. Motorized trail. POC Mitigation: seasonal closure 

required at beginning of route. Gate mid-Oct thru early June; need culvert 

at POC site, barricade end of route gravel and culvert placement in 

seepy area as needed. Route delineation.

305.118 0.76 0.80 1.56 UAR Restore Waterbar/rolling dips as needed. Barricade.

305.121 0.63 0.00 0.63 UAR Motorized Trail Add as motorized trail. POC Mitigation: seasonal gate closure.
36 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 4

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 4: Proposed Actions

305.121A 0.28 0.00 0.28 UAR Restore POC Mitigation: barricade.

305.121B 1.03 0.00 1.03 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

305.123 0.63 0.00 0.63 UAR Motorized Trail Add as motorized trail. Reinforce stream crossing.

305.124 1.20 0.00 1.20 UAR Restore Rolling dips as needed and barricade.

305.125 1.44 0.00 1.44 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route. POC Mitigation: 

seasonal closure, gate at both ends.

305.126 1.56 0.00 1.56 UAR Motorized Trail Add as trail. Motorized trail, route delineation.

305.128 0.70 0.00 0.70 UAR Restore Barricade.

305.129 0.40 0.00 0.40 UAR Restore Barricade.

305.130 1.72 0.00 1.72 UAR Motorized Trail Add as motorized trail.

305.131 0.09 0.00 0.09 UAR Restore Barricade.

305.132 0.04 0.00 0.04 UAR Motorized Trail Designate as motorized trail.

305.133 0.01 0.00 0.01 UAR Motorized Trail Add as motorized trail.

305.134 0.14 0.00 0.14 UAR Restore Barricade.

314.1 1.21 0.00 1.21 UAR Motorized Trail Add to trail system. Motorized trail. POC Mitigation: 

barricade at milepost

1.21.

314.107 0.26 0.00 0.26 UAR2 Add to road system. OML 2. Delineate route. Three Ponds camping area. 

POC Mitigation: rock/gravel as needed.

315.100 1.68 0.00 1.68 UAR Motorized Trail Add as motorized trail. Barricade at end.

315.102 0.48 0.00 0.48 UAR Restore Barricade.

315.103 0.26 0.00 0.26 UAR Restore Barricade

315.104 0.82 0.00 0.82 UAR Motorized Trail Add as motorized trail.

315.106 0.25 0.00 0.25 UAR Restore Barricade.

315.107 0.30 0.00 0.30 UAR Restore Barricade.

315.108 0.46 0.00 0.46 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

315.110 0.07 0.00 0.07 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel as needed.

315.111 0.03 0.00 0.03 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel as needed.

315.2 0.51 0.00 0.51 UAR Restore Rolling dips as needed. Remove culverts at milepost 0.07

, 0.13 and 0.18 

to improve drainage. POC Mitigation: barricade.

315.3 0.98 0.00 0.98 UAR Motorized Trail Add as motorized trail

. POC Mitigation: rock/gravel creek crossing and 

place culvert as needed.

315.3A 0.24 0.00 0.24 UAR Restore Remove all culverts. Waterbars as needed.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 37

Alternative 4

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 4: Proposed Actions

315.9A 1.22 0.00 1.22 UAR Restore Remove culverts and associated fill from stream channels. Waterbars as 

needed. POC Mitigation: barricade.

316.1 0.26 0.00 0.26 UAR2 Add to road system. OML 2. Administrative use only. Add rolling dips.

POC Mitigation: rock/gravel length of road.

316.10 0.03 0.00 0.03 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel as needed.

316.11 0.04 0.00 0.04 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel as needed.

316.12 0.03 0.00 0.03 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel as needed.

316.2 0.20 0.00 0.20 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel as needed.

316.3 0.08 0.00 0.08 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel as needed.

316.4 0.07 0.00 0.07 UAR Motorized Trail Add as motorized trail

. Route delineation. POC Mitigation: rock/gravel as 

needed.

316.5 0.03 0.00 0.03 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel as needed.

316.6 0.03 0.00 0.03 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel as needed.

316.7 0.02 0.00 0.02 UAR Motorized Trail Add as motorized trial. Route delineation.

316.7A 0.02 0.00 0.02 UAR Motorized Trail Add as motorized trail. Route delineation.

316.8 0.05 0.00 0.05 UAR Motorized Trail Add as motorized trail. Route delineation; waterbars. POC Mitigation: 

gravel as needed.

316.9 0.06 0.00 0.06 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel as needed.

316.9A 0.05 0.00 0.05 UAR Restore Barricade.

324.100 0.13 0.00 0.13 UAR Restore Barricade.

405.10 0.74 0.00 0.74 UAR Motorized Trail Add drivable portion to trail system. Motorized trail. Delineate route. 

Route delineation at milepost 0.36.

405.100 0.11 0.00 0.11 UAR Restore Barricade.

405.101 0.17 0.00 0.17 UAR Restore Barricade.

405.103 3.47 0.00 3.47 UAR Motorized Trail Add to trail system. Motorized trail. Improve surface drainage near creek; 

repair culvert.

405.9 0.05 0.00 0.05 UAR Restore Barricade.

411.101 0.30 0.00 0.30 UAR Restore Barricade.

411.102 0.17 0.00 0.17 UAR Restore SUP access road.

427.101 0.15 0.00 0.15 UAR1 Add to road system. OML 1.

427.103 0.32 0.00 0.32 UAR2 Add to road system. OML 2. Delineate route.

427.104 0.30 0.00 0.30 UAR Motorized Trail Add as motorized trail.
38 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 4

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 4: Proposed Actions

427.105 0.29 0.00 0.29 UAR2 Add to road system. OML 2. County disposal site; may be gated 

periodically for administrative purposes.

427.106 0.13 0.00 0.13 UAR Motorized Trail Add to trail system. Motorized trail. Install rolling dips to improve drainage.

427.107 0.05 0.00 0.05 UAR2 Add as OML 2. POC Mitigation: gravel as needed.

427.108 0.09 0.00 0.09 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel as needed.

427.108A 0.04 0.00 0.04 UAR Restore Barricade.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 39

Alternative 5

Table A-4. Alternative 5.

Alternative 5

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 5 Proposed Actions

13N35.5 0.14 0.00 0.14 UAR Restore Barricade.

13N35K 0.10 0.18 0.282 Decommission Remove from system. Barricade.

13N37 2.00 0.00 2.0021

Remove or repair road drainage features as needed to improve resource 

protection. Waterbars/rolling dips as needed and barricade. Downgrade to 

OML 1.

13N37.1 0.11 0.00 0.11 UAR Restore Barricade.

13N37A 0.77 0.00 0.772 Decommission Remove from system. Remove culverts and associated fill as needed.

Waterbars as needed and barricade.

13N37B 0.27 0.00 0.272 Decommission Remove from system. Remove culverts and associated fill as needed.

Waterbars as needed and barricade.

14N01 4.61 9.60 14.2133 POC Mitigation: seasonal gate closure.

14N01D 1.80 0.00 1.802 Decommission Decommission and barricade. Remove culverts. Waterbars and rolling dips 

as needed.

14N08 0.50 0.00 0.5022 POC Mitigation: year-round gate closure

14N08T 0.11 0.00 0.111 Decommission Remove from system. Remove all culverts and associated fill. Waterbars as 

needed and barricade.

14N15 0.50 0.00 0.502 Decommission Decommission and barricade. Remove culverts. Waterbars and rolling dips as 

needed. POC Mitigation: proposed seasonal gate on 14N01 restricts access.

14N15.1 3.80 0.00 3.80 UAR Restore Remove culverts and associated fill. Waterbar as needed and barricade.

14N32.1 0.26 0.00 0.26 UAR Restore Barricade.

14N33 1.60 0.18 1.782 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars and barricade.

14N33.3 0.52 0.00 0.52 UAR Restore Remove culverts and associated fill from stream channels as on 14N33.

Waterbar as needed. Closed by barricade on 14N33.

14N33A 0.22 0.00 0.221 Decommission Remove from system. Remove all culverts and associated fill. Waterbars as 

needed and barricade.

14N38 0.60 0.00 0.602 Decommission Decommission. Remove culverts. Waterbars and rolling dips as needed. 

Barricade.

14N39 1.90 0.00 1.902 Decommission Decommission and barricade. Remove culverts and associated fill. 

Waterbar as needed and barricade.
40 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 5

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 5 Proposed Actions

14N46 2.70 0.00 2.7021 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars as needed and barricade. Downgrade to OML 1.

14N46.2 0.13 0.00 0.13 UAR Restore Waterbars and barricade.

14N46B 0.37 0.00 0.371 Decommission Remove from system. Waterbars as needed and barricade.

15N01.102 0.29 0.00 0.29 UAR Restore Barricade.

15N01.102 0.19 0.29 0.48 UAR Restore Barricaded by first segment of 15N01.102.

15N01A.1 0.10 0.00 0.10 UAR Restore Barricade.

15N01A.2 0.05 0.00 0.05 UAR Restore Barricade.

15N01A.4 3.84 0.00 3.84 UAR1 Add to road system. OML 1. Remove or repair road drainage features as 

needed to improve resource protection. Repair road surface. Barricade.

15N01P 0.09 0.79 0.881 Decommission Remove from system. Remove all culverts and associated fill. Waterbars as 

needed and barricade.

15N01R 0.10 0.00 0.1011 Waterbars as needed and barricade.

15N01S 0.10 0.00 0.1011 Waterbars as needed and barricade.

15N01U 0.70 0.00 0.701 Decommission Remove from system. Remove all culverts and associated fill. Waterbars as 

needed and barricade.

15N01U.1 0.58 0.00 0.58 UAR Restore Barricade.

15N02 11.10 0.00 11.102 Decommission Decommission and barricade. Remove culverts, waterbars as needed.

15N02.101 0.81 0.00 0.81 UAR Restore Closed by barricade on 15N02.

15N02.103 0.58 0.00 0.58 UAR Restore Closed by barricade on 15N02.

15N02.106 0.48 0.00 0.48 UAR Restore Closed by barricade on 15N02.

15N02.107 0.42 0.00 0.42 UAR Restore POC Mitigation: closed through barricade on 15N02.

15N02.108 1.14 0.00 1.14 UAR Restore Barricade.

15N02.108A 0.59 0.39 0.98 UAR Restore Barricade.

15N02.2 0.24 0.00 0.24 UAR Restore Barricade.

15N02.4 0.49 0.00 0.49 UAR Restore Closed by barricade on 15N02.

15N02.5 0.90 0.00 0.90 UAR Restore Waterbars or rolling dips as needed and barricade.

15N02.5A 0.05 0.00 0.05 UAR Restore Closed by barricade on 15N02.

15N11.2 0.32 0.00 0.32 UAR Restore Barricade.

15N11A 1.70 0.00 1.701 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 41

Alternative 5

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 5 Proposed Actions

15N11A.1 0.25 0.00 0.25 UAR Restore Remove all culverts and associated fill from stream channels. Waterbars as 

needed. Closed by barricade on 15N11A.

15N11B 1.39 0.00 1.391 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars and barricade.

15N13 3.80 0.00 3.8022 Improve maintenance, repair/replace all culverts and drainage structures as 

needed. Manage as OML 2. POC Mitigation: seasonal gate closure.

15N13.100 0.49 0.62 1.11 UAR Restore Year-round gate closure southern terminus adjacent to private landholding.

15N13.100 0.48 1.74 2.22 UAR Restore Year-round gate closure northern terminus adjacent to private landholding.

15N33 0.90 0.00 0.901 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

15N35A 0.24 0.00 0.242 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

15N35B 0.57 0.00 0.571 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

15N35C 0.57 0.00 0.571 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

15N36.1 0.62 0.00 0.62 UAR Restore Remove 3 culverts and associated fill from stream channels. Waterbars as 

needed and barricade.

15N36C 0.55 0.00 0.551 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

15N36N 1.30 0.00 1.3012

Upgrade first 1.3 miles to OML 2. Maintain, repair, or replace each culvert. 

Improve surface drainage with waterbars and rolling dips as needed.

15N36N 1.30 1.30 2.601 Decommission Decommission from 1.3 to 2.6. Barricade.

15N36N.1 0.90 0.00 0.90 UAR2

Add to road system. OML 2. Access to Blackhawk Bar. Keep, maintain, 

repair, or replace each culvert. Improve surface draining with waterbars and 

rolling dips as needed. POC Mitigation: add gravel at drainage crossings 

and along areas with POC.

15N36N.1A 0.16 0.00 0.16 UAR Restore Barricade.

15N36N.1B 0.21 0.00 0.21 UAR Restore Barricade.

15N36N.1C 0.03 0.00 0.03 UAR Restore Closed by barricade on 15N36N.1B.

15N38 1.50 0.00 1.5022 Improve surface drainage and install culvert at stream ford on road near 

private land.

15N38 1.40 1.50 2.9021 Downgrade to OML 1. Remove or repair road drainage features as needed 

to improve resource protection. Waterbar as needed. Barricade.

15N39A 1.20 0.00 1.201 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Barricade.
42 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 5

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 5 Proposed Actions

15N39A.1 0.18 0.00 0.18 UAR Restore Barricade.

15N39B 0.50 0.00 0.501 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

15N42 1.06 0.00 1.062 Decommission Decommission and barricade. Remove all 3 culverts and associated fill.

Waterbars as needed.

15N42A 0.44 0.00 0.441 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

15N45 1.13 0.00 1.131 Decommission Decommission and barricade. Excavate culverts and associated fill.

15N45.100 0.22 0.00 0.22 UAR Restore Barricade.

15N45.101 0.12 0.00 0.12 UAR Restore Barricade.

15N63 0.30 0.00 0.3022 Manage as OML 2.

16N02.1 0.10 0.00 0.10 UAR2 Add to road system. OML 2. Bear Basin water source. Route delineation.

16N02.2 0.87 0.00 0.87 UAR Restore Barricade.

16N02.5 0.21 0.00 0.21 UAR Restore Waterbar or rolling dips as needed and barricade.

16N02D 0.61 0.00 0.612 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

16N02G 0.70 0.00 0.702 Decommission Decommission and barricade. Remove culverts and associated fill. 

Waterbar as needed.

16N02H 0.40 0.00 0.4011 Waterbars or rolling dips as needed.

16N02L 1.70 0.00 1.702 Decommission Decommission and barricade. Remove culverts. Install waterbars or rolling 

dips. POC Mitigation: current seasonal gate restricts access.

16N02S 1.20 0.00 1.201 Decommission Remove from system. Remove culverts and associated fill as needed.

Waterbars as needed and barricade.

16N02S.1 0.21 0.00 0.21 UAR Restore Barricade.

16N02T 0.50 0.00 0.501 Decommission Remove from system. Remove culverts and associated fill as needed.

Waterbars as needed and barricade.

16N02T.1 0.12 0.00 0.12 UAR Restore Barricade.

16N03.100 0.10 0.00 0.10 UAR Restore Barricade.

16N03.2 0.87 0.00 0.87 UAR Restore Remove 3 culverts and associated fill from stream channels. Waterbars as 

needed and barricade.

16N03D 1.48 0.00 1.4811 Waterbars as needed and barricade.

16N03F 0.70 0.00 0.702 Decommission Decommission and barricade. Remove all 4 culverts and associated fill.

Waterbars as needed.

16N03G 0.08 0.00 0.081 Decommission Remove from system. Waterbar landing as needed and barricade.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 43

Alternative 5

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 5 Proposed Actions

16N03H 0.30 0.00 0.302 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

16N03K 0.63 0.87 1.5021

Downgrade to OML 1. Remove or repair road drainage features as needed 

to improve resource protection. Waterbar as needed and barricade. POC 

Mitigation: current seasonal gate restricts access.

16N03L 0.20 0.00 0.201 Decommission Remove from system. Remove culverts and associated fill as needed.

Waterbars as needed and barricade.

16N10.1 0.14 0.00 0.14 UAR Restore Barricade.

16N10.2 0.21 0.00 0.21 UAR Restore POC Mitigation: route extends from non-motorized trail. No motorized access.

16N15A 0.17 0.00 0.172 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

16N16 1.50 0.00 1.5022 Repair or replace plugged culverts.

16N16 0.60 1.50 2.1021 Downgrade to OML 1. Remove or repair road drainage features as needed 

to improve resource protection. Waterbars and barricade.

16N18.1 1.04 0.00 1.04 UAR Restore Barricade past point where two access point joint, approx. 200' up road.

16N18.3 0.49 0.00 0.49 UAR Restore Barricade.

16N18.4 0.67 0.00 0.67 UAR Restore Barricade.

16N18A 1.35 0.00 1.3521 Downgrade to OML 1. Remove or repair road drainage features as needed 

to improve resource protection. Rolling dips as needed. Barricade.

16N18A 0.95 1.35 2.302 Decommission Remove 5 culverts and decommission.

16N18B.1 0.66 0.00 0.66 UAR Restore Barricade.

16N18C 0.39 0.00 0.391 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

16N18E 0.96 0.00 0.962 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

16N18K 1.10 0.00 1.1011 Waterbar or rolling dips as needed.

16N19 8.28 0.00 8.2821 Downgrade to OML 1. Barricade. Remove or repair road drainage features 

as needed to improve resource protection.

16N19.1 0.05 0.00 0.05 UAR Restore Barricade.

16N19.2 0.08 0.00 0.08 UAR Restore Rolling dips as needed and barricade.

16N19.3 0.30 0.00 0.30 UAR Restore Barricade.

16N19.4 0.87 0.00 0.87 UAR Restore Barricade.

16N19.5 0.19 0.00 0.19 UAR Restore Remove fill from culvert. Barricade.
44 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 5

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 5 Proposed Actions

16N19A 0.23 0.00 0.232 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

16N19B 1.40 0.00 1.4021 Waterbars as needed and barricade. Downgrade to OML 1.

16N19D 0.40 0.00 0.4021 Downgrade to OML 1. Barricaded through network on 16N19.

16N19E 0.95 0.00 0.9521 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars as needed and barricade. Downgrade to OML 1.

16N19E.1 0.41 0.00 0.41 UAR Restore Barricade.

16N19F 0.76 0.00 0.762 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

16N19G 0.23 0.00 0.232 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

16N21.1 0.15 0.00 0.15 UAR Restore Waterbars or rolling dips as needed and barricade.

16N21.2 0.10 0.00 0.10 UAR Restore Barricade.

16N21F.1 0.09 0.00 0.09 UAR Restore Barricade.

16N23 7.40 0.00 7.402 Decommission Decommission and barricade. Remove culverts, waterbars or rolling dips as 

needed.

16N23.100 0.64 0.00 0.64 UAR Restore Closed through network barricade on 16N23A.1.

16N23.2 0.22 0.00 0.22 UAR Restore This route comes off an OML 1 road. Will be barricaded through network on 

16N23.

16N23.4 0.69 0.00 0.69 UAR Restore Closed through network barricade on 16N23.

16N23A.1 1.90 0.00 1.90 UAR Restore Closed through network barricade on 16N23.

16N24A 0.65 0.00 0.651 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

16N27 0.50 0.00 0.501 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

16N30 0.24 0.00 0.241 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Barricade.

16N31 0.35 0.00 0.351 Decommission Decommission and barricade.

16N31A.1 0.22 0.00 0.22 UAR Restore Barricade.

16N31B 1.00 0.00 1.001 Decommission Decommission and barricade.

16N31B.2 0.13 0.00 0.13 UAR Restore Barricade.

16N32 3.12 0.82 3.9421

Downgrade to OML 1. Remove or repair road drainage features as needed 

to improve resource protection. Waterbar as needed and barricade. POC 

Mitigation: current seasonal gate restricts access.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 45

Alternative 5

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 5 Proposed Actions

16N32 0.82 0.00 0.8222 Improve maintenance, repair, or replace culverts. POC Mitigation: current 

seasonal gate restricts access.

16N32A 0.08 0.00 0.081 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

16N32C 0.47 0.00 0.471 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Closed through network barricade on 16N32.

16N33 0.70 0.00 0.702 Decommission Decommission and barricade.

16N33 3.70 0.70 4.401 Decommission Decommission and barricade.

16N33A 0.21 0.00 0.211 Decommission Decommission and barricade.

16N34 0.60 0.00 0.6022 Add culvert at milepost0.34.

16N34 0.30 0.60 0.9021 Downgrade to OML 1. Remove last culvert at milepost

0.9 switchback.

POC Mitigation: barricade.

16N34A 0.50 0.00 0.5021 Waterbars as needed and barricade. Downgrade to OML 1.

16N35A 0.14 0.00 0.141 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

16N35C 0.12 0.00 0.122 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Barricade.

16N36 1.20 0.00 1.2022 Improve maintenance, repair, or replace each of the culverts.

16N36.1 0.11 0.69 0.80 UAR Restore

16N36.1 0.69 0.00 0.69 UAR Restore Barricade.

16N36B 0.82 0.00 0.8222 Clean blocked culverts and install 2 additional culverts.

16N37 1.20 0.00 1.2021 Downgrade to OML 1. Remove or repair road drainage features as needed to 

improve resource protection. Waterbars or rolling dips as needed. Barricade.

16N37B 0.17 0.00 0.172 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

16N38 1.32 0.28 1.6021 Downgrade to OML 1. Remove or repair road drainage features as needed 

to improve resource protection. Waterbar as needed and barricade.

16N39A 0.22 0.00 0.221 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

16N41 0.06 0.53 0.5922 Replace culvert at milepost

0.56. POC Mitigation: gravel areas with dead 

POC along road as needed.

16N41A 0.17 0.00 0.172 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

16N41B 0.09 0.00 0.092 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.
46 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 5

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 5 Proposed Actions

16N55 0.50 0.00 0.5012 Upgrade to OML 2. POC Mitigation

16N55.1 0.16 0.00 0.16 UAR Restore Barricade.

17N01 0.70 0.00 0.7022 POC Mitigation: rock/gravel road as needed.

17N01.1 0.21 0.00 0.21 UAR Restore Barricade.

17N01.100 2.49 0.00 2.49 UAR Restore Remove all culverts and associated fill from stream channels. Barricade.

17N01.1A 0.02 0.00 0.02 UAR Restore Closed by barricade on 17N01.1.

17N01.1B 0.03 0.00 0.03 UAR Restore Closed by barricade on 17N01.1.

17N01.1C 0.09 0.00 0.09 UAR Restore Waterbars as needed. Closed by barricade on 17N01.1.

17N01.1D 0.13 0.00 0.13 UAR Restore Barricade.

17N01.2 0.30 0.00 0.30 UAR Restore Barricade.

17N01.2B 0.03 0.00 0.03 UAR Restore Barricade.

17N01.3 0.13 0.00 0.13 UAR Restore Barricade. Waterbar as needed.

17N01.3A 0.07 0.00 0.07 UAR Restore Closed by barricade on 17N01.3A.

17N03 1.20 0.00 1.2011 Waterbars as needed and barricade.

17N04.1 0.12 0.00 0.12 UAR Restore Barricade.

17N04.2 0.35 0.00 0.35 UAR Restore Barricade.

17N04.3 0.97 0.00 0.97 UAR Restore Remove culvert and associated fill. Rolling dips as needed and barricade.

17N04L 3.10 0.00 3.101 Decommission Decommission and barricade.

17N04S 1.80 0.00 1.801 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

17N05.100 0.88 0.00 0.88 UAR Restore Barricade.

17N05.101 0.06 0.00 0.06 UAR Restore Barricade.

17N05.4 0.32 0.00 0.32 UAR Restore Barricade.

17N05.4A 1.36 0.00 1.36 UAR Restore Rolling dips as needed and barricade.

17N05.5 0.14 0.00 0.14 UAR Restore Waterbar or rolling dips as needed and barricade.

17N05C 0.97 0.00 0.971 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

17N05E 0.71 0.00 0.7111 Barricade.

17N05G 0.67 0.00 0.671 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

17N05U 0.28 0.00 0.281 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 47

Alternative 5

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 5 Proposed Actions

17N07 10.39 0.00 10.3932 Downgrade to OML 2. POC Mitigation: rock/gravel as needed at wet areas, 

draws and areas with POC.

17N07.1 0.25 0.00 0.25 UAR Restore Waterbars or rolling dips as needed and barricade.

17N07.101 0.09 0.00 0.09 UAR Restore Barricade.

17N07.102 3.07 0.00 3.07 UAR Restore Road not stable; failing. Remove all culverts and associated fill from stream 

channels. Barricade.

17N07.2 0.51 0.00 0.51 UAR Restore Waterbar or rolling dips as needed and barricade.

17N07.4 0.21 0.00 0.21 UAR Restore Waterbars/rolling dips as needed. No treatment recommended for this 

segment, but larger segment should have road blocked at beginning of route.

17N07.5 0.32 0.00 0.32 UAR Restore Barricade.

17N07.5A 0.15 0.00 0.15 UAR Restore Barricade.

17N07.6 0.75 0.00 0.75 UAR Restore Barricade.

17N07.7 0.30 0.00 0.30 UAR Restore Barricade.

17N07G 1.67 0.00 1.6721 Downgrade to OML 1. Barricade.

17N07J 1.64 0.00 1.6422 Repair culvert at milepost 1.25. POC Mitigation: rock/gravel as needed at 

wet areas, draws and areas with POC.

17N07K 0.80 0.00 0.8021 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars as needed and barricade. Downgrade to OML 1.

17N07Q 0.22 0.00 0.222 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

17N07R 0.44 0.00 0.442 Decommission Remove from system. Remove culvert and associated fill. Barricade.

17N07R.1 0.16 0.00 0.16 UAR Restore Barricade.

17N07R.1A 0.25 0.00 0.25 UAR Restore Barricade.

17N08.3 0.30 0.00 0.30 UAR Restore Barricade.

17N08A 0.50 0.00 0.501 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Barricade.

17N13 0.70 0.00 0.7021 Downgrade to OML 1. Barricade. Remove or repair road drainage features 

as needed to improve resource protection.

17N13A 0.38 0.00 0.3821 Waterbars as needed and barricade. Downgrade to OML 1.

17N14 0.39 0.00 0.3921 Downgrade to OML 1. Barricade first 100' from west side access.

17N15 0.90 0.00 0.9021 Waterbars as needed and barricade. Downgrade to OML 1.

17N15A 0.13 0.00 0.131 Decommission Remove from system. Waterbar as needed and barricade.

17N16 0.65 0.00 0.6521 Waterbars as needed and barricade. Downgrade to OML 1.
48 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 5

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 5 Proposed Actions

17N16.1 0.17 0.00 0.17 UAR Restore Barricade.

17N16.100 0.07 0.00 0.07 UAR Restore Waterbar or rolling dips as needed and barricade.

17N17 0.60 0.00 0.601 Decommission Remove from system. Remove culvert and associated fill from stream 

channel. Waterbars as needed and barricade.

17N17.1 1.98 0.00 1.98 UAR Restore Closed by barricade on 17N17.

17N18.2 0.39 0.00 0.39 UAR Restore Remove 2 culverts and associated fill from stream channels. Waterbar as 

needed and barricade.

17N18.3 0.74 0.00 0.74 UAR Restore Barricade.

17N18.4 0.15 0.00 0.15 UAR Restore Barricade.

17N18A 0.94 0.00 0.9412 Upgrade to OML 2.

17N18C 0.67 0.00 0.6721 Downgrade to OML 1. Remove or repair road drainage features as needed to 

improve resource protection. Waterbars and rolling dips as needed. Barricade.

17N18E 0.42 0.00 0.421 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N18F 0.07 0.00 0.071 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N20 0.19 0.00 0.1922 Improve maintenance, repair, or replace each of the 3 culverts.

17N21.1 0.41 0.00 0.41 UAR Restore Waterbar or rolling dips as needed and barricade.

17N22A 0.79 0.00 0.7922 Improve maintenance, repair, or replace culvert at milepost 0.7.

17N22A.1 0.21 0.00 0.21 UAR Restore Waterbar or rolling dips as needed and barricade.

17N22A.2 0.25 0.00 0.25 UAR Restore Barricade.

17N22D 0.08 0.00 0.082 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N22J 0.12 0.00 0.1222 Waterbars or rolling dips as needed.

17N22W.1 0.46 0.00 0.46 UAR Restore Waterbar as needed. SUP Road, do not barricade.

17N23 1.30 1.50 2.801 Decommission Remove from system. Waterbars as needed, remove culverts, barricade.

17N23 1.15 0.35 1.501 Decommission Remove from system.

17N23C.1 1.04 0.05 1.09 UAR1 Add to road system. OML 1.

17N23C.1 0.05 0.00 0.05 UAR1 Add to road system. OML 1. Barricade.

17N23C.1 1.15 1.09 2.24 UAR1 Add to road system. OML 1.

17N23C.2 0.59 0.00 0.59 UAR1 Add to road system. OML 1.

17N26 0.25 0.00 0.2521 Downgrade to OML 1. Barricade.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 49

Alternative 5

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 5 Proposed Actions

17N26A 0.37 0.00 0.3721 Downgrade to OML 1. Remove or repair road drainage features as needed 

to improve resource protection. Waterbar as needed and barricade.

17N27A.1 0.21 0.00 0.21 UAR Restore Closed by barricade on 17N27.

17N27B 0.40 0.00 0.401 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N27C 0.40 0.00 0.401 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N27D.1 0.36 0.00 0.36 UAR Restore Waterbar or rolling dips as needed and barricade.

17N28 0.20 0.00 0.201 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N29 1.00 0.00 1.002 Decommission Decommission. Pull fill back from landing.

17N29.100 0.04 0.00 0.04 UAR Restore Closed by barricade on 17N32G.

17N29B 0.20 0.00 0.202 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N30 0.89 0.00 0.8921 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars as needed. Downgrade to OML 1 and barricade.

17N30 0.55 0.89 1.442 Decommission Remove from system.

17N30A 0.40 0.00 0.4021 Downgrade to OML 1.

17N31 1.60 0.00 1.6021 Waterbars as needed and barricade. Downgrade to OML 1.

17N31.3 0.17 0.00 0.17 UAR Restore Barricade.

17N31A.1 0.36 0.00 0.36 UAR Restore Barricade.

17N32 2.22 0.00 2.222 Decommission Decommission and barricade. Remove culvert and fill. Waterbar as needed.

17N32.1 0.31 0.00 0.31 UAR Restore Barricade.

17N32.2 0.17 0.00 0.17 UAR Restore Closed by barricade on 17N32.

17N32B 0.80 0.00 0.802 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N32F 1.00 0.00 1.002 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N32G 1.20 0.00 1.202 Decommission Decommission. Repair or replace culverts.

17N35 0.50 0.00 0.502 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

17N35.100 0.35 0.00 0.35 UAR Restore Barricade.

17N36 2.50 0.00 2.5022 Improve maintenance, repair, or replace each of the 14 culverts. POC 

Mitigation: seasonal gate closure near 17N04.
50 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 5

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 5 Proposed Actions

17N36B.1 0.26 0.00 0.26 UAR Restore Barricade.

17N36C 0.43 0.00 0.431 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

17N36F 1.20 0.00 1.2012 Upgrade to OML 2.

17N39 2.19 0.00 2.1921 Downgrade to OML 1. Remove or repair road drainage features as needed to 

improve resource protection. Waterbars and rolling dips as needed. Barricade.

17N39A 0.95 0.00 0.951 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

17N39B 0.51 0.00 0.511 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Barricade.

17N39C 0.12 0.00 0.121 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

17N40 0.35 0.65 1.0021 Waterbars as needed and barricade. Downgrade to OML 1.

17N40 0.28 0.37 0.6521 Downgrade to OML 1. Barricade.

17N40B 0.53 0.00 0.5321 Waterbars as needed and barricade. Downgrade to OML 1.

17N40B.1 0.19 0.00 0.19 UAR Restore Barricade.

17N40C.1 0.20 0.00 0.20 UAR Restore Barricade.

17N40D 0.18 0.00 0.181 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

17N41 4.25 0.00 4.2521 Downgrade to OML 1. Remove or repair road drainage features as needed to 

improve resource protection. Waterbars and rolling dips as needed. Barricade.

17N41.1 0.74 0.00 0.74 UAR Restore Barricade.

17N41.2 0.02 0.00 0.02 UAR Restore Barricade.

17N41A 0.30 0.00 0.3011 Barricade.

17N41G.1 0.17 0.00 0.17 UAR Restore Waterbars or rolling dips as needed and barricade.

17N41H 0.90 0.00 0.9021 Downgrade to OML 1. Remove or repair road drainage features as needed 

to improve resource protection. Waterbar as needed and barricade.

17N41H.100 0.06 0.00 0.06 UAR Restore Close by barricade on 17N41H.

17N42A.100 0.48 0.00 0.48 UAR Restore Barricade.

17N43 1.00 0.00 1.0021 Downgrade to OML 1. Barricade.

17N43.1 0.04 0.00 0.04 UAR Restore Barricade.

17N46 1.20 0.00 1.2021 Downgrade to OML 1. Remove or repair road drainage features as needed 

to improve resource protection. Waterbar as needed.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 51

Alternative 5

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 5 Proposed Actions

17N46A 0.16 0.00 0.161 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

17N48 1.66 0.00 1.6621 Downgrade to OML 1. Remove or repair road drainage features as needed 

to improve resource protection. Waterbar as needed and barricade.

17N48.1 0.33 0.00 0.33 UAR Restore Barricade.

17N48.3 0.16 0.00 0.16 UAR Restore Waterbars or rolling dips as needed and barricade.

17N48.4 0.46 0.00 0.46 UAR Restore Waterbars or rolling dips as needed and barricade.

17N48C 0.47 0.00 0.471 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Barricade.

17N49 1.75 2.96 4.7132

Downgrade to OML 2. POC Mitigation: rock/gravel as needed stretch with 

infected POC, approx. milepost 3.8, just north of 17N49.101 junction, for 

100'.

17N49 1.34 4.71 6.0532 Downgrade to OML 2.

17N49 1.80 6.05 7.8532 Downgrade to OML 2.

17N49.1 0.04 0.00 0.04 UAR Restore Barricade.

17N49.100 0.12 0.00 0.12 UAR Restore Barricade.

17N49.100 3.88 0.12 4.00 UAR Restore Barricade.

17N49.100A 0.21 0.00 0.21 UAR Restore Barricade.

17N49.101 1.17 0.00 1.17 UAR Restore Barricade.

17N49.102 0.87 0.00 0.87 UAR Restore Barricade.

17N49.102A 0.71 0.00 0.71 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.102B 0.17 0.00 0.17 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.102C 0.20 0.00 0.20 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.103 0.26 0.00 0.26 UAR Restore Waterbars or rolling dips as needed and barricade.

17N49.104 3.82 0.00 3.82 UAR Restore Barricade.

17N49.104 0.86 3.82 4.68 UAR Restore Barricade.

17N49.104A 0.05 0.00 0.05 UAR Restore Barricade.

17N49.104B 0.08 0.00 0.08 UAR Restore Barricade.

17N49.105 1.43 0.00 1.43 UAR Restore Barricade.

17N49.105A 0.12 0.00 0.12 UAR Restore Barricade.

17N49.106 0.32 0.00 0.32 UAR Restore Barricade.

17N49.107 0.64 0.00 0.64 UAR Restore Barricade.
52 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 5

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 5 Proposed Actions

17N49.108 0.31 0.00 0.31 UAR Restore Barricade.

17N49.11 1.94 0.00 1.94 UAR Restore Barricade.

17N49.11 2.55 1.94 4.49 UAR Restore Barricade

17N49.11M 0.17 0.00 0.17 UAR Restore Closed by barricade on 17N49.15, 17N49.7, and 17N49.11.

17N49.11N 0.23 0.00 0.23 UAR Restore Closed by barricade on 17N49.15, 17N49.7, and 17N49.11.

17N49.11P 0.21 0.00 0.21 UAR Restore Barricade.

17N49.12 2.10 0.00 2.10 UAR Restore Barricade.

17N49.13 0.30 0.00 0.30 UAR Restore Barricade.

17N49.14 0.54 0.00 0.54 UAR Restore Barricade.

17N49.15 0.62 0.00 0.62 UAR Restore Barricade.

17N49.15A 0.24 0.00 0.24 UAR Restore Barricade.

17N49.2 0.20 0.00 0.20 UAR Restore Barricade.

17N49.3 0.23 0.00 0.23 UAR Restore Barricade.

17N49.4 1.29 0.00 1.29 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.4 0.75 1.29 2.04 UAR Restore Barricade both ends.

17N49.4A 1.06 0.00 1.06 UAR Restore Year-round gate.

17N49.7 3.06 0.00 3.06 UAR Restore Barricade.

17N49.7 0.29 3.06 3.35 UAR Restore Barricade.

17N49.7A 0.82 0.00 0.82 UAR Restore Barricade.

17N49.8 0.39 0.00 0.39 UAR Restore Barricade.

17N63 0.30 0.00 0.3021 Downgrade to OML 1. Barricade.

17N85 1.20 0.00 1.20 UAR Restore Remove culverts and barricade.

18N01 0.10 0.00 0.1022 Maintain as OML 2.

18N01 0.06 0.10 0.162 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N02 1.75 0.00 1.7533 POC Mitigation: rock/gravel segment 100' either side of Sanger Lake Outlet.

18N02 0.85 1.75 2.6033 POC Mitigation: install seasonal gate closure.

18N02.1 0.14 0.00 0.14 UAR Restore Barricade.

18N02.2 0.28 0.00 0.28 UAR Restore Barricade.

18N02.3 0.02 0.00 0.02 UAR Restore Barricade.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 53

Alternative 5

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 5 Proposed Actions

18N03 1.91 0.00 1.911 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N04.2 0.11 0.00 0.11 UAR Restore Barricade.

18N04E 0.21 0.65 0.862 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar or rolling dips as needed and barricade.

18N05.1 0.20 0.00 0.20 UAR Restore Remove culverts and associated fill from stream channels. Waterbar as 

needed and barricade.

18N05.100 2.16 0.00 2.16 UAR Restore Remove culverts and associated fill from stream channels. Waterbar as 

needed. POC Mitigation: barricade.

18N05.2 0.53 0.00 0.53 UAR Restore Remove culverts and associated fill from stream channels. Closed by 

barricade on 18N05.

18N06A 0.18 0.00 0.181 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N07 0.05 0.00 0.0533 bridge repair/replacement

18N07.11 0.06 0.00 0.06 UAR Restore Barricade.

18N07.12 0.04 0.00 0.04 UAR Restore Barricade.

18N07.14 0.05 0.00 0.05 UAR Restore Barricade.

18N07.2 0.13 0.00 0.13 UAR2 Add to road system. Manage as OML 2.

18N07.3 0.08 0.00 0.08 UAR Restore Barricade.

18N07.6 0.25 0.00 0.25 UAR Restore Remove culverts and associated fill from stream channels. Waterbar as 

needed and barricade.

18N07.8 0.38 0.00 0.38 UAR Restore Remove culverts and associated fill from stream channels. Waterbar as 

needed and barricade.

18N08.2 0.03 0.00 0.03 UAR2 Add to road system. OML 2.

18N08F 0.90 0.90 1.8021 Downgrade to OML 1. Remove or repair road drainage features as needed 

to improve resource protection. Waterbar as needed and barricade.

18N08G 1.12 0.00 1.121 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N09 5.10 0.00 5.1022 POC Mitigation: seasonal gate closure.

18N09.100 0.27 0.00 0.27 UAR Restore Rolling dips as needed and barricade at 18N09.

18N09.100A 0.16 0.00 0.16 UAR Restore Rolling dips as needed and barricade.

18N09.101 0.16 0.00 0.16 UAR Motorized Trail Add as motorized trail. POC Mitigation: gravel last 100' of route.

18N09.102 1.84 0.00 1.84 UAR Restore Rolling dips as needed and barricade.

18N09.103 0.04 0.00 0.04 UAR Restore Waterbar or rolling dips as needed and barricade.
54 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 5

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 5 Proposed Actions

18N09.104 0.05 0.00 0.05 UAR Restore Rolling dips as needed and barricade.

18N09.105 0.12 0.00 0.12 UAR Restore Rolling dips as needed and barricade.

18N09.106 0.02 0.00 0.02 UAR Restore Barricade.

18N09.107 0.01 0.00 0.01 UAR Restore Barricade.

18N09.108 0.03 0.00 0.03 UAR Restore Barricade.

18N10.1 0.70 0.00 0.70 UAR Restore Barricade.

18N11 1.92 4.15 6.0722 Replace culvert at milepost 5.78.

18N11A 0.80 0.00 0.801 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N11B 0.19 0.00 0.191 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N11C 0.20 0.00 0.201 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N11D 0.46 0.00 0.461 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N11D.1 1.75 0.00 1.75 UAR Restore Closed by barricade on 18N11D.

18N11D.2 0.25 0.00 0.25 UAR Restore Remove culverts and associated fill from stream channels. Waterbar as 

needed. Closed by barricade on 18N11D.

18N11D.3 0.29 0.00 0.29 UAR Restore Remove culverts and associated fill from stream channels. Waterbar as 

needed. Closed by barricade on 18N11D.

18N11D.4A 0.73 0.00 0.73 UAR Restore Barricade.

18N11D.5 2.11 0.00 2.11 UAR Restore Remove culverts and fill from stream channels. Waterbars as needed and 

barricade.

18N12A 0.43 0.00 0.431 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N13.100 0.21 0.00 0.21 UAR Restore Barricade.

18N13.101 0.08 0.00 0.08 UAR Restore Closed by barricade on 18N13.

18N15 1.20 0.00 1.202 Decommission Decommission and barricade. Upsize culverts, install waterbars or rolling dips.

18N15A 0.60 0.00 0.602 Decommission Decommission.

18N15D 0.23 0.00 0.232 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N16 5.33 0.00 5.3322 POC Mitigation: add rock/gravel as needed 0.28 miles within infected POC.

18N16.100 2.60 0.00 2.60 UAR Restore Barricade.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 55

Alternative 5

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 5 Proposed Actions

18N16E 0.38 0.00 0.381 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N16F.1 0.16 0.00 0.16 UAR Restore Barricade.

18N16W 0.17 0.00 0.172 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N17 8.10 0.00 8.102 Decommission Decommission and barricade. Remove culverts. Rolling dips and waterbars 

as needed. POC Mitigation: current seasonal gate.

18N17.100 1.01 0.00 1.01 UAR Restore Barricade.

18N17.100A 0.08 0.00 0.08 UAR Restore Barricade.

18N17.101 0.05 0.00 0.05 UAR Restore Closed by barricade on 18N17.

18N17.102 0.06 0.00 0.06 UAR Restore Closed by barricade on 18N17.

18N17.103 0.21 0.00 0.21 UAR Restore Barricade.

18N17.104 0.20 0.00 0.20 UAR Restore Barricade.

18N17.104A 0.02 0.00 0.02 UAR Restore Closed by barricade on 18N17.

18N17A 0.21 0.00 0.212 Decommission Decommission. Remove culverts and associated fill. Waterbar as needed. 

Barricade 100' north from junction of 18N17H.

18N17B 0.87 0.00 0.872 Decommission Decommission. Install culvert at milepost 0.5.

18N17C 1.18 0.00 1.182 Decommission Decommission. Remove culverts. Rolling dips and waterbars as needed. 

Barricade. POC Mitigation: existing seasonal gate on 18N17 restricts access.

18N17C.1 0.05 0.00 0.05 UAR Restore Closed by barricade on 18N17C.

18N17D 0.25 0.00 0.252 Decommission Decommission.

18N17E 0.90 0.00 0.902 Decommission Decommission. Remove culverts and fill. Waterbar as needed.

18N17F 0.54 0.00 0.542 Decommission Decommission.

18N17G 0.12 0.00 0.122 Decommission Decommission. Remove culverts and associated fill from stream channels.

Waterbar as needed.

18N17H 0.15 0.00 0.152 Decommission Decommission. Remove culverts and associated fill from stream channels.

Waterbar as needed.

18N18A 0.20 0.00 0.201 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N18B 0.15 0.00 0.151 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N18C 0.08 0.00 0.081 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.
56 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 5

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 5 Proposed Actions

18N18D 0.13 0.00 0.131 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N19A 0.22 0.00 0.221 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N19B 0.20 0.00 0.201 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N19C 0.17 0.00 0.171 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N20 1.000.00 1.002 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N20.100 0.28 0.00 0.28 UAR Restore Barricade.

18N20.100A 0.08 0.00 0.08 UAR Restore Remove culverts and associated fill from stream channels. Waterbar as 

needed. Closed by barricade on 18N20.

18N20.101 0.12 0.00 0.12 UAR Restore Barricade.

18N20.102 0.47 0.00 0.47 UAR Restore Remove culverts and associated fill. Waterbar as needed.

18N20A 0.40 0.00 0.402 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N22 2.00 0.00 2.0021

Remove or repair road drainage features as needed to improve resource 

protection. Waterbars/rolling dips as needed and barricade. Downgrade to 

OML 1.

18N22D 0.62 0.00 0.622 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N22E 0.14 0.00 0.142 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N23 0.10 0.00 0.101 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N24 1.10 0.00 1.1011 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars/rolling dips as needed and barricade.

18N26 1.75 0.00 1.7511 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars/rolling dips as needed and barricade.

18N26A 0.15 0.00 0.1511 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars/rolling dips as needed and barricade.

18N26A.2 0.06 0.00 0.06 UAR Restore Closed by barricade on 18N26A.

18N26B 0.08 0.00 0.0811 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars/rolling dips as needed and barricade.

18N30.100 0.04 0.00 0.04 UAR Restore Barricade.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 57

Alternative 5

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 5 Proposed Actions

18N30A 0.28 0.00 0.281 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N30B 0.46 0.00 0.461 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N31 0.60 0.00 0.601 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Barricade.

18N31.1 0.16 0.00 0.16 UAR Restore Closed by barricade on 18N31.

18N31.2 0.23 0.00 0.23 UAR Restore Rolling dips as needed. Closed by barricade on 18N31.

18N31.3C 0.18 0.00 0.18 UAR Restore Rolling dips as needed. Barricade.

18N31.4 1.25 0.00 1.25 UAR Restore Rolling dips as needed. Barricade.

18N46 0.39 0.00 0.392 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N47 0.44 0.00 0.441 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N48 0.31 0.00 0.311 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N51 0.27 0.00 0.2712 Upgrade to OML 2.

18N51.100 1.45 0.00 1.45 UAR Restore Barricade.

18N51.100A 0.46 0.00 0.46 UAR Restore Barricade.

18N56 0.88 0.00 0.8821 Downgrade to OML 1. Remove or repair road drainage features as needed to 

improve resource protection. Rolling dips and waterbars as needed. Barricade.

18N56.100 0.04 0.00 0.04 UAR Restore Closed by barricade on 18N56.

18N57 0.56 0.00 0.561 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

18N58.1 0.13 0.00 0.13 UAR Restore Barricade.

18N58B 0.25 0.00 0.251 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

199.102 0.13 0.00 0.13 UAR2 Add to road system. OML 2.

199.103 0.10 0.00 0.10 UAR3 Add to road system. OML 3. Griffin Bridge. POC Mitigation: gravel areas 

near creek and river as needed.

199.104 0.11 0.00 0.11 UAR3 Add to road system. OML 3. Madrona Campground. POC Mitigation: gravel 

areas near creek and river as needed.

199.105 0.03 0.00 0.03 UAR3 Add to road system. OML 3. Darlingtonia Trail head access.
58 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 5

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 5 Proposed Actions

199.106 0.18 0.00 0.18 UAR3 Add to road system. OML 3. Eighteen

-mile river access site. POC 

Mitigation: rock/gravel route as needed.

199.107 0.10 0.00 0.10 UAR Restore Barricade.

199.108 0.24 0.00 0.24 UAR Restore Barricade.

199.109 0.10 0.00 0.10 UAR Restore Barricade to allow parking at turnout and hiking access to river.

199.111 0.09 0.00 0.09 UAR Restore Barricade.

199.111A 0.07 0.00 0.07 UAR Restore Closed by barricade on 199.111.

199.112 0.29 0.00 0.29 UAR Restore Barricade.

199.113 0.07 0.00 0.07 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel route as needed.

19N01 1.60 0.00 1.6021 Downgrade to OML 1. Waterbar as needed and barricade.

19N01E 0.47 0.00 0.4721 Downgrade to OML 1. Waterbar as needed. Closed by barricade on 19N01.

19N34 1.95 0.00 1.951 Decommission Remove from system. Remove culvert and associated fill as needed.

Waterbars as needed and barricade.

19N34A 0.28 0.00 0.281 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

19N34B 0.29 0.00 0.291 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

19N34C 0.08 0.00 0.081 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbar as needed and barricade.

305.100 0.57 0.00 0.57 UAR Restore Barricade.

305.101 1.08 0.00 1.08 UAR Restore Barricade.

305.101A 0.04 0.00 0.04 UAR Restore Barricade.

305.101B 0.50 0.00 0.50 UAR Restore Barricade.

305.102 0.15 0.00 0.15 UAR Restore Barricade.

305.103 0.14 0.00 0.14 UAR Restore Barricade.

305.104 0.14 0.00 0.14 UAR Restore Barricade.

305.105 0.22 0.00 0.22 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

305.106 0.21 0.00 0.21 UAR Restore Barricade.

305.107 1.25 0.00 1.25 UAR Restore Barricade.

305.108 0.06 0.00 0.06 UAR Restore Barricade.

305.109 2.43 0.00 2.43 UAR Restore Barricade.

305.109A 1.02 0.00 1.02 UAR Restore Barricade.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 59

Alternative 5

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 5 Proposed Actions

305.113 0.12 0.00 0.12 UAR Restore Barricade.

305.114 0.63 0.00 0.63 UAR Restore Waterbar or rolling dips as needed and barricade.

305.115 1.74 0.00 1.74 UAR Restore Waterbar or rolling dips as needed and barricade.

305.115A 0.18 0.00 0.18 UAR Restore Waterbar or rolling dips as needed and barricade.

305.118 0.80 0.00 0.80 UAR Restore POC Mitigation: barricade. Waterbars/rolling dips as needed.

305.119 0.22 0.00 0.22 UAR Restore Barricade.

305.120 0.04 0.00 0.04 UAR Restore Barricade.

305.121 0.63 0.00 0.63 UAR Restore Barricade.

305.121A 0.28 0.00 0.28 UAR Restore Barricade.

305.121B 1.03 0.00 1.03 UAR Restore Barricade.

305.123 0.63 0.00 0.63 UAR Restore Barricade.

305.124 1.20 0.00 1.20 UAR Restore Waterbar or rolling dips as needed and barricade.

305.125 1.44 0.00 1.44 UAR Restore Barricade. Place barricade 600' up road from NE junction with 305, before first

POC storm crossing, other barricade at milepost 1.02 from west side of 305.

305.125A 0.21 0.00 0.21 UAR Restore Barricade.

305.126 1.56 0.00 1.56 UAR Restore Barricade.

305.128 0.70 0.00 0.70 UAR Restore Barricade.

305.129 0.40 0.00 0.40 UAR Restore Barricade.

305.130 1.72 0.00 1.72 UAR Restore Barricade.

305.131 0.09 0.00 0.09 UAR Restore Barricade.

305.132 0.04 0.00 0.04 UAR Restore Barricade.

305.133 0.01 0.00 0.01 UAR Restore Barricade.

305.134 0.14 0.00 0.14 UAR Restore Barricade.

314.1 1.21 0.00 1.21 UAR Restore Barricade.

314.102 0.80 0.00 0.80 UAR Restore Barricade.

314.107 0.26 0.00 0.26 UAR Restore Barricade. Place large boulders at each entrance to pond areas.

314.108 0.06 0.00 0.06 UAR Restore Barricade.

315.100 1.68 0.00 1.68 UAR Restore Barricade.

315.102 0.48 0.00 0.48 UAR Restore Barricade.

315.103 0.26 0.00 0.26 UAR Restore Barricade.

315.104 0.82 0.00 0.82 UAR Restore Barricade.
60 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 5

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 5 Proposed Actions

315.106 0.25 0.00 0.25 UAR Restore Barricade.

315.107 0.30 0.00 0.30 UAR Restore Barricade.

315.108 0.46 0.00 0.46 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

315.109 0.50 0.00 0.50 UAR Restore Barricade.

315.110 0.07 0.00 0.07 UAR Restore Barricade.

315.111 0.03 0.00 0.03 UAR Restore Barricade.

315.2 0.51 0.00 0.51 UAR Restore Rolling dips as needed. Remove culverts at milepost 0.07, 0.13 and 0.18 to 

improve drainage. Barricade.

315.3 0.98 0.00 0.98 UAR Restore Remove all culverts. Barricade.

315.3A 0.24 0.00 0.24 UAR Restore Remove all culverts. Waterbar as needed. Closed by barricade on 315.3.

315.9A 1.22 0.00 1.22 UAR Restore Remove culverts and associated fill from stream channels. Waterbar as 

needed and barricade.

316.1 0.26 0.00 0.26 UAR2 Add to road system. OML 2. Administrative use only. Add rolling dips. POC 

Mitigation: rock/gravel length of road.

316.10 0.03 0.00 0.03 UAR Restore Barricade.

316.11 0.04 0.00 0.04 UAR Restore Barricade.

316.12 0.03 0.00 0.03 UAR Restore Barricade.

316.2 0.20 0.00 0.20 UAR Restore Barricade.

316.3 0.08 0.00 0.08 UAR Restore Barricade.

316.4 0.07 0.00 0.07 UAR Restore Barricade.

316.5 0.03 0.00 0.03 UAR Restore Barricade.

316.6 0.03 0.00 0.03 UAR Restore Barricade.

316.7 0.02 0.00 0.02 UAR Restore Barricade.

316.7A 0.02 0.00 0.02 UAR Restore Barricade.

316.8 0.05 0.00 0.05 UAR Restore Barricade. Waterbars. POC Mitigation: gravel as needed.

316.9 0.06 0.00 0.06 UAR Restore Barricade.

316.9A 0.05 0.00 0.05 UAR Restore Barricade.

324.100 0.13 0.00 0.13 UAR Restore Barricade.

405.10 0.23 0.51 0.74 UAR Restore Barricade.

405.10 0.51 0.00 0.51 UAR Motorized Trail Add to trail system. Motorized trail

. Delineate route. Route delineation at 

milepost 0.36.

405.100 0.11 0.00 0.11 UAR Restore Barricade.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 61

Alternative 5

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 5 Proposed Actions

405.101 0.17 0.00 0.17 UAR Restore Barricade.

405.103 3.47 0.00 3.47 UAR Motorized Trail Add to trail system. Motorized trail. Improve surface drainage near creek; 

repair culvert.

405.9 0.05 0.00 0.05 UAR Restore Barricade.

411.101 0.30 0.00 0.30 UAR Restore Barricade.

411.102 0.17 0.00 0.17 UAR Restore

427.101 0.15 0.00 0.15 UAR1 Add to road system. OML 1.

427.103 0.32 0.00 0.32 UAR2 Add to road system. OML 2. Delineate route.

427.104 0.30 0.00 0.30 UAR Restore Barricade.

427.105 0.29 0.00 0.29 UAR2 Add to road system. OML 2. County disposal site; may be gated 

periodically for administrative purposes.

427.106 0.13 0.00 0.13 UAR Motorized Trail Add to trail system. Motorized trail. Install rolling dips to improve drainage.

427.107 0.05 0.00 0.05 UAR2 Add as OML 2. POC Mitigation: gravel as needed.

427.108 0.09 0.00 0.09 UAR Restore Barricade.

427.108A 0.04 0.00 0.04 UAR Restore Closed by barricade on 427.108.
62 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 6

Table A-5. Alternative 6.

Alternative 6

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 6 Proposed Actions

13N35.5 0.14 0.00 0.14 UAR Restore Barricade.

13N35K 0.10 0.18 0.282 Decommission Remove from system. Barricade.

13N37 2.00 0.00 2.0021

Remove or repair road drainage features as needed to improve resource 

protection. Waterbars/rolling dips as needed and barricade. Downgrade to 

OML 1.

13N37.1 0.11 0.00 0.11 UAR Restore Barricade.

13N37A 0.77 0.00 0.772 Decommission Remove from system. Remove all culverts and associated fill. Waterbars 

as needed and barricade.

13N37B 0.27 0.00 0.272 Decommission Remove from system. Remove all culverts and associated fill. Waterbars 

as needed and barricade.

14N01 4.61 9.60 14.2133 POC Mitigation: seasonal gate closure.

14N01D 1.80 0.00 1.8022 Maintain, repair, or replace each culvert; improve surface drainage. POC 

Mitigation: seasonal gate near private property to mitigate POC risk.

14N08 0.50 0.00 0.5022 POC Mitigation: year-round gate closure.

14N08T 0.11 0.00 0.111 Decommission Remove from system. Remove all culverts and associated fill. Waterbars 

as needed and barricade.

14N15 0.50 0.00 0.5022 Maintain, repair, or replace each culvert; improve surface drainage. POC 

Mitigation: proposed seasonal gate on 14N01 restricts access.

14N15.1 3.80 0.00 3.80 UAR1 Designate as ML1. Remove or repair road drainage features as needed to 

improve resource protection. Waterbar as needed and year-round gate.

14N32.1 0.26 0.00 0.26 UAR Restore Barricade.

14N33 1.60 0.18 1.782 Decommission Remove from system. Remove culverts and associated fill from stream 

channels. Waterbars as needed and barricade.

14N33.3 0.52 0.00 0.52 UAR Restore Remove culverts and associated fill from stream channels as on 14N33. 

Waterbars as needed. Closed by barricade on 14N33.

14N33A 0.22 0.00 0.221 Decommission Remove from system. Remove all culverts and associated fill. Waterbars 

as needed and barricade.

14N38 0.40 0.00 0.4022 Improve surface drainage and maintain as OML 2. POC Mitigation: seasonal gate closure at beginning of road.

14N38 0.20 0.40 0.602 Decommission Decommission past water source. Remove culverts, 

waterbar as needed 

and barricade.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 63

Alternative 6

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 6 Proposed Actions

14N46 2.70 0.00 2.7021 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars as needed and barricade. Downgrade to OML 1.

14N46.2 0.13 0.00 0.13 UAR Restore Waterbars as needed and barricade.

14N46B 0.37 0.00 0.371 Decommission Remove from system. Waterbars as needed and barricade.

15N01.102 0.29 0.00 0.29 UAR2 Add to road system. OML 2. POC Mitigation: 

add gravel at terminus of 

road where water accumulates.

15N01.102 0.19 0.29 0.48 UAR Restore Barricade.

15N01A.1 0.10 0.00 0.10 UAR Restore Barricade.

15N01A.2 0.05 0.00 0.05 UAR Restore Barricade.

15N01A.4 3.84 0.00 3.84 UAR1 Remove or repair road drainage features as needed to improve resource 

protection. Manage as OML 1 and gate year round.

15N01P 0.09 0.79 0.881 Decommission Remove from system. Remove all culverts and associated fill. Waterbars 

as needed and barricade.

15N01Q 0.50 0.00 0.501 Motorized Trail Convert to motorized trail to Marlow Campsite.

15N01R 0.10 0.00 0.1011 Waterbars as needed and barricade.

15N01S 0.10 0.00 0.1011 Waterbars as needed and barricade.

15N01U 0.70 0.00 0.701 Decommission Remove from system. Remove all culverts and associated fill. Waterbars 

as needed and barricade.

15N01U.1 0.58 0.00 0.58 UAR Restore Barricade.

15N02 11.10 0.00 11.1022 Replace 3 priority culverts. POC Mitigation: seasonal gate near beginning 

of road.

15N02.101 0.81 0.00 0.81 UAR Motorized Trail Add to trail system. Motorized trail. Barricade at end.

15N02.103 0.58 0.00 0.58 UAR Motorized Trail Add to trail system. Motorized trail.

15N02.106 0.48 0.00 0.48 UAR Motorized Trail Add to trail system. Motorized trail.

15N02.107 0.42 0.00 0.42 UAR Motorized Trail Add to trail system. Motorized trail. Barricade at milepost 0.37, about 0.05 

miles before end of road.

15N02.108 1.14 0.00 1.14 UAR Restore Barricade.

15N02.108A 0.59 0.39 0.98 UAR Restore Barricade.

15N02.2 0.24 0.00 0.24 UAR Restore Barricade.

15N02.4 0.49 0.00 0.49 UAR Motorized Trail Add to trail system. Motorized trail. POC Mitigation: 

barricade at end of 

segment.

15N02.5 0.71 0.19 0.90 UAR Restore Waterbars/rolling dips as needed and barricade at 15N02 junction.

15N02.5 0.19 0.00 0.19 UAR Motorized Trail Add as motorized trail. Proposed barricade at the end of this segment.
64 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 6

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 6 Proposed Actions

15N02.5A 0.05 0.00 0.05 UAR Motorized Trail Add as motorized trail.

15N11.2 0.32 0.00 0.32 UAR Restore Barricade.

15N11A 1.70 0.00 1.701 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

15N11A.1 0.25 0.00 0.25 UAR Restore Remove all culverts and associated fill from stream channels. Waterbar as 

needed. Closed by barricade on 15N11A.

15N11B 1.39 0.00 1.391 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

15N13 3.80 0.00 3.8022 Improve maintenance on, repair/replace all culverts and drainage structures 

as needed. Manage as OML 2. POC Mitigation: seasonal gate closure.

15N13.100 0.49 0.62 1.11 UAR Restore Year round gate closure adjacent to private landholding.

15N13.100 0.48 1.74 2.22 UAR Restore Year round gate closure adjacent to private landholding.

15N33 0.90 0.00 0.901 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

15N35A 0.24 0.00 0.242 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

15N35B 0.57 0.00 0.571 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

15N35C 0.57 0.00 0.571 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

15N36.1 0.62 0.00 0.62 UAR Restore Remove 3 culverts and associated fill from stream channels. Waterbars as 

needed and barricade.

15N36C 0.55 0.00 0.551 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

15N36N 1.30 0.00 1.3012 Upgrade first 1.3 miles to OML 2. Maintain, repair, or replace each culvert. 

Improve surface drainage with waterbars/rolling dips as needed.

15N36N 1.30 1.30 2.601 Decommission Decommission from 1.3 to 2.6. Barricade.

15N36N.1 0.90 0.00 0.90 UAR2

Add to road system. OML 2. Access to Blackhawk Bar. Keep, maintain, 

repair or replace each culvert. Improve surface draining with waterbars 

and rolling dips as needed. POC Mitigation: add gravel at drainage 

crossings and along areas with POC.

15N36N.1A 0.15 0.00 0.15 UAR Motorized Trail Add as motorized trail.

15N36N.1B 0.21 0.00 0.21 UAR2 Add as OML 2. POC Mitigation: rock/gravel last 100'.

15N36N.1C 0.03 0.00 0.03 UAR Motorized Trail Add as motorized trail.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 65

Alternative 6

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 6 Proposed Actions

15N38 2.90 0.00 2.9022

Improve surface drainage and install culvert at stream ford on road near 

private land. POC Mitigation: barricade last 300' of road, before bottom of 

POC stand.

15N39A 1.20 0.00 1.201 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

15N39A.1 0.18 0.00 0.18 UAR Restore Barricade.

15N39B 0.50 0.00 0.501 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

15N42 1.06 0.00 1.0621 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars as needed and barricade. Downgrade to OML 1.

15N42A 0.44 0.00 0.441 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

15N45 1.13 0.00 1.1311 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars as needed and barricade.

15N45.100 0.22 0.00 0.22 UAR Restore Barricade.

15N45.101 0.12 0.00 0.12 UAR Restore Barricade.

15N63 0.30 0.00 0.3022 Manage as OML 2.

16N02.1 0.10 0.00 0.10 UAR2 Add to road system. OML 2. Bear Basin water source. Route delineation.

16N02.2 0.87 0.00 0.87 UAR Restore Barricade.

16N02.5 0.21 0.00 0.21 UAR Restore Waterbars/rolling dips as needed and barricade.

16N02D 0.61 0.00 0.612 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

16N02H 0.40 0.00 0.4011 Waterbars/rolling dips as needed.

16N02L 1.70 0.00 1.7022 Upsize culverts, install waterbars or rolling dips. POC Mitigation: current 

seasonal gate restricts access.

16N02S 1.20 0.00 1.201 Decommission Remove from system. Remove all culverts and associated fill. Waterbars 

as needed and barricade.

16N02S.1 0.21 0.00 0.21 UAR Restore Barricade.

16N02T 0.50 0.00 0.501 Decommission Remove from system. Remove all culverts and associated fill. Waterbars 

as needed and barricade.

16N02T.1 0.12 0.00 0.12 UAR Restore Barricade.

16N03.100 0.10 0.00 0.10 UAR Restore Barricade.

16N03.2 0.87 0.00 0.87 UAR Restore Remove 3 culverts and associated fill from stream channels. Waterbars as 

needed and barricade.
66 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 6

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 6 Proposed Actions

16N03A 0.06 0.00 0.061 Motorized Trail Convert to motorized trail for access to a small peak on Hurdygurdy Butte.

16N03D 1.40 0.00 1.4011 Waterbars as needed and barricade.

16N03F 0.70 0.00 0.7021 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars as needed and barricade. Downgrade to OML 1.

16N03G 0.08 0.00 0.081 Decommission Remove from system. Waterbar landing as needed and barricade.

16N03H 0.30 0.00 0.302 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

16N03K 1.50 0.00 1.5022 Repair culverts at milepost 1.08 and 1.14. POC Mitigation: current 

seasonal gate restricts access.

16N03L 0.20 0.00 0.201 Decommission Remove from system. Remove all culverts and associated fill. Waterbars 

as needed and barricade.

16N10.1 0.14 0.00 0.14 UAR Restore Barricade.

16N10.2 0.21 0.00 0.21 UAR Restore Closed by network to motorized access, extends off non-motorized trail.

16N15A 0.17 0.00 0.172 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

16N16 1.50 0.00 1.5022 Repair or replace plugged culverts.

16N16 0.60 1.50 2.1021 Downgrade to OML 1. Remove or repair road drainage features as needed 

to improve resource protection. Waterbars as needed and barricade.

16N18.1 1.04 0.00 1.04 UAR Restore Barricade.

16N18.3 0.49 0.00 0.49 UAR Restore Barricade.

16N18.4 0.67 0.00 0.67 UAR Restore Barricade.

16N18A 1.35 0.00 1.3522 Repair or replace 8 culverts on section up to milepost 1.35 at bridge. POC 

Mitigation: seasonal gate closure at beginning.

16N18A 0.95 1.35 2.302 Decommission Remove 5 culverts and decommission. Waterbars as needed and barricade.

16N18B.1 0.66 0.00 0.66 UAR Restore Barricade.

16N18C 0.39 0.00 0.391 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

16N18E 0.96 0.00 0.962 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

16N18K 1.10 0.00 1.1011 Waterbars/rolling dips as needed.

16N19 8.28 0.00 8.2822

Improve maintenance on, repair, or replace each of the 17 culverts. 

Reinforce creek crossings and sections of road with POC 0.29 to 0.46 

miles west of 16N19E intersection as needed.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 67

Alternative 6

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 6 Proposed Actions

16N19.1 0.05 0.00 0.05 UAR2 Add as OML 2; water source

. POC Mitigation: rock/gravel entire route as 

needed.

16N19.2 0.08 0.00 0.08 UAR2 Add as OML 2 for access to Coon Creek. POC Mitigation: rock/gravel 

entire route as needed.

16N19.3 0.30 0.00 0.30 UAR Restore Barricade.

16N19.4 0.87 0.00 0.87 UAR Restore Barricade.

16N19.5 0.19 0.00 0.19 UAR Restore Remove fill from culvert. Waterbars as needed and barricade.

16N19A 0.23 0.00 0.232 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

16N19B 1.40 0.00 1.4021 Waterbars as needed and barricade. Downgrade to OML 1.

16N19E 0.95 0.00 0.9521 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars as needed and barricade. Downgrade to OML 1.

16N19E.1 0.41 0.00 0.41 UAR Restore Barricade.

16N19F 0.76 0.00 0.762 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

16N19G 0.23 0.00 0.232 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

16N21.1 0.15 0.00 0.15 UAR Restore Waterbars/rolling dips as needed and barricade.

16N21.2 0.10 0.00 0.10 UAR Restore Barricade.

16N21F.1 0.09 0.00 0.09 UAR Restore Barricade.

16N23 7.40 0.00 7.4022 Improve road drainage at all culverts. POC Mitigation: seasonal gate 

closure and add gravel in areas with POC within 50' of road.

16N23.100 0.64 0.00 0.64 UAR Motorized Trail Add to trail system. Motorized trail.

16N23.2 0.22 0.00 0.22 UAR Motorized Trail Add to trail system. Motorized trail. POC Mitigation: gravel and rock route 

as needed.

16N23.4 0.69 0.00 0.69 UAR Motorized Trail Add to trail system. Motorized trail.

16N23A.1 1.90 0.00 1.90 UAR Motorized Trail Add to trail system. Motorized trail.

16N24A 0.65 0.00 0.651 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

16N27 0.50 0.00 0.501 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

16N30 0.24 0.00 0.241 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

16N31A.1 0.22 0.00 0.22 UAR Restore Barricade.
68 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 6

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 6 Proposed Actions

16N31B.2 0.13 0.00 0.13 UAR Restore Barricade.

16N32 3.12 0.82 3.9422 Improve maintenance, repair, or replace each of the 16 culverts. POC 

Mitigation: current seasonal gate restricts access.

16N32A 0.08 0.00 0.081 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

16N32C 0.47 0.00 0.471 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

16N33 0.70 0.00 0.7022 POC Mitigation: seasonal gate closure. Rock/gravel POC crossing as 

needed.

16N33 3.70 0.70 4.4011 Barricade.

16N34 0.60 0.00 0.6022 Add culvert at milepost0.34.

16N34 0.30 0.60 0.9021 Downgrade to OML 1. Remove last culvert at milepost

0.9 switchback. 

POC Mitigation: barricade.

16N34A 0.50 0.00 0.5021 Waterbars as needed and barricade. Downgrade to OML 1.

16N35A 0.14 0.00 0.141 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

16N35C 0.12 0.00 0.122 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

16N36 1.20 0.00 1.2022 Improve maintenance, repair, or replace each of the culverts.

16N36.1 0.11 0.69 0.80 UAR Restore Barricade.

16N36.1 0.69 0.00 0.69 UAR2 Add as OML 2. Repair or replace culverts.

16N36B 0.82 0.00 0.8222 Clean blocked culverts and install 2 additional culverts.

16N37 1.20 0.00 1.2022 Improve maintenance, repair, or replace each of the 6 culverts. POC 

Mitigation: reinforce POC crossing with gravel and install culvert.

16N37B 0.17 0.00 0.172 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

16N38 1.32 0.28 1.6022 POC Mitigation: 

reinforce POC crossing with gravel, about 170' west of 

16N21 junction.

16N39A 0.22 0.00 0.221 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

16N41 1.43 0.00 1.4322 Replace culvert at milepost 0.56. POC Mitigation: 

reinforce POC crossing 

with gravel and install culvert, about 200' east of 16N37 junction.

16N41A 0.17 0.00 0.172 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 69

Alternative 6

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 6 Proposed Actions

16N41B 0.09 0.00 0.092 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

16N55 0.50 0.00 0.5012 Upgrade to OML 2.

16N55.1 0.16 0.00 0.16 UAR Restore Barricade.

17N01 0.70 0.00 0.7022 POC Mitigation: rock/gravel road as needed.

17N01.1 0.21 0.00 0.21 UAR2 Add to road system. OML 2. POC Mitigation: rock/gravel length of road as 

needed.

17N01.100 2.49 0.00 2.49 UAR Restore Remove all culverts and associated fill from stream channels. Waterbar as 

needed and Barricade.

17N01.1A 0.02 0.00 0.02 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel route as needed.

17N01.1B 0.03 0.00 0.03 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel route as needed.

17N01.1C 0.09 0.00 0.09 UAR Restore Barricade. Waterbar as needed.

17N01.1D 0.13 0.00 0.13 UAR Restore Barricade.

17N01.2 0.30 0.00 0.30 UAR2 Add as OML 2. POC Mitigation: rock/gravel entire route as needed.

17N01.2B 0.03 0.00 0.03 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel entire route as needed.

17N01.3 0.13 0.00 0.13 UAR Motorized Trail Add as motorized trail. Rolling dips as needed. POC Mitigation: 

rock/gravel route as needed.

17N01.3A 0.07 0.00 0.07 UAR Restore Barricade.

17N03 1.20 0.00 1.2011 Waterbars as needed and barricade.

17N04.1 0.12 0.00 0.12 UAR Restore Barricade.

17N04.2 0.05 0.00 0.05 UAR Restore Barricade.

17N04.3 0.97 0.00 0.97 UAR Restore Remove culvert and associated fill. Waterbars/rolling dips as needed and 

barricade.

17N04S 1.80 0.00 1.801 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N05.100 0.88 0.00 0.88 UAR Restore Barricade.

17N05.101 0.06 0.00 0.06 UAR Restore Barricade.

17N05.4 0.32 0.00 0.32 UAR Restore Barricade.

17N05.4A 1.36 0.00 1.36 UAR Restore Waterbars/rolling dips as needed and barricade.

17N05.5 0.14 0.00 0.14 UAR Restore Waterbars/rolling dips as needed and barricade.

17N05C 0.97 0.00 0.971 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N05E 0.71 0.00 0.7111 Barricade.
70 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 6

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 6 Proposed Actions

17N05G 0.67 0.00 0.671 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N05U 0.28 0.00 0.281 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N07 10.39 0.00 10.3932 Downgrade to OML 2. POC Mitigation: rock/gravel as needed at wet 

areas, draws and areas with POC.

17N07.1 0.25 0.00 0.25 UAR Restore Waterbars/rolling dips as needed and barricade.

17N07.101 0.09 0.00 0.09 UAR Restore Barricade.

17N07.102 3.07 0.00 3.07 UAR Restore Road not stable; failing. Remove all culverts and associated fill from 

stream channels. Waterbar as needed and barricade.

17N07.2 0.51 0.00 0.51 UAR Restore Waterbars/rolling dips as needed and barricade.

17N07.4 0.21 0.00 0.21 UAR Restore Waterbars/rolling dips as needed. Barricade.

17N07.5 0.32 0.00 0.32 UAR Restore Barricade.

17N07.5A 0.15 0.00 0.15 UAR Restore Barricade.

17N07.6 0.75 0.00 0.75 UAR Restore Barricade.

17N07.7 0.30 0.00 0.30 UAR Restore Barricade.

17N07G 1.62 0.00 1.6222 POC Mitigation: rock/gravel from milepost 0.2 to approx. 0.22 stretch as 

needed.

17N07J 1.64 0.00 1.6422 Repair culvert at milepost 1.25. POC Mitigation: rock/gravel as needed at 

wet areas, draws and areas with POC.

17N07K 0.80 0.00 0.8021 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars as needed and barricade. Downgrade to OML 1.

17N07Q 0.22 0.00 0.222 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N07R 0.44 0.00 0.442 Decommission Remove from system. Remove culvert and associated fill. Barricade.

17N07R.1 0.16 0.00 0.16 UAR Restore Barricade.

17N07R.1A 0.25 0.00 0.25 UAR Restore Barricade.

17N08.3 0.30 0.00 0.30 UAR Restore Barricade.

17N08A 0.50 0.00 0.501 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N13 0.70 0.00 0.7021 POC Mitigation: 

downgrade to OML 1. Barricade. Remove or repair road 

drainage features as needed to improve resource protection.

17N13A 0.38 0.00 0.3821 Waterbars as needed and barricade. Downgrade to OML 1.

17N14 0.33 0.00 0.3322 POC Mitigation: rock/gravel approx. milepost 0.14 to 0.16.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 71

Alternative 6

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 6 Proposed Actions

17N15 0.90 0.00 0.9021 Waterbars as needed and barricade. Downgrade to OML 1.

17N15A 0.13 0.00 0.131 Decommission Remove from system. Waterbars as needed and barricade.

17N16 0.65 0.00 0.6521 Waterbars as needed and barricade. Downgrade to OML 1.

17N16.1 0.17 0.00 0.17 UAR Restore Barricade.

17N16.100 0.07 0.00 0.07 UAR Restore Waterbars/rolling dips as needed and barricade.

17N17 0.60 0.00 0.601 Decommission Remove from system. Remove culvert and associated fill from stream 

channel. Waterbars as needed and barricade.

17N17.1 1.98 0.00 1.98 UAR Restore Closed by barricade on 17N17.

17N18.2 0.39 0.00 0.39 UAR Restore Remove 2 culverts and associated fill from stream channels. Waterbars as 

needed and barricade.

17N18.3 0.74 0.00 0.74 UAR Restore Barricade.

17N18.4 0.15 0.00 0.15 UAR Restore Barricade.

17N18A 0.94 0.00 0.9412 Upgrade to OML 2.

17N18C 0.67 0.00 0.6722 Improve maintenance, repair, or replace each of the 3 culverts. POC 

Mitigation: rock/gravel entire length of road as needed, infested POC.

17N18E 0.42 0.00 0.421 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N18F 0.07 0.00 0.071 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N20 0.19 0.00 0.1922 Improve maintenance, repair, or replace each of the 3 culverts.

17N21.1 0.41 0.00 0.41 UAR Restore Waterbars/rolling dips as needed and barricade.

17N22A 0.79 0.00 0.7922 Improve maintenance on, repair, or replace culvert at milepost 0.7.

17N22A.1 0.21 0.00 0.21 UAR Restore Waterbars/rolling dips as needed and barricade.

17N22A.2 0.25 0.00 0.25 UAR Restore Barricade.

17N22D 0.08 0.00 0.082 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N22J 0.12 0.00 0.1222 Waterbars/rolling dips as needed.

17N22W.1 0.46 0.00 0.46 UAR Restore Rolling dips as needed. SUP road, do not barricade.

17N23 1.30 1.50 2.801 Decommission Remove from system.Remove culverts, waterbars as needed and barricade.

17N23 1.15 0.35 1.501 Decommission Remove from system.

17N23C.1 1.04 0.05 1.09 UAR1 Add to road system. OML 1.

17N23C.1 1.15 1.09 2.24 UAR1 Add to road system. OML 1.
72 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 6

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 6 Proposed Actions

17N23C.1 0.05 0.00 0.05 UAR1 Add to road system. OML 1. Barricade.

17N23C.2 0.59 0.00 0.59 UAR1 Add to road system. OML 1. Closed by barricade on 17N23C.1.

17N26 0.25 0.00 0.2522 POC Mitigation: rock/gravel entire length of road as needed, infested POC.

17N26A 0.37 0.00 0.3722 POC Mitigation: rock/gravel entire length of road as needed.

17N27A.1 0.21 0.00 0.21 UAR Restore Closed by barricade on 17N27A.

17N27B 0.40 0.00 0.401 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N27C 0.40 0.00 0.401 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N27D.1 0.36 0.00 0.36 UAR Restore Waterbars/rolling dips as needed and barricade.

17N28 0.20 0.00 0.201 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N29 1.00 0.00 1.0022 Pull fill back from landing. Proposed seasonal gate on network.

17N29.100 0.04 0.00 0.04 UAR Restore Barricade.

17N29B 0.20 0.00 0.202 Decommission

Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade. Proposed seasonal gate on 

network.

17N30 0.89 0.00 0.8921 Remove or repair road drainage features as needed to improve resource protection. Waterbars as needed. Downgrade to OML 1. Barricade.

17N30 0.55 0.89 1.442 Decommission Remove from system. Waterbars as needed. Closed by barricade on first 

segment of 17N30 that is OML 1.

17N30A 0.40 0.00 0.4021 Downgrade to OML 1. Closed by barricade on 17N30 that is OML 1.

17N31 1.60 0.00 1.6021 Waterbars as needed and barricade. Downgrade to OML 1.

17N31.3 0.17 0.00 0.17 UAR Restore Barricade.

17N31A.1 0.36 0.00 0.36 UAR Restore Barricade.

17N32 3.40 0.00 3.4022 POC Mitigation: 

seasonal gate closure. Rock/gravel POC crossing as 

needed.

17N32.1 0.31 0.00 0.31 UAR Restore Barricade.

17N32.2 0.17 0.00 0.17 UAR Restore Barricade.

17N32B 0.80 0.00 0.802 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N32F 1.00 0.00 1.002 Decommission

Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade. Proposed seasonal gate on 

network.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 73

Alternative 6

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 6 Proposed Actions

17N32G 1.20 0.00 1.2022 Improve maintenance, repair, or replace culverts. Proposed seasonal gate 

on network.

17N35 0.50 0.00 0.502 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N35.100 0.35 0.00 0.35 UAR Restore Barricade.

17N36 2.50 0.00 2.5022 Improve maintenance, repair, or replace each of the 14 culverts. POC 

Mitigation: seasonal gate near beginning, just off 17N04.

17N36B.1 0.26 0.00 0.26 UAR Restore Barricade.

17N36C 0.43 0.00 0.431 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N36F 1.20 0.00 1.2012 Upgrade to OML 2.

17N39 2.19 0.00 2.1922

Improve maintenance, repair, or replace each of the 25 culverts. POC 

Mitigation: rock/gravel stretch with infected POC as needed, from junction 

with 411 to approx. milepost 0.65.

17N39A 0.95 0.00 0.951 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N39B 0.51 0.00 0.511 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N39C 0.12 0.00 0.121 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N40 0.35 0.65 1.0021 Waterbars as needed, barricade, and downgrade to OML 1.

17N40 0.65 0.00 0.6522 POC Mitigation: seasonal gate closure.

17N40B 0.53 0.00 0.5321 Waterbars as needed and barricade. Downgrade to OML 1.

17N40B.1 0.19 0.00 0.19 UAR Restore Barricade.

17N40C.1 0.20 0.00 0.20 UAR Restore Barricade.

17N40D 0.18 0.00 0.181 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N41 4.25 0.00 4.2522

Improve maintenance on, repair, or replace/upgrade each of the 13 

culverts and waterbars as needed. POC Mitigation: rock/gravel stretch 

with infected POC, from junction with 411 to approx. milepost 1.05.

17N41.1 0.74 0.00 0.74 UAR Restore Barricade.

17N41.2 0.02 0.00 0.02 UAR Restore Barricade.

17N41A 0.35 0.00 0.3511 Barricade.

17N41G.1 0.17 0.00 0.17 UAR Restore Waterbars/rolling dips as needed and barricade.
74 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 6

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 6 Proposed Actions

17N41H 0.90 0.00 0.9022 POC Mitigation: rock/gravel stretch approximately first 0.25 mile as needed.

17N41H.100 0.06 0.00 0.06 UAR Restore Barricade.

17N42A.100 0.48 0.00 0.48 UAR Restore Barricade.

17N43 1.00 0.00 1.0022 POC Mitigation: rock/gravel stretch approx. milepost 0.47 to 0.68 as needed.

17N43.1 0.04 0.00 0.04 UAR Restore Barricade.

17N46 1.22 0.00 1.2222 POC Mitigation: seasonal gate on 17N40 closes access to this route.

17N46A 0.16 0.00 0.161 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N48 1.66 0.00 1.6622 POC Mitigation: rock/gravel entire length of road as needed.

17N48.1 0.33 0.00 0.33 UAR Restore Barricade.

17N48.3 0.16 0.00 0.16 UAR Restore Waterbars/rolling dips as needed and barricade.

17N48.4 0.46 0.00 0.46 UAR Restore Waterbars/rolling dips as needed and barricade.

17N48C 0.47 0.00 0.471 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

17N49 1.75 2.96 4.7132 Downgrade to OML 2. POC Mitigation: rock/gravel as needed stretch with 

infected POC, approx. milepost 3.8, just north of 17N49.101 junction, for 100'.

17N49 0.90 5.15 6.0532 Downgrade to OML 2.

17N49 0.44 4.71 5.1532 Downgrade to OML 2.

17N49 1.80 6.05 7.8532 Downgrade to OML 2.

17N49.1 0.04 0.00 0.04 UAR Restore Barricade.

17N49.100 0.12 0.00 0.12 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.100 3.88 0.12 4.00 UAR Restore Barricade.

17N49.100A 0.21 0.00 0.21 UAR Restore Barricade.

17N49.101 1.17 0.00 1.17 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.102 0.87 0.00 0.87 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.102A 0.71 0.00 0.71 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.102B 0.17 0.00 0.17 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.102C 0.20 0.00 0.20 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.103 0.26 0.00 0.26 UAR Restore Waterbars/rolling dips as needed and barricade.

17N49.104 3.82 0.00 3.82 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.104 0.86 3.82 4.68 UAR Restore Barricade.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 75

Alternative 6

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 6 Proposed Actions

17N49.104A 0.05 0.00 0.05 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.104B 0.08 0.00 0.08 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.105 1.43 0.00 1.43 UAR Restore Barricade.

17N49.105A 0.12 0.00 0.12 UAR Restore Barricade.

17N49.106 0.32 0.00 0.32 UAR Restore Barricade.

17N49.107 0.64 0.00 0.64 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.108 0.31 0.00 0.31 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.11 1.94 0.00 1.94 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.11 2.55 1.94 4.49 UAR Motorized Trail

Add to trail system. Motorized trail. Delineate route. POC Mitigation: 

seasonal gate closure, gate mid-slope of 17N49.11, near long 124.0119W 

and lat 41.88593.

17N49.11M 0.17 0.00 0.17 UAR Restore Barricade.

17N49.11N 0.23 0.00 0.23 UAR Restore Barricade.

17N49.11P 0.18 0.00 0.18 UAR Motorized Trail Add to trail system. Motorized 

trail. Delineate route. POC Mitigation: 

proposed seasonal gates on 17N49.11 and 17N49.7, restrict access.

17N49.11P 0.03 0.18 0.21 UAR Restore Barricade.

17N49.12 2.10 0.00 2.10 UAR Restore Barricade.

17N49.13 0.30 0.00 0.30 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.14 0.54 0.00 0.54 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.15 0.62 0.00 0.62 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.15A 0.24 0.00 0.24 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.2 0.20 0.00 0.20 UAR Restore Barricade.

17N49.3 0.23 0.00 0.23 UAR Restore Barricade.

17N49.4 1.29 0.00 1.29 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.4 0.75 1.29 2.04 UAR Motorized Trail Add to trail system. Motorized 

trail. Delineate route. POC Mitigation: 

seasonal gate closure, just to east of 17N49.102.

17N49.4A 1.06 0.00 1.06 UAR Restore Year-round gate.

17N49.7 2.15 0.91 3.06 UAR Motorized Trail

Add to trail system. Motorized trail. Repair road drainage at spring area 

and two culverts. Delineate route. POC Mitigation: install seasonal gate 

north of junction with 17N49.15.

17N49.7 0.29 3.06 3.35 UAR Restore Barricade.

17N49.7 0.91 0.00 0.91 UAR Motorized Trail Add to trail system. Motorized 

trail. Repair road drainage at spring area 

and two culverts. Delineate route and gravel areas with POC.
76 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 6

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 6 Proposed Actions

17N49.7A 0.82 0.00 0.82 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N49.8 0.39 0.00 0.39 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

17N63 0.30 0.00 0.3022 POC Mitigation: rock/gravel entire length of road as needed.

17N85 1.20 0.00 1.20 UAR1 Add as OML 1. Remove or repair road drainage features to improve 

resource protection. POC Mitigation: barricade.

18N01 0.10 0.00 0.1022 Maintain as OML 2

18N01 0.06 0.10 0.162 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N02 1.75 0.00 1.7533 POC Mitigation: 

rock/gravel segment 100' either side of Sanger Lake 

outlet as needed.

18N02 0.85 1.75 2.6033 POC Mitigation: install seasonal gate closure.

18N02.1 0.14 0.00 0.14 UAR Restore Barricade.

18N02.2 0.08 0.00 0.08 UAR Motorized Trail Add as motorized trail.

18N02.3 0.02 0.00 0.02 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel length of route as 

needed.

18N03 1.91 0.00 1.911 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N04.2 0.11 0.00 0.11 UAR Restore Barricade.

18N04E 0.21 0.65 0.862 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar or rolling dips as needed and barricade.

18N05.1 0.20 0.00 0.20 UAR Restore Remove culverts and associated fill from stream channels. Waterbars as 

needed. Closed by barricade on 18N05.100.

18N05.100 2.16 0.00 2.16 UAR Restore Remove culverts and associated fill from stream channels. Waterbars as 

needed. POC Mitigation: barricade.

18N05.2 0.53 0.00 0.53 UAR Restore Remove culverts and associated fill from stream channels. Waterbars and 

barricade as needed.

18N06A 0.18 0.00 0.181 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N07 0.05 0.00 0.0533 Bridge repair/replacement.

18N07.11 0.06 0.00 0.06 UAR Restore Barricade.

18N07.12 0.04 0.00 0.04 UAR Motorized Trail Add as motorized trail.

18N07.14 0.05 0.00 0.05 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel route as needed.

18N07.2 0.13 0.00 0.13 UAR2 Add as OML 2

18N07.3 0.08 0.00 0.08 UAR Restore POC Mitigation: barricade.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 77

Alternative 6

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 6 Proposed Actions

18N07.6 0.25 0.00 0.25 UAR Restore Remove culverts and associated fill from stream channels. Waterbars as 

needed. Barricade.

18N07.8 0.38 0.00 0.38 UAR Restore Remove culverts and associated fill from stream channels. Waterbars as 

needed. POC Mitigation: barricade.

18N08.2 0.03 0.00 0.03 UAR2 Add to road system. OML 2

18N08F 0.90 0.90 1.8021

POC Mitigation: downgrade to OML 1. Remove or repair road drainage 

features as needed to improve resource protection. Waterbars as needed 

and barricade.

18N08G 1.12 0.00 1.121 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N09 5.10 0.00 5.1022 POC Mitigation: seasonal gate closure at beginning of road.

18N09.100 0.21 0.00 0.21 UAR Motorized Trail Add as motorized trail

. Route delineation at site, POC Mitigation: seasonal 

gate on 18N09 closes access to this route.

18N09.100 0.06 0.21 0.27 UAR Restore Waterbars/rolling dips as needed and barricade at 18N09.

18N09.100A 0.16 0.00 0.16 UAR Restore Waterbars/rolling dips as needed and barricade.

18N09.101 0.16 0.00 0.16 UAR Motorized Trail Add as motorized trail. POC Mitigation: gravel last 100' of route.

18N09.102 1.84 0.00 1.84 UAR Restore Waterbars/rolling dips as needed and barricade.

18N09.103 0.04 0.00 0.04 UAR Restore Waterbars/rolling dips as needed and barricade.

18N09.104 0.05 0.00 0.05 UAR Restore Waterbars/rolling dips as needed and barricade.

18N09.105 0.12 0.00 0.12 UAR Restore Waterbars/rolling dips as needed and barricade.

18N09.106 0.02 0.00 0.02 UAR Motorized Trail Add as motorized trail.

18N09.107 0.01 0.00 0.01 UAR Motorized Trail Add as motorized trail.

18N09.108 0.03 0.00 0.03 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel route as needed.

18N10.1 0.70 0.00 0.70 UAR Restore Barricade.

18N11 1.92 4.15 6.0722 Replace culvert at milepost 5.78.

18N11A 0.80 0.00 0.801 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N11B 0.19 0.00 0.191 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N11C 0.20 0.00 0.201 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N11D 0.46 0.00 0.461 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N11D.1 1.75 0.00 1.75 UAR Restore Closed by barricade on 18N11D.
78 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 6

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 6 Proposed Actions

18N11D.2 0.25 0.00 0.25 UAR Restore Remove culverts and associated fill from stream channels. Waterbars as 

needed. Closed by barricade on 18N11D.

18N11D.3 0.29 0.00 0.29 UAR Restore Remove culverts and associated fill from stream channels. Waterbars as 

needed. Closed by barricade on 18N11D.

18N11D.4A 0.73 0.00 0.73 UAR Restore Barricade.

18N11D.5 2.11 0.00 2.11 UAR Restore Remove culverts and fill from stream channels. Waterbars as needed. 

POC Mitigation: barricade.

18N12A 0.43 0.00 0.431 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N13.100 0.21 0.00 0.21 UAR Restore Barricade.

18N13.101 0.08 0.00 0.08 UAR Restore Closed by barricade on 18N13.

18N15 1.20 0.00 1.2022 Resource 

risk mitigation: Delineate route near milepost0.01. Upsize 

culverts, install waterbars or rolling dips.

18N15D 0.23 0.00 0.232 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N16 5.33 0.00 5.3322 POC Mitigation: rock/gravel first 0.28 miles as needed.

18N16.100 2.60 0.00 2.60 UAR Restore Barricade.

18N16E 0.38 0.00 0.381 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N16F.1 0.16 0.00 0.16 UAR Restore Barricade.

18N16W 0.17 0.00 0.172 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N17 8.10 0.00 8.1022 Improve maintenance on, repair, or replace/upgrade each of the 19 

culverts and waterbars as needed. POC Mitigation: current seasonal gate.

18N17.100 1.01 0.00 1.01 UAR Restore Barricade.

18N17.100A 0.08 0.00 0.08 UAR Restore Barricade.

18N17.101 0.05 0.00 0.05 UAR Restore Closed by barricade on 18N17.

18N17.102 0.06 0.00 0.06 UAR Restore Closed by barricade on 18N17.

18N17.103 0.21 0.00 0.21 UAR Restore Barricade.

18N17.104 0.20 0.00 0.20 UAR Restore Barricade.

18N17.104A 0.20 0.00 0.20 UAR Restore Closed by barricade on 18N17.

18N17B 0.87 0.00 0.8722 Install culvert at milepost 0.5. POC Mitigation: seasonal gate closure on 

18N17.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 79

Alternative 6

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 6 Proposed Actions

18N17C 1.18 0.00 1.1822

Replace culverts at milepost 0.35 and 0.77; and maintain, repair or 

upgrade remaining 4 culverts and improve surface drainage. POC 

Mitigation: existing seasonal gate on 18N17 restricts access.

18N17C.1 0.05 0.00 0.05 UAR Restore Barricade.

18N17G 0.12 0.00 0.122 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N17H 0.15 0.00 0.152 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N18A 0.20 0.00 0.201 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N18B 0.15 0.00 0.151 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N18C 0.08 0.00 0.081 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N18D 0.13 0.00 0.131 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N19A 0.22 0.00 0.221 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N19B 0.20 0.00 0.201 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N19C 0.17 0.00 0.171 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N20 1.00 0.00 1.0021 Downgrade to OML 1. Remove or repair road drainage features as 

needed to improve resource protection. Waterbar as needed and gate.

18N20.100 0.28 0.00 0.28 UAR Restore Barricade.

18N20.100A 0.08 0.00 0.08 UAR Restore Remove culverts and associated fill from stream channels. Waterbars as 

needed. Closed by barricade on 18N20.

18N20.101 0.12 0.00 0.12 UAR Restore Barricade.

18N20.102 0.47 0.00 0.47 UAR Restore Remove culverts and associated fill. Waterbars as needed. Closed by 

barricade on 18N20.

18N20A 0.40 0.00 0.402 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N22 2.00 0.00 2.0021

Remove or repair road drainage features as needed to improve resource 

protection. Waterbars/rolling dips as needed and barricade. Downgrade to 

OML 1.
80 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 6

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 6 Proposed Actions

18N22D 0.62 0.00 0.622 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N22E 0.14 0.00 0.142 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N23 0.10 0.00 0.101 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N24 1.10 0.00 1.1011 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars/rolling dips as needed and barricade.

18N26 1.75 0.00 1.7511 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars/rolling dips as needed and barricade.

18N26A 0.15 0.00 0.1511 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars/rolling dips as needed and barricade.

18N26A.2 0.06 0.00 0.06 UAR Restore Closed by barricade on 18N26A.

18N26B 0.08 0.00 0.0811 Remove or repair road drainage features as needed to improve resource 

protection. Waterbars/rolling dips as needed and barricade.

18N30.100 0.04 0.00 0.04 UAR Restore Barricade.

18N30A 0.28 0.00 0.281 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N30B 0.46 0.00 0.461 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N31 0.60 0.00 0.601 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N31.1 0.16 0.00 0.16 UAR Restore Closed by barricade on 18N31.

18N31.2 0.23 0.00 0.23 UAR Restore Waterbars/rolling dips as needed and barricade.

18N31.3C 0.18 0.00 0.18 UAR Restore Waterbars/rolling dips as needed and barricade.

18N31.4 1.25 0.00 1.25 UAR Restore Waterbars/rolling dips as needed and barricade.

18N46 0.39 0.00 0.392 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N47 0.44 0.00 0.441 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N48 0.31 0.00 0.311 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N51 0.27 0.00 0.2712 Upgrade to OML 2.

18N51.100 1.45 0.00 1.45 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

18N51.100A 0.46 0.00 0.46 UAR Restore Barricade.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 81

Alternative 6

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 6 Proposed Actions

18N56 0.88 0.00 0.8822 Replace culverts; install rolling dips as needed. POC Mitigation: 

rock/gravel 

100' either side of infected creek crossing near milepost 0.15 as needed.

18N56.100 0.04 0.00 0.04 UAR Restore Barricade.

18N57 0.56 0.00 0.561 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

18N58.1 0.13 0.00 0.13 UAR Restore Barricade.

18N58B 0.25 0.00 0.251 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

199.102 0.13 0.00 0.13 UAR2 Add to road system. OML 2.

199.103 0.10 0.00 0.10 UAR3 Add to road system. OML 3, Griffin Bridge. POC Mitigation: 

rock/gravel 

entire route of infected POC as needed.

199.104 0.11 0.00 0.11 UAR3 Add to road system. OML 3, Madrona Campground. POC Mitigation: rock/gravel entire route of infected POC as needed.

199.105 0.03 0.00 0.03 UAR3 Add to road system. OML 3, Darlingtonia Trail head access.

199.106 0.18 0.00 0.18 UAR3 Add to road system. OML 3, Eighteen

-mile river access site. POC 

Mitigation: rock/gravel entire route of infected POC as needed.

199.107 0.10 0.00 0.10 UAR Restore Barricade.

199.108 0.24 0.00 0.24 UAR Restore Barricade.

199.109 0.10 0.00 0.10 UAR Restore Barricade to allow parking at turnout and hiking access to river.

199.111 0.07 0.02 0.09 UAR Restore Barricade.

199.111 0.02 0.00 0.02 UAR2 Add to road system. Add road to creek as OML 2. POC Mitigation: rock/gravel entire route of infected POC as needed.

199.111A 0.07 0.00 0.07 UAR Restore Closed by barricade on 199.111.

199.112 0.29 0.00 0.29 UAR Restore Barricade.

199.113 0.07 0.00 0.07 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel route as needed.

19N34 1.95 0.00 1.951 Decommission Remove from system. Remove culvert and associated fill as needed. 

Waterbars as needed and barricade.

19N34A 0.28 0.00 0.281 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

19N34B 0.29 0.00 0.291 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

19N34C 0.08 0.00 0.081 Decommission Remove from system. Remove culverts and associated fill from stream 

channel. Waterbar as needed and barricade.

305.100 0.57 0.00 0.57 UAR Restore Barricade.
82 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 6

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 6 Proposed Actions

305.101 1.08 0.00 1.08 UAR Restore Barricade.

305.101A 0.04 0.00 0.04 UAR Restore Barricade.

305.101B 0.50 0.00 0.50 UAR Restore Barricade.

305.102 0.15 0.00 0.15 UAR Restore Barricade.

305.103 0.14 0.00 0.14 UAR Restore Barricade.

305.104 0.14 0.00 0.14 UAR Restore Barricade.

305.105 0.22 0.00 0.22 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

305.106 0.21 0.00 0.21 UAR Restore Barricade.

305.107 1.25 0.00 1.25 UAR Restore Barricade.

305.108 0.06 0.00 0.06 UAR Restore Barricade.

305.109 2.43 0.00 2.43 UAR Motorized Trail Add to trail system. Motorized trail. POC Mitigation: 

at seepy crossing with 

POC, install culvert and add gravel. Route delineation.

305.109A 1.02 0.00 1.02 UAR Restore Barricade.

305.113 0.12 0.00 0.12 UAR Restore Barricade.

305.114 0.63 0.00 0.63 UAR Restore Waterbars/rolling dips as needed and barricade.

305.115 1.74 0.00 1.74 UAR Restore Waterbars/rolling dips as needed and barricade.

305.115A 0.18 0.00 0.18 UAR Restore Waterbars/rolling dips as needed and barricade.

305.118 0.80 0.00 0.80 UAR Motorized Trail

Add to trail system. Motorized trail. POC Mitigation: seasonal closure 

required at beginning of route. Gate mid-Oct to early June; need culvert in 

at POC site. Barricade end of route. Route delineation.

305.118 0.76 0.80 1.56 UAR Restore Waterbars/rolling dips as needed. POC Mitigation: barricade.

305.119 0.22 0.00 0.22 UAR Restore Barricade.

305.120 0.04 0.00 0.04 UAR Restore Barricade.

305.121 0.63 0.00 0.63 UAR Restore Barricade.

305.121A 0.28 0.00 0.28 UAR Restore Barricade.

305.121B 1.03 0.00 1.03 UAR Motorized Trail Add to trail system. Motorized 

trail. Delineate route. POC Mitigation: 

barricade just before creek, near milepost 1.02.

305.123 0.63 0.00 0.63 UAR Restore Barricade.

305.124 1.20 0.00 1.20 UAR Restore Waterbars/rolling dips as needed and barricade.

305.125 1.44 0.00 1.44 UAR Motorized Trail Add to trail system. Motorized 

trail. Delineate route. POC Mitigation: 

seasonal gate closure, gate at both ends.

305.125A 0.21 0.00 0.21 UAR Restore Barricade.
Appendix A. Alternative Tables

Final Environmental Impact Statement – Appendices – 83

Alternative 6

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 6 Proposed Actions

305.126 1.56 0.00 1.56 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

305.128 0.70 0.00 0.70 UAR Restore Barricade.

305.129 0.40 0.00 0.40 UAR Restore Barricade.

305.130 1.72 0.00 1.72 UAR Restore Barricade.

305.131 0.09 0.00 0.09 UAR Restore Barricade.

305.132 0.04 0.00 0.04 UAR Motorized Trail Designate as motorized trail.

305.133 0.01 0.00 0.01 UAR Motorized Trail Add as motorized trail.

305.134 0.13 0.00 0.13 UAR Restore Barricade.

314.1 1.21 0.00 1.21 UAR Motorized Trail Add to trail system. Motorized trail. POC Mitigation: 

barricade at milepost

1.21.

314.102 0.80 0.00 0.80 UAR Restore Barricade.

314.107 0.26 0.00 0.26 UAR2 Add to road system. OML 2

. Delineate route. Three Ponds camping area. 

POC Mitigation: rock/gravel length of motorized trail as needed.

314.108 0.06 0.00 0.06 UAR Restore Barricade.

315.100 1.48 0.20 1.68 UAR Restore Barricade.

315.100 0.20 0.00 0.20 UAR Motorized Trail Add to trail system. Motorized trail.

315.102 0.48 0.00 0.48 UAR Restore Barricade.

315.103 0.26 0.00 0.26 UAR Restore Barricade.

315.104 0.82 0.00 0.82 UAR Restore Barricade.

315.106 0.25 0.00 0.25 UAR Restore Barricade.

315.107 0.30 0.00 0.30 UAR Restore Barricade.

315.108 0.46 0.00 0.46 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route.

315.109 0.49 0.00 0.49 UAR Restore Barricade.

315.110 0.07 0.00 0.07 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel route as needed.

315.111 0.03 0.00 0.03 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel route as needed.

315.2 0.51 0.00 0.51 UAR Restore Waterbars/

rolling dips as needed. Remove culverts at milepost 0.07, 0.13 

and 0.18 to improve drainage. POC Mitigation: barricade.

315.3 0.98 0.00 0.98 UAR Restore Remove all culverts. Waterbars as needed. POC Mitigation: barricade.

315.3A 0.24 0.00 0.24 UAR Restore Remove all culverts. Waterbars as needed and barricade.

315.9A 1.22 0.00 1.22 UAR Restore Remove culverts and associated fill from stream channels. Waterbars as 

needed and barricade.
84 – Smith River National Recreation Area Restoration and Motorized Travel Management

Appendix A. Alternative Tables

Alternative 6

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 6 Proposed Actions

316.1 0.26 0.00 0.26 UAR2 Add to road system. OML 2. Administrative use only. Add rolling dips. 

POC Mitigation: rock/gravel length of road.

316.10 0.03 0.00 0.03 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel route as needed.

316.11 0.04 0.00 0.04 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel route as needed.

316.12 0.03 0.00 0.03 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel route as needed.

316.2 0.20 0.00 0.20 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel route as needed.

316.3 0.08 0.00 0.08 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel route as needed.

316.4 0.07 0.00 0.07 UAR Motorized Trail Add as motorized trail. Route delineation. POC Mitigation: rock/gravel 

route as needed.

316.5 0.03 0.00 0.03 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel route as needed.

316.6 0.03 0.00 0.03 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel route as needed.

316.7 0.02 0.00 0.02 UAR Motorized Trail Add as motorized trail; route delineation.

316.7A 0.02 0.00 0.02 UAR Motorized Trail Add as motorized trail; route delineation.

316.8 0.05 0.00 0.05 UAR Motorized Trail Add as motorized trail; route delineation; waterbars. POC Mitigation: 

gravel as needed.

316.9 0.06 0.00 0.06 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel route as needed.

316.9A 0.05 0.00 0.05 UAR Restore Barricade.

324.100 0.13 0.00 0.13 UAR Restore Barricade.

405.10 0.23 0.51 0.74 UAR Restore Barricade.

405.10 0.51 0.00 0.51 UAR Motorized Trail Add to trail system. Motorized trail. Delineate route. Route delineation at 

milepost 0.36.

405.100 0.11 0.00 0.11 UAR Restore Barricade.

405.101 0.17 0.00 0.17 UAR Restore Barricade.

405.103 3.47 0.00 3.47 UAR Motorized Trail Add to trail system. Motorized trail. Improve surface drainage near creek; 

repair culvert.

405.9 0.05 0.00 0.05 UAR Restore Barricade.

411.101 0.30 0.00 0.30 UAR Restore Barricade.

411.102 0.17 0.00 0.17 UAR Restore SUP road, do not barricade.

427.101 0.15 0.00 0.15 UAR1 Add to road system. OML 1.

427.103 0.32 0.00 0.32 UAR2 Add to road system. OML 2. Delineate route.

427.104 0.30 0.00 0.30 UAR Restore Barricade.
Appendix A. Alternative Tables

Final Environmental Impact Statement 

– Appendices 

– 85

Alternative 6

Road

or Route Miles BeginningMile Point

End

Mile Point

Existing Status 

or Maintenance 

Level

Final Status or 

Maintenance 

Level

Alternative 6 Proposed Actions

427.105 0.29 0.00 0.29 UAR 2 Add to road system. OML 2. County disposal site; may be gated 

periodically for administrative purposes.

427.106 0.13 0.00 0.13 UAR Motorized Trail Add to trail system. Motorized trail. install rolling dips to improve drainage.

427.107 0.05 0.00 0.05 UAR 2 Add as OML 2. POC Mitigation: gravel.

427.108 0.09 0.00 0.09 UAR Motorized Trail Add as motorized trail. POC Mitigation: rock/gravel route as needed.

427.108A 0.04 0.00 0.04 UAR Restore Barricade.

Appendix B. Monitoring Plan

Final Environmental Impact Statement – Appendices – 87

Appendix B. Monitoring Plan

Water Quality Monitoring Plan

The Water Resources Monitoring Plan presented here was developed to meet state water quality 

objectives as identified by the State of California Regional Water Quality Management Plan, which is 

intended to protect and maintain the identified beneficial uses of water flowing from NFS land. Best 

Management Practices (BMPs) were developed specifically for meeting all state water quality objectives.

The BMP (Practice: 4-7) for off-highway vehicle (OHV) use is described below. This monitoring also 

satisfies the requirements of the Watershed and Fisheries Restoration Program biological assessment 

(WFR BA) for coho salmon as well as soils and geology resource concerns.

Water Quality Monitoring of OHV Use According to a Developed Plan

Objective: To provide a systematic process to determine when and to what extent OHV use will cause, or 

is causing adverse effects on water quality.

Explanation: Each forest’s OHV plan will:

• Identify areas or routes where OHV use could cause degradation of water quality.

• Establish baseline water quality data for normal conditions as a basis from which to measure change.

• Identify water quality standards and the amount of change acceptable.

• Establish monitoring methods and frequency.

• Identify controls and mitigation appropriate in management of OHVs.

• Restrict OHV use to designated routes.

Implementation: Monitoring results are evaluated against the OHV plan objectives for water quality and 

the Forest Plan objectives for the area. These results are documented, along with the actions necessary to 

correct identified problems.

If considerable adverse effects are occurring, or are likely to occur, immediate corrective action will 

be taken. Corrective actions may include, but are not limited to, reduction in the amount of OHV use, 

signing, or barriers to redistribute use, partial closure of areas, rotation of use on areas, closure to 

causative vehicle type(s), or total closure, and structural solutions, such as culverts and bridges. Closure is 

accomplished through authority of the forest supervisor.

Water Resources Monitoring Plan

Over the next 10-year period, monitor and evaluate at least 20 percent of routes added to the NFTS 

annually, which were identified as high risk. Monitoring is predicated on available funding.
Appendix B. Monitoring Plan

88 – Smith River National Recreation Area Restoration and Motorized Travel Management

The recommended protocol for monitoring of newly added routes is the Region 5 OHV TrailMonitoring Protocol, commonly referred to as Green-Yellow-Red. This protocol was developed in Region 

5 specifically to evaluate OHV route impacts to soil and water resources (see following table).

Table B-1. Green-yellow-red water quality monitoring indicators.

Green Condition Yellow Condition Red Condition

G1

Water control is provided by 

enough functional water breaks to 

divert runoff from the trail before it 

has the volume and velocity to 

cause erosion. Where present, rills 

occur on less than one-third of the 

distance between water breaks.

Y1

Water breaks do not divert all runoff from 

the trail because they are nearly filled to 

capacity and/or are partially breached, or 

spaced too widely. Where present, rills 

occur on more than one-third of the 

distance between water breaks.

R1

Water breaks no longer divert 

runoff from the trail because they 

are full and/or have been 

breached, or are absent or spaced 

too widely. Gully or rill erosion may 

be present.

G2

No accelerated erosion off-trail. 

Runoff at water break outlets and 

on slopes adjacent to the trail is 

dispersed effectively. All sediment 

is filtered by vegetation or litter.

Y2

Rill erosion and/or sediment deposition 

occurs at water break outlets and/or on 

slopes adjacent to the trail. All sediment 

is filtered or deposited before it reaches 

a watercourse with a scoured channel.

R2

Gully erosion occurs at water

break outlets or on slopes adjacent 

to the trail and/or sediment is 

transported to an intermittent or 

perennial watercourse.

G3

Sediment traps, where present, 

are all functional and have 

adequate capacity for at least 

one season of use. Trapped 

sediment can be retrieved during 

normal maintenance.

Y3

Where present, most sediment traps 

are full or nearly full, but still functional. 

Most trapped sediment can be retrieved 

during normal maintenance.

R3

Where present, sediment traps 

have been breached and have a 

plume of sediment and/or a gully 

below the breach. Most sediment 

cannot be retrieved.

G4

Tread wear is minimal. Tread is 

generally incised less than 6 

inches. Tread wear is generally 

evident on less than one-third of 

the distance between water

breaks or on less than one-third

of the tread width.

Y4

Tread wear is evident. Tread is 

generally incised 6 to 12 inches and 

tread wear is generally evident on more 

than one-third the distance between 

water breaks and on more than onethird of the tread width. If present, 

whoops or stutter bumps and high 

berms are well developed.

R4

Tread wear is severe. Tread 

incision is generally greater than 12 

inches deep and tread wear is 

generally evident on the entire 

distance between water breaks. If 

present, deep whoops and stutter

bumps force traffic off the trail.

G5

Tread width is generally no 

greater than 1.5 times the design 

width for the designated use.

Y5

Tread width is generally greater than 2 

times the design width for the designated 

use and appears to be increasing.

R5

Tread width is generally greater 

than 3 times the design width for 

the designated use and has 

caused or is causing severe 

resource damage.

G6

Unauthorized user-created trails 

are limited to single tracks or 

single passes generally less than 

300 feet long. Tracks are not 

eroded and have little effect on 

water control.

Y6

Unauthorized user-created trails are 

common, well defined, and generally 

greater than 300 feet long. Water control 

is inadequate. Areas with resource 

damage can be revegetated/restored 

with ordinary effort.

R6

Unauthorized user-created trails 

have caused severe resource 

damage such as gully erosion, 

eroded hill climbs, or extensive 

damage to vegetation and/or 

sensitive habitat. Restoration will 

usually require a major effort (e.g., 

large equipment, topsoil 

replacement, etc.)

G7

Approach to watercourse crossing 

is short and has a gentle 

gradient. Tread is stable, shows 

little evidence of erosion, 

and is at design width. No 

damage to riparian vegetation 

outside the tread.

Y7

Approach to watercourse crossing is 

short and steep or long and gentle. Tread 

may show some evidence of erosion and 

may show evidence of widening. Minimal 

damage to riparian vegetation.

R7

Approach to watercourse crossing 

is both steep and long and/or tread 

is unstable and shows evidence of 

accelerated erosion. Approach 

may be widening and damaging 

riparian vegetation.
Appendix B. Monitoring Plan

Final Environmental Impact Statement – Appendices – 89

Port-Orford-Cedar Monitoring Plan

Objectives

1) Monitoring for the illegal use (i.e. use outside allowed season of use) of roads and motorized 

trails on the NFTS rated as high risk of introducing Phytophthora lateralis (PL) into POC stands.

2) Monitoring and inspecting current gates and newly installed gates and barricades to determine 

gate condition and efficacy in limiting motor vehicle access to the open dry season.

3) Monitoring of known or unmapped areas of uninfected trees behind POC closures near NFTS 

roadways for signs of PL and confirming the presence of the disease.

Timing: All of the above shall occur at least once during closure season, more often depending on 

available resources. In addition to specified monitoring for the above items, monitoring will also occur 

during routine work across the district.

Methodology

• Gate and Barricade Monitoring and Inspections: Forest Service personnel shall inspect 

seasonal gates annually to look for signs of illegal use beyond the gate and to ensure gate 

integrity is sound. At each gate location, at a minimum the following data will be collected:

o Name of personnel performing monitoring

o District

o Date

o Location (road number and intersecting road number – if applicable)

The following observations shall also be collected.

o Condition of gate: Is gate still functional?

o What repairs are needed, if applicable?

o Is there evidence that motor vehicle traffic is bypassing gate?

o If yes, list recommendations to increase effectiveness.

• Uninfected POC Stand Monitoring: FS personnel will be trained to look for new signs of POC 

root disease in trees and stands that appear to be otherwise healthy. This will primarily be 

observing POC trees with changes in color from a healthy green crown, primarily yellow, orange 

and reddish colors occurring throughout the entire crown. The location of the site will be recorded 

and given to the district POC manager. Follow-up will occur to confirm presence of the disease.

Implementation: If signs of illegal access are noted, corrective action will be taken. Corrective actions 

may include, but are not limited to, reinforcing areas around gates to restrict access beyond areas of 

illegal use, such as boulder placement or moving gates to a different location that may be more effective 

at preventing trespass, or complete closure of the road.
Appendix B. Monitoring Plan

90 – Smith River National Recreation Area Restoration and Motorized Travel Management

Botanical Resources Monitoring Plan

Introduction: It is Forest Service policy to analyze impacts to sensitive species to ensure management 

activities do not create a significant trend toward federal listing or loss of viability. The Botanical 

Resources Monitoring Plan was developed to assess impacts to Sensitive plants resulting from the 

implementation of the Smith River National Recreation Area Restoration and Travel Management project.

Objective: The objective is to collect population data over time in order to detect if a consequential 

downward trend in any population of sensitive plant species within 30 feet of UARs proposed for addition 

to the NFTS has occurred and to implement a management response to avoid reaching the threshold of 

concern for loss of viability or trend toward federal listing.

Location: A selection of the following routes will be monitored:

Table B- 2. Routes to be monitored – botany.

Road_Route Miles OCC_ID LEOP SISE10 STHO VIPRO2

17N49.100 3.88 SISE10_020 1139

17N49.100 3.88 STHO_014 2

17N49.100 3.88 STHO_017 50

17N49.101 1.17 SISE10_007 300

17N49.101 1.17 SISE10_009 300

17N49.102 0.87 SISE10_008 1000

17N49.104 3.82 SISE10_012 200

17N49.104 3.82 SISE10_016 650

17N49.104 3.82 SISE10_018 616

17N49.104 0.86 STHO_017 4

17N49.104 3.82 STHO_017 120

17N49.107 0.64 STHO_017 2

17N49.108 0.31 STHO_017 2

17N49.11 1.94 SISE10_014 147

17N49.11 2.55 SISE10_014 517

17N49.11 1.94 STHO_017 19

17N49.11 2.55 STHO_017 16

17N49.11N 0.23 STHO_002 3

17N49.12 2.1 SISE10_017 302

17N49.12 2.1 STHO_010 76

17N49.13 0.3 SISE10_019 45

17N49.14 0.54 STHO_017 9

17N49.15 0.62 STHO_017 1

17N49.4 0.75 SISE10_006 750

17N49.7 2.15 SISE10_013 400

17N49.7 0.29 SISE10_015 800

17N49.7 2.15 VIPRO2_005 500

17N49.7 2.15 VIPRO2_007 100

17N49.7 2.15 VIPRO2_008 100

17N49.7A 0.82 SISE10_017 600

17N49.8 0.39 SISE10_016 58
Appendix B. Monitoring Plan

Final Environmental Impact Statement – Appendices – 91

Road_Route Miles OCC_ID LEOP SISE10 STHO VIPRO2

17N49.8 0.39 STHO_017 13

18N51.100 1.45 LEOP_014 27

305.109 2.43 LEOP_011 29

305.109 2.43 LEOP_012 42

305.109 2.43 LEOP_013 162

305.109 2.43 SISE10_027 295

305.118 0.8 STHO_039 7

305.121B 1.03 STHO_027 6

305.125 1.44 STHO_016 1

305.126 1.56 STHO_009 44

305.126 1.56 STHO_013 1

Totals 260 8,119 376 700

Timing: Baseline data collection of sensitive plant occurrences corresponding with UARS will occur 

within three years prior to designating a UAR as a motorized trail or road on the MVUM and occur within 

that timeframe over at least two consecutive years. Once baseline is established monitoring will 

commence within three years of the addition of motorized trails to the NFTS and will occur once a year 

thereafter for five years until analysis shows that occurrences are stable.

Methodology: The analysis of effects on rare botanical species (federally listed, Forest Service sensitive 

botanical species) involve a process that starts with reviewing existing data sources (FSM 2672.43). In the 

first step, federally listed and sensitive botanical species that are known or are believed to have potential 

to occur in the analysis area were reviewed to identify potential affected botanical species associated with 

the proposed actions. A list of federally listed species to review for the analysis was compiled using the 

Arcata USFWS office online IPaC (Information for Planning and Conservation) search page (USDI 

2016). The list of sensitive botanical species was from the USDA Forest Service Region 5 Sensitive 

Species List (USDA Forest Service 2013).

The second step in the analysis of effects on sensitive botanical species was field reconnaissance 

surveys. Field surveys were conducted at the time of year when plants were evident and identifiable. 

Additionally, information on rare plants from past field surveys, monitoring, and personal field 

observations were utilized during the analysis. Surveys were performed on a subset of inventoried UARs, 

which includes motorized trails, contained in the project, specifically in those areas where target species 

could be affected to determine the presence or absence of federally listed plant species, or Region 5 Forest 

Service sensitive plants (herein referred to as sensitive plant species). Where detected, federally listed or 

sensitive plants were documented by species and the number of individuals (herein synonymous with the 

number of ramets or above ground shoots as determining actual plant counts would requiring digging 

individuals up) were tallied by occurrence—an occurrence being an aggregation of plants that are 

geographically separated by another aggregate by less than a quarter mile1

. Occurrences for species 

 

1 Occurrence definition follows the standard established by NatureServe, which defines the ranking methodology nationally for all 

Heritage Programs including the California Natural Diversity Database www.wildlife.ca.gov/Data/CNDDB/Plants-and-Animals.
Appendix B. Monitoring Plan

92 – Smith River National Recreation Area Restoration and Motorized Travel Management

analyzed in this document are commensurate with sub-populations. National Forest Transportation 

System roads were not surveyed, as their highly altered, engineered surfaces are not considered suitable 

habitat for the target species nor are the target species known to occur on these surfaces. No federally 

listed plant species were found within 100 feet of UARs proposed for addition to the NFTS.

Sensitive Plant Species Management Actions

It is Forest Service policy (FSM 2670.22) to analyze impacts to sensitive species to ensure management 

activities do not create a significant trend toward federal listing or loss of viability. The overall objective 

of the sensitive species management actions is to assess direct effects over time to sensitive plants 

associated with UARs designated on the NFTS as motorized trails and seek to guide management 

response. Specifically, these management actions would:

• Update baseline conditions for the four sensitive plant species that will refine, if needed, 

thresholds triggering management response,

• Substantiate the findings on the direct effects of the project to sensitive plants occurring within 

the active road prism and adjacent to the UAR by using a paired sampling approach,

• Determine if a downward trend in a sensitive plant occurrence has occurred that would result in a 

management response, and

• In coordination with the line officer, identify and implement the applicable management response 

(e.g., barricading) to prevent a loss of viability or a trend towards federal listing.

The goal is to detect if a downward trend in any population has occurred through direct effects of 

motorized use that could foreshadow a loss of viability or a trend toward federal listing and to take 

management action at the management response threshold before a loss of viability occurs.

Important background is the definition of occurrence for the purposes of collecting the baseline and 

effects data associated with management. Surveys performed for the Smith River National Recreation 

Area Restoration and Motorized Travel Management Project were restricted to within 100 feet of UARs 

by the district ranger. One of the consequences of restricting sensitive plant surveys to 100 feet of UARs 

is that our universe of a species’ occurrence, against which we measure viability losses, is also restricted.

The context of a given sensitive plant’s occurrence is now defined as within 100 feet of UARs. The 

distribution of the sensitive plant, if any, beyond this parameter of 100 feet, does not apply to the analysis 

of viability since no surveys were conducted beyond this distance for the project.

Baseline Data Collection – Phase 1

Project surveys for the opposite leaved lewisia, the serpentine Indian pink and Howells jewelflower

occurred in 2006 and are considered dated in terms of establishing a baseline for the respective 

occurrences against which current thresholds can be evaluated and updated as necessary. Western bog 

violet surveys have occurred more recently than the other species (2014), but not over consecutive years.

Baseline data collection of sensitive plant occurrences corresponding with UARS will occur within 

three years prior to designating a UAR as a motorized trail or road on the MVUM and occur within that 
Appendix B. Monitoring Plan

Final Environmental Impact Statement – Appendices – 93

timeframe over at least two consecutive years. The consecutive years of sampling is an attempt to account 

for year-to-year fluctuations due to natural population variations. Data collection will occur in keeping 

with the phenology of the respective species, which typically ranges from late April and May for oppositeleaved lewisia and western bog violet and June to July for serpentine Indian pink and Howells jewelflower.

Data (e.g. counts of individuals/ramets, bare ground cover, associating species) will be collected 

within one meter quadrats along paired transects that are monumented to improve accuracy in re-locating 

quadrat installation points and repeated sampling. Given its scattered, non-clumped distribution, sampling 

methodology for Howells jewelflower will depart from the quadrat methodology and instead focus on a 

count of individuals along a transect and paired sampling where it can be accommodated.

Paired transects will provide a comparison between plants in a setting most vulnerable to direct 

effects by motor vehicles against those that are not. The respective transects will correspond to this 

gradient of disturbance with one located within the travel way and the other in close proximity on the 

edge or sides that are unlikely to be impacted by vehicular disturbance.

A backdrop to these management actions is that the proposed action would designate existing 

inventoried UARs as motorized trails or roads that have experienced a low-level use of motorized 

recreation use over the years. Baseline data will therefore reflect some level of previous disturbance.

Monitoring – Phase 2

Once baseline data is collected, management response thresholds are reviewed by a journey level botanist 

based upon such factors as changes in plant numbers of an occurrence and visual signs of motorized use. 

Monitoring would begin in keeping with the designation of the UARs on the MVUM and the 

commencement of use.

The types of data collected will follow that of the baseline data collection and sample the same paired 

transects and associated quadrats. In addition:

• Data collected along the transect not effected by motorized use outside of the immediate travel 

way will serve as the reference against which the data collected along the transect directly 

affected within the travel way will be compared. Measurements along the transect out of the 

travel way will aim to account for natural fluctuations in the occurrence.

• Additional metrics will be added pertaining to direct effect measurements, such as the number of 

individuals crushed by vehicle tires, documentation of wheel ruts present in quadrat, etc.

• Photo points will be established.

• Traffic counters will be installed initially to capture quantity and rate of motorized use along 

those UARs associated with sensitive plant monitoring. This information may assist in 

correlations relative to extent of direct effects to the occurrence.

Frequency and duration of monitoring will be evaluated based on monitoring results from the prior 

year. Initially monitoring will occur annually. The yearly frequency may be lessened (i.e. every second or 

third year) if data collected over subsequent years indicates that there is little or no difference from 
Appendix B. Monitoring Plan

94 – Smith River National Recreation Area Restoration and Motorized Travel Management

reference conditions. If subsequent years indicate that there are changes to the reference condition due to 

motorized use, more frequent monitoring will resume and may indicate a need to monitor beyond 10 years.

If at any time during monitoring a downward trend is detected in any of the four sensitive species 

measured, the data will be analyzed in relation to the management response thresholds discussed in the 

next section.

Management Response Threshold

The management response thresholds shown in Table B-3 identifies the point at which management actions 

are triggered to avoid a loss of viability or trend toward federal listing of the species. Professional knowledge 

of the respective species is factored into determining thresholds such as a species growth habit (perennial or 

annual, rhizomatous or not), b) its phenology (e.g. season of emergence, blooming and dormancy if 

applicable), or c) habitat setting and vulnerability (e.g. opposite-leaved lewisia occupies habitat of relatively 

gentle topography compared to Howells jewelflower which can occupy rocky slopes) in determining a given 

species management response threshold. The management response threshold in the proposed action is lower 

than the threshold of concern identified in the Forest Plan (USDA Forest Service 1995) which is identified as 

a more than 20 percent decline in the number of individuals over a 5-year sampling period. The management 

response threshold is lower in order to provide time for corrective action to occur before the threshold of 

concern, indicating a loss of viability or trend toward federally listing, is approached.

The loss of an occurrence with a good or better viability rating would represent a management 

response threshold. An assessment of viability loss will generally incorporate methodology developed by 

NatureServe whose rankings are used by the Forest Service to designate Sensitive species. The California 

Natural Diversity Data Base, which is the California based NatureServe organization, provides a 

definition of an element occurrence (herein referred to as an occurrence) which is used to identify finite 

spatial portions of meta-populations that have practical conservation value as evidenced by potential 

continued presence or regular occurrence at a given location (NatureServe 2002). This methodology 

provides a succinct assessment of estimated viability or probability of persistence to assess the likelihood 

of whether an occurrence will persist for a defined period by ranking them on a scale from ‘A’ (excellent 

estimated viability) to ‘X’ (extirpated). The occurrence rank reflects “the degree to which people have 

directly or indirectly adversely impacted community composition, structure, and/or function, including 

alteration of natural disturbance processes”. In general, occurrences are ranked based on size (both spatial 

and population abundance), condition and landscape context. An occurrence with at least good (i.e., 

excellent-to-good) viability exhibits favorable characteristics with respect to population size and/or 

quality and quantity of occupied habitat; and, if current conditions prevail, the occurrence is likely to 

persist for the foreseeable future (NatureServe 2009). Evaluating a downward change in viability rating of 

an occurrence will be based on the NatureServe ranking methodology titled Key for Ranking Species 

Element Occurrences Using the Generic Approach (Tomaino 2008). The evaluation will be performed by

a journey level botanist who is knowledgeable of the sensitive plant species affected and their analysis of 

a comparison between baseline data and monitoring data collected over time.
Appendix B. Monitoring Plan

Final Environmental Impact Statement – Appendices – 95

The percentages in Table B-3 reflect the culmination of the aforementioned factors to foreshadow when a 

given species’ viability is a concern and when management response is needed. The opposite-leaved lewisia 

and Howells jewelflower, which are represented by low plant counts, have a management response threshold 

of 10 percent. The management response threshold for the serpentine Indian pink and the western white bog 

violet is 15 percent. These thresholds can change if baseline data collection reveals that population size has 

changed significantly since survey data was last collected for these species in 2006 and 2014.

If a management response threshold is breached due to motorized use of UARs, a concern for species 

viability is triggered thus warranting line office involvement and management action that includes:

barricading the affected occurrence, buffering the occurrence with boulders, or having use restricted or 

prohibited by order of the forest supervisor (Forest Plan standard and guideline 18-24, IV-128). If impacts

are noted that are below the management response threshold but which create a concern for a downward 

trend, actions such as, but not limited to, signing or route delineation will be implemented

Table B-3. Management response thresholds.

Thresholds Opposite 

leaved lewisia

Serpentine 

Indian pink

Howells 

jewelflower

Western bog 

violet

Alternative 6 plant totals within 30 feet of UARs 260 6,678 1,96 700

Plant numbers triggering a management concern 26 1,002 20 105

Management Response Threshold 10% 15% 10% 15%

Alternative 6 occurrence totals 4 13 3 3

Occurrence decline – a decline in an occurrence from a good 

to a poor viability ranking will trigger a management response. 0 0 0 0

Implementation: If significant downward trends are noted, or are likely to occur, corrective action will be 

taken. Corrective actions may include, but are not limited to, signing, barriers, closure to causative vehicle 

type(s), or removal of the route from the Motor Vehicle Use Map (MVUM).

Protocol: The recommended protocol for monitoring affects to Sensitive plants is the Region 5 OHV 

Trail-Monitoring Protocol, using the Green-Yellow-Red indicators.

Table B-4. Green-yellow-red botany monitoring indicators.

Green Condition Yellow Condition Red Condition

There is no downward trend in 

numbers of individuals or loss of 

viable occurrences.

There is evidence of downward 

trend in numbers of individuals.

10% loss of opposite leaved lewisia or Howells jewelflower.

15% loss of serpentine Indian pink or western bog violet.

A change in viability rating from good to poor for an 

occurrence of any of the four sensitive species.

Table B-5. Cost per year.

Personnel Number of Days Cost Per Day Total Cost

2 GS-430-11 10 $770 $15,400

2-GS-430-09 10 $420 8,400

Travel and Per Diem 6 $150 $3,600

Total Cost Per Year $27,400
Appendix B. Monitoring Plan

96 – Smith River National Recreation Area Restoration and Motorized Travel Management

Recreation Monitoring Plan

Objective: Monitoring of motorized trail use is conducted by the forest to meet standards and guidelines 

set by the LRMP and by national and regional direction. Note that the Forest Plan references OHV routes.

These routes are analogous to NFTS motorized trails as referenced in this document.

Timing: Monitoring/field reviews of motorized trail conditions is required annually, currently monitored 

on a five-year cycle (approximately 20 percent per year), in accordance with national and regional 

direction. If the national or regional policy inspection frequency changes in the future, then Forest trail 

monitoring frequency and cycles will conform to policy direction at that time.

Implementation: If monitoring, or trail condition surveys, lead the Responsible Official to determine 

motor vehicle use is directly causing or will directly cause considerable adverse effects on public safety or 

soil, vegetation, wildlife, wildlife habitat, or cultural resources, then corrective actions will be taken 

immediately. Corrective actions may include but are not limited to signing, maintenance, stormproofing, 

barriers, closure to causative vehicle type(s), partial closure, or total closure.

Protocol: The annual monitoring of NFTS motorized trails and dispersed recreation resources (currently 

required at about 20 percent of routes per year) is generally focused on routes with specific resource 

concerns, such as those in areas classified as having a semi-primitive recreation setting (as determined by 

the recreation opportunity spectrum or ROS). Routine road and trail condition surveys are conducted 

using a random sample and must meet national and regional standards. The recreation monitoring element 

thresholds of concern, as provided in the Forest Plan include:

• More than 10 percent variance from planned use levels; and/or

• Visible damage of forest resources along or adjacent to NFTS motorized trails.

Noxious Weed Monitoring Plan

Table B-6. Noxious weed sites to be monitored.

Route Miles Species Date Last Treated Plants Treated Exist Alt 6

13N37 2.00 Scotch broom 7/10/2012 1 2 1

15N38 2.90 Scotch broom 1/27/2012 69 2 2

15N63 0.30 Scotch broom 9/15/2010 20 2 2

16N03K 1.50 Scotch broom 8/23/2011 67 2 2

16N19 8.28 Scotch broom 7/24/2013 63 2 2

16N38 2.90 Scotch broom 5/23/2010 327 2 2

16N41 1.43 Scotch broom 5/27/2010 10 2 2

17N04S 1.80 Scotch broom 6/5/2006 50 1 DECO

17N05C 0.97 Scotch broom 6/15/2012 986 1 DECO

17N13A 0.38 Scotch broom 9/19/2012 280 2 1

17N15A 0.13 Scotch broom 7/27/2012 282 2 DECO

17N16 0.65 meadow knapweed 7/19/2012 6 2 1

17N22J 0.12 Scotch broom 4/21/2011 5 2 2
Appendix B. Monitoring Plan

Final Environmental Impact Statement – Appendices – 97

Route Miles Species Date Last Treated Plants Treated Exist Alt 6

17N26 0.25 tansy ragwort 7/24/2013 13 2 2

17N31 1.60 Scotch broom 1/4/2012 82 2 1

17N36 2.50 Scotch broom 9/11/2012 1 2 2

17N41H 0.90 Scotch broom 11/19/2008 463 2 2

17N48 1.66 Scotch broom 4/25/2012 85 2 2

17N49 3.52 French broom 8/23/2011 1 3 3

17N49 0.44 Scotch broom 6/10/2010 1 3 3

18N07.2 0.13 Scotch broom 4/8/2013 5745 UAR 2

18N08.2 0.03 Scotch broom 12/7/2011 14 UAR 2

18N16E 0.38 Scotch broom 3/8/2013 671 1 DECO

18N17 8.10 Scotch broom 8/8/2012 10 2 2

18N19C 0.17 Scotch broom 11/17/2011 30 1 DECO

18N20 1.00 Scotch broom 8/7/2012 10 2 DECO

18N20 Scotch broom 8/7/2012 1 2 DECO

18N20 tansy ragwort 8/7/2012 160 2 DECO

18N56 0.88 Scotch broom 8/8/2012 7 2 2

199.104 0.11 Scotch broom 3/17/2013 132 UAR 3

427.103 0.32 Scotch broom 12/16/2011 71 UAR 2

427.106 0.13 Scotch broom 4/28/2011 476 UAR TRAIL

Timing: Monitoring will commence at the end on one full growing season following the addition of the 

routes to the NFTS. Monitoring shall occur in late Fall, following the first rains. Monitoring shall occur 

every year thereafter.

Methodology: Priority will be given to sites treated. Rangeland General Forms (weed inventory forms) 

shall be completed for each site visited to quantify weed species present.

Protocol: Motorized trails and NFTS roads shall be maintained in a weed free state. If weed sites are 

found on motorized trails or NFTS roads, they will be treated to removal all weeds. If yellow star-thistle, 

diffuse or spotted knapweed infestations are found on motorized trails, these trails should be removed 

from the Motor Vehicle Use Map (MVUM) until the infestations are eradicated.

Table B-7. Green-yellow-red weed monitoring indicators.

Green Condition Yellow Condition Red Condition

There is no evidence of priority 

noxious weeds on designated routes.

Due to proximity, there is potential for priority 

noxious weeds to spread from existing 

system roads to newly designated motorized 

trails or newly designated NFTS roads.

Priority noxious weeds have spread to 

newly designated motorized trails or newly 

designated NFTS roads.

Table B-8. Cost.

Personnel Number of Days Cost Per Day Total Cost

2 GS-430-09 10 $600 $6,000

Travel 10 $70 $700

Total Cost Per Year $6,700
Appendix B. Monitoring Plan

98 – Smith River National Recreation Area Restoration and Motorized Travel Management

Heritage Monitoring

There are twenty-seven cultural resources within the APE, which represents the maximum footprint of the 

project (Alternative 4). Twenty-three are historic archaeological sites, three are multi-component 

archaeological sites, and one is a gathering area, which contains an historic component. A route-by-route 

assessment was completed to determine the effects to cultural resources from the proposed alternatives 

(Confidential Tables in CRIR # R2014051011033 and CRIR # R2015051000047). These detailed 

assessments looked at the type of effect, nature of effects, severity of effect, and Standard Resource 

Protection Measures prescribed under Appendix E of the PA and Appendix B of the Motorized PA to 

determine no adverse effects.

Monitoring will be conducted at archaeological sites where minor effects are anticipated. Where 

moderate effects are anticipated, barriers (or other standard protection measures) will be in place. No sites 

are at risk for having severe effects. It is anticipated that there will be no adverse effects to historic 

properties under Alternatives 4, 5, or 6, if all standard protection measures are followed.

Table B-9. Site effects and SRPM by alternative.

Count FS Site # Type of Effect Severity of 

Effect

SRPM2 Required by Alternative

Alt 1 Alt 4 Alt 5 Alt 6

1 05-10-51-2 None N/A No No No No

2 05-10-51-10 Indirect Minor No Monitor No Monitor

3 05-10-51-11 None N/A No No No No

4 05-10-51-18 Indirect Moderate No Barrier Barrier Barrier

5 05-10-51-26 Direct Moderate No Barrier Barrier Barrier

6 05-10-51-27 Direct / Indirect Minor No Monitor No Monitor

7 05-10-51-33 None N/A No No No No

8 05-10-51-34 None N/A No No No No

9 05-10-51-37 None N/A No No No No

10 05-10-51-39 None N/A No No No No

11 05-10-51-49 Direct / Indirect Minor No Monitor No Monitor

12 05-10-51-55 Indirect Minor No Monitor No Monitor

13 05-10-51-68 None N/A No No No No

14 05-10-51-133 Indirect Minor No Monitor No No

15 05-10-51-143 None N/A No No No No

16 05-10-51-144 None N/A No No No No

17 05-10-51-178 Indirect Minor No Monitor No No

18 05-10-51-204 None N/A No No No No

19 05-10-51-207 None N/A No No No No

20 05-10-51-310 Indirect Negligible No No No No

21 05-10-51-315 None N/A No No No No

22 05-10-51-318 None N/A No No No No

23 05-10-51-320 None N/A No No No No

 

2 SRPM refers to the Standard Resource Protection Measure defined in Appendix B of The Programmatic Agreement for 

Designating Motor Vehicle Routes and Managing Motorized Recreation on the National Forests in California.
Appendix B. Monitoring Plan

Final Environmental Impact Statement – Appendices – 99

Count FS Site # Type of Effect Severity of 

Effect

SRPM2 Required by Alternative

Alt 1 Alt 4 Alt 5 Alt 6

24 05-10-51-321 Indirect Moderate No Allow Access Allow Access Allow Access

25 05-10-51-322 None N/A No No No No

26 05-10-51-327 None N/A No No No No

27 05-10-51-328 None N/A No No No No
Appendix B. Monitoring Plan

100 – Smith River National Recreation Area Restoration and Motorized Travel Management

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Appendix C. Past, Present and Reasonably Foreseeable Activities

Final Environmental Impact Statement – Appendices – 101

Appendix C. Past, Present and Reasonably 

Foreseeable Activities

A detailed description of these activities is located in the project record.

Implementation Complete

Forest Service

• Coast to Crest Trail

• Abandon Mines Safety Closure Decision

• Abandoned Mines Safety Closure Decision

• Abandoned Mines Safety Closure Decision

• Altaville Mining District Site: Union-Zaar Mine Rehabilitation

• Goose Creek Land Acquisition

• Hurdygurdy Land Acquisition

• Siskiyou Fork Donation Land Acquisition

• Gasquet MVUM

• Roadside Sanitation of 15N39

• Youngs Valley Trailhead Relocation and Road Improvement

• Doe Flat Trail and Trailhead Relocation Project

• Gasquet Fires Complex Suppression and Repair

Non-Forest Service

• Del Norte County Rural Recreation Roads Ordinance

• Hardscrabble Bridge Replacement Project (US 199, PM 10.9–PM 11.2)

• Del Norte 199 Cable Mesh Drape Project (US 199, PM 18.3–PM 18.6)

• Hurdygurdy Bridge Replacement

• Steven Memorial Bridge Replacement

• CalTrans – Hiouchi Community Improvements Project (US 199, PM 5.4-6.2)

• CalTrans – Culvert replacement on Griffin Creek

• CalTrans – Storm damage repair – Dollar Bend Soldier Pile Wall

• Private timber harvests
Appendix C. Past, Present and Reasonably Foreseeable Activities

102 – Smith River National Recreation Area Restoration and Motorized Travel Management

Implementation Ongoing

Forest Service

• Hurdygurdy Recreation Improvement Project

• Dome Timber Sale (High Dome Meadow Restoration)

• Big Flat Vegetation and Fuels Management Project

• Station 3 Fuelbreak

• Coon Mountain Meadow Restoration

• Gasquet Community Wildfire Protection and Supplemental Information Report

• Hiouchi Community Protection Fuelbreak Project

• Gasquet Shaded Fuel Break / Rescoped as Elk Camp Fuel Break Project

• Mus-Yeh-Sait-Neh Understory Burn and Supplemental Information Report

• North Fork Smith Special Interest Area Road Access and Supplemental Information Report

• Forest-wide Integrated Management of Invasive Non-native Plant Species

• Gordon Hill Vegetation and Fuels Management Project

• Gasquet Complex Burn Area Emergency Response

Planned Activities

Forest Service

• Aquatic Restoration EA

• Rogue River – Siskiyou National Forest Travel Management

• Hurdygurdy Land Acquisition

• Hardscrabble Mine Engineering Evaluation and Cost Analysis

• Mammoth Mine Engineering Evaluation and Cost Analysis

• Cleopatra Mine Preliminary Assessment and Site Inventory

• Aurora Mine Preliminary Assessment and Site Inventory

• Webb Pine PA/SI

Non-Forest Service

• Private Timber Harvests

• Hiouchi Community Improvements Project (US 199, PM 5.4–6.2)

• Major Bridge Seismic Retrofit Project at five bridges (US 101 and US 199, various locations)
Appendix C. Past, Present and Reasonably Foreseeable Activities

Final Environmental Impact Statement – Appendices – 103

• Maintenance project for a thin blanket overlay (US 199, PM 0.7–4.2), planned for 2014

• Three storm damage repair projects on US 199 (PMs 8.6 – 8.8, 21.7, 24.67, and 26.31, these 

being called Patrick Creek Slipout, Dollar Bend Soldier Pile Wall, and Siskiyou Forks Slipout)

• Hamilton Road High Friction Surface Treatment (US 101, PM 22.5–23.0)

• Smith River Canyon Safety Project (US 199, PM 8.1–8.4)

• Dr. Fine Bridge Project

• CalTrans STAA Hwy 199:

o Patrick Creek Narrows Location 1 (US 199: PM 20.5 to 20.7)

o Patrick Creek Narrows Location 2 (US 199: PM 23.9 to 24.3)

o Patrick Creek Narrows Location 3 (US 199: PM 25.55 to 25.65)

o The Narrows (US 199: PM 22.7 to 23.0)

o Washington Curve (US 199: PM 26.3 to 26.5)
Appendix C. Past, Present and Reasonably Foreseeable Activities

104 – Smith River National Recreation Area Restoration and Motorized Travel Management

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Appendix D. Mitigation Measures

Final Environmental Impact Statement – Appendices – 105

Appendix D. Mitigation Measures

Mitigation measures (also design features, design criteria) are described throughout the FEIS for the 

various resources in general and specific to the individual roads, UARs and motorized trails. Some 

mitigations are identified as part of the proposed actions, others as added on to the activities described. 

For instance, adding seasonal gates to certain roads or motorized trails is included as part of the 

management actions under all action alternatives and it is listed as a mitigation or design feature for POC 

and water quality. Many of the actions and mitigations below are considered restoration and risk 

reduction for identified resources.

In addition, the FEIS will follow best management practices for water quality (Regional and National) 

and for noxious weeds (Forest) on all management actions from planning through implementation. 

Monitoring identified in Appendix B is a feedback loop to effectiveness of implementation of the 

management actions, mitigations and design feature.

Table D-1 includes all mitigations and design feature included in the FEIS. All roads and UARs in 

Appendix A identify the proposed action for that road or route, including any site-specific mitigations, 

design feature or monitoring. Routes will not be placed on the MVUM until mitigations identified in the 

tables in Appendix A are in place (i.e., UARs proposed for designation on the NFTS as roads or motorized 

trails need mitigations in place prior to including them to MVUM). Actions/mitigations that would need 

to occur on a UAR-by-UAR basis include:

• Storm proofing (water quality, soils, geology, aquatic biota),

• Signage (recreation, NOA, transportation),

• Sensitive plant surveys (botanical resources),

• Seasonal gate installation (POC, aquatic biota), and

• Noxious weed treatments (noxious weeds).

Table D-1. Mitigation measures by resource.

Mitigation Measures Resources Rationale

Mitigations/Management Actions

Road improvements to UARs added to existing 

NFTS when change in maintenance level.

Recreation, Transportation, Water 

Quality

Recreational opportunities, improve roads 

for public safety, reduce resource impacts

Block or barricade roads, UARs.

Block ML 1 roads.

Barricade decommissioned roads.

Barricade UARs not added to the System.

Recreation, Water Quality, Botany, 

Geology, Soils, POC, 

Transportation, Noxious Weeds

Implement Subpart A; prevent illegal use;

public safety; prevent resource damage to 

water quality, POC and botanical 

resources; reduce risk of spread of weeds.

Season of Use: Install seasonal gates as identified 

in Appendix A prior to onset of wet weather.

Seasonal, year-round gates.

POC, Water Quality, Fisheries

Protect uninfected POC stands, reduce 

risk of spread, reduces risk to water 

quality and fisheries.

Sensitive plant species management actions.

Motorized trail (route) delineation through use of 

boulders, logs, etc.

Changes to road/motorized trails based on 

effectiveness (see monitoring).

Botany

Reducing the risk of loss of viability for 

Sensitive plant species on UARs added to 

the NFTS of roads and motorized trails.
Appendix D. Mitigation Measures

106 – Smith River National Recreation Area Restoration and Motorized Travel Management

Mitigation Measures Resources Rationale

Maintain NFTS road and motorized trail system.

Six Rivers Road Maintenance Decision Memo 

2016-2022.

Motorized trail maintenance.

All

Maintain NFTS roads and motorized trails 

to protect the transportation system 

investment, public safety and access, 

reduce resource impacts.

Mitigations/Design Feature

Improve road surface by adding gravel/rock to 

roads and trails surface.

POC, Water Quality, Recreation, 

Transportation

Reduce risk of spread of POC and 

impacts to water quality while allowing use 

of motorized trails.

Delineate route/motorized trails.

Using boulders, logs, barricades, or gates to 

protect resource, shorten route prior to addition, 

direct vehicles.

Place signs.

Water Quality, Botany, POC, 

Cultural Resources

To prevent unlawful use and keep vehicles 

on the road or motorized trail.

Stormproofing roads and motorized trails.

Add waterbars/rolling dips to reduce diversion 

potential.

Repair/upgrade culverts (100-year flood)

Maintain roads and motorized trails.

Water Quality, Soils,

Transportation, Public Safety, 

Geology, Recreation

Reduce the risk of road failures during 

storm events, maintain roads and trails 

thereafter to keep risk low, protect the 

road and trail investment, and increase 

public safety.

Restore drainage patterns on UARs not added, 

decommissioned roads and ML 1 roads.

Remove culverts and fill.

Add waterbars/rolling dips.

Water Quality, Soils, Geology, 

Wildlife, POC

Reduce/eliminate potential for water 

quality impacts.

For ML 1: restore drainage patterns to put 

ML roads into road storage category 

(hydrologically maintenance free status).

Season of use/operating period: limitations for 

use of heavy equipment.

Wet weather standards for construction (BMPs).

Noise disturbance (TES Wildlife BA).

Water Quality, Geology, Fisheries, 

Soils, POC, Wildlife TE Species

Limit ground-disturbing actions 

(decommissioning, culvert upgrades, etc.) 

to dry season.

Limit noise disturbance effects for TE 

wildlife species.

Limitations on watershed disturbance.

Road Maintenance CE.

Watershed and Fisheries Restoration Program 

BA/BO.

Water Quality, Geology, Fisheries, 

Soils

Reduce the risk of multiple grounddisturbing actions occurring that would 

lead to excess water quality concerns.

Noxious weed control mitigations.

Materials used (straw, gravel, etc.).

Eradication: survey/treat roads/UARs prior to 

decommissioning/closing.

See BMPs below.

Noxious Weeds Reduce the risk of introduction and the 

rate and spread of weed populations.

Naturally occurring asbestos (NOA).

Public education.

Speed limits.

Sign roads and trails with NOA risk as indicated 

in Appendix A.

Public Safety Air Quality, Geology, Transportation

Best Management Practices

Water quality BMPs.

Region 5 BMPs.

National BMPs.

Watershed, Geology, Fisheries, 

Soils

Reduce impacts to water quality as per the 

CWA.

Invasive plant species and aquatic organisms 

BMPs. Noxious Weeds, Aquatic Invasives Reduce the risk of introduction and the rate and spread of weed populations.
Appendix D. Mitigation Measures

Final Environmental Impact Statement – Appendices – 107

Resource Mitigations/Design Feature

Water Quality

To reduce the risk of sediment delivery to streams, all applicable best management practices (BMPs) will 

be implemented. In addition, the following design features would be implemented.

• Restoration, decommissioning, downgrading and upgrading work will occur when stream flow is 

at a minimum, typically during the summer months. Streams will be dewatered where necessary 

prior to any activity involving heavy equipment. Specific dewatering methods (pipe, pump, etc.) 

will be determined on a site-by-site basis.

• Native or straw mulch will be applied to all disturbed ground prior to seasonal rain or summer 

thunderstorms to minimize surface erosion.

• Decommissioned or restored stream channel side slopes and channel bottom gradients will be 

designed to blend with the natural channel above and below to minimize potential for unexpected 

channel adjustments.

• Large rocks will be placed in the restored stream channels where needed to protect newly created 

side slopes and reduce the potential for post-treatment channel adjustments.

• Replacement of stream crossings (upsizing) culverts will be designed to accommodate the 100-

year flood event and have no diversion potential.

Fisheries

Project implementation would be consistent with the activities described in the Watershed and Fisheries 

Restoration Program biological assessment (WFR BA; 2015). Changes to the design features listed 

within the BA would be discussed with NMFS Level 1 to ensure variations to the following design 

features would not cause an effect that was not analyzed:

• Individual projects with the potential to generate sediment would typically be implemented 

annually during the Normal Operating Season (between June 15 and November 1) or first 

significant rainfall, whichever comes first. Actual project start and end dates are based on weather 

predictions and rainfall predictions. The work window can be extended to November 15 

contingent on appropriate dry weather conditions and stream flows.

• Reduce delivery of sediment to stream network through upslope watershed restoration projects.

Road and trail related actions fall into two main categories:

• First: maintaining and upgrading the identified minimum road (and trail) transportation system as 

determined through travel management plans and implemented through past and future decisions 

across the forest to prevent existing road network from degrading such water quality impacts 

occur, and programmatic/public notice road closures. This includes:

o Upgrading undersized or worn out pipes,
Appendix D. Mitigation Measures

108 – Smith River National Recreation Area Restoration and Motorized Travel Management

o Storm-proofing by adding rolling dips to prevent diversions at stream crossings,

o Changing maintenance level of road (either increase or decrease to meet management 

objective),

o Closing roads – make the road unavailable for vehicle use, make hydrologically 

maintenance free, which could include:

 Installation of gates (for ML 1 roads and/or seasonally for POC concerns),

 Placement of boulders or earth berm/vehicle trap to prevent traffic.

o Maintaining and improving OHV and non-motorized trails to reduce sedimentation and 

could include:

 Sediment reduction work on routes not added to trail system as identified during 

travel management NEPA,

 Relocation of recreation sites/reducing impacts.

• Second: Implementing decisions to decommission system roads, trails and unauthorized routes to 

restore drainage patterns (i.e. removing culvert, re-establish vegetation, re-contour).

• Griffin Creek Bridge is a full spanning bridge and allows for full passage and will not affect 

habitat/flow conditions.

o Site containment during demolition so concrete wash water or other concrete does not 

enter stream. When concrete is poured to construct bridge footings or other infrastructure 

in the vicinity of flowing water, work must be conducted to prevent contact of wet 

concrete with water (e.g., within a cofferdam). Concrete or concrete slurry will not come 

into direct contact with flowing water.

o Falsework will be installed to keep bridge debris and construction, maintenance, and 

repair materials from falling into streams during demolition, construction, and substantial 

maintenance and repair activities.

Wildlife

Northern Spotted Owl (NSO)

Road/route upgrades, decommissioning, or restoration activities has the potential to cause noise 

disturbance to nesting NSO from loud and sustained noise-generating activities (use of heavy equipment 

machinery or chainsaws). Based on consultation with the USFWS, except for specific high priority roads 

that pose a high risk to aquatic resources scheduled for upgrades or decommissioning:

• Noise-generating activities within 0.25 miles of unsurveyed northern spotted owl nesting and 

roosting habitat will not occur between February 1 and July 9, unless surveys determine the site 

to be unoccupied.

To minimize impacts to northern spotted owl from noise-generating activities on high priority roads:
Appendix D. Mitigation Measures

Final Environmental Impact Statement – Appendices – 109

• No activities will occur between February 1 and July 31 within 0.25 miles of occupied NSO 

activity centers (AC; nest site) unless surveys determine the birds are non-nesting;

• No limited operating period (LOP) will be applied on high priority roads outside of known NSO 

ACs;

• No suitable nesting or roosting habitat will be removed;

• No large snags would be felled unless they pose a hazard to public or staff safety; and

• All hazard trees would be felled and left on site.

Marbled Murrelet (MAMU)

Road/route upgrades, decommissioning, or restoration activities has the potential to cause noise 

disturbance to nesting MAMU from loud and sustained noise-generating activities (use of heavy 

equipment machinery or chainsaws). Based on consultation with the USFWS, except for high priority 

roads that pose a high risk to aquatic resources roads:

• Noise-generating activities within 0.25 miles of unsurveyed MAMU nesting habitat will not 

occur between March 24 and August 5; and

• Work between August 5 and September 15 will not begin until 2 hours after sunrise and stop two 

hours before sunset unless surveys determine the site to be unoccupied.

To minimize impacts to MAMU from noise-generating activities on high priority roads:

• No activities will occur between March 24 and September 15 within 0.25 miles of occupied 

MAMU site unless surveys determine the birds are non-nesting;

• No LOP will be applied on high priority roads outside of known MAMU sites; and

• No suitable nesting habitat will be removed.

Port-Orford-Cedar

All mitigation measures proposed in the various alternatives, including barricades, gates, seasonal road 

closures, and road surface and drainage improvements did not factor into the initial analysis of risk. They 

were, however, included in the effects section to show how each alternative reduced the degree of risk, which 

is primarily a function of the ability to restrict motor vehicle traffic into areas that have uninfected POC.

Management action refers to mitigations put in place that would reduce the risk of disease spread. 

These include:

• Improvements to road surfaces, such as applying gravel and improving culverts,

• Seasonal gates during the wet season,

• Year-round gates where occasional use is anticipated (sup), but otherwise closed to public use, and

• Change in maintenance level – downgrade to ML 1 (closed to public use).
Appendix D. Mitigation Measures

110 – Smith River National Recreation Area Restoration and Motorized Travel Management

This indicator is being used to show the relative risk reduction of each mitigation. On a spectrum of 

the greatest risk to the least risk, unrestricted road use is the greatest risk and complete road blockage 

where motor vehicle access is not even possible is the least risk. The following diagram displays a 

continuum of risk:

Least Risk Greatest Risk

Impassable Barricade Permanent Gate Seasonal Gate Road Improvement Unrestricted Use

These management mitigation actions are not quantitative but demonstrate increased or decreased risk 

associated with spreading POC root disease when compared to one another. Using this indicator for routes 

accessing POC stands gives a relative measure of determining the quantity (acres) of POC at risk. For 

example, when comparing a route with different mitigations, a route with a permanent barrier that 

prevents motor vehicle traffic from accessing uninfected POC in a watershed would have less risk of 

introducing POC root disease beyond that point than a seasonal gate would.

Noxious Weed Control Mitigations Common to All Action Alternatives

It is recommended that the following measures be incorporated into the decision document to reduce the 

risk of weed introduction and spread:

• Identified weed sites will be removed by hand and weed propagules (seeds) shall be removed 

from the forest or burned.

• Time removal activities prior to plants producing seed to avoid spread during treatment. The 

weed species will require repeated treatment over time to remove the seed bank.

• Of particular concern, due to their persistence are the meadow knapweed on 17N16 and the tansy 

ragwort on 17N26, 17N41G.1 and 18N20.100. These species will require repeated treatment 

annually, over time, to achieve control. The most effective time to hand pull these species is when 

the ground is moist.

• Treatment in the spring, with follow up removal after the first ground soaking rains, is the most 

effective way to remove the plants in their entirety and to reduce the seed bank. Treatment shall 

reoccur annually until weed sites are eradicated.

• All routes should be monitored over time to avoid infestation.

• System roads that are proposed to have heavy equipment work such as restoration of hydrological 

function, decommissioning, barricading, or culvert replacement that have weed infestations 

should have weeds removed prior to commencing work.

• Additionally equipment used in implementation should be cleaned prior to entering the forest and, 

if weed infestations are found, equipment should be cleaned upon leaving infested roads to avoid 

dispersing the weed seed to other areas of the forest.
Appendix D. Mitigation Measures

Final Environmental Impact Statement – Appendices – 111

• Any imported mulch or other erosion control material should come from a certified weed free source.

• Identified routes proposed for closure is treated to remove weed infestations. It is recommended 

that weed sites are hand pulled prior to commencing any work leading up to closure. All sites 

noted should have certified weed free mulch (i.e. wood straw or wood chips) installed to impede 

subsequent germination of the weed seed bank. Vehicles should be cleaned to remove weed 

propagules prior to leaving site. Introduction and spread of these infestations will continue in the 

absence of mitigations. Because of their knowledge of the weed sites listed, a botanist should be 

consulted when developing an implementation plan for closure. The weed sites listed have been 

treated multiple times and are a high priority for treatment.

• Use of mulch such as wood straw or mulch from chipped or masticated native material is 

preferable to imported materials that may be weed contaminated. Ensure rock, boulders, sand or 

other material to be used for project implementation originate from a weed-free source. Sources 

for these materials shall be inspected by staff trained in invasive plant identification or 

documented by contractor that material is weed-free. Do not use borrow material from weedinfested stockpiles.

• Where determined to be appropriate, use clauses requiring contractors or permittees to clean their 

equipment prior to entering NFS lands.

USDA Forest Service – Region 5 BMPs

OHV Use and Road Construction and Maintenance

The following are the Best Management Practices (BMPs) for the control of non-point source pollution 

associated with OHV use and road maintenance activities (Regional Water Quality Management Plan, 

2000). These BMPs were formulated based on the administrative directives that guide and direct the 

Forest Services’ construction and maintenance of roads, buildings, and administrative facilities on NFS 

land. The line officer on each administrative subunit is responsible for fully implementing the directives 

that require water quality protection and improvement for maintenance of motorized trails and NFTS 

roads. The BMPs synthesize the direction into a process to be followed.

Trained and qualified earth scientists, and other professional employees, are available to provide the 

engineering work force with technical assistance to identify beneficial uses and the most recent state-ofthe-art water quality control methods and techniques; and to evaluate results. Publications and training 

sessions provide road and motorized trail maintenance engineers with knowledge of the latest proven 

water-quality protection methods.

Water Quality Monitoring of OHV Use According To a Developed Plan 

(Practice: 4-7)

Objective: To provide a systematic process to determine when and to what extent OHV use will cause, or 

is causing adverse effects on water quality.
Appendix D. Mitigation Measures

112 – Smith River National Recreation Area Restoration and Motorized Travel Management

Explanation: Each forest’s OHV plan will:

• Identify areas or routes where OHV use could cause degradation of water quality.

• Establish baseline water-quality data for normal conditions as a basis from which to measure change.

• Identify water quality standards and the amount of change acceptable.

• Establish monitoring methods and frequency.

• Identify controls and mitigation appropriate in management of OHVs.

• Restrict OHV use to designated routes.

Implementation: Monitoring results are evaluated against the OHV plan objectives for water quality and 

Forest Plan objectives for the area. These results are documented, along with the actions necessary to 

correct identified problems. If considerable adverse effects are occurring, or are likely to occur, 

immediate corrective action will be taken. Corrective actions may include, but are not limited to, 

reduction in the amount of ORV use, signing, or barriers to redistribute use, partial closure of areas, 

rotation of use on areas, closure to causative vehicle type(s), or total closure, and structural solutions, such 

as culverts and bridges. Closure is accomplished through authority of the forest supervisor.

Erosion Control Plan (Practice: 2-2)

Objective: To limit and mitigate erosion and sedimentation through effective planning prior to initiation of 

construction and maintenance activities and through effective contract administration during implementation.

Explanation: Land disturbing activities can result in short term erosion. By effectively planning for 

erosion control, sedimentation can be controlled or prevented. Within a specified period after award of a 

contract (presently 60 days prior to the first operating season in Timber Sale Contracts, per C6.3) the 

purchaser or contractor will submit a general plan which, among other things, sets forth erosion control 

measures. Operations cannot begin until the Forest Service has given written approval of the plan. The 

plan recognizes the mitigation required in the contract. A similar plan is required of miners and special 

use permittees.

Implementation: Design engineers develop detailed mitigation using an IDT. The detailed mitigations 

are reflected in the contract specifications and provisions. The intent of mitigation is to prevent 

construction and maintenance-generated erosion, as well as that generated from the completed road, from 

entering watercourses. Contracted projects are implemented by the contractor or operator. Compliance 

with contract specifications and operating plans is ensured by the Contracting Officer Representative

(COR), Engineering Representative (ER), or Forest Service Representative (FSR) through inspection.

This practice is commonly applied to all road construction through contract clauses and specifications 

and will apply to road construction and maintenance for timber sales, mining, recreation, special uses and 

other roadwork on NFS lands.
Appendix D. Mitigation Measures

Final Environmental Impact Statement – Appendices – 113

Timing of Construction Activities (Practice: 2-3)

Objective: To minimize erosion by conducting operations during minimal runoff periods.

Explanation: The amount of erosion and sedimentation from road construction are affected by the 

magnitude of water runoff. An essential element of effective erosion control is to schedule operations 

during the dry season or when rain and runoff are unlikely. Purchasers will be required to schedule and 

conduct operations during the dry season or when rain and runoff are unlikely. Purchasers will be 

required to schedule and conduct operations to minimize erosion and sedimentation. Equipment will not 

be allowed to operate when ground conditions are such that excessive rutting and soil compaction could 

result. Such conditions will be identified by the COR or ER with the assistance of an earth scientist or 

other specialists as needed.

Erosion control work will be kept as current as practicable on active road construction projects.

Construction of drainage facilities and performance of other contract work to control erosion and 

sedimentation will be required in conjunction with earthwork projects. The operator should limit the 

amount of area being graded at a site at any one time, and should minimize the time that an area is laid 

bare. Erosion control work must be kept current when road construction occurs outside of the normal 

operating season.

Implementation: Detailed mitigations developed by design engineers and an IDT will be included in the 

environmental analysis and in subsequent project plans and contracts.

Project crew leaders and supervisors will be responsible for implementing force account projects to 

construction specifications and as specified in the project plan. Contracted projects are implemented by 

the contractor, or operator. Compliance with plans, specifications, and the operating plan will be achieved 

by the COR or ER through inspection.

Control of Road Drainage (Practice: 2-7)

Objective: Is to minimize the erosive effects of water concentrated by road drainage features; to disperse 

runoff from disturbances within the road clearing limits; to lessen the sediment yield from roaded areas; 

to minimize erosion of the road prism by runoff from road surfaces and from uphill areas.

Explanation: This is a preventive practice. A number of treatments can be used, alone, or in combination, 

to control unacceptable effects of road drainage. Methods used to reduce erosion include but are not 

limited to such controls as construction of properly spaced cross drains, water bars or rolling dips; 

installing energy dissipaters, apron, downspouts, gabions, flumes, overside drains and debris racks; 

armoring of ditches, drain inlets and outlets and removing or adding berms to control runoff. Accomplish 

dispersal of runoff on the road surface by such means as rolling the grade, outsloping, or crowning.

Installing water spreading ditches or contour trenching can disperse road water after the water leaves the 

road surface.

Dispersal of runoff reduces downstream peak flows and associated scouring of the channels and sediment 

transport. Reduce sediment loads from road surfaces by adding aggregate or paving surfaces or by installing 
Appendix D. Mitigation Measures

114 – Smith River National Recreation Area Restoration and Motorized Travel Management

such controls as: sediment filters, settling ponds, and contour trenches. Soil stabilization can reduce 

sedimentation by lessening erosion on borrow and waste areas, on cut and fill slopes, and on road shoulders.

Implementation: Project location, design criteria and detailed mitigation are determined and documented 

during the environmental analysis process. These are then incorporated into the project plan.

Project crew leaders and supervisors will be responsible for ensuring that force account projects meet 

construction specifications, and project criteria. Contracted projects are implemented by the contractor, or 

operator. Compliance with plans, specifications, and operating plans is ensured by the COR, ER, or FSR.

This practice is required in contracts when the need is identified in the project planning process.

Timely Erosion Control Measures on Incomplete Roads and Stream 

Crossing Projects (Practice: 2-9)

Objective: To minimize erosion and sedimentation from disturbed ground on incomplete projects.

Explanation: The best drainage design can be ineffective if erosion control has not been completed by

the end of the normal operating season. Affected areas can include roads, road fills, tractor trails, skid 

trails, landings, stream crossings, bridge excavations, and firelines. Preventive measures include:

• Removal of temporary culverts, culvert plugs, diversion dams, or elevated stream crossings.

• Installation of temporary culverts, side drains, flumes, cross drains, diversion ditches, energy 

dissipaters, drainage or diversion dips, sediment basins, berms, debris racks, or other facilities 

needed to control erosion.

• Removal of debris, obstructions and spoil material from channels and floodplains.

• Planting vegetation, mulching, and/or covering exposed surfaces with jute mats or other 

protective material.

Implementation: Apply protective measures to all areas of disturbed, erosion-prone, unprotected ground 

that is not to be further disturbed in the present year. When conditions permit operations outside of the 

normal operating season, update the operating plan as necessary and keep erosion control measures 

sufficiently current with ground disturbance to allow rapid closure when weather conditions deteriorate.

Do not leave project areas for the winter with remedial measures incomplete.

Develop project mitigation measures and layout requirements during the environmental analysis 

process. Incorporate them into subsequent project plans and/or contracts.

Project crew leaders and supervisors are responsible for ensuring that force account projects meet 

construction specifications and project criteria. Contracted projects are implemented by the contractor or 

operator. Compliance with project plan criteria, contract specifications and operating plans is ensured by 

the COR, ER, or FSR.
Appendix D. Mitigation Measures

Final Environmental Impact Statement – Appendices – 115

Control of Sidecast Material during Construction and Maintenance 

(Practice: 2-11)

Objective: To minimize sediment production originating from sidecast material during road construction 

or maintenance.

Explanation: Unconsolidated materials including rocks and boulders that are cast over the side of the 

road shoulder can roll directly into streams, damage downslope vegetation and create bare areas that are 

difficult to stabilize with vegetation. Where spoil does not directly reach a stream, it is still highly 

susceptible to erosion, dry ravel and mass instability, and subsequently can directly deliver sediment to a 

nearby stream. Site-specific limits and controls for side casting or end hauling are developed and 

documented during environmental analysis. Loose, unconsolidated sidecast material must not be 

permitted to enter stream management zones, (see Practice 2-17).

Sidecasting is an unacceptable construction and maintenance alternative in areas where it can 

adversely impact water quality. Prior to the start of construction, or maintenance activities, waste areas 

must be located where excess material can be deposited and stabilized. During road maintenance 

operations, potential sidecast and other waste material will be utilized on the road surface or removed to 

designated disposal sites.

The roadway will be constructed within reasonable limits of the lines, grades, and dimensions given 

in the engineering drawings and designated on the ground. Provisions for waste material disposal are 

included in every road construction and maintenance contract.

Implementation: Project location, selected disposal areas, and mitigation will be developed and 

documented during the environmental analysis.

Project crew leaders and supervisors will be responsible for ensuring that force account projects meet 

construction specifications and project criteria. Road maintenance plans are developed for each forest and 

include slide and slump repairs and disposal site locations for excess material.

Contracted projects are implemented by the contractor or timber sale operator. Compliance with 

project criteria, contract specifications, and operating plans will be enforced by the COR, ER, or FSR.

Standard maintenance specifications have been prepared which include disposal area operation, disposal 

methods, and surface treatment. Timber sale contracts include clause C5.4 to address temporary road 

maintenance specifications, which includes slide and slump repair, surface blading, and side casting 

during road maintenance.

Control of Construction and Maintenance Activities Adjacent to Stream 

Management Zones (Practice: 2-13)

Objective: To protect water quality by controlling construction and maintenance actions within and 

adjacent to any streamside management zone so that the following stream management zone functions are 

not impaired:
Appendix D. Mitigation Measures

116 – Smith River National Recreation Area Restoration and Motorized Travel Management

• Acting as an effective filter for sediment generated by erosion from bare surfaces, road fills, dust 

drift, and oil traces;

• Maintaining shade, riparian habitat (aquatic and terrestrial), and channel stabilizing effects;

• Keeping the floodplain surface in a resistant, undisturbed condition to slow water velocities and 

limit erosion by flood flows.

Explanation: Construction and maintenance fills, sidecast, and end-hauled materials are kept out of 

stream management zones except at designated sites to minimize effects on the aquatic environment.

Factors such as stream class, channel stability, sideslope steepness, ground cover, and sideslope stability 

are taken into account in developing zone widths. In some situations, stream management zone widths are 

established by records of decision and by EIS standards and guidelines (e.g., PACFISH EA, Northwest 

Forest Plan ROD). It is also necessary to stabilize fill slopes to prevent sediment accumulations in the 

streamside zone.

Stream management zones are determined and documented during the environmental analysis process 

by the IDT, which includes hydrologists, fishery biologists, and other specialists as required.

Implementation: Project location alternatives are formulated, and mitigation measures developed by the 

IDT are included into the contract by design engineers. Project crew leaders and supervisors are 

responsible for ensuring that force account projects meet maintenance and construction specifications and 

project criteria.

Contracted projects are implemented by the contractor, or operator. Compliance with mitigation 

measures, contract specifications, and operating plans is ensured by the COR, FSR, or ER.

Controlling In-Channel Excavation (Practice: 2-14)

Objective: To minimize stream channel disturbances and related sediment production.

Explanation: During construction, heavy equipment may need to cross, or work in and near streams or 

lakes. This is permitted only as necessary in the construction, or removal of culverts and bridges and other 

facilities (e.g., water sources, boat ramp/launching sites) and only under specific protection requirements.

The ER is authorized to designate the location of crossings or work sites and coordinate with the 

contractor to manage heavy equipment. Excavation during the installation of instream structures must 

follow all of the following minimum water-quality protection requirements.

• Unless otherwise approved, no excavation will be made outside of caissons, cribs, cofferdams, or 

sheet piling.

• The natural streambed or lake bottom adjacent to the structure will not be disturbed without prior 

approval of the ER or COR.

• If any excavation, or dredging is made at the site of the structure before caissons, cribs, or 

cofferdams are sunk in place, all such excavations will be restored to the original surface and the 

streambed or lake bottom must be protected with suitable stable material.
Appendix D. Mitigation Measures

Final Environmental Impact Statement – Appendices – 117

• Material deposited within the stream or lake area from foundation, or other excavation will not be 

discharged directly into live streams or lakes, but will be put into settling areas as shown on the 

engineering drawings or as approved by the ER, or COR. (See Practice 2-15)

• If the channel or lake bottom is disturbed during construction, it must be restored to its original 

configuration while minimizing any additional disturbance.

• Disturbances of stream or lake banks are kept to a minimum. Disturbed banks are stabilized.

Implementation: Mitigation measures developed by the IDT are set forth in the environmental 

documentation and incorporated into the contract by design engineers. Project crew leaders and

supervisors will be responsible for ensuring that force account projects meet construction specifications 

and project criteria. Contracted projects are implemented by the contractor or operator. Compliance with 

mitigation measures, contract specifications, and operating plans is enforced by the CI, COR, FSR or ER.

USDA Forest Service National BMPs –

Water Quality Management on NFS Lands (April 2012)

Rec-4. Motorized and Non-motorized Trails

Reference: FSM 2353, FSH 2309.18, FSM 7715.5, FSM 7723 and EM 7720-104

Objective: Avoid, minimize or mitigate adverse effects to soil, water quality and riparian resources by 

controlling soil erosion, erosion of trail surface materials and water quality problems originating from 

construction, maintenance and use of motorized and non-motorized trails.

Explanation: The Forest Service manages about 133,000 miles of trails that are part of the designated 

transportation system. Only portions of these trails are open to motorized vehicle use. Almost all NFS 

trails serve non-motorized users, including hikers, bicyclists and equestrians, alone or in some 

combination with motorized uses.

Trail construction, maintenance and use by motorized vehicles, human or stock traffic can adversely 

affect water quality by increased sediment delivery and contamination from vehicle fluids, human and 

animal wastes to nearby waterbodies. Compaction of the trail surface limits water infiltration, which can 

lead to concentrated runoff on the trail surface. Concentrated runoff on trails lacking adequate drainage 

causes erosion of the trail surface and can transport sediment and other pollutants directly into 

waterbodies if not filtered. Heavy tread, foot or hoof traffic can loosen some trail surface materials, 

making them more susceptible to erosion.

Trails open to motorized use are designated during the Travel Management process and depicted on 

the Motor Vehicle Use Map (MVUM). Motorized use is designated by allowed vehicle class and, if 

appropriate, time of year, with the objective of minimizing damage to soil and water resources.
Appendix D. Mitigation Measures

118 – Smith River National Recreation Area Restoration and Motorized Travel Management

Practices: Develop site-specific BMP prescriptions for the following practices, as appropriate or when 

required, using state BMPs, Forest Service regional guidance, Forest or Grassland Plan direction, BMP 

monitoring information and professional judgment:

• Use applicable Road Management Activities BMPs for construction, operation and maintenance 

of motorized trails.

• Locate or relocate trails to conform to the terrain, provide suitable drainage, provide adequate 

pollutant filtering between the trail and nearby waterbodies, and reduce potential adverse effects 

to soil, water quality or riparian resources.

o Avoid sensitive areas, such as riparian areas, wetlands, stream crossings, inner gorges and 

unstable areas to the extent practicable.

o Use suitable measures to mitigate trail impacts to the extent practicable where sensitive 

areas are unavoidable.

o Use suitable measures to hydrologically disconnect trails from waterbodies to the extent 

practicable.

• Design, construct and maintain trail width, grades, curves and switchbacks suitable to the terrain 

and designated use.

• Use applicable practices of BMP Fac-2 (Facility Construction and Stormwater Control) for 

control of erosion and stormwater when constructing trails.

• Install and maintain suitable drainage measures to collect and disperse runoff and avoid or 

minimize erosion of trail surface and adjacent areas.

• Use and maintain surfacing materials suitable to the trail site and use to withstand traffic and 

minimize runoff and erosion.

o Pay particular attention to areas where high wheel slip (curves, acceleration and/or 

braking) during motorized use generates loose soil material.

• Design stream crossings to use the most cost efficient structure consistent with resource 

protection, facility needs and types of use, and safety obligations (see BMP Road-2 (Road 

Location and Design) and BMP Road-7 (Stream Crossings)).

• Designate season-of-use to avoid periods when trail surfaces are particularly prone to 

unacceptable erosion, rutting or compaction.

• Designate class of vehicle and type of non-motorized uses (e.g., hiking, bicycling, equestrian,) 

suitable for the trail width, location, waterbody crossings and trail surfaces to avoid or minimize 

adverse effects to soil, water quality or riparian resources.

• Monitor trail condition at regular intervals to identify drainage and trail surface maintenance needs to 

avoid, minimize, or mitigate adverse effects to soil, water quality, and/or riparian resources.
Appendix D. Mitigation Measures

Final Environmental Impact Statement – Appendices – 119

• Manage designated trails to mitigate adverse effects to soil, water quality and/or riparian 

resources from over-use when closure and rehabilitation is not practicable or desired.

o Change designated vehicle class and/or season-of-use period as necessary.

• Close and rehabilitate unauthorized trails that are causing adverse effects on soil, water quality 

and/or riparian resources (see BMP Fac-10 (Facility Site Reclamation)).

Road-1. Travel Management Planning and Analysis

Reference: FSM 7710, FSH 7709.55 and FSH 7709.59 Chapter 10

Objective: Use the travel management planning and analysis processes to develop measures to avoid, 

minimize or mitigate adverse effects to soil, water quality and riparian resources during road management 

activities.

Explanation: Road management related planning includes travel analyses as well as consideration of road 

management objectives and maintenance levels to address access needs and adjustments for projects.

Planning occurs at scales that range from forest-wide assessments and plans, to watershed scale or project 

level analyses, to individual road activities. Effects to soil, water quality and riparian resources are 

evaluated during planning and balanced with the social, economic, and land management needs of the 

area. Appropriate protection and mitigation measures are considered when soil, water quality and riparian 

resources may be adversely impacted.

Travel analysis is conducted at a scope and scale determined by the line officer, and used to inform 

future project decisions on the benefits and risks, and the ongoing need for, the transportation system.

Project-level travel analyses are conducted to inform decisions and facilitate vegetation, fire and fuels, 

rangeland, recreation, minerals or other management actions. Such analyses contain detail on the 

condition of individual roads.

Road management objectives are developed and documented for each system road and include the 

intent and purpose in providing access to implement the Forest or Grassland Plan. In addition to 

considering route needs at the site scale, road management objectives also document the purpose of the 

road (access needs) along with maintenance levels and objectives.

Practices: Develop site-specific BMP prescriptions for the following practices, as appropriate or when 

required, using state BMPs, Forest Service regional guidance, Forest or Grassland Plan direction, BMP 

monitoring information and professional judgment:

• Use applicable practices of BMP Plan-2 (Project Planning and Analysis) and BMP Plan-3 (AMZ 

Planning) when conducting travel management planning and analysis.

• Use interdisciplinary coordination for travel planning and project-level transportation analysis, 

including engineers, hydrologists, soil scientists and other resource specialists as needed, to balance 

protection of soil, water quality and riparian resources with transportation and access needs.
Appendix D. Mitigation Measures

120 – Smith River National Recreation Area Restoration and Motorized Travel Management

• Design the transportation system to meet long-term Forest or Grassland Plan desired conditions, 

goals and objectives for access rather than to access individual sites.

• Limit roads to the minimum practicable number, width and total length consistent with the 

purpose of specific operations, local topography, geology, and climate to achieve Forest or 

Grassland Plan desired conditions, goals and objectives for access and water quality management.

o Use existing roads when practicable.

o Use system roads where access is needed for long-term management of an area or where 

control is needed in the location, design or construction of the road to avoid, minimize or 

mitigate adverse effects to soil, water quality and riparian resources.

o Use temporary roads for short-term access needs if the road can be constructed, operated 

and obliterated without specific control of techniques to avoid, minimize or mitigate 

adverse effects to soil, water quality and riparian resources (See BMP Road-5 

(Temporary Roads)).

o Decommission temporary roads and return to resource production when the access is no 

longer needed (See BMP Road-6 (Road Storage and Decommissioning)).

o Consider placing roads in storage (ML 1) when the time between intermittent uses exceeds 

one year and the costs of annual maintenance (both economic and potential disturbance) or 

potential failures due to lack of maintenance, exceed the benefits of keeping the road open 

in the interim (See BMP Road-6 (Road Storage and Decommissioning)).

o Consider decommissioning unneeded existing roads within a planning area when 

planning new system roads to reduce cumulative impacts to soil, water quality and 

riparian resources (See BMP Road-6 (Road Storage and Decommissioning)).

• Plan road networks to have the minimum number of waterbody crossings as is practicable and 

necessary to achieve transportation system desired conditions, goals and objectives.

• Develop or update road management objectives for each system road to include design criteria, 

operation criteria and maintenance criteria to avoid, minimize or mitigate adverse effects to soil, 

water quality and riparian resources.

o Use applicable practices of BMP Road-2 (Road Location and Design) to establish design 

elements and standards.

o Use applicable practices of BMP Road-4 (Road Operations and Maintenance) to establish 

criteria on how the road is to be operated and maintained.

o Revise road management objectives as needed to meet changing conditions.

• Identify and evaluate road segments causing, or with the potential to cause, adverse effects to soil, 

water quality and/or riparian resources.
Appendix D. Mitigation Measures

Final Environmental Impact Statement – Appendices – 121

o Identify and prioritize suitable mitigation measures to avoid, minimize or mitigate 

adverse effects (see BMPs Road-2 (Road Location and Design), Road-3 (Road 

Construction and Reconstruction), Road-4 (Road Operations and Maintenance), Road-6 

(Road Storage and Decommissioning), and Road-7 (Stream Crossings) for potential 

mitigation measures).

Road-4. Road Operations and Maintenance

Reference: FSM 7732 and FSH 7709.59 Chapter 60

Objective: 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.

Explanation: Control of road use and operations, and appropriate maintenance can protect road 

investment and soil, water quality and riparian resources. Periodic inventory and assessment that 

determine road condition are used to determine operational controls and maintenance needs.

Operational objectives and activities are documented in the road management objective. In Travel 

Management decisions, roads open to motorized vehicle use are designated by allowed vehicle class and, 

if appropriate, by time of year. Road operations include permit, contract, and agreement administration, 

control of allowed use, maintaining roads in closed status and revising maintenance levels and seasonal 

closures as needed. Road closures and restrictions are necessary because many forest roads are designed 

for dry season use. Many local roads are not surfaced; while others have some surfacing but little to no 

base. Such roads can be damaged by use during wet periods or by loads heavier than the road was 

designed to convey.

Properly maintained road surfaces and drainage systems can reduce adverse effects to water resources 

by encouraging natural hydrologic function. Roads and drainage systems normally deteriorate because of 

traffic, weather, and age. In addition, roads occasionally become saturated by groundwater springs and seeps 

after a wildfire or unusually wet periods. Many such conditions can be corrected by timely maintenance.

However, while routine maintenance is needed to ensure the road performs as designed, it can also be a 

source of soil disturbance, concentrated flow, sediment production and slope instability if done improperly.

Lower impact maintenance techniques may be desired to minimize disturbance of stable sites.

Practices: Develop site-specific BMP prescriptions for the following practices, as appropriate or when 

required, using state BMPs, Forest Service regional guidance, Forest or Grassland Plan direction, BMP 

monitoring information and professional judgment:

Operations

• Designate season-of-use to avoid or restrict road use during periods when use would likely 

damage the roadway surface or road drainage features.
Appendix D. Mitigation Measures

122 – Smith River National Recreation Area Restoration and Motorized Travel Management

• Designate class of vehicle and type of uses suitable for the road width, location, waterbody 

crossings and road surfaces to avoid or minimize adverse effects to soil, water quality or riparian 

resources to the extent practicable.

• Use suitable measures to communicate and enforce road use restrictions.

• Use suitable measures to avoid or minimize adverse effects to soil, water quality or riparian 

resources when proposed operations involve use of roads by traffic and/or during periods for 

which the road was not designed.

o Strengthen the road surface in areas where surfaces are vulnerable to movement such as 

corners and steep sections.

o Upgrade drainage structures to avoid, to the extent practicable, or minimize direct 

discharges into nearby waterbodies.

o Restrict use to low-ground-pressure vehicles or frozen ground conditions.

o Strengthen the road base if roads are tending to rut.

o Adjust maintenance to handle the traffic while minimizing excessive erosion and damage 

to the road surface.

• Ensure that drainage features are fully functional upon completion of seasonal operations.

o Shape road surfaces to drain as designed.

o Construct or reconstruct drainage control structures as needed.

o Ensure that ditches and culverts are clean and functioning.

o Remove berms unless specifically designed for erosion control purposes.

• Consider potential for water quality effects from road damage when granting permits for 

oversize/overweight loads.

• Use suitable road surface stabilization practices and dust abatement supplements on roads with 

high/heavy traffic use (See FSH 7709.56 and FSH 7709.59).

• Use applicable practices of Chemical Use Management Activities BMPs when chemicals are used 

in road operations.

Inspection

• Periodically inspect system travel routes to evaluate condition and assist in setting maintenance 

and improvement priorities.

o Give inspection priority to roads at high risk of failure to reduce risk of diversions and 

cascading failures.

• Inspect drainage structures and road surfaces after major storm events and perform any necessary 

maintenance (see BMP Road-11 (Road Storm-Damage Surveys)).
Appendix D. Mitigation Measures

Final Environmental Impact Statement – Appendices – 123

o Repair and/or temporarily stabilize road failures actively producing and/or transporting 

sediment as soon as practicable and safe to do so.

• Inspect roads frequently during all operations.

o Restrict use if road damage such as unacceptable surface displacement or rutting is 

occurring.

Maintenance Planning

• Develop and implement annual maintenance plans that prioritize road maintenance work for the 

forest or district.

o Increase priority for road maintenance work on road sections where road damage is causing, 

or potentially would cause, adverse effects to soil, water quality and riparian resources.

o Consider the risk and consequence of future failure at the site when prioritizing repair of 

road failures.

• Develop and implement annual road maintenance plans for projects where contractors or 

permittees are responsible for maintenance activities.

o Define responsibilities and maintenance timing in the plan.

Maintenance Activities

• Maintain the road surface drainage system to intercept, collect and remove water from the road 

surface and surrounding slopes in a manner that reduces concentrated flow in ditches, culverts 

and over fill slopes and road surfaces.

o Clean ditches and catch basins only as needed to keep them functioning.

o Do not undercut the toe of the cut slope when cleaning ditches or catch basins.

o Use suitable measures to avoid, to the extent practicable, or minimize direct discharges 

from road drainage structures to nearby waterbodies.

• Identify diversion potential on roads and prioritize for treatment.

o Minimize diversion potential through installation and maintenance of dips, drains or other 

suitable measures.

• Maintain road surface treatments to stabilize the roadbed, reduce dust, and control erosion 

consistent with anticipated traffic and use.

• Grade road surfaces only as necessary to meet the smoothness requirements of the assigned

maintenance level and to provide adequate surface drainage.

o Do not undercut the toe of the cut slope when grading roads.

o Do not permit sidecasting of maintenance-generated debris within the AMZ to avoid or 

minimize excavated materials entering waterbodies or riparian areas.
Appendix D. Mitigation Measures

124 – Smith River National Recreation Area Restoration and Motorized Travel Management

o Avoid over-widening of roads due to repeated grading over time especially where 

sidecast material would encroach upon waterbodies.

o Utilize potential sidecast or other waste materials on the road surface where practicable.

o Dispose of unusable waste materials in designated disposal sites.

• Remove vegetation from swales, ditches, shoulders, and cut and fill slopes only when it impedes 

adequate drainage, vehicle passage or obstructs necessary sight distance to avoid or minimize 

unnecessary or excessive vegetation disturbance.

• Maintain permanent stream crossings and associated fills and approaches to reduce the likelihood 

that water would be diverted onto the road or erode the fill if the structure becomes obstructed.

• Identify waterbody-crossing structures that lack sufficient capacity to pass expected flows, bedload 

or debris, or that do not allow for desired aquatic organism passage, and prioritize for treatment.

o Use applicable practices of BMP Road-7 (Stream Crossings) to improve crossings.

• Use applicable practices of BMP Road-6 (Road Storage and Decommissioning) for maintenance 

and management of Maintenance Level 1 roads.

• Assure the necessary specifications concerning pre-haul maintenance, maintenance during haul, 

and post haul maintenance (putting the road back in storage) are in place when ML 1 roads are 

opened for use on commercial resource management projects or other permitted activities.

o Require the commercial operator or responsible party to leave roads in a satisfactory 

condition when project is completed.

Road-6. Road Storage and Decommissioning

Reference: FSH 7709.59 Chapter 60 and FSM 7734

Objective: Avoid, minimize or mitigate adverse effects to soil, water quality and riparian resources by 

storing closed roads not needed for at least one 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.

Explanation: Roads not needed for access for long periods (greater than one year) may be put into 

storage (Intermittent Stored Service – ML 1) to reduce maintenance costs. Level 1 roads receive basic 

custodial maintenance focusing on maintaining drainage facilities and runoff patterns to avoid or 

minimize damage to adjacent resources and to perpetuate the road for future use. The integrity of the 

roadway is retained to the extent practicable and measures are implemented reduce sediment delivery 

from the road surface and fills and reduce the risk of crossing failure and stream diversion.

Roads no longer needed are identified during transportation planning activities at the forest, 

watershed or project level. The former road may be decommissioned or converted to a trail as appropriate.

Decommissioned roads are stabilized and restored to a more natural state to protect and enhance NFS 
Appendix D. Mitigation Measures

Final Environmental Impact Statement – Appendices – 125

lands. Temporary roads constructed for a specific short-term purpose (e.g., ski area development, minerals 

exploration, timber harvesting) are decommissioned at the completion of their intended use.

Road decommissioning includes a variety of treatments to block the road, revegetate the road surface, 

restore surface drainage, remove crossing structures and fills, mitigate road surface compaction, reestablish 

drainageways, remove unstable road embankments and/or recontour to restore natural slopes. One or more 

treatments are applied to decommission the road depending upon resource objectives and cost.

Practices: Develop site-specific BMP prescriptions for the following practices, as appropriate or when 

required, using state BMPs, Forest Service regional guidance, Forest or Grassland Plan direction, BMP 

monitoring information and professional judgment:

All Activities

• Implement suitable measures to close and/or physically block the road entrance so that 

unauthorized motorized vehicles cannot access the road.

o Remove the road from the MVUM to include the change in the annual forest-wide order 

associated with the MVUM.

• Establish effective ground cover on disturbed sites to avoid or minimize accelerated erosion and 

soil loss.

o Use suitable species and establishment techniques to stabilize and revegetate the site in 

compliance with local direction and requirements per FSM 2070 and FSM 2080 for 

vegetation ecology and prevention and control of invasive species.

Road Storage

• Evaluate all stream and waterbody crossings for potential for failure or diversion of flow if left 

without treatment.

o Use suitable measures to reduce the risk of flow diversion onto the road surface.

o Consider leaving existing crossings in low risk situations where the culvert is not 

undersized, does not present an undesired passage barrier to aquatic organisms and is 

relatively stable.

o Remove culverts; fill material and other structures that present an unacceptable risk of 

failure or diversion.

o Reshape the channel and streambanks at the crossing-site to pass expected flows without 

scouring or ponding, minimize potential for undercutting or slumping of streambanks, 

and maintain continuation of channel dimensions and longitudinal profile through the 

crossing site.

o Use suitable measures to avoid or minimize scour and downcutting.

• Use suitable measures to ensure that the road surface drainage system will intercept, collect and 

remove water from the road surface and surrounding slopes in a manner that reduces concentrated 

flow in ditches, culverts and over fill slopes and road surfaces without frequent maintenance.
Appendix D. Mitigation Measures

126 – Smith River National Recreation Area Restoration and Motorized Travel Management

• Use suitable measures to stabilize unstable road segments, seeps, slumps, or cut or fill slopes 

where there is evidence of potential failure.

Road Conversion to Trail

• Reclaim unneeded road width, cut and fill slopes when converting a road for future use as a trail.

• Use suitable measures to stabilize reclaimed sections to avoid or minimize undesired access and 

to restore a desired ecologic structures or functions.

• Use suitable measures to ensure that surface drainage will intercept, collect and remove water 

from the trail surface and surrounding slopes in a manner that minimizes concentrated flow and 

erosion on the trail surfaces without frequent maintenance.

• Use applicable practices of BMP Road-7 (Stream Crossings) to provide waterbody crossings 

suitable to the expected trail uses.

Road Decommissioning

• Use existing roads identified for decommissioning as skid roads in timber sales or land 

stewardship projects prior to closing the road where practicable as the opportunity arises.

• Evaluate risks to soil, water quality and riparian resources and use the most practicable, costeffective treatments to achieve long-term desired conditions and water-quality management goals 

and objectives.

• Use applicable practices of BMP Fac-2 (Facility Construction and Stormwater Control) for 

stormwater management and erosion control when obliterating system roads.

• Implement suitable measures to re-establish stable slope contours, and surface and subsurface 

hydrologic pathways where necessary to the extent practicable to avoid or minimize adverse 

effects to soil, water quality and riparian resources.

o Remove drainage structures.

o Recontour and stabilize cut slopes and fill material.

o Reshape the channel and streambanks at crossing-sites to pass expected flows without 

scouring or ponding, minimize potential for undercutting or slumping of streambanks, 

and maintain continuation of channel dimensions and longitudinal profile through the 

crossing site.

o Restore or replace streambed materials to a particle size distribution suitable for the site.

o Restore floodplain function.

• Implement suitable measures to promote infiltration of runoff and intercepted flow and/or desired 

vegetation growth on the road prism and other compacted areas.

• Use suitable measures in compliance with local direction to prevent and control invasive species.
Appendix D. Mitigation Measures

Final Environmental Impact Statement – Appendices – 127

Road-7. Stream Crossings

Reference: FSM 7722 and FSH 7709.56b

Objective: Avoid, minimize or mitigate adverse effects to soil, water quality and riparian resources when 

constructing, reconstructing or maintaining temporary and permanent waterbody crossings.

Explanation: Forest and grassland management activities often occur in areas that require surface waters 

to be crossed. Depending on the activity type and duration, crossings may be needed permanently or 

temporarily. Permanent crossings are generally more durable and are designed by an engineer to meet 

applicable standards while also protecting water quality and riparian resources.

Examples of crossings include culverts, bridges, arched pipes, low water crossings, vented fords and 

permeable fills. Crossings materials and construction will vary based on the type of access required, 

duration of need and volume of use expected. Crossings should be designed and installed to provide for 

flow of water, bedload and large woody debris, desired aquatic organism passage, and minimize 

disturbance to the surface and shallow groundwater resources.

Construction, reconstruction and maintenance of a crossing usually requires heavy equipment to be in 

and near streams, lakes and other aquatic habitats to install or remove culverts, fords and bridges and their 

associated fills, abutments, piles, and cribbing. Such disturbance near the waterbody can increase the 

potential for accelerated erosion and sedimentation by altering flow paths and destabilizing streambanks 

or shorelines, removing vegetation and ground cover, and exposing or compacting the soil. Use of heavy 

equipment has a potential for contamination of the surface water from vehicle fluids or introduction of 

aquatic nuisance species.

Some crossings may require adherence to special conditions associated with CWA 401 Certification 

or CWA 404 permits. State and local entities may also provide guidance and regulations such as a Forest 

Practices Act or a Stream Alteration Act.

Practices: Develop site-specific BMP prescriptions for the following practices, as appropriate or when 

required, using state BMPs, Forest Service regional guidance, Forest or Grassland Plan direction, BMP 

monitoring information and professional judgment:

All Crossings

• Plan and locate surface water crossings to limit the number and extent to that which is necessary 

to provide the level of access needed to meet resource management objectives as described in the 

road management objective.

• Use applicable practices of BMP AqEco-2 (Operations in Aquatic Ecosystems) when working in 

or near waterbodies.

• Use crossing structures suitable for the site conditions and the road management objective.

• Design and locate crossings to minimize disturbance to the waterbody.

• Use suitable measures to locate, construct and decommission or stabilize bypass roads to avoid, 

minimize or mitigate adverse effects to soil, water quality and riparian resources.
Appendix D. Mitigation Measures

128 – Smith River National Recreation Area Restoration and Motorized Travel Management

• Use suitable surface drainage and roadway stabilization measures to disconnect the road from the 

waterbody to avoid or minimize water and sediment from being channeled into surface waters 

and to dissipate concentrated flows.

• Use suitable measures to avoid, minimize or mitigate damage to the waterbody and banks when 

transporting materials across the waterbody or AMZ during construction activities.

Stream Crossings

• Locate stream crossings where the channel is narrow, straight and uniform, has stable soils and 

relatively flat terrain to the extent practicable.

o Select a site where erosion potential is low.

o Orient the stream crossing perpendicular to the channel to the extent practicable.

o Keep approaches to stream crossings to as gentle a slope as practicable.

o Consider natural channel adjustments and possible channel location changes over the 

design life of the structure.

• Design the crossing to pass a normal range of flows for the site.

o Design the crossing structure to have sufficient capacity to convey the design flow 

without appreciably altering stream flow characteristics.

o Install stream crossings to sustain bankfull dimensions of width, depth and slope, and 

maintain streambed and bank resiliency and continuity through the structure.

• Bridge, culvert or otherwise design road fill to prevent restriction of flood flows.

o Use site conditions and local requirements to determine design flood flows.

o Use suitable measures to protect fill from erosion and to avoid or minimize failure of the 

crossing at flood flows.

o Use suitable measures to provide floodplain connectivity to the extent practicable.

• Use suitable measures to avoid or minimize scour and erosion of the channel, crossing structure 

and foundation to maintain the stability of the channel and banks.

• Design and construct the stream crossing to maintain the desired migration or other movement of 

fish and other aquatic life inhabiting the waterbody.

o Consider use of bottomless arch culverts where appropriate to allow for natural channel 

migration and desired aquatic organism passage.

o Install or maintain fish migration barriers only where needed to protect endangered, 

threatened, sensitive, or unique native aquatic populations, and only where natural 

barriers do not exist.

o Use stream simulation techniques where practicable to aid in crossing design.
Appendix D. Mitigation Measures

Final Environmental Impact Statement – Appendices – 129

Bridges

• Use an adequately long bridge span to avoid constricting the natural active flow channel and 

minimize constriction of any overflow channel.

• Place foundations onto non-scour susceptible material (e.g., bedrock or coarse rock material) or 

below the expected maximum depth of scour.

• Set bridge abutments or footings into firm natural ground (e.g., not fill material or loose soil) 

when placed on natural slopes.

• Use suitable measures as needed in steep, deep drainages to retain approach fills or use a 

relatively long bridge span.

• Avoid placing abutments in the active stream channel to the extent practicable.

• Place in-channel abutments in a direction parallel to the stream flow where necessary.

• Use suitable measures to avoid or minimize, to the extent practicable, damage to the bridge and 

associated road from expected flood flows and floating debris and bedload.

• Inspect the bridge at regular intervals and perform maintenance as needed to maintain the 

function of the structure.

Culverts

• Align the culvert with the natural stream channel.

• Cover culvert with sufficient fill to avoid or minimize damage by traffic.

• Construct at or near natural elevation of the streambed to avoid or minimize potential flooding 

upstream of the crossing and erosion below the outlet.

• Install culverts long enough to extend beyond the toe of the fill slopes to minimize erosion.

• Use suitable measures to avoid or minimize water from seeping around the culvert.

• Use suitable measures to avoid or minimize culvert plugging from transported bedload and/or debris.

• Regularly inspect culverts and clean as necessary.

Low Water Crossings

• Consider low water crossings on roads with low traffic volume and slow speeds, and where water 

depth is safe for vehicle travel.

• Consider low water crossings to cross ephemeral streams, streams with relatively low baseflow 

and shallow water depth or streams with highly variable flows or in areas prone to landslides or 

debris flows.

• Locate low water crossings where streambanks are low with gentle slopes and channels are not 

deeply incised.

• Select and design low water crossing structures to maintain the function and bedload movement 

of the natural stream channel.
Appendix D. Mitigation Measures

130 – Smith River National Recreation Area Restoration and Motorized Travel Management

• Locate unimproved fords in stable reaches with a firm rock or gravel base that has sufficient load 

bearing strength for the expected vehicle traffic.

• Construct the low water crossing to conform to the site, channel shape and original streambed 

elevation, and to minimize flow restriction, site disturbance and channel blockage to the extent 

practicable.

• Use suitable measures to stabilize/harden the streambed and approaches, including the entire

bankfull width and sufficient freeboard, where necessary to support the design vehicle traffic.

• Use vented fords with high vent area ratio (VAR) to maintain stream function and aquatic 

organism passage.

• Construct the roadway-driving surface with material suitable to resist expected shear stress or 

lateral forces of water flow at the site.

o Consider using temporary crossings on roads that provide short-term or intermittent access 

to avoid, minimize or mitigate erosion, damage to streambed or channel and flooding.

• Design and install temporary crossings suitable for the expected users, loads and timing of use.

• Design and install temporary crossing structures to pass a design storm determined based on local 

site conditions and requirements.

• Install and remove temporary crossing structures in a timely manner as needed to provide access 

during use periods and minimize risk of washout.

• Use suitable measures to stabilize temporary crossings that must remain in place during high 

runoff seasons.

• Monitor temporary crossings regularly while installed to evaluate condition.

• Remove temporary crossings and restore the waterbody profile and substrate when the need for 

the crossing no longer exists.

Standing Water and Wetland Crossings

• Disturb the least amount of area as practicable when crossing a standing waterbody.

• Provide for sufficient cross drainage to minimize changes to, and avoid restricting, natural surface 

and subsurface water flow of the wetland under the road to the extent practicable.

o Locate and design roads or road drainage to avoid dewatering or polluting wetlands.

o Avoid or minimize actions that would significantly alter the natural drainage for flow 

patterns on forestlands immediately adjacent to wetlands.

• Use suitable measures to increase soil-bearing capacity and reduce rutting from expected vehicle 

traffic.

• Construct fill roads only when necessary.
Appendix D. Mitigation Measures

Final Environmental Impact Statement – Appendices – 131

o Construct fill roads parallel to water flow and to be as low to natural ground level as 

practicable.

o Construct roads with sufficient surface drainage for surface water flows.

Road-9. Parking and Staging Areas

Reference: FSM 7710, FSM 7720 and FSM 7730

Objective: Avoid, minimize or mitigate adverse effects to soil, water quality and riparian resources when 

constructing and maintaining parking and staging areas.

Explanation: Parking and staging areas on NFS lands may be permanent or temporary and are associated 

with a variety of uses including administrative buildings, developed recreation sites, trailheads, and forest 

management projects. These parking facilities sometimes constitute large areas with little or no 

infiltration capacity. Runoff from these areas can create rills or gullies and carry sediment, nutrients and 

other pollutants to nearby surface waters.

Practices: Develop site-specific BMP prescriptions for the following practices, as appropriate or when 

required, using state BMPs, Forest Service regional guidance, Forest or Grassland Plan direction, BMP 

monitoring information and professional judgment:

• Design and locate parking and staging areas of appropriate size and configuration to 

accommodate expected vehicles and avoid or minimize adverse effects to adjacent soil, water 

quality and riparian resources.

o Consider the number and type of vehicles to determine parking or staging area size.

• Use applicable practices of BMP Fac-2 (Facility Construction and Stormwater Control) for 

stormwater management and erosion control when designing, constructing, reconstructing or 

maintaining parking or staging areas.

• Use suitable measures to harden and avoid or minimize damage to parking area surfaces that 

experience heavy use or are used during wet periods.

• Use and maintain suitable measures to collect and contain oil and grease in larger parking lots 

with high use and where drainage discharges directly to streams.

• Connect drainage system to existing stormwater conveyance systems where available and 

practicable.

• Conduct maintenance activities commensurate with parking or staging area surfacing and 

drainage requirements as well as precipitation timing, intensity and duration.

• Limit the size and extent of temporary parking or staging areas.

o Take advantage of existing openings, sites away from waterbodies and areas that are apt 

to be more easily restored to the extent practicable.
Appendix D. Mitigation Measures

132 – Smith River National Recreation Area Restoration and Motorized Travel Management

o Use temporary stormwater and erosion control measures as needed.

o Use applicable practices of BMP Fac-10 (Facility Site Reclamation) to rehabilitate 

temporary parking or staging areas as soon as practicable following use.

Road-10. Equipment Refueling and Servicing

Reference: FSM 2160 and FSH 7109.19 Chapter 40

Objective: 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.

Explanation: Many activities require the use and maintenance of petroleum-powered equipment in the 

field. For example, mechanical vegetation management activities may employ equipment that uses or 

contains gasoline, diesel, oil, grease, hydraulic fluids, antifreeze, coolants, cleaning agents, and/or 

pesticides. These petroleum and chemical products may pose a risk to contaminating soils, surface water 

and groundwater during refueling and servicing the equipment. BMP Fac-6 (Hazardous Materials) 

provides additional guidance for handling hazardous materials.

Practices: Develop site-specific BMP prescriptions for the following practices, as appropriate or when 

required, using state BMPs, Forest Service regional guidance, Forest or Grassland Plan direction, BMP

monitoring information and professional judgment:

• Plan for suitable equipment refueling and servicing sites during project design.

o Allow temporary refueling and servicing only at approved locations, located well away 

from the AMZ, groundwater recharge areas and waterbodies.

• Develop or use existing fuel and chemical management plans (e.g., SPCC, spill response plan, 

emergency response plan) when developing the management prescription for refueling and 

servicing sites.

• Locate, design, construct and maintain petroleum and chemical delivery and storage facilities 

consistent with applicable local, state and federal regulations.

• Use suitable measures around vehicle service, storage and refueling areas, chemical storage and 

use areas, and waste dumps to fully contain spills and avoid or minimize soil contamination and 

seepage to groundwater.

• Provide training for all agency personnel handling fuels and chemicals in their proper use, 

handling, storage and disposal.

o Ensure that contractors and permit holders provide documentation of proper training in 

handling hazardous materials.

• Use suitable measures to avoid spilling fuels, lubricants, cleaners and other chemicals during 

handling and transporting.
Appendix D. Mitigation Measures

Final Environmental Impact Statement – Appendices – 133

• Prohibit excess chemicals or wastes from being stored or accumulated in the project area.

• Remove service residues, used oil and other hazardous or undesirable materials from NFS land 

and properly dispose them as needed during and following completion of the project.

• Clean up and dispose of spilled materials according to specified requirements in the appropriate 

guiding document.

• Report spills and initiate suitable clean-up action in accordance with applicable state and federal 

laws, rules and regulations.

o Remove contaminated soil and other material from NFS lands and dispose of this 

material in a manner consistent with controlling regulations.

• Prepare and implement a certified SPCC Plan for each facility, including mobile and portable 

facilities, as required by federal regulations.

• Use applicable practices of BMP Fac-10 (Facility Site Reclamation) to reclaim equipment 

refueling and services site when the need for them ends.

Invasive Plant Species and Aquatic Organisms BMPs

The Forest Service National Strategic Framework for Invasive Species Management (USDA 2013; 

framework) was developed in 2004 and updated in 2013 to guide the implementation of Executive Order 

13112 and Forest Service Policy (FSM 2900) (Appendix A of the framework). The framework provides 

strategic direction for all Forest Service programs and outlines four key elements necessary to respond to the 

threat of invasive species on ecosystems. The four elements of the Invasive Species Systems Approach

(ISSA) are a) prevention, b) detection, c) control and management, and d) restoration and rehabilitation.

Prevention and early detection and rapid response are the most strategic, and thus effective, elements 

in the framework to reduce the risk of invasive species introduction and spread. Prevention requires 

integrated planning and implementation across all forest activities. Early detection requires personnel 

trained in invasive species threats, identification and effective treatment techniques, as well as the 

infrastructure to coordinate reporting and documentation of occurrences. The framework identifies the 

following actions for prevention:

• Identify, forecast, and prioritize invasive species threats,

• Identify high-risk pathways of movement and introduction,

• Identify vulnerable ecosystems,

• Improve cooperative efforts, and

• Recommend, program, and implement appropriate actions to prevent introductions and spread.

Since 2001, the SRNF has had in place a standardized method assessing the risk of introducing or 

spreading invasive plant species related to proposed actions (USFS 2001). The SRNF’s Invasive Plant 

Species Risk Assessment uses a standard methodology to analyze ground-disturbing projects for the risk 
Appendix D. Mitigation Measures

134 – Smith River National Recreation Area Restoration and Motorized Travel Management

of introducing or spreading invasive plant species, emphasizing those invasive species considered a 

priority on the forest by virtue of a particular species’ distribution, abundance and geographic location.

Risk is evaluated in the assessment based five factors: 1) presence of known invasive plant species in the 

project area, 2) habitat vulnerability, 3) non-project-dependent vectors such as existing roads or trails, 

adjacent private property, 4) habitat alteration expected as a result of project implementation, and 5) 

increased vectors as a result of project implementation.

In order to more fully implement the 2013 framework and associated law and policy, to improve 

coordination between all Six Rivers’ program areas and administrative units, and to provide invasive 

species prevention practices applicable to various forest and contractor activities, the following BMPs have 

been developed including one overarching prevention practice relative to aquatic invasive organisms.

The invasive plant BMPS are consistent with, if not directly drawn from Preventing the Spread of 

Invasive Plants: Best Management Practices for Land Managers, 3rd Edition (Cal-IPC 2012), developed 

by the California Invasive Plant Council, in coordination with a technical advisory team of whose 

members represented such agencies as the US Forest Service, National Park Service, Bureau of Land 

Management, US Geological Survey, US Fish and Wildlife, California Department of Forestry and Fire 

Prevention, California State Parks, California Department of Fish and Wildlife, and other entities 

including University of California Cooperative Extension, California Association of Resource 

Conservation District and land trusts.

BMP Implementation on the Six Rivers National Forest

Best management practices would be incorporated as standard operating procedures for all forest 

management activities, across all program areas to reduce or eliminate the risk of invasive plant species 

introduction or spread. Best management practices do not necessarily preclude the need for a risk 

assessment; the latter may be warranted depending on the nature of the activity proposed where sitespecific project design features are needed such as relatively large-scale, projects or activities (e.g.,

vegetation and fuels projects, travel analysis). Best management practices alone may suffice for planning 

documents or National Environmental Policy Act (NEPA) for activities that are programmatic or routine 

in nature that lend themselves to an adaptive management approach, specifically on-site inspection prior 

to implementation by trained staff (e.g., road maintenance, storm-proofing, trail construction, emergency 

road repair, certain special use permits).

The level of risk assessment needed for a given project—the application of BMPs or a risk 

assessment with site-specific design features—would be determined by the forest invasive plant 

coordinator or interdisciplinary team botanist.

Following are BMPs organized by those that are associated with administration, prevention measures 

applicable to all resource areas, and then itemized by specific resource areas.
Appendix D. Mitigation Measures

Final Environmental Impact Statement – Appendices – 135

General Category Prevention and Management Practices

Administrative

GA1. Appoint Forest Service staff members to serve respectively as the forest invasive plant 

coordinator and forest invasive aquatics coordinator.

GA2. As feasible, district ranger to identify district staff interested in serving as unit invasive 

plant species liaison to the forest invasive plant coordinator.

GA3. Ensure invasive species prevention practices are incorporated in every staff area and 

activities are designed to minimize or eliminate the possibility of establishment or spread of 

invasive species on National Forest System (NFS) or adjacent lands (FSM 2903).

GA4. Coordinate with State and county agencies, with adjacent federal and tribal agencies, with 

non-governmental organizations and landowners through active involvement in county 

Weed Management Areas (WMAs) in prevention, control, containment, monitoring, and 

education efforts involved with the management of invasive species.

GA5. Conduct periodic trainings on the forest related to invasive species identification, biology and 

dispersal, prevention practices, treatment methodologies, and invasive plant reporting protocol.

GA6. Develop and foster partnerships at different scales to enhance opportunities for funding, 

continuity in on-the-ground invasive plant management, and local community participation.

GA7. Maintain standardized databases for invasive plant occurrences and monitoring.

GA8. Maintain and update geographic information system (GIS) files of invasive plant locations 

on the forest in a corporate area for use by various resource areas in project planning and 

wildfire suppression/rehabilitation.

GA9. Implement a monitoring/management program for high priority invasive species sites.

Prevention – Aquatics

A major pathway for the spread of aquatic invasive species is as hitchhikers on waders, boats, trailers, 

nets, and other equipment used by aquatic specialists and helicopters and water tenders used for 

firefighting or road related work. Any equipment used in a water body containing an invasive species 

could transport various life stages (eggs, resting stages, or fragments that are hardly visible to the human 

eye) to an un-infected water body.

GPA1. Minimize the movement of aquatic invasive species, including fish, crustaceans, mollusks, 

plants, insects, and diseases among waterways during actions involving transfer of water 

between basins including aquatic habitat management and assessment activities. In 

consultation with a fisheries biologist or aquatic specialist, BMPs may include the following:

 Clean equipment that comes in contact with water infested with aquatic invasive 

species,
Appendix D. Mitigation Measures

136 – Smith River National Recreation Area Restoration and Motorized Travel Management

 Equipment that draws water from one water body should not be drained into 

another water body,

 As part of general maintenance, equipment, portable pumps and hoses should be 

flushed with clean water between uses.

GPA2. See Appendix D of the framework for 2010 Draft Operational Guidelines for Aquatic 

Invasive Species Prevention and Equipment Cleaning.

Prevention – Terrestrial Invasive Plants

GP1. Include invasive plant prevention costs in budgeting for project planning, project layout and 

design and, implementation. This cost could include site inspection for presence of invasives 

or design/construction costs applicable during implementation (e.g., contractor equipment 

cleaning, application of native mulch).

GP2. Prior to implementation of any forest activities or those authorized by the forest a risk

assessment of the potential for invasive species introduction and spread shall be completed by 

a staff botanist or other staff trained in invasive plant management. Level of analysis (e.g.,

Invasive Plant Risk Assessment with site-specific design features or over-arching BMPs) may 

vary depending on such variables as geographic scope, type and location of the activity.

GP3. Incorporate applicable BMPs into contract specifications (FSM 2904.47) or partner 

agreement responsibilities. Address invasive plant provisions during pre-work and other 

meetings prior to ground disturbance.

GP4. Prevention of invasive species introduction will be incorporated into landscape-level or other 

planning documents such as watershed analysis; roads analysis; fire and fuels management 

plans; Wildland Fire Decision Support System (WFDSS), Burned Area Emergency Recovery 

Plans (BAER); community wildfire protection plans, grazing allotment management plans, 

recreation management plans, and vegetation management plans.

GP5. Actions conducted or authorized by written permit by the Forest Service operating on and 

outside the road prism (including public works, special-uses, and service contracts) will 

require cleaning of all heavy equipment (bulldozers, skidders, graders, backhoes, dump 

trucks, etc.) prior to entering NFS lands.

GP6. Each unit shall identify sites for Forest Service vehicle cleaning and equip the sites 

sufficiently (i.e. high-pressure hose) to ensure mud or vegetative material trapped in tires or 

on the carriage of the vehicle can be effectively removed.

GP7. If there is a moderate to high risk of spreading invasives from an infested area to an 

uninfested area during operations and alternate project design features are not feasible to 

reduce risk of spread, equipment/machinery shall be cleaned prior to leaving the infested area 

and operating elsewhere.
Appendix D. Mitigation Measures

Final Environmental Impact Statement – Appendices – 137

GP8. When needed to control soil erosion, use mulch from chipped or masticated native material or 

certified weed-free straw (see www.cal-ipc.org/ip/prevention for a weed-free forage and 

straw supplier list).

GP9. Rock, sand or other material to be used for projects conducted or authorized by the Forest 

Service shall originate from a weed-free source. Rock source shall be inspected by staff 

trained in invasive plant identification or if source is off-forest, contractor shall provide 

documentation that material is weed-free. Appendix B of the Invasive Plant Species BMPs

includes material source inspection forms for contract specifications.

GP10. Material excavated at a project site that is contaminated with invasive plants can be a) reused 

at the site, b) stockpiled on site, or c) relocated to an area that is already contaminated.

During transport of contaminated soil or sand, cover material with an impervious material.

GP11. Consider stockpiling native mulch at designated areas on districts for use in projects (e.g., postfire rehabilitation) where ground cover will reduce the risk of invasive plant establishment.

GP12. District shall identify one or more disposal sites when large quantities of invasive plant 

material are planned for removal. Select areas for disposal that either already include invasive 

plants or are otherwise compromised.

GP13. Post educational/prevention information at Forest Service administrative sites including 

Ranger Stations, trailheads, campground kiosks, river access sites, interpretive and historic 

sites, and boat launches.

GP14. For activities conducted or authorized by the forest and where seeding is determined to be 

necessary (including emergency soil stabilization related to fire, flood, landslide, etc.) use 

when available native seed stock or refer to the forest’s seeding guidelines for direction 

related to non-persistent alternatives.

GP15. Locate activity boundaries or areas of concentrated use to exclude areas infested with 

invasive plants. Activity boundaries include staging areas, parking areas, trailheads, river 

access points, roadside pullouts, and timber harvest landings.

In addition to the general practice BMPs above, the following are identified for specific resource areas:

Forest Road-Related Projects

In the course of planning any road-related project, coordinate with botany staff to review invasive plant 

location GIS maps (see GP2 above) and document those known invasive plant occurrences/or information 

gaps in contracts or agreements that may necessitate site review and application of design features to 

reduce the risk of spreading invasive plants.

RD1. Avoid staging equipment where invasive plants occur. If avoidance is not feasible, contractor 

shall treat staging areas prior to using (e.g., manual or mechanically remove) and maintain as 

needed throughout the life of the project. Locate treated material on site and out of the way of 

equipment operations.
Appendix D. Mitigation Measures

138 – Smith River National Recreation Area Restoration and Motorized Travel Management

RD2. Attempt to implement ground disturbing activities (e.g., road-blading, brushing, ditch 

cleaning, storm proofing) according to a progression of work schedule, operating first in 

invasive plant-free areas (typically upper watershed areas) before moving to heavily infested 

road segments.

RD4. Based upon botany review (GP2):

 If consistent with project objectives, identify specific areas where mowing or 

ground disturbance can be avoided to reduce spreading invasives,

 To reduce the alteration of site conditions that favor invasive plant establishment 

and spread, limit mowing and other mechanical control to the minimum needed

to meet maintenance objective.

 If feasible, avoid operations during the time of year when invasive plants pose 

the highest risk of spread (e.g,. when ground is wet and seeds can be picked up in 

the mud) (See Appendix C for seasonality of species).

RD5. Incorporate, where applicable, the following into forest road decommissioning projects to 

reduce the risk of an existing invasive plants occurrence from spreading occurrence to 

unoccupied areas as a result of project implementation:

 Where there is a risk of spread of invasive plants from an existing occurrence on 

or along the road to be decommissioned into unoccupied wildland settings (e.g.,

in settings where the vegetative ground and canopy cover in the adjacent habitat 

is minimal), remove entire plant (including roots) mechanically or manually prior 

to decommissioning,

 Mechanically or manually remove any invasive plant occurrence (remove entire 

plant) at the intersection of the decommissioned road and forest system road.

♦ Apply ground cover in the form of native mulch/finely masticated 

material spread to depth of 6 inches over the area where plants were 

removed, or

♦ If feasible, decompact/rip and revegetate area with suitable native 

planting stock that optimizes resistance to invasive plant 

establishment (e.g., tree stock, early-successional/disturbance 

tolerant shrubs).

RD6. See GP8 to GP10 above relative to rock, sand, gravel; material used in erosion control; and 

contaminated material on-site.

Recreation

Rec 1. Use educational and permit programs to increase invasive plant weed awareness and 

understanding of prevention practices. For example, post invasive plant prevention 
Appendix D. Mitigation Measures

Final Environmental Impact Statement – Appendices – 139

information at trailhead kiosks or river access points; include prevention measures in 

recreation outfitter permits. See LSU 10.

Rec 2. Conduct periodic inventory along designated off-highway vehicle trails for new introductions 

and treat as necessary.

Rec 3. Prioritize trailheads, boat launches, administrative sites, campgrounds, picnic areas, river 

access sites and other areas of concentrated public use for invasive plant 

management/containment. Priority sites could include those that pose a risk of invasive plant 

species spreading into wildland settings or into corridors of potential spread. As examples, 

remove and maintain invasive plant occurrences associated with priority settings that are:

 Adjacent to river or riparian corridors

 Adjacent to grassland or other open settings

 In high use areas such as trailhead parking areas or boat launches

 Adjacent to roads that are not occupied by invasive plants.

Rec 4. Seek partners among recreation groups or campground hosts to adopt a site for invasive plant 

species management.

Rec 5. See GPA1 relative to aquatic invasives.

Six Rivers Road Maintenance Project – 2016 to 2022

In 2016, Forest Supervisor Merv George Jr. signed the Six Rivers Road Maintenance Project Decision 

Memo. This decision memo authorized road maintenance throughout the forest to meet the following 

goals and objectives:

• Smoothing road surfaces, repairing road signs, removing hazards and vegetation blocking driver 

visibility to maintain drivable road conditions that promote safe passage on all roads open for the 

public to drive (ML 2-5).

• Maintaining road stream crossings, drainage structures, ditches and replacing culverts to 

effectively channel storm runoff during 100-year flood events in compliance with the 1994 Six 

Rivers National Forest Land and Resource Management (LRMP pg. IV-49) (ML 1-5).

• Reshaping slopes and stabilizing eroding soils to lower non-point source pollution into waterways 

in compliance with the Clean Water Act; thereby lowering environmental stressors to aquatic 

habitats to aid listed salmon species recovery on all roads (ML 1-5).

Maintenance Activities Covered

The R5 Forest Service Specifications for Maintenance of Roads (USDA 1992), water quality BMPs, 

general prevention (GP) measures to prevent the introduction and spread of invasive plant and aquatic 

species (GPA) and specific road-related prevention measures (RD) will be applied to avoid, minimize, or 
Appendix D. Mitigation Measures

140 – Smith River National Recreation Area Restoration and Motorized Travel Management

mitigate potential adverse resource effects, as described below. Following the list of activities are 

additional design features by resource area (archeology, wildlife, hydrology, etc.) that would be applied 

during the annual review on a road-by-road basis.

Road maintenance will be confined to previously maintained surfaces, ditches, culverts and cut and 

fill slopes within the road prism. An annual operating allowance is identified for a subset of road 

maintenance activities in order to prevent multiple projects impacting water quality in a single 6th-field 

watershed. For each road maintenance activity that involved the potential for sediment entering a 

watercourse, the historic range of activity intensity (number of culverts replaced, miles of ditch 

maintenance) was identified. Exceeding these annual operating allowances in a single watershed may 

require additional review, documentation or, postponement of site-specific road actions:

• Grading/reshaping

• Dust abatement

• Spot surfacing

• Asphalt pavement

• Paved surface cleaning

• Re-paving

• New paving

• Surface treatment

• Maintenance of unpaved shoulders

• Asphalt crack cleaning and repairing

• Ditch maintenance

• Remove and end haul road debris

• Culvert replacement

• Drainage structure maintenance

• Drainage dip maintenance

• Vegetation establishment

• Cutting roadway vegetation

• Logging out

• Hazard removal and cleanup

• Maintenance of cattle guards

• Sign maintenance

• Maintenance of road closures

• Rock and common borrow sites
Appendix D. Mitigation Measures

Final Environmental Impact Statement – Appendices – 141

• Slide and fill stabilization

• Bridge repair (no replacement).

Design Features and Mitigation Measures

Timing of Activities

Generally, road maintenance will occur during dry weather in the summer and fall, although work may 

occur at any time if conditions allow and clearance from appropriate specialists has been obtained 

(wildlife, botany, fisheries, hydrology, and archeology). Six Rivers’ Wet Weather Operation Standards

will apply to protect water quality and road investment. In addition, preventing the transmittal of PortOrford-cedar root disease will also restrict the timing of activities.

Roads under fire closure or other closure orders for special events and uses will not receive 

maintenance during restricted periods in order to mitigate user conflicts.

Archeology

It is anticipated that there will be no adverse effects to historic properties, provided these project design 

features are followed.

If new sites are found during implementation, all work shall halt until the heritage program manager 

is notified and clearance to continue work is approved. Should inadvertent effects to or unanticipated 

discoveries of human remains be made on Region 5 lands, the county coroner (California Health and 

Safety Code 7050.5(b)) shall be notified immediately. If the remains are determined to be Native 

American or if Native American (Indian) cultural items pursuant to NAGPRA are uncovered, the 

provisions of NAGPRA and its regulations at 43 CFR 10 and ARPA at 43 CFR 7 shall be followed on 

federal lands (Stipulation 7.9 (a)).

On an annual basis, and as early as possible, engineering and watershed staffs will provide a list of 

roads proposed for maintenance that year to the forest heritage program manager and tribal relations 

program manager. The heritage and tribal relations program managers will provide information back to 

the engineering and watershed departments regarding whether or not there are any heritage concerns prior 

to implementation of any roadwork.

Tribes will be consulted with on an annual basis regarding scheduled roadwork activities, locations, 

and timelines. Close coordination is especially critical when roadwork is scheduled within the boundaries 

of traditional cultural properties, Native American contemporary use areas, or cultural management areas, 

or when ground-disturbing activities (e.g. culvert replacements) are scheduled.

• Road maintenance will be confined to previously maintained surfaces, ditches, culverts, and cut 

and fill slopes within the road prism (i.e., previously disturbed areas).

• All activities will involve less than one cubic meter of cumulative new ground disturbance per acre.

• When felling standing hazardous trees at work sites or clearing wind-thrown trees that have fallen 

within the existing road prism, tree trunks, limbs and tops will be: 1) left in place, or 2) cut up 

with hand tools, including chain saws, and removed from the roadway by hand, or 3) felled into 
Appendix D. Mitigation Measures

142 – Smith River National Recreation Area Restoration and Motorized Travel Management

and removed from within the existing road prism. All material removed would be hauled to 

designated disposal sites as per activity 12 – Remove and end haul road debris.

Botany – Invasive Plants

Maintenance activities will be planned and implemented to reduce the introduction and spread of invasive 

species (aquatic and terrestrial) that coincide with road maintenance activities. The Forest Service 

National Strategic Framework for Invasive Species Management (USDA 2013; framework) was 

developed in 2004 and updated in 2013 to guide the implementation of Executive Order 13112 and Forest 

Service Policy (FSM 2900). Those maintenance activities with the potential to have a moderate to high 

risk of introducing or spreading invasive species will be reviewed in the field by botany staff and as 

applicable, control measures will be undertaken to reduce this risk. Control measures or BMPs have been 

developed on the SRNF and are applicable to all forest projects. Examples of BMPs pertaining to road 

maintenance activities include:

• Actions conducted or authorized by written permit by the Forest Service operating on and outside 

the road prism (including public works, special-uses, and service contracts) will require cleaning 

of all heavy equipment (bulldozers, skidders, graders, backhoes, dump trucks, etc.) prior to 

entering National Forest System Lands). GP5

• Minimize the movement of aquatic invasive species, including fish, crustaceans, mollusks, plants, 

insects, and diseases among waterways during actions involving transfer of water between basins 

including aquatic habitat management and assessment activities. In consultation with a fisheries 

biologist or aquatic specialist, equipment that comes in contact with water infested with aquatic 

invasive species may need to be cleaned prior to use. GPA1

• Based upon pre-implementation field review, if consistent with project objectives, identify 

specific areas where mowing or ground disturbance can be avoided to reduce spreading invasive 

plants. RD4

• Rock, sand or other material to be used for projects conducted or authorized by the Forest Service 

shall originate from a weed-free source. Rock source shall be inspected by staff trained in 

invasive plant identification or if source is off-forest, contractor shall provide documentation that 

material is weed-free. GP9

Botany – ESA-listed plants and Forest Service Sensitive plant species

This project will be in compliance with the Forest-wide Road Maintenance Wildlife, Fisheries and 

Botany biological assessment/biological evaluation (2015; BA/BE), and as such, this document may be 

used for any type of road maintenance activity where the activity is not occurring within occupied 

McDonalds rockcress (Arabis macdonaldiana) habitat nor has the potential to indirectly impact the 

occurrence. In the event that McDonalds rockcress is known or detected within 0.25 miles of the activity 

area, additional review by the Level 1 Team is required to determine how impacts to this species will be 

avoided. If impacts cannot be avoided, re-initiation of consultation is required.
Appendix D. Mitigation Measures

Final Environmental Impact Statement – Appendices – 143

Also in keeping with the BA/BE, this document may be used for any type of road maintenance 

activity that is not within 0.25 miles of documented early-successional Forest Service Sensitive plant 

occurrences (e.g., California globe mallow, Siskiyou bells) or documented Sensitive plants associated 

with Darlingtonia wetlands (e.g., western bog violet, Waldo gentian). Early successional species do occur 

on road edges or within the road prism. An occurrence may expand beyond where originally mapped 

depending on the roadside setting; therefore, 0.25 miles provides a trigger for field surveys by botany 

staff to determine the extent of the occurrence. Darlingtonia wetland species do occur in association with 

stream courses that maybe indirectly affected by road maintenance activities (i.e. culvert replacement); 

therefore, 0.25 miles trigger applies to these species as well. In the event planned activities do coincide 

with occurrences of early successional or Darlingtonia wetland Sensitive plants, project design features 

may be needed to alleviate or reduce impacts to the Sensitive plant occurrence.

Hydrology

A waiver of waste discharge requirements application will be filed prior to project implementation in 

compliance with the Clean Water Act, Porter-Cologne Water Quality Control Act, applicable water 

quality control plans, and the Regional Board waiver of waste discharge requirements (Order No. R1-

2015-0021).

An erosion control plan shall be prepared describing the storm water control structures and maintenance 

management practices that will be implemented to minimize pollutants in storm water discharges after 

project activity phases have been completed at the site. It shall also specify controls to be removed from the 

activity site(s) and methods for their removal. Site-specific factors and seasonal conditions must be 

considered when designing the control practices that will function after the project is complete.

The application of regional and national BMPs will be applied as described in the Hydrology Report 

(Black 2015).

• Location of Designated Disposal Sites (under Region 5 BMP 2.3 and National Road-3): Locate 

and designate disposal areas before operations begin such as that the location of sites are away 

from failure and erosion prone areas. Provide for adequate surface drainage and erosion 

protection at disposal sites.

• Road Maintenance and Operations (Region 5 BMP 2.4 and National BMP Road-4): All roads 

were assigned maintenance levels that were commensurate with the planned use and potential 

impacts to water quality. The portion of BMP 2.3 that addresses disposal of debris may also be 

applicable to road maintenance activities and helpful in reducing the risk of slope failure. This 

BMP directs designation of disposal sites, locations of sites away from failure- and erosion-prone 

areas, and adequate drainage of disposal sites.

• Road Storage (Region 5 BMP 2.6 and National BMP Road-4): Where necessary for resource 

protection, all drainage structure shall be removed prior to closure/storage to preclude the need 

for routine road maintenance and insure water quality standards are met.
Appendix D. Mitigation Measures

144 – Smith River National Recreation Area Restoration and Motorized Travel Management

• Stream Crossings (Region 5 BMP 2.8 and National BMP Road-7): Where field data indicated 

evidence of undersized culverts, diversion potential, or other physical defects associated with any 

stream crossings in the project area, BMPs will be used to reduce risks to water quality. New 

crossings will be sized to meet the 100-year flood where feasible and shall have no diversion 

potential. All live streams shall be dewatered prior to construction. Dewatering techniques 

typically include using a pump and hose lay to route water around construction site and deposited 

below the work site and into the same channel that was dewatered.

• Equipment Refueling and Servicing (Region 5 BMP 2.11 and National BMP Road-10): All 

temporary refueling and servicing will occur at approved locations, located well away from 

streams and waterways.

• Water Drafting (Region 5 BMP 2.5): All water source drafting operations will protect base flows 

and beneficial uses at the water drafting site. Water drafting occurring in occupied ESA listed 

salmonid habitat would have additional requirements, including screening.

• Erosion Control Plans (BMP 2.13): All road maintenance activities shall develop a site-specific 

erosion control plan. In addition, these plans will comply with the forest’s Wet Weather Operating 

Standards (See Appendix 2 of Hydrologist Report). Erosion control plans are also a requirement 

set forth by the Regional Water Quality Control Boards Discharge Waiver as described above.

Soils and Slope Stability

The Road Maintenance and Operations BMP 2.4 is applicable to slope stability, and will be followed to 

ensure that mass wasting does not negatively impact water quality during road maintenance. Provisions of 

this BMP that will help maintain slope stability include: required inspections; maintenance, repair, and resiting of drainage structures to reduce diversion potential and hydrologic connectivity; addressing of 

known failure sites with proven remedies; avoidance of undercutting cutslopes; installation of erosion 

control structures; and enforcement of timber-associated maintenance requirements, including restoration 

of all drainage structures.

The portion of BMP 2.3 that addresses disposal of debris may also be applicable to road maintenance 

activities and helpful in reducing the risk of slope failure.

Road maintenance should not require consultation with earth science professionals to remedy routine 

situations such a rockfall, cutslope erosion or failure, plugged culverts, or minor drainage diversions. 

However, if any such problem appears to involve any of the natural hillslope outside of the road prism or 

appears to be part of a larger slope failure or landslide, engineering personnel should consult with Forest 

geologists before proceeding with maintenance and/or repairs. If necessary, geotechnical expertise should 

be consulted when problems appear to be beyond the scope of routine maintenance.

Fisheries

This project will be in compliance with the Forest-wide Road Maintenance Wildlife, Fisheries and Botany 

BA/BE (2015), which includes analysis of effects of road maintenance on aquatic Forest Service Sensitive 
Appendix D. Mitigation Measures

Final Environmental Impact Statement – Appendices – 145

and incorporates the requirements of the Watershed and Fisheries Restoration Program biological 

assessment (WFR BA; 2015) for ESA-listed salmonids.

• ESA listed salmonids: Activities resulting in ground disturbance that may impact listed salmonids 

would be reviewed by the Six Rivers National Forest/National Marine Fisheries Level 1 team as 

per the WFR Program BA.

• Exceeding the annual allowance may require additional review and documentation to be in 

compliance with the WFR Program BA.

• ESA listed and FSS aquatic species: To reduce the impacts to aquatic species, individual or a 

combination of the following broad design features will occur, depending on the methods of road 

maintenance being planned, local environmental conditions and distance to occupied habitat:

o Water quality BMPs and Waiver compliance for reducing sediment delivery into stream 

channels;

o Water drafting at approved locations only and NMFS Water Drafting Guidelines 

implemented in ESA-listed fish bearing stream reaches;

o Application of SRNF Wet Weather Operating Guidelines for any work outside the normal 

operating window with potential notification to NMFS.

Naturally occurring asbestos (NOA)

Naturally occurring asbestos (NOA) has only relatively recently been identified as a health hazard in 

areas where ultramafic bedrock is present and dust generated during recreational or construction and 

maintenance activities may be inhaled and cause respiratory illness or certain types of cancers. NOA may 

be present and co-located wherever ultramafic bedrock (serpentine and/or peridotite) occurs, or where it 

has been applied as an aggregate surface.

Where road maintenance is planned to occur in areas of known or likely ultramafic rock or NOA 

presence with less than one acre of disturbance, a suite of preventative measures are required, including 

speed limits, dust abatement by wetting, wetting or coverage of storage piles, and track-out prevention 

and removal. The local air pollution control or air quality management district must also be notified 

before any work begins. Projects over an acre also require an air quality district-approved asbestos dust 

mitigation plan.

Vegetation

Port-Orford-cedar

Operations planned where there is a potential to spread Port-Orford-cedar root disease or wet weather 

associated damage will be limited to the dry season (June 1 through September 30), in compliance with 

the Six Rivers LRMP, Appendix K – Port-Orford-Cedar Action Plan, provision E-7A of the Engineering 

and Road Management Disease Control Strategies.
Appendix D. Mitigation Measures

146 – Smith River National Recreation Area Restoration and Motorized Travel Management

Wildlife

Any maintenance activities within 0.25 miles of an occupied marbled murrelet (MAMU) site, occupied 

northern spotted owl (NSO) activity center (AC), or known fisher den require additional review by the 

Six Rivers National Forest/Arcata Fish and Wildlife Service Level 1 Consultation Team before any 

actions can occur to ensure no adverse effects will occur.

Noise Disturbance

For the most part, the proposed road maintenance activities will occur on high-use roads where normal 

background noise equals or exceeds the noise generated by the maintenance; therefore, activities on high 

use roads would not require a limited operating period (LOP). A high-use road is defined as one or more 

of the following:

High-use Road

• Use by an average of 5 vehicles or more per day typically associated with MLs 3 to 5,

• Access to a high-use destination such as a trailhead or campground,

• Use for hauling associated with timber harvest that is concurrent with maintenance activities.

Since low-use roads receive less traffic, background (ambient) noise levels for these roads would be 

lower than for frequently traveled roads. As a result, road maintenance projects on low use roads may 

occur with no LOP only if:

• They do not occur within 0.25 miles of unsurveyed or occupied nesting/denning habitat for any 

TEPS species during the breeding season or

• Activities are of a mobile nature, such as blading or brushing, or,

• If they are stationary activities that meet the definition of short duration (15 minutes per 0.25 

mile of road within 0.25 mile of suitable habitat).

Long duration, stationary road maintenance projects could exceed ambient noise levels and create noise 

disturbance to nesting/denning TEPS species. Road maintenance activities that may exceed the ambient 

noise levels (generally on low-use roads) will require the following limiting operating periods (LOPs):

Northern Spotted Owl:

o Any noise-generating activity within 0.25 miles of known NSO AC will not occur 

between February 1 and July 31, unless surveys determine the site to be unoccupied.

o Any noise-generating activity within 0.25 miles of unsurveyed, high quality NSO nesting 

and roosting habitat will not occur between February 1 and July 9, unless surveys 

determine the site to be unoccupied.

Marbled Murrelet:

o Any noise generating activity within 0.25 miles of known MAMU nest will not occur 

between March 24 and September 15.
Appendix D. Mitigation Measures

Final Environmental Impact Statement – Appendices – 147

o Any noise generating activity within 0.25 miles of unsurveyed, high quality MAMU 

nesting habitat will not occur between March 24 and August 5. In addition, work between 

August 5 and September 15 will not begin until 2 hours after sunrise and stop 2 hours 

before sunset unless surveys determine the site to be unoccupied.

Fisher:

o Any noise-generating activity within 0.25 miles of known fisher den will not occur 

between February 1 and July 9, unless surveys determine the site to be unoccupied.

o Any noise-generating activity within 0.25 miles of unsurveyed, high quality fisher 

denning habitat will not occur between February 1 and July 9, unless surveys determine 

the site to be unoccupied.

Activities that Exceed Ambient Noise

Certain activities (blasting, pile driving, jackhammers, and chippers) always exceed ambient noise levels, 

regardless of maintenance level of the road. Therefore, LOPs will be applied wherever these actions are 

used and will be applied as follows:

• Pile Driving, Jackhammers, and Chippers:

o NSO: Use of this equipment will not occur within 0.25 mile of unsurveyed northern 

spotted owl nesting/ roosting habitat between February 1 and July 9, unless surveys 

determine the site to be unoccupied.

o MAMU: Use of this equipment will not occur within 0.25 mile of unsurveyed suitable 

MAMU nesting habitat between March 24 and August 5. In addition, work between 

August 5 and September 15 will not begin until 2 hours after sunrise and stop 2 hours 

before sunset unless surveys determine the site to be unoccupied

o Fisher: Use of this equipment will not occur within 0.25 miles of unsurveyed fisher denning 

habitat between February 1 and July 9, unless surveys determine the site to be unoccupied.

• Blasting and Rock Crushing:

o NSO: These actions will not occur within 1 mile of unsurveyed northern spotted owl 

nesting/roosting habitat between February 1 and July 9, unless surveys determine the site 

to be unoccupied.

o MAMU: These actions will not occur within 1 mile of unsurveyed suitable MAMU 

nesting habitat between March 24 and August 5. In addition, work between August 5 and 

September 15 will not begin until 2 hours after sunrise and stop 2 hours before sunset 

unless surveys determine the site to be unoccupied

o Fisher: These actions will not occur within 1 mile of unsurveyed fisher denning habitat 

between February 1 and July 9, unless surveys determine the site to be unoccupied.

Projects located within the nest protection or primary disturbance zones of any Forest Service 

Wildlife Sensitive species would be evaluated on an individual basis to determine if further mitigations 
Appendix D. Mitigation Measures

148 – Smith River National Recreation Area Restoration and Motorized Travel Management

would be appropriate to minimize disturbance or impacts to habitat (SRNF LRMP Standard and 

Guidelines General Wildlife Management, under section 8-2 (page IV-97)).

Habitat Disturbance

No actions will occur within any NSO nest grove or within an occupied MAMU site.

• Vegetation removal may be required at culvert replacements sites. Removal is limited to 11-inch

or less dbh trees and less than 1/10th acre in size under this decision unless site specific review by 

a wildlife biologist determines that no TEP species habitat will be removed or downgraded and 

that any affected habitat retains all habitat function post-project.

• All vegetation removal in nesting/denning or Critical Habitat must maintain the current function 

of the habitat.

Hazard Trees: Large-scale hazard tree removal is not part of this proposed action; however, in some 

cases work sites may need hazard trees removed for safe operations. A work site is defined as an area 

where stationary work needs to occur (such as a culvert removal site).

Under this decision, the following conditions apply:

• Hazard trees must meet the current FS definition and be within reach of the work site (Region 5 

Hazard Tree Policy, April 2012).

• Activities cannot remove more than three hazard trees in suitable TEP habitat from any one work 

site.

• Road maintenance activities that remove hazard trees greater than 18-inch dbh require sitespecific review by a wildlife biologist to ensure that nesting habitat or primary constituent 

elements of Critical Habitat will not be removed or downgraded and the habitat will remain 

functional post-project.

• Activities that remove trees in suitable habitat must ensure that the canopy closure will remain 

unchanged and that large snags are not limited in the stand. Any hazard tree cut will be left on site 

or removed to designated disposal site as per activity 12 – Remove and end haul road debris.

Attachment B: Specialist Annual Review Process

Implementing the Road Maintenance Program

Goal: Implement the Road Maintenance CE in a way that: preserves investments in the NFTS 

infrastructure to mandated design standards, sustains safe public and administrative access to NFS lands; 

and, reduces risk to water quality while preventing resource damage or impacts. This Plan to 

Implementation can be achieved by:

• Providing a process for documenting specialist review, issues and approval on a yearly basis;

• Providing a simple visual of what roads are ready for implementation (contracting);

• Providing documentation of resolution of specialist issues.
Appendix D. Mitigation Measures

Final Environmental Impact Statement – Appendices – 149

Objective: To implement an iterative interdisciplinary review process that optimizes roadwork

accomplishments within the NEPA decision as funding becomes available. This process would:

• Identify which specific roads/activities can be implemented immediately (no resource concerns or 

issues);

• Identify which roads/activities have issues that need follow up specialist review/action;

• Identify by road/activity what project design features from the NEPA CE apply (LOPs, surveys, etc.);

• Identify which roads need onsite implementation review and which specialist needs to be 

contacted prior to activity;

• Identify ways to streamline review process.

Initial Strategy on how this works:

• Engineering and watershed (with line officers) staff provide a list of new roads/activities (with as 

much detail as possible as to the types and locations of activities that would occur) to district and 

supervisor’s specialists for their review 2 weeks (minimum) prior to the annual review meeting.

• Engineering/Watershed staff also identify the previous year’s approved actions that did not get 

implemented on the ground (for ground disturbing activities limitations by watershed).

• Specialists come to the meeting (at district and/or supervisor’s office) prepared to fill out tracking 

spreadsheet to identify:

o Roads that are reviewed and approved for contracting (IDIQ) and on-the-ground 

implementation – no resource concerns (these are automatically coded green – see Figure 1),

o Roads that need additional survey work/information (issues) to identify potential design 

features,

o Roads that need specific PDFs (LOPs, buffers, etc.),

o Roads that have issues, but can be resolved with on-site monitoring, timing, etc.

• Document outcome in the yearly spreadsheet – those that are all green can move forward with no 

more review.

• Based on district ranger’s input, engineering/watershed staff works with specialists with 

issues/concerns for current fiscal year priorities. Funding, staffing levels and timing of surveys 

may result in roads moving to next year’s list.

Specifically: This documents that all road maintenance projects are implementing the Road Maintenance 

CE and all associated law policy and regulation. The spreadsheet as developed, can also serve as 

documentation of us identifying issues, and identifying that we resolved them before implementing.

Related Law Policy Regulation

ESA Compliance and FS Sensitive: ESA compliance is met during this process and by the approved 

list being attached to the September 24, 2015 Forest-wide Road Maintenance Wildlife, Fisheries and 

Botany BA/BE (2015) 2015-2022 Tiering Form and copies submitted to USFWS and NMFS.
Appendix D. Mitigation Measures

150 – Smith River National Recreation Area Restoration and Motorized Travel Management

Clean Water Act Compliance: NCWQCB Waiver compliance is met during this process by having 

the approved list of Category B projects to the water board along with identification of addition 

documentation. This process would be updated as the waiver process is finalized.

Tribal/Cultural: The National Historic Preservation Act Section 106 process is met by following all 

stipulations in the Programmatic Agreement among the USDA Forest Service, Pacific Southwest 

Region (Region 5), California State Historic Preservation Officer, Nevada State Historic Preservation 

Officer, and the Advisory Council on Historic Preservation Regarding the Processes for Compliance 

with Section 106 of the National Historic Preservation Act for Management of Historic Properties by 

the National Forests of the Pacific Southwest Region (2013). Tribal consultation will be on going

throughout the life of the project. A copy of the document with an original signature may be found in 

the project record at the Six Rivers National Forest Supervisor’s office, in Eureka, California.

Motorized Trail Maintenance

The Six Rivers Road Maintenance Project CE (Road Maintenance CE) design criteria, mitigation 

measures and annual operating allowance thresholds are applicable to all NFTS roads designated and 

existing (remaining ML 3 to 5) included in the Smith River National Recreation Area Restoration and 

Motorized Travel Management Project including:

• Smoothing road surfaces, repairing road signs, removing hazards and vegetation blocking driver 

visibility to maintain drivable road conditions that promote safe passage on all roads open for the 

public to drive (ML 2 to 5).

• Maintaining road stream crossings, drainage structures and ditches, and replacing culverts to 

effectively channel storm runoff during 100-year-flood events, in compliance with the LRMP (p. 

IV-49) (ML 1 to 5). These types of actions implement stormproofing measures identified in the 

FEIS for NFTS roads.

This decision clarifies that future maintenance would also occur on all motorized trails added to the 

NFTS in all action alternatives. The motorized trails proposed for addition would follow the same process 

identified in the Road Maintenance CE, including the requirement for notifying specialists on the 

proposed annual trail maintenance.

• Maintain designated motorized trails, road surfaces, repairing road signs, removing hazards and 

vegetation blocking driver visibility to promote safe OHV experiences.

• Maintain trail stream crossings, drainage structures (water bars/rolling dips) and ditch cleaning, 

clean and replace culverts to effectively channel storm runoff during 100-year-flood events, and 

add additional gravel to control rutting

The following motorized trail maintenance activities were reviewed by the IDT to determine if the 

design features contained within the Road Maintenance CE listed above were sufficient for minimizing 

effects to resources.
Appendix D. Mitigation Measures

Final Environmental Impact Statement – Appendices – 151

The FEIS identifies mitigations that would need to occur on some of the proposed motorized trails 

prior to being added on the MVUM. Post decision, all motorized trails designated would be maintained as 

needed, actions would include the following types of activities:

• Brushing

• Culvert cleaning

• Maintain rolling dips

• Add dips/waterbars as needed

• Spot rocking of motorized trails

• Rocking longer sections of motorized trials as conditions change (applies to motorized trails only)

• Drainage maintenance

• Maintain route delineation (including any barriers)

• Maintenance of identified seasonal gates.

Assumption for motorized trail maintenance:

• Annual Trail Maintenance proposed plan would have review by specialist, and

• All work would occur within the motorized trail prism.

The interdisciplinary team was emailed on September 22, to determine if including motorized trail 

maintenance in the FEIS would result in additional analysis or new consultation. Table D-2 documents the 

responses of the IDT.

Table D-2. Additional analysis or new consultation required if motorized trail maintenance included in FEIS.

Resource Design Features and Process

in Road Maintenance CE

Additional Effects to be 

Analyzed/Consultation

Air Quality No additional design features. N/A

Aquatics No additional design features. No – ESA consultation covered WFRBA - No 

additional analysis

Botany

Annual maintenance plan would need review by a 

botanist. Of particular concern are trail side ditches 

associated with the Spring Road (17N49.7).

Add dips and waterbars, and spot rocking and 

brushing where Sensitive plants are present.

No new effects analysis or consultation would be 

required.

Effects would be mitigated through the review 

process.

Recreation/Engineering No additional design features. N/A

Heritage Resources All work would remain within existing motorized trail 

system. No additional design features.

Any effects would be mitigated through the 

review process.

Water Quality, Soils No additional design features. Trail maintenance is not a category B project that 

would require consultation with the water board.

Wildlife

All the wildlife design features of the Road 

Maintenance CE would be applied to motorized trail 

maintenance. No additional design features required.

No additional analysis or consultation required.
Appendix D. Mitigation Measures

152 – Smith River National Recreation Area Restoration and Motorized Travel Management

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Appendix E. Cumulative Watershed Effects

Final Environmental Impact Statement – Appendices – 153

Appendix E. Cumulative Watershed Effects Analysis 

Using R-5 ERA Model

Assumptions and ERA Coefficients used for Travel Management 

Assessment

The Forest Service in Region 5 has adopted the Equivalent Roaded Acres (ERA) model as a method of 

addressing cumulative watershed effects. This model is designed as a preliminary indicator for managers to 

determine whether past and present land management disturbances in a given watershed approach or exceed 

a threshold of concern (TOC). Where ERAs approach or exceed a given watershed’s TOC, further fieldwork

would be necessary to ascertain whether cumulative watershed effects are present and if land management 

activities would adversely add to those effects and result in detrimental impacts to beneficial uses.

The ERA methodology has both strengths and weaknesses. The analysis is readily duplicated and 

easily understood. It also incorporates rates of management disturbance and recovery times associated 

with those disturbances, an attribute which is missing in many other CWE models. On the other hand, it is 

only an office exercise based on management-related hill slope disturbance. It also does not address 

physical or biological processes in stream channels, nor does it account for the time lag associated with 

routing sediment delivered from a given activity. Recovery times in the ERA model apply only to onsite 

treatments, not to recovery of downstream impacts.

ERA Calculations

The CWE ERA analysis for the Travel Management Project was conducted on all lands within the 

affected watersheds (Public and Private). The methods used to calculate %ERAs for past and present land 

management activities are described below. The coefficients used in the ERA calculations are listed in 

Tables E-1 through E-6, which include the rational for assigning of coefficients.

ERA Equations and Coefficients for Existing and Current Land 

Management Activities

Timber Harvest

The timber harvest ERA is calculated using the following formula:

• ERA = [Acres Harvested] x [Logging System Coefficient]

Table E-1 lists the coefficients assigned to various logging systems. In addition, the recovery times 

anticipated for each activity is included as well as the type of recovery curves. Some activities recover 

gradually and mimic a linear recovery while other activities recover rapidly initially and then gradually 

taper off. Those activities are better represented by a concave recovery curve.
Appendix E. Cumulative Watershed Effects

154 – Smith River National Recreation Area Restoration and Motorized Travel Management

Table E-1. Logging system ERA coefficient and recovery times.

Logging Activity Logging System ERAs per Acre 

Coefficient Recovery Time Recovery Curve

Changes Fire 0.15 15 Linear

Fuel-Treatment Broadcast Burn 0.04 4 Concave

Fuel-Treatment Burn Piles 0.02 2 Concave

Fuel-Treatment Mechanical 0.15 15 Concave

Fuel-Treatment Piling – hand 0.02 2 Concave

Fuel-Treatment Piling – tractor 0.15 15 Concave

Fuel-Treatment Under burning 0.1 10 Concave

Harvest Change Detection, NFS 0.2 20 Concave

Harvest Change Detection, Other 0.25 25 Concave

Harvest Clear-cut 0.25 25 Concave

Harvest Clear-cut, Skyline 0.2 20 Concave

Harvest Clear-cut, Tractor/Mechanical 0.3 30 Concave

Harvest Group Select 0.2 20 Concave

Harvest Group Select, Helicopter 0.1 10 Concave

Harvest Group Select, Skyline 0.15 15 Concave

Harvest Group Select, Tractor/Mechanical 0.2 20 Concave

Harvest Overstory Removal 0.25 25 Concave

Harvest Overstory Removal, Helicopter 0.1 10 Concave

Harvest Overstory Removal, Skyline 0.2 20 Concave

Harvest Overstory Removal, 

Tractor/Mechanical

0.3 30 Concave

Harvest Shelter wood 0.25 25 Concave

Harvest Shelter wood, Skyline 0.2 20 Concave

Harvest Shelter wood, Tractor/Mechanical 0.25 25 Concave

Harvest Thin 0.2 20 Concave

Harvest Thin, Skyline 0.15 15 Concave

Harvest Thin, Tractor/Mechanical 0.2 20 Concave

TSI Pre-commercial Thin 0.05 5 Concave

TSI Pre-commercial Thin, Biomass 0.15 15 Concave

TSI Pre-commercial Thin, Manual 0.02 2 Concave

TSI Pre-commercial Thin, Tractor 0.15 15 Concave

Roads

The road ERA is calculated using the following formula:

• ERA = [Road Miles] x [Average width of Road Prism]

Road miles (all public, state, county and privately owned) were converted to acres (ERAs) based on 

an average road prism width of 35 feet. Roads are a permanent feature on the landscape and unless they 

are decommissioned or restored, they do not recover over time. As such, their recovery curve is shown in 

Table E-2 as a flat curve. The recovery rate for a decommissioned or restored road, based on professional 

judgment and experience, is estimated to be 10 years. The ERAs associated with open roads will stay 
Appendix E. Cumulative Watershed Effects

Final Environmental Impact Statement – Appendices – 155

constant over time and not reduce as in the case of timber sale acres that recover over time. Table E-2 lists 

the coefficients used to develop ERAs per road mile.

Table E-2. Road ERA coefficient and recovery times.

Roads and Motorized Trails ERAs per Mile Recovery Time Recovery Curve

Existing/In Use 4.2 0 Flat

Decommissioned or Restored 4.2 10 Linear

Wildfire

Table E-3 shows the ERAs assigned to burned areas (within the past 15 years) in the analysis watersheds.

It was assumed that low to moderate burn intensities had no negative watershed impacts. Moderate 

intensity burns were assumed to have a light impact on a watershed similar to that of an extremely light 

land management ground disturbing activity (e.g., timber stand improvement activities). Higher burn 

intensities were given ERAs/Acre similar to more ground disturbing activities such as skyline or cable 

suspension systems and in the case of the most intense burned areas, ERAs/Acre values were assigned 

similar to disturbances associated with tractor yarding systems.

Wildfire burn severity ERAs were calculated using the following formula:

• ERA = Wildfire Acres x Burn Severity (ERAs/Ac) x Burn Recovery Coefficient3

Table E-3. Wildfire equivalent roaded areas.

Wildfire Burn Severity Description ERAs

0 – No burn 0.00

1 – Low burn intensity 0.00

2 – Low to moderate burn intensity 0.00

2a – Moderate burn intensity 0.05

3 – Moderate to high burn intensity 0.10

4a – High burn intensity 0.15

4b – Extreme burn intensity 0.20

Table E-4 illustrates the estimates made as to how long it would take a burned area to recover relative 

to the burn severity. Estimates on recovery times were extremely conservative, especially since evidence 

exists that surface erosion is essentially negligible after the first 1 to 5 years after a fire. However, due to 

the decay of roots associated with dead trees, steep hillslopes may reach maximum instability 10 to 15 

years after the fire and become more susceptible to mass wasting processes.

 

3 Burn recovery coefficient = 1 – (current year–year burned)/years to recover after burn.
Appendix E. Cumulative Watershed Effects

156 – Smith River National Recreation Area Restoration and Motorized Travel Management

Table E-4. Years to recover post-wildfire.

Burn Severity Descriptions Years To Recovery

0 – No burn 0

1 – Low burn severity 0

2 – Low to moderate burn severity 0

2a - Moderate burn severity 5

3 – Moderate to high burn severity 10

4a – High burn severity 15

4b – Extreme burn severity 15

Percent ERAs for all Past Actions (existing condition)

The CWE ERA Analysis for the Travel Management project was conducted on twenty 6th-field 

watersheds (including all federal, state and privately owned lands). The methods used to calculate 

%ERAs for past and present land management activities are described in the above sections. The 

coefficients used in the ERA calculations are listed above in Tables E-1 through E-3.

The following equation is used to calculate total percent ERAs for all past actions and represents the 

current condition:

• %ERA = (([Timber Harvest ERA] + [Roads ERA] + [Wildfire ERA]) / [watershed acres]) x 100

The total percent ERA results are shown below in Table E-5.

Table E-5. Total percent ERAs by watershed.

6th-Field 

Watershed Name

Watershed 

Acres

Existing National 

Forest Roads / 

Motorized Trails

Past National 

Forest Mgmt 

Projects

Private Land 

Timber 

Harvest

Wildfire ERA 

Total %ERA Threshold of Concern

Craigs Creek 11,533 224 12 188 1 425 3.7% 10.0%

Diamond Creek 21,307 312 0 0 1051 1,363 6% 12.9%

Eightmile Creek 15,243 20 1 0 515 536 3.5% 13.1%

Goose Creek 26,022 577 57 70 0 703 3% 11.7%

Hardscrabble 

Creek – Smith 

River

17,788 338 7 15 265 624 4% 10.0%

Hurdygurdy Creek 19,149 303 52 0 0 355 2% 11.9%

Jones Creek 15,714 157 41 0 0 197 1% 12.1%

Lower Middle Fork 

Smith River 27,251 347 31 0 310 687 3% 10.0%

Lower North Fork 

Smith River 35,484 354 7 0 769 1,130 3% 10.0%

Lower South Fork 

Smith River 27,359 433 27 0 236 737 3% 11.6%

Smith RiverFrontal Pacific 

Ocean

25,513 35 0 341 0 376 1% 12.7%

Middle South Fork 

Smith River 33,111 505 65 4 538 1,157 3% 10.7%

Hunter Creek 19,103 72 0 284 0 355 2% 13.1%

Patrick Creek 14,789 369 2 0 37 407 3% 12.9%

Rock Creek 10,288 65 0 95 0 160 2% 11.7%
Appendix E. Cumulative Watershed Effects

Final Environmental Impact Statement – Appendices – 157

6th-Field 

Watershed Name

Watershed 

Acres

Existing National 

Forest Roads / 

Motorized Trails

Past National 

Forest Mgmt 

Projects

Private Land 

Timber 

Harvest

Wildfire ERA 

Total %ERA Threshold of Concern

Rowdy Creek 21,864 198 2 850 25 1,075 5% 10.5%

Siskiyou Fork 

Smith River 17,504 202 31 0 154 425 2% 11.4%

Turwar Creek 20,380 0 1 77 0 77 0.4% 11.7%

Upper Middle Fork 

Smith River 24,177 461 46 3 6 516 2% 11.8%

Upper South Fork 

Smith River 28,514 116 8 0 103 235 0.8% 12.7%

ERA Calculations for Reasonably Foreseeable Future Land Management 

Activities

The same equations as the ones used calculate existing and project related ERAs were used to estimate 

near future timber and fuel treatment projects. The Gordon Hill Vegetation and Fuel Management Project 

was added to the total percent ERAs in the Hardscrabble Creek-Smith River, Lower Middle Fork Smith 

River, Craigs Creek, Hurdygurdy Creek and Lower South Fork Smith River watersheds.

Development of Threshold of Concern (TOC)

Thresholds of concern (TOC) by watershed were developed in 1995 Six Rivers National Forest Land and 

Resource Management Plan revision. The TOC is an estimated upper limit of total disturbance that a 

watershed can tolerate without adverse impacts to beneficial uses. In the event that the %ERAs begin to 

approach a TOC, management actions should be evaluated to insure that detrimental cumulative 

watershed effects do not occur. In developing TOCs, several physical and biological parameters were 

evaluated, including inherent geologic stability, extent of inner gorges plus active and inactive landslides, 

erodibility of soils, slope steepness, status of anadromous fish, condition of riparian areas and others. 

Assigning a TOC to a given watershed is an interdisciplinary professional judgment that weighs the 

various environmental indicators described above. The TOCs for this project range between 10.0 to 13.1 

percent ERAs in all affected watersheds (see Table E-6).
Appendix E. Cumulative Watershed Effects

158 – Smith River National Recreation Area Restoration and Motorized Travel Management

Table E-6. Existing %ERA compared to threshold of concern.

6th-Field Watershed Name Existing %ERA % Threshold of 

Concern

Craigs Creek 3.69 10.0

Diamond Creek 6.41 12.9

Eightmile Creek 0.33 13.1

Goose Creek 2.72 11.7

Hardscrabble Creek-Smith River 3.51 10.0

Hunter Creek 1.86 13.1

Hurdygurdy Creek 1.86 11.9

Jones Creek 1.25 12.1

Lower Middle Fork Smith River 2.52 10.0

Lower North Fork Smith River 3.18 10.0

Lower South Fork Smith River 1.67 11.6

Middle South Fork Smith River 2.96 10.7

Patrick Creek 2.76 12.9

Rock Creek 1.56 11.7

Rowdy Creek 4.93 10.5

Siskiyou Fork Smith River 1.36 11.4

Smith River-Frontal Pacific Ocean 1.47 12.7

Turwar Creek 0.38 11.7

Upper Middle Fork Smith River 2.14 11.8

Upper South Fork Smith River 0.48 12.7
Appendix F. Law Enforcement

Final Environmental Impact Statement – Appendices – 159

Appendix F. Law Enforcement

Forest Service Law Enforcement and Investigations (LEI) personnel are responsible for protecting the 

public, employees, natural resources, and other property under the agency’s jurisdiction. Additionally, 

LEI investigates and enforces applicable laws and regulations that affect the National Forest System 

(NFS) lands and prevents criminal violations. The Travel Management Rule is one such regulation.

The Travel Management Rule requires designation of roads, trails, and areas open to motor vehicle 

use, and the prohibition of cross-country wheeled motor vehicle travel by the public. The implementation 

of designated routes and areas for motor vehicles will be the responsibility of all agency employees, 

especially in the area of education and enforcement. The law enforcement program is primarily 

responsible for issuing violations to enforce the Travel Management Rule.

The national LEI budget is funded by appropriated dollars from Congress to provide law enforcement 

services on the NFS lands. The Travel Management program is one of many forest programs to benefit 

from federal law enforcement funding. Law Enforcement and Investigations staff work in cooperation 

with Forest Service line officers to accomplish forest resource management objectives, yet LEI is 

administratively separated to maintain legal and investigatory independence.

To enhance enforcement of Travel Management Rule, Region 5 Forest Recreation Programs applied 

for and received grant dollars (green sticker funding) from the State of California Off-Highway Motor 

Vehicle Recreation Division Grants Program. These state funds are earmarked specifically for enforcement 

of off-highway vehicle laws and regulations on the various forests, and are performed primarily by forest 

protection officers (FPOs). In addition, law enforcement officers (LEOs) support the FPOs as needed, 

especially if serious violations occurred. In recent years, state law enforcement grants ranged from 1.26 to 

1.67 million dollars annually with similar funding anticipated for the 2014-2015 grant cycle.

Authority and Jurisdiction

The Forest Service exercises its law enforcement authority when violation of laws or regulations occurs 

on NFS lands or when incidents affect the NFS. The existing authorities for enforcement are completely 

adequate and no new laws will be needed to enforce the Travel Management Rule.

Every national forest annually updates a law enforcement plan. All Forest Service employees have a 

duty to know and understand their authorities and responsibilities, and to properly enforce laws and 

regulations relating to the forest within their authority and capability. Law Enforcement and 

Investigations and agency personnel provide a regular and recurring presence on vast amounts of public 

land, roads, trails, and areas taking appropriate action if illegal activity is discovered. Violations are 

primarily enforced by LEOs and FPOs who patrol off-highway use roads, trails, and areas. Law 

enforcement officers use discretion when deciding what type of action to initiate when handling violations 

to the following federal laws that pertain specifically to motor-vehicle use.

• The Act of June 4, 1897 (Title 16 USC 551) is the authority for issuing regulations at 36 CFR 

261. Specific OHV travel management regulations are in §261.9 – Property, §261.13 – Motor 
Appendix F. Law Enforcement

160 – Smith River National Recreation Area Restoration and Motorized Travel Management

Vehicle Use, and §261.15 – Use of Vehicles Off-Road. These CFRs cover a wide array of 

misdemeanor infractions.

• The Act of March 3, 1905 (16 USC 559) authorizes all employees of the Forest Service to make 

arrests for violation of the laws and regulations pertaining to national forests. Normally, arrest 

authority is limited to trained law enforcement personnel. Any employee may take immediate action 

when necessary to protect life and prevent serious damage to or destruction of property, escape of a 

suspect, or loss of material evidence when such action can be done with reasonable safety.

The legal foundation for enforcement on the forest was established by Congress as proprietary 

jurisdiction. This term means that the federal government has acquired some degree of right or title to an 

area in a state, but has not obtained any measure of the state’s authority over the area. The legal scope of 

the Forest Service is limited to laws established for that property, or national forest. However, 

enforcement agencies with state authority in California retain their full legal authority on the forest.

Notably, for enforcement of violations committed by motor vehicle operators, the California Highway 

Patrol and the four county Sheriffs have separate authority and jurisdiction to enforce OHV laws under 

the California Vehicle Code (CVC).

In November 2008, the Regional Forester signed a new regional order that allows Forest Service 

officers to enforce the OHV section (CVC §38000) of the CVC on NFS roads.

Cooperation

The Forest Service shares responsibility and cooperates with local, state, and other federal agencies in the 

execution of its law enforcement program. The authority for cooperation among agencies, especially as it 

pertains to Travel Management Rule is within the following laws:

• The Act of August 10, 1971 (16 USC 551a) authorizes the Secretary of Agriculture to cooperate 

with, and provide reimbursement to, any state or political subdivision thereof, for the enforcement 

of their laws within NFS. This law does not deprive any state or local law enforcement agency 

from exercising its criminal and civil jurisdiction on lands that are part of the NFS.

• California Penal Code §830.8 provides that Forest Service law enforcement personnel may 

exercise state peace officer authority where the sheriff of the county wherein the officer works 

provided specific written permission for the officer.

• California Vehicle Code §38301 allows state law enforcement officers to support enforcement of 

any of the federal CFRs related to motor vehicles on NFS lands (CVC penalties would apply.).

Each forest maintains close working relationships with many state and local law enforcement 

agencies with law enforcement responsibilities in or adjacent to the forest boundary. Significant 

cooperating agencies relative to enforcing Travel Management Rule include the local county sheriff 

departments, the California Department of Fish and Game, California Highway Patrol, California 

Department of Forestry and Fire Protection, and occasionally one or more Federal agencies depending on 
Appendix F. Law Enforcement

Final Environmental Impact Statement – Appendices – 161

the violation. Forest Service law enforcement personnel cooperate fully with these agencies in carrying 

out their law enforcement responsibilities by providing assistance, liaison, advice, and information.

Forests maintain Cooperative Law Enforcement Agreements with their respective county sheriff’s 

office. These funds are for performance of duties in addition to the normal activities in which the sheriff’s 

deputies handle crimes against persons and their property that may occur within the NFS boundary. In 

these agreements, both parties recognize that public use of NFS lands is usually located in areas that are 

remote or sparsely populated and the enforcement of state and local law is related to the administration 

and regulation of NFS lands. Within the Cooperative Law Enforcement Agreements, an operating plan is 

developed outlining the supplemental work to be performed by the cooperating agency. Operating plans 

may provide:

• Supplemental patrols in areas of high use.

• Supplemental patrols on weekends or during particular months of high use.

• Additional officers for large group gatherings or events (Enduros).

• Vehicle checkpoints for vehicle registration spark arrestors, and other miscellaneous items.

Implementation and Tracking

Implementation of the Forest Service law enforcement program is continually adapting as law 

enforcement personnel assess the changing patterns of visitor use and attitudes, and the trends in 

violations, especially for property and resource damage. One method of assessment is the analysis of Law 

Enforcement and Investigations Management Attainment Reporting System (LEIMARS) data. LEIMARS 

tracks all known violations of criminal law or regulation on NFS lands (FSH 5309.11 Chapter 40 and 

FSM 5340). Additionally, imbedded in LEIMARS is the Case Tracking System, which tracks all felony 

and serious misdemeanor cases. These tracking systems:

• Capture and record information on location, volume, damages, and type of violations occurring 

on NFS lands.

• Provide a retrieval system of data on incidents and violations that is responsive to the needs of all 

organizational levels.

• Provide agency managers with a means to identify and monitor law enforcement activities.

• Specifically identify problem areas and periods of activity.

• Provide a method to record and analyze incidents involving violations or suspected violations on 

NFS lands.

Trends in violations can be analyzed and appropriate action(s) taken, if needed. Appropriate action(s) 

may involve one or more techniques or adaptive strategies. In the law enforcement community, this is 

often referred to as the three E strategy of engineering, education, and enforcement. With the changes to 

how the public accesses and travels on NFS lands, it is anticipated that the law enforcement program will 

use a combination of strategies, especially during the first five years of implementation of the MVUM.
Appendix F. Law Enforcement

162 – Smith River National Recreation Area Restoration and Motorized Travel Management

Assumptions

Based on many years of enforcing off-highway vehicles, implementing change in access and enforcement 

of Travel Management Rule, from a law enforcement perspective, assumes the following assumptions to 

be true. These assumptions may change over time with analysis of the LEIMARS database.

Enforcement Assumptions

• Enforcement of the laws and regulations related to Travel Management Rule are enforced equally in 

authority and weight as with all other Federal laws and regulations.

• As with any change in a regulation on NFS lands, there is usually a transitional period for the public 

to understand the changes. It is anticipated there will be a higher number of violations to Travel 

Management Rule in the first couple of years and the number of violations will decline as the users 

understand and comply with the rules.

o Users in communities adjacent to the forest will comply within 1 to 2 years.

o Frequent users, but further in distance from the forest, will comply within 2 to 3 years.

o Infrequent users regardless of distance may take up to 5 years to comply.

• Law enforcement officer and agency personnel’s presence and enforcement actions will positively 

affect OHV users’ behaviors and attitudes.

• The MVUM defines the designated routes, season of use, and type of use, therefore, making 

violations unequivocal.

• Once the MVUM is published, the designated network of roads and trails with signs, and user 

education programs, will reduce the number of violations.

• Depending on location of the forest, FPOs may spend a large percentage of their time on travel 

management issues.

Agency Funding Assumptions

• Appropriated program funding levels and number of law enforcement personnel does not affect 

enforcement of Travel Management Rule. All laws and regulations are enforced equally.

• The state of California Off-Highway Motor Vehicle Recreation Division Grants Program (green sticker 

funding) enhances and provides additional law enforcement presence in the field at the forest level.

Public Attitude and Compliance Assumptions

Forest users want to do the right thing, and will therefore, obey the Travel Management Rule (Tyler 

2006), once they understand the Travel Management Rule and Motor Vehicle Use Map (MVUM).
Appendix F. Law Enforcement

Final Environmental Impact Statement – Appendices – 163

Measure of Success

Measuring the success of the compliance with Travel Management Rule will be done using the LEIMARS 

database. An analysis of the data may alert a forest to a particular problem area for violations such as a 

dispersed group campsite area that may be surrounded by flat meadow areas inviting riders to potentially 

violate the regulation. A successful program will see a positive change in the following measures:

Measure 1. A reduction in the number of off-route travel violations.

Measure 2. A reduction in the number of resource damage violation.
Appendix F. Law Enforcement

164 – Smith River National Recreation Area Restoration and Motorized Travel Management

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Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 165

Appendix G. Response to Comments

One goal of NEPA is to inform decision makers about the consequences of proposed and alternative 

actions. Public comments play a role in guiding the scope of the analysis and in identifying concerns to be 

addressed through the decision making process. The preparation of a NEPA document does not determine 

which alternative to choose. It does not prevent environmental impacts from happening or guarantee the 

final decisions will resolve everyone’s concerns. It does not prohibit any actions. Simply stated, NEPA is 

a public information disclosure process that results in better and more informed decision.

The public was invited to submit comments on the proposed action during the scoping period in April 

2012. Comments submitted during the scoping period were analyzed to identify significant issues. 

Alternatives to the proposed action were considered and developed that address the significant issues that 

were within the scope of the project, compliant with law, regulation, and policy, within the agency’s 

purview to implement, and met the purpose and need of the project. The public was invited to provide 

comment on the DEIS, and will be given the opportunity to review the FEIS and draft Record of Decision 

and participate in the Objection process (36 CFR 218 subparts A and B). Three significant issues, 

including Impacts to Access and Recreation Opportunity, Impacts to Inventoried Roadless Areas, and 

Impacts to Resources, drove the development of three action alternatives, which include a modified 

version of the proposed action. These alternatives range from one alternative that emphasizes motorized 

recreation opportunities by proposing designation of motorized trails on the Smith River NRA, including 

designation of additional miles of motorized trails in IRAs, to another alternative that emphasizes risk 

reduction to resources by not designating any additional motorized trails that occur within IRA boundaries 

or have any occurrences of sensitive plants within 30 feet of the UAR.

To systematically document and respond to the concern of the public, each comment letter was 

assigned a number with each comment within that letter also receiving a number – resulting in a unique 

identifier for every comment (e.g., 42-5 would be the 42nd letter, 5th comment in that letter). An initial 

analysis was completed using the Content Analysis and Response Application (CARA) software to 

identify form letters and unique letters. CARA was further used in the content analysis process to code 

issues. The interdisciplinary team worked in concert to sort comments into two categories: substantive 

and non-substantive comments.

Substantive comments identify an issue or concern that commenter has with the project, or identify 

where more information or clarification is needed. The SRNF may respond to such comments by 

expanding modifying the scope context and/or parameters of the analysis, changing the parameters of the 

analysis, developing a new or modifying an existing alternative, or providing an answer, clarification, or

further information when appropriate.

Non-substantive comments do not state a cause-effect relationship related to the project, but offer 

opinions about the project or vote on their favorite alternative. While these comments cannot be used to 

affect the scope of the analysis or drive the development of an alternative, they are helpful in providing 

the decision maker a sense of the community values and sentiments at stake in the decision. Other non-
Appendix G. Response to Comments

166 – Smith River National Recreation Area Restoration and Motorized Travel Management

substantive comments are either beyond the scope of the project, or beyond the authority of decision 

makers to address.

The Six Rivers National Forest (forest or SRNF) received 854 comments during the comment period

in response to the draft environmental impact statement (DEIS), including comments from Del Norte 

County Board of Supervisors, Smith River Alliance, Northwest Trail Riders, Blue Ribbon Coalition, 

Klamath-Siskiyou Wildlands Center, Del Norte Resource Advisory Committee, Deschutes County 4 

Wheelers, Four Runners of Klamath Falls, Pacific Northwest Four Wheel Drive Association, PacifiCorp, 

ADH Environmental, US Environmental Protection Agency (EPA), USDI Office of Environmental Policy 

and Compliance, and 841 individuals. The full list of commenters is located at the end of this appendix.

Organizational Structure of Response to Comments

To assist the reader in locating comments related to their issue of interest, the response to comments is 

organized by general comment categories, topics and sub-topics, where applicable. In many cases, multiple 

comments were submitted that addressed one topic or subtopic. Such comments were grouped and 

presented in a table with unique identifiers (letter and comment number). Identical comments are grouped 

and listed in the table with their unique identifiers. Following is an example of the organizational structure:

General Comment Category

Topic

Sub topic (if applicable)

Letter 

Number

Comment 

Number Comment Text

Number Number Comment

Response: SRNF response to comments received on this concern statement.

In some cases, a large number of similar comments that covered a number of inter-related topics were 

received. In such cases, a concern statement was generated to summarize the issues identified in the 

comments for the ease of the reader. Representative example comments are provided to give the reader a 

sense of the tone and breadth of the comment, which is followed by the forest’s response. Following is an 

example of the organizational structure described above:

General Comment Topic

Sub topic (if applicable)

Concern Statement: like comments were summarized into a concern statement.

Example Comments: example of comments (with unique number identifier)

Letter 

Number

Comment 

Number Comment Text

Number Number Comment

Response: SRNF response to comments received on this concern statement.
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 167

Project Development, NEPA and Implementation

Use of the Travel Analysis Process (TAP) in Alternative Development

Letter 

Number

Comment 

Number Comment Text

819 26

It appears that the findings of the Forest Service 2005 RAP regarding the need for a minimum road 

system and the risk/need assessment seem largely irrelevant to the content of the agency’s 

preferred alternative. Rather than utilize the data in the RAP to inform the agency proposal, it 

appears that decision making authority has been largely handed over to the collaborative group 

assigned with adding controversial high-risk routes to the NFTS.

819 97

The 2005 RAP identified the minimum road system and produced risk/need assessments, which 

provide a rational basis for determining the size of the NFTS in relation to the agency’s maintenance 

obligations. Yet this information was not utilized in developing the preferred alternative. Instead the 

Forest Service insists on adding high risk-high maintenance – low use motorized trails in some of 

the most sensitive botanical, roadless and POC watersheds in the Recreation Area. Such an 

approach is arbitrary and capricious.

819 133

Please Account For Changes in Use Patterns and For Impacts From Roads That Were Not Built To 

USFS Specifications. While it is true that some of the routes proposed for addition to the road 

system have been in existence for many years, this does not mean their uses, especially the 

changing use patterns and increasing “extreme” use, will not result in additional significant 

hydrological and botanical impacts. Many of the routes of concern were established either by 

repeated travel or by miners with bulldozers for the purpose of mining access, mineral exploration, 

or for mining claim assessment work. They were not established to Forest Service specifications or 

standards and were located without consideration of resource protection and values.

Response: The 2005 Smith River NRA Roads Analysis (RAP) addressed Forest System roads with a 

maintenance level of 1 through 5, as well as inventoried Unauthorized Roads (UARs) for planning. One 

of the purposes of this project is to implement the recommendations identified in the 2005 RAP and 

revised by the USFS Travel Analysis Process (TAP) guidance, and the 2005 Travel Management Rule 

(cite), which identified public and administrative access needs.

As stated in the 2005 RAP, the intent of the analysis was to provide decision-makers with critical 

information to develop a road system that is safe and responsive to public needs and desires as well as has

minimal negative ecological effects on the land. To that end, the forest has provided multiple 

opportunities for the public to provide information on what roads/routes are needed for access, with the 

majority of public comments provided after the RAP was completed. The RAP is a planning tool, not a 

decision document, and both resource risk and public need ratings were modified based on information 

provided by the public during the NEPA process in the 11 years since the RAP was completed. The RAP 

and subsequent public comments were indeed used to develop the preferred alternative. Only roads/routes 

with an identified public or administrative need were proposed for addition, provided any identified 

resource risks could be mitigated. No low-use routes proposed for addition to the system.

The collaborative group, convened by US Institute for Collaborative Policy, was narrowly focused on 

reaching agreement on nine UARs in IRAs that were the subject of two appeal processes in the 2007 

Road Management and Decommissioning NEPA process. Some interest groups that were invited to 

participate in the collaborative group choose not to participate.

All action alternatives will reduce roads/routes miles across the NRA by between 21 and 47 percent, 

including in sensitive plant habitat and POC areas. Routes will only be added to the system provided

resource risks can be mitigated. All action alternatives would result in resource protection benefits
Appendix G. Response to Comments

168 – Smith River National Recreation Area Restoration and Motorized Travel Management

including 1) less than 0.1 percent of the serpentine sensitive plant habitats on the NRA are being affected; 

2) all routes into the North Fork Botanical Area are being closed, protecting over 20,000 acres of potential 

habitat; 3) routes to be kept will be upgraded to correct drainage problems, and 4) POC protection 

measures are common to all action alternatives.

The majority of UARs on the NRA are not user created routes. They include old mining roads, old 

logging roads from previously private land that was later acquired by the FS, and previous access routes 

to private lands. Although construction standards have changed and improved, many of these old roads 

were engineered. Mitigations proposed in this project would minimize resource impacts. The Forest 

Service would close and restore between 2 to 4 times the miles of UARs that would be added. Adding the 

UARs that are needed for access would be consistent with Forest Service Rules and Regulations.

Coordination with Del Norte County

Coordination Process

Letter 

Number

Comment

Number Comment Text

826 1

Specifically, it is the opinion of the BOS that the following issues require further review before this 

plan can be adopted: outstanding conflict with the Del Norte County General Plan’s stated goal of 

maintaining recreational opportunities in the County, negative effects on public safety, diminished 

access to historic areas, errors and inconsistencies in mapping, and a failure to sufficiently 

coordinate the planning process with the County.

826 15

The Forest has not coordinated with the County pursuant to the various section of law pertaining to 

coordination (i.e. FLPMA 43 USC 1712, 1982 Planning Rule Section 219.7, 2012 Planning Rule 

Section 219.4, etc.) as well as the 2012 Memorandum of Agreement (MOA) signed by the Regional 

Forester, the Bureau of Land Management, the California State Association of Counties (CSAC), 

and the Regional Council of Rural Counties (RCRC) and adopted locally under Del Norte County 

Resolution 2012-06. Under the terms of the MOA all Forests within the Pacific Southwest Region 

are required to participate in meetings with their respective county’s Board of Supervisors at any 

time during the planning process.

826 16

While the Forest’s preferred alternative (Alternative 6) may come closest to achieving the goals 

identified by the Forest it falls well short of the Board’s hope for a plan that accommodates the needs 

of the County and the policies adopted by this Board. It is the opinion of the BOS that had the Forest 

adequately engaged in coordination many of the issues identified herein could have been more 

appropriately addressed in this plan. At this time, we have reservations with all of the alternatives, 

including the Forest’s preferred alternative, and request that the Forest not proceed with the adoption 

of the plan until the issues identified herein can be resolved through adequate coordination with the 

BOS and/or incorporation of the amendments in these comments. While the BOS appreciates the 

considerable efforts the Forest has undertaken in the development of this Plan we ask that you contact 

the County Administrative Officer, Jay Sarina, who is designated by Del Norte County Resolution 

2012-06 as the point of contact between the County and the Forest, for proper coordination. It is our 

sincere hope that a final plan may be adopted that best accommodates the goals established by the 

County Board of Supervisors and the Six Rivers National Forest for the NRA.

826 17

At this time, the BOS has significant reservations with the project, as proposed, as well as concerns 

relating to the process by which the Forest has solicited the BOS’s involvement in the development 

of this plan.

Response: The Forest Service has coordinated extensively with the Del Norte County over the 12 years 

of the RAP and NEPA process. These opportunities included meetings, field trips, and months of review 

time. Numerous two-by-two meetings with Board members regarding travel management have been 

conducted since this process began. On August 3, 2009, Del Norte County Board of Supervisors and staff 

met with Forest Service representatives, including Regional Forester Randy Moore, Forest Supervisor 
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 169

Tyrone Kelley, Deputy Forest Supervisor Nancy Gibson, District Ranger Mary Kay Vandiver, and Forest 

staff to discuss the Smith River NRA travel management process. The Forest Service proposed the use of 

a collaborative process to proceed with the Travel Management EA. The process was designed to include 

appellants to the two previous Decisions, as well as interested stakeholders. The Board agreed to 

participate, provided the forest use the first Decision (dated April 4, 2007) as the starting point for the 

process. The draft proposed action presented to the collaborative group included the all the actions and 

tables from the first Decision. During the collaborative process, Mr. Kelley and Ms. Vandiver met with 

the Board, and were commended on the process. Since that time, current Forest Supervisor Merv George 

Jr. and current District Ranger David Palmer have met with the Board on numerous occasions, including a 

field trip to discuss specific road issues.

The SRNF has coordinated with Del Norte County as required, and has met its obligations under the 

law. See Chapter 1 under the Public Involvement section, subheading County Coordination for the 

response to these comments.

Consistency with Del Norte County General Plan and Smith River NRA Act

Letter 

Number

Comment 

Number Comment Text

826 6

The purpose, as stated in the Smith River NRA Management Plan, for the establishment of the 

Smith River NRA includes ensuring that recreational opportunities are preserved (specifically, the 

need to provide a broad range of recreation uses including roads, trails, and OHV routes). The 

concept of road “restoration”, decommissioning, and downgrading to ML 1, as expressed in the 

proposed plan, should present cause for concern to the forest managers in that such actions are in 

conflict with the NRA’s Management Plan in regard to ensuring recreational opportunities.

According to the plan (pg. 54-56) under the preferred alternative a total of 42 miles will be added to 

the NFTS however it is important to note that these routes are not actually going to be “added” so 

much as the Forest would now merely recognize these existing non-system routes. On the other 

hand, under the preferred alternative, 53 miles of roads will be removed (decommissioned) from the 

NFTS, another 40 miles would be downgraded to level 1 roads (closed) and 98 miles of roads would 

be “restored”. In meetings with the public it was noted that the terms “restored” and “unauthorized 

routes” were considered to be offensive language to many long time users of these non-system 

routes. The term “restored”, in particular, was taken as a duplicitous term in that it implies a positive 

end use when, in fact, the term includes actions such as “placing vehicle barriers, installing 

waterbars and culvert removal.” Furthermore, the BOS questions why despite roads being classified 

as low risk and moderate risks to water quality so many road miles are scheduled for decommission 

(35 miles of “low risk” and 7 miles of “moderate risk”), downgrade to level 1 (21 miles of “low risk”

and 6 miles of “moderate risk”), or “restoration” (71 miles of “low risk” and 13 mile of “moderate 

risk”). With the NRA Management Plan’s goal of ensuring recreational opportunities in mind it is not 

appropriate that these “low risk” and “moderate risk” roads should be considered for 

decommissioning, downgrading to level 1, or restoration if they do not pose significant threats to the 

environment. When taking all of the proposed actions into consideration it appears that a net 

reduction in access would clearly arise from adoption of the preferred alternative, which presents a 

conflict with the stated goals of the County General Plan as well as the Smith River NRA 

Management Plan relating to recreational opportunities.

826 3

Conflict with the Del Norte County General Plan Diminished Recreational Opportunities Section 5 of the 

Del Norte County General Plan outlines the County’s goals, policies, and programs for the continued 

development and enhancement of Del Norte County’s rich recreational opportunities and cultural assets. 

Under Policy 5.B.1 the General Plan states: “The County shall encourage Federal, State, and local 

agencies currently providing recreation facilities to maintain, at a minimum, and improve, if possible, their 

current levels of service.” Under all but one (the No Action Alternative) of the various alternatives 

presented the Forest would effectively close routes that have been recreationally used for many 

generations. It is the opinion of this Board that any restoration (closure), decommissioning, or 

downgrading of roads or trails represents a reduction in recreational opportunities.

Response: The Del Norte County Board’s opinion that any restoration of drainage patterns, 

decommissioning, or downgrading of roads represents a reduction in recreational opportunities that have 
Appendix G. Response to Comments

170 – Smith River National Recreation Area Restoration and Motorized Travel Management

been used for many generations, and that only Alternative 1, the No Action alternative avoids this 

reduction, yet does not take into consideration the Smith River National Recreation Act of 1990 (16 USC 

460bbb et seq.), which restricted travel on the NRA to designated National Forest Transportation System 

(NFTS) routes. The Smith River NRA does currently have a map of all designated NFTS routes; those are 

shown on the Alternative 1 National Forest Transportation System map with the EIS. Routes that are not 

already designated as part of the NFTS are not on that map and are not legally available for motorized 

travel, based on the Smith River NRA Act. In order for the public to legally use these routes in the future, 

the Forest Service must designate them on the Forest Transportation System. Alternative 1 does not 

designate these UARs to the Forest Transportation System. Therefore, these unauthorized (non-system) 

routes would not continue to be available for under Alternative 1 and would not be illustrated on the 

Motor Vehicle Use Map (MVUM). Any of the action alternatives (Alternatives 4, 5, and 6) designate 

more of these routes to the Forest Transportation System than Alternative 1 does, so that these routes can 

be used for motorized recreation in the future within the parameters of the law.

Unauthorized routes and roads that provide access to recreation opportunities, or fulfill administrative 

access needs will be designated or maintained on the NFTS provided risks can be mitigated to an 

acceptable level. The 1990 Smith River NRA Act restricted motorized travel to designated NFTS routes. 

In 2009, the forest published the MVUM for the Smith River NRA, in compliance with Subpart B of the 

Travel Management Rule. The MVUM displays the current designated NFTS of roads and motorized 

trails open for motorized travel on the NRA pursuant to the Smith River NRA Act and 36 CFR 212.51.

Unauthorized routes, while recognized as having an existing footprint on the landscape, are not part of the 

designated NFTS and therefore are not currently open to legal motorized use. Routes added to the NFTS, 

in other words, designated as part of the NFTS, would be legally authorized for motorized use.

Through the Scoping process, it was identified that the term restoration meant different things to 

different people. In response, the term was changed to restoration of drainage patterns on unauthorized 

routes in the DEIS. Restoration of drainage patterns on unauthorized routes is one of the main proposed 

actions described in Chapter 2 (Description of Alternatives section) and includes waterbars, rolling dips, 

removal of culverts and associated fill, and barricades.

Risk to water quality was just one of several criteria considered in the alternatives. The preferred 

alternative reduces the miles of roads the forest is responsible for maintaining while increasing the 

number of miles of motorized on the NFTS. Under Alternative 6, there is a net increase in legally 

authorized motorized trails, compared to the current condition analyzed as Alternative 1 (No action). The 

forest reviewed the County General Plan and presented the elements of the Plan identified as having 

relevance to the Project to the County BOS through the two-by-two coordination process on October 25, 

2011. The forest found that the purpose and need of the Project and the County General Plan were 

consistent in that they both identified recreation opportunities as a need but also recognized the need to 

reduce risk to ecological resources. At no time, have any goals or policies from the County General Plan 

been presented to the forest that show the Project and the General Plan to be inconsistent.
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 171

Planning Process (including NEPA)

Letter 

Number

Comment 

Number Comment Text

1 1 I am dismayed by the direction that the Smith River National Recreation Area Travel Management 

process is taking. (615-1, 635-1, 759-1, 791-1)

605 1

I am dismayed by the direction that the Smith River National Recreation Area Travel Management 

process is taking. Living in this beautiful redwood and world-treasure biologically diverse area, I 

have seen FAR too much illegal and legal destruction by ORV use. I feel, along with many who do 

not actively communicate with governmental agencies, that ORVs MUST BE BANNED 

COMPLETELY FROM USE ON PUBLIC LANDS. Being educated in biology and spending much 

time, observing and exploring the organisms and ecosystems that make up this area, and other 

areas in the Western USA, I recognize the need for preservation.

819 41 The preference of some in the collaborative group to encourage and codify off-road motorized use 

of IRAs does not relieve the agency of its NEPA or NFMA responsibilities.

Response: The purpose and need of the project is consistent with the Smith River NRA Act (5.a.2) 

which states “Provide and maintain adequate public access, including vehicular roads for general 

recreational activities such as camping, hiking, hunting, and fishing”. The 1990 Smith River NRA Act 

restricted motorized travel to designated routes.

The SRNF is pursuing the revision of the designation of the NFTS through the development of an 

Environmental Impact Statement pursuant to the National Environmental Policy Act (42 U.S.C. §§4321-

4370f). The Responsible official will consider the public’s comments and the impacts to resources 

displayed in Chapter 3 in selecting the alternative that best meets the purpose and need of the project.

Consistency with NFMA and the Forest Plan is required for all project alternatives. The FEIS will display 

the effects to Inventoried Roadless Area character and values, and will be considered by the Responsible 

Official in the decision making process.

Letter 

Number

Comment 

Number Comment Text

819 25

We remain extremely concerned that this NEPA process may be a precursor to an inevitable and 

forgone decision. As you know, for a wide variety of reasons, many of our organizations elected not 

to engage in the “collaborative group” stakeholder process for this project. Collectively our 

organizations represent thousands of Americans who value wildlife, water quality, botanical 

hotspots and wildlands.

Response: The collaborative group, convened by US Institute for Collaborative Policy, was narrowly 

focused on reaching agreement on nine UARs in IRAs that were the subject of two appeal processes in 

the 2007 Road Management and Decommissioning NEPA process. Some interest groups that were 

invited to participate in the collaborative group choose not to participate. The project record will show 

that the procedural aspects of the current analysis comply with the legal requirements of NEPA. The 

alternatives currently under consideration were developed in response to comments received during an 

open public scoping process, and address significant issues identified by all responding segments of the 

public. The preferred alternative, Alternative 6, is not identical to the previous proposed action, which 

was the result of the collaborative process. The Responsible Official will consider these and other issues 

brought forth by the public to select the alternative that best responds to those issues while meeting the 

project’s purpose and need.
Appendix G. Response to Comments

172 – Smith River National Recreation Area Restoration and Motorized Travel Management

Violation of Administrative Procedures Act

Letter 

Number

Comment 

Number Comment Text

819 106

The Proposed Action violates the Administrative Procedure Act: The purpose of the project is to 

establish “a system of roads and designated routes that: is safe and responsive to public needs and 

desires; is more affordable and efficient to manage; has minimal negative ecological effects on the 

land; is in compliance with the Smith River NRA Act.” The proposal to adopt a road and motorized 

trail system where there is zero likelihood it can be maintained to standard does not meet the

purpose and need for the following reasons: a. The system has zero likelihood of being maintained 

to standard and this will result in significant risks to the safety of the public/system users. b. Failure 

to maintain the system to standard will not minimize ecological effects on the land.

Response: As stated above, all action alternatives will reduce roads/routes miles across the NRA by 

between 21 and 47 percent, which will reduce resource risks and maintenance costs.

The Record of Decision (ROD) is informed by the public comment and the analysis contained within 

the final Environmental Impact Statement. The ROD articulates Responsible Official’s rationale for the 

decision, including how the selected alternative responds to the purpose and need, addresses significant 

issues, and complies with the Travel Management Rule as well as other law, policy and regulation 

relevant to this project. Specific concerns stated above are also addressed in the Transportation section of 

Chapter 3 related to funding and safety concerns.

Compliance with the Travel Management Rule

Letter 

Number

Comment 

Number Comment Text

830 12

A favored line of present attack will be through the “minimization criteria.” The minimization criteria 

have been around since 1972 and long received only passing interest, but have acquired teeth 

largely through recent litigation involving similar regulatory language addressing management of the 

National Forest System. See, 36 CFR § 212.55(b) (requiring agency to “consider effects...with the 

objective of minimizing” a variety of factors including damage to soil, watershed, vegetation and 

other forest resources; harassment of wildlife and significant disruption of wildlife habitats; conflicts 

between motor vehicle and other uses; and conflicts among different classes of motor vehicle uses). 

In particular, this renewed interest springs in large part from the decision by a U.S. Magistrate 

declaring invalid the Salmon Challis NF travel decision. This decision was issued in 2011, and is 

published as Idaho Conservation League v. Guzman, 766 F.Supp.2d 1056 (D.Idaho 2011). In short, 

that decision rejected the Forest Service effort to characterize the minimization criteria as providing 

broad guidance (“consider with objective of minimizing”) and interpreted the language as requiring 

the agency to show, in its NEPA analysis, how it applied the minimization factors in selecting from 

decision options for specific routes. There have been several more decisions that have followed 

similar reasoning, which have only come from federal district courts. The 9th Circuit has on three (3) 

occasions heard cases involving the OHV “minimization criteria” and has declined to follow the 

Guzman court’s reasoning in two of those cases, with the third still under advisement following 

argument on November 7, 2013. The agency has broad discretion applying the minimization criteria 

and is certainly not obligated to restrict motorized access, particularly in response to the subjective 

complaints or other “evidence” provided by self-interested non-motorized use advocates. Several 

decisions reflect this important truth, most notably the two (2) 9th Circuit decisions on the topic, both 

issued in unpublished memorandum dispositions. See, The Pryors Coalition v. Weldon, 803 

F.Supp.2d 1184 (D.Mont. 2011), aff’d, __Fed.Appx.__, 2014 WL 46468; The Wilderness Soc’y v. 

BLM, 822 F.Supp.2d 933, aff’d, 526 Fed.Appx. 790 (2013). Relatedly, non-motorized recreationists 

have no inherent “right” to exclusive use, or any use, that exceeds or trumps those of other 

recreationists. See, Bicycle Trails Council of Marin v. Babbitt, 82 F.3d 1445 (9th Cir. 1994) (rejecting 

challenge to NPS management plan restrictions on bike access). The agency cannot be strongarmed into motorized use closures or restrictions, and a well-reasoned and documented balance 

affording reasonable opportunities to a spectrum of recreational uses will be upheld by the courts. 

BRC was a party in the Pryors case, and a copy of the Circuit’s decision can be viewed at:

http://www.sharetrails.org/uploads/54-1-Memorandum_decision_01.07.14.pdf
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 173

Letter 

Number

Comment 

Number Comment Text

830 13

Another area of frequent preservationist attack, as a subcategory of the minimization arguments or 

an independent line of attack, is the assertion of “user conflict” which allegedly requires designation 

of exclusive non-motorized recreation areas. Again, these claims have been recently and forcefully 

rejected by the courts, as was recently punctuated by the decision in Wild Wilderness v. Allen, 

__F.Supp.2d__, 2014 WL 1477398 (D.Or. 2014), in which the court found that “tradeoffs between 

motorized and non-motorized users have already occurred and will continue in the future. The 

record demonstrates that the Forest Service is continuing a long, inclusive process to manage 

winter recreation use on the Cascade Lakes Highway.” The court’s decision may be viewed at:

http://www.snowmobilers.org/docs/KAPKA-decision-March-2014.pdf

Response: The 2005 Smith River NRA RAP and subsequent NEPA process identified site-specific 

resources risks and site-specific mitigations for every road and UAR on the NRA. However, in the 

decision making process, the Responsible Official will consider the ‘minimization criteria’ (36 CFR 

§212.55) while weighing the alternatives as it is part of the project’s purpose and need. The Record of 

Decision identifies the considerations and rationale that support the decision.

Scope of Analysis

Letter 

Number

Comment 

Number Comment Text

819 91

In addition, routes under consideration cross administrative boundaries into the Rogue RiverSiskiyou National Forest (RR-SNF). NEPA analysis of the project’s impacts should not stop at the 

Six Rivers National Forest (SRNF) boundary. Proliferating use on the SRNF will increase use and 

impacts on the adjacent RR-SNF. Of special mention are roads 16N19 (plus spurs) and 405.103 

which present a serious 21 habitat fragmentation problem. These roads have very high 

maintenance requirements. This system duplicates a cut across route along 17N07.

Response: While the roads managed by the Rogue River-Siskiyou NF are beyond the scope of the 

proposed actions, the analysis area extent by resource is explained in Chapter 3. Pertaining to the specific 

concerns identified by the commenter, all action alternatives will reduce the miles of roads and 

unauthorized routes across the NRA. 16N19 is the only access to a large area of the NRA (17N07 does 

not provide duplicate access) that also accesses private land. This road has a high administrative need for 

fire access and was critical in protecting the community of Rock Creek during the 2015 wildfires. The 

majority of spurs off 16N19 are proposed to be removed. Route 405.103 is a narrow track, the majority of 

which occurs in naturally open serpentine habitat. Neither the road nor the UAR poses a serious 

fragmentation issue.

Letter 

Number

Comment 

Number Comment Text

819 93

Please document and analyze the multitude of necessary culverts and road repairs needed to bring 

user-created routes up to NFTS standards. The agency has acknowledged that if these mitigations 

do not occur, the risks to resources are significant and unacceptable.

Response: The preferred alternative identified mitigations for UARs that must be implemented prior to 

its designation on the NFTS and addition to the MVUM. Site-specific mitigations are documented in the 

2005 Rap and in the road tables in the DEIS and FEIS.
Appendix G. Response to Comments

174 – Smith River National Recreation Area Restoration and Motorized Travel Management

Traditional Cultural Properties

Letter 

Number

Comment 

Number Comment Text

826 13

It is not clear to the BOS if any of the identified mines and roads in Table 4 exist within Traditional 

Cultural Properties (TCP) (which have been excluded from analysis by the Forest in the DEIS) 

however if that is the case the BOS requests that these sites be discussed in coordination for 

consideration on a case by case basis.

Response: None of the roads/UARS within the TCP were included in the DEIS. These areas will be 

analyzed in a future NEPA process, which will include coordination with the County.

Alternatives

Preferred Alternative, Alternative 6

Letter 

Number

Comment 

Number Comment Text

846 6

Project and the action alternatives. The DEIS does not identify a “preferred alternative.” Based upon 

our review, we recommend the selection of Alternative 5 as the preferred alternative due to the 

increased benefits and protections this alternative offers for water quality, cultural resources, 

sensitive species and their habitats, and its lower relative cost.

Response: The Preferred Alternative was identified in the DEIS as Alternative 6 in the abstract and 

summary, and in the introduction to Chapter 2. The Recreation Opportunity, Alternative 4, the 

Environmental Preferred Alternative 5, and the Agency preferred Alternative, Alternative 6 are as well 

identified in the FEIS, abstract, summary, and in Chapter 2.

Alternative 6

Letter 

Number

Comment 

Number Comment Text

830 8

We urge the Forest Service to understand the full extent of its discretionary authority, and exercise 

that authority in adopting a Modified Alternative 6 in the same spirit as the Pryors Mountains or 

Kapka Butte projects.

830 11

IMPORTANCE OF USING DISCRETIONARY AUTHORITY TO CREATE A FUNCTIONAL ROUTE 

NETWORK It is both legally necessary and pragmatically essential that the agency use its 

discretionary authority to formally establish a functional yet sustainable network of designated 

routes. Various preservationist and anti-access special interests will incant a litany of alleged legal 

violations that prevent adoption of Alternative 6 or any meaningful network of vehicle routes in the 

NRA. They are certainly entitled to voice their opinions, but the agency should carefully evaluate 

any such claims and realize they are thinly veiled efforts to advance an agenda that includes 

significantly reducing, if not eliminating, recreational use of vehicle in the National Forest System. 

The agency is empowered to reject these anti-access positions through correct interpretation of the 

law, as reflected in various recent court decisions.

Response: The Forest Service must carefully consider all comments provided, and must balance 

management of both non-motorized and motorized recreation opportunities, as well as natural and cultural

resources. The Agency’s preferred alternative, Alternative 6, is aimed at providing adequate public and 

administrative access while reducing risk to resources and meeting criteria contained in Subpart B of the 

Travel Management Rule, as described in the Purpose and Need section of the EIS, in Chapter 1. The 

preferred alternative meets the Purpose and Need by decommissioning roads not needed for public or 

administrative access, and designating additional pubic access routes, while also investing in ecological 

protection mitigations to protect resource values where necessary.
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 175

Alternatives Analyzed in Detail

No Action Alternative

Letter 

Number

Comment 

Number Comment Text

828 14

The no action alternative assumes that the Forest Service can continue to allow motorized use of 

unauthorized routes in high resource areas and roadless areas, without repercussions. This 

baseline for comparison is the equivalent of allowing murders to continue without law enforcement, 

and then claiming that making murder legal will somehow fix the problem. Elk Camp Ridge 

motorized trail alone is about 6 miles of motor intrusion into a roadless area. 

831 17 We are asking that no roads, motorized routes, Level I or Level II road be closed whether created 

by blade or mechanized wheel.

243 4

I strongly request that there is no forward movement for motorized vehicles in our forests. We have 

truly only a fraction of what once was that is undisturbed by noise pollution and environmental 

pollution.

243 7 We need to allow for a place for humans to be in solitude, in nature. Please, do not add any new 

roads/trails for motorized vehicles.

144 1

PLEASE DON’T ADD ANY ROADS OR DISTURB ANYTHING IN SMITH RIVER NRA, NO

DISRUPTION PLEASE, LEAVE IT WILD, DON’T BUILD ANYTHING AT ALL, ONLY RUINS OUR 

WILD PLACES FOREVER, HANDS OFF SRNRA IMMEDIATELY, LEAVE IT ALONE, NOW!

Response: The roads and routes being considered in this analysis are open and drivable. All action 

alternatives will reduce roads/routes miles across the NRA by between 21 and 47 percent.

Elk Camp Ridge Trail is an existing motorized trail on the NFTS. If the agency takes no action then 

Elk Camp Ridge Trail would continue to exist as designated motorized trail, no changes would occur to 

the NFTS including decommissioning, or closing roads, or designating new roads or motorized trails. The 

analysis for the no action alternative provides a comparative basis for which to assess the environmental 

consequences of the alternatives.

All Action Alternatives

The following comments provide recommendations that were addressed in all action alternatives:

Provide and maintain adequate public access, including vehicular roads for recreational activities

Letter 

Number

Comment

Number Comment Text

828 2 Provide for a broad range of recreational uses. Provide and maintain adequate public access, 

including vehicular roads for general recreational activities such as camping, hiking, hunting, fishing.

Response: The purpose and need of the project includes providing for a diversity of motorized recreation 

opportunities and access to dispersed recreation sites. The action alternatives provide a range of levels of 

recreation opportunities and access to dispersed recreation sites. The comparison of alternatives table in 

Chapter 2 outlines the range of motorized recreation and access to dispersed recreation sites analyzed in 

each alternative.
Appendix G. Response to Comments

176 – Smith River National Recreation Area Restoration and Motorized Travel Management

Repairing or closing and revegetating the backlog of old, unmaintained roads and trails

Letter 

Number

Comment 

Number Comment Text

805 12

The plan must also set about the critical task of either repairing or closing and revegetating the 

backlog of old, unmaintained roads and trails. This is the first task to achieve before the Forest 

Service even considers opening new routes or watersheds and magnifies its enforcement 

challenges beyond its already deficient management capacity

Response: The 2005 Smith River NRA RAP and subsequent NEPA documents identified site-specific 

resources risks and site-specific mitigations for every road and UAR on the NRA. All action alternatives 

include actions to decommissioning and barricading existing NFTS roads. The roads and routes being 

considered in this analysis are open and drivable. No road construction or reconstruction will occur; 

therefore, no new routes will be opened. All action alternatives will reduce roads/routes miles across the 

NRA by between 21 and 47 percent. See the comparison of alternatives table at the end of Chapter 2 for 

the miles of decommissioning and barricading restored UARs by alternatives.

Physically close non-system routes that are not added to the system

Letter 

Number

Comment 

Number Comment Text

819 135

Our organizations would like to support a travel management decision that: 1. Recognizes and 

protects the outstanding natural values that most Americans find in non-motorized Inventoried 

Roadless Areas; 2. Refrains from adding routes and motorized trails to the road system that occur 

within occupied sensitive plant habitat; 3. Fully analyzes and discloses the potential for increased 

motorized off-route and off-road damage to serpentine sites due to the addition of non-system roads 

to the system; 5. Discloses the actual efficacy of agency road gating, blocking and closure

mechanisms; 6. Avoids designation of “high risk” user-created routes and emphasizes

decommissioning of “high risk” NFTS roads; 39 7. Contains meaningful and substantive protections 

for Port Orford Cedar populations across the planning area; 8. Physically closes non-system routes 

that are not added to the system.

581 1

I urge policy direction for the Smith River National Recreation Area that limits off-road usage. We 

value the wildlands, watersheds and wildflowers of this special place, and want to protect it from 

damage by extreme off-road vehicle enthusiasts.

197 1 Do not allow ORV into any more areas and block off areas so that they may be rehabilitated.

806 6 Please close as many roads as possible, and rehabilitate these roads into as natural a state as 

possible

197 1

I’ve rafted down the Smith River and explored many of the remote canyons and ridges of the area. 

Over the last 15 years, I have seen massive damage done to the wild places by off road vehicles. 

This must be stopped! Do not allow ORV into any more areas and block off areas so that they may 

be rehabilitated.

197 1 Do not allow ORV into any more areas and block off areas so that they may be rehabilitated.

Response: All action alternatives include physically barricading unauthorized routes not designated on 

the NFTS. The roads and routes being considered in this analysis are open and drivable. No road 

construction or reconstruction will occur; therefore, no new routes will be opened. All action alternatives 

will reduce roads/routes miles across the NRA by between 21 and 47 percent. All alternatives would 

restrict vehicles to designated routes.
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 177

Remove sediment fill

Letter 

Number

Comment 

Number Comment Text

819 114

Previously the initial EA for this project (page 35) acknowledged that the Middle Fork Smith 

watershed process has been “moderately altered by disturbance” yet the agency’s Decision rejected 

the increased removal of sediment fill volume contemplated in Alternative 3 (page 32) in order to 

stick with the Proposed Action alternative (Alternative 2) with modifications. We urge the agency to 

reconsider this direction during the current planning process.

Response: Road density is the highest in the Middle Fork Smith (1.62 miles per square mile) due to 

State Highway 199, Del Norte County roads, and primary Forest Service access roads; however, all action 

alternatives will reduce road/route miles across the NRA by between 21 and 47 percent, including most of 

the roads and routes identified in the initial EA. Road density will be reduced across the NRA including 

in the Middle Fork Smith (down to between 1.05 miles to 1.30 miles per square miles).

Access to dispersed recreation

Letter 

Number

Comment 

Number Comment Text

826 7

During previous discussion with the Forest the County and members of the public emphasized the 

importance of preserving identified dispersed campsites and a list was provided to the Forest for 

inclusion in the plan. Now, in review of the proposed plan it appears that while a number of 

identified dispersed camp sites were included as Dispersed Recreation Sites many County-priority 

sites were omitted. In addition to being valuable recreational sites many of these sites are regularly 

used by Del Norte County Search & Rescue (see Table 2). The below identified dispersed camp 

sites should be included in the final plan and access routes into these sites should be classified as 

no lower than Motorized Trail in order to allow for access to each identified priority dispersed camp 

site for recreational and public safety purposes. In order to protect environmental resources and to 

encourage responsible use of these sites the County suggests that where resources may exist 

within proximity of dispersed campsites (such as watercourses) that barricades could installed (such 

as boulders) which would serve to impede encroachment into such resource areas.

Response: Several routes to sites identified by the County are proposed for designation in Alternatives 4 

and 6. There were a limited number of situations where the County-provided campsite did not have a 

route that could be considered in detail for inclusion in an Alternative. Other issues that precluded 

proposing a route for detailed consideration were that some routes were popular illegal dumping grounds, 

or far exceeded the general guideline of short routes (generally 300 feet or shorter). Likewise, if the 

resource and/or safety concerns on a route could not be reasonably mitigated, then it was not considered 

in detail in an alternative, but there were very few sites where this kept a route from being considered -

one notable example was if the Forest Service would need to build a new bridge to provide access, which

would be beyond the scope of the project since it would require new construction.

Mixed-use and county roads ordinance

Letter 

Number

Comment 

Number Comment Text

830 15

OHV USE ON ML 3 ROADS or ML 2 ROADS Historically, the Forest (1994 Smith River NRA Forest 

Map) designated routes such as 17N49, 17N07, and 18N09 for non-street legal OHV use. It appears 

the Forest had classified said routes at ML 2 roads (which allow for non-street legal OHV use) or 

those routes were classified as ML 3 roads – which generally does not allow for non-street legal OHV 

use unless designated as mixed-use roads – but were managed as ML 2 roads – which does allow 

for non-street legal OHV use. Alternative 6 appears to have classified those routes (and others) as 

ML 3 roads, which might be interpreted by some as prohibiting use upon them by non-street legal 

OHVs such as ATVs, Side-by-Sides, and dirt bikes. It is unclear if that is the intent of the DEIS.
Appendix G. Response to Comments

178 – Smith River National Recreation Area Restoration and Motorized Travel Management

Letter 

Number

Comment 

Number Comment Text

826 5

It is the County’s understanding that Off-highway vehicle (OHV) use is not allowed on ML 3, ML 4, 

or ML 5 designated system roads however OHV’s could be allowed on such roads if also 

designated as Mixed Use. Therefore, as a means to facilitate and promote responsible recreational 

use the County has proposed a number of ML 3 roads for mixed use in conjunction with promoting 

additional motorized trails (MTs). The roads identified in the table below include roads that 

represent ideal OHV routes as they loop around longer segments and tie into designated Motorized 

Trails. The County believes that designating these roads as Mixed Use will provide an incentive to 

responsible recreating in the NRA and will discourage irresponsible recreating in unauthorized 

areas. It is anticipated that in the coming months the County will consider a similar program on its 

unpaved County road system which could lead to enhanced recreational opportunities as well as 

access to funding under the California State Parks Off-Highway Motor Vehicle Recreation (OHMVR) 

Grant Program. In seeking OHMVR grants, it would certainly be seen as positive aspect if the NRA 

had OHV accessible system roads that could be accessed from County OHV accessible roads.

Response: OHVs are not allowed on ML 3-5 roads unless designated for mixed use. ML 2 roads are 

constructed for use by high-clearance vehicles, and OHV use is allowed. The project was expanded to 

include downgrading a limited number of ML 3 roads to ML 2. To provide for expanded motorized 

recreation in the County Road 17N07 is included in the Alternative 4 and 6 for downgrading to ML 2, 

which was determined to be consistent with ML 2 management given the road surface type (aggregate). 

Downgrading 17N07 to ML 2 will open an extensive network of roads to OHV travel, which supports the 

purpose and need of the project to provide a diversity of motorized recreation opportunities. The northern 

portion of 17N49 is also proposed for downgrading to ML2 in all action alternatives.

At the time the DEIS was released, state, county, and Smith River NRA ML 3, 4 and 5 roads were 

being considered in this analysis; however, since this time Del Norte County Board of Supervisors passed 

the Del Norte County Rural Recreational Roads Ordinance on October 28, 2014, which provided for OffHighway Vehicles, further defined in the ordinance as motorized wheeled vehicles that are not licensed for 

on-highway use as well as highway licensed vehicles while operating off-highway. The Board then 

requested during the comment period that the forest supervisor to consider providing mixed-use travel on 

specific ML 3 roads. The scope of the project was expanded in response to the consideration of 

coordination with Del Norte County road management to consider a limited number of ML 3 roads for 

downgrading to ML 2 to accommodate mixed-use, when road surface type, use levels and road geometry 

were compatible.

Alternative 4

Existing Level I and user-created routes be used for Class II trails

Letter 

Number

Comment 

Number Comment Text

831 25

Most Americans want and ask for a way through the forest slowly as it naturally meanders through 

the forest terrain in their chosen mode of motorized transportation. The obstacles of the forest and 

mother earth left in place and very little maintenance done to the wheeled route. This is entirely left 

out of the alternative provided in this document. Just fast roads, fast/hot routes but the majority of 

the forest users are there to enjoy the forest at a leisurely pace in a motorize vehicle.

831 12

Class II users have very few trails and insignificant trail mileage within the Smith River National 

Recreation Area Motorized Travel Plan. As a motorized travel plan this needs a very hard look at as 

to why there are not hundreds of miles of motorized trails that are below Level II roads. Roads are 

not trails. We ask you to take a very hard look throughout your forest and see if many of the existing 

Level I and user created routes could not be used for Class II trails.
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 179

Response: The project will provide hundreds of miles of roads and motorized trails that will provide for 

a variety of user preferences. UARs will be added to the system as motorized trails, including trail 

systems on Gasquet Mountain and Rattlesnake Mountain.

Create hundreds of miles of different types of motorized trails, motorized ways

Letter 

Number

Comment 

Number Comment Text

831 9

The CFRs state that millions of forest users come in a motorized vehicle and continue to do so 

throughout their forest visit. Instead of single mile of existing motorized routes being closed the 

management of this forest should be creating hundreds of miles of different types of motorized 

trails, motorized ways, opening hundreds of miles of Level I and Level II roads to high-clearance

travel vehicles (already existing is thousands of miles of roads that are maintained to some degree). 

It is the primitive motorized roadway, trail, way, route that the motorized community is looking for.

Response: Alternative 4 most fully explores the options provided within the scope of the project by 

proposing converting 7.6 miles of ML 1 road to motorized trail, and designating 58.2 miles of UARs as

motorized trails. The consideration of complexity of the motorized trails proposed within the project is 

limited to inventoried UARs and the existing NFTS. Creating new, slow tracks for a high-complexity 

OHV experience is outside the scope of this project because construction of new routes is outside the 

scope of the project.

Trails range in difficulty levels: easy, difficult, very difficult, extreme

Letter 

Number

Comment 

Number Comment Text

831 12

There has to be a range for all OHVs and Class II is not being considered for the full range of Class II 

users currently using your forest. Roads are good for many Americans using national forest lands but 

these are not trails. Trails range from Easy, Difficult, Very Difficult and Extreme. There are no play 

areas for mudding, rock crawling or hill climbing that would allow the Class II user to play without 

damage to a bona-fide trails system (even a road system) included in any of your alternatives. It is 

not right to write a motorized travel plan without including all of the people currently using this forest. 

The writers of this document need to take a hard look at why all of the users particularly Class II are 

not being included. This forest is made up of a variety of plants; Class II users are also a variety of 

users and all aspect of their current use must be include within these pages.

Response: Preliminary analysis indicates that there are a variety of difficulty levels proposed in 

Alternatives 4 and 6; however, Alternative 4 offers the greatest variety. The results of the analysis are 

located in the project record and are available upon request. The final trail class designation will be 

identified during implementation.

Alternative 5

Letter 

Number

Comment 

Number Comment Text

819 135

Our organizations would like to support a travel management decision that: 1. Recognizes and 

protects the outstanding natural values that most Americans find in non-motorized Inventoried 

Roadless Areas; 2. Refrains from adding routes and motorized trails to the road system that occur 

within occupied sensitive plant habitat; 3. Fully analyzes and discloses the potential for increased 

motorized off-route and off road damage to serpentine sites due to the addition of non-system roads 

to the system; 5. Discloses the actual efficacy of agency road gating, blocking and closure

mechanisms; 6. Avoids designation of “high risk” user-created routes and emphasizes

decommissioning of “high risk” NFTS roads; 39 7. Contains meaningful and substantive protections 

for Port Orford Cedar populations across the planning area; 8. Physically closes non-system routes 

that are not added to the system.
Appendix G. Response to Comments

180 – Smith River National Recreation Area Restoration and Motorized Travel Management

Response: As stated in the 2005 RAP, the intent of the analysis was to provide decision-makers with 

critical information to develop a road system that is safe and responsive to public needs and desires as well 

as have minimal negative ecological effects on the land. To that end, the forest has provided multiple 

opportunities for the public to provide information on what roads/routes are needed for access, with the 

majority of public comments provided after the RAP was completed. The RAP is a planning tool, not a 

decision document, and both resource risk and public need ratings were modified based on information 

provided by the public during the NEPA process in the 11 years since the RAP was completed. The RAP 

and subsequent public comments were indeed used to develop the preferred alternative. Only roads/routes 

with an identified public or administrative need were proposed for addition, provided any identified 

resource risks could be mitigated. No low-use routes proposed for addition to the system.

All action alternatives will reduce roads/routes miles across the NRA by between 21 and 47 percent, 

including in sensitive plant habitat and POC areas. Routes will only be added to the system provided 

resource risks can be mitigated. All action alternatives would result in resource protection benefits 

including: 1) less than 0.1 percent of the serpentine sensitive plant habitats on the NRA are being affected; 

2) all routes into the North Fork Botanical Area are being closed, protecting over 20,000 acres of potential 

habitat; 3) routes to be kept will be upgraded to correct drainage problems, and 4) POC protection 

measures are common to all action alternatives.

The majority of UARs on the NRA are not user created routes. They are old mining roads to 

legitimate claims, old logging roads from previously private land that was later acquired by the FS, etc. 

Although construction standards have changed and improved, many of these old roads were engineered.

Many of these roads access popular recreation sites. Mitigations have been proposed to minimize resource 

impacts while providing access. The Forest Service would close between 2 to 4 times the miles of UARs 

that would be added. Adding the UARs that are needed for access would be consistent with Forest Service 

Rules and Regulations.

All alternatives would restrict vehicles to designated routes. Off-road use is illegal. Any areas where 

such use is occurring will have further mitigations imposed. The Forest Service cannot analyze illegal use 

of OHVs.

Monitoring by the Six Rivers and Rogue River-Siskiyou national forests has determined that 

barricades are 96 percent effective and gates are 90 percent effective.

Analyzed Under More than One Alternative

Search and Rescue Routes

Route-by-Route response and review

Letter 

Number

Comment 

Number Comment Text

826 9

In addition to providing for recreational opportunities many NFTS routes and County roads in the 

NRA provide for emergency response. As stated above a number of dispersed camp sites have 

been identified as being of importance to Search & Rescue efforts however these sites have been 

omitted from the Forest’s preferred alternative. The below table includes an additional list of roads 

provided by the Del Norte Search & Rescue Coordinator and members of the public and should be 

included in the plan in order for the plan to not negatively impact the ability of Search & Rescue 

personnel in their efforts in the NRA.
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 181

Response: All emergency access, including fire suppression, search and rescue, and law enforcement 

actions, are legally authorized to go wherever needed, whether it is designated on the transportation 

system or not. Emergency operations in response to threats to health and safety are authorized across the 

forest and not subject to the restrictions on travel described in the MVUM (36 CFR 212 Subpart B, 

212.51a(5)).

Exclude motorized use on 16N23

Letter 

Number

Comment 

Number Comment Text

819 92 Please note that 16N23 has a high risk of PL and moderate for both wildlife and fisheries. This loop 

should exclude vehicle access for resource protection.

Response: Under Alternative 5, this road is proposed to be decommissioned and barricaded. The 

preferred alternative, Alternative 6, proposes a seasonal gate closure to mitigate resource risks. The effects 

of the different types of management for this road will be fully analyzed and displayed in the FEIS.

Eliminated from Detailed Analysis

Search and Rescue Routes

Letter 

Number

Comment 

Number Comment Text

826 9

In addition to providing for recreational opportunities many NFTS routes and County roads in the 

NRA provide for emergency response. As stated above a number of dispersed camp sites have 

been identified as being of importance to Search & Rescue efforts however these sites have been 

omitted from the Forest’s preferred alternative. The below table includes an additional list of roads 

provided by the Del Norte Search & Rescue Coordinator and members of the public and should be 

included in the plan in order for the plan to not negatively impact the ability of Search & Rescue 

personnel in their efforts in the NRA.

Response: Emergency operations in response to threats to health and safety are authorized across the forest 

and not subject to the restrictions on travel described in the MVUM (36 CFR 212 Subpart B, 212.51a(5)).

Route-by-Route response and review

Table 3 as Referenced in Del Norte County Comments

Road or 

Trail Route Specific Considerations identified by Interdisciplinary Team

305.113 This route leads to Cleopatra Mine. Mine hazards have not been remediated to allow for safe access, it is therefore 

not proposed for designation in any action alternatives.

305.121

This route extends off of and leads to private property. The FS does not have ROW across the private parcel. 

Forest Plan Standard and Guideline #15-5 “Right of way needed for public access and National Forest resource 

needs must be acquired in advance of scheduled programs.” Designating this route as a Motorized Trail would 

encourage trespass, which is not consistent with the Forest Plan. Emergency operations in response to threats to 

health & safety are authorized across the forest and not subject to the restrictions on travel described in the MVUM. 

305.121.B Do not have ROW across private property to this route, Not consistent with LRMP S&G 15-5 “Right of way needed 

for public access and National Forest resource needs must be acquired in advance of scheduled programs.”

305.124

This route extends off of private property. The FS does not have ROW across the private parcel. Forest Plan 

Standard and Guideline #15-5 “Right of way needed for public access and National Forest resource needs must be 

acquired in advance of scheduled programs.” Designating this route as a Motorized Trail would encourage 

trespass, which is not consistent with the Forest Plan. Emergency operations in response to threats to health & 

safety are authorized across the forest and not subject to the restrictions on travel described in the MVUM. 
Appendix G. Response to Comments

182 – Smith River National Recreation Area Restoration and Motorized Travel Management

Table 3 as Referenced in Del Norte County Comments

305.126

Surveys for Arabis MacDonaldiana were conducted and it was found that there were no occurrences of this plant 

associated with this route. Given the reduction in risk ratings for this route, it was reconsidered and decided to 

propose as a motorized trail with route delineation as a mitigation in Alternatives 4 & 6.

315.104 This route is not in the project, and is therefore beyond the scope of the project.

Accessed to Dispersed Sites

Letter 

Number

Comment 

Number Comment Text

826 7

During previous discussion with the Forest the County and members of the public emphasized the 

importance of preserving identified dispersed campsites and a list was provided to the Forest for 

inclusion in the plan. Now, in review of the proposed plan it appears that while a number of 

identified dispersed camp sites were included as Dispersed Recreation Sites many County-priority 

sites were omitted. In addition to being valuable recreational sites many of these sites are regularly 

used by Del Norte County Search & Rescue (see Table 2). The below identified dispersed camp 

sites should be included in the final plan and access routes into these sites should be classified as 

no lower than Motorized Trail in order to allow for access to each identified priority dispersed camp 

site for recreational and public safety purposes. In order to protect environmental resources and to 

encourage responsible use of these sites the County suggests that where resources may exist 

within proximity of dispersed campsites (such as watercourses) that barricades could installed (such 

as boulders) which would serve to impede encroachment into such resource areas.

Response: Several routes to sites identified by the County are proposed for designation in Alternatives 4 

and 6. There were a limited number of situations where the County-provided campsite did not have a 

route that could be considered in detail for inclusion in an Alternative. Other issues that precluded 

proposing a route for detailed consideration were that some routes were popular illegal dumping grounds, 

or far exceeded the general guideline of short routes (generally 300 feet or shorter). Likewise, if the 

resource and/or safety concerns on a route could not be reasonably mitigated, then it was not considered 

in detail in an alternative, but there were very few sites where this kept a route from being considered -

one notable example was if the Forest Service would need to build a new bridge to provide access, which 

would be beyond the scope of the project since it would require new construction.

Route by Route response and review

Table 2 as Referenced in Del Norte County Comments (826)

Dispersed 

Site Name Access Route Response to Individual UARs Dispersed Site

18-Mile Camp 314.1

Field check in May 2013 revealed that no site was present at the end of the route as mapped for 

the PA (which was the whole inventoried route). There is a site at the County-provided point 

(W97), but this is far (~2100 ft) from the end of 314.1. With this route well beyond 300’ of an 

inventoried route; it was therefore identified in the Scoping Report (Appendix C, Short Routes) 

of the project record as being beyond scope of this project. Maintaining the action on this route 

as described in Alternative 6 of the DEIS is consistent with the recommendation of the 

collaborative group, which was to designate 1.21 miles as motorized trail and barricade the end 

of the route to mitigate risk to POC.

Cavell Camp 17N07.102

Designating this route would not meet standard and guides for Aquatic Conservation Strategy 

objectives given slope instability and proximity to the creek and therefore would not be 

compliant with the Forest Plan. Concerns identified by member of public about having motor 

vehicle access to an important family gathering site were weighed heavily in the decision, 

however concerns over meeting ACS objectives given the proximity of the road in relation to 

Coon Creek drove the decision to not designate this route on the NFTS.

Cleopatra 

Camp 305.115

Not consistent with Botanical Area Mgt; No sensitive plants on route, however, Arabis 

MacDonaldiana, Federally Listed Endangered plant, occurs within 30′ of route. In the preferred 

alternative, this route will be barricaded to protect resources. 
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 183

Table 2 as Referenced in Del Norte County Comments (826)

Copper Creek 

View Camp 305.123

This route is only accessible by crossing private property, on which the FS does not possess a 

ROW or easement. By designating this route, the Forest would be encouraging illegal trespass 

which is not consistent with Forest Plan standard and guidelines or regulation and policy

(S&G15-5). Therefore, designation of this route on the NFTS is beyond the scope of the project.

Hardscrabble 

Camp 305.124

This is an anadromous fish-bearing stream, the road enters the creek several times with low 

water crossings, and is in very bad shape – it would be cost-prohibitive to bring to standard. 

Multiple stream crossings. Anadromous stream habitat Concerns. (Scoping Report Appendix C, 

Long Routes; Also the RAP). This route is accessed by crossing private lands for which the FS 

has no easement or ROW.

Hole-in-theGround Camp

305.118

This route was considered in the Scoping Report (Appendix B), and was also addressed in the 

RAP. The road is added to the NFTS as Motorized Trail in Alternatives 4 and 6, with the 

exception of the last 0.4 miles. The last 0.4 miles are closed to protect uninfected POC adjacent 

to the LE Horton RNA, before the road enters the steepest area (average grade greater than or 

equal to 23%).This route was considered through the collaborative process and had a 

recommendation that is consistent with the proposal in the DEIS alternative 6. It is the intent to 

maintain the recommendations on nine key routes the collaborative group supported where 

possible and appropriate.

Island Lake 

Trailhead 

Camp

16N02

Road 16N02 has no changes proposed on it under any Alternative, and Island Lake Trailhead 

can be accessed under all Alternatives. According to the RAP for NRA system roads (July 

2005), the Island Lake Trailhead was relocated under a 2001 NEPA decision. The current 

trailhead is adjacent to wilderness, which is outside the project area and is accessible by nonmechanized means only, in accordance with The Wilderness Act.

Jones Flat 

Camp #1 17N41.1

After a review of the records associated with 17N41.1 and Forest Road 17N41, it was determined 

that 17N41.1 was erroneously identified as a UAR not Forest Road 17N41. The corporate and 

project data will be updated to correct this error, and illustrating the full length of 17N41.

Jones Flat 

Camp #2 17N41.1

After a review of the records associated with 17N41.1 and Forest Road 17N41, it was determined 

that 17N41.1 was erroneously identified as a UAR not Forest Road 17N41. The corporate and 

project data will be updated to correct this error, and illustrating the full length of 17N41.

Leave only main roads open, close wild roads in fragile areas – NRA Act calls for recreation

Letter 

Number

Comment 

Number Comment Text

821 1 I would like to see more wild roads laid to rest, especially in fragile areas. Traditional Mainline roads 

should remain open and available.

204 1

After reading over the proposals, I see none as having everything that should be available but that 

Alternative # 5 comes closest. I am in favor of closing more if not all to motorized travel but realize 

that the political will to do what is the most needed and best is lacking. So, unfortunately

compromise of the environment to favor human desires is making an ugly presence again. I would 

hope further modification(s) in the final plan will be made to eliminate more or all roads and make 

none that are new.

Response: The Smith River National Recreation Area (NRA) Act requires under (PL 101-612) section 

5(b)(2) that in administering the Smith River NRA the Forest Service “will provide and maintain 

adequate public access, including vehicular roads for general recreational activities such as camping, 

hiking, hunting, and fishing”. In addition, much of the administrative access needs on the Forest are 

serviced by ML 2 roads. Closing all roads except for mainline roads would virtually eliminate needed 

administrative access and access to much of the remote recreation and cultural use destinations on the 

Smith River NRA, including wilderness trailheads, hunting and fishing access, and contemporary cultural 

use areas and is therefore inconsistent with the administrative duties outlined in the Smith River NRA 

Act. It is therefore eliminated from detailed analysis.
Appendix G. Response to Comments

184 – Smith River National Recreation Area Restoration and Motorized Travel Management

Mixed-Use Consideration

Staging site at intersection of 17N49 and Highway 199

Letter 

Number

Comment 

Number Comment Text

830 15

During the stakeholder process, OHV groups urged the Forest to designate the lower portion of 

17N49 as a mixed-use road and to create a parking/staging area just off of Highway 199. Users 

stated they preferred to stage close to the freeway for security reasons and because it was more 

practical for users to ride up the dirt road to some of the more rugged trail opportunities in and 

around Gasquet Mountain.

830 16

Alternative 6 ignores that request and proposes to instead designate several parking areas along 

the northern section of 17N49. Those staging areas are not practical nor do they enhance the OHV 

opportunity in that area. In addition, it appears that 17N49 remains closed to OHV use along those 

proposed staging areas. Remedy – Coordinate with county officials and stakeholders to review 

looped touring opportunities for non-street legal OHVs on the aforementioned roads. The agency 

has broad discretion to make administrative decisions to allow OHV use on ML 1 roads (manage 

them as motorized trails) and to designate ML 3 roads as “mixed-use” roads for use by non-street 

legal OHVs or to reclassify a ML 3 road as a ML 2 road. Site an OHV staging area on 17N49 near 

the junction of Highway 199. If the county designates a number of their non-paved county roads as 

“non-highways” under the CVC, the import of such a coordination meeting becomes even more 

desirable. Coordination meetings can occur in addition to, or outside of, the public comment period.

Response: Del Norte County specifically requested that the forest evaluate the following ML 3 roads 

14N01, 16N02, 17N02, 17N04, 17N07, and 18N08 to allow for mixed-use. Maintenance Level 2 roads 

allow for OHV use, therefore the forest evaluated downgrading these roads to ML 2 for inclusion in an 

action alternative, by the recreation opportunity provided, safety considerations, compatibility of uses, road 

surfacing and geometry, and impacts on funding. There is no 17N02 on the NFTS; therefore, it was 

eliminated from further consideration. Roads 18N08, 14N01, 16N02, and 17N04 were identified as not 

being good candidates for downgrading to ML 2, given either the existing level of investment on the road, 

the administrative needs of the road, the use level of the road, the funding opportunities, potential conflicts 

with private property owners, and their potential significant effects to areas excluded from the geographic 

scope in response to a significant issue, and are not proposed for downgrading in any action alternatives.

The entire length of 17N49 was also considered for downgrading to ML 2; however, the southern 

segment of 17N49 will be maintained as an OML 3 given the road geometry and road surface type, which 

is paved. Alternatives 4 and 6 propose to downgrade 17N49 to ML 2 beginning at DN 305 road and 

extending south for approximately 4.9 miles to allow for OHV use. Downgrading 17N49 would support 

the motorized recreation opportunity in that area by providing loops that connect with nearby motorized 

trails. In addition, the SRNF analyzed parking areas in Alternatives 4, 5 and 6 in response to scoping 

comments from the Del Norte County Sherriff regarding safety concerns about OHV staging, by people 

accessing the proposed motorized trail network near 17N49. No comments were received during scoping 

for this project requesting a parking area on 17N49 near Highway 199.

Designating a parking site at the intersection of Highway 199 and Forest Road 17N49 as a staging 

area for motorized recreationist to access the proposed trail network that stems off 17N49 would require 

that the southernmost segment of 17N49 from milepost 0.0 to 3.8 would need to allow for non-highway 

legal travel. The entire length of 17N49 was also considered for downgrading to ML 2; however, the 

southern segment of 17N49 will be maintained as an OML 3 given the road geometry and road surface 
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 185

type, which is paved. This proposal is therefore eliminated from detailed analysis, as it is not consistent 

with law, policy and regulation.

The forest has worked closely with Del Norte County in many two-by-two meetings over a period of 

years, discussed the project with county supervisors at several two-by-two meetings, public meetings, and 

a field trip and a meeting to clarify the County’s top priorities submitted during the DEIS comment 

period, and carefully considered and responded to the proposals in the County’s DEIS comments on a 

route-by-route basis.

Mixed-Use Table 1. Del Norte County request on existing UAR,ML 1 roads and non motorized trails.

Mixed Use Table 1 as Referenced in Del Norte County Comments

Road or Trail Response to Individual Road or Trail

4E05

The portion of 4E02 that was previously Road 16N10 was downgraded and barricaded under the 2001 NEPA 

decision for the Doe Flat and Island Lake Trailhead Relocation Projects. Existing motorized and non-motorized 

trails are not within the scope of project to consider changing designations. See Chapter 1, Project Scope for 

more information.

199.108

This route was erroneously not considered in Alternatives 3 to 6 in the DEIS. This route has a number of 

problems associated with it. Illegal dumping often occurs here and has been the site of a more than one fire 

start. Not allowing motorized access down this short route will deter many of these issues occurring here in the 

future. The LRMP designates the Recreation Opportunity Spectrum (ROS) for this area as Semi-Primitive NonMotorized, and this designation overlaps the Wild River designation established by Congress along this portion 

of Myrtle Creek. To designate this route as ML 2 as the commenter proposes would require a Forest Plan 

amendment. Given the ROS designation of SPNM and the existing issues associated with this site, the 

Responsible Official recommends not designating the route on the NFTS.

305.101

The route identified is an unauthorized route that leads directly to private land. As part of the scoping process, 

the Forest attempted to contact private property owners whose property access could be potentially affected by 

a project Alternative. If property owners notify us that they need to maintain regular property access using a 

route that is closed to the public, then the Forest will work with them to establish a reasonable access route to 

their property. This access is provided via a Special Use Permit and to obtain one, the permit holder assumes 

certain permit costs and responsibilities. The Forest Service does not typically maintain Forest System roads or 

trails to access private property when the routes do not serve some broader public or administrative need.

305.101B

This route extends off private property. The Forest Service does not have ROW across the private parcel. 

Forest Plan Standard and Guideline #15-5 “Right of way needed for public access and national forest resource 

needs must be acquired in advance of scheduled programs." Designating this route as a motorized trail would 

encourage trespass, which is not consistent with the Forest Plan. Emergency operations in response to threats 

to health and safety are authorized across the forest and not subject to the restrictions on travel described in 

the MVUM.

17N01.1C

Field evaluation of the route determined that mitigating erosion issues would be difficult due to steepness of 

route. Routes where resource risks cannot be readily reduced to an acceptable level are not proposed for 

addition to the NFTS. The adjacent UAR 17N01.1B is being added to the system at the top of the hill.

17N01.1D

This is a steep route with one campsite at the bottom by the river, in the flood zone. The route was not 

proposed for designation to the NFTS because since the campsite is in the active channel, the potential for 

flooding poses a safety issue. Designating this route would not meet the Forest Plan standard and guides for 

Aquatic Conservation Strategy objectives.

17N07.102

Designating this route would not meet the Forest Plan standard and guides for Aquatic Conservation Strategy 

objectives given slope instability and proximity to the creek and therefore will not be analyzed in detail. 

Concerns over meeting ACS objectives given the proximity of the road in relation to Coon Creek drove the 

decision to not propose designation to the NFTS in any action alternatives for this route.

18N03

This route was identified in the RAP as a high-risk, low-need road posing a high risk to fish and water quality, 

and a moderate geological risk, with a low need for administrative and recreation purposes. Therefore, it is 

proposed for decommissioning.
Appendix G. Response to Comments

186 – Smith River National Recreation Area Restoration and Motorized Travel Management

Reclassify ML 4 and 5 roads mixed-use

Letter 

Number

Comment 

Number Comment Text

826 5

The County believes that designating these roads (ml 3, 4 & 5) as Mixed Use will provide an 

incentive to responsible recreating in the NRA and will discourage irresponsible recreating in 

unauthorized areas.

Response: Forest Service Handbook direction (FSH 7709.58, 10, 12.3) defines the level of service 

provided by the different maintenance level roads. These definitions are provided in the FEIS Glossary. 

Maintenance Level 4 and 5 roads provide for a moderate to high degree user comfort and convenience, 

have moderate to high traffic volume and speeds, and are subject to the Highway Safety Act. ML2 roads 

are built for high-clearance vehicles, to allow for highway and non-highway legal vehicle travel, provide 

a low level of service where traffic volume and speed are low, and surface smoothness is not a 

consideration. Maintenance Level 2 roads are not subject to the Highway Safety Act. Downgrading ML 4 

and 5 roads to ML 2 roads would unduly limit access to public and private lands, as these roads provide 

essential administrative access and recreational opportunities. The existing surface type, speed, volume 

and composition allows for higher speeds and would present a risk to public safety, as allowing for nonhighway legal vehicle use on a road designed to accommodate passenger cars would increase conflicts 

among different classes of motor vehicle uses on NFS lands. Given the potential increase risk to public 

safety and the decrease level of administrative access this would provide, consideration of ML 4 and 5 

roads for mixed-use designation was eliminated from detailed consideration.

Seasonal Closure Dates Flexibility

Letter 

Number

Comment 

Number Comment Text

324 1

I understand the importance of seasonal road closures, but recreation in our forest is very important 

to me. Opening the Gates should have a specific date, April 1st, which is just prior to Spring Turkey 

season until November 1st the end of Western Oregon deer season and not be an arbitrary decision 

by someone with no interest in keeping it available to motorized recreation.

818 1

Seasonal road closures are important, but recreation in our forests is extremely important to me. 

Specific dates to open gates and roads should not be left open to arbitrary decisions by someone 

with no interest in keeping access open to the public and motorized recreation. I would like to see 

the gates open April 1st through November 1st, just prior to turkey season and the end of Western 

Oregon deer season.

324 2

Every May and June for past 32 years, the Pacific Northwest Four wheel Drive Association uses the 

McGrew Trail. Every year we run into arbitrary decision making and resistance by ignoring us. In 

2010, it took a call from Senator Ron Wyden’s office to get our permit to use the McGrew Trial. To 

me, these acts are demonstrations of a bias, which should be disposed of by having set dates for 

the gates to open each year.

811 3 I would like to see roads open April first each year and remain open to November first at the end of 

Deer season.
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 187

Letter 

Number

Comment 

Number Comment Text

846 13

EPA supports the implementation of seasonal closures to avoid and minimize the adverse effects of 

motorized vehicle use during the conditions in which unpaved roadways are the most susceptible to 

erosion. The DEIS indicates that motorized recreation on unpaved routes within the NRA is limited 

to the months of May through October. Page 33 of the DEIS addresses the notion of using rainfall 

based or ground-condition based wet weather closures under the heading “alternatives considered 

but eliminated from detailed study.” While EPA recognizes that, as stated on page 33 of the DEIS, 

the scope of possible actions available to the Forest is constrained by regulation, we encourage the 

Forest Service to consider whether an administrative action might enable the use of a precipitationbased approach to seasonal route closures. A precipitation or ground condition-based closure could 

offer greater protection to sensitive resources, such as water quality, aquatic species and PortOrford-cedar, while minimizing the effect of seasonal closure on motorized recreational users. 

Furthermore, changes in patterns of precipitation and snowmelt are predicted effects of global 

climate change. Route open and closure determinations based on date alone may limit the Forest 

Service’s ability to adapt to changes of this sort in the short term. This approach would be generally 

consistent with the structural policy goals set forth in the USFS’ “Strategic Response to Climate 

Change” (page 5): http://www.fs.fed.us/climatechange/documents/framework-draft-discussionpaper.pdf Recommendations: The Forest should further consider what actions would be necessary 

to enable the use of a precipitation or ground-condition based seasonal closure system. The FEIS 

should describe the circumstances in which such a modification to the season of use rules could be 

implemented. If such a revision is deemed feasible and within the scope of this project, the FEIS 

should fully analyze this project component, describing the potential beneficial and adverse 

consequences of this action. If this modified season of use approach is implemented, EPA 

recommends that once a road closure occurs due to wet road conditions, those roads and routes 

should remain closed until the end of the wet season in order to minimize public confusion and 

simplify enforcement.

344 1

I understand the importance of seasonal road closures, but recreation in our forest is quite important 

to me. Opening the Gates should have a specific date and not be an arbitrary decision by someone 

with no interest in keeping it available to motorized recreation. I would like to see the gates open 

April 1st just prior to spring turkey season until November 1st witch is the end of Western Oregon 

deer season. Every May and June for past 32 years, the Pacific Northwest Four wheel Drive 

Association uses the McGrew Trail. Every year we run into arbitrary decision making and resistance 

by ignoring us. In 2010, it took a call from Senator Ron Wyden’s office to get our permit to use the 

McGrew Trial. To me, these acts are demonstrations of a bias, which should be disposed of by 

having set dates for the gates to open each year.

303 1

The McGrew trail should be open to the public from April 1 through November 1 to encompass 

Turkey through deer seasons. Opening the trail should not be an arbitrary decision by someone with 

no interest in keeping it available to the public. I understand that there is a person assigned to close 

the trail nut no one assigned to opening it. Every year we try to use the trail, we run into arbitrary 

decision making and resistance by ignoring us. One year, it took a call from a legislator to get the 

trail open. To me, these acts are demonstrations of a bias, which should be disposed of by having 

set dates for the trail to open each year.

824 7

Closed gates are not an effective tool. Take a hard look at what happens when gates are closed at 

one point but access is available behind the gate. Gates create frustration and distrust. Education 

by kiosk and by public service announcements are a far more effective tool. Forests throughout the 

northwest have seasonal closures generally November 31st through April 1st. Your forest deserves 

the same treatment: a season closure to align with local hunts. Road 4402, Road 206, Road 450 

are good roads for high clearance vehicles. The typical 4-wheel drive vehicle enjoys a slow trip 

down a road like this. Please do not consider any closures of these roads and reopen the roads that 

bleed off these, as they are campsites. No maintenance on these roads keeps traffic slower and 

also delivers a very enjoyable excursion for families and friends.

Response: Site-specific evaluations were conducted for every road and UAR on the NRA. Seasons of 

use were identified for roads and motorized trails where appropriate to protect resource values from 

potential spread of Port-Orford-cedar root disease. Use of roads and motorized trails with potential 

resource risk to Port-Orford-cedar on the Smith River NRA is limited to the dry season. These dates are 

based on Forest Plan direction identified in Appendix K (provision E-7A of the Engineering and Road 

Management Disease Control Strategies) in the Forest Plan provides for the restriction of management 

activities to the dry season, June 1 through September 30.
Appendix G. Response to Comments

188 – Smith River National Recreation Area Restoration and Motorized Travel Management

The Forest Service is managing seasonal road closures based on rainfall/wet weather, and road closure 

periods do vary from year to year based on the onset or the rainy or dry seasons. However, there is clear 

Forest Service direction on how the closures are to be described. The Travel Management Rule subpart b 

(36 CFR 212.56) requires that MVUM display “the times of year for which use is designated”. So closure 

dates must be established for the public to know in advance of when the wet season generally occurs.

16N71 Bear Basin

Letter

Number

Comment 

Number Comment Text

820 1

The access road to Bear Basin Lookout and Pierson Cabin, 16N71, should be upgraded from Level 

2 (high-clearance vehicles) to Level 3 (suitable for passenger cars). This half-mile of road is heavily 

used by visitors accessing the facility from the beginning of June to the end of October. The facility 

typically is booked solid during these months. It is also used during the rest of the year, although 

less so because road access is usually limited by snow. The road is easily passable by passenger 

cars and has been for several years. A list of the passengers cars that have used the road during 

the last year, from May 2013 to April 2014, include Toyota Corolla, Toyota Camry, Toyota Prius (3), 

Chrysler PT Cruiser (2), Kia Forte, and Ford Focus. The road is in as good or better shape than 

Road 16N02 leading up to it (see attached photos of 16N71). Because this road is classified as 

“high clearance” the information on the recreation.gov (reservation service) web page for the facility 

must state, “High clearance vehicles are recommended.” This has the effect of unnecessarily 

discouraging people without access to high-clearance vehicles from reserving the facility and 

denying them one of the best and most popular experiences the Forest has to offer.

822 1

I believe the access road to Bear Basin Butte Lookout and Pierson Cabin, Road 16N71, should be 

upgraded from Level 2 (high-clearance vehicles) to Level 3 (suitable for passenger cars). This halfmile of road is heavily used by visitors accessing the facility from June to the end of October. The 

facility typically is booked solid during these months. It is also used during the rest of the year, the 

degree to which is dependent on how long road access is limited by snow. According to the Forest 

Service Guidelines for Road Maintenance Levels, the definition, in part, for road maintenance level 

2 is defined in the FSH as, “Traffic is normally minor, usually consisting of one or a combination of 

administrated, permitted, dispersed, recreation, or other specialized uses.” The road is easily 

passable by passenger cars and has been for many years according to a long-time Smith River 

NRA employee. A list of the known passengers cars that have used the road during the last year, 

from May 2013 to April 2014, include Toyota Corolla, Toyota Camry, Toyota Prius (3), Chrysler PT 

Cruiser (2), Kia Forte, and Ford Focus. The road is in as good or better condition than the half-mile 

of Road 16N02 leading up to it (see attached photos of 16N71). No complaints about the condition 

of Road 16N71 have been received by the Smith River NRA district office. Because this road is 

classified as “high clearance”, the information on recreation.gov (reservation service) web page for 

the facility must state, “High clearance vehicles are recommended.” This has the effect of 

unnecessarily discouraging people without access to high-clearance vehicles from reserving the 

facility and denying them one of the best and most popular experiences the Six Rivers National

Forest has to offer.

Response: The forest can provide maintenance as needed on this road without classifying it as OML3.

To classify it as ML 3 would automatically raise the deferred maintenance costs just by reclassifying. The 

comments provided here indicate that many users of this cabin are already aware that the road is suitable 

for their passenger vehicles, and that the site does not appear to be under-utilized; on the contrary, it is 

popular and is fully occupied—possibly with some not able to make reservations at the cabin because of 

how quickly the availability fills up.

Ban motorized travel

Letter 

Number

Comment 

Number Comment Text

605 6

This destruction must be ended, and I am sure that you are as aware as I that only complete ban 

can prevent the losses, which include the introduction of Phytophthora fungi, which are killing near 

100% of the Port Orford Cedar, for instance, but not limited to this particular catastrophe.
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 189

Letter 

Number

Comment 

Number Comment Text

605 1

I am dismayed by the direction that the Smith River National Recreation Area Travel Management 

process is taking. Living in this beautiful redwood and world-treasure biologically diverse area, I 

have seen FAR too much illegal and legal destruction by ORV use. I feel, along with many who do 

not actively communicate with governmental agencies, that ORVs MUST BE BANNED 

COMPLETELY FROM USE ON PUBLIC LANDS. Being educated in biology and spending much 

time, observing and exploring the organisms and ecosystems that make up this area, and other 

areas in the Western USA, I recognize the need for preservation.

Response: All action alternatives will reduce roads/routes miles across the NRA by between 21 and 47 

percent, including in POC areas. Routes will only be added to the system provided resource risks can be 

mitigated. All action alternatives would result in resource protection benefits. POC protection measures 

are common to all action alternatives.

As required by the 1990 NRA Act, all alternatives would restrict vehicles to designated routes. Offroad use is illegal. Any areas where such use is occurring will have further mitigations imposed.

It is beyond the Forest Service’s authority to completely ban motorized travel within the project area, 

as there are many roads owned and managed by other local, state, and federal government entities, as well 

as private landowners. Banning motorized travel within the project area is therefore beyond the scope of 

the project and is not analyzed in detail.

300-foot buffer

Letter 

Number

Comment 

Number Comment Text

826 8

In addition to the priority dispersed campsites identified in the above table there are a vast number 

of other dispersed recreational sites available for use within 300-feet of the NFTS and county roads. 

During outreach with the public on this issue the need to add a “300-Foot Rule” to allow for the use 

of these areas for camping, wood gathering, and hunting was identified as having been omitted from 

the plan despite prior discussions between the County, users, and the Forest. Currently there is no 

provision in the plan to allow for such uses within 300-feet of NFTS routes. This should be added in 

order to facilitate lawful and responsible recreating, wood gathering, and hunting in the NRA. In 

addition to the priority dispersed sites in the above table, the County has geo-located dozens of 

other unnamed, dispersed sites that would benefit from the incorporation of a 300-foot Rule into the 

plan and have been historically used for camping, wood gathering, and hunting.

Response: The 1990 NRA Act limits motorized travel to designated routes. The 300-foot rule did not 

apply to the NRA. However, allowing motorized travel within 300 feet of the edge of the travelway is no 

longer consistent with Forest Service Policy on Travel Planning. Forest Service Manual 7700 – Chapter 

7710, §7716.1 Content of Designations, effective January 8, 2009, states that “road designations must 

specify either that they include parking within one vehicle length, or within a specified distance of up to 

30 feet, from the edge of the road surface.” For the aforementioned reasons this alternative is eliminated 

from detailed analysis.
Appendix G. Response to Comments

190 – Smith River National Recreation Area Restoration and Motorized Travel Management

Play areas for mud, rock crawling, or hill climbing – beyond scope of NRA Act

Letter 

Number

Comment 

Number Comment Text

831 12

There are no play areas for mudding, rock crawling or hill climbing that would allow the Class II user 

to play without damage to a bona-fide trails system (even a road system) included in any of your 

alternatives. It is not right to write a motorized travel plan without including all of the people currently 

using this forest. The writers of this document need to take a hard look at why all of the users 

particularly Class II are not being included. This forest is made up of a variety of plants; Class II users 

are also a variety of users and all aspect of their current use must be include within these pages.

Response: The 1990 NRA Act limits motorized travel to designated routes; therefore play areas for 

mudding, rock crawling, or hill climbing are illegal and beyond the scope of the project. The project will 

provide hundreds of miles of roads and motorized trails that will provide for a variety of user preferences.

UARs will be added to the system as motorized trails, including trail systems on Gasquet Mountain and 

Rattlesnake Mountain.

Beyond the Scope

Uninventoried unauthorized routes

Letter 

Number

Comment 

Number Comment Text

830 17

MOTORIZED ACCESS TO DISPERSED CAMPING AND HISTORIC MINING SITES Local access 

interests have long articulated their passion for motorized access to many of the historic mining 

sites or camps in the area. These sites are detailed primarily in Table 2 and 4 to the Del Norte 

County comments. A typical example of such a site is at the end of the 314.1 road, which

Alternative 6 proposes to designate as open for motorized use. Alt. 6 proposes to close the road at 

the 1.2-mile marker. Unfortunately, the road continues up the mountain and onto a plateau for 

another .5 to .75 of a mile. It makes a loop at the end where there is an old mine site and a water 

source. This is a popular dispersed camp or hunting area. Concerns about Port Orford cedar root 

disease is listed a reason for the road closure. BRC believes that a field trip is warranted with 

county staff to review practical implications of the proposed action and discuss if a seasonal wet 

weather closure would be sufficient to meet the agency’s resource protection objective while 

meeting the county’s general plan prescription for public access to important mining sites. 

Response: Alternatives 4 and 6 propose to designate all but the last 0.3 mi of the inventoried UAR, 

314.1. This portion of the route accesses an uninfected Port-Orford-cedar spring and will be blocked to 

protect this unique feature. This mitigation was agreed to the collaborative group in order to be able to 

add the remainder of the route.

RS 2477

Letter 

Number

Comment 

Number Comment Text

826 12

In the summer of 2013, the Del Norte County Board of Supervisors adopted a resolution (Resolution 

2013-022) which recognized various rights of way, across public lands, to identify historic mine 

locations in Del Norte County. At the time no status or maintenance level was proposed by the 

County as the adoption of the resolution was simply a recognition of the right of way as allowed for 

by the United States Congress under Revised State 2477 (RS 2477). The RS 2477 mines were 

identified as existing between 1866, when RS 2477 was enacted by the US Congress, and 1976, 

when it was effectively repealed under the Federal Lands Policy Management Act. In passage of 

Resolution 2013-022 the Board of Supervisors recognized that the locations of these mines are of a 

“historic” nature and value to the County and that access should be kept open. The resolution was 

passed unanimously by the BOS with a 5-0 vote.

Response: The RS 2477 law states, “The right-of-way for the construction of highways across public 

land not reserved for public purposes is hereby granted.” Lands administered by the Forest Service were 
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 191

reserved for public uses as of the date of their reservation, and what is now the Six Rivers National Forest

was first established by Presidential proclamation in July 1908. If the route to any of these mines was in 

existence prior to the establishment of the national forest, it would have been for the specific purpose of 

allowing the mining claimant(s) access to the claim. This does not meet the criteria of being a public 

highway as the road’s primary purpose. The forest recognizes all legal right-of-way designations, and has 

identified those routes in this project.

Pappas Flat

Letter 

Number

Comment 

Number Comment Text

819 126 Please note that in our Pappas Flat comments (below) we provide specific examples of illegal offroad use that are both foreseeable and predictable.

819 127

The Forest Service must provide greater protection for the small meadow area called “Pappas Flat”

at the end of spur road 17N69 (that immediately forks off the Gasquet Mt. Road, just above, 

Gasquet Mt. Road’s junction with Hwy. 199). Consistent with the Smith River NRA’s stated desire to 

“define a road system that is economically and ecologically sustainable (reduces both maintenance 

costs and risk to sensitive resources),” the gate on this road needs to be permanently locked, with a 

key provided only to the power line company, private landowners, or private parties (such as tribal 

members) that are permitted for special events or other members of the public that have a specific 

reason requiring that they drive all the way in. Off road vehicle damage to the meadow has been 

documented by both the public and the Forest Service. Additionally, someone has been 

inappropriately target shooting, and damaged a mature madrone tree at the edge of this meadow.

The Pappas Flat meadow would be best protected by allowing people to use the existing parking 

area on the west side of the existing gate, and not trying to further develop this area for more 

intense public use and even easier motorized access-that will facilitate, and likely increase the 

present problems. The Forest Service should seek to make this area “a more special place” by 

describing the area as an approximately one-mile hiking destination. Trying to provide parking at the 

meadow will only create foreseeable harmful impacts. Rock barricades will not be effective in 

stopping dirt bikes, excessive shooting, excessive campfire building, littering, or dumping of 

garbage. These concerns were identified in our previous comments on this project and simply 

ignored by the agency. Improper public use can be better and more effectively restrained by 

providing a lock on the existing gate. The particular location of this gate also provides a far more 

effective barrier, while still allowing easily accessible, properly controlled and appropriate public use. 

Finally, it is inappropriate for vehicles to drive through the small creek just before the Pappas Flat 

meadow. Doing so only puts more sediment in the creek, and ultimately will likely result in the 

intentional, or unintentional, destruction of the small, adjacent footbridge, which crosses this stream.

Barriers need to be placed in areas that don’t impact the very location the agency is trying to 

protect, and need to be placed at locations where they are most effective. The present gate, with a 

lock, provides the most effective, most economical, and most ecologically desirable way to protect 

this special resource. Because the spur road to Pappas Flat is very wide at the gate, no additional 

ground disturbance is necessary to provide parking opportunities in front of the gate.

819 128

Pappas Flat is special, not only due to its cultural and uncharacteristic open meadow habitats. 

Additional botanical features of the surrounding Pappas Flat area include the native Oregon White 

Oak grove (on the way in), and at Pappas Flat proper, there are two American chestnut trees.

Response: Pappas Flat was removed from the project area prior to the release of the FEIS in response to 

a significant issue identified through scoping. Therefore, actions within the Pappas Flat area are 

eliminated from detailed study as they are beyond the geographic scope of the project.
Appendix G. Response to Comments

192 – Smith River National Recreation Area Restoration and Motorized Travel Management

Letter 

Number

Comment 

Number Comment Text

819 129

Furthermore, just above the Smith River, and southwest of Pappas Flat proper, a small population 

of a native shrub (& small tree) Toyon, Heteromeles arbutifolia, was recently discovered. This 

population is currently being investigated as it is believed to be the most northern distribution of this 

species in California (and thus anywhere in the northwest.) It was not previously included on a

Forest Service plant list for the Gasquet area, and except for a few very specific sites downstream 

of Pappas Flat, this species is not known elsewhere on the Smith River Recreation Area. Signs 

explaining the special and cultural significance of the area should be placed at the parking area in 

front of a locked gate. These signs too will do doubt periodically need to be replaced. But the costs 

of replacing these signs will be far less than the economic and ecological damage that will otherwise 

result, or continue to occur.

Response: Heteromeles arbutifolia is found in Oregon and the location southwest of Pappas Flat is not 

the northernmost site in the Pacific Northwest. Additionally, this site is adjacent to Highway 199 and will 

not be affected by the proposed actions, and is outside the geographic scope of the project.

Management of roads and routes on Rogue River-Siskiyou National Forest

Letter 

Number

Comment 

Number Comment Text

824 7

Closed gates are not an effective tool. Take a hard look at what happens when gates are closed at 

one point but access is available behind the gate. Gates create frustration and distrust. Education 

by kiosk and by public service announcements are a far more effective tool. Forests throughout the 

northwest have seasonal closures generally November 31st through April 1st. Your forest deserves 

the same treatment; a season closure to align with local hunts. Road 4402, Road 206, Road 450 

are good roads for high clearance vehicles. The typical 4-wheel drive vehicle enjoys a slow trip 

down a road like this. Please do not consider any closures of these roads and reopen the roads that 

bleed off these, as they are campsites. No maintenance on these roads keeps traffic slower and 

also delivers a very enjoyable excursion for families and friends.

831 20

We ask specifically that Road 4402, (road to Sourdough campground) Road 206, and (road up to 

McGrew trail) Road 450 and all existing roads leading off from 4402 to be left open to Class II 

vehicles and all slow traveling OHVs. These three roads are excellent examples of a High 

Clearance, Easy OHV Roads that is currently being maintained as such. No blade; just motorized 

wheels of vehicles keeping them open mostly to forest users’ primary enjoying the beauty of forest 

lands. Please keep them as they are.

831 21

These three roads [4402, 206, 450] are an example of how Level 1 and user created routes can be 

an asset to this forest forever if left open. Instead of closing motorized ways, allow us to keep them 

open mainly by hand as much as possible. Return these roads to this exact state if logging, mining or 

fire crews need to use them. Leaving this type of roads to Mother Nature and the ten thousand of 

motorized forest users (road walkers and MT bikers are also using these roads) who are currently are 

using them annually as the only maintenance needed normally. The little maintenance that is needed 

is by those using these roads as each needs with very little mechanical maintenance needed.

811 2

The decision to close roads by a Forest Service worker out of the Cave Junction Forest Service 

office does not appear to be taking this into account, almost an all or nothing approach to land 

management. If we close roads to prevent access to OUR forests what is the whole point of the 

Forest Service? Keep out the public but let in logging operations that rape the land?

811 4

For more than 30 years now, the Klamath Four Runners 4WD club tries to make a run on the 

McGrew Trail – a wagon road since 1850 for transporting freight to the Illinois Valley – and is still a 

road open to the public. However, our club has to procure a special permit and follow strict 

conditions not required by individuals using the road. HOWEVER in recent years we have had to 

contact Oregon Senator Ron Wyden’s office to obtain the required permit in somewhat of a timely 

manner. Our own telephone calls and e-mails inquiring on the status of the permit are ignored and 

remain unanswered. This would seem to be an unnecessary discourtesy to the very public they are 

supposed to be serving. Routine communication especially in this age of technology should not be 

too much to ask for.

354 1

I’m horrified that you’re considering opening up some of the region’s most special and rare areas for 

off-road vehicles. We have very few places left like the Klamath-Siskiyou forest. Do we really need 

more places for people to drive their giant mud trucks, especially in such ecologically sensitive 

places? Please don’t let ORVs into any more areas. Enough is enough.
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 193

Letter 

Number

Comment 

Number Comment Text

344 1

I understand the importance of seasonal road closures, but recreation in our forest is quite important 

to me. Opening the Gates should have a specific date and not be an arbitrary decision by someone 

with no interest in keeping it available to motorized recreation. I would like to see the gates open 

April 1st just prior to spring turkey season until November 1st witch is the end of Western Oregon 

deer season. Every May and June for past 32 years, the Pacific Northwest Four wheel Drive 

Association uses the McGrew Trail. Every year we run into arbitrary decision making and resistance 

by ignoring us. In 2010, it took a call from Senator Ron Wyden’s office to get our permit to use the 

McGrew Trial. To me, these acts are demonstrations of a bias, which should be disposed of by 

having set dates for the gates to open each year.

324 2

Every May and June for past 32 years, the Pacific Northwest Four wheel Drive Association uses the 

McGrew Trail. Every year we run into arbitrary decision making and resistance by ignoring us. In 

2010, it took a call from Senator Ron Wyden’s office to get our permit to use the McGrew Trial. To 

me, these acts are demonstrations of a bias, which should be disposed of by having set dates for 

the gates to open each year.

303 1

The McGrew trail should be open to the public from April 1 through November 1 to encompass 

Turkey through deer seasons. Opening the trail should not be an arbitrary decision by someone with 

no interest in keeping it available to the public. I understand that there is a person assigned to close 

the trail nut no one assigned to opening it. Every year we try to use the trail, we run into arbitrary 

decision making and resistance by ignoring us. One year, it took a call from a legislator to get the 

trail open. To me, these acts are demonstrations of a bias, which should be disposed of by having 

set dates for the trail to open each year.

818 2

For the past 32 years in May and June, the Pacific Northwest Four Wheel Drive Association uses 

the McGrew Trail. Each of these years has seen issues with arbitrary decisions and resistance by 

ignoring us. In the year 2010, it took a phone call from Senator Ron Wyden to get our permit to use 

the McGrew Trail. Personally, I see these actions as bias against motorized recreation and public 

access to public lands, which would be stopped by having concrete dates for the gates to be 

opened each year.

819 130

The McGrew Trail It has been the position of the SRNF that, because the majority of the McGrew 

Trail is on the adjacent Rogue River-Siskiyou National Forest, the SRNF bears no responsibility for

management of the part of the trail within the Smith River NRA (SRNRA). However, while the RRSNF has initiated a wet season closure and installed a gate on the northern terminus of the trail, the 

southern terminus on the NRA remains a no-man’s land with neither arm of the Forest Service 

taking responsibility for making decisions and protecting the public’s interest regarding the segment. 

Because the southern terminus remains open to all users in all weather, it essentially makes efforts 

of the RR-SNF to at least provide some protection for the large watersheds that are not currently 

infested with the POC root disease ineffective and meaningless. Our organizations brought this 

issue up in comments and in meetings with the SRNRA District Ranger and the Forest Supervisor 

to no avail. The SRNF’s excuse for doing nothing is that there’s an agreement that the RR-SNF is 

the lead agency on the trail. However, the RR-SNF cannot come and install a gate on the SRNF 

end of the trail, nor should they have to. The segment of the trail is clearly on the SRNF and should 

at the very least be mirroring and complimenting the efforts of the adjacent forest. In addition, 

populations of the highly invasive alyssum, that’s of such great concern on serpentine terrain in 

Oregon, have been found along the FS Road 4402, which provide access to the northern terminus 

of the trail. Road 4402 also accesses the SRNRA and North Fork Smith Botanical Area.

819 50

The assumption on page 317 of the DEIS that massive jacked-up 4 by 4 vehicles have the same 

impact on roadless character as dirt bikes is arbitrary and capricious and not based upon any facts 

in the administrative record. See photo attachments 6-7 of a large vehicles being hauled back from 

a “McGrew Trail Run” that enters the Smith River NRA. Does the agency contend that use of these 

vehicles has the same impacts to riparian, soil, roadless, and botanical resources as would use of a 

dirt bike on a single-track trail?

824 8

Sourdough Campground with all of its history is just one example of traditional and historic facts that 

must not be forgotten by closures. Please take a hard look at the devastation closing roads create in 

forest from fire’s horrific murder of plants and animals to the children whose parents are not working 

as the lumber rots and re-burns to the children that will be deprived of tradition and history.

Response: The Sourdough Camp Road and the McGrew Trail, also referred to as Roads 4402, 206, and 

450, are managed by the Rogue River-Siskiyou National Forest and are therefore outside the scope of the 

project. Although the McGrew Trail extends onto the forest where it intersects with Del Norte County 

Road 305, it is managed in its entirety by the Rogue River-Siskiyou National Forest, including the 

issuance of special use permitted events, and is outside the scope of this project. The Gasquet District 
Appendix G. Response to Comments

194 – Smith River National Recreation Area Restoration and Motorized Travel Management

Ranger is in communication with the Rogue River-Siskiyou National Forest to aid in addressing the

concern over the management of the southern terminus of the McGrew Trail.

The forest is aware of the threat posed by yellow tuft alyssum, which is currently not known to occur 

on SRNF. The forest will continue to monitor for it. Anyone with knowledge regarding its presence 

within the proclaimed boundary of SRNF should contact the forest botanist.

High Dome Trail and Elk Camp Ridge Trail

Letter 

Number

Comment 

Number Comment Text

828 14

Elk Camp Ridge motorized trail is a redundant motorized use, as it parallels 314. The supposed 

strategy of the analysis is to reduce redundancy where it exists. Retaining this route is a direct 

conflict of guiding principles.

826 4

While the BOS certainly understands the balance the Forest must strike with the proposed plan the 

County has consistently held the position that maintaining recreational access is a top priority. To 

wit, according to the most recent data available approximately 69.3% of Del Norte County’s lands 

are under federal management (Source: Del Norte County Economic and Demographic Profile 

2014, Center for Economic Development at CSU, Chico). This overwhelmingly preponderance of 

federally managed lands has, over the years, led to a deterioration of access to the “public” lands of 

Del Norte County by recreational users. An example proposed in this plan is the downgrading of 

3E02, the High Dome Trail, from a trail available for motorized use on the current Motor Vehicle Use 

Map (MVUM) to a Non-Motorized Trail.

828 4

The only exception for new recreational opportunity for hiking is high dome trail. This route change 

provides the only new unmotorized recreational opportunity, while also protecting an otherwise 

roadless area. As it is now, high dome motorized trail is an ugly scar on the landscape, an intrusion 

into an otherwise pristine area that can be seen on Google Earth. Furthermore, motorized travel on 

high dome trail is a redundant access that is paralleled by route 315.

830 10

A typical example of a key recreational route is the High Dome Motorized Trail (3E02), which has 

been a popular motorcycle single-track trail used by off-roaders for several decades. Closure of that 

trail has never been proposed by the agency or brought up for discussion during the stakeholder 

process. Yet, Alternative 6 proposes it for closure. This route has long served and become desirable 

within an array of legitimate forest users, and meets the criteria for formal designation for continuing 

vehicle access.

830 14 Remedy – BRC strongly urges the agency to modify Alternative 6 to include the specified routes, 

such as 3E02, among those designated for motorized use.

823 3

I don’t think High Dome is appropriate for a motorized trail because it has a talus slope at one end 

(unsafe), a creek at the other (oil washing into the creek), and a meadow in the middle (vulnerable 

to damage). Elk Camp Ridge trail is too steep and rocky, at least at the lower end, to be motorized 

trail. It borders the North Fork Botanical Area and a meadow at the upper end.

Response: High Dome and Elk Camp Trails are existing motorized trails The scope of the actions 

considered in the project do not include existing motorized trails; therefore there are no proposed actions 

for these trails in any of the action alternatives. See Chapter 1, for more information on the scope of the 

project. The maps in the DEIS incorrectly illustrated High Dome Trail as a non-motorized trail, and will 

be corrected in the FEIS maps.

1872 Mining Act

Letter 

Number

Comment 

Number Comment Text

800 1

The Mining Act of 1872 needs to be abolished. Currently it allows anyone (!) to go anywhere (!) to 

get anything (!). This “Act” is not something that was written for the year 2014. It was written for the 

year 1872. It is part of the problem of anyone having access to “Resources,” whenever and 

wherever they choose. The “anyone,” part can be from any country. We need to be focusing instead 

on protecting what is left. By moving into alternative energy and locomotion, and when we quit 

buying “Their,” poisons and get back on the right track for the sake of our grandchildren.
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 195

Response: The 1990 Smith River NRA Act withdrew the lands of the Smith River NRA from mineral 

entry, subject to valid existing rights. Abolishment or further amendment of the 1872 Mining Law is 

within the purview of Congress and not within the authority of the Responsible Official. Such an action is 

therefore outside the scope of this project.

Private Property and Special Use Permitting

PacifiCorp powerline access

Letter 

Number

Comment 

Number Comment Text

803 3

Please find enclosed a map showing the approximate location of PacifiCorp’s required access. 

PacifiCorp requests continued access along the existing route to provide for the continued safe 

operation and maintenance of our facilities and for the restoration of power in the event of an outage 

or emergency.

Response: No map was enclosed; however, the power line is currently authorized under a special use 

permit and its location is shown on USGS quadrangle maps.

17N23

Letter 

Number

Comment 

Number Comment Text

847 1

Road 17N23 runs through my property (APN 124-02-58. I feel 17N23 should be left open for fire 

protection. 17N23 runs on top of the ridge between Myrtle Creek and Hwy 197. 17N23 could be 

gated at my property, but maintained for fire protection.

Response: Follow-up discussion with this commenter revealed that the concern was for fire protection, 

and does not need or want to use 17N23 for property access. The Forest Service does not have legal 

access (an easement) to cross private property to get to the Forest Service portion of 17N23. If the forest

gets permission to cross the private properties in order to maintain the fuelbreak on 17N23, then the FS 

would not need the road to be drivable in order to do that maintenance work.

18N26

Letter 

Number

Comment 

Number Comment Text

849 1

As you are aware, John P Krauss & Fred R Krauss Calif. Trust own 155 acres in Tl8N R3E Sections 

8, 9, 16, 17, Gov tract 46. Road l8N26 provides access to this tract along with a 1/4 mile spur that 

runs north off of the 18N26 road as show on attached map.

849 2

We request that the Forest Service maintain road 18N26 in a way that will continue to provide 

access to our property for management purposes. A particular concern is to have rapid response 

time for any lightning fires. It is crucial to prevent catastrophic fire loses and maintain the existing 

thrifty conifer forest. In order to maintain reasonable access time, you need to maintain culverts, 

fills, water dips or water bars, minimum road maintenance. The road maintenance will then also 

keep erosion to a minimum.

849 4 We absolutely do not want road 18N26 obliterated or culverts removed.

Response: The Preferred Alternative lists 18N26 as an OML1 (closed road) and calls for reducing the 

risk of road-related sedimentation to protect water quality. Under the No Action Alternative, Road 18N26 

is already OML1, so no change in public access on this road is proposed under the Preferred Alternative.

Access to private land parcels from a closed (OML1) road may be accommodated through a special use 
Appendix G. Response to Comments

196 – Smith River National Recreation Area Restoration and Motorized Travel Management

permit, if no alternative access is possible across private lands. Emergency response access during fires is 

analyzed in the Fire and Fuels Analysis section of the EIS.

411.102

Letter 

Number

Comment 

Number Comment Text

853 1

I am the landowner of 160 acres known as French Hill within the Smith River NRA and I just now 

received notice of this plan. The parcel I own has access by what I believe is marked as 411.102 on 

Alternative 6 map. Alternative 3 does not have this road on it. I need this access road and it has been 

the access road to the property for as long as anyone can remember. I am personally aware of 

records going back 45 years that show the road. As the landowner for the last 10 years, I have used 

this road as my sole access. My personal preference would be to put a gate where 411.102 meets 

411 that Forest Personnel would have a key to and so would I. This would effectively close the road 

to the public but keep open a necessary access for me and an emergency access for firefighting.

Response: The commenter was contacted regarding the special use permitting process, which would be a 

separate project from this Travel Management project. The landowner has indicated that they will pursue 

a special use permit for the use of this route to their property. For these reasons, the barricade will be 

removed in the proposed action alternative for this route.

17N26

Letter 

Number

Comment 

Number Comment Text

853 1

Dave Scheve is concerned about access to his private property, which continues off the end of road 

17N26. He does not like Alternative 5, which would barricade and restore 17N26. He does support 

Alternatives 4 & 6, which specify rocking 17N26. He would like the Forest Service to rock the whole 

road to his property. He installed a gate at his expense at the beginning of 17N26 in coordination 

with District Forest Service staff many years ago.

Response: The commenter’s support of Alternatives 4 and 6, and disagreement with Alternative 5, is 

noted. In Alternatives 4 and 6, the Forest Service proposes surfacing on the entire length of system road 

17N26. This system road does not extend to the commenter’s private property boundary. There is an 

uninventoried route that extends from the end of 17N26 to the private property boundary. The commenter 

has been informed directly that a special use permit is required to use that uninventoried route for private 

property access. NFTS roads can only be gated for administrative purposes only. The gate would need to 

be moved to the private land boundary.

16N19

Letter 

Number

Comment 

Number Comment Text

282 2

It was much appreciated a few years back when 16N19 was brushed...across HW3 land and 

onward toward my home. Monte Saturn started the promise, continued by Pamela Winn, to grade 

the road. Don Pass said to my gate. I look forward to this mitigation occurring.

Response: Routes needed for private property access can be proposed for a special use permit, and if 

approved, the permittee must maintain the road in accordance with the terms of that permit. The Forest 

Service maintains roads for administrative purposes, and maintenance activities will occur based on 

funding and in order of district priority.
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 197

17N22W and 17N22W.1

Letter 

Number

Comment 

Number Comment Text

803 1

As you are aware, PacifiCorp operates and maintains its existing electrical transmission power lines 

on property located within the Six Rivers National Forest and Smith River National Recreation Area. 

Pursuant to your letter, the Forest Service is proposing actions, which may include 

decommissioning or restoring route 17N22W.l which is currently used by PacifiCorp. Such action 

would negatively impact our ability to maintain and service our existing transmission lines.

803 2 On May 20, 2014, a representative from PacifiCorp met with Mr. Mike McCain of the Forest Service 

to further discuss the proposed DEIS alternatives and our required access routes.

Response: The proposed actions in the preferred alternative, Alternative 6, for road 17N22W and UAR 

17N22W.1 are: to Decommission, and to Restore respectively, with water drainage structures planned. 

The following is also noted in the action for each road/route: SUP Road, do not barricade. SUP means 

Special Use Permit, and specifically refers to PacifiCorp’s powerline special use and associated access 

roads. Access would be covered by the special use permit, which is currently in the process of reissuance. 

The permit reissuance project is considered a separate project from the Travel Management project. 

While these two travelways would not be available for public use were Alternative 6 selected, they would 

also not be barricaded, therefore Alternative 6 would not conflict with special use access on these roads.

Multiple Routes

Letter 

Number

Comment 

Number Comment Text

848 1

Along with John and Carolyn Westbrook, my wife and I are owners of ten (10) separate parcels 

(totaling over 610 acres) within the NRA. All of these properties are accessed via USPS roads. 

These include USPS road 15N01 (G-0 Road), 15N01A, 15N38, 15N63, 16N18, 16N18K, 17N04 

and 16N33. Under the preferred Alternative 6 it appears 16Nl 8K will be designated as ML 1 (map 

indicates “closed”) maintained with waterbars/rolling dips as needed. Also, 16N33 will be 

barricaded. These two roads provide the means of accessing two of our parcels (Sugarloaf and 

Hurdygurdy properties, respectively)

848 6

Obviously, we need to maintain access to all of our properties. It is our understanding that the 

USPS does enter into agreement (Use Pennit) with private landowners for this purpose. We would 

willing to maintain (brush and maintain a passable grade) behind gated (rather than barricaded) 

roadways. Of course, we would need keyed access to all locked gates along the access routes. 

While we offer this comment specifically in regards to 16N18K and 16N33, the same comment 

applies to all of the USFS roads which we use for access in the event they are, or may be, proposed 

for closure or maintenance level reduction under any of the proposed alternatives, or in the future.

Thank you in advance for your consideration of our comments. We look forward to working with the 

USFS to assist in any appropriate management of the USFS roads, which we use for access.

Response: Follow-up discussion with this commenter revealed that although a special use permit for 

16N18K may be sought to facilitate private property access in the future, that regular, ongoing access via 

this road is not needed at this time nor in the foreseeable future. Additionally, Road 16N33 does not 

actually access one of the commenter’s other properties. Access to that private parcel would be via an 

uninventoried route, which is by definition outside the scope of the Travel Management project yet would 

still need a special use permit to allow regular, ongoing access. Further discussion revealed that since 

regular access is not needed at this time, that a special use permit could be sought in the future when 

access needs are anticipated. The commenter was advised to contact the Forest Service well in advance of 

needing a special use permit for private property access on any route(s), to allow time to get their 

proposal on the forest’s program of work and to process their request.
Appendix G. Response to Comments

198 – Smith River National Recreation Area Restoration and Motorized Travel Management

Cumulative Effects and Connected Actions

Letter 

Number

Comment 

Number Comment Text

819 60

In the past, our organizations have pointed to concrete and site-specific examples of illegal off-road 

use, like that occurring at Pappas Flat, only to have the agency respond that “the NRA is steep, 

rocky and very brushy.” Such vague generalizations will not pass NEPA muster. The comments 

submitted by Barbara Ullian on the initial EA contained photos demonstrating the increased 

“extreme” ORV use in which riders “rock climb” and “creek” on steep, rocky and brushy terrain 

located off-road. The agency has a NEPA duty to address this increasingly significant connected 

and cumulative impact of off road vehicle use that will be facilitated by the designation of 

controversial user-created routes as part of the NFTS system.

819 120

Cumulative and Connected Impacts Must Be Considered To meet its NEPA obligations the Forest 

Service must adequately document the past, present, and reasonably foreseeable projects that may, in 

conjunction with the proposed project, have cumulative effects that are significant. The combined 

effects of these projects must be evaluated as a whole, regardless of what agency or person 

undertakes these actions (40 C.F.R. Â§ 1508.7; 1508.25 (a)(2); Natural Resources Defense Council v.

Hodel, 865 F.2d 288, 299 (D.C. Cir. 1988); Neighbors of Cuddy Mountain v. U.S.F.S. (9th Cir. 1998) 

137 F.3d 1372; Blue Mountain Biodiversity Project v. Blackwood (9th Cir. 1998) 161 F.3d 1208).

Response: Cumulative Effects are addressed in each resource analyzed within Chapter 3. A list of the 

projects and activities considered in the cumulative effects analysis is in the Appendices, and addressed by 

resource in Chapter 3. This project does not authorize motorized travel up creeks as shown in Ullian’s 

photos, which are actually of an area located on the Rogue-Siskiyou NF. The project includes mitigations, 

such as route delineation, boulders, gates and barricades to reduce the likelihood of travel off designated 

routes, and therefore the risk to resources due to illegal motorized travel off designated routes. The actions 

shown in the photo are not considered connected as defined by CEQ. As such, “Actions are connected if 

they: (i) Automatically trigger other actions which may require environmental impact statements; (ii) 

Cannot or will not proceed unless other actions are taken previously or simultaneously; (iii) Are 

interdependent parts of a larger action and depend on the larger action for their justification.” The actions 

included in this project do not automatically trigger other actions shown in the photos which would require 

the preparation of an EIS; the illegal activities are not dependent on the project moving forward, nor is the 

project dependent on illegal activities occurring to proceed, and lastly neither the illegal activities shown in 

the photos nor the project depend on one another for their justification.

Cumulative Effects to Sensitive Plants

Letter 

Number

Comment 

Number Comment Text

819 122

The agency must analyze what the cumulative impacts of this project will be on sensitive plant 

species long-term viability, relative to projects and policies on private land, including fire 

suppression, mining, timber harvest, and land management practices on other ranger districts (40 

CFR 1508.7). The NEPA document must address cumulative effects to sensitive plant occurrences 

of increased off-highway vehicle use or an increase in illegal off-road vehicle use related to the 

route designation. According to Appendix D in the previous NEPA analysis, the Cumulative Effects 

Analysis for the proposed action includes: ...to allow dual use, licensed and unlicensed motorized 

recreation vehicles, on county roads within the project area. These demographic processes may 

increase recreation and other resource demands in the NRA. If future use of routes proposed for 

designation by motorized recreation results in an increase so to does the potential for intensity of 

negative effects to TES plant species growing on the road surface.

Response: All action alternatives will reduce roads/routes miles across the NRA by between 21 and 47 

percent, including in sensitive plant habitat. Routes will only be added to the system provided resource 

risks can be mitigated. All action alternatives would result in resource protection benefits including 1) less 
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 199

than 0.1 percent of the serpentine sensitive plant habitats on the NRA are being affected; 2) all routes into 

the North Fork Botanical Area are being closed, protecting over 20,000 acres of potential habitat; 3) 

routes to be kept will be upgraded to correct drainage problems, and 4) POC protection measures are 

common to all action alternatives.

A cumulative effects analysis was completed which analyzed the impacts of past, present and 

foreseeable future projects on sensitive plant species long-term viability affected by the proposed actions.

It did not include an analysis of off road illegal use, which is beyond the scope of the proposed actions.

Use will be monitored to determine if it is increasing toward a threshold that could lead to a trend 

toward a loss of viability. Sensitive plant populations within 100 feet of UARs added to the NFTS will be 

managed via monitoring to determine if a decline in Sensitive plant populations has occurred. If a decline 

of any Sensitive plant population is found to have occurred that indicates a trend toward a loss of viability, 

the UARs with the declining species that were added to the NFTS will be removed from the Motor Vehicle 

Use Map and barricaded until such time that Sensitive plant populations are found to have recovered.

Cumulative Effects to IRAs, POC, Botanical Reserves and Salmon Habitat

Letter 

Number

Comment 

Number Comment Text

828 14

The review document is internally inconsistent, and fails to consider the cumulative impact of adding 

more unauthorized motorized routes (motorized trails/motorized roads/motorized use of all kinds 

along a graded surface upon the land) to a road system that is already broken by OHV use and is 

significantly impacting roadless characteristics and irreplaceable resources such as Port Orford 

Cedar, and botanical reserves, and cumulatively does impact precious salmonid habitat.

Response: All action alternatives will reduce roads/routes miles across the NRA by between 21 and 47 

percent, including in sensitive plant habitat. Routes will only be added to the system provided resource 

risks can be mitigated. All action alternatives would result in resource protection benefits including: 1) 

less than 0.1 percent of the serpentine sensitive plant habitats on the NRA are being affected; 2) all routes 

into the North Fork Botanical Area are being closed, protecting over 20,000 acres of potential habitat; 3) 

routes to be kept will be upgraded to correct drainage problems, and 4) POC protection measures are 

common to all action alternatives. All alternatives would restrict vehicles to designated routes.
Appendix G. Response to Comments

200 – Smith River National Recreation Area Restoration and Motorized Travel Management

Cumulative Effects of BMPs

Letter 

Number

Comment 

Number Comment Text

819 124

The Forest Service should not rely on Best Management Practices (BMP) to assure water quality 

while failing to disclose the cumulative impacts of implementing the proposed BMPs. Please note 

that on page 587 of the DEIS the agency states that when designating motorized trails it will 

implement a BMP to “avoid sensitive areas, such as riparian areas, wetlands, stream crossings, 

inner gorgeous and unstable areas to the extent practicable.” Yet the preferred alternative calls for 

adding high risk routes (such as 305.118) that impact nearly all of the sensitive areas listed above.

Page 587 of the DEIS states that it will implement a BMP to “close and rehabilitate unauthorized 

trails that are causing adverse effects on soil, water quality and or riparian reserves.” Actually, the 

agency is proposing to add a number of high risk, high impact unauthorized trails. Page 588 of the 

DEIS acknowledges that a BMP is to “design the transportation system to meet long-term Forest or 

Grassland Plan desired conditions, goals and objectives for access rather than to access individual 

sites.” The preferred alternative places access to individual sites ahead of the long-term

maintenance needs, desired conditions, goals and objectives of the Forest Plan. The prevention of 

potentially adverse impacts at the project site through BMPs is indeed necessary, but not sufficient 

to avoid cumulative effects (CEQ 1971). As Reid (1993) states: The BMP approach is based on the 

premise that if on-site effects of a project are held to an acceptable level, then the project is 

acceptable, regardless of activities going on around it. Interactions between projects are beyond the 

scope of BMP analysis, and operational controls are applied only to individual projects. However,

useful site specific BMPs are in minimizing effects of individual actions, they still do not address the 

cumulative effects of multiple actions occurring in the watershed, which, though individually 

“minimized” through application of site-specific BMPs, may still be significant, in their totality, and 

have undesirable consequences for beneficial uses such as salmon populations and salmon 

habitat. The argument that applying a BMP while conducting a specific forest practice minimizes 

site-specific effects and thus also minimizes cumulative effects is logically flawed. Every BMP is an

action and has an effect ... thus generally, the more the BMPs are applied the greater the

cumulative effect. Only by minimizing the number of actions, i.e., the number of individual

applications of BMPs, would cumulative effects by minimized. This is precisely why a cumulative 

effects assessment is needed-to establish the watershed-specific limits and excesses of BMP 

applications. –Reid, L.M. 1993, Research and cumulative watershed effects, Berkeley, California, 

Pacific Southwest Research Station: US Department of Agriculture, Forest Service General 

Technical Report PSW-GTR-141, 118p.

Response: A cumulative watershed effects analysis was conducted for this project. All of the affected 

watersheds are well below the Threshold of Concern. Implementation of the proposed actions will not 

result in cumulative adverse impacts to water quality. Consultation with the National Marine Fisheries 

Service determined that the project was not likely to adversely affect listed fish or Critical Habitat, and in 

fact is considered beneficial. The project will reduce road miles and sedimentation across the district, and 

will meet ACS objectives.

All action alternatives will reduce roads/routes miles across the NRA by between 21and 47 percent.

Routes will only be added to the system provided resource risks can be mitigated. All action alternatives 

would result in resource protection benefits.

The route mentioned, UAR 305.188, was identified by the Del Norte County Board of Supervisors 

and Sheriff’s Office as valuable access for search and rescue operations in the North Fork. As such, the 

preferred alternative designates the first portion of Route 305.118 to be added as a motorized trail open 

for use during the dry season. The remaining portion, which has a Darlingtonia bog and accesses 

uninfected POC stands (and the portion with the high risk to water quality) would be barricaded and not 

open to motorized travel. Because of the steep terrain surrounding much of the NRA, most vehicle 

barriers are effective for eliminating motorized access. Barriers or gates are placed adjacent to steep cut 

banks where a vehicle cannot get around the closure area. Best management practice monitoring results 

across the SRNF verify these findings.
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 201

Letter 

Number

Comment 

Number Comment Text

819 125

Besechta et al. (1995) also identified several conditions necessary for accurate analysis of

cumulative watershed effects, including: 1) accurate understandings of natural variation in 

environment; 2) reliable baseline information at the local and regional scale (ideally from “reference”

sites); 3) accurate assessments of the probable effects on key resources of past, present and 

foreseeable future activities; 4) development of reliable models that relate resource conditions within 

a dynamic spatial framework; and 5) establishment of levels of acceptable change in the 

environment. The FEIS did not adequately consider and disclose the synergistic effects of the 

proposed action.

Response: A cumulative watershed effects analysis has been completed for the FEIS. The methodology 

includes and synthesis of direct, indirect and cumulative effects and conforms to Regional policy and 

direction. The analysis revealed that the proposed actions would not result in adverse cumulative 

watershed effects. Road decommissioning and route restoration is a major component of the proposed 

actions and is intended to reduce past impacts associated with road construction and unauthorized 

motorized use.

Irreversible and Irretrievable Determinations

Letter 

Number

Comment 

Number Comment Text

819 81

Please note that the contention on page 417 that the project does not involve an irreversible or 

irretrievable commitment of resources is incorrect. In fact, the decision to encourage motorized use 

on high-risk routes has “the potential to have a relatively large impact to Port Orford Cedar plant 

communities based on plant community composition or the potential to infect currently uninfected 

watersheds.” (DEIS 218). Despite the clear mandates from the LRMP and Smith River NRA Act to 

protect POC resources and the stated project purpose to implement the findings of the Travel 

Analysis Process (TAP) the Forest Service appears irreversibly committed to implementing

Alternative 6 such that 50 high risk UARs are added to the NFTS providing additional motorized 

access to uninfected POC watersheds in order to maximize the recreational preferences of a small 

minority of forest visitors.

Response: The roads and routes being considered in this analysis are open and drivable. All action 

alternatives will reduce roads/routes miles across the NRA by between 21 and 47 percent. POC mitigation 

measures are incorporated into all alternatives. Routes will only be added to the system provided resource 

risks can be mitigated. All action alternatives would result in resource protection benefits. The project 

meets LRMP S&Gs and Smith NRA Act objectives.

The DEIS definitions for Irreversible, worst case, would be the extinction of the species or perhaps 

interpreted more conservatively would mean the extirpation of the species from an area. Implementation 

of any of the alternatives would not lead to the extinction or extirpation of Port Orford cedar from the 

analysis area.
Appendix G. Response to Comments

202 – Smith River National Recreation Area Restoration and Motorized Travel Management

Impacts to Motorized Recreation Opportunities and Access to 

Dispersed Recreation

Historic, Current and Proposed Access to Dispersed Recreation

Letter 

Number

Comment 

Number Comment Text

824 4

Hunters of all denomination and form utilize their 4-wheel drive vehicle to slowly maneuver the trails 

in this forest. You must take a hard look at your fact gathering tactics and the results closures would 

bring. Please take a hard look at your over amount of closers for Class II recreationalists. The forest 

in question is highly utilized by the populace of Oregon and California for varied uses. Ranging from 

hunting wild animals to hunting mushrooms and your lack of concern as you have closed roads is 

disconcerting to the citizens who depend upon access to these woods.

824 6

You must take a hard look at the traditions of the families and businesses that have for generations 

maintained a living in and around the Smith River National Recreation Area. Motorized vehicles 

have brought families to picnics in special areas for countless generations you cannot alter the lives 

of these people and their heritages. Please take a hard look at what your choices are doing to the 

heritages of these families and businesses. Camping is another issue that you are not evaluating 

wholly. Take a hard look at the camping that will be eliminated in your choices. This represents 

countless traditional outings and you must not end the ability to tell family heritages at campfires in 

the same spot as their forefathers did. Camping is seclusion and camps close to roads with traffic 

over 5 miles an hour is not camping.

826 8

In addition to the priority dispersed campsites identified in the above table, there are a vast number 

of other dispersed recreational sites available for use within 300-feet of the NFTS and county roads. 

During outreach with the public on this issue the need to add a “300-Foot Rule” to allow for the use 

of these areas for camping, wood gathering, and hunting was identified as having been omitted from 

the plan despite prior discussions between the County, users, and the Forest. Currently there is no 

provision in the plan to allow for such uses within 300-feet of NFTS routes. This should be added in 

order to facilitate lawful and responsible recreating, wood gathering, and hunting in the NRA. In 

addition to the priority dispersed sites in the above table, the County has geo-located dozens of 

other unnamed, dispersed sites that would benefit from the incorporation of a 300-foot Rule into the 

plan and have been historically used for camping, wood gathering, and hunting.

804 2

When the National Rec. Area was first implemented, we were promised that access was going to be 

increased into our forest. So now when your proposal to close 200 miles of road is on the table is 

just shows us that we can’t trust the promises made by our government and the environmental 

movement attempting to keep us out of our forest.

Response: The 1990 NRA Act limits motorized travel to designated routes. The 300-foot rule did not 

apply to the NRA. In addition, Forest Service Policy on Travel Planning. Forest Service Manual 7700-

Chapter 7710, Section 7716.1 Content of Designations, effective January 8, 2009, states that “road 

designations must specify either that they include parking within one vehicle length, or within a specified 

distance of up to 30 feet, from the edge of the road surface.”

In 2005, the Travel Management Rule established and required the use of MVUM to display the 

designated NFTS open to motorized travel. The current MVUM for the Gasquet Ranger District (Smith 

River NRA) reflects the status of NFTS roads and motorized trails in the forest’s transportation database 

at the time of publication in 2009. Many UARs on the Smith River NRA are not the result of off-road 

recreationists, as the terrain in many parts of the Smith River NRA itself limits this, but rather they are old 

mining roads or Forest Service logging roads that were not tracked in the transportation database in 1990. 

The public’s input was not involved in identifying recreation opportunities or determining the NFTS 

shown on the 2009 MVUM. With the publication of the 2009 MVUM many of the routes that had been 

used by recreationist in the past were then identified as UARs and therefore illegal for motorized travel. 

Unauthorized routes considered for designation on the NFTS are limited to those that currently exist on 

the ground and have been inventoried.
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 203

During the summer of 2012, more than 100 short routes were inventoried and reviewed for inclusion 

in the project, and recommendations for designation on the NFTS were made based on the recreation 

opportunity, provided any safety and resource concerns could be mitigated. As a result the project 

analysis a range of alternatives that provides access to dispersed campsites was developed. Effects to 

dispersed recreation opportunities are analyzed in the Recreation Section of Chapter 3 of the Final EIS.

The Smith River NRA Act recognized the unique attributes of the Smith River watershed including 

diverse conifer forests of the Siskiyou Mountains, unique botanical communities of the North Fork, and 

renowned anadromous fisheries, while also acknowledging the exceptional opportunities for a wide range 

of recreational opportunities that through careful development and utilization would provide mutually 

compatible levels of recreation, fisheries, and timber resources. Direction is provided to the forest service 

to provide for a broad range of recreation uses and provide recreational and interpretive services and 

facilities (including trails and campgrounds) for the public, provide and maintain adequate public access, 

including vehicular access roads for general recreation activities, and permit the use of off-road vehicles 

only on designated routes. However, the Act strongly balances the direction to provide for recreation 

opportunities by directing the Forest Service to improve the anadromous fishery and water quality, 

provide for the long-term viability and presence of Port-Orford cedar; protect, preserve and increase oldgrowth forest habitat; and restore landscapes damaged by past human activity, to name a few. This project 

is consistent with the intent and administrative direction outlined in the SR NRA Act by providing for 

motorized recreation opportunities through the addition of motorized trails to the NFTS, while also 

reducing risks to the unique qualities and characteristics of the SR NRA such as botanical communities, 

water quality, POC, and cultural resources through decommissioning of roads and the implementation of 

risk reducing mitigations on the proposed NFTS.

Authorizations for the collection of special forest products, such as mushrooms and firewood, are 

handled under separate permitting authority and are subject to the parameters of the permit.

Consideration of ‘Class II’ input

Letter 

Number

Comment 

Number Comment Text

824 1

Please take a hard look at the facts of your documents. I do not find Class II input. I do not think a 

true document can be based on half facts. OHV is Off Highway Vehicle: it does not mean crosscountry vehicle. You must take a hard look at the fact-finding within your documents. Class II 

vehicles are a legitimate use of public lands. You have omitted largely half to three quarters of 

Oregonians and Californians by closures and gates on roads and trails.

Response: All interested parties are invited to provide input at various stages of this project, and many 

have. Comment-by-comment and route-by-route analysis was completed based on comments received 

during the scoping and public comment periods. The significant issues and suggested alternatives 

identified by the public drove the development of Alternatives 4, 5, and 6, which are alternatives to the 

Proposed Action (Alternative 3). It is recognized that OHV does not mean cross-country (off-route) travel.

It is also recognized that using OHVs, also known in Oregon as Class II vehicles, is a legitimate form of 

motorized recreation in National Forest System lands. Motorized recreation opportunities are one of the 

many resources being managed for with this project. The project will provide hundreds of miles of roads 
Appendix G. Response to Comments

204 – Smith River National Recreation Area Restoration and Motorized Travel Management

and motorized trails that will provide for a variety of user preferences. Unauthorized routes will be added 

to the system as motorized trails, including trail systems on Gasquet Mountain and Rattlesnake Mountain.

The Forest Service is required by the Smith River NRA Act and Forest Plan standard and guidelines 

to reduce risk to Port Orford cedar. Seasonal gate closures are a mitigation used to reduce risk to POC by 

eliminating motorized travel in the wet season when the risk of the spread of infection to POC is high, 

while maintaining motorized access during the dry season. For more information on seasonal closures, see 

Chapter 2 under Resource Risk Mitigations.

Anticipated Motorized Recreation Use Level & OHV Community Engagement

Letter 

Number

Comment 

Number Comment Text

831 9

The CFRs state that millions of forest users come in a motorized vehicle and continue to do so 

throughout their forest visit. Instead of single mile of existing motorized routes being closed the 

management of this forest should be creating hundreds of miles of different types of motorized 

trails, motorized ways, opening hundreds of miles of Level I and Level II roads to high clearance 

travel vehicles (already existing is thousands of miles of roads that are maintained to some degree). 

It is the primitive motorized roadway, trail, way, route that the motorized community is looking for.

831 17

It is our belief that no road should be barricaded or gated until the OHV community and others 

(particularly local motorized residents) have been consulted on the ground and in person. The forest 

service is not doing enough to include the people who are currently using particular motorized routes 

before closing them whether for work or outdoor recreation. This type of document will not be seen by 

the majority of the local and national OHV community but input or the lack of it gained by the few 

public comments receive does not justify closures of miles of roads. Millions of Americans will be 

affected by these closures forever but millions of Americans have not nor will be contacted to address 

this motorized travel plan, which will be implemented. We are asking that no roads, motorized routes, 

Level I or Level II road be closed whether created by blade or mechanized wheel. Motorized routes 

need to be increased to meet the growing number of Americans using motorized transportation within 

national forest boundaries not decreasing the miles available. It should be apparent to the writers of 

this document that there is millions of acres set aside for non-motorized activities.

831 22

Let it be noted for the record that under Supporting Notice and Resource Reports that not a single 

motorized group is mentioned. Not one single OHV club, group or economic reports from OHV shop 

either for sales, repairs or exchanges have been contacted for information for this document. Not a 

single OHV organization was contacted for their inputs on roads, motorized trail, their usage 

documented per roads and trails of use. Not a single motorized user of the forest has words written 

within this document supporting motorized use on public lands. This is wrong! This is supposed to 

be an unbiased document concerning Motorized Travel Management Plan within the Smith River 

National Recreation Area and it should be filled to the brim with our documentation whether for work 

or outdoor recreation. Why have the writers not contacted the motorized user of public lands for 

written documentation of our current, past and hopefully future use of these lands? We cannot 

support Alternative 6. We would support Alternative 4 if the eleven paragraphs above would be 

considered and Alternative 4 would be amended to include each.

Response: It is recognized that millions of visitors to national forests arrive and recreate in motorized 

vehicles. The SRNF’s National Visitor Use Monitoring Reports from 2008 and 2013 identify visitor rates 

and activities specific to the forest (Chapter 3). To leave open every mile of existing NFTS route, if no 

administrative or public need has been identified for that route, would not meet the purpose and need of 

the project.

The forest strives to engage interested and potentially affected publics in a manner that meets or 

exceeds our legal obligations. Over the 12-year period of the Smith River NRA Roads Analysis Process 

and subsequent NEPA documents, the Forest Service has provided multiple opportunities for the public to 

comment on the process, including multiple public meetings and workshops, newspaper articles, public 

service announcements, and months of public review time. Multiple OHV groups were contacted and 
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 205

provided comments throughout the process, and two OHV groups, as well as individual OHV enthusiasts, 

participated in the 2010 collaborative process for the project.

In the preparation of this EIS, the forest exceeded the public involvement requirements legally 

mandated by the Travel Management Rule and the NEPA process. In addition to the soliciting comments 

from the public through the Scoping and Draft EIS commenting period required by the NEPA process, the 

SRNF has hosted four public meetings or workshops prior to the release of the FEIS, where forest staff 

presented information about the project, the alternatives, the planning process and how to get involved, 

and discussed both general and route-specific concerns with members of the OHV community in-person 

to gain a shared understanding of the issues of concern and values at stake. Letters representing OHV 

groups came from the Blue Ribbon Coalition during the scoping process and from numerous independent 

OHV users. During the DEIS comment period, in addition to the comments provided by the Pacific 

Northwest Four Wheel Drive Association, letters also came from: Northwest Trail Riders, Blue Ribbon 

Coalition, Deschutes County 4 Wheelers, Klamath Falls Four Runners, and independent OHV users. This 

project includes a range of alternatives developed in response to the issues and route specific information 

provided by the public.

Diversity of Motorized Recreation Experiences

Letter 

Number

Comment 

Number Comment Text

400 1

I am encouraged by the direction that the Smith River National Recreation Area Travel Management 

process is taking. Like most Americans, I value the wildlands, watersheds and wildflowers of this 

special place. I am not able to hike anymore due to cancer. I still want to experience this special area 

via OHV. I would like to place special attention on keeping the trail system and primitive as possible.

831 25

Most Americans want and ask for a way through the forest slowly as it naturally meanders through 

the forest terrain in their chosen mode of motorized transportation. The obstacles of the forest and 

mother earth left in place and very little maintenance done to the wheeled route. This is entirely left 

out of the alternative provided in this document. Just fast roads, fast/hot routes but the majority of 

the forest users are there to enjoy the forest at a leisurely pace in a motorize vehicle.

Response: The project will provide hundreds of miles of roads and motorized trails that will provide for 

a variety of user preferences and experiences. Unauthorized routes will be added to the system as 

motorized trails, including trail systems on Gasquet Mountain and Rattlesnake Mountain. Creating new, 

slow tracks for a high-complexity OHV experience is outside the scope of this project because 

construction of new routes is outside the scope of the project.

Impacts to Motorized Recreation Opportunities

Letter 

Number

Comment 

Number Comment Text

559 1 We do not need to close “off-road” riding trails and areas just to preserve a “special flower”.

559 2

Those “special flowers” will continue to grow just as they have been growing for the past hundreds 

& hundreds of years. Furthermore, we are talking about vehicles and or motorcycles traveling on a 

road or trail, and the “special flowers” don’t grow in the middle of the road or trail, so why the need 

to shut our beautiful riding areas down??? There are millions of flowers and plants all over the 

world, are you suggesting we shut down motorized use on all of the roads and trails out there? No, 

because that would not make any sense.
Appendix G. Response to Comments

206 – Smith River National Recreation Area Restoration and Motorized Travel Management

Letter 

Number

Comment 

Number Comment Text

559 3 So why continue to try and shut down the places my family and I use, love and care for. I’m sure 

you wouldn’t like it if I was trying to shut down the trails & roads that you and your families use, love 

and care for.

Response: The Forest Service is required to manage resources in compliance of the standards and 

guidelines in the Forest Plan, the Smith River NRA ACT, and the IRA values that provide guidance to 

conserve and protect. Several Forest Service Sensitive plants do occur on some of the unauthorized routes 

(UARs) proposed for addition to the National Forest Transportation System. Forest Service Sensitive 

plant species are those that have been identified by the Regional Forest for which there is a concern for 

their viability as evidenced by significant current or predicted downward trends in population numbers.

The Forest Service is required to manage these very rare plants to avoid a loss of viability or trend toward 

Federal Listing. Sensitive plants that are present on UARs proposed for addition to the NFTS, some of 

which occur in the middle of these routes, have a tolerance for the low level of use that has been 

occurring on those routes most likely due to passive avoidance, subterranean meristem tissue, and multistem growth, enhanced seedbed conditions, and a reduction in competition from plant species that are less

tolerant of the current level of use. The projects aims to protect the viability of the rarest plants in the 

project area via an adaptive management strategy to monitor motorized impacts as use rates change over 

time. In keeping with the adaptive management strategy, if a concern for species viability is triggered it 

will warrant line office involvement and management action that includes either: barricading the affected 

occurrence, buffering the occurrence with boulders, or barricading the UAR with associated removal from 

the MVUM if occurrence barriers are not feasible.

Access for Americans with Disabilities

Letter 

Number

Comment 

Number Comment Text

804 4

3. Your road closers proposal also is a violation of the Americans with Disabilities Act by denying

access to our backcountry to disabled people and elderly seniors who have mobility issues. 4. I am 

a sportsman and love to hunt, but the older I get the harder it gets to hike in and drag out a game 

animal. Roads are a huge plus for me personally and my family and friends who are disabled. I 

disagree with any and all proposed road closers.

831 14

Every road will enable millions of Americas that are disabled, sick, old and most important those 

who just don’t have time to spend more than an hour or day in the forest and then motor back home 

on a motorized travel system.

854 1

He and 30 other disabled people are wondering why there is no access for disabled people. Why 

only catering to hikers and kayakers? His group is considering a class action lawsuit to get more 

disabled access. There is no access for disabled people to get to Devil’s Punchbowl, or in 

campgrounds. There is no real access to rivers for people in wheelchairs.

Response: Implementation of the Travel Management Rule, Subpart B is forest wide and applies to all 

forest users equally. Under the Architectural Barriers Act, the Forest Service will follow the Forest 

Service Outdoor Recreation Accessibility and the Forest Service Trails Accessibility Guidelines.

However, facilities that are non-motorized or closed are not subject to these guidelines. Restrictions on 

motor vehicle use that are applied consistently to everyone are not discriminatory.
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 207

Impacts to Non-Motorized Recreation

Quiet Recreation

Letter 

Number

Comment 

Number Comment Text

828 3 Yes, you can get to the backcountry by vehicle – but when you get there, you are not going to be 

able to hike in peace and safety.

20 1

I can’t believe that you would even contemplate opening the Smith River National Recreation Area 

to a handful of extreme off-road vehicle enthusiasts. I value the wildlands, watersheds and 

wildflowers of this special place and often kayak quietly down several of the forks of the Smith river. 

I am concerned that the wreck-recreational preferences of extreme off-road vehicle riders would 

destroy my ability to enjoy the Smith River National Recreation Area.

243 4 I strongly request that there is no forward movement for motorized vehicles in our forests. We have truly

only a fraction of what once was that is undisturbed by noise pollution and environmental pollution.

755 2 Those of us who enjoy the more quiet means of recreation might be more quiet in our requests, but 

we are here, in numbers.

793 5

Last but not least, like other hikers, I value the peace and quiet that natural places offer. The sights 

and sounds of ATV’s and other obnoxious off-road vehicles are completely antithetical to the 

original purposes for which National Forests and Parks were designed.

828 8

Roadless characteristics are valued because of the recreational need to experience the natural 

world and all its subtle sounds that are despoiled by engine noise. And this is no small oversight, as 

the majority of recreational users are those who seek the sounds of nature.

Response: The roads and routes being considered in this analysis are open and drivable. All action 

alternatives will reduce roads/routes miles across the NRA by between 21 and 47 percent. The acres 

available by alternative for quiet recreation activities within the project area by season are described in the 

Recreation section of Chapter 3.

The impact to quiet recreation opportunities by season is analyzed in respect to recreation 

opportunities on the SRNRA, and specifically in IRAs that occur on the SRNRA and considered in the 

decision making process. The results of the analysis are shown in Chapter 3 of the FEIS under the 

Environmental Consequences subheading within the Recreation and IRA sections.

Non-Motorized Recreation

Letter 

Number

Comment 

Number Comment Text

828 6

During scoping and the alternative presentation, the lack of attention to the needs of non-motorized 

recreational travelers was pointed out. But this need goes unanswered for the most part. The 

recreational need to experience the outdoors filled by the sounds of the natural world, rushing of 

water, songs and calls from above, wind through leaves – the recreational need to travel, immersed 

in the sights and sounds of the natural world, is overlooked. What we find in this document is the 

identification of a resource impact to roadless characteristics, without the associated degradation to 

recreational experience.

828 7

Within the summary of effects table, page 36, an appropriate negative rating of 3 for preferred 

alternative 6 is given to Inventoried Roadless Area impacts. But the summary chart fails to 

recognize the associated degraded recreational experience that most users will encounter if 

vehicles are permitted to intrude directly adjacent to or within roadless areas. The summary chart 

gives a higher rating for quality recreational experience to alternative 6 (which despoils roadless 

areas) than it does for alternative 5, which better conserves roadless areas.

Response: The roads and routes being considered in this analysis are open and drivable. All action 

alternatives will reduce roads/routes miles across the NRA by between 21 and 47 percent.
Appendix G. Response to Comments

208 – Smith River National Recreation Area Restoration and Motorized Travel Management

The Summary of Environmental Consequences table located at the end of Chapter 2 of the EIS 

summarizes the resource analyses detailed in Chapter 3. Effects to quiet recreation are broken out separately 

in the summary table of the EIS for the Recreation resource. Effects to primitive and semi-primitive nonmotorized, and semi-primitive motorized are IRA values and characteristics that were analyzed and 

considered in respect to effects to IRAs. The information provided in Summary of Effect Table in the IRA

section of Chapter 3 of the EIS summarizes the effects to IRA as defined by IRA values and characteristics. 

The Summary of Environmental Consequences table is derived from these determinations.

Letter 

Number

Comment 

Number Comment Text

255 3

I want my National Forest lands to stay forest: with wildlife, wild plants, clean air, clean water, 

peace, quiet, hunting, camping and fishing values preserved...NOT GIVEN AWAY to a loudmouth, 

vocal minority that want to ram their off-road vehicles even further through these lands.

Response: The roads and routes being considered in this analysis are open and drivable. All action 

alternatives will reduce roads/routes miles across the NRA by between 21 and 47 percent.

The Forest Service, as an agency tasked with multiple-use conservation by the Federal Lands Policy 

and Management Act of 1976 (FLPMA), must provide for and manage motorized recreational access to 

Forest Service lands, in addition to the many other resources values managed. This motorized access must 

address both OHV travel and other motorized travel to access non-motorized travel opportunities, such as 

trailheads and dispersed camping areas. Where possible within the scope of the project and in compliance 

with law, regulation, and policy, the Forest Service is required to analyze impacts to recreation resources 

along with all the other resources that we must protect and manage, including quiet recreation resources.

The acres available by Alternative for quiet recreation activities within the project area, by season, is 

described in the Recreation section of Chapter 3 of the EIS, and summarized in the Summary of 

Environmental Consequences table in Chapter 2.

Letter 

Number

Comment 

Number Comment Text

850 4

The Northwest Trail Riders are an equestrian group whose goal is to assist and encourage the 

acquisition, construction, maintenance and supervision of bridle paths, horseback trails, staging 

areas and rights of way in the north coast area. Old roads make excellent bridle paths.

Response: Closed (ML 1) roads that are not available for motorized use will remain legal for equestrian 

and other non-motorized travel. Routes not designated on the NFTS will continue to be available for nonmotorized recreation.

Conflict of Uses

Letter 

Number

Comment 

Number Comment Text

659 1

My family has stopped going to some of our favorite wilderness areas to avoid the prevalence of 

rowdy, destructive ATV’s. They are anything but family friendly. Please do not turn the Six Rivers 

National Forest into another ATV off road park.

802 1

As an avid forest lands hiker, I am dismayed by the direction that the Smith River National 

Recreation Area Travel Management process is taking. So often anymore, I find it difficult to find 

areas where OHV and motor vehicles are not traveling in the same areas I am in.
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 209

Letter 

Number

Comment 

Number Comment Text

828 1

Although the National Recreation Area Travel Management Plan should support a range of 

recreational travel uses, it does not. The analysis, for the most part, fails to consider important 

recreational trail uses that are in direct conflict with motorized use. Such important recreational use 

is the enjoyment of hiking without the noise, pollution and danger of vehicles, through the last 

vestiges of roadless areas in our nation. Recreational travel by foot or by bicycle or by horse along 

trails seems to have almost no place in this plan, although the report claims to include these uses 

on page 4, item 1, and again on page 11.

828 2 Provide for a broad range of recreational uses. Provide and maintain adequate public access, 

including vehicular roads for general recreational activities such as camping, hiking, hunting, fishing.

828 5

Personally, I avoid hiking SRNRA roads or unauthorized routes because I was almost run over by 

OHV users that were having fun doing what they like to do best, drive recklessly in the backcountry. 

For most backcountry hikers, being worried about an OHV user barreling around a tight turn on a 

narrow road pretty much eliminates hiking opportunities on motorized routes.

655 1

As someone who has lived in Del Norte County for 28 years and explored miles of forest service 

roads, I am well aware that there are many, many roads that go lots of wonderful places, and, if you 

drive slowly, even my little Toyota car can navigate them. I have also hiked with great pleasure in 

the wilderness areas where motor vehicles are off limits. While I agree that we need a balance, I do 

not believe that our forests need to cater to souped up off-road vehicles that want to go tearing 

through the forests. That kind of driving belongs on a racetrack. I appreciate your consideration of 

those of us who head up to the mountains to experience the natural environment in all its natural 

beauty, and who care about the survival of these wild lands.

296 1

I am more than dismayed! Why cater to a small population of people who have little regard for their 

impact! I regularly hike and camp in the Smith River NRA. Many of the campgrounds I visit are not at 

all pleasant as people with their ATV’s and other motorized toys dominate the space with the noise

and dust. This is not compatible with a nature experience. Let the motorized toys use the many, 

many existing roads and already compromised areas! As I understand it, it is your job to protect the 

natural values. We have little enough of this kind of land left. Please don’t give away anymore!

12 2 This is a terrible idea. I have been nearly run off the road and hit by off road vehicles, and they just 

destroy everything in their path and the quietude of the forest for the habitat and for the people visiting.

Response: The roads and routes being considered in this analysis are open and drivable. All action 

alternatives will reduce roads/routes miles across the NRA by between 21 and 47 percent.

This project includes the restoration of unauthorized routes. The intent of this project is in part to 

manage motorized recreation on the Smith River NRA to prevent resource damage. The action 

alternatives reinforce the existing prohibition of motorized cross-country travel and restrict motorized 

travel to designated routes. They are designed to protect and improve water quality, riparian and botanical 

areas, while simultaneously providing access to dispersed and motorized recreation opportunities as 

specified in the Purpose and Need for the project. Implementation of the Travel Management process will 

provide a framework for improved enforcement, engineering, and public education intended to deter and 

reduce violations. This includes issuance of an MVUM, which will identify NFTS roads and trails open to 

motorized use and give law enforcement the necessary documentation with which to enforce the proper 

use of these routes; signing of NFTS roads and motorized trails; and barricading UARs not added to the 

NFTS. ML 1 roads not open for motorized use will remain legal for equestrian and other non-motorized 

travel. Unauthorized routes not designated on the NFTS will be available for non-motorized recreation.

Under the Smith River NRA Act of 1990 (16 USC 460bbb et seq.), travel was restricted to designated 

routes; off-road and off-trail use was prohibited. The acres available under each Alternative for quiet 

recreation activities within the project area are shown in the Recreation Section of Chapter 3 of the EIS, 

and will be considered by the Responsible Official in the decision making process. Non-motorized trails 
Appendix G. Response to Comments

210 – Smith River National Recreation Area Restoration and Motorized Travel Management

are not part of the scope of this project and will continue to be open and available for non-motorized 

recreation opportunities.

It is possible that there can be some conflict from competing uses within the vicinity of designated 

roads and motorized trails, where motorized recreationist and quiet recreationists may be in close 

proximity. However, both the legal framework of the MVUM that implements this decision and the 

terrain common across the landscape of the NRA will help contain motorized recreation to legally 

authorized routes. Quiet recreation activities have no such limitations and can occur near or away from 

motorized routes, with or without a non-motorized trail; this assumption has been articulated in the 

Recreation section in Chapter 3 of the FEIS. No OHV parks or play areas are proposed in this project.

Impacts to Resources

Cultural Resources

Letter 

Number

Comment 

Number Comment Text

819 119

Heritage Resources Implementation of Alternative 6 threatens violation of the National Historic 

Preservation Act while page 345 of the DEIS indicates that Alternative 5 would put the fewest 

cultural sites at risk and have the least effect on cultural resources.

Response: The Smith River NRA Restoration and Motorized Travel Management project was designed 

to ensure compliance with federal historic preservation laws, including the National Historic Preservation 

Act (NHPA). Cultural resources were considered in all aspects of the project. A route-by-route 

assessment was completed to determine effects to cultural resources. The §106 of the NHPA clearance 

report for this project concluded that there will be no adverse effect to cultural sites related to any of the 

alternatives with the application of standard resource protection measures. The eight sites considered at 

risk in Alternative 6 will be protected utilizing a combination of standard protection measures (i.e. 

barriers) and monitoring.

Natural Resources

Letter 

Number

Comment 

Number Comment Text

821 2

I was a survey tech for the Gasquet ranger District in the 1970’s. I saw on the ground just how 

temporary many of the logging roads would be. Later, working for the CA Conservation Corps I 

became involved putting roads to bed, salvaging slide areas with plantings and restoring stream fish 

habitat. There were a lot of ruts everywhere and road barriers were typically removed with trucks 

and their winches. Motorcycles have virtually no limits in their ability to try every hill and ravine.

Locally there are many people who want only to go where no one has gone, tear up Off road sites 

and even ford streams with their mudboggers, equipped with air intake snorkels. If it were just 

elders who couldn’t walk the trails, I would feel better.

819 102

Since the DEIS proposes a road and motorized trail system that is not likely to be maintained to 

standard, we must ask what the consequences for the environment and for human/forest user 

safety are likely to result from this project.
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 211

Letter 

Number

Comment 

Number Comment Text

806 5

What is off road vehicle use? For the most part, it is the adult equivalent of riding go-carts. It is 

overgrown children using expensive toys. It is a measure of this culture’s stupidity and hatred of 

nature that even with biodiversity crashing the way it is, we still have to defend closing roads to off 

road vehicle use. To be clear, we are not talking about food, clothing, shelter, or any other necessity 

of life. We are talking about overgrown children using expensive toys. The ecological health of the 

bioregion is more important than the ability of some people to play, and when there is a choice, a 

sane culture would each and every time choose the health of the bioregion over destructive leisuretime activities.

806 13

Now here is my point. Instead of saying, “I was able to drive my go-cart wherever I wanted when I 

was 19, and now that I am 50 I still want to be able to drive it wherever I want, consequences to the 

land be damned,” members of a sane culture would be attending to the health of the land. Members 

of a sane culture would be saying, “I used to see dragonflies all through the air. Now I do not see so 

many. We must do whatever we can to protect the land, for the sake of the land, for the sake of the 

nonhuman inhabitants, and so that my children and their children and their children will be able to see 

the dragonflies and newts and songbirds and bats and salmon, as I did when I was a child.” In any 

conflict between the health of the land and playtime, the health of the land must always come first.

829 4

I feel that the option of user-created routes is an open ticket to erosion, slope failure, siltation and 

destruction, as the average recreational ORV user does not have the education or experience that 

is necessary to properly plan and install roads in sensitive habitat.

806 4

The stressors on the bioregion will continue to rise, and will rise exponentially with global warming.

Just as a patient in critical care in the hospital must not have additional and completely unnecessary 

and frivolous stresses added to his or her life, we need to not add additional and completely 

unnecessary and frivolous stresses to the health of the bioregion. And off road vehicle use is as close 

as one can get to a completely unnecessary and frivolous stress to the health of any bioregion.

197 1

I’ve rafted down the Smith River and explored many of the remote canyons and ridges of the area. 

Over the last 15 years, I have seen massive damage done to the wild places by off road vehicles. 

This must be stopped! Do not allow ORV into any more areas and block off areas so that they may 

be rehabilitated.

829 10 To allow off road vehicles to travel anywhere they desire is a recipe for disaster.

Response: All action alternatives will reduce roads/routes miles across the NRA by between 21 and 47 

percent. Routes will only be added to the system provided resource risks can be mitigated. All action 

alternatives would result in resource protection benefits including: 1) less than 0.1 percent of the serpentine 

sensitive plant habitats on the NRA are being affected; 2) all routes into the North Fork Botanical Area are 

being closed, protecting over 20,000 acres of potential habitat; 3) routes to be kept will be upgraded to 

correct drainage problems, and 4) POC protection measures are common to all action alternatives.

The potential for cumulative effects to global warming due to off-road vehicle use is considered 

negligible for all alternatives because none of the alternatives would result in a measurable change in the 

level of use, but rather redirect the pattern of use.

The 1990 NRA Act limits motorized travel to designated routes. Off-road use is illegal. Any areas 

where such use is occurring will have further mitigations imposed. The potential for cumulative effects is 

considered negligible for all alternatives because none of the alternatives would result in a measurable 

change in the level of use, but rather redirect the pattern of use.

The Smith River NRA Roads Analysis was developed in part to identify risks associated with NFTS 

roads and UARs. Watershed related risks such as erosion, slope failure, and associated impacts are 

identified and mitigations to stabilize UARs that pose a risk to watershed resources proposed for 

designation on the NFTS are included in the alternatives. Signing of designated motorized trails and 

barricading of UARs not proposed for designation is also included in Alternatives 5 and 6, which will 

reduce the likelihood of unintended illegal motorized travel off the NFTS by clearly defined NFTS where 
Appendix G. Response to Comments

212 – Smith River National Recreation Area Restoration and Motorized Travel Management

motorized travel is allowed. Only existing UARs are proposed to be designated on the NFTS. The project 

does not provide for any NEW motorized trail construction. Unauthorized routes refers to motorized trails 

that are pre-existing and not constructed by the Forest Service.

Letter 

Number

Comment 

Number Comment Text

819 134

Leaving open or designating numerous user created routes in the project area – as either system 

roads or ORV trails – will exacerbate increasing ORV impacts which must be disclosed and 

analyzed in NEPA documents, especially as ORVs become more powerful, sophisticated and there 

is a proliferation of “extreme” off-roading including rock “crawling” (often over Forest Service 

barriers) and “creeking” in streambeds. Stronger measures are needed to protect the nationally 

outstanding hydrological, botanical and ecological values, found within the project area.

Response: The majority of UARs on the NRA are not user created routes. Many are old mining roads 

and some logging roads on previously private land that was later acquired by the Forest Service. 

Mitigations have been proposed to minimize resource impacts while providing access. The Forest Service 

would close between 2 to 4 times the miles of UARs that would be added. Adding the UARs that are 

needed for access would be consistent with Forest Service Rules and Regulations.

The 1990 NRA Act limits motorized travel to designated routes. All alternatives would restrict 

vehicles to designated routes. Off-road use is illegal. Any areas where such use is occurring will have 

further mitigations imposed.

Alternatives 5 and 6 include barricading all UARs that are not designated on the NFTS to deter illegal 

motorized travel and the impacts associated with it.

Impacts of Off-Road Travel on Gasquet Mountain or Gordon Mountain

Letter 

Number

Comment 

Number Comment Text

823 2

I disagree with the placement of motorized trails in Alternative 5 or any of the other alternatives. The 

motorized trails on Gasquet Mountain and Gordon Mountain are too close to areas of gentle terrain 

and open, grassy areas, tempting off-highway vehicle (OHV) riders to stray off designated routes. 

All it takes is one trip through a wet meadow with an OHV to cause long-lasting damage and there 

is always someone who is going to do that no matter how many signs are put up.

Response: Alternative 5 most closely addresses the concerns of this commenter, while not fully 

eliminating all motorized trails from Gasquet Mountain and Gordon Mountain, Alternative 5 only 

proposes 0.5 miles of motorized trails on Gordon Mountain, and 2.3 miles of motorized trail on Gasquet 

Mountain. All proposed trails include route delineation to reduce the risk of travel off the trail.
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 213

Aquatic and Terrestrial Species

Letter 

Number

Comment 

Number Comment Text

819 108

Please Acknowledge and Disclose All the Impacts of Road Use KS Wild’s scoping comments of 

August 1, 2006 contained a peer-reviewed article by Trombulack and Frissell detailing some of the 

negative impacts of road density and use on terrestrial and aquatic ecosystems. In those scoping 

comments, we requested that the agency consider options to mitigate or reduce many of the 

negative effects of roads detailed in the study. The abstract for the article reads as follows: Roads 

are a widespread and increasing feature of most landscapes. We reviewed the scientific literature 

on the ecological effects of roads and found support for the general conclusion that they are 

associated with negative effects on biotic integrity in both terrestrial and aquatic ecosystems. Roads 

of all kinds have seven general effects: mortality from road construction, mortality from collision with 

vehicles, modification of animal behavior, alteration of the physical environment, alternative of the 

chemical environment, spread of exotics, and increased use of areas by humans. Road construction 

kills sessile and slow-moving organisms, injures organisms adjacent to a road, and alters physical 

conditions beneath a road. Vehicle collisions affect the demography of many species, both 

vertebrates and invertebrates; mitigation measures to reduce roadkill have been only partly 

successful. Roads alter animal behavior by causing changes in home ranges, movement, 

reproductive success, escape response, and physiological state. Roads change soil density, 

temperature, soil water content, light levels, dust, surface waters, patterns of runoff, and 

sedimentation, as well as adding heavy metals (especially lead), salts, organic molecules, ozone, 

and nutrients to roadside environments. Roads promote the dispersal of exotic species by altering 

habitats, stressing native species, and providing movement corridors. Roads also promote 

increased hunting, fishing, passive harassment of animals, and landscape modifications. Not all 

species and ecosystems are equally affected by roads, but overall the presence of roads is highly 

correlated with changes in species composition, population sizes, and hydrologic and geomorphic 

processes that shape aquatic and riparian systems. More experimental research is needed to 

complement post-hoc correlative studies. Our review underscores the importance to conservation of 

avoiding construction of new roads in roadless or sparsely roaded areas and of removal or 

restoration of existing roads to benefit both terrestrial and aquatic biota. –Trombulack, S.C. and C.A. 

Frissell. 2000. Review of ecological effects of roads on terrestrial and aquatic communities. 

Conservation Biology 14(1): 18-30. Unfortunately, the DEIS largely ignores many of the negative 

impacts of motorized road use. The impacts of road use (as opposed to road construction) 

delineated in the Trombulack paper are not fully disclosed and analyzed in the DEIS.

Response: The negative impacts of motorized road use on wildlife species was fully disclosed in the 

EIS, including the potential impact of road use as delineated in the Trobulak and Frissel (2000) paper. All 

action alternatives will reduce road densities of ML 1, 2 roads and unauthorized routes across the NRA. 

Reducing road density across the district will reduce fragmentation of habitat as the decommissioned 

roads revegetate, increase patch size, reduce sedimentation in stream channels, and reduce disturbance 

and direct mortality. In addition, cross-country travel is prohibited under the Smith River NRA Act of 

1990. An overall reduction of road densities across the NRA will benefit wildlife in the short-term 

through elimination of noise disturbance on closed roads/routes and in the long-term through the 

reduction of fragmentation and habitat restoration.

NWFP and ESA Compliance with Coho

Letter 

Number

Comment 

Number Comment Text

819 115

The Forest Service’s current (DEIS) proposal to add non-system routes to the permanent road 

system in at-risk Key watersheds that serve as Essential and Critical fish habitat for Coho and as 

EFH for Chinook runs afoul of both the Endangered Species Act (ESA) and the Aquatic 

Conservation Strategy (ACS) of the Northwest Forest Plan.

Response: The proposed actions were designed to meet the objectives of, and fully comply with ESA, 

ACS and the Forest Plan and will not adversely affect listed species. All of the action alternatives would 

implement the ACS and decrease in road miles on the NFTS within the Smith River Key Watershed. In 
Appendix G. Response to Comments

214 – Smith River National Recreation Area Restoration and Motorized Travel Management

addition, the proposed actions under the FEIS were reviewed by the Forest Service and National Marine 

Fisheries Service and the actions were found to be consistent with the Watershed and Fisheries Restoration 

Program biological assessment (WFR BA; 2015) and corresponding biological opinion from NMFS.

Smith River NRA Act and Improving Fishery

Letter 

Number

Comment 

Number Comment Text

825 3

The Act also directs the Secretary to improve/restore the anadromous fishery and water quality, 

including (but not limited to) improving fish spawning and rearing habitat, and placing appropriate 

restrictions or limitations on soil disturbing activities.

Response: All action alternatives will reduce roads/routes miles across the NRA by between 21 and 47 

percent, including roads with pose risks to water quality and fish habitat. The project will implement the 

ACS as it was designed to improve and restore aquatic resources. The project implements recovery action 

under the Final Recovery Plan for the Southern Oregon/Northern California Coastal population of coho 

salmon, including reducing road-stream hydrologic connectivity, decommissioning roads and upgrading 

roads within the Smith River watershed.

Assumptions and Determination on Listed and Candidate Species

Letter 

Number

Comment 

Number Comment Text

819 107

Foreseeable Impacts to Listed and Candidate Fish Species The National Marine Fisheries Service 

(NMFS) initially found that the Project was “likely to adversely impact listed species” (DN at P.12). 

That document must be included as part of the project Administrative Record. However, the FS was 

subsequently able to convince NMFS to alter that finding. The previous Decision provided two posthoc justifications supporting the altered NMFS finding: “Distance to Critical and essential Fish 

Habitat” and “the reduction of sediment overall from current levels” (DN at P.12). Careful review of 

that analysis, however, indicates that the conclusion that sediment will be reduced overall is based 

on unsupported assumptions, i.e. 1) that the road system adopted by the agency would be

maintained to standard; and 2) that the funding necessary to complete “improvements” would be 

forthcoming. But as noted above, the RAP itself admits that maintenance is currently funded at 10% 

of need and that more funding for maintenance is not expected. When information from the RAP 

and proposed action are integrated it becomes clear that what the Forest Service is essentially 

saying in these documents is that the agency currently has the funds to maintain 35.5 miles of OLM 

1, OLM 2 roads and motorized trails, and that this funding level is not likely to change substantially 

anytime soon. We believe that if NMFS had been informed of these facts – and if they had been

supplied Forest Service and other research on road related sediment impacts, NMFS would have 

held fast to the initial, correct, Likely to Adversely Impact finding. 1 See, for example, “Channel 

Suspended Sediment and Fisheries: A Synthesis for Quantitative Analysis of Risk and Impact, NA 

Journal of Fisheries Management, Vol.16, No.4, Nov. 1996. 25 The Not Likely to Adversely Affect 

(NLAA) finding is based on inaccurate Forest Service assumptions and contentions concerning the 

management situation with respect to maintenance needs and sediment delivery impacts which are 

likely to result from failure to adequately maintain roads and motorized trails.

Response: In 2007, consultation with the National Marine Fisheries Service determined that the project 

was not likely to adversely affect listed fish or Critical Habitat, and in fact is considered to be beneficial.

The conservative preliminary finding of likely to adversely affect was not initially made by NMFS, rather 

it was made by the USFS fisheries biologist for the project prior to consultation with the National Marine 

Fisheries Service. The NMFS does not make ESA Section 7 determinations, rather NMFS renders either 

concurrence (informal consultation) or and opinion (formal consultation) on the determination of the 

USFS biologist.
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 215

As part of the ESA §7 Streamlining Consultation (i.e. Level 1) process, a Level 1 project field review 

that included NMFS and USFS biologists was held to visit sites where proposed road decommissioning and 

maintenance would occur within proximity to SONCC coho salmon Critical Habitat. This field review with 

NMFS allowed the USFS fisheries biologist to develop the final determination of not likely to adversely 

affect, and allowed NMFS to concur on that determination with site-specific knowledge of the project.

Since 2007, the forest completed a program level consultation on watershed and fisheries restoration 

actions that meet SONCC recovery plan objectives. This program level consultation considered 

previously consulted on actions, such as the 2007 consultation for the original proposed action in order to 

incorporate more recent status reviews, science and the 2014 SONCC recovery plan. The proposed 

actions under the FEIS were found to be not only consistent with this Watershed and Fisheries 

Restoration Program biological assessment (WFR BA; 2015) and corresponding biological opinion 

(NMFS 2015), but also implemented components of the 2014 SONCC recovery plan.

Wildlife

Letter 

Number

Comment 

Number Comment Text

819 109

Previously in this planning process the Six Rivers National Forest contended (without citation or 

analysis) that “[t]he effects to suitable and Critical habitat [from roads and routes] have already 

occurred.” (EA Appendix C page 40.) This statement completely ignores significant research that 

attributes motorized impacts to wildlife, including but not limited to, direct harassment, noise 

disturbance, dust production and increased erosion that are known to result from road and route 

use through critical and suitable habitat. On August 12, 2002 our organizations provided a copy of 

the Hayward et al. paper (mentioned on page 131 of the DEIS) to the Forest Supervisor and the 

District Ranger. We pointed out that the paper concluded that “routine traffic exposure may 

decrease NSO reproductive success over time” and asked that the Forest Service analyze and 

codify the impacts of user created routes proposed for addition to the NFTS in Late Successional

Reserves and NSO critical habitat. The agency elected not to provide such analysis or codification 

and continues to largely ignore the peer reviewed findings of the Hayward paper by contending that 

owls are “habituated” to ORV noise from rarely used UARs and that the “noise associated with 

motorized use of these routes is considered ambient.” (DEIS page 131).

Response: Critical Habitat is designated by USFWS and is a specific, mapped area, not a habitat 

description. Within Critical Habitat, the USFWS identifies the primary constituent elements (PCE) which 

are specific elements that provide for a species life-history processes and are essential to the conservation 

of the species. For the NSO, the PCEs are the specific characteristics that make areas suitable for nesting, 

roosting, foraging, and dispersal habitat. All PCEs for NSO CH must occur in conjunction with PCE1, 

Forested types in early-, mid-, or late-seral stages and that support the northern spotted owl (emphasis 

added). Primary constituent elements of marbled murrelet Critical Habitat units include: 1) individual 

trees with potential nesting platforms, and 2) forested areas within 0.5 miles of individual trees with 

potential nesting platforms, and with a canopy height of at least one-half the site-potential tree height.

Impacts to Critical Habitat are evaluated based on direct impacts to PCEs, not to the species. Impacts to 

the species are analyzed separately. As stated in the DEIS, no new road construction or reconstruction 

will occur under any alternative. Therefore, no additional northern spotted owl or marbled murrelet 

Critical Habitat will be removed through road construction and no suitable habitat will be removed for 

any listed species. The DEIS goes on to explain that road decommissioning may impact NSO Critical 

Habitat PCE4 (dispersal habitat) at culvert removal sites. One-tenth acre of brush and small diameter trees 
Appendix G. Response to Comments

216 – Smith River National Recreation Area Restoration and Motorized Travel Management

will be removed in any one area. Impacts to northern spotted owl Critical Habitat units will be negligible. 

The project will result in a reduction of fragmentation and long-term improvement of primary constituent 

elements in the Critical Habitat units. Current habitat function in all Critical Habitat Units will be 

maintained in all treatment areas.

As stated in the DEIS, not all decommissioned roads occur in Critical Habitat Units; therefore, 

potential acres affected over estimates the potential effects to NSO CHU. The USFWS concurred that 

there would be no adverse effects to NSO CHU and no effect to MAMU CHU.

The negative impacts of roads are described in detail in the DEIS, which discusses the negative

impacts of roads on animal behavior from fragmentation, noise disturbance, and dispersal of exotic 

species. Findings of Hayward et al. (2011) are specifically referenced in the DEIS.

Management Indicator Species

Letter 

Number

Comment 

Number Comment Text

819 110

Management Indicator Species (MIS) and Survey and Manage Species “Most native terrestrial 

species located on the forest are adversely affected by road associated factors that can degrade 

habitat or increase mortality.” –DEIS page 118. In our May 2012 scoping comments we urged the 

Forest Service to address the 9th Circuit opinion in Native Ecosystem Council v. Tidwell, 599 F 3d. 

926 (9th Cir 2010) in which that court held that the agency’s “proxy on proxy” MIS approach does 

not provide an assurance of species viability when: 1) population trend monitoring as per 1982 

NFMA regulation hasn’t been performed, and 2) MIS surveys in the project area fail to located key 

MIS species. We can find no acknowledgement of this case law in the DEIS or in the agency’s 

treatment of MIS species. We pointed out that the forthcoming NEPA documents must analyze and 

disclose the potential impacts of the project on Management Indicator Species (MIS) as defined by

the Six Rivers LRMP. At a minimum, the Forest Service must address the effects of proposed 

motorized use on MIS “individual species” such as the NSO, pileated woodpecker, black bear, 

American Marten, Fisher and Black-tailed deer as well as the Snag Assemblage, the Down Woody 

Material Assemblage and the Black Oak/White Oak Assemblage. See the LRMP page 97. The 

Forest Service elected not to disclose, analyze, monitor or codify impacts to any of these species 

and instead rests on the contention that “the Six Rivers Forest Plan does not require population 

monitoring or surveys at the project level.” Instead of addressing the effects of increasing the size of 

the NFTS by adding high risk UARs to the maintenance backlog, the analysis contained in the DEIS 

consists primarily of acknowledging the lack of information about sensitive and indicator species 

while reaffirming a disinterest in gathering information or data that would allow for meaningful

analysis of project impacts on such species. “There is little information available on wildlife species 

diversity, abundance and distribution in the Smith River Watershed.” DEIS page 116. “Determining 

the actual amount of preferred habitat for each species assemblage would require more detailed 

habitat data than the models and current databases provide. Updating and refining the habitat 

suitability models (including field research to determine species habitat requirements) and tailoring 

vegetative data collection is required. No estimates of population size, distribution or diversity were 

made based on the estimates of potential habitat from these model runs.” DEIS page 116. The role 

of management indicator species in National Forest planning is described in the 1982 implementing 

regulations for the National Forest Management Act (NFMA) of 1976: “In order to estimate the 

effects of each [Forest Plan] alternative on fish and wildlife populations, certain vertebrate and/or 

invertebrate species present in the area shall be identified and selected as management indicator 

species and the reasons for their selection will be stated. These species shall be selected because 

their population changes are believed to indicate the effects of management activities. In the 

selection of management indicator species, the following categories shall be represented where 

appropriate: Endangered and Threatened plant and animal species identified on State and Federal 

lists for the planning area; species with special habitat needs that may be influenced significantly by 

planned management programs; species commonly hunted, fished or trapped; non-game species of 

special interest; and additional plant or animal species selected because their population changes 

are believed to indicate the effects of management activities on other species of selected major 

biological communities or on water quality. [36 CFR 219.19 (a)(1)].” (emphasis added) Here the 

Forest Service has refused to provide information describing population numbers, locations, and 

trends for key wildlife species, and monitoring data to determine that the proposed action would 

maintain numbers and distribution of these species sufficient to ensure long-term viability. The Six 

Rivers LRMP (IV 96) indicates that MIS species “serve as the primary measure of the biological 

diversity trend on the Forest.” Given this purpose of the MIS designations and the acknowledgment 

that some “MIS were selected based on concern for their current population status,” it is very 
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 217

Letter 

Number

Comment 

Number Comment Text

difficult to understand how MIS could fulfill their management function if the Forest Service refuses 

to collect information about population size, distribution, and trend and analyze and disclose that 

information in site specific NEPA analysis for this project. To assert that “[c]ollecting population data 

is not a requirement” for imperiled species and MIS is, essentially, to say that the agency can legally 

manage the habitat on public lands on the basis of projections of what might, or ought, to be 

happening with respect to wildlife populations, without regard to what the facts might actually be. 

This cannot be correct. If the purpose of designating MIS is to use their population changes to 

assess the “effects of management activities,” then the Forest Service must actually attend to those 

population changes, which cannot be done without “collecting population data.” Therefore, 

assessing population levels, distribution, and trends is in fact critical to assessing not only the 

effects of management actions, but also to evaluating the accuracy of the habitat capability models 

which the agency uses to estimate the relationship between habitat and population levels for 

imperiled and MIS species.

Response: As stated in the DEIS, “Under the Six Rivers Forest Plan, project level analysis of effects to 

management indicator species involves an analysis of the effects (direct, indirect, and cumulative) to 

habitat. The Six Rivers Forest Plan does not require population monitoring or surveys at the project level. 

Project level impacts to habitat are then related to broader scale (generally Forest, and in some cases, 

bioregional) population and/or habitat trends.” No construction or reconstruction will occur under this 

project; therefore, no changes in the distribution or abundance of habitat available to MIS are anticipated. 

All action alternatives will reduce road densities of ML 1 and 2 roads, and unauthorized routes across the 

NRA. Reducing road density across the district will reduce fragmentation of habitat as the 

decommissioned roads revegetate, increase patch size, reduce sedimentation in stream channels, and 

reduce disturbance and direct mortality. In addition, cross-country travel is prohibited under the Smith 

River NRA Act of 1990. An overall reduction of road densities across the NRA will benefit MIS in the 

long-term through the reduction of fragmentation and habitat restoration. The project will benefit MIS. 

The Smith River RMTM project was determined to have minimal habitat effects (between 8 to 25 acres, 

depending on the alternative, across the district at culvert removal sites) with long-term benefits of 

reducing fragmentation and road density across the district. The project complies with the Six Rivers 

LRMP in regards to the analysis of effects to MIS.

Botany

Science, Date and Determinations

Letter 

Number

Comment 

Number Comment Text

819 61

Our requests for detailed, accurate, site specific analysis of the threats to the world-class botanical 

resources in the NRA from codified and mapped motorized trails was not reflected in the DEIS 

analysis which concludes that “because data was not collected at the occurrence level a rigorous 

qualitative analysis and ranking of the scope and severity to specific occurrences [of rare plants] 

cannot be performed.” (DEIS page 155). This failure to collect (or analyze) data renders the 

agency’s conclusions suspect. Page 294 of the DEIS acknowledges that a “primary goal” of the 

Smith River NRA legislation was to “emphasize, protect and enhance” the area’s “unique biological 

diversity.” Table 76 on page 198 of the DEIS concludes that implementation of Alternative 5 would 

best protect rare plant species as required by this “primary goal” of Congress. Yet the Forest 

Service appears to “prefer” implementation of Alternative 6 in order to better maximize the 

recreational preferences of 1.1% of Six Rivers National Forest visitors. (See DEIS page 371)

Response: The lack of occurrence data noted in the DEIS should not be interpreted as indicating that 

the analysis of effects to Sensitive plant species was not rigorous. The comment indicates a 
Appendix G. Response to Comments

218 – Smith River National Recreation Area Restoration and Motorized Travel Management

misunderstanding of the point made that occurrence data was incomplete and a more meaningful 

comparison of effects between alternatives was based on actual numbers of plants or ramets of Sensitive 

plants found within 30 feet of unauthorized routes proposed for addition to the NFTS.

Rare plant survey data collected thus far on routes proposed to be added to the National Forest 

Transportation System indicate that these species are persisting in the presence of the current low level of 

use. This survey data indicates that they are more abundant on and immediately adjacent to (within 30 

feet) the inventoried unauthorized routes (UARs). The project proposes to monitor use to prevent a loss of 

viability by establishing management response thresholds that, when triggered, would implement line 

officer action to prevent addition loss to Sensitive plant species. This would include such actions as 

barricading the affected occurrence, buffering the occurrence with boulders, or having use restricted or 

prohibited by order of the forest supervisor.

Sensitive Plant Species

Letter 

Number

Comment 

Number Comment Text

819 87

The Six Rivers National Forest (SRNF) Land and Resource Management Plan (LRMP) requires 

demographic monitoring on an annual basis using permanent quadrants for species most at risk in 

order to gather baseline information (LRMP H-2). For Sensitive Plants, the management guidelines 

in place since 1995 also include development of “Species/Habitat Management Guides” (LRMP IV83). In spite of this requirement, no botanical investigations or species management guides have 

been prepared for the 10 species in the project area that have the potential to be affected by the 

proposed action. It is difficult to understand how the agency can conclude that the impacts of the 

proposed action will not contribute to a trend towards federal listing for these plants without having 

conducted any investigations into the species existence and welfare in the planning area. Without 

substantive monitoring and biological investigations, the Forest Service is simply guessing.

819 89

The Forest Service cannot go forward with potential negative impacts to these species “until such time 

as the significance of the involved populations as related to total distribution and endangerment can be 

assessed” (see FSM 2672.4 and FSH 1.21(a) (6). Further, FSM 2670.32 (4) requires the agency to 

“...analyze the significance of adverse effects on the population or its habitat within the planning area of 

concern and on the species as a whole” and “It is essential to establish population viability objectives 

when making decisions that would reduce sensitive species numbers” (FSM 2672.1).

819 55

The previous unsupported and undocumented contention on page 45 of the initial EA that motorized 

use of “non-system routes may affect individuals growing on travel surfaces but will not cause a 

trend towards listing” was speculative and arbitrary. The contention that permanently designating 

non-system routes in sensitive plant habitat will not trend plants towards ESA listing was directly 

contradicted by the acknowledgment that: The direct negative effects to Sensitive species as a 

result of the proposed action include crushing, uprooting, or otherwise damaging individual plants 

and recruits. Indirect negative effects pertain to 1) altering habitat beyond its capacity to support 

Sensitive species which includes soil compaction, reduction of water vapor transport, increases in 

surface temperature, reduction in soil moisture content, and the mobilization and spread of dust 

which blocks photosynthesis (Trombulak 2000), 2) loss of habitat niches for recruitment, 3) potential

reduction in occurrence size which has implications for the vigor of the occurrence over time, 11 and 

4) potential for illegal motorized vehicle use off the road surface affecting Sensitive plant

occurrences. – Initial Smith River NRA Road Management and Route Designation EA pages 43-44.

The direct negative effects to Sensitive Species from adding UARs as motorized trails that may 

result in a trend toward listing are also acknowledged on page 178 of the DEIS as: Reductions in 

photosynthetic capacity, poor reproduction, mortality, increases in bare ground, diminished litter 

cover, and a reduction in the overall cover and frequency of plant species. These effects are of 

particular concern with rare plant species, which are typically represented by a limited number of 

populations and or individuals due to their potential to affect the long-term viability of rare plant 

populations by increasing mortality and decreasing the vigor and productivity of populations.

819 59

The California Native Plant Society writes of the 17N49 road system in their previous scoping 

comments: “These areas provide habitat for one of the rarest of Forest Service sensitive plant 

species (STHO) as well as SISE. How serpentine habitat will be barricaded is hard to conceive as 

nearly all if not all of the STHO and SISE in this area exist on these roads or directly roadside.”
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 219

Letter 

Number

Comment 

Number Comment Text

819 82

The Proposed Botanical Resources Monitoring Plan Does Not Qualify as a Monitoring and 

Species/Habitat Management Guide Ten Forest Service Sensitive CNPS-listed plants are known to 

occur in the project area (Sensitive Plant Biological Evaluation, December 8, 2006). According to 

the initial Sensitive Plant Biological Evaluation (BE) the project may affect individuals but is not likely 

to result in a trend toward Federal listing or loss of viability for Eriogonum pendulum, Gentiana 

setigera, Lewisia oppositifolia, Silene serpentinicola, Streptanthus howellii, or Viola primulifolia ssp. 

occidentalis. The determination of “may affect individuals but will not cause trend toward listing” was

based on an incomplete analysis, incomplete information, and anecdotal supposition. As stated on 

page 155 of the DEIS “because data was not collected at the occurrence level a rigorous qualitative 

analysis and ranking of the scope and severity of threats to specific occurrences cannot be 

performed.” NEPA does not allow an agency to rely on the conclusions and opinions of its staff, 

without providing both supporting analysis and data. Idaho Sporting Congress v. Thomas, 137 F.3d 

at 1150. The Six Rivers National Forest (SRNF) must conduct population trend monitoring, 

population viability analyses, or science-based research on the reasons for rarity of these species, 

all of which are necessary to make a determination on the significance of potential impacts.

819 58

Page 152 of the DEIS acknowledges that: “There is a potential for both vehicular and pedestrian 

cross-country travel in areas with relatively flat topography and open vegetation. Such travel could 

impact unique botanical features within these areas such as rare species in Jeffrey pine woodlands 

and rocky barrens.” Unfortunately the DEIS largely fails to analyze or disclose the potential for 

increased off-route and off-road ORV abuse of serpentine sites due to the addition of non-system 

roads to the system and instead assumes that such sites will not be subject to increasing motorized 

damage over time due to the decision to codify NFTS travel ways adjacent to and through them.

The Smith River NRA’s NEPA analysis should not pretend that increased illegal off-route and offroad use in serpentine areas will not occur as a result of adding routes to the mapped system.

819 86

According to the initial Sensitive Plant Biological Evaluation (BE), Strepthanthus howellii and Silene 

serpentinicola do exhibit a tolerance to disturbance by virtue of their presence in disturbed settings, 

including roadbeds, but there is a threshold beyond which plants are negatively affected. This is 

evidenced by the relatively fewer number of plants found on the segment of non-system roads 

proximal to a system road compared to distal road segments, which presumably receive less 

disturbance... While Streptanthus howellii and Silene serpentinicola do occur on some route 

segments experiencing use, it is not possible to state emphatically that the current level of use is not 

affecting plants. Nor is it possible to state with any certainty that closing these routes will either 

benefit the species by removing traffic or negatively affect the species by shrub encroachment. It is 

conceivable that designating routes with Streptanthus howellii and Silene serpentinicola occurring 

on travel surfaces would have both negative and beneficial effects to these species and that the 

beneficial effects would serve to moderate the negative effects. The previous Sensitive Plant 

Biological Evaluation (BE) acknowledges, It is important to emphasize that surveys associated with 

this project were not conducted at the occurrence level. If surveys had been performed at the 

occurrence level, extending beyond proposed routes, the ratio of plants on routes to plants off 

routes would likely have been lower. Casual observations made on Pine Flat Mountain indicate a 

number of plants exist outside the surveyed area. There are undoubtedly more plants on High 

Plateau than is currently known. Consequently, the numbers of plants provided in the following 

tables do not present a complete picture of the population size of the occurrences, but rather what is 

known based on limited surveys. [page 11] This statement indicates that the impacts analysis 

contained in the prior NEPA document was based in large part on speculation rather than factual 

information. To suppose that “a number of plants exist outside the surveyed area” without any 

definition of “number” – not to mention the lack of demographic data such as trend monitoring-is 

unacceptable as a basis for assessing the potential impacts of the proposed action. The Forest 

Service is required to conduct a botanical investigation and prepare “Species Management Guides”

for sensitive species in order to accurately analyze the status and the significance of sensitive 

species populations. Development of these guides shall be prioritized based on threats due to 

Forest Service management activities, and also if the species known range occurs almost entirely 

within National Forest System lands. Therefore botanical investigations in compliance with Forest 

Service Manual 2670.22 and 2672.4 are required for these species before impacts of the proposed 

action can be accurately assessed. The proposed Botanical Resources Monitoring Plan does not 

qualify as a Species Management Guide.

Response: There is one federally listed endangered and five Forest Service Sensitive plant species 

within the project area. The forest is not required to manage plants listed in the California Native Plant 

Society Inventory of Rare Plants if they are not federally listed or Forest Service Sensitive. Although rare 

plant surveys were not performed at the population level, surveys were performed within 100 feet of 
Appendix G. Response to Comments

220 – Smith River National Recreation Area Restoration and Motorized Travel Management

unauthorized routes (UARs) and impacts were analyzed based on the number of plants that would be 

affected by motorized use.

Implementation of this project is designed to provide for improved management of motorized 

recreation on the Smith River NRA by providing an NFTS that is signed and clearly distinguished from 

routes that are not open to motorized use. This is anticipated to decrease the potential for illegal motorized 

use and damage to sites and can reduce negative effects to native vegetation and Sensitive plant species. 

All UARs not added to the NFTS will be barricaded affording protection to the Sensitive plant 

occurrences growing within 30 feet. Seasonal closures and the restoration of hydrologic function will 

benefit Sensitive plant species, particularly those that occur in serpentine wetland habitat. Route 

delineation (barricading the edge of the travel way) will occur to prevent travel off designated UARs onto 

undesignated routes.

The determination in the biological evaluation is based on the premise that Sensitive plant species can 

be managed by monitoring impacts and establishing management response actions that would be 

implemented before a loss of viability (a 20% loss) is reached. This would include such actions as 

barricading the affected occurrence, buffering the occurrence with boulders, or having use restricted or 

prohibited by order of the forest supervisor.

Letter 

Number

Comment 

Number Comment Text

819 84

Strepthanthus howellii (Howell’s jewelflower, “STHO”) is confined to dry, brushy serpentine 

exposures in the Siskiyou Mountains of Josephine and Curry counties, Oregon and Del Norte 

County in California. The California Native Plant Society rates it as List 1B.2 – Rare, Threatened, or 

Endangered in California and elsewhere. It is a Forest Service Region 5 and Region 6 Sensitive 

Species and is included on the BLM Oregon State Office Sensitive Species List. According to the 

initial Sensitive Plant Biological Evaluation (BE),”[i]t is the rarest in terms of number of individuals of 

all Sensitive plants documented in this analysis and, hence, the most at risk” (page 11). The fact 

that this rare species is confined to serpentine exposures increases its susceptibility to damage 

from off-road vehicle use adjacent to designated ORV routes contained in the proposed action. All 

of the California occurrences of the species are located within the Smith River National Recreation 

Area. Of these, 387 plants or approximately 60% were found on the surface of routes proposed for 

designation in the proposed action.

Response: Implementation of the project is designed to provide for improved management of motorized 

recreation on the Smith River NRA. This increased potential to deter illegal use and damage to sites can 

reduce negative effects to Sensitive plant species such as Streptanthus howellii. Streptanthus howellii

plants that are present on inventoried UARs proposed for addition to the NFTS have a tolerance for the 

low level of use that has been occurring on those routes, most likely due to passive avoidance, 

subterranean meristem tissue, and multi-stem growth, enhanced seedbed conditions, and a reduction in 

competition from plant species that are less tolerant of the current level of use. Sensitive plant populations 

within 30 feet of UARs added to the NFTS will be managed by monitoring impacts and establishing 

management response actions that would be implemented before a loss of viability (a 20% loss) is 

reached. This would include such actions as barricading the affected occurrence, buffering the occurrence 

with boulders, or having use restricted or prohibited by order of the forest supervisor.
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 221

Letter 

Number

Comment 

Number Comment Text

819 85

Silene serpentinicola (serpentine catchfly, “SISE”) is a rare herbaceous perennial known only from 

Del Norte County, California. There are 11 known occurrences, all of which occur on the Smith 

River National Recreation Area. Sensitive plant surveys for the Smith River are RMRD project found 

Silene serpentinicola growing either on or adjacent to the travel surface of routes proposed for 

designation. Of these, 1806 plants or 54% were found near routes proposed for designation.

According to the Resource Specific Monitoring Program section of the LRMP, the threshold of 

concern for sensitive plants is to the 20% decline in the number of individuals over a five-year 

period (H-2). If 50 to 60% of all known individuals of these two sensitive species are found within the 

routes proposed for designation in the 19 proposed action, it would appear that the threshold of 

concern of a 20% decline is likely to occur as a result of the proposed action.

Response: The substantially higher number of Silene serpentinicola found within 30 feet of UARs 

compared to those found from 30 to 100 feet indicates that this species has a tolerance for the low level of 

use that has been occurring on these routes most likely due to passive avoidance, subterranean meristem 

tissue, and multi-stem growth, enhanced seedbed conditions, and a reduction in competition from plant 

species that are less tolerant of the current level of use. Sensitive plant populations within 30 feet of 

UARs added to the NFTS will be managed by monitoring impacts and establishing management response 

actions that would be implemented before a loss of viability (a 20% loss) is reached. This would include 

such actions as barricading the affected occurrence, buffering the occurrence with boulders, or having use 

restricted or prohibited by order of the forest supervisor.

Federally Listed Plants

Letter 

Number

Comment 

Number Comment Text

819 56

Please note that our May 2012 scoping comments included an attachment consisting of a March 11, 

2009 correspondence from Barbara Ullian to District Ranger Mary K. Vandiver documenting 

significant travel management issues concerning Arabis macdonaldiana that we indicated should be 

addressed in an EIS. Unfortunately, the DEIS failed to adequately address the site-specific 

information provided by the public during the scoping process for this project.

Response: Barbara Ullian’s comments to Mary Kay Vandiver center around her concern for impacts to 

Arabis macdonaldiana from illegal cross country travel and that use can occur beyond 100 feet of the 

routes being analyzed.

All alternatives would restrict vehicles to designated routes. Use beyond 100 feet is not proposed and 

therefore not part of this analysis. If use beyond what is analyzed herein is found to be affecting federally 

listed endangered or Sensitive plant occurrences it will be mitigated via such actions as barricading the 

affected occurrence, buffering the occurrence with boulders, or having use restricted or prohibited by 

order of the forest supervisor.
Appendix G. Response to Comments

222 – Smith River National Recreation Area Restoration and Motorized Travel Management

Noxious Weeds

Letter 

Number

Comment 

Number Comment Text

819 131

Noxious Weeds The DEIS acknowledges that the spread of noxious weeds is hindering the 

management objectives of the LRMP and that “noxious weeds are a serious environmental concern

[because] they threaten natural diversity, habitat for fish and wildlife and native plants, soil stability 

and ecosystem process.” (DEIS page 223). Hence, the intent of the LRMP, the Smith River NRA 

Act and the project purpose and need is best met by implementation of an action alternative that 

minimizes the impacts of noxious weeds. Alternative 5 best reduces the threat of noxious weeds on 

the natural resources the Smith River NRA is charged with protecting because “direct and indirect 

effects are lowest where the number of miles of open road is less.” (DEIS 235). Alyssum has been 

identified as a high priority by the Forest Service to prevent its spread from the Illinois River 

watershed. A potential exists for Alyssum to be spread by motorized users from Oregon via several 

routes that cross the state line into the Smith River watershed (18N14, 316, 19N01, 315). The 

SRNRA must coordinate with RRSNF, county and state governments to prevent the spread of 

Alyssum into the SRNRA. The SRNRA must consider a coordinated closure of roads to prevent the 

spread of Alyssum. The DEIS fails to analyze the dire consequences of the spread of Alyssum into 

the serpentine landscape of the SRNRA and likely significant adverse impacts to native plants.

819 132

The two Alyssum species were ranked as “A” listed noxious weeds because they have the potential 

to outcompete native flora on serpentine substrates with a moderate probability of introduction 

through human activities (Amsberry et al. 2008). In 2008, an Alyssum murale population was found at 

the base of the Lone Mt/Wimer Road in 2008 (Amsberry et al 2008:5) (Photo 1). Although the plants 

were removed “more escaped Alyssum may be going undetected due to lack of surveys and a lack of 

knowledge of other Alyssum plantings near public land.” 37 Photo 1. An Alyssum murale population 

found at the base of the Lone Mt./Wimer road (4402) near O’Brien, Oregon in 2008. This population 

consisted of 198 seedlings and 21 flowering plants-all were removed after documentation. The road 

is a primary access route onto the Josephine ophiolite shield (one of largest and most botanically 

unique masses of serpentine bedrock in North America. (Photo by K. French) In a letter dated 

December 29, 2009 The California Native Plant Society states: We [California Native Plant Society] 

are particularly concerned about the potential spread of these invasive species [Alyssum] to the 

sensitive serpentine areas of Del Norte County, which known for its botanical uniqueness. The Smith 

River National Recreation Area is particularly at risk due to the network of dirt roads coursing the 

Oregon-California border. These roads are regularly used by off-highway vehicle (OHV) drivers who 

access the Smith River National Recreation Area from area in Oregon where roadside populations of 

Alyssum have already been documented just miles from the California border. Since the seeds are 

known to spread on vehicle tires and equipment, as well as by water and wind, the continued 

uncontrolled expansion of infestations is highly likely. [Amsberry et al. 2008]

Response: The SRNF has an active noxious weed removal program. The forest is aware of the threat 

posed by yellow tuft alyssum, which is currently not known to occur on the SRNF. The forest will 

continue to monitor for it. Anyone with knowledge regarding its presence within the proclaimed boundary 

of Forest should contact the forest botanist.

Impacts to Watershed Resources

Letter 

Number

Comment 

Number Comment Text

819 90

Please Address Significant Road Maintenance Issues The initial EA assumed that, “NFS System 

roads are constructed or maintained to specific Forest Service standards.” However, there are miles 

of old, eroding user-created routes in the planning area not constructed to Forest Service standards, 

which have been inventoried as “NFS system roads.” One example is the Diamond Creek road 

18N09. The route known as the McGrew Trail is another. Such roads are potentially hazardous to 

the outstanding resource values of the Smith River National Recreation Area and to forest visitors.

Response: All roads or motorized trails proposed to be added to the NFTS will meet Forest Service road 

maintenance standards. Specific project design features are incorporated for those routes not currently 

meeting road maintenance standards and shall be in place prior to being available for public use. While 

the McGrew Trail extends onto the Six Rivers NF, it is managed in its entirety by the Rogue-River 

Siskiyou NF and is beyond the scope of this project. The Six Rivers Road Maintenance Project, 
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 223

authorized in January 2016, applies to all NFTS maintenance levels (ML 1 through 5) managed by the 

SRNF, including the Smith River NRA, and the Ukonom District of the Klamath National Forest. The Six 

Rivers Road Maintenance Project complements the Smith River National Recreation Area Restoration 

and Motorized Travel Management Project, by preserving investments in NFTS infrastructure to 

mandated design standards that sustain safe public and administrative access to NFS lands (Highway 

Safety Act), while preventing resource damage (LRMP, p. IV-49; Clean Water Act; and Endangered 

Species Act).

Specifically, the Six Rivers Road Maintenance Project design criteria, mitigation measures and annual 

operating allowance thresholds are applicable to road designations included in the Smith River National 

Recreation Area Restoration and Motorized Travel Management Project.

Soils

Letter 

Number

Comment 

Number Comment Text

59 4 Creating and promoting off road use damages water quality, increases erosion, destroys native 

vegetation and leaves lasting soil degradation.

805 9

In my time as a resident of Southwest Oregon, I am personally familiar with the extreme fragility of 

the soils and vegetation of this landscape, and to the helplessness of public lands officials in 

policing ORV route use, even those in relative proximity to urban areas.

Response: Only designated motorized trails and roads that are depicted on the MVUM are available for 

public use. This EIS does not propose to designate any off road use. The project has numerous project 

design features, along with the LRMP and the Smith River NRA standards and guidelines that address 

concerns associated with sensitive soils and vegetation. As it states in the EIS, monitoring and condition 

surveys would be conducted annually, and corrective actions taken if roads and/or trail routes are out of 

compliance, including closures. Appendix B outlines the monitoring plans required for implementation 

for each resource area analyzed. Implementation of the Travel Management process will provide a 

framework for improved enforcement, mitigations, and public education intended to deter violations. For 

more information related to enforcement capabilities, see response to comments under Health and Safety.

Letter 

Number

Comment 

Number Comment Text

819 104

Page 246 of the DEIS states that “most routes being evaluated to be added to the NFTS are likely in 

need of upgrading to NFTS as well as maintenance.” The very next page acknowledges that “lack of 

maintenance also leads to plugging of culverts, ditch lines with sediment or vegetation debris leading to 

washouts.” Yet the Forest Service wants to add 40 miles of UARs to the NFTS that “have a high hazard 

risk rating with increased risk of soil erosion and potential for sedimentation.” Simple economics prohibit 

this dangerous approach to forest management. The agency must follow the requirements of the Six 

Rivers LRMP and “manage soil and water resources to protect and enhance long-term productivity of 

the forest, water quality, associated beneficial uses and aquatic ecosystems.”

Response: Erosion Hazard Ratings (EHR) is a broad evaluation of the soils’ susceptibility to erosion and 

the potential for soil displacement (movement off site), as discussed in the Soils section of the FEIS.

Roads to be added with high EHR ratings do not necessarily reflect the on the ground conditions. Most 

UARs were evaluated by field specialists, and those that have existing/potential erosion and 

sedimentation concerns would be addressed as described in the EIS. The soil resource is one of many 
Appendix G. Response to Comments

224 – Smith River National Recreation Area Restoration and Motorized Travel Management

evaluation criteria being analyzed and compared in the DEIS. All action alternatives would meet LRMP 

soil productivity standards and guidelines. Application of project mitigations/design features identified in 

Chapter 2 (and Appendix D) is applied where necessary to mitigate risk when designating UARs on the 

NFTS. When considered along with both active and passive restoration treatments, these actions would 

improve soil productivity, thereby better meeting LRMP standard and guidelines, and improving water 

quality. As it states in the Monitoring and Condition Surveys section of Chapter 2, monitoring and 

condition surveys would be conducted annually, and corrective actions taken, including closures, if roads 

and motorized trails are out of compliance. The monitoring plans are described in more detail the 

Appendices of the EIS, and are required for implementation for each resource area analyzed. The 

motorized trails proposed for addition to the NFTS require less maintenance for resource protection as 

compared to roads. Impacts to water quality from motorized trails are expected to be minor primarily due 

to the fact that most are ridge top roads, with existing hardened through past use, and are generally selfmaintaining and do not cross live streams. Most maintenance associated with motorized trails is 

associated with brushing and minor clearing of the travelway. Where necessary to mitigate the potential 

for adverse impacts to natural resources appropriate project design features are incorporated into the 

proposed actions.

Letter 

Number

Comment 

Number Comment Text

819 118

Soils Page 260 of the DEIS indicates that “the potential for impacts to watershed resources

associated with adding UARs to the NFTS does exist, especially with respect to those with high 

erosion hazard ratings.” Page 264 indicates that implementation of Alternative 5 (rather than 

Alternative 6) “has the least impacts to soil resources.” Please note that as acknowledged on page 

266 the Six Rivers LMP indicates that “the primary management goal is maintenance of long-term 

soil productivity and high water quality” and that the agency must “manage soil and water resources 

to protect and enhance long-term productivity of the forest, water quality, associated beneficial uses 

and aquatic ecosystems.” Alternative 6 would not accomplish these goals as it adds high risk routes 

to the NFTS with no assurance of maintenance funding and with limited (and unfunded) monitoring 

requirements. Please note that page 293 of the DEIS indicates that the agency is aware that it must

establish Riparian Reserve protection for routes located in unstable terrain. Addition of such routes 

to the NFTS threatens violation of the ACS of the Northwest Forest Plan.

Response: The soil resource is one of many evaluation criteria being analyzed and compared in the EIS.

All action alternatives would meet LRMP soil standards and guidelines. UARs proposed for designation 

on the NFTS where the existing condition presents a high or moderate risk to soil and water resources has 

an associated project design feature to reduce the risk from motorized use. Application of project design 

features along with both active and passive restoration treatments, would improve soil productivity, 

thereby better meeting LRMP standards and guidelines and improving water quality. Most routes that are 

in Riparian reserves are considered for decommissioning, restoration or upgrading. As stated in Chapter 

2, monitoring and condition surveys would be conducted annually and corrective actions taken, including 

closures, if roads or motorized trails are out of compliance. The monitoring plans are described in more 

detail in Appendix B of the EIS, and are required for implementation for each resource area analyzed. It is 

important to note that the appropriated funds shown in the DEIS table only identify a portion of the funds 

available for implementation and maintenance of the NFTS. Funding is also made available from funds 

generated from timber sales and commercial road access permits, State OHV Division grants, emergency 
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 225

repairs through the ERFO program (Emergency Repair for Federally Owned roads), competitive funds 

such as the Federal Lands Transportation Program, and partnership opportunities. In the past, stimulus 

funds were made available to the forest, but these dollars are not available on a regular basis. The 

Transportation Section of Chapter 3 is updated to reflect the diversity funding sources available. For more 

information on the economic viability of the project’s implementation please refer to the response to 

comments under the heading Economic Viability.

Key Watershed and ACS

Letter 

Number

Comment 

Number Comment Text

819 113

Key Watersheds and the Aquatic Conservation Strategy “Roads within the Smith River NRA are a 

primary threat to water quality as they are the leading source of management-related sediment 

impacts to streams.” –DEIS page 47. “Watershed restoration should focus on removing and 

upgrading roads” –Six Rivers LRMP IV-III 30 “Existing permanent roads not necessary for 

administrative, recreation, resource protection, commercial or public access should be closed after 

all project work has been completed.” –Six Rivers LMRP IV-115 The Six Rivers LRMP states that in 

Key Watersheds the existing system and non-system road mileages should be reduced (LRMP IV111). Please note that Key Watersheds serve as refugia crucial for maintaining and recovering 

habitat for at-risk anadromous salmonids and resident fish species.

819 116

Also, during the last NEPA process, Appendix C (Response to Comments) of the EA failed to 

acknowledge or respond to the public concerns regarding the continuing impact of mid-slope 

erosion from the “18 N” and “16 N” road systems in the Key watershed. Instead of addressing this 

concern, the Forest Service made vague reference to undocumented and undisclosed “long-term 

access needs” that in no way addresses the findings of the Watershed Analysis, the goals and 

objectives of the Aquatic Conservation Strategy, or the goals of the National Recreation Area 

designation. We are still waiting for the agency to address these impediments to attaining the 

objectives of the ACS.

Response: This project will reduce the amount of the overall miles of the NFTS, and will restore, 

decommission, or stormproof roads that threaten water quality and downstream beneficial uses. Roads with 

high risk to fisheries/water quality are either being stormproofed or decommissioned. Consultation in 2007 

with the National Marine Fisheries Service determined that the project was not likely to adversely affect 

listed fish or Critical Habitat. The project was reviewed in 2015 as part of the Watershed and Fisheries 

Restoration Program biological assessment (WFR BA) that covers restoration actions to meet the 

anadromous fish recovery plans and improve water quality. The NMFS agreed that the project is consistent 

with this programmatic consultation and in fact is considered to meet recovery goals established in the 

final SONCC coho recovery plan. The project will reduce road miles and sedimentation across the district.

As part of the Six Rivers NF LRMP, the ACS is the overarching conservation strategy that helps 

provide the context and sets the stage for this project, as well as directs the analysis methodology. There 

are four components of the ACS: Riparian Reserves, Key Watersheds, Watershed Analysis, and Watershed 

Restoration. Implementation of these components operate together to maintain and restore the 

productivity and resiliency of riparian and aquatic ecosystems. These four ACS components are integral 

to the development and design of this project, with Watershed Restoration being part of the project 

Purpose and Need, and the project scope being the entire Smith River basin – a Key Watershed.

Therefore, this project does much more than meet ACS objectives; rather it is the site-specific 

manifestation of the ACS on the Smith River basin landscape. Implementation of this project equates to 

pro-active implementation of the ACS.
Appendix G. Response to Comments

226 – Smith River National Recreation Area Restoration and Motorized Travel Management

Roads on the NRA are number by township; therefore, the 18N and 16N roads are all roads across the 

entire district in township 18 or 16. It would not meet the P&N to remove all roads in these two areas.

Long-term access needs refers all administrative management actions now and in the future (currently 

unplanned) as well as public access needs. The Alternative Tables in the DEIS identifies every road and 

route in these townships that were identified for risks to fisheries and aquatic resources, as well as the 

required mitigations.

Air Quality

Letter 

Number

Comment 

Number Comment Text

41 8

With the HUGE problems being caused by excess CO2 and climate change, IT IS YOUR 

RESPONSIBILITY TO REDUCE THE USE OF FOSSIL FUELS AND YOU SHOULD CERTAINLY 

NOT BE PUSHING VEHICLE OFF-ROADING AS “RECREATION”. This must stop.

846 14

Air Quality and Naturally Occurring Asbestos As stated in our June 4, 2012 scoping comments for 

this project, two-stroke engines of all-terrain vehicles allow up to one third of the fuel delivered to the 

engine to be passed through the engine and into the environment virtually un-burned. A majority of 

these hydrocarbons are aromatic hydrocarbons, including polyaromatic hydrocarbons, which, as a 

group, are considered to be the most toxic component of petroleum products. Aromatic 

hydrocarbons are also associated with chronic and carcinogenic effects. Increased ATV use could 

increase pollutant emissions in valleys that have frequent inversion conditions and periods of poor 

air dispersion. The air quality section of Chapter 3 of the DEIS does not address the potential 

human health effects of OHV use within the NRA. Recommendation: We recommend that the FEIS 

provide a detailed evaluation of the potential accumulation of hazardous pollutants from the use of 

OHVs in mountain valleys subject to frequent inversion conditions. We also recommend a 

discussion of the potential human health effect of exposure to these harmful compounds as a 

consequence of OHV use within the Smith River NRA.

Response: The roads and routes being considered in this analysis are open and drivable. All action 

alternatives will reduce roads/routes miles across the NRA by between 21 and 47 percent.

The selected alternative is not expected to have a noticeable influence on the number of OHV use in 

the project area, and therefore is not expected to have any direct, indirect, or cumulative effects on Air 

Quality given the low level of OHV use on the forest. The visitation data from Round 2 of the National 

Visitor Use Monitoring, reflecting data collected from Fiscal Year 2007 through 2011, found that the Six 

Rivers National Forest had one of the lowest visitor use rates, ranking 114 out of 121 national forests and 

grasslands. The latest data available for Six Rivers National Visitor Use Monitoring results from 2008 

indicate that OHV use was the primary activity for 1.6 percent of visitors, who on average spent 

approximately 3 hours engaged in this activity. Approximately 53 percent of visitors reside within 50 

miles of the forest. Crescent City is the closest municipality to the Project area. As noted in the Society, 

Culture and Economy section of Chapter 3, Del Norte County is home to approximately 25,000 people. 

Population increase over the past 10 years has been steady with an average annual increase of 0.5 percent. 

There is no indication that the local population or visitor use will increase dramatically over the next 10 to 

15 years beyond the current population growth trend. As described in the Air Quality section of Chapter 3, 

the existing condition for air quality on the forest is, except during extreme events such as the 1999 and 

2008 wildfires, considered to be in attainment by Federal standards, and it has previously met and 

currently meets ambient air quality standards. The implementation of any of the alternatives is not 

expected to affect use levels. Given the low level of OHV use in the project area, the expected population 
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 227

trends, and the existing condition of air quality, no direct, indirect or cumulative effects are expected to 

impact Air Quality attainment due to the use of two-stroke engines in the project area.

Port-Orford-Cedar

Letter 

Number

Comment 

Number Comment Text

819 66

It is impossible to overstate the importance to our organizations of retaining healthy populations of 

this key riparian tree species. The decisions we make now will determine the future of Port Orford 

Cedar (POC) populations for generations to come. As stated on page 19 of the Siskiyou National 

Forest’s North Fork Smith Watershed Analysis “the consequences of disease introduction are high 

due to the amount of uninfected Port Orford Cedar at risk both on routes and downstream.” As 

stated on page 206 of the DEIS “failure to limit vehicle use during the wet season on roads and 

routes near POC stands would have a potentially great impact.” This is because in ultramafic 

riparian reserves, POC are the “major riparian tree species” and their loss “might dramatically 

change ecosystem dynamics because there are few trees species that would provide similar

ecological functions.” (DEIS 208).

819 67 There is no question that the proposal to add “high risk” user-created routes in POC habitat is a highly 

controversial and significant action that threatens the values the NRA was established to protect.

Response: Port-Orford-cedar are an important species for the forest. It has been identified as a species of 

special management consideration within the Forest Plan, and this analysis is a result of acknowledging 

this. The commenter is describing the effects of the current condition. The roads and routes being 

considered in this analysis are open and drivable. All action alternatives will reduce roads/routes miles 

across the NRA by between 21 and 47 percent, including in POC areas. Routes will only be added to the 

system provided resource risks can be mitigated. All action alternatives would result in resource protection 

benefits. Port-Orford-cedar protection measures are common to all action alternatives.

Each route has been individually reviewed and analyzed as to how each proposed management action 

may affect POC. The intent of this analysis is to minimize the spread of POC root disease while still 

considering other potential uses of the existing and proposed roads and motorized trails. High-risk routes 

added to the system will have mitigations to reduce the risk. Some Mitigations may be seasonal 

restrictions, barricading portions that terminate in POC stands, downgrading roads to ML 1, or improving 

road surface. The type of mitigation would depend on several factors, such as the nature of the high risk 

rating, whether infestation was currently present or not, if an alternate route was available, and acres of 

POC that could potentially be infected if the disease was introduced into a stand.

Actions in Partially Infected Stands

Letter 

Number

Comment 

Number Comment Text

819 72

While the Forest Service acknowledged in the initial EA (page 37) that “vehicular access for both 

the public and Forest Service personnel is a concern within Port Orford-cedar range due to the 

potential spread of Port Orford-cedar root disease” We contend that the Forest Service’s proposal to 

write-off partially infected watersheds, including POC pockets upstream and uphill from infected 

populations violates, the LRMP sections referenced above and indeed, the DEIS does not 

demonstrate that the Forest Service has complied with these requirements.

Response: The FEIS identifies multiple needs for routes. Routes that currently have infestation along the 

route are recognized as being vectors for the disease and mitigation efforts are put into each route to 

reduce spread from infected to non-infected stands. There are two overall strategies for managing POC, 
Appendix G. Response to Comments

228 – Smith River National Recreation Area Restoration and Motorized Travel Management

which are reducing the spread of the disease from these existing infested stands and preventing its spread 

into uninfested stands. Closing roads to prevent access to currently infested stands would do little to 

reduce the spread of the disease within the stand itself, primarily because movement of the disease from 

the infected portion to the uninfected portions that grow uphill or upstream of the infection is spread by 

root-to-root contact, not vehicle access.

Seasonal Gate Mitigation

Letter 

Number

Comment 

Number Comment Text

819 73

The Smith NRA has generally relied on gates and closures to mitigate the potential spread of POC 

root rot while steadfastly refusing to analyze or disclose the failures and impacts of agency road 

gating and road closure methodologies. As detailed in our previous comments regarding Sensitive 

plant species, many BLM and Forest Service Districts have concluded that gates and barricades 

(especially in serpentine forest types) are ineffective at preventing motorized use. The DEIS 

provided no (as in zero) evidence to refute the widespread belief that gates and barricades are often 

ineffective at preventing motorized use. However, the previous post-decisional Response to 

Comments (Appendix A page 84) acknowledged that “some barriers have been circumvented.” Yet

in the DEIS the agency again refused to disclose the environmental impacts that have resulted from 

such circumvention despite our repeated requests that it do so and as NEPA and NFMA (through 

the LRMP and NRA Management Plans) requires.

819 62

Previously the Smith NRA has erroneously concluded that “[b]arricades have proven to be (sic) 

effective deterrent to illegal off road travel” (initial EA Appx C page 19) and “gates have proven to be 

(sic) effective deterrent to wet weather travel” (initial EA Appx C page 1). Such un-documented 

contentions can be directly contrasted with the findings of the Ashland Resource Area of the 

Medford District BLM, which concluded on page III-110 of the Deadman’s Palm EA that “barricades 

are seldom 100 percent effective in eliminating autos and trucks, and they don’t stop any of the 

OHV-type of vehicle use. Consequently, even with barricades in place the negative impacts of noise 

disturbance, increased poaching potential, and the potential for over hunting remain.” As the 

Medford BLM has not posted that EA on-line, a hard copy of the Deadman’s Palm EA is available

from KS Wild at your request.

819 64

After the close of the first round of public commenting and the issuance of the Decision to 

implement the project in 2007, the agency belatedly claimed that “[f]rom 2000-2006, installed 

barriers were 93% effective in keeping vehicle traffic off of these decommissioned roads.” (Appendix 

A at 41). Yet no analysis was provided as to the impacts of the illegal (and foreseeable) breaching 

of 7% of the barricades on resources such as Port Orford Cedar, hydrology and sediment, wildlife 

and botany nor is any such analysis forthcoming. We specifically ask that the Forest Service provide 

evidence – via monitoring reports or other documents – in the FEIS that establishes the efficacy of 

road closure mechanisms on the Smith River NRA.

819 37

Also note that the DEIS provides almost no information about the content or efficacy of the barelymentioned Port Orford Cedar “Monitoring Plan.” The Forest Service appears poised to simply write 

off the major riparian tree species in the NRA whose loss “might dramatically change ecosystem 

dynamics because there are few tree species that would provide similar ecological functions.” (DEIS 

page 208). Page 206 of the DEIS acknowledges that “seasonal gate closure success is dependent 

on the correct timing of the closure and the ability to restrict access beyond the gate,” yet the 

monitoring plan and the DEIS fail to disclose why the NRA has been unable to maintain effective 

seasonal gate closures for the past several decades and what the assumption that these closures 

will suddenly be effective is based upon.
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 229

Letter 

Number

Comment 

Number Comment Text

819 75

In our reconstruction of the history of disease spread across a 37 km 2 landscape, the majority of 

new infections were associated with roads (n = 26; Jules et al. 2002), and stream populations 

crossed by roads had a four – to five-fold increase in infection risk over the 23 years since the first 

infection in our study area (1977). We suggest that road closures be a priority management goal in 

the range of POC. There is no better way to reduce the risk of further spread of the disease. 

Currently, federal agencies have implemented seasonal road closures in areas with which we are 

familiar. We believe that the agencies should not rely on seasonal closures for mitigating the spread 

of P. lateralis; rather these should be used in cases where no other option exists. No studies have 

been done to test the relative efficacy of seasonal vs. permanent road closures, but it is well known

that seasonal road closures do not mean that traffic does not enter the roads. Seasonal road 

closures, in our opinion, can be a risky strategy for several reasons. First, locking of gates must 

happen before the first rain, and we know this can be difficult for agency employees that have 

numerous other tasks to perform. We have known of many gates (with POC closure signs) that 

were not locked before the rainy season. Second, gates do not necessarily keep Off Road Vehicles 

(ORV) from driving the road, as gates can be bypassed by these vehicles. Third, we do not yet 

know the risk of infection during dry seasons, but our opinion is that it can be significant. Water, in 

the form of puddles and run-off near springs, often are evident into midsummer with the range of 

POC. In short, seasonal road closures should not be considered as the equivalent of permanent 

road closures, and they should be viewed as an unproven mitigation measure.

819 74

The agency’s reliance on “gating” to prevent spread of POC disease from route 305.118 was 

misplaced and lacked support or analysis. This is particularly troubling given that the route also 

traverses just uphill/upstream of the Horton Research Natural Area. We are very disappointed that 

the Forest Service refuses to consider decommissioning this unneeded route despite the potentially 

huge impacts to significant environmental resources. Permanent road closure is the only reliable 

method of reducing the spread of POC root disease, and should be prioritized in all uninfected 

stands and watersheds. Jules and Kauffman (2003) wrote that: Permanent closure of logging roads 

is by far the most direct and effective way to stem the spread of P. lateralis. There has never been 

much disagreement about the efficacy of this management strategy, given the clear association of 

the disease with road vectors. The general thinking has been that large uninfected and roadless 

watersheds would remain free of the pathogen, so long as they remain free of roads. Our research 

findings have been in agreement with this assumption.

Response: It is acknowledged that gates are not 100 percent effective, especially for individuals who are 

determined to get past them. However, gates do reduce the overall risk, which is compliant with the 

Forest Plan direction. Monitoring of barricades and gates has shown that these structures are 96 and 90

percent effective, respectively. Effectiveness of barricades and gates on the NRA cannot be compared to 

the Ashland Resource Area because of very different topography and vegetation. The district topography 

does not lend itself to allowing OHVs around all barriers. Installing additional gates will reduce legal 

access beyond that point, and provide additional protection. However, gates are a management tool in 

reducing risks of infestation to POC stands. The steep topography can be used as an advantage when 

finding suitable locations for gates or barricades. Monitoring is required, and when needed, barricades 

would be modified. Extreme measures such as welding gates shut have been implemented in the wet 

season when it became apparent that the gate was not 100 percent effective in keeping out vehicles.

Illegal acts are not foreseeable events capable of NEPA. In general, criminal actions are not required 

for NEPA considerations. Therefore, the Travel Management process does not include an analysis of 

damage due to the speculative nature of illegal activities. The Travel Management process cannot analyze 

or predict illegal activities. It would be very difficult to disclose or analyze environmental impacts due to 

circumvention of seasonal gates because of the time between infection and manifestation of the disease 

varies. Infections along a route could be from the illegal trespass around a gate or from legal access. A 

certain amount of illegal activities are likely to continue under any scenario for motorized use, however, 

the goal of this process is to enact a system that would help to curtail illegal use, and provide a 
Appendix G. Response to Comments

230 – Smith River National Recreation Area Restoration and Motorized Travel Management

mechanism to allow enforcement citations for any illegal use. Seasonal gates have been shown to be 

effective, and deter illegal motorized access along routes when they are located in strategic areas.

UAR 305.118 was identified by the Del Norte County Board of Supervisors and Sheriff’s Office as 

valuable access for search and rescue operations in the North Fork. As such, the preferred alternative 

designates the first portion of Route 305.118 to be added as a motorized trail open for use during the dry 

season. The remaining portion, which has a Darlingtonia bog and accesses uninfected POC stands would 

be barricaded and not open to motorized travel.

Risk Key and Science

Letter 

Number

Comment 

Number Comment Text

819 76

Reliance upon the Risk Key as described in the 2003 Range Wide Assessment of Port Orford 

Cedar on Federal Lands is inadequate as described below by Port Orford cedar experts Jules and 

Kauffman (2004): The Risk Key is, however, inherently flawed because there is no scenario in 

which the key can lend the following answer: this project is too risky and no mitigation will reduce 

risk enough to make it worthwhile.” While the response says this has been fixed, it is clear from 

reading the final Risk Key that the focus remains on going through with the project with mitigation

regardless of a potentially high risk of disease spread. Indeed, the Risk Key states that if the project 

can’t be redesigned to reduce risk to acceptable levels then “...the project may proceed if the 

analysis supports a finding that the value or need for the proposed activity outweighs the 17

additional risk to POC created by the project.” If this Risk Key is going to be effective, it must

provide for a scenario where a project is denied because the risk for disease spread is too high.

Both of the studies referenced above were included in our May 2012 scoping comments, yet the 

DEIS fails to respond or address the information provided to agency planners. POC is a major 

shade tree and large wood source for serpentine streams. Risking PL infestation violates Aquatic 

Conservation Strategy and Clean Water Act due to increased stream temps. This impact is 

irreversible and significant.

Response: The risk key was designed to determine the risk of POC root disease spread, not determine the 

outcome or consequence of its spread. Determining which routes to propose for designation by alternative 

rests with the Responsible Official and is based on several factors, risk being one of those factors. The 

analysis of the alternatives will provide the Responsible Official a comparative basis on which to weigh the 

environmental consequences of the alternatives against one another. The direct, indirect and cumulative 

effects to POC will be considered by the Responsible Official in the decision making process. The project 

was designed to be in compliance with the Clean Water Act, the Porter-Cologne Act, the California 

Regional Water Quality Control Board, and North Coast Region Waiver of Waste Discharge 

Requirements. The proposed actions and project design features describe measures to promote the 

attainment of Aquatic Conservation Strategy Objectives. This project will restrict the overall miles of 

vehicle access open for use, especially in areas with the potential to spread or introduce POC root disease.

Route Specific

Letter 

Number

Comment 

Number Comment Text

819 77

The agency’s proposal to encourage, codify, map, and sign user-created routes into Hole and the 

Ground Mine and Elk Camp Ridge will greatly increase the likelihood of PL spread. Such proposals 

ignore the values and preferences of most forest visitors and may preclude the ability of future 

generations to experience and enjoy healthy Port Orford Cedar forest stands.

Response: The 18N51.100 route crosses a draw at one of the headwaters of Still Creek. Port-Orfordcedar does not grow here or anywhere near it for several hundred yards downstream.
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 231

Letter 

Number

Comment 

Number Comment Text

819 69

Page 211 acknowledges that routes 17N49.7, 17N49.11 and 305.125 present high risks. Page 214 

indicates that roads 18N02.3 and 18N09.100 are high risk. Page 218 concludes that 14N15.1 and 

17N49.7 “have the potential to have a relatively large impact to POC plant communities based on 

plant community composition or the potential to infect [a]currently uninfected watershed.” It is 

foreseeable that the Forest Service decision to dedicate these routes and roads to motorized travel 

will directly harm POC. The agency’s reliance on seasonal gates as a foolproof solution has been 

proven ineffective time and time again in the NRA such that over 3,000 acres of POC have already 

been irreversibly infested. (DEIS page 199)

819 71

The DEIS continues the practice of avoiding analysis or documentation as to the interaction of these 

variables with increased (or continued) motorized use on the road. Nor did the agency attempt to 

compare the influence of road decommissioning or road use on the interaction of these variables on 

the spread of the root disease. Instead, the Forest Service continues to write-off the entire road 

length regardless of the site-specific 15 conditions and variables that “resulted” in the retention of 

many stands of live, healthy POC stands despite the fact that the road has been infected “for many 

years.” NEPA requires the Forest Service to conduct the missing analysis. Please note that the Six 

Rivers LRMP (page IV-129) requires that: 20-6 Port-Orford-cedar will be managed as a long-term 

component of plant associations where it is present. 20-7 Strategies for reducing the risk to PortOrford-cedar from infection of the root disease will be integrated into all levels of planning and 

analysis (NEPA documents, watershed analysis, Late-Successional Reserve assessments, wild and 

scenic river management plans, transportation planning, recreation planning and other activities or 

strategies) in all watersheds where it is present. Transportation plans will evaluate the risk or spread 

of Port-Orford-cedar root disease through road upgrades, seasonal closures, maintenance, and 

decommissioning or obliteration. As acknowledged on page 11 of the DEIS the Smith River NRA 

Management Plan requires that agency planners: Provide for the long-term viability and presence of 

Port-Orford-cedar and ensure its continued present economic and noneconomic uses through 

implementation of management strategies developed by the Forest Service.

Response: Numerous project design features are designed to mitigate the introduction and spread of 

POC root disease. The risk to introduction and spread of POC root disease will be reduced because of 

implementing this project. The preferred alternative addresses these routes as follows. Portions of 

17N49.7 and 17N49.11 with uninfested POC are proposed to be permanently barricaded. Regulating 

access on 305.125 through route delineation would reduce the risk to POC and minimize additional illegal 

cross county travel that would cause other additional resource damage. This is a similar situation with 

18N02.3. Route 14N15.1 is proposed to be permanently barricaded, and the segment of 18N09.100 that 

accesses the creek containing uninfested POC is proposed to be permanently barricaded.

Letter 

Number

Comment 

Number Comment Text

819 55 Page 217 of the DEIS indicates that “system road 15N13 has the greatest risk by accessing the 

non-infected Goose Creek Watershed. Yet the road is retained for motorized use.

Response: Road 15N13 was identified by the county as a need in order to facilitate search and rescue. 

The preferred alternative proposes designating this route as an OML 1 road with a permanent gate closure 

to allow for emergency access.
Appendix G. Response to Comments

232 – Smith River National Recreation Area Restoration and Motorized Travel Management

19N01

Letter 

Number

Comment

Number Comment Text

819 70

Please note that the proposal to retain 19N01 on the system for motorized use appears to rely on 

the agency’s preference to simply give up on reducing or slowing PL infection in the watershed. This 

is arbitrary and capricious. In Appendix A (page 5) of the initial EA the Forest Service acknowledged 

that: The POC risk was based on the fact that 19N01 is already infected along its entire length, and

has been for many years. The presence of uninfected POC in this infected area can be attributed to 

numerous variables related to specific locations of POC, such as degree of root contact and 

distance between trees (stand density), POC proximity to streams or wetlands, [and the] amount of 

overland flow of infected water that can contact roots.

Response: The risk ratings were based on the potential for the road to spread the disease to an 

uninfected, unprotected area. As stated in the EA, 19N01 occurs in a heavily infected area. In addition, 

19N01 is accessed by county roads on both ends of the road. The headwaters to several streams that flow 

from 19N01 are also accessed by county roads. Several portions of the road, along with the north end of 

19N01 pass through non-Forest Service property.

Photo Comments

Barbara Ullian’s four photos submitted during the public comment period to the EA in 2007 are described 

therein as illustrating OHVs creeking in the South Kalmiopsis Inventoried Roadless Area (IRA), which is 

not on the Six Rivers National Forest, and “how extreme OHV vehicle use can impact Port Orford cedar, 

fish habitat and botanical values and how OHV routes can have impacts far beyond road corridors”. The 

use shown in the photographs is not legal and is not proposed in any of the action alternatives; therefore,

it is not an action that can be analyzed with predictable effects.

To clarify, gates and berms are used to regulate motorized use of a road or motorized trail, typically 

not as a management action to deter illegal motorized travel in streams. No gate closure or berm is 100

percent effective, but they are intended to reduce and deter violations. The effectiveness of gates and 

berms depends on monitoring (see Chapter 1, Monitoring and Condition Surveys) and involves 

identifying resource concerns and providing a mechanism to fix the problem in a timely manner to 

minimize resource damage. Future effectiveness will rely partly on ensuring the gate location is such to 

minimize driving around the gate as much as possible. Modifications to gates and placement, i.e. moving 

to a more effective location or reinforcing perimeters, may be necessary when consistent problem areas 

are identified. The Smith River NRA currently has 1 law enforcement officer, 3 fire prevention patrols

who serve as forest protection officers (FPOs) and have citation authority, and 1 permanent recreation 

officer. All monitor use and compliance. The district also staffs a permanent road manager position and 

typically, two seasonal recreation staff serve spring through fall, all of whom will also monitor use and 

compliance. The SRNF also has a cooperative agreement with the Del Norte County Sheriff’s Office that, 

per the agreement, provides for the Sheriff’s Office patrol of “roads designated and maintained by the 

Forest Service within the Cooperator’s (Sheriff’s) jurisdiction.” It is anticipated that law enforcement will 

continue to apply for and receive grant dollars (green sticker funding) from the State of California OffHighway Motor Vehicle Recreation Division Grants Program. These state funds are earmarked 

specifically for enforcement of off-highway vehicle laws and regulations on the various forests, and are 
Appendix G. Response to Comments

Final Environmental Impact Statement – Appendices – 233

performed primarily by FPOs. The Law Enforcement Program has been consistently successful in 

securing these sources of funding in the past. Implementation of the Project will provide a framework for 

improved enforcement, engineering, and public education intended to deter and reduce violations. This 

includes issuance of a MVUM, which will identify NFTS roads and trails open to motorized use and give 

law enforcement the necessary documentation with which to enforce the proper use of these routes; 

signing of motorized recreation routes; decommissioning roads removed from system; barricading UARs; 

and seasonal gate closures. The photos submitted during this comment process are responded to on a 

photo-by-photo basis in the response-to-comments.

The photos attached to the DEIS comments did not have specific comments associate with each of 

them; therefore, much was left to Forest staff to infer the issue the commenter was intending to 

communicate. A photo-by-photo response is provided though.

Letter 

Number

Comment 

Number Comment Text

819 137 We will be submitting 17 attachments (primarily photos) to the general Forest Service mailbox for 

this project.

819 30

Please note that we have repeatedly provided agency planners with photo-documentation of nonfunctional berms and POC gates in the Smith River NRA (see photo attachments 1-5), and hereby 

ask the Forest Service to include this information in the administrative record for this project. It is 

essential that the decision maker explain how and why closure mechanisms will prove effective 

given that they have been repeatedly breached in the past.

819 63

Tragically, the difficulty of keeping agency gates locked and vandalism-free has been in the news:

http://seattletimes.nwsource.com/html/travel/2003517023_webkimfamily09.html. The Smith River NRA 

would truly be unique in the National Forest Service if it is the sole District in the system that has not 

been plagued by vandalism of locked gates. Such a curious and undocumented contention strains the 

agency’s credibility. Attached photos illustrate breached POC gates in the Smith River NRA.

819 65

We again bring to the agency’s attention the images of off-road ORV resource damage submitted 

by Friends of Del Norte and Barbara Ullian in their comments on the initial EA. With very limited 

finances available to adequately patrol the Recreation Area, it is reasonably foreseeable that these 

abuses will continue and accumulate as the agency increases the size of the NFTS. Friends of Del 

Norte submitted a Triplicate article, dated Feb. 8, 2007, in their comments on the initial EA that 

highlights the lack of enforcement capability to control abuse of resources within the vastness of the 

Recreation Area, and the rise in damage that has been incurred. In that article US Forest Service 

Officer Steve White stated: “We definitely have some crime issues that impact the quality of our 

resources and the quality of the time our recreationers enjoy...The sense of remoteness does really 

play into the people feeling more free (to commit crimes), and the shear vastness of the parks and 

forests prevent thorough policing.” Page 206 of the DEIS acknowledges that “seasonal gate closure 

success is dependent on the correct timing of the closure and the ability to restrict access beyond 

the gate.” The Smith River NRA has not been able to demonstrate success at restricting motorized

access via gates, berms or boulders. Nevertheless the analysis contained in the DEIS rests upon 

the assumption that these methods will become effective once the ROD is signed. Our 

organizations have submitted photos of non-functional POC gates as well as breached berm and 

boulder closures to the District Ranger, the Forest Supervisor and the “collaborative” group on 

multiple occasions. None of these site-specific photos are addressed in the DEIS.
234

Appendix G. Response to Comments

– Smith River National Recreation Area Restoration and Motorized Travel Management

Letter 

Number

Photo 

Number

Route/Road 

Number Photo Name (Provided) Reviewer Description Response

819 1 17N49 17N49 Berm

Berm on closed road with 

man standing on it. 

Appears berm is 6' tall and 

has been driven over.

The Forest cannot guarantee 100% of OHV operators will comply 100% of the 

time. However, implementation of the Travel Management process will provide a 

framework for improved enforcement, mitigations, and public education intended 

to deter and reduce violations. However, what is important to note is that the 

breached berm in the picture leads to an undrivable section of an old road.

819 2 305.19.00 305.19.00 Wimer Berm, appears to have 

been driven over.

The title of this photo does not coincide with any inventoried unauthorized routes 

considered within the scope of this analysis.

819 3 ? Non-functional POC gate Open gate.

The photo shows an open gate. It is not clear that the gate is a POC gate, nor that 

it is not functional, but rather that it is open. It is also not apparent as to what time 

of the year this photo was taken. Port-Orford-cedar gates are open seasonally to 

allow motorized access during the dry season.

819 4 ? POC gate open, shot Open gate.

The photo shows an open Forest Service gate; however, it is not clear that the 

gate is a POC gate. Nor is it clear from the photo that the gate, while showing 

evidence of being shot, is not functional. It is also not apparent as to what time of 

the year this photo was taken. Port-Orford-cedar gates are open seasonally to 

allow motorized access during the dry season.

819 5 ? POC gate shot up

Post where gate locks has 

been shot through. Gate is 

open.

The photo shows an open Forest Service gate; however, it is not clear that the 

gate is a POC gate. Nor is it clear from the photo that the gate, while showing 

evidence of being shot, is not functional. It is also not apparent as to what time of 

the year this photo was taken. Port-Orford-cedar gates are open seasonally to 

allow motorized access during the dry season.

819 6 ? McGrew Run OHV >50" on a trailer being 

pulled down the road.

The analysis of effects accounts for the addition of motorized trails for vehicles 50" 

or greater. The McGrew Trail is managed by the Siskiyou National Forest.

819 7 ? Not a dirt bike OHV >50" on a trailer being 

pulled down the road.

The analysis of effects accounts for the addition of motorized trails for vehicles 50 

inches or greater.

819 8 305.118 H2O fen POC

Slump/slide into route with

Fen & Darlingtonia, water 

running down route.

The site shown in the photograph occurs on the segment of 305.118 (milepost 

0.80 to 1.56) that is identified in the Preferred Alternative (Alt 6) to be restored 

through barricading and the installation of waterbars and rolling dips.

819 9 305.118 Fen POC on 305.118

Slump/slide into route with

Fen & Darlingtonia, water 

running down route.

The site shown in the photograph occurs on the segment of 305.118 (milepost

0.80 to 1.56) that is identified in the Preferred Alternative (Alt 6) to be restored 

through barricading and the installation of waterbars and rolling dips.

819 10 305.118 Fen & PL on 305.118

Small POC trees on side 

of route, showing 

yellow/brown discoloration 

on needles.

All action alternatives that propose designating this route as a Motorized Trail include 

POC mitigations which include seasonal gate closure at the beginning of the route, 

drainage work on the travelway surface and barricading and putting in waterbars or 

rolling dips on the last half of the route from the 0.80 mile post to 1.56 mile post.

819 11 305.118 H2O=PL 305.118

Water running directly 

down route and then 

channel cuts across the 

route and exits route.

All action alternatives that propose designating this route as a Motorized Trail include 

POC mitigations which include seasonal gate closure at the beginning of the route, 

drainage work on the travelway surface and barricading and putting in waterbars or 

rolling dips on the last half of the route from the 0.80 mile post to 1.56 mile post.
Final Environmental Impact Statement – Appendices

– 235 

Appendix G. Response to Comments

Letter 

Number

Photo 

Number

Route/Road 

Number Photo Name (Provided) Reviewer Description Response

819 12 ? Bear Basin Boulders

Boulder blocking vehicle 

access has been moved 

allowing for vehicle access.

The Forest cannot guarantee that closures are 100% effective, however, the 

implementation of the project will provide a framework for improved enforcement, 

engineering, and public education intended to deter and reduce violations. This 

includes issuance of a Motor Vehicle Use Map which will identify NFTS roads and 

trails open to motorized use; give Law Enforcement the necessary documentation 

with which to enforce the proper use of these routes; signing of motorized 

recreation routes; decommissioning roads removed from system; barricading 

UARs not designated on the NFTS. There are civils fines currently in place for 

damage caused by motorized resources. Two examples are CFR 261.15(h)- ($250 

in N. District of CA.), and 261.12(c)- ($100 in N. District of CA.). The Smith River 

NRA currently has 1 Law Enforcement Officer, 3 Fire Prevention Patrol who serve 

as Forest Protection Officers (FPOs) and have citation authority, and 1 permanent 

Recreation Officer. All monitor use and compliance. In addition, a permanent Road 

Manager position is slated to be staffed within the next few months and 

approximately 2 seasonal recreation staff are typically hired to serve spring 

through fall, all of whom will also monitor use and compliance. The Forest also has 

a Cooperative Agreement with the Del Norte County Sheriff’s Office that, per the 

agreement, provides for the Sheriff’s Office patrol of "roads designated and 

maintained by the Forest Service within the Cooperator’s (Sheriff’s) jurisdiction."

819 13 305.109 Pine Flat Rutting Pooling of water and 

rutting of route shown.

Action alternatives that propose adding this route to the NFTS as a motorized trail 

also include mitigations to address drainage problems associated with the travelway.

819 14 305.109 Rutting near 305.109 Pooling of water and 

rutting of route shown.

Action alternatives that propose adding this route to the NFTS as a motorized trail 

also include mitigations to address drainage problems associated with the travelway.

819 15 17N49 ORV Meadow 17N49 View shows looking at 

UAR 17N49.100A

The view shown is looking at the inventoried UAR 17N49.100A, which is proposed 

for restoration and barricading in all of the action alternatives. 
Appendix G. Response to Comments 

236 – Smith River National Recreation Area Restoration and Motorized Travel Management

Impacts to Specially Designated Areas 

IRA, SRNRA and Impacts

Commenters are concerned that the unique qualities of the Smith River National Recreation Area and 

Inventoried Roadless Area characteristics will be compromised if more motorized trails are designated 

within their boundaries. The commenters question the need and validity of designating motorized trails 

within the Smith River NRA and Inventoried Roadless Areas located within the project area, and are 

concerned that recreation preferences will outweigh the need to conserve the qualities for which the Smith 

River NRA was established and the IRA characteristics, including to but not limited to sensitive plants.

The following responses are preceded by the comments grouped into three main topics where the 

concerns are similar. Responses discuss existing MVUM development, management of NFTS roads and 

motorize trails, sensitive plants and compliance with the Forest Plan, Travel Management Rule, 

Redesignation of the NFTS, and compliance with the Smith River NRA Act, Roadless Rule and IRAs.

Existing MVUM Development and Management of NFTS Roads and Motorized Trails

Letter – Comment Number Comment

1-6; 41-6; 476-5; 521-5;

615-6; 620-4; 790-5; 790-6;

791-5; 605-8; 620-1; 759-6;

805-7; 338-3, 819-57

The Smith River National Recreation Area and the Six Rivers National Forest offer hundreds of 

miles of existing Forest Service roads where motorized recreation is an appropriate and harmless 

activity. Additional user-created routes should not be added to the current system.

Existing MVUM development

Response: In 1990, the Smith River NRA limited motorized travel to designated routes on the NFTS, 

whereas other districts and forests were open to cross-country motorized travel. At that time, there was no 

codified legal mechanism for displaying the designated NFTS to the public. Visitor use maps and USGS 

maps displayed information related to roads and motorized trails, which were not based on information 

stored in the Forest Service transportation database. In 2005, the Travel Management Rule established 

and required the use of Motor Vehicle Use Maps (MVUM) to display the designated NFTS open to 

motorized travel. The current MVUM for the Smith River NRA reflects the status of NFTS roads and 

motorized trails in the forest’s transportation database at the time of publication in 2009. Many UARs on 

the Smith River NRA are not the result of off-road recreationists, as the terrain in many parts of the Smith 

River NRA itself limits this, but rather they are old mining roads or Forest Service logging roads that 

were not tracked in the transportation database in 1990. The public’s input was not involved in identifying 

recreation opportunities or determining the NFTS shown on the 2009 MVUM. The information displayed 

in the current MVUM differs in respect to recreational opportunities from what had been displayed in 

map products the public had relied on for knowledge of trails and roads available for motorized use prior 

to the publication of the MVUM. With the publication of the 2009 MVUM many of the routes that had 

been used by recreationist in the past were then codified as UARs and therefore illegal for motorized 

travel. Unauthorized routes considered for designation on the NFTS are limited to those that currently 

exist on the ground and have been inventoried. 
Appendix G Response to Comments 

Final Environmental Impact Statement – Appendices – 237

Management of NFTS Roads and Motorized Trails

Response: Whether a route is a road or motorized trail depends on how it is managed (e.g., surface type), 

along that route. The assumptions provided in the IRA analysis are intended to frame the difference in 

general terms, but do not describe Forest Service classification policy – in other words, the traveler’s 

intentions do not determine whether they are on a road or a trail; however, certain travel purposes are 

more commonly seen on roads than on trails, and vice versa. Forest Service direction defines a trail as “a 

route 50 inches or less in width or a route over 50 inches wide that is managed as a trail” (36 CFR 212.1; 

FSH 2309.11, Chapter - Zero Code). A road is defined as “a motor vehicle route over 50 inches wide, 

unless identified and managed as a trail” (36 CFR 212.1). The Forest Service Trails Management 

Handbook, FSH 2309.11, defines trail management terminology and provides further management 

prescriptions for trail (development) class, depending on the managed use for a given trail. Though 

travelers may use any mode of travel on a motorized trail other than the managed use, the Forest Service 

assigns one managed use to each trail and designs and/or maintains the trail according to those standards.

Motorized trails managed for vehicles greater than 50 inches wide differ from roads in the design 

criteria and standards; these differences are more pronounced for Class 2 and Class 3 motorized trails 

(FSH 2309.11, Ch. 20; FSH 7709.56, Ch. 40). For many motorized trails proposed for designation on the 

Smith River NRA that are greater than 0.25-miles long, we anticipate that they will fall into Class 2 or 

Class 3 based on their slope. Regardless of a motorized trail’s class, we anticipate that trail maintenance 

will be less frequent or intensive than is done on roads, and will focus primarily on hazards removal and 

resource protection. 

Sensitive Plants and Compliance with the Forest Plan

Letter – Comment Number Comment

1-3; 20-1; 41-2; 64-3; 476-2; 521-4;

615-3; 605-2; 759-2; 791-3; 840-1;

338-1; 369-2; 590-3; 521-4; 419-1;

790-1; 793-3; 805-5; 829-2; 837-10

I am concerned that the recreational preferences of a handful of extreme off-road vehicle 

enthusiasts appear to outweigh the need to protect at-risk botanical treasures and 

irreplaceable roadless areas.

50-2; 50-4; 243-5; 255-9; 263-5;

263-7; 369-1; 590-2; 751-6; 791-2;

805-3; 829-9; 834-1; 837-9

I am dismayed by the direction that the Smith River National Recreation Area Travel 

Management process is taking. Like most Americans I value the wildlands, watersheds and 

wildflowers of this special place. There is no need to convert plant communities to mud pits. 

Protection, preservation and diversity for the long range should be your primary goal.

1-7; 20-2; 20-4; 41-7; 59-2; 64-4;

79-2; 139-3; 182-2; 338-4; 369;

476-6; 521-6; 603-1; 605-9; 615-7;

620-5; 755-1; 791-6; 790-7; 805-6;

813-1; 840-2; 419-4; 837-8; 369-4;

829-5; 590-5; 581-4

The Smith River National Recreation Area and the Six Rivers National Forest offer hundreds 

of miles of existing Forest Service roads where motorized recreation is an appropriate and 

harmless activity. There is simply no need to sacrifice wildlands and rare plants in order to 

establish additional “motorized trails” in these special places.

1-4; 41-4; 64-2; 79-1; 79-2; 139-1;

255-4; 263-3; 400-2; 419-2; 590-4;

521-1; 605-3; 615-4; 620-2; 759-2;

790-2; 837-11; 829-8

It is my understanding that the Forest Service is proposing to add user-created routes 

through roadless areas and botanical hotspots to the Forest Service road system.

23-1; 793-4; 197-2; 339-2; 434-1;

476-1; 484-1; 825-3

Don’t undermine the Forest Service policy to “maintain viable populations of all native and 

desired non-native wildlife, fish, and plant species in habitats distributed throughout their 

geographic range on National Forest System lands” (FSM 2670.22). The Forest Service 

needs to protect our natural resources.

Response: Of particular controversy is the proposed designation of motorized trails and its effect on 

sensitive plants. The Six Rivers Forest Plan standard and guideline for the management of sensitive plants 
Appendix G. Response to Comments 

238 – Smith River National Recreation Area Restoration and Motorized Travel Management

requires that the Forest Service actions may not lead to a loss of species viability. A loss of viability 

determination would occur if 20 percent or greater of a species were found to decline over a 5-year 

period. (USDA Forest Service 1995. Six Rivers National Forest Land and Resource Management Plan. Pp 

V-18). Implementation of this project is designed to provide for improved management of motorized 

recreation on the Smith River National Recreation Area (SRNRA) through the implementation of 

mitigation measures aimed to reduce risk to resources associated with the NFTS. Some examples include 

route delineation, which is the placement of physical barriers to travel, in close proximity to the 

motorized trail prism, designed to keep vehicular traffic on the designated travelway, and barricading 

UARs that are not designated which will prevent unintended illegal use on these UARs. It is anticipated 

that these mitigation measures would decrease unintentional illegal use and damage to sites, which in turn 

would reduce negative effects to native vegetation and Sensitive plant species.

Sensitive plants that are present on UARs proposed for addition to the NFTS have a tolerance for the 

low level of use that has been occurring on those routes most likely due to passive avoidance, subterranean 

meristem tissue, and multi-stem growth, enhanced seedbed conditions, and a reduction in competition from 

plant species that are less tolerant of the current level of use. (Brewer 2011, Brown et. al. 2000, Cook 1979, 

Larcher 1995, Stohlgen and Rundel 1986, Zober 1992) The projects aims to protect the viability of the 

rarest plants in the project area via monitoring. Sensitive plant populations within 100 feet of UARs added 

to the NFTS will be managed via monitoring to determine if a decline in Sensitive plant populations has 

occurred. Once baseline and initial monitoring is complete, the intent is to continue monitoring every 5 

years, as per the LRMP, until the species are no longer considered Sensitive. If a decline of any Sensitive 

plant population is found to have occurred that indicates a trend toward loss of viability, the UARs with the 

declining species that were added to the NFTS will be removed from the Motor Vehicle Use Map and 

barricaded until such time that Sensitive plant populations are found to have recovered.

The majority of UARs on the NRA are not user created routes. They are old mining roads—old logging 

roads from previously private land that was later acquired by the Forest Service, etc. Although construction 

standards have changed and improved, many of these old roads were engineered. Many of these roads access 

popular recreation sites. Mitigations have been proposed to minimize resource impacts while providing 

access. The Forest Service would close between 2 to 4 times the miles of UARs that would be added. Adding 

the UARs that are needed for access would be consistent with Forest Service rules and regulations.

The roads and routes being considered in this analysis are open and drivable. All action alternatives 

will reduce roads/routes miles across the NRA by between 21 and 47 percent, including in sensitive plant 

habitat. Routes will only be added to the system provided resource risks can be mitigated. All action 

alternatives would result in resource protection benefits including: 1) less than 0.1 percent of the 

serpentine sensitive plant habitats on the NRA are being affected and 2) all routes into the North Fork 

Botanical Area are being closed, protecting over 20,000 acres of potential habitat. 

The NRA Act requires the forest improve the anadromous fishery and water quality (water resources), 

improve spawning and rearing habitat (aquatic biota), and place appropriate restriction or limitation on 

soil disturbing activities (soil).
Appendix G. Response to Comments 

Final Environmental Impact Statement – Appendices – 239

Recreation Use – Cross-Country Travel

It is anticipated that the likelihood of illegal cross-country motorized travel will be reduced through the 

implementation of the project, as it would provide for a diversity of motorized recreation opportunity in 

coordination with a framework for improved enforcement through public education intended to deter 

violations, issuance of a revised Motor Vehicle Use Map that will identify NFTS roads and trails open to 

motorized use; signing of motorized recreation routes; seasonal gate closures; barricading UARs not 

added to the NFTS and decommissioned roads removed from system. All action alternatives will reduce 

roads/routes miles across the NRA by between 21 and 47 percent. 

Travel Management Rule, Redesignation of the NFTS, and Compliance

Letter – Comment Number Comment

581-1; 819-6; 819-40; 819-44;

819-48a/48b; 825-2 Follow the Roadless Rule, the Smith River NRA Act and the NEPA.

1-2; 41-1; 59-1; ; 476-1; 476-

3; 521-3; 615-2; 605-2; 581-2;

805-8; 819-42/43; 819-49;

819-53; 828-11; 840-1

There is no reason to add user-created routes through roadless areas.

It seems like a bad-idea to add user-created routes through roadless areas.

Travel Management Rule and Redesignation of the NFTS

Response: One of the purposes of this project is to implement the recommendations identified in the 

Travel Analysis Process (TAP), consistent with Subpart A of the Travel Management Rule (36 CFR 212), 

which identified administrative access needs, as well as motorized recreation opportunities through a 

public process, and risks associated with each road or UAR. With the use of the information provided in 

the TAP, road and route specific actions and mitigations were crafted to provide recreational 

opportunities and administrative access while also investing in mitigations to reduce risks identified on 

routes. Unauthorized routes that are proposed to be added to the NFTS meet the mandate of the agency to 

provide suitable recreational opportunities while managing natural resources compliant with Forest Plan 

standards and guidelines and other applicable law, policy, and regulation. This is often achieved with

mitigations designed to reduce moderate and high risks. 

The forest is pursuing the revision of the designation of the NFTS through the development of an 

Environmental Impact Statement pursuant to the National Environmental Policy Act. The public was 

invited to submit comments on the proposed action during the scoping period in April 2012. Comments 

submitted during the scoping period were analyzed to identify significant issues. Alternatives to the 

proposed action were considered and developed that address the significant issues that were within the 

scope of the project, compliant with law, regulation, and policy, within the agency’s purview to 

implement, and met the purpose and need of the project. The public was invited to provide comment on 

the DEIS, and will be given the opportunity to review the FEIS and draft Record of Decision and 

participate in the Objection process (36 CFR 218 subparts A and B). Three significant issues, including 

Impacts to Access and Recreation Opportunity, Impacts to Inventoried Roadless Areas, and Impacts to 

Resources, drove the development of three action alternatives, which include a modified version of the 

modification of the proposed action. These alternatives respond uniquely to roadless area consideration

for features and values. Alternative 4 proposes designation of 66 miles of motorized trails on the Smith 
Appendix G. Response to Comments 

240 – Smith River National Recreation Area Restoration and Motorized Travel Management

River NRA, including 9.4 miles in IRAs, compared to Alternative 5 that proposes 7.4 miles of motorized 

trails excluding designations in IRAs altogether. Alternative 6 responds uniquely by proposing 47 miles of 

motorized trail designation with 3.1 miles occurring within two IRAs. 

Compliance with the Smith River NRA Act

Response: The purpose of the Smith River NRA Act is to ensure “the preservation, protection, 

enhancement, and interpretation for present and future generations of the Smith River watershed’s 

outstanding wild and scenic rivers, ecological diversity, and recreation opportunities while providing for 

the wise use and sustained productivity of its natural resources”. In Parts 1, 2, and 4 of §5 of the Act, 

direction is provided to the forest service to provide for a broad range of recreation uses and provide 

recreational and interpretive services and facilities (including trails and campgrounds) for the public, 

provide and maintain adequate public access, including vehicular access roads for general recreation 

activities, and permit the use of off-road vehicles only on designated routes. The Act strongly balances the 

direction to provide for recreation opportunities by directing the Forest Service to improve the 

anadromous fishery and water quality, provide for the long-term viability and presence of Port-Orfordcedar; protect, preserve and increase old-growth forest habitat; and restore landscapes damaged by past 

human activity. This project is consistent with the intent and administrative direction outlined in the SR 

NRA Act by providing for motorized recreation opportunities through the designation of motorized trails 

to the NFTS, while also reducing risks to the unique qualities and characteristics of the SR NRA such as 

botanical communities, water quality, POC, and cultural resources through decommissioning of roads and 

the implementation of risk reducing mitigations on the proposed NFTS. 

The Smith River National Recreation Area Act incorporated in the Six Rivers National Forest Plan 

guides management of the Smith River NRA, which also includes portions of eight Inventoried Roadless 

Areas. Management Direction contained in the Smith River NRA Management Plan related to motorized 

recreation includes direction for all areas and directs the forest to provide and maintain adequate public 

access, including vehicular roads for general recreational activities such as camping, hiking, hunting and 

fishing. Specific to the North Fork Management Area, the management plan states that the NRA shall

provide and maintain facilities for information services and recreation activities, which are compatible 

with the Wild, Scenic, or Recreational River designations, including hiking, camping, white water 

boating, off-highway vehicle use on designated trails, and hunting. 

Compliance with Roadless Rule

The Roadless Area Conservation Rule (36 CFR 294), referred to as the ‘Roadless Rule’ identifies values 

or features that often characterize IRAs, such as “diversity of plant and animal communities; habitat for 

threatened, endangered, proposed, candidate, and sensitive species...; and semi-primitive motorized 

classes of dispersed recreation”. In the response to comments on the Roadless Rule (FR 3251), a trail is 

defined as “established for travel by foot, stock, or trail vehicle, and can be over, or under, 50 inches 

wide.” The response to comments on the Roadless Rule in the Federal Register further clarifies that the 

Roadless Rule was not intended to prohibit the authorized construction, reconstruction, or maintenance of 
Appendix G Response to Comments 

Final Environmental Impact Statement – Appendices – 241

motorized or non-motorized trails that are classified and managed as trails pursuant to existing statutory 

and regulatory authority and agency direction (FSM 2350). The action alternatives considered offer a 

range of options that are being analyzed in the FEIS, which include Alternative 4 that would offer a sum 

total of 13 additional miles motorized recreation opportunities and restore 20 miles of UARs in IRAs, 

while Alternative 5 would decrease motorized recreation opportunities in IRAs by 19 miles and restore 39 

miles of UARs in IRAs. Lastly, Alternative 6, the preferred alternative includes a total of 4 additional 

miles of motorized recreation opportunity and 29 miles of restoration on UARs in IRAs. Designation of 

these routes as motorized trails will meet the intent of the Rule as it will provide authorized OHV access 

and does not involve new road construction or reconstruction. Inventoried Roadless Areas within the 

project area account for approximately 147,000 acres. UARs proposed for designation on the NFTS occur 

at the boundaries of IRAs and do not transect the heart of any of the IRAs. 

The Roadless Rule allows for authorized OHV use. It is important to understand that all the roads 

considered for addition and use are not new but currently open and drivable, and have been so for many 

decades. The roads and routes being considered in this analysis are open and drivable. No new road 

construction or increased use would occur under this proposed action. The project as proposed would 

reduce road mileage across the district by between 21 and 47 percent, including in IRA, sensitive plant 

habitat, and POC areas. 

Designation of these routes will not constitute a substantial impact to Roadless or wilderness 

characteristics in that, under the preferred alternative, 3 miles of UARs will be added to the system but 29 

miles of UARs will be restored in the IRAs. The project will restore seven times more UARs than will be 

designated. The project will reduce the road density in the IRAs. 

Wild and Scenic Rivers

Letter 

Number

Comment 

Number Comment Text

819 106

The proposal to adopt an inadequately maintained system will result in significant environmental 

and human safety risks and violates the following legal requirements: * The Proposed Action 

violates the Clean Water Act and the Northcoast Basin Plan: Specifically the Basin Plan, State and 

Federal Anti-degradation policies each and all require that “whenever existing water quality is better 

than the water quality objectives established herein, such existing (water) quality shall be 

maintained” (Northcoast Basin Plan at 3-2.00 and Appendix 6 and 6B). Because inadequate

maintenance is an inevitable consequence of the proposed action and because inadequate 

maintenance will lead to sediment delivery to streams, the proposed action will not maintain the 

existing high quality of the Smith River and its tributaries. * The Proposed Action violates the Wild & 

Scenic Rivers Act (WSRA): The intentional retention of a system that cannot be adequately 

maintained can reasonably be expected to result in degradation of the values for which the Smith

River and its tributaries were declared to be part of the federal Wild & Scenic Rivers System. The 

primary designation value is anadromous fisheries; there is no scientific controversy concerning the 

negative impact of system related sediment on 24 anadromous fisheries.1 Because the proposed 

action can be reasonably expected to degrade the anadromous fisheries through chronic delivery of 

fine sediment to the Smith River and its tributaries, it violates the WSRA.

Response: The proposed actions are intended to adopt a road system that will minimize adverse impacts 

to water quality through road decommissioning and stormproofing. The project as proposed would reduce 

road mileage across the district by between 21 and 47 percent, and reduce road density in all 5th-field 
Appendix G. Response to Comments 

242 – Smith River National Recreation Area Restoration and Motorized Travel Management

watersheds. The proposed actions are in compliance with the Clean Water Act, the Basin Plan and the 

North Coast Waiver.

Consultation with the National Marine Fisheries Service determined that the project was not likely to 

adversely affect listed fish, and in fact is considered beneficial.

L.E. Horton RNA and Rare Plant Assemblages

305.118

Letter 

Number

Comment 

Number Comment Text

819 7 

An unfortunate example of the willingness to place high value natural resources at risk to meet a 

non-existent “need” for motorized access is the proposal to add route 305.118 to the NFTS. As 

pointed out in our 2012 scoping comments, this route is currently impassible to motor vehicle traffic 

and has been so for quite some time. Yet neither the DEIS or the Scoping Report reflect the fact 

that the route is and has been impassible to motorized travel. Additionally, the length of the route 

traverses numerous seeps, subsurface flows (in the cut banks), springs and riparian features. PortOrford-cedar is found along the route. The potential for codified and mapped motorized use of this 

route to spread POC root rot disease is extremely high, and the consequences could be irreversible

and significant.

819 8 

Additionally, this is a dead-end spur route that provides very limited motorized recreational 

opportunities and none of the loop routes requested by motorized advocates. Indeed, many forest 

visitors currently walk the route. Additionally, the seeps, 3 springs and watercourses that are 

impacted by the route flow into the Horton Research Natural Area. Why is the agency willing to 

place the route’s unique botanical, hydrological and cedar resources at-risk to re-open a currently 

impassible route for which there exists no real need? We asked that question in our 2012 scoping 

comments and we ask it again now. Page 3 of the DEIS indicates that unauthorized routes can only 

be added to the NFTS when they have a high recreational value and do not pose resource concerns 

that cannot be “readily mitigated.” Route 305.118 clearly does not meet that criteria. The 

recreational value it provides can be enjoyed by all who are willing to walk the route and the 

resource concerns of opening it to motorized travel are significant and (in the case of Port Orford

Cedar) irreversible.

819 51 The botanical “analysis” of impacts to roadless values on page 323 of the DEIS simply ignores the 

information and photos submitted by the public regarding 305.118. See photo attachments 8-11.

819 74

The agency’s reliance on “gating” to prevent spread of POC disease from route 305.118 was 

misplaced and lacked support or analysis. This is particularly troubling given that the route also 

traverses just uphill/upstream of the Horton Research Natural Area. We are very disappointed that 

the Forest Service refuses to consider decommissioning this unneeded route despite the potentially 

huge impacts to significant environmental resources. Permanent road closure is the only reliable 

method of reducing the spread of POC root disease, and should be prioritized in all uninfected 

stands and watersheds. Jules and Kauffman (2003) wrote that: Permanent closure of logging roads 

is by far the most direct and effective way to stem the spread of P. lateralis. There has never been 

much disagreement about the efficacy of this management strategy, given the clear association of 

the disease with road vectors. The general thinking has been that large uninfected and roadless 

watersheds would remain free of the pathogen, so long as they remain free of roads. Our research 

findings have been in agreement with this assumption.

828 10

It is insincere to claim no impact to designated botanical areas because motorized trails are outside

such areas, but then place motorized use on Route 305.118, which parallels the boundary of L.E. 

Horton Area and crosses drainages into the area.

819 54

The contention on page 330 of the DEIS that the routes under consideration for addition to the 

NFTS within IRAs “are part of the existing condition” is simply not accurate. As reflected by photos 

submitted to the agency by our organizations, full size off road vehicles cannot currently utilize 

sections of 305.118 proposed for permanent motorized use.
Appendix G. Response to Comments 

Final Environmental Impact Statement – Appendices – 243

Letter 

Number

Comment 

Number Comment Text

819 80

In A Field Guide to Serpentine Plant Associations and Sensitive Plants in Northwestern California 

(USDA, Pacific Southwest Region R5-ECOL-TP006) Forest Service scientists write that: Port Orford 

cedar is commonly found in association with many rare species. The L.E. Horton Research Natural 

Area Ecological Survey (Keeler-Wolf 1986) and results of rare plant surveys in bogs commonly found 

surrounded by Port Orford cedar plant communities revealed Siskiyou Indian Paintbrush (Castilleja 

miniata) California pitcher plan (Darlingtonia californica), Waldo gentia (Gentiana setigera), great 

burned (Sanguisorba officianalis) and western bog violet growing in association with one another. 

Loss of Port Orford cedar, as the primary associating conifer, could lead to the cumulative loss of the 

rare species associated with wetland communities. The distinctiveness of serpentine environments 

and the high concentration of rare flora warrant special management considerations.

Response: This route was identified by Del Norte County and the Sheriff’s office as important access to 

the North Fork of the Smith River for search and rescue teams. In response to the competing needs for 

emergency access and careful management of resource values, Alternatives 4 and 6 would designate and 

seasonally gate the first 0.80 miles as motorized trail, while the segment from milepost 0.8 to 1.56 on 

which the Darlingtonia bog shown in the referenced in comments by Barbara Ullian as photographs 8, 9, 

10, and 11 occurs and much of the uninfected POC along this route grow, is not proposed for designation 

on the NFTS and is proposed to be barricaded. The UARs that cross the L.E. Horton Research Area 

would barricade at the beginning of the route 

Health and Safety 

Fire Events and Suppression

Letter 

Number

Comment 

Number Comment Text

50 3 Furthermore, allowing increased activity of this type increases the possibility of accidental wildfires, 

at expense to us all.

804 1 

My reasons against any road closers 1. Restricts ability of wildland firefighting and search and 

rescue to perform their jobs to save our forest and all the people who get lost in the forest and need 

to be rescued.

824 5 

The lack of management resulted in devastation due to fires already. The approach of: closures and 

hands off management is not working. You must take a hard look at the closures and open these 

ways, routes and trails back up to motorized vehicles. Slow moving traffic over time creates a 

firebreak and access for suppression of fire and weeds.

Response: The NRA fire personnel evaluated the entire road system during the RAP and reviewed it again 

during this process to determine access needs in relation to such factors as fire-fighter safety, cost efficiency 

(quicker, easier access), proximity to private land, fuels treatment areas, difficulty of the terrain, etc. The 

primary access roads/routes to specific areas were identified which will allow prompt and successful initial 

attack. All emergency access, including fire suppression, search and rescue, and law enforcement actions, is

legally authorized to go wherever needed, whether it is designated on the transportation system or not. This 

provision, found in 36 CFR 261.13, lists the many exceptions to the prohibitions. 
Appendix G. Response to Comments 

244 – Smith River National Recreation Area Restoration and Motorized Travel Management

Letter 

Number

Comment 

Number Comment Text 

819 112

On a more general level, the SNEP Report, the ICBEMP report and the Roadless Area

Conservation Rule EIS all indicate that most human-caused fires (the majority of ignition sources in 

many areas) are located near roads, so roads are places where more fires are started than are 

stopped. Previously, the Smith NRA initial EA contended (page 56) that “roads can be an

impediment to fire spread at low fire intensity levels by acting as fuel breaks” while failing to 

acknowledge that the fire-evolved, fire-dependent forests of the Smith NRA are in dire need of “fire 

spread at low fire intensity levels” and that roads (or fuel breaks in general) are simply not effective 

against high intensity fires under extreme conditions which are the kind of fires that the Forest 

Service should in fact be concerned about. Please respond to the peer-reviewed findings contained 

in the article Fuelbreaks for Wildland Fire Management: A Moat or a Drawbridge for Ecosystem Fire 

Restoration by Dr. Timothy Ingalsbee.

Response: As stated in the EIS, although some authors such as Inglesbee question the use of fuelbreaks 

in the article Fuelbreaks for Wildland Fire Management: A Moat or a Drawbridge for Ecosystem Fire 

Restoration, others have found that fuel breaks have been effective (Agee, Skinner 2005: Jimerson and 

Jones 2000) including fuel breaks constructed on Six Rivers. Agee (2000) concluded that “a welldesigned fuel break will alter the behavior of wildland fire entering the fuel-altered zone. Both surface 

and crown fire behavior may be reduced. Shaded fuel breaks must be created in the context of the 

landscape within which they are placed. Landscape-level treatments such as prescribed fire can use 

shaded fuel breaks as anchor points, and extend the zone of altered fire behavior to larger proportions of 

the landscape. Therefore, reducing surface fuels, increasing the height to the live crown base, and opening 

canopies should result in (a) lower fire intensity, (b) less probability of torching, and (c) lower probability 

of independent crown fire.” 

Letter 

Number

Comment 

Number Comment Text

819 136

Significant road access is provided to Smith River RNA forests via the Level 3, 4, and 5 roads that 

are not at issue in this analysis process. Even if existing Level 3, 4, and 5 roads did not provide 

significant access to these watersheds independent of the status of Level 1 and 2 roads, there is 

compelling peer-reviewed literature indicating that the agency can and has engaged in effective fire 

suppression and fire management activities in unroaded landscapes. Attached to our May 2012 

scoping comments was a PDF of Volume 2 of the Spring 2001 issue of Fire Management. The 

peer-reviewed articles in this issue of Fire Management clearly establish that agencies do not need 

to retain user-created routes in roadless areas in order implement effective fire management 

strategies. As stated on page 298 of the DEIS “no major ridgetop or main access roads on the 

NFTS are proposed to be decommissioned from the NFTS or downgraded.” Hence, additional highrisk user-created motorized trails are not needed to provide effective fire suppression/exclusion. We 

again bring to your attention the conclusions on page 341 of the March 4, 2006 Draft Environmental 

Impact Statement (DEIS) for Oil and Gas Leasing and Roads Management for the Santa Fe 

National Forest that calls for significant road decommissioning in that Forest: The proposed road 

decommissioning would not create large isolated parcels of land, and an adequate number of open 

and closed roads would remain available for use when needed. There would continue to be an 

adequate road density in wildland-urban interface areas surrounding private lands, communities, 

water systems, and other infrastructure. It is important to note that the majority of the roads targeted 

for decommissioning are user-created and are not vital access roads. Many of the roads proposed 

for decommissioning are short spurs, duplicative, in poor condition, or are on steep slopes that 

would not likely be used by fire crew trucks and engines. Therefore, it would be unlikely that a fire 

would reach catastrophic proportions due to lack of access under the Proposed Action.

www.fs.fed.us/r3/sfe/projects/projects/oil-gas%20and%20roads/index.html. Just as with the road 

decommissioning authorized in the Santa Fe National Forest, the ML 1 and 2 roads in this Planning 

Area are not vital access roads and are primarily short spurs, duplicative, in poor condition or are on 

steep slopes and hence are not necessary for fire suppression (or fire management) activities. 

Thus, we encourage and support efforts to close these roads, as they are often a source of humancaused ignition, rather than a means for controlling fire events. Wildfire frequency and seasonality 

are related to road density; Noss (1995) cites several studies demonstrating that 78% of humancaused fires occur within 265 feet of a road. In his study of the effects of roads on wildfires in 

national forests in California, Robert F. Johnson concluded that over 52 percent of man-caused fires 
Appendix G. Response to Comments 

Final Environmental Impact Statement – Appendices – 245

Letter 

Number

Comment 

Number Comment Text

occurred within 33 feet of a road edge (Johnson, 1963). Other studies showed similar results, 

reinforcing the correlation between roads and wildfire (Show et al 1941; California Division of 

Forestry and USDA Forest Service, 1968). Given the importance of roads to the fire suppression

campaign, it is surprising that these studies, over 30 years old, are the most recent analyses of the 

road problem in fire control. Their results, if not conclusive on their own, indicate a possible causal 

relationship between human-caused wildfire and roads, and support the need for further research 

on the subject. Analysis of the 2000 wildfire season, for example, noted that all of the fire starts in 

the Skalkaho Valley Complex were in roaded and developed areas, which accounted for 93% of the 

total area burned (Morrisson et al 2000). Increased attention to data of this kind is needed to 

adequately assess the extent of the impact of roads on wildfires. Please note that page 294 of the 

DEIS acknowledges that “human ignitions [near roads] have accounted for the largest number of 

ignitions of wildfire for the past 34 years of fire history on the Smith River National Recreation Area.” 

Response: We reviewed the spring 2001 issue of Fire Management you provided and although the article 

is specific to fighting fire in Roadless Areas, we found that the issues raised in the article were similar to 

the criteria used by the NRA fire personnel to evaluate the road system, which led to removal of roads 

across the district. The NRA fire personnel evaluated the road system during the Smith River NRA RAP 

and reviewed it again during this TM process to determine access needs in relation to such factors as firefighter safety, cost efficiency (quicker, easier access), proximity to private land, fuels treatment areas, 

difficulty of the terrain, etc. All action alternatives will reduce road density across the district. The terrain 

on the NRA is steep, rocky, and very brushy. Cross-country travel is very difficult. The NRA fire 

personnel evaluated the road system during the RAP and reviewed it again during this process to 

determine access needs in relation to a variety of factors to safely and efficiently respond to wildland fire. 

Roads proposed to be kept are the primary access roads (regardless of OML) to specific areas. Duplicate 

roads would be removed wherever possible. Closing high-need roads would limit access for resources 

such as engines and hand crews. This could increase the time it takes to respond to an unwanted wildfire 

and lead to larger fires, decreasing fire fighter safety and increasing resource damage. It could also require 

the use of more resources than if better access allowed prompt and successful initial attack. This could 

contribute to a larger fire size and higher operation costs. As stated in the EIS, recent fire records show 

human caused fires tend to cluster along major highways, county roads, OML 3, 4, and 5 roads, and near 

communities and developed campgrounds. Human causes have accounted for the largest number of 

ignitions of wildfire for the past 34 years of fire history on the Smith River NRA; however, lightning 

occurs frequently throughout the forest, often with multiple ignitions from the same storm, and is 

responsible by far for the greatest number of acres burned for the past 34 years (EIS). Access is needed to 

safely and efficiently respond to wild land fires on the NRA. 

Search and Rescue Operations

Letter 

Number

Comment 

Number Comment Text

804 1 

My reasons against any road closers 1. Restricts ability of wildland firefighting, and search and 

rescue to perform their jobs to save our forest and all the people who get lost in the forest and need 

to be rescued.

855 3 Need to keep routes open for search and rescue operations.
Appendix G. Response to Comments 

246 – Smith River National Recreation Area Restoration and Motorized Travel Management

Letter 

Number

Comment 

Number Comment Text

806 7 

All that said, I would like to rebut two of the especially absurd arguments often used by the off-road 

vehicle crowd. A representative example of the first is by Dean Wilson, the Sheriff in Del Norte 

County. Wilson has a well-earned reputation for using his position as the armed leader of this 

county’s sheriff’s department to further his own political and social agenda. His frequent use of his 

armed position for political purposes is as intimidating as it is socially destructive. Now to his 

argument: Wilson has, as reported by The Triplicate, “often said that closing any of the roads in the 

Six Rivers National Forest wou1d endanger public safety by making it more difficult for search and 

rescue operations or for targeting off-the-grid criminal activities.” His statement is close to 180 

degrees from reality. The truth is that roads and motorized activity can facilitate criminal activities 

and provide access to otherwise remote wild areas for the purposes of illegal dumping, 

methamphetamine production, marijuana gardens, fish and wildlife and tree poaching, wildfire 

arson, and illegal target shooting. Closing roads would decrease criminal activity and increase 

public safety. And so far as search and rescue operations, on the chance that any of these closed 

roads are needed for one of these operations, the Forest Service would most likely immediately reopen the road for that purpose.

806 8 

The sad part is that Dean Wilson knows all of this, but he nonetheless continues to push for more 

illegal access. I need to remark further that opening up more remote access will facilitate more 

visitors becoming lost, or having ORV accidents in the back country, or running out of fuel, or some 

other problem that necessitates search and rescue operations. So, far from increasing public safety, 

opening up more roads will decrease public safety, including for search and rescue personnel. An 

example of the second position I would like to rebut is a comment by Jim Pofahl, president of the 

off-road vehicle club North Coast Cliffhangers, who said, “Just because they didn’t recognize the 

[unauthorized routes, or UARs] doesn’t mean that the public didn’t recognize them as a road to get 

somewhere, and if you take that away from them how do you get to the campsite that you’ve been 

going to since you were 19 years old?” 

Response: As part of the Travel Management process, the forest is required to coordinate with local 

governments. As part of this process, the forest has sought input from the Del Norte County Sheriff’s 

office on safety issues that the forest should consider in the revision of the NFTS. The NRA fire 

prevention staff evaluated the entire road system during the Smith River RAP and reviewed it again in the 

preparation of this TM EIS to determine access needs in relation to such factors as fire-fighter safety, cost 

efficiency (quicker, easier access), proximity to private land, fuels treatment areas, difficulty of the 

terrain, and fire start history by location. The primary access roads and UARs to specific areas were 

identified which will allow prompt and successful initial attack for fire suppression. All emergency 

access, including fire suppression, search and rescue, and law enforcement actions, is legally authorized 

to go wherever needed, whether it is designated on the transportation system or not. This provision, found 

in 36 CFR 261.13, lists the many exceptions to the prohibitions. By providing a more clearly defined 

NFTS, it is anticipated that the likelihood of motorists getting lost on the NFTS to the point of requiring 

Search and Rescue assistance would be reduced. A route-by-route review and response to Del Norte 

County’s Search and Rescue recommendation is provided.

Illegal Activities

Legitimizing Illegal Activities

Letter 

Number

Comment 

Number Comment Text

805 10

If the Six Rivers staff allows ORV use as called for in the current proposal, especially that which 

teaches the pernicious lesson that lawless off-trail use will be retroactively legitimized, then this 

corrosive ORV use will further metastasize. 
Appendix G. Response to Comments 

Final Environmental Impact Statement – Appendices – 247

Letter 

Number

Comment 

Number Comment Text

605 5 

In Six Rivers NF and other adjacent NF areas, I have witnessed and observed the ORV intrusion of 

the last decade especially. By roading anywhere, your agency has been a part of the problem of 

illegal and destructive use.

805 1 

I write to urge you to adopt a travel/motorized recreation plan for the Smith River National 

Recreation Area that addresses the incessant and intense damage inflicted by off-road vehicles. I 

am deeply disturbed that the Six Rivers NF staff appear prepared to retroactively legalize the blatant 

violations of ORV enthusiasts, and effectively reward their impunity with new official map 

designations for gashes on the landscape they have created.

843 1 

I am disappointed in your web site in that it is hard to find the most current management plans so I 

can do a timely comment. As a resident of Illinois Valley, I live close to the Gasquet District. I also 

see firsthand the destruction OHV use on our public lands from erosion, invasive species, and the 

all-out destruction of plants. OHV users should not be rewarded with new road routes created by 

OHV users. I have lived in the area for 40 years and the damage from off road use has just 

multiplied. Plus there is little enforcement. Our national forest lands should not be turn into 

motorized amusement park.

263 2 

I am deeply disturbed that the Six Rivers NF staff appear prepared to retroactively legalize the 

blatant violations of ORV enthusiasts, and effectively reward their impunity with new official map 

designations for gashes on the landscape they have created.

263 4 

Moreover, the NRA and the adjacent lands of the Six Rivers National Forest already provide 

hundreds of miles of marked roads, more than any human being could sanely request as a 

reasonable recreational allocation. For the Forest Service to hand over and legitimize more gashes 

in the Earth, marked officially as ‘roads,’ would constitute a gross dereliction of Forest Service duty 

to reasonably balance public values, and to enforce the policies administering that balance against 

those who would drive over it with impunity.

263 7 

If the Six Rivers staff allows ORV use as called for in the current proposal, especially that which 

teaches the pernicious lesson that lawless off-trail use will be retroactively legitimized, then this 

corrosive ORV use will further metastasize. Forest Staff will discover a new network of rogue trails 

inviting another recreational plan a decade from now, if its authority to control ORV use is not 

demarcated today.

263 8 The new plan must not legitimize illegal routes deep into the backcountry, far from classified system 

roads and therefore unlikely to receive monitoring or attention from the Forest Service.

Response: The 2009 MVUM displays the designated NFTS open for motorized use. In 1990, the Smith 

River NRA limited motorized travel to designated routes on the NFTS, whereas other districts and forests 

were open to cross-country motorized travel. In 2005, the Travel Management Rule established and 

required the use of Motor Vehicle Use Maps (MVUM) to display the designated NFTS open to motorized 

travel. The current MVUM for the Gasquet Ranger District (Smith River NRA) reflects the status of 

NFTS roads and motorized trails in the forest’s transportation database at the time of publication in 2009. 

Many UARs on the Smith River NRA are not the result of off-road recreationists, as the terrain in many 

parts of the Smith River NRA itself limits this, but rather they are old mining roads or logging roads on 

lands that were previously privately owned. 

Project Effects on Illegal Activities

Letter 

Number

Comment 

Number Comment Text

805 10 Forest Staff will discover a new network of rogue trails inviting another recreational plan a decade 

from now, if its authority to control ORV use is not demarcated today. 

805 11

Allowing an atmosphere of lax supervision and impunity tends to encourage the worst in human 

behavior, in forest recreation as in any other realm of humanity. ORV use should be directed onto a 

finite number of clearly marked and mapped routes that can be policed and enforced with 

reasonable frequency given the staff time available. The plan must establish a clear, unambiguous, 

blanket prohibition on any off-route, cross-country travel with civil fines commensurate with the level 

of resource damage this causes, and sufficient to meaningfully deter willful violators.
Appendix G. Response to Comments 

248 – Smith River National Recreation Area Restoration and Motorized Travel Management

Letter 

Number

Comment 

Number Comment Text

605 5 

In Six Rivers NF and other adjacent NF areas, I have witnessed and observed the ORV intrusion of 

the last decade especially. By roading anywhere, your agency has been a part of the problem of 

illegal and destructive use.

819 123

NEPA requires the Forest Service to disclose and analyze the environmental impacts of foreseeable 

increased illegal off-road use as a consequence of the Proposed Action designating routes as 

“motorized trails.” The NEPA document must adequately analyze and disclose the management 

implications and impacts to resources from the maintenance backload for ML 1 and 2 roads and for 

user-created routes.

819 126

Failure to Analyze and Disclose Impacts of Foreseeable Illegal Off-Road Use It is essential that the 

Forest Service analyze and disclose the foreseeable connected action of illegal off-road use that will 

be facilitated by the Proposed Action as required by NEPA. The agency has contended that “off 

road use is illegal on the NRA; therefore it is not a reasonably foreseeable future action that can be 

analyzed with predictable cumulative effects.” This is a cop-out. Off-road use has been prohibited by 

the Smith NRA Act since 1990, yet it proliferates across the landscape. This is an indisputable fact. 

Please note that in our Pappas Flat comments (below) we provide specific examples of illegal offroad use that are both foreseeable and predictable.

255 11

The Smith River federal lands already have way more roads tangled through the woods than are 

needed, than can be maintained and that can be law enforcement patrolled. These roads really aide 

various outlaw individuals like drug cartels, dopers and cross country off-road vandals. Laxity on 

these folks degrades the forests for the vast majority of Americans.

263 8 

Allowing an atmosphere of lax supervision and impunity tends to encourage the worst in human 

behavior, in forest recreation as in any other realm of humanity. ORV use should be directed onto a 

finite number of clearly marked and mapped routes that can be policed and enforced with 

reasonable frequency given the staff time available. The plan must establish a clear, unambiguous, 

blanket prohibition on any off-route, cross-country travel with civil fines commensurate with the level 

of resource damage this causes, and sufficient to meaningfully deter willful violators. The plan must 

also set about the critical task of either repairing or closing and revegetating the backlog of old, 

unmaintained roads and trails. This is the first task to achieve before the Forest Service even 

considers opening new routes or watersheds and magnifies its enforcement challenges beyond its 

already deficient management capacity. Although I am certain that the majority of ORV users do not 

willfully destroy forest resources, there is a non-negligible fraction of truly impudent ORV users who 

play with utter disregard for soil and vegetation.

826 10

For good reason the proposed plan is very concerned with the preservation of water quality within 

the various watersheds of the Smith River. However, the Forest may create unintended 

consequences in its plan for closing roads by way of the inadvertent promotion illicit outdoor 

marijuana cultivation, which is occurring across the United States at an increasing rate (Frye, Bob. 

“Pot farms in forests a growing problem.” Pittsburg Tribune Published August 26, 2013.) Based on 

discussions with staff of regional resource agencies it would seem to be naive to believe that 

barricading or otherwise closing off access would have any practicable effect upon these criminal 

activities. The ability to set up a “grow” in a secluded, difficult to access area is quite often viewed 

as a desirable feature for illicit outdoor marijuana cultivation as it makes the detection and 

apprehension of such criminal activity challenging for law enforcement personnel while also creating 

potentially dangerous situations for hikers, kayakers, mountain bikers, etc. who venture into these 

roadless areas. Perhaps most significant, to the goal of preserving water quality, outdoor marijuana 

cultivation is highly dependent on access to significant amounts of water which has led to stream 

diversions, sedimentation, point source pollution, and other adverse impacts on water quality in 

areas, not far from Del Norte County, where marijuana cultivation has been increasing at an 

alarming rate (Trinity County, Humboldt County, etc.). As such, barricading and decommissioning 

roads (which will surely not deter the criminally inclined) should be reserved as a last resort for 

roads rather than the default option, which appears to be the case under most presented 

alternatives in the plan.

Response: It is assumed that any of the action alternatives provide designated motorized recreation 

opportunities that are clearly defined parts of the NFTS (e.g., signing designated roads and motorized 

trails, while barricading closed and decommissioned roads, and UARs not added to the NFTS), and that 

this would reduce the likelihood of intentional or unintentional illegal cross-country motorized travel. Any 

type of barricade, closure device, or gate should not be assumed 100 percent effective at preventing illegal 

cross-country travel. However, these devices are an effective deterrent to unintended illegal cross-country 

travel, meaning travel that occurs off the NFTS because the designated NFTS is not clearly defined on the 
Appendix G.Response to Comments 

Final Environmental Impact Statement – Appendices – 249

ground. By providing a more clearly defined NFTS. Illegal acts are neither reasonably foreseeable events 

capable of NEPA analysis and are beyond the scope of this proposed action. 

The Travel Management process cannot analyze or predict illegal activities. However, one goal of this 

Travel Management process is to provide an NFTS network that would be signed adequately and help 

curtail illegal use, and provide a mechanism to allow enforcement citations for any illegal use. All action 

alternatives include physical deterrents to motorized travel off the NFTS, some of which were developed 

in response to known sites specific issues. The analysis of the no action alternative, Alternative 1, reflects 

the environmental consequences associated with doing nothing. Known risks to resources will be factored 

into the analysis and reflected in the environmental consequence resource sections of Chapter 3.

Enforcement Capabilities

Letter 

Number

Comment 

Number Comment Text

821 3 

Our tea party sheriff is not going to patrol these roads to help make law-abiding hikers safe. Our 

county supervisors are not going to authorize funding to maintain USFS roads. That will be Your 

Job and taxpayers will have to pay! Kind of ironic for these folks that don’t believe in taxes!

833 4 What we need is careful strong protection management planning and enforcement of this public 

trust not planned abuse

819 94

We believe that the Forest Service may be incapable of accomplishing the needed mitigations and 

law enforcement necessary to protect resources from significant impacts that are the direct result of 

keeping so many proposed roads open to vehicles.

819 95 Please provide documentation regarding the capability for adequate law enforcement.

805 13

Although I am certain that the majority of ORV users do not willfully destroy forest resources, there 

is a non-negligible fraction of truly impudent ORV users who play with utter disregard for soil and 

vegetation. Six Rivers staff must be willing to cite and ticket violators on sight, in order to segregate 

the criminals from the responsible recreationists whose reputation is unjustly tarnished by the 

former. The new plan should also include rewards for photographic documentation of off-route 

violations, so that citations may remain a substantial deterrent even for those violators who avoid 

the scarce and occasional USFS ranger.

255 5 Keep vehicles on established roads; roads that Forest Service can afford to maintain and patrol 

better than they have.

805 10 The new plan must not legitimize illegal routes deep into the backcountry, far from classified system 

roads and therefore unlikely to receive monitoring or attention from the Forest Service.

825 5 

April 2011 Comments Incorporated by reference:

Re motorized trail use: we feel there is a critical need for increased enforcement and monitoring re 

illegal use of closed routes and off-route travel – particularly at specific sites. Pine Flat is a prime 

example. We support increased investment in signage, education, enforcement, and monitoring re 

safe and legal motorized use of routes. As we discussed during the collaboration, these investments 

are essential to managing motorized trail use.

As discussed during the collaboration, we believe site-specific standards and thresholds need to be 

established whereby if there are violations of these standards and thresholds – then the Smith River 

NRA must be able to take corrective action. Therefore, there will be consequences where there is 

continued illegal activity. We recommend that “action” include closing and curtailing use in those 

areas where illegal use and environmental damage is occurring. Thus, we can agree to motorized 

use in specific areas, but we require there be 1) additional resources secured and used to 

implement monitoring and enforcement; and 2) consequences (including closure), if there is 

continued illegal activity as determined by monitoring and enforcement at sensitive sites.

263 8 

Six Rivers staff must be willing to cite and ticket violators on sight, in order to segregate the 

criminals from the responsible recreationists whose reputation is unjustly tarnished by the former. 

The new plan should also include rewards for photographic documentation of off-route violations, so 

that citations may remain a substantial deterrent even for those violators who avoid the scarce and 

occasional USFS ranger.

Response: It is anticipated that by providing for motorized recreation opportunities that are clearly 

defined through signing roads and motorized trails, while also barricading UARs, closed and 
Appendix G. Response to Comments 

250 – Smith River National Recreation Area Restoration and Motorized Travel Management

decommissioned roads that unintended illegal use will be deterred. In addition, the Gasquet Ranger 

District has a law enforcement officer, 3 fire prevention patrols, and a road manager who serve as forest 

protection officers (FPOs) and have citation authority, and 1 permanent Recreation Officer, and typically 

two seasonal recreation technicians are employed in the spring through the fall, all of whom will also 

monitor use and compliance. The forest also has a Cooperative Agreement with the Del Norte County 

Sheriff’s Office that, that provides for the Sheriff’s Office patrol of “roads designated and maintained by 

the Forest Service within the Cooperator’s (Sheriff’s) jurisdiction.” Civil fines are currently in place for 

damage caused by motorized resources. Two examples are CFR 261.15(h) – $250 in the Northern District 

of California, and 261.12(c) – $100 in the Northern District of California. For more information on 

Resource Monitoring, see Appendix B of the EIS. 

Naturally Occurring Asbestos

Letter 

Number

Comment 

Number Comment Text

846 15

The DEIS states that asbestos-bearing ultramafic rock occurs throughout the Smith River NRA, 

including many of the unauthorized routes proposed for addition to the NFTS. EPA notes that the 

Forest performed laboratory testing on material taken from the road surface of 27 of these 

unauthorized routes and found that the majority of these routes contained NOA and six of the 27 

contained concentrations in excess of 0.25 percent (p. 279). Asbestos levels even less than 0.25 

percent in soil can generate airborne asbestos at hazardous levels. The DEIS states that there are 

no plans to conduct additional laboratory work to determine the content of asbestos on the 

unauthorized routes that have not yet been tested. EPA notes that the DEIS states that for all routes 

with the potential to contain NOA, the Forest will inform the public of the risk of potential exposure 

on these roadways, impose reduced speed limits in these areas, and provide signage to these 

effects along these routes. Recommendations: EPA recommends that the FEIS expand upon the 

NOA analysis provided in the DEIS. For those routes where laboratory testing has found the 

roadway to contain NOA, or for routes suspected to contain NOA, we recommend that background 

asbestos concentrations in the air be determined, based on proper sampling protocols, and 

disclosed in the FEIS. We refer you to EPA Region 9’s asbestos web page at 

http://www.epa.gov/region9/toxic/noa/ and the California Air Resources Board’s (CARB) asbestos 

web page at http://www.arb.ca.gov/toxics/asbestos/asbestos.htm for useful information on NOA, 

including air monitoring.

806 10

Many mining UARs are either of native surfaces or paved with mine waste, containing high levels of 

asbestos and heavy metals. Further, several ORV deaths have occurred in the last decade on/off 

these UARs, specifically in the North Fork Smith area.

823 4 

I think the only way you’re going to keep an irresponsible OHV rider from straying off designated 

routes is to have either thick vegetation and/or very steep slopes on both sides of the trail. Then 

there is the problem of airborne asbestos--I think it is highly unlikely that OHV riders will observe 

posted speed limits to keep the dust down. The snarl of motorized trails proposed for the Gasquet 

Mountain area in alternatives 3, 4, and 6 look like they could eventually turn into one big dust bowl 

with heavy OHV use.

Response: Forest staff is aware of the presence of ultramafic bedrock, both in natural outcrops and as 

used in the past for road surfacing in many areas and on many routes in the project area. The forest has 

tested and confirmed the presence of chrysotile asbestos in some areas where ultramafic rock occurs. 

While asbestos may be present wherever ultramafic rocks are situated, its distribution may be highly 

variable even in samples taken in close proximity to one another. The known risks associated with 

naturally occurring asbestos (NOA) are described and information is provided for the user to assess and 

mitigate the hazards while recreating, however there are no known deaths due to NOA exposure that have 

been identified by anyone consulted in the preparation of the EIS. 
Appendix G. Response to Comments 

Final Environmental Impact Statement – Appendices – 251

As stated in the EIS, the SRNF will provide information to the public on the potential for the presence 

of NOA in areas underlain by ultramafic bedrock. This approach has been established by the regional 

forester’s letter to forests on February 11, 2009, in which he directs forests to make the public aware of 

the potential risk of NOA and its presence on national forest lands as well as provide guidance on how 

visitors can reduce their exposure to the substance. Asbestos sampling conducted to date has proved 

inconclusive regarding the distribution of asbestos concentrations on proposed routes, with substantial 

variation between closely spaced samples, reflecting an observed scattered distribution of asbestosbearing outcrops. It is anticipated that additional sampling, including background airborne asbestos 

concentration sampling, would not provide additional meaningful data regarding the levels of asbestos 

exposure that might be encountered during motorized recreation, or the degree of risk associated with that 

exposure. As US EPA has acknowledged, per the Regional Forester’s letter of direction, “the scientific 

assessment and identification of actual public health risks associated with NOA is a complex and time 

intensive process. Until such studies are performed, the Region will not have definitive information 

regarding actual employee and public health risks posed by NOA on national forest lands.” At present, the 

science regarding the public health risk from recreational exposure to naturally occurring chrysotile 

asbestos, as is found in the project area, is not conclusive. It is beyond the scope of this EIS to conduct 

new scientific studies to definitively determine the level of risk present and the associated protective 

measures necessary to eliminate that risk. Rather, the SRNF can best serve and protect the public by 

providing 1) information sufficient to inform people of the potential presence of asbestos; 2) resources to 

provide access to further information on the topic; and 3) guidance on best practices to reduce or 

eliminate exposure. In so doing, the forest has met the obligation to inform the public of potential hazards, 

while allowing the public to make informed decisions regarding the level of risk they are willing to 

accept, to the degree that present scientific knowledge and existing data regarding asbestos presence and 

associated hazards will allow. 

Letter 

Number

Comment 

Number Comment Text

846 19

Furthermore, we recommend that the FEIS discuss: The potential for releases of asbestos minerals 

to soils and surface waters from ground disturbing activities, such as road decommissioning and 

restoration work, as well as from OHV use upon these routes. The potential for indirect exposure to 

others outside the project area from “track out” from contaminated vehicles, equipment, and clothing 

transported off the project site. Measures that would be implemented to protect human health during 

project work, including OSHA requirements that would apply to workers, and measures to prevent 

track out (e.g., vehicle wash rack). Measures to prevent releases of asbestos minerals from 

disturbed areas and roads to soils and surface waters. And air monitoring measures during the 

project, including those for asbestos.

Response: While some naturally occurring asbestos may be released to soils and surface waters when 

project-related activities are implemented or during public recreational use, there is no reason to believe 

that such releases would detectably increase the level of hazard associated with NOA. The only known 

health hazard associated with NOA is related to inhalation of fugitive dust, and NOA that is contained in 

soil or suspended in water presents no known health hazard. If NOA released during ground disturbance 

were to become airborne, either in situ or after transport off-site, it could then pose a health hazard. 

However, the on-site release of asbestos is already analyzed in the EIS re project activities and 
Appendix G. Response to Comments 

252 – Smith River National Recreation Area Restoration and Motorized Travel Management

recreational use. While it is possible that some quantity of asbestos-bearing dust could be transported 

offsite following visits to portions of the project area where ultramafic geology predominates and NOA 

may be present in surface materials, risk of exposure to inhalation of such dust can be mitigated by 

informing the public of the potential presence of NOA and of ways to reduce that risk, including ways to 

reduce the quantity of dust carried out of the area and clean-up methods that will reduce the risk of 

indirect dust exposure. Relevant information useful in mitigating exposure may be found in the Region 5 

web resources to which the public is directed. In addition to directing the readership to the appropriate 

websites, a list of the suggested mitigations is included in the EIS. Appropriate mitigations to reduce 

health hazards from asbestos exposure are mandated by OSHA and other regulatory bodies, including the 

California Air Resources Board (CARB). The CARB Asbestos Toxic Control Measures (ATCMs) for 

construction would apply to project activities such as road decommissioning. In general, these measures 

include dust abatement and control, vehicle speed limits, and dust track-out prevention and removal. 

OSHA provides no regulations specific to NOA, but suggests that local regulations, such as the provisions 

of the CARB ATCMs for wetting of excavations and materials, should be effective in controlling 

exposure (29 CFR Parts 1910, 1915, and 192, OSHA final rule, Occupational Exposure to Asbestos, 

1994). Additionally, the Six Rivers National Forest has a job hazard analysis (JHA) specific to hazardous 

dust exposure that includes much of the known information regarding NOA and exposure hazards, and 

specifies a number of abatement actions that would apply to any Forest Service employees’ job-related 

activities in areas with potential for NOA. If personal air monitoring is recommended or required for 

project work under safety regulations such as OSHA or the CARB ATCMs, then the requirements and 

applicable regulations will be included in any project implementation guidelines, such as contract clauses 

and job hazard analyses. As stated above, there is no known health hazard from asbestos in soil and water. 

There is an EPA standard for asbestos concentrations in drinking water; however, it is not anticipated that 

project activities or motorized travel will release asbestos in sufficient quantity to raise asbestos levels in 

any known drinking water source above EPA thresholds. Consequently, no measures to prevent release to 

soil and water are deemed necessary, except where there is likelihood that such releases could generate 

airborne dust to present an inhalation hazard, such as on paved roadways adjacent to construction sites.

CARB ATCM provisions to prevent dust track-out on paved roads will be followed to minimize this 

possibility. The EIS discusses these points.

Letter 

Number

Comment 

Number Comment Text

846 16

We recommend that the FEIS contain more detailed maps of the location of known and probable 

NOA. While the DEIS contains such a map at page 280, it is of a low resolution and would not serve 

to sufficiently inform a potential recreational user of the location and extent of probable NOA hazards.

Response: The included map displaying the distribution of ultramafic bedrock is small-scale (1:250,000) 

and of relatively low resolution. The geologic data displayed are a compilation of all known geologic 

mapping in the area, performed at a variety of scales, and represent the best available mapping for the 

region. The scale of mapping in general does not provide useful detail at scales greater than 1:24,000 at 

best, and no better than 1:250,000 in some areas. Nor is the EIS itself intended to provide visitor 
Appendix G. Response to Comments 

Final Environmental Impact Statement – Appendices – 253

information regarding travel routes and any associated hazards. Rather, once the travel system is 

finalized, visitor information will be made available in the form of an MVUM, and other relevant 

information, including NOA maps, will be made available at visitor service locations. Per the Regional 

Forester’s direction of February 11, 2009, public awareness of the presence, distribution potential hazards 

and best practices to reduce exposure to NOA is to be enhanced by making available a NOA fact sheet 

and maps of known or potential NOA distribution on the various Forest Service administrative units. This 

information is available at all Forest Service visitor information locations in the Region, and on the 

Regional website. A reference to the web address to access this information (www.fs.fed.us/r5/noa/) will 

be included in the FEIS. The NOA maps provided at these locations for the Six Rivers National Forest 

display the same data regarding ultramafic geology that are displayed in the map in the EIS. Future 

signage and information directed at the recreating public will also refer to these sources so that the public 

may be informed on the topic. 

Implementation 

Monitoring

Letter 

Number

Comment 

Number Comment Text

819 33

Curiously, page 6 of the Scoping Report states that “monitoring plans that apply to the proposed 

action and all the alternatives considered in detail will be more fully developed in the EIS.” This is in 

fact not the case. Rather, the monitoring “plans” are if anything less developed in the DEIS. 

However, page 565 of the DEIS confirms that at most 20% of the high risk routes to water resources 

will be monitored annually for at most the first 10 years of implementation and that “monitoring is 

predicated on available funding.” 

Response: The POC and botany monitoring plans located in Appendix B of the EIS is revised to reflect a 

more robust monitoring regime to comply with the parameters outlined in the EIS. 

Botany

Letter 

Number

Comment 

Number Comment Text

819 35

Unfortunately, the Botanical Resources Monitoring Plan is even more arbitrary and capricious. 

Despite the fact that one of the “primary goals” of Congress in establishing the Smith River NRA 

was “to emphasize, protect and enhance the unique biological diversity” of the NRA, the proposed 

action Botanical Resources Monitoring Plan simply writes off up to 10% loss of rare and endemic 

plants to ORV damage as a “green condition” indicating that resource objectives are being met on 

designated routes. Does the agency contend that the foreseeable loss of up to 10% of rare and 

endemic plants to user-created routes really emphasizes protection and enhancement of the area’s 

unique biological diversity? Such an approach threatens violation of the California Native Plant

Protection Act. Further, page 67 of the Scoping Notice indicates that the proposed action will allow 

for loss of up to 20% of rare plants over a 5-year period. Why is the codification of extreme 

motorized recreation in the NRA more important to the Forest Service than the protection of the 

unique and irreplaceable botanical legacy for which the NRA was designated? Why is the agency 

advocating for the loss of up to 19% of rare plants located near user-created routes in the NRA? 

Why would the proposed “monitoring” end after a mere 9 years? The DEIS addresses none of these 

questions despite their being raised in the scoping period for this project. Yet page 16 of the DEIS

acknowledges that “monitoring is critical for evaluating the effectiveness of management designs 

and the accuracy of analysis assumptions and conclusions.” 
Appendix G. Response to Comments 

254 – Smith River National Recreation Area Restoration and Motorized Travel Management

Letter 

Number

Comment 

Number Comment Text

819 31

It appears that the Forest Service is contending that it can evade the intent and requirements of the 

Smith NRA Act to preserve, protect, and enhance botanical and 5 hydrological values through 

“monitoring” of the inevitable and foreseeable damage that codified motorized use of “high risk” 

routes will facilitate.

Response: The project proposes to monitor use to prevent a trend toward a loss of viability. Sensitive 

plant populations within 100 feet of UARs added to the NFTS will be managed via monitoring to 

determine if a decline in Sensitive plant populations has occurred. If a decline of any Sensitive plant 

population is found to have occurred that indicates a trend toward a loss of viability, the UARs with the 

declining species that were added to the NFTS will be removed from the Motor Vehicle Use Map until 

such time that Sensitive plant populations are found to have recovered.

Noxious Weeds

Letter 

Number

Comment 

Number Comment Text

819 36

Please note that the Noxious Weed Monitoring Program would only be administered for “up to four 

years.” Most of the project will not even have been implemented within that timeframe. Unless 

noxious weeds are continuously monitored and problematic populations are addressed, motorized 

access is likely to exacerbate botanical resources in the NRA.

Response: The noxious weed monitoring plan specifies, “Monitoring will commence at the end on one 

full growing season following the addition of the routes to the National Forest Transportation System. 

Monitoring will include hand removal and will occur prior to invasive plant species producing seed.” 

Water Quality and ACS Objectives

Letter 

Number

Comment 

Number Comment Text

819 32

Please note that page 64 of the Scoping Notice indicates that the agency intends to monitor only up 

to 20% of the routes that present a “high risk” to water resources over the next 10 years, and even 

that minimal amount of monitoring is contingent on funding that has not been secured. Presumably, 

no “moderate” risk routes will be monitored at all. In other words, the Forest Service is proposing to 

add routes it knows present a “high risk” to aquatic values and monitor less than 1 in 5 of the routes 

over the next 10 years if funding is provided. Such an approach is wholly inadequate and does not 

ensure that hydrological resources will be preserved, protected, and enhanced as required by the

Smith River NRA Act. Further, such an approach will not lead to the attainment of the Aquatic 

Conservation Strategy (ACS) objectives of the Northwest Forest Plan or compliance with the 

requirements of the Water Quality Board.

819 31

It appears that the Forest Service is contending that it can evade the intent and requirements of the 

Smith NRA Act to preserve, protect, and enhance botanical and 5 hydrological values through 

“monitoring” of the inevitable and foreseeable damage that codified motorized use of “high risk” 

routes will facilitate.

Response: While the monitoring plan refers to “high risk” routes, it should be noted that any high-risk

route proposed for addition to the NFTS would have the appropriate project design features implemented 

prior to being open for public use. These project design features (such as water bars installed to restore 

proper drainage patterns to reduce the potential for sedimentation) must be sufficient to reduce the risk 

from high to moderate or low levels. One of the primary reasons for monitoring is to verify and insure 

that the project design features are adequate in keeping the risk to water quality to a low level.

Implementing these project design features meets the requirements of the North Coast Water Quality 
Appendix G. Response to Comments 

Final Environmental Impact Statement – Appendices – 255

Control plan. Reducing sedimentation from roads is an important Watershed Restoration treatment in 

implementing the ACS, and therefore helps to attain the ACS objectives. Sufficient project design 

features have been defined that will insure there are no adverse impacts to water quality because of these 

route designations. 

Water quality

Letter 

Number

Comment 

Number Comment Text

819 34

How will the Forest Service demonstrate compliance with state and federal requirements pertaining 

to the protection of water quality if the Forest Service has no information on its activities and how 

those activities are affecting water quality?

Response: The USFS Region 5 Best Management Practices (BMPs) are included as an Appendix to the 

EIS. The BMPs are measures that have been certified by the North Coast Regional Water Quality Control 

Board and approved by the US Environmental Protection Agency (EPA) as effective measures of 

protecting water quality impacts from non-point source of pollution. The BMPs discussed in the EIS 

included but are not limited to water quality monitoring of OHV use, control of road drainage, road 

operation and maintenance, and road decommissioning and storage. The BMPs are designed to minimize 

impacts to water quality during project implementation.

Recreation

Letter 

Number

Comment 

Number Comment Text

819 38

Lastly, please note that the Recreation Monitoring Plan (DEIS page 567) calls for monitoring 

(depending on hypothetical funding) only 20% of motorized trails per year despite the fact that “most 

routes being evaluated to be added to the NFTS are likely in need of upgrading to NFTS standards 

as well as maintenance” (DEIS 246) and that “motorized routes may have unavoidable effects on 

streams, no matter how well they are located, designed or maintained.” (DEIS 106). Monitoring 1 

out of 5 such routes annually (should funding be available) is arbitrary and capricious and will not 

meet the requirements of the Smith National Recreation Act or the Northwest Forest Plan.

Response: The Travel Management EIS monitoring plan for motorized trails is directed by the forest’s

LRMP (p. V-20, Recreation Program), and the 20 percent annual monitoring requirement is currently a 

part of the recreation annual base program with annual accomplishment targets assigned by USFS Region 

5 staff. As such, it is neither arbitrary nor capricious. The statement on page 246 is based on an 

assumption that since UARs are not already on the NFTS, that some resource protection work would be 

done in the implementation phase to bring them up to NFTS standards. This work is listed in the 

Proposed Actions column of the alternative tables in Appendix A. The effectiveness of the design features 

is among what will be evaluated in annual monitoring effort. 

The statement the commenter referenced from page 106 of the DEIS states “The effects of any of the 

action alternatives are expected to not adversely affect threatened, endangered and sensitive fish, critical 

habitat, and essential fish habitat and in fact would be beneficial to threatened, endangered and sensitive 

fish, critical habitat and essential fish habitat.” Although there may be a direct effect from motorized 

routes, mitigation is in place to protect fish.
Appendix G. Response to Comments 

256 – Smith River National Recreation Area Restoration and Motorized Travel Management

Economic Viability

Letter – Comment Number Comment Text

139-2; 1-5; 419-3; 476-4; 581-3;

615-5; 620-3; 837-12; 20-3; 829-

8;590-4; 41-5; 64-1; 521-2; 605-

7; 759-5; 790-4; 791-4; 840-2

I would prefer not to have my tax dollars subsidize extreme off-road vehicle recreation in 

sensitive areas on our public lands.

139-2;1-5;338-5;419-3;476-4;

581-3; 605-4; 615-5; 620-3; 759-

3; 837-12; 1-5; 338-5; 419-3;

476-4; 581-3; 605-4; 615-5; 620-

3; 759-3; 837-12; 20-3; 829-8;

590-4; 41-5; 605-4; 521-2

Given the immense road maintenance backlog that the Forest already has this does not seem 

wise to me.

Letter 

Number

Comment 

Number Comment Text

239 1 

I am dismayed by the direction that the Smith River National Recreation Area Travel 

Management process is taking. I value the wildlands, watersheds and wildflowers of this special 

place and am concerned that the recreational preferences of a handful of extreme OHV 

enthusiasts will outweigh the need to protect at-risk botanical treasures and irreplaceable 

roadless areas. It is my understanding that the Forest Service is proposing to add user-created 

routes through roadless areas and botanical hotspots to the Forest Service road system. Given 

the immense road maintenance backlog that the Forest already has this does not seem wise to 

me. I urge you to not use MY tax dollars to subsidize extreme OHV recreation in sensitive areas 

on OUR public lands. The Smith River National Recreation Area and the Six Rivers National 

Forest already offer hundreds of miles of EXISTING roads where motorized recreation is an 

appropriate and harmless activity. There is simply no need to sacrifice wildlands and rare plants 

in order to establish additional “motorized trails” in these special places.

369 3 

It is my understanding that the Forest Service is proposing to add user-created routes through 

roadless areas and botanical hotspots to the Forest Service road system. Given the immense 

road maintenance backlog that the Forest already has this does not seem wise to me. I would 

prefer not to have my tax dollars subsidize extreme off-road vehicle recreation in sensitive 

areas on our public lands.

819 23

Please note that page 390 of the DEIS acknowledges that “current appropriated road

maintenance funding is insufficient to cover current annual road maintenance needs” and that 

“current and projected funding does not cover deferred maintenance, which means that the 

deferred maintenance backlog grows annually.” 

819 27

It also appears that the DEIS justifies this approach by relying extensively on “mitigation” of high 

risk routes that requires funding that the Forest Service does not have access to and monitoring 

of a small segment of high risk routes (again dependent on hypothetical funding). Indeed, the 

agency’s preferred alternative appears designed to increase, rather than decrease, the extreme 

NFTS maintenance backlog in the National Recreational Area.

819 95 Please provide budget and timetable that illustrate what work is anticipated and will in fact occur

in the near future.

819 96

Please Do Not Adopt a Road and Motorized Trail System That the Forest Service Cannot Afford 

to Maintain Can the Forest Service afford to maintain the road system in the proposed action to

prescribed agency standards? The Smith River NRA Roads Analysis (RAP) indicates that the 

Forest Service cannot afford to maintain the existing system to standard. According to the RAP:

* “Road maintenance funding has declined in the last decade and is expected to continue to

decline. Maintenance funding allotted to the NRA varies from year to year based on projects on

other Districts on the Forest. For example, in 2003 the NRA received $58,000, and in 2004

received $87,000. This funding covers all road levels, but the majority is spent on Levels 3, 4,

and 5 to meet maintenance standards. The NRA receives less than 10% of annual maintenance

funding needed. Limited amounts of funding can be spent on Level 1 and 2, and is usually

focused on safety and resource repair needs.” (SR NRA RAP at P.5) * “The disparity between

the amount of maintenance funds needed for the current road system and the amount available

is expected to continue. Therefore, the Forest Service is looking for opportunities to reduce road

maintenance costs through the elimination of unneeded roads, reduction in maintenance levels

to appropriate minimums, and reduction of maintenance requirements.” (SR RAP at P.5).

819 98

Page 384 of the DEIS indicates that the annual cost to adequately maintain the Smith River 

NRA NFTS is $709,000 and that the District has been allocated $50,000 total for FY 14 

resulting in a $659,000 road maintenance shortfall. Hence, the proposal to implement 

Alternative 6 and add an additional $27,000 in annual maintenance obligations is unwise. In 

contrast, implementation of Alternative 5 would decrease the NRA’s maintenance obligation by 

$44,700 a year. (DEIS page 384). Given that page 4 of the DEIS indicates that part of the 

project purpose and need is to reduce NFTS maintenance costs, the agency must implement 
Appendix G. Response to Comments 

Final Environmental Impact Statement – Appendices – 257

Letter – Comment Number Comment Text

Alternative 5. To further increase the agency’s road maintenance backlog will frustrate 

attainment of the very purpose of this planning effort. As acknowledged on page 384 of the 

DEIS “adding new facilities to the NFTS will increase the amount of deferred maintenance and 

increase the maintenance cycle.” Page 388 of the DEIS reveals that “motorized trails may 

require considerable hand work and more time to maintain than the equivalent mile of road.” Yet 

the Forest Service is proposing to add 8 out of 9 highly controversial motorized trails through 

botanical hotspots and Inventoried Roadless Areas.

819 99

36 CFR 212.55 clearly requires consideration of the need for maintenance and administration of 

the designated NFTS. Yet here it appears that the agency is committed to increasing its 

maintenance backlog regardless of the consequences to natural resources or visitor safety.

819 101

Page 401 of the DEIS reveals that annual maintenance of motorized trails alone under

Alternative 6 would cost approximately $42,800. This is over 80% of the NRA’s total

maintenance budget, and would leave less than $8,000 maintenance dollars to maintain the 

NFTS roads that are actually needed for administrative and public access rather than just for 

the motorized play desires of a small segment of forest visitors.

819 103

Please note that page 3 of the DEIS indicates that UARs can only be added when they don’t 

have resource concerns that cannot be “readily mitigated.” The Smith River NRA cannot 

“readily mitigate” the resource concerns on the existing NFTS given the $113,000,000 deferred 

maintenance backlog on the Six Rivers National Forest. Therefore, it is arbitrary and capricious 

to assume that the agency will have the funding necessary to “readily mitigate” damage from 

additional NFTS motorized trails. Page 47 of the DEIS acknowledges as much: “the risks roads 

pose to water quality is increased by 23 the fact that road maintenance funding has been 

declining while the road maintenance needs of our road system continues to increase.” 

Consequently, “there is a need to restructure our current level of road miles to a more 

affordable level to better maintain and protect water quality and fish habitat.” Please note that 

these statements directly undermine the incorrect contention on page 6 of the Scoping Report 

that economic feasibility of road maintenance is not a significant issue for this project.

819 105

We conclude from the preponderance of empirical research and from experience on the ground 

that the proposal to adopt a system that cannot be maintained to standard (due to the disparity 

between available and likely funding and the system’s maintenance needs) will result in 

sediment mobilization and delivery to streams. Furthermore, adoption of the system will result in 

significant human safety risks and injury resulting directly and indirectly from the failure to 

maintain the system to standard.

829 8 

It is my understanding that the Forest Service is proposing to add user-created routes through 

roadless areas and botanical hotspots to the Forest Service road system. Given the immense 

road maintenance backlog that the Forest already has this does not seem wise to me. I would 

prefer not to have my tax dollars subsidize extreme off-road vehicle recreation in sensitive 

areas on our public lands.

833 1 

The Forest Service needs to unlink its funding dependence on OHV funds which influences 

preference for OHV demands on the forest for their over use, harming wildlands, wild animals, 

watersheds and wildflowers of the public’s Six River’s National Forest. The conflict of interest 

shows in current proposals for changes to the Smith River National Recreation Area 

Restoration & Motorized Travel Management Planning of April 2014. Much more openness to 

motorized impact than restorative action is evident in your preferred alternative. Your preferred 

alternative shows this bias toward increase use of damaging OHV, that get bigger and bigger 

and damage more and more, rather than assertive stewardship of the natural environment.

Alternative 5 is the least damaging choice I support.

846 3 

While EPA approves of the goals of this project, we have serious concerns regarding the 

feasibility of implementation in light of the budgetary constraints described in the DEIS. Under 

existing conditions, the Smith River NRA has an annual road and trail maintenance deficit of 

approximately $650,000. Some project alternatives could increase and others decrease this

annual shortfall. According to the DEIS, the one-time implementation expense of the action 

alternatives ranges from $6.3 to $7.3 million dollars; however, the DEIS does not describe how 

funding for these activities would be secured. In the absence of sufficient funding, the full effects 

of project implementation, both adverse and beneficial, as disclosed in the DEIS, may not come 

to fruition. In addition, the DEIS does not disclose which project components would be 

implemented and which would be deferred should project funding fall short of the identified 

need. Without this information, it is difficult to determine what the environmental consequences 

of the proposed actions will truly be.

846 8 

All action alternatives discussed in the DEIS have clear benefits to water quality, aquatic 

resources, wildlife, and other resources as compared to the no action alternative. EPA strongly 

supports the implementation of an action alternative; however, we have significant concerns 

regarding the feasibility of project implementation given the stated budgetary constraints and 

annual maintenance deficit, as discussed in the “Transportation Facilities” section of Chapter 3. 

Page 47 of the DEIS indicates that road maintenance funding for the Six Rivers National Forest 
Appendix G. Response to Comments 

258 – Smith River National Recreation Area Restoration and Motorized Travel Management

Letter – Comment Number Comment Text

has experienced a long term declining trend, while annual maintenance demands have 

continued to increase. The Smith River National Recreation Area averages an approximate 

$650,000 deficit of the necessary funds for annual routine maintenance. As a consequence, 

nearly 50 percent of stream crossings in the NRA are in need of routine maintenance. The 

maintenance backlog within the NRA has significant short and long-term consequences for 

water quality, including an increase in sediment load in NRA watersheds, impacts on wildlife, 

and the potential for an increased mass wasting hazard (p. 72). Recommendation: The FEIS 

should include a short discussion of the effect of the National Forest Transportation System 

maintenance backlog on each major resource area discussed in Chapter 3 and the extent to 

which each Alternative’s described environmental outcomes are dependent upon the 

elimination of this backlog.

846 9 

Furthermore, monitoring and mitigation activities with the potential to affect environmental 

outcomes are also predicated upon funding availability (for example water resource monitoring, 

page 565).

846 10

Recommendations: The FEIS should discuss the likelihood that sufficient funding will be made 

available for project implementation. The FEIS should also discuss which project components 

would be given priority for implementation and the extent to which this would affect environmental 

outcomes should sufficient funds be absent in future budgets. It would be helpful to include a 

short description of the most likely project build-out scenario in light of budgetary constraints.

846 11

Page 40 of the DEIS states as an assumption inherent to this NEPA analysis that “The [NFTS] will 

be maintained to standard and all additions or changes to the NFTS will meet standards prior to 

availability for public use,” EPA questions the validity of this assumption in light of the enormous 

maintenance backlog and the improbability that this backlog will be eliminated in the near future.

Recommendation: The FEIS should discuss the basis for this assumption and whether it is 

reasonable in light of the facts provided with regard to trail and roadway conditions and 

maintenance backlog. EPA notes that Alternative 5 is the least costly action alternative described 

with regard to both implementation expense and annual maintenance costs. Recommendation: 

The FEIS should discuss the extent to which the relative expense of the various action alternatives 

affects the likelihood of the environmental outcomes described for each.

846 12

Off highway vehicle use can adversely affect water quality, sensitive fish habitat, and other 

aquatic resources by compacting soil, disturbing or eliminating vegetative cover, decreasing 

water infiltration, and increasing surface runoff and erosion. These effects are magnified on 

steep slopes or in erosive, unstable soils. In addition, under-maintained roadways pose a 

significant risk to water quality and aquatic resources due to blocked culverts, erosion, rilling, 

and increased mass wasting hazard. The incorporation of unauthorized routes into the NFTS 

will increase the maintenance burden on the Smith River NRA. In light of the budgetary 

constraints discussed above, it seems probable that the motorized routes added to the NFTS 

may be under-maintained in the future; minimizing the total miles of NFTS routes would serve to 

minimize this future impact. Recommendations: The FEIS should discuss the likelihood that 

unauthorized routes added to the NFTS would be under-maintained following project 

implementation and the effect this may have upon water quality. The Forest should consider 

alternatives that minimize the potential impact of roadways and motorized routes upon water 

quality, aquatic species, and watershed health.

Responses: The following response is grouped into four main topic areas brought up in the comment letters:

Why use tax dollars to provide motorized recreation opportunities?

Providing safe motor vehicle access to the National Forest for public use is a fundamental part of the 

USFS mission. Access to landscapes, natural resources, facilities, and trailheads to wilderness areas along 

with driving for pleasure are primary uses of USFS NFTS. Congress funds the USFS to manage routes 

and provide safe administrative and public access.

Deferred Maintenance and Anticipated Maintenance Costs

The purpose of the deferred and annual maintenance figures is to capture the costs of the NFTS at a 

national level, so that National Forests can communicate the maintenance funding needs versus funding 

levels to Congress at a national level. The deferred and annual maintenance figures were generated using 

a national formula based on random sampling (less than 0.2 percent miles of system roads nationwide for 
Appendix G Response to Comments 

Final Environmental Impact Statement – Appendices – 259

2009) and standard maintenance prescriptions. It is a useful tool for tracking national trends and 

producing auditable outputs, but was never intended for use at the forest level (need some citation). The 

nationally calculated cost figures for ML 2 and 3 roads are based on several assumptions, which include 

but are not limited to the following: high cost aggregate surfacing should be replaced and maintained on 

most level 3 roads; culverts have fixed and relatively limited life spans; ML 2 roads require high numbers 

of cross drain culverts; and roadside vegetation and debris should be regularly removed from every road. 

These assumptions are not specific to the SRNF, and do not apply to many of the forest’s roads. The 

deferred maintenance for the Smith River NRA, in large part includes the types of maintenance activities 

that affect drivability (brushing, surfacing, pothole repair, etc.). Given the conditions on the ground and 

current maintenance and environmental objectives, the maintenance figures for ML 2 and 3 roads are 

considered unreasonably high, which artificially inflates the forest’s annual and deferred maintenance 

figures. In this project, roads with a high level of maintenance required, for example have a high number 

of stream-crossings, are proposed for decommissioning in Alternatives 5 and 6. In contrast, roads with a 

low level of maintenance required, for example ridge roads with no stream crossings are proposed to be 

kept or designated on the NFTS and require less maintenance.

In response to public comments, the cost per mile of motorized trail was reassessed from the figure 

used in the DEIS, which was based on motorized trail maintenance costs of the Pilot Creek motorized trail 

network. The Pilot Creek trail maintenance relies on the use of hand crews because these are largely 

single-track trails on steep terrain that require hand crew work, which has a higher cost per mile than 

work performed using small equipment. Given that, the motorized trails proposed for designation in 

Alternative 6 are largely on gentle slopes and accessible by small equipment, it is not expected that handcrew work will be needed for motorized trail maintenance. Motorized trail maintenance costs are less per 

mile to maintain over the long term as there are typically less drainage structures to maintain, however, 

the cost for the initial implementation of some of the mitigations may be higher as they may be 

implemented by hand. Therefore, the annualized maintenance cost is expected to be on average $500 per 

mile. It is important to note that the amount listed would be needed to perform all potential maintenance 

actions every year. This cost does not take into account site-specific conditions. Not all actions are needed 

on every road/trail each year. Therefore, the cost estimates utilized for the purposes of this analysis 

overestimate actual maintenance costs.

The costing models assess all road maintenance needs as the same and do not reflect the consideration 

that was given to the on-going maintenance needs when crafting the proposed action and Alternatives 5 and 

6. In the long-term, the forest anticipates that the maintenance costs will be less than the No Action 

alternative and Alternative 4. In crafting the proposed action, and Alternatives 5 and 6, roads and UARS that

had a high level of stream crossing and therefore would be expensive to maintain were identified for

decommissioning or restoration, while less maintenance intensive that would be more affordable to maintain

was proposed for maintaining or designating on the NFTS. Investments, such as stormproofing, which make

roads more resilient to storm damage is also an action that is proposed in all action alternatives that, in the

long-term, would reduce the amount of maintenance required due to large storm events.
Appendix G. Response to Comments 

260 – Smith River National Recreation Area Restoration and Motorized Travel Management

Funding Sources and Strategy

The SRNF will implement the project over the next 10 to 15 years. Having NEPA decision on this project 

would position the Smith River NRA to compete for supplemental funding from both external and internal 

sources for the restoration, decommissioning, stormproofing and monitoring work that is being proposed, 

which contribute directly to protecting water quality from road-related sediment sources. It is important to 

note that the appropriated funds shown in the DEIS table only identify a portion of the funds available for 

implementation and maintenance of the NFTS. Funding is also made available from funds generated from 

timber sales and commercial road access permits, State OHV Division grants, emergency repairs through 

the ERFO program (Emergency Repair for Federally Owned roads), competitive funds such as the Federal 

Lands Transportation Program, and partnership opportunities. State OHV division grants are also used to 

fund water quality and botanical resource mitigations required prior to route designation on the NFTS,

OHV law enforcement, and decommissioning of roads. In the past, stimulus funds were made available to 

the forest, but these dollars are not available on a regular basis. Actions considered in alternatives must 

comply with the Forest Plan standards and guidelines irrespective of the funds used to implement the 

project. The completion of this project will allow the forest and partners to compete for grant funds, which 

are only available for projects where there is an existing NEPA decision. The Transportation section of 

Chapter 3 is updated in the FEIS to reflect the diversity funding sources available.

History of Implementation on Similar Projects

Since 1999, the SRNF has received and implemented over $6.7 million in funding for road 

decommissioning and stormproofing under similar NEPA decisions across the forest. This work has 

saved millions of cubic yards of potential sediment from entering anadromous streams and it is expected 

that the implementation of the proposed actions will have the similar success in protecting water quality. 

As stated in the Monitoring and Condition Surveys section of Chapter 2, monitoring and condition 

surveys would be conducted annually, and corrective actions taken if roads or motorized trails are out of 

compliance, including closures. The monitoring plans are described in more detail in the EIS appendices, 

and are required for implementation for each resource area analyzed. The forest anticipates there will be a 

deferred maintenance backlog in the future; however, the forest’s annual road maintenance strategy 

prioritizes public safety and resource risk reduction associated with the NFTS. The forest plans to 

implement this project over the next 10 to 15 years, and expects that the effects of the project will be 

consistent with the analysis shown in Chapter 3 of the EIS. 

The statement that the maintenance cycle or frequency at which a road or motorized trail is 

maintained is erroneous and is corrected in the FEIS. 

Partnerships

Letter 

Number

Comment 

Number Comment Text

825 6 

Regarding implementation funding, SRA encourages application through the State OHV Division. 

We would be pleased to work cooperatively with Forest Service staff and other stakeholders on the 

development of grant proposals, which would seek funding for a vigorous monitoring and education 

campaign involving volunteers who are recruited and trained to assist Forest staff. This suggestion 

was also made by the California Wilderness Coalition in their April 2011 scoping comments.
Appendix G Response to Comments 

Final Environmental Impact Statement – Appendices – 261

Response: Thank you for your support. Developing new partnerships and strengthening existing 

partnerships contributes to the forest’s ability to compete successfully for additional grant funds.

Opinion or Position Statement 

Letter 

Number

Comment 

Number Comment Text

127 1 Hi, please make the top priority the needs of the Off-Highway Vehicle community, thank you for your 

consideration, Robert Jump (Lifetime member of the Blue Ribbon Coalition)

825 7 Thank you again for your outstanding diligence and assistance with implementation of the Travel 

Management Rule.

830 1 

BRC appreciates and publicly thanks the various stakeholders who in 2010-2011 participated in various 

meetings facilitated by the U.S. Institute for Environmental Conflict Resolution to create a collaborative 

atmosphere whereby public input could be used to enhance OHV opportunities on the NRA.

831 24

Every road is an asset for fire crews, fire breaks, place for water run off to occur, emergence crews 

to access the forest, hunters to retrieve game, loggers to access trees, miners looking for treasures, 

animal grazers to tend their flocks/heads, humans to access the forest easily, wild animal picture 

taking (which really is wildlife harassment) The benefits of leaving all existing roads, motorized 

ways, motorized trails man made far outreach the benefits of closing them forever.

806 11

Finally, I want to point out the absurdity of Pofahl’s comment (and the pro-ORV argument his 

comment exemplifies): just because something was considered acceptable in the past doesn’t 

mean it must remain acceptable. Morals change. Laws change. At one point it was acceptable (to 

white people) for white people in this region to steal land from the Tolowa. Does that mean it should 

continue? It’s just nuts to believe that simply because someone felt entitled to perpetrate some 

destructive behavior such as ORV use in the forests when he was 19 that he should continue to be 

allowed to perpetrate such behavior when he is older. This also of course makes my point about 

how the argument over this misuse of the land is basically between those who think that the health 

of the land is primary versus those who are essentially overgrown children who want to continue to 

play with the expensive and destructive toys they played with in their youth.

806 12

I want to turn his statement around. When I first moved to Del Norte fifteen years ago, I would 

routinely see a dozen rough-skinned newts at a time in shallow waters. Old timers have told me of 

seeing hundreds at a time. Now I see them rarely. Only fifteen years ago, I would routinely see a 

hundred dragonflies in the air at one time. Now I see one or two. Years ago, I saw some tiny 

streams so full of tadpoles that the tadpoles were out of space and pushing each other out of the 

stream. Now of course I don’t see so many. Bat populations have collapsed. Migratory songbird 

populations have dropped. And on and on.

481 1 Are you out of your minds? We need to be taking vehicles out of the forest, not sending more in.

197 4 In summary: I want you to pick the option that keeps the most land wild and OVR free.

793 2 

I have read the summary of your Alternative 3, modified proposed action. I do appreciate the 

difficulty of navigating the opposing demands of passionate off-road enthusiasts and the equally 

passionate protectors of sensitive public wildlands.

825 1 We believe motor vehicle recreation and dispersed use can and should be balanced with reducing 

the risk to both cultural and ecological resources.

762 1 My heart sinks to think that future generations will not experience the beauty of this area due to the 

selfish acts of a few who feel that this earth is here at their disposal.

255 12 No on more off-road use on the Smith River National Recreation Area.

12 3 DON’T ALLOW THIS

559 3 

So why continue to try and shut down the places my family and I use, love and care for. I’m sure 

you wouldn’t like it if I was trying to shut down the trails & roads that you and your families use, love 

and care for.

819 52

Page 331 of the DEIS indicates that implementation of Alternative 6 “would favor semiprimitive 

motorized recreation opportunities over non-motorized opportunities.” This is a true and accurate 

statement. Alternative 6 favors the interests of the 1.1% of Six Rivers Forest visitors for whom ORV 

use is their primary activity (DEIS page 371) over the millions of Americans who value the roadless 

character of the last remaining 2% of our existing wildlands. The Blue Ribbon Coalition’s advocacy 

for the 11,200 annual motorized trail visits is impressive in its ability to get the Forest Service to 

discount the values and desires of the 212,800 non-motorized visits. (DEIS page 371).
Appendix G Response to Comments 

262 – Smith River National Recreation Area Restoration and Motorized Travel Management

Letter 

Number

Comment 

Number Comment Text

819 45

The Forest Service has also downplayed the significant impacts of motorized use in IRAs by 

referencing the “historic” nature of the “mining routes” that the agency intends to designate as 

motorized trails. Yet Smith River NRA Motorized Travel Management EA previously acknowledged 

that “[m]ining roads continue to erode in places where roads were constructed down a slope or 

across a drainage.” These are the types of impacts that the Roadless Rule, and the Smith National 

Recreational Area Act, were designed to avoid rather than to facilitate and codify.

819 24

It is undisputed that the existing network of user-created routes, in addition to a number of poorlydesigned system roads, are a major cause of chronic sedimentation problems in streams, cause 

damage to rare and endemic plant populations, contribute to the loss of roadless wildland recreational 

opportunities, and spread of Phytophthora lateralis (PL). This planning process is the appropriate 

mechanism for alleviating the negative impacts associated with roads and motorized routes.

830 3 

BRC also supports and specifically incorporates by reference herein the list of UAR segments and 

other site-specific proposals submitted by Del Norte County. These modifications represent 

important routes to dispersed campsites, historical uses, or are needed as routes used by the 

county search and rescue.

830 9 

While the general approach of Alternative 6 is preferable to other alternatives, there are specific 

issues and routes that have been overlooked or otherwise improperly omitted from the list of routes 

that will be designated for continuing and/or necessary vehicle access. We have reviewed the Del 

Norte County submissions, and rather than unnecessarily repeating those comments will specifically 

note our support for them and incorporate those comments by reference herein.

850 6 Today the Del Norte County Board of Supervisors approved a letter with their comments about the 

above travel plan. The Northwest Trail Riders support their decision.

851 3 

Today the Del Norte County Board of Supervisors approved a letter with comments regarding the 

above travel plan. I support their decision. I am a concerned citizen and resident of 55 years in Del 

Norte County. We raised our children here and spent much time exploring the backcountry. 

819 1 

The Klamath Siskiyou Wildlands Center (KS Wild), the Environmental Protection Information Center, 

the Klamath Forest Alliance, Friends of the Kalmiopsis, Siskiyou Land Conservancy, WildEarth 

Guardians, Friends of Del Norte, the California Native Plant Society, and The Wilderness Society 

would like to support efforts to reduce road maintenance costs, protect and restore aquatic and 

terrestrial ecosystems, and reduce the spread of Port Orford cedar root disease through road and 

route decommissioning in the Smith River National Recreation Area – unfortunately we are 

concerned that the preferred alternative in the DEIS will not adequately accomplish these objectives.

759 4 Perhaps the Forest Service prefers off-road vehicles to hikers for example. The damage caused by 

off-road vehicles may make it easier to eventually log the forest, right?

831 10 Sharing the routes is not the issue on most motorized trail beds. Hot, fast tracks for OHVs are fun 

for only a small portion of forest users.

135 1 

Hey Guys, I see you are planning to open more Off Road User trails in your area. Thank You, 

Please keep our forest open to Family’s to Recreate on and use reasonably. We need to get future 

generations into our woods and Off Road Recreation is the best!

811 1 

Please understand what road closures mean to ATV’s, Jeeps. 4wd motor cycles, deer hunters, 

ANYONE who enjoys use of our public forests. Roads are our access to OUR lands, enjoying the 

best of what Nature has to offer. How will our children understand the forests and what is needed if 

there is a KEEP OUT sign on the roads? They are the future stewards of the land.

831 13

No roads should be ever closed or decommissioned. Every road leads someone where the 

motorized public chooses and wishes to go. The reason are many but each road, motorized way, 

motorized trail whether created by blade or wheel; leads a motorized user on an adventure that will 

enable them to enjoy their national forest

50 1 These areas are national botanical treasures and it is shortsighted to put them in harm’s way.

590 1 I am very concerned that we need to protect native plants and wildflowers.

197 3 Remember, this is not about giving people access. People are welcome to visit any of these 

wonderful places; it is their noisy, polluting, damaging vehicles that are not welcome.

833 3 

Please review your actions without increasing the OHV special interest group demands, after all 

they also want the forest healthy and beautiful to ride in. The Smith River National Recreation Area 

and the Six Rivers National Forest already offer hundreds of miles of existing Forest Service roads 

where motorized recreation is allowed.
Appendix G. Response to Comments 

Final Environmental Impact Statement – Appendices – 263

Letter 

Number

Comment 

Number Comment Text

846 1 

The U.S. Environmental Protection Agency has reviewed the Draft Environmental Impact Statement 

for The Smith River National Recreation Area Restoration and Motorized Travel Management 

Project. Our review is provided pursuant to the National Environmental Policy Act, the Council on 

Environmental Quality’s NEPA Implementing Regulations (40 CFR 1500-1508), and Section 309 of 

the Clean Air Act. EPA supports the Forest Service’s effort to address increased motorized vehicle 

use on national forest lands and the related issues of resource damage, user conflicts, 

maintenance, monitoring and enforcement. We support the transition from unmanaged motorized 

recreation to managed recreational travel on designated travel routes. Managed recreational travel 

is essential in ensuring ecosystem sustainability, protecting forest resources, and providing 

equitable accommodation for both motorized and non-motorized recreation use.

825 4 

Regarding the April 2014 DEIS, the Smith River Alliance (SRA) recommends the implementation of 

Alternative 5. While we are comfortable with parts of other Alternatives as presented in the DEIS, 

Alternative 5 most closely reflects our mission to provide long-term protection, restoration and 

stewardship for Smith River watershed resources.

846 4 We have rated all project alternatives proposed in the DEIS as Environmental Concerns.

806 2 

The first is that the bioregion has been deeply stressed over the last 180 years, since conquest by 

the dominant culture. These stresses include reduction in salmon numbers, reduction in megafauna, 

including many predator species, precipitous drops in populations of small vertebrates such as 

frogs, salamanders, newts, and of course migratory songbirds, equally precipitous drops in 

populations of small invertebrates such as dragonflies and native pollinators, and so on.

806 3 

An additional stress is the removal of Indigenous humans living traditionally, and their replacement 

by industrial humans. This latter is of course the cause of the other stresses, as industrial humans 

have brought with them extractive industries such as mining, logging, and commercial fishing. 

These activities have led to other destructive activities such as roadbuilding, and germane to this 

discussion, off road vehicle use.

846 2 

EPA commends the Forest Service for its efforts to address the many challenges inherent in 

developing a balanced motorized travel management plan that responds to recreational and 

resource management demands.

739 1 

I am writing to comment on the Smith River National Recreation Area Travel Management proposal. 

It is true that recreation in National Forests can be prioritized when considering the management of 

these beautiful public lands. However, the scenic beauty that draws recreationists also needs to be 

heavily weighed in these management decisions.

830 2 

BRC has reviewed the DEIS and supports many underlying tenets of preferred Alternative 6, which 

include to add a number of short inventoried unauthorized routes (UARs) to popular dispersed 

recreation sites to the NFTS and designates parking and mixed-use along road 17N49. BRC also 

supports the addition of 16 miles of motorized access on NFTS, the designation of mixed-use on 0.4 

miles of road 17N49, the addition of 50 routes to dispersed sites, the designation of parking at 4 

sites along 17N49, the stormproofing of 122 miles of roads and motorized trails, seasonal wet 

weather road closures as appropriate on roads and motorized trails, and the reclassification of 6 

acres from semi-primitive non-motorized to semi-primitive motorized in the ROS which requires a 

Forest Plan Amendment.

830 7 

The DEIS represents progress from the unacceptable prior situation and toward a workable means 

of allowing reasonable yet sustainable access to the project area. However, several key 

shortcomings or areas of possible confusion remain. The Forest Service can work within the 

procedural and substantive framework of the DEIS to address these concerns in a Modified 

Alternative 6 as outlined in these comments. We look forward to working with the agency and other 

stakeholders in achieving this outcome.

819 100

Page 402 of the DEIS indicates that implementation of Alternative 5 best achieves the project 

objectives of “public safety” and “transportation system affordability.” Consequently, choosing 

Alternative 5 would be preferable to Alternative 6.

806 1 

I have lived in Del Norte for 15 years. I have had avascular necrosis in both ankles, which means I 

am one of those people who cannot hike in the back country, one of those people for whom off-road 

vehicle proponents often claim to speak. Below are my comments on the Smith River NRA 

Restoration and Motorized Travel Management Project. My preference would be that as many 

“roads” as possible be decommissioned and returned to as close as possible to a natural state, for 

many reasons.

827 1 The Department of the Interior has received and reviewed the subject document and has no 

comments to offer. Thank you for the opportunity to review this project.
Appendix G. Response to Comments 

264 – Smith River National Recreation Area Restoration and Motorized Travel Management

Letter 

Number

Comment 

Number Comment Text

806 9 

But the UARs have been recognized. Many are recognized as unsafe and hazardous, because 

they’re not designated for ORVS. They are too steep, narrow, unstable, and unmaintained. They’re 

not patrolled and they have no easy to access for rescue. Many old UARs were built strictly for 

mining under the (dreadful) 1872 Mining Act. Many were closed, and then were re-opened illegally 

under the ORV-industry-frontman Don Amador’s guise of “public access for public lands.” 

161 1 

I am strongly against the 4x4 motorcycle etc. that would tear up the forests and disturb wildlife 

habitat. We should be advocating for quiet and undisturbed places for wildlife habitat at a time when 

so much is lost in decline....too many people encroaching in on too few places left for the wild.

23 1 

This landscape has been inexpressibly dear to me for over 60 years. I am appalled that you would 

even consider a course of action that would put it at the mercy of this kind of destructive activity. My 

brother put himself on the line as a wildland firefighter with the Six Rivers N.F. He worked to protect 

these places and cherishes them still.

204 1 

After reading over the proposals, I see none as having everything that should be available but that 

Alternative # 5 comes closest. I am in favor of closing more if not all to motorized travel but realize 

that the political will to do what is the most needed and best is lacking. So, unfortunately

compromise of the environment to favor human desires is making an ugly presence again. I would 

hope further modification(s) in the final plan will be made to eliminate more or all roads and make 

none that are new.

235 1 

I value and use the Smith River area for kayaking, hiking and back packing. Off road users need to 

stay on the existing roads. Please don’t contribute to the degradation of this wonderful resource.

Thank you for considering my concerns.

823 1 

I prefer Alternative 5 because it will have the least detrimental impact on forest resources. I believe 

the area should be managed primarily to improve and protect the fishery, botanical, and wildlife 

resources. Recreational uses should be those that cause little impact.

345 1 I am a business owner of Naturespirit Herbs, a Southern Oregon based company. We wildcraft 

medicinal plants from the unique and botanically rich lands in our area.

493 1 It is very important to protect the great DIVERSITY that we still have. It is very threatened, and 

worthy of our care. Our lives depend on it, not just animals and plants.

59 3 There are plenty of existing unmaintained roads for “off road vehicles.” 

59 5 I think you can do better. I am guessing if you were listening to your scientists, you would do better.

819 39

Please note the recent Travel Management Decisions from both the Klamath National Forest and 

the Shasta-Trinity National Forest elected not to encourage and codify motorized use within 

Inventoried Roadless Areas (IRAs). Those decision documents were attached to our May 2012 

scoping comments.

830 4 

Unfortunately, Alternative 6 does not fully capture the tone and direction from the aforementioned 

stakeholder group meetings where county government and the OHV community asked to be 

embraced either as genuine partners via the county coordination process or as a valued user group. 

Fortunately, the elements necessary to address these shortcomings are well within the “decision 

space” created by the planning process and DEIS. We urge the agency to finish the DEIS solution 

in progress by adopting a final Modified Alternative 6 as outlined in these comments and those of 

Del Norte County.

819 16

It appears that the agency’s preferred alternative places the preferences and desires of the 

motorized off-road vehicle lobby above the “high risk” to the botanical and hydrological forest 

resources the Forest is charged by Congress to preserve, protect and enhance.
Appendix G. Response to Comments 

Final Environmental Impact Statement – Appendices – 265

Letter 

Number

Comment 

Number Comment Text

825 5 

Work on implementation of the Travel Management Rule for the Smith River National Recreation 

Area has been underway for several years. Accordingly, SRA wishes to incorporate by reference 

our earlier correspondence and submittals including scoping comments in April 2011 and specific 

recommendations and observations provided for many of the routes discussed during the 

collaborative process. SRA is interested in continuing to work collaboratively with all stakeholders 

and Forest Service staff to improve the funding for public education, engagement, monitoring, and 

enforcement related to implementation of the Travel Management Rule.

“We appreciate staff’s extensive work on this Scoping Document — as well as the months of work 

supporting the collaborative stakeholder process. The Smith River Alliance (SRA) and other 

environmental stakeholder groups were involved in many site inspections of specific routes and we 

also submitted recommendations in September that were included in the “Outcomes” document 

prepared by facilitator Austin McInerny following the final (October 6) collaborative session. We 

support the recommendations included in the October 6 collaboration “Outcomes” document, which

informs the subject Scoping Document. My comments below are consistent with these earlier 

recommendations.

April 2011 Comments Incorporated by reference:

Of course, we look forward to progress on the restoration components. Thank you for your work 

with the diverse stakeholders to move this Project forward.

830 4 

Unfortunately, Alternative 6 does not fully capture the tone and direction from the aforementioned 

stakeholder group meetings where county government and the OHV community asked to be 

embraced either as genuine partners via the county coordination process or as a valued user group. 

Fortunately, the elements necessary to address these shortcomings are well within the “decision 

space” created by the planning process and DEIS. We urge the agency to finish the DEIS solution 

in progress by adopting a final Modified Alternative 6 as outlined in these comments and those of 

Del Norte County.

339 1 

I would like to remind you that the Smith is the last undammed river and a jewel, a river like no 

other. For that reason alone, it should not be impacted beyond the very light impacts for camping, 

fishing and swimming.

195 1 Love the Smith River! It is extraordinarily beautiful and so clear – a rarity – why it must be protected. 

Motorized vehicles will clearly eventually muddy the watershed, ruin the unique botanical ecosystems.

806 4 

The stressors on the bioregion will continue to rise, and will rise exponentially with global warming.

Just as a patient in critical care in the hospital must not have additional and completely unnecessary 

and frivolous stresses added to his or her life, we need to not add additional and completely 

unnecessary and frivolous stresses to the health of the bioregion. And off road vehicle use is as close 

as one can get to a completely unnecessary and frivolous stress to the health of any bioregion.

369 7 

More and more people no longer tolerate practices with zero integrity and zero compassion. Be an 

upstander, not a bystander! Meaning you stand up for Justice. Animal Rights is a (Social) Justice 

Issue. Stand up for Animals, and for Zero Tolerance for Human Cruelty towards All Animals.

263 1 I write to urge you to adopt a travel/motorized recreation plan for the Smith River National 

Recreation Area that redresses the incessant and intense damage inflicted by off-road vehicles.

805 8 there is also no compelling need or cause to allow ORV use in inventoried roadless areas that by 

right ought to be formal Wilderness

790 1 

I strongly oppose any effort that opens “high risk” off-road vehicle routes in the Smith River National 

Recreation Area Travel Management area. The interests of a handful of extreme off-road vehicle 

enthusiasts should not outweigh the need to protect at-risk botanical treasures and irreplaceable 

roadless areas and the current plan puts those botanical treasures at severe risk.

819 15

We remain extremely perplexed as to why the Forest Service continues to propose the addition of 

user-created routes to the NFTS that pose “high” and “moderate” risks to important natural values. 

Please note, the DEIS reflects a “preferred action” in which a number of user created routes are 

proposed for motorized use despite the “low” need for the routes and the “moderate” or (much more 

often) “high” risk to irreplaceable environmental values. Please further note, many of the allegedly 

“high need” user-created routes are not needed for any administrative or recreational purpose other 

than catering to the segment of forest visitors who primarily value the National Recreation Area as a

place to engage in extreme off-road travel.
Appendix G. Response to Comments 

266 – Smith River National Recreation Area Restoration and Motorized Travel Management

Letter 

Number

Comment 

Number Comment Text

819 117

Page 295 of the DEIS acknowledges that a primary goal of Congress in creating the Smith River 

NRA was to “emphasize, protect and enhance” forest resources including “anadromous fisheries 

and the wild and scenic” values of the Smith River Key Watershed. Page 46 of the DEIS clearly 

identifies roads in the NRA as a “primary threat to water quality” and page 47 notes that “the risk 

roads pose to water quality is increased by the fact that road maintenance funding has been 

declining while the road maintenance needs of our road system continues to increase.” Hence,

page 47 concludes “therefore there is a need to restructure our current level of road miles to a more 

affordable level to better maintain and protect water quality and fish habitat.” Yet the agency’s 

preferred alternative would not accomplish this. Indeed, Alternative 6 would add 42 miles of UARs

to the Forest Service’s NFTS that would further strain the agency’s overtaxed road maintenance 

budget and increase the maintenance backlog. Those additions include routes with a moderate 

and/or high risk to water quality and involve 17 road/stream crossings. (DEIS 55). Whereas 

Alternative 5 “predicts the least impacts to water quality because it proposes more road 

decommissioning and restoration of unauthorized routes.” Please note that the claim on page 64 of 

the DEIS that the preferred alternative would result in “no net gain” in open road miles within the 

Key Watershed is incorrect. As stated in the abstract, the press statement, and the DEIS that the 

Forest Service released for this project, the preferred alternative “would result in an overall increase 

of 16 miles of motorized access.” Please do not increase NFTS road miles (and the subsequent 

road maintenance backlog) in this Key Watershed for salmon.

819 131

Noxious Weeds The DEIS acknowledges that the spread of noxious weeds is hindering the 

management objectives of the LRMP and that “noxious weeds are a serious environmental concern

[because] they threaten natural diversity, habitat for fish and wildlife and native plants, soil stability 

and ecosystem process.” (DEIS page 223). Hence, the intent of the LRMP, the Smith River NRA 

Act and the project purpose and need is best met by implementation of an action alternative that 

minimizes the impacts of noxious weeds. Alternative 5 best reduces the threat of noxious weeds on 

the natural resources the Smith River NRA is charged with protecting because “direct and indirect 

effects are lowest where the number of miles of open road is less.” 

819 14

We believe that the values that most Americans find in roadless wildlands, rare botanical areas, 

Port Orford cedar stands, riparian areas, serpentine barrens and meadow habitat are not reflected 

in the agency’s preferred alternative (alternative 6) that is primarily based upon the preferences of 

some members of a collaborative group whose stated purpose was to determine how to add high 

risk controversial user created routes to the Smith River NRA NFTS. Alternative 6 favors the 

interests of the 1.1% of Six Rivers Forest visitors for whom ORV use is their primary activity (DEIS 

page 371) over the millions of Americans who value the roadless character of the last remaining 2% 

of our nation’s existing wildlands.

204 1 

After reading over the proposals, I see none as having everything that should be available but that 

Alternative # 5 comes closest. I am in favor of closing more if not all to motorized travel but realize 

that the political will to do what is the most needed and best is lacking. So, unfortunately

compromise of the environment to favor human desires is making an ugly presence again. I would 

hope further modification(s) in the final plan will be made to eliminate more or all roads and make 

none that are new.

255 12 No on more off-road use on the Smith River National Recreation Area.

831 13

No roads should be ever closed or decommissioned. Every road leads someone where the 

motorized public chooses and wishes to go. The reason are many but each road, motorized way, 

motorized trail whether created by blade or wheel; leads a motorized user on an adventure that will 

enable them to enjoy their national forest

Response: Thank you for your comments on the Smith River NRA Restoration and Motorized Travel 

Management Project. Comments and opinions about the project are appreciated as this gives the 

Responsible Official a sense of views and beliefs about a proposed course of action. While such 

information can be used by the decision maker in arriving at a decision, it cannot be used to improve the 

environmental analysis or documentation. 
Appendix G. Response to Comments 

Final Environmental Impact Statement – Appendices – 267

Summary of Alternatives Table

Letter 

Number

Comment 

Number Comment Text

846 20

Table 10 on page 36 of the DEIS ranks the project alternatives with regard to their impact upon 

each resource area. The table provides a rank from 1-5, wherein 1 indicates the greatest impact 

upon the specified resource to 5 indicates the least impact. However, the potential impact upon the 

various resources listed is detrimental in some cases and beneficial in many others. For this reason, 

we find this ranking system to be confusing and difficult to decipher. Recommendation: For greater 

clarity, we recommend that this table be revised to differentiate beneficial and detrimental impacts.

Response: The summary of alternatives table is updated in the EIS to reflect the results of the analysis 

by resource by displaying the indicator results by alternative.

Maps 

16N19

Letter 

Number

Comment 

Number Comment Text

282 1 

Any of your ‘alternatives’ are pretty much OK by me. They all include the trunk of 16N19 as an OML 

2 road. My problem lies in your incorrect inventory of it in the system roads system. This had long

been a problem. I have written confirmation from Don Pass that the mapping would be corrected to 

show 16N19 continues to the property line/gate at its terminus with McClendon Property. After a lot

of wrangling with George Fry not being able to find the USFS easement over HW3 property, Tyrone 

Kelley wrote me a letter stating that 16N19 would terminate at the HW3 property line. I have spoken 

to this at your public comment fielding meetings. The mapping has never been updated. It shows 

16N19 ending several miles short with a trailing squiggle that does not exist. This mileage should be 

added to the 7.5 miles of 16N19 on inventory as OML 2 and brought up to whatever level of 

mitigation that the plan ( whichever of the ‘alternatives’) calls for 16N19. 

Response: A review of the administrative record on 16N19 finds that the road was mapped incorrect 

when it veers to the east in the last segment. The administrative record shows that 16N19 does terminate 

at the boundary of the HW3 property. This error is corrected in the project data and corporate road data.

Errors 

Letter 

Number

Comment 

Number Comment Text

855 2 Accuracy of map of Alternative 6 in the Northwest corner at issues.

826 14

There are numerous errors and inconsistencies in the plan, which render providing meaningful 

comments challenging. In particular, mapping inconsistencies in which various routes are proposed 

for “restoration” under the Decommissioning & Restoration Actions map. In many of these cases on 

the Proposed National Forest Transportation System map, the routes are designated with a possibly 

inconsistent classification or level, which creates confusion on the reviewer’s part. For example, in 

most cases it appears that restoration means full closure, in other cases restoration is indicated to 

result in a Motorized Trail, and in some cases Motorized Trails are designated to be barricaded in 

Table 168, in yet another case a UAR scheduled for restoration appears as a ML 2 road on the final 

map (14N15.1, see table below). When asked about these inconsistencies the response from 

representatives from the Forest was that when there is an identified inconsistency the tables in the 

plan prevail over the maps. This is not acceptable to the County as it creates confusion and a sense 

of misleading information being presented. It is not appropriate for the Forest to proceed with the 

adoption of the plan until such a time that all maps and tables are reviewed by the Forest and all 

inconsistencies are corrected so that it is clear to the reviewer what is being proposed. Table 5 

presents a very limited sampling of these routes, which need to be clarified.
Appendix G. Response to Comments 

268 – Smith River National Recreation Area Restoration and Motorized Travel Management

Response: In an effort to address any questions the public may have had during the comment period, the 

team leader was made available and visited with those who requested more information. Map corrections 

are identified in the Changes between the Draft and Final section of this document.

Commenter Names, Organizations, and Letter Number 

Letters from Organizations

Last Name First Name Organization Name Letter Number

Amador Don Blue Ribbon Coalition, Inc. 830

Beyerle Karl Del Norte Resource Advisory 

Committee 852

Black Mike ADH Environmental 829

Drake Mona Deschutes County 4 Wheelers 824

Drake Randell Pacific Northwest Four Wheel Drive 

Association 831

Gardner Elaine Northwest Trail Riders 850

Goforth Kathleen United States Environmental 

Protection Agency 846

Matlock Sharon PacifiCorp 803

Meek Janet Klamath Falls Four Runners 818

Sanderson Port Patricia

US Department of the Interior: Office 

of Environmental Policy and 

Compliance

827

Self Antoinette County of Del Norte Board of 

Supervisors 826

Sexton George Klamath Siskiyou Wildlands Center 819

Werschkull Grant Smith River Alliance 825
Appendix G. Response to Comments 

Final Environmental Impact Statement – Appendices – 269

Letters from Individuals

Last Name First Name Letter Number

A. Nando 260

A. Nando 280

Abrams Al 674

Ahmad Ismail 35

Al-Tukhaim Mary 61

Albury Judy 681

Aleman Corina 186

Aleman Corina 207

Alexander Natalie 611

Alker Marcus 236

Allan Kathleen 537

Allen Catherine 763

Allen Dana 589

Allen Don 841

Allis-Sicherer Ineke 200

Ames Allen 529

Amick Brenda 710

Andersen Sandra 840

Anderson Karen 736

Anderson Richard 847

Anderton Phillip 402

Anderton Phillip 422

Andres Dustin 399

Andretta Jeaneen 475

Andrew Chianis Antonia 363

Andries Anneke 616

Angell J 72

Angell J 183

Angus Billy 651

Anon Sue Pappalardo 820

Anthony Candace 34

Arapoudis Sandra 266

Arias Teresa 645

Aubrey Heidi 438

Auerbach Stephen 437

Austin-Kennett Danielle 109

B Mykka 372

Babbitt Susan 28

Bachhuber Stephen 747

bacon jennifer 81

Baker James 779

Baker Karen 16

Baker Sandra 202

Baker Vickey 677
Appendix G Response to Comments 

270 – Smith River National Recreation Area Restoration and Motorized Travel Management

Last Name First Name Letter Number

Baldwin Theresa 390

Barbara Comnes Brian 276

Barca Erin 468

Bassler David 774

Beausoleil Claudia 185

Bechmann Elisabeth 367

Beck Margaret 126

Belachew Daniel 1 

Benedict C. 648

Benesovsky Mary 458

Bennett Gregory 321

Bennett Ron 451

bennett ross 627

Benton Patricia 469

Berg H 358

Berger David 143

Bergsma Debi 420

Berlant Emily 99

Berta Charlotte 159

Bertano Silvia 70

Bertrand Wendy 833

Bev Woodsong Paul 71

Beverly J 373

Beverly Fety James 65

Bezy Robert 309

Bienick Michelle 243

Birtel Tracey 713

Bischoff Carol 395

Bissell Kathy 228

Black Karen 488

Black Patricia 655

Blevins William 816

Bob Carolyn 481

Bodden William 413

Boersma Cindy 319

Boomhower Deborah 634

Boone Foster 97

Bostock Vic 514

Bouchard Aaron 719

Bowen P 21

Bowman Candy 721

Bowman Jason 470

Bowron Alice 242

Bozzola Eliette 30

Bradley Ralph 790

Breen Margo 165
Appendix G. Response to Comments 

Final Environmental Impact Statement – Appendices – 271

Last Name First Name Letter Number

Bress Daniela 417

Broshot Nancy 754

Browning Cassandra 472

Bruce Eugene 792

Bruner Cheryl 563

Brunton James 115

Buckley Lynne 162

Buddenhagen Mary 169

Buddenhagen Mary 192

Burghart Barbara 439

Bush Theresa 329

Buslot Chantal 362

Buslot Chantal 381

Butcher Sara 795

Butler Chris 264

Butler Doug 11

bx kx 492

Byers Brett 305

C. Ford and Dr. Richard B. Marks Mr. 151

Cain Jon 765

Calamai Barbara 725

Calkin Kelly 810

Calvert Stacey 494

Canning Stephen 233

Capobianco Anthony 108

Carlson-Leavitt Joyce 370

Carlstroem Matthew 298

Carr Gaile 509

Carvajal Mauricio 642

Cathey Gynette 517

Cattell June 661

Chandramo Elizabeth 544

Chapin Marcy 138

Chase Janet 246

Chieco Helen 412

Chittim Veroune 649

Christiansen Harold 746

Chudy Cathryn 74

Cin Ama 527

Clark Jason 389

Clausen Daphne 452

clausen nina 18

Clay Ted 531

Cobban Ann 411

Cody Mary 7 

Coe Michael 521
Appendix G. Response to Comments 

272 – Smith River National Recreation Area Restoration and Motorized Travel Management

Last Name First Name Letter Number

Cole Dori 562

Coleman Edith 561

Collier Michael 558

Collier Michael 576

Collinet Albert 291

Collins Brenda 171

Commons Kelly 691

Condon Dale 821

Cooper Eileen 828

Cooper Romain 844

Cornelius Michele 507

Correia Claudia 513

Corviday Morgan 808

covault jonnel 310

Cross Heather 549

Cross Merridy 482

Cruz John 574

Cruz Kay 78

D’amore Oceanah 312

Dailey John 660

Danielson Amy 84

Davidson Jane 565

Davie Dennis 205

Dean Michael 782

Deborah Anthes Russell 473

Debraal Karen 442

Decker Dee 311

Delahay Misty 32

Delaunay Deborah 161

Delgado Dru 140

DelGiudice Barbara 471

Delles Susan 781

Dennis Fiedler Rita 297

DeSalvo Melda 641

Devar Clemen 526

Diener B. 40

Dillon Sheila 599

DiPietro Laura 635

Dolan J.D. 119

Donahue Nona 453

Donelson Bruce 209

Donnell Bruce 220

Dorner Catherine 170

Dorner Catherine 193

Dotson Michael 476

Douglas Dianne 426
Appendix G. Response to Comments 

Final Environmental Impact Statement – Appendices – 273

Last Name First Name Letter Number

Doyle Sean 160

Drabic AniMaeChi 146

Drescher Linda 302

Drumright Chris 715

Drumright Chris 718

Duggan Jack 484

Dunham Frances 789

Dunn Christie 843

Darrenberg M. 268

Dwyer Karen 385

Easley Stan 491

East Larry 344

Easter Laurie 316

Efimova Valeriya 702

Eggers Elizabeth 148

Elepano Amy 407

Eliason Alan 783

Embry Judith 77

Engelbrecht Mrs. 707

Evans Bronwen 663

Evans Dinda 365

Eye David 380

F A 60

Fall Fred 668

Falletta Paul 10

Faulks Lea 617

Faure Peter 85

Favre Thierry 496

Fazzari Angela 479

Feichtl James 534

Filice Edward 289

Finney Rory 431

Fisher-Smith Dot 27

Flann Nicholas 197

Foley Jolene 547

Foley Thomas 314

Forestville Ed 282

Forman Fay 388

Forrest Vicky 348

Frances Alderson George 620

Francesca Paola 551

Francis Larry 279

Freberg Harry 791

Freeberg Jim 666

Freel Richard 664

Freiberg Harry 637
Appendix G. Response to Comments 

274 – Smith River National Recreation Area Restoration and Motorized Travel Management

Last Name First Name Letter Number

Froehlich Andrew 350

Froehlich Anna 195

Fulelr Katherine 522

Furguson Helen 855

G Michael 222

Ganley Roxanne 116

Garcia Aaron 6 

Garcia Dave 838

Garcia Mary 540

Garvey Lydia 672

Garvey Lydia 697

GAYE Alysia 287

Gehring Wendy 796

Gerding Jenny 519

Gibbons Brian 541

Giesen Erika 477

Gillespie Sharon 392

Gingras Brian 43

Goes Jim 38

Goff Dr. 614

Goldstein Steven 631

Golick Jan 105

Gomez Katie 525

Goodman Ellen 709

Goodman Greg 700

Goodman Michael 250

Goodwin Jayne 717

Gouveia Joseph 756

Gowen Megan 731

Grabsch Dagmar 219

Gracia Conchi 364

Grames Patricia 686

Green Jacqueline 353

Green Morris 772

Gregory Alan 401

Griffith John 670

Grobe Nicola 248

Grank Mona 130

Guilbault Aubrey 533

Gulyas Lindsey 428

Guthrie Elizabeth 490

Guzman Alex 456

Hadden Marion 176

Hall Rose 366

Hall Rose 383

Hamilton Christine 767
Appendix G. Response to Comments 

Final Environmental Impact Statement – Appendices – 275

Last Name First Name Letter Number

Hamilton Donna 68

Hammond Christina 793

Hannagan Brian 22

Hansen Dameon 760

Hanson Kathy 394

Hanson Larry 339

Hanus Jeffry 598

Harde Pragati 712

Harkrider John 223

Harrington Sue 47

Harris Andy 322

Harrison Randy 495

Hart Denice 64

Harvey Robert 66

Hayes Maura 581

Heatherstone Kristi 326

Heckman Wayne 147

Hedger Lloyd 308

Heinlein Richard 455

Heintz Nancy 357

Herberg John 29

Herberg John 45

Herbert P. 82

Herrick James 854

Hershiser James 378

Hervert Carla 184

Herzog Jonas 67

Heyerman Barbara 4 

Heyerman Opie 129

Heyerman Opie 196

Hildebrand Valerie 69

Hilden BJ 604

Hill Frank 716

Hill Frank 729

Hill Ginger 669

Hines John 528

Hoffman David 338

Hofford William 139

Holland George 676

Hollyfield Ann 608

Hollyfield Ann 832

Holmquist Kirsten 749

Hood Naomi 807

Hope Jane 46

Hopkins Jeff 259

Horn Hannah 101
Appendix G. Response to Comments 

276 – Smith River National Recreation Area Restoration and Motorized Travel Management

Last Name First Name Letter Number

Horn Lisa 493

Howell Marybeth 296

Hoyer Eric 328

Huber Monika 592

Hubner Helmut 273

Hughes Gary 252

Hughes Mark 626

Hunter Ryan 750

Hutton Doug 212

Hyatt Donald 382

Ignatovich Cynthia 812

Ira Rubin Brady 449

Irons Bridget 386

Ivie Trish 377

Jackson Elizabeth 189

Jackson Maureen 489

Janet Kramer David 128

Janicki Ellaine 410

Jarvis Scott 733

Jefferson Gabriele 427

Jenkins Phyllis 714

Jennings T.J. 845

Jensen Derrick 806

Jerskey Paul 619

John Kalayjian Linda 811

Johnson Edwin 685

Johnson Hillary 771

Johnson Stephen 738

Johnston Philip 178

Jones Marie 156

Jones Marie 175

Josephine von Hippel Peter 775

Joshua Susan 247

Jr Henry 100

Kamil Jeremy 75

Kaminker Matthew 743

Karwatzki Heike-Ingeborg 572

Kasza Teresa 813

Kauth Joseph 693

Kegler John 48

Kegler Lori 31

Kegler Susannah 63

Kegler Tyler 546

Kelly Erin 524

Kelly Lucy 585

Kelly Maria 13
Appendix G. Response to Comments 

Final Environmental Impact Statement – Appendices – 277

Last Name First Name Letter Number

Kelly Wayne 550

Kelly Wayne 571

Kelz Lisa 277

Kendal Melanie 542

Kenner Kate 462

Kenneth Ampel Carol 23

Kerr Andrew 272

Kerr Andrew 786

Kerr Karli 690

Kessler Greg 658

Keyes Jack 788

Kiley Rita 762

Kimball Jon 173

Kinsey William 804

Kisinyo-Locher Clara 349

Kleiman Christine 406

Klopp Basey 360

Knablin Richard 505

Kochmeister Jan 443

Koestler Monika 9 

Kowalewski Joyce 292

Krach Judy 583

Krach Judy 600

Kraemer Melissa 239

Krause Doug 110

Krauss John 849

Kresh Eric 594

Krumper Michael 757

Kruzik Tom 418

kuykendall dustin 559

Lambert Mara 609

Lambert Mara 814

LaMorte R 374

Landau Doug 502

Landers Gary 802

Landt Rick 59

Lanette Eagar Jim 689

Langley Judith 773

Lanka Mike 306

Lapointe Kenneth 217

Laughlin Alison 300

Laurie Molly 226

Lazar Burton 483

Lear Kirsten 632

LeBlanc Candy 231

Lee Jackie 798
Appendix G. Response to Comments 

278 – Smith River National Recreation Area Restoration and Motorized Travel Management

Last Name First Name Letter Number

Lee Trisha 12

Leekwijck Natalie 270

Leibold Dara 535

Lelli Elisabetta 106

Lenardson Denise 304

Lenardson Denise 325

Lent Max 448

Lentz Hugh 256

LeRoy Jack 400

Lescher George 355

Lesmond Sue 511

Leszczynski M 190

Levey Alice 419

Levin Beth 150

Levine David 133

Lian Joseph 543

Lifton Fred 447

Lim Yee 214

Limburg Lars 73

Lindley Conny 478

Lindquist Erin 726

Lindsay Kathi 794

Lindsey Joshua 368

Lips Stu 722

Lish Chris 837

Lishawa Shane 103

Litjens Jessica 557

Little Ronald 621

Litton Ruth 49

Logan Leslie 397

Long Herbert 57

Low Grant 15

Lucas Steve 163

Lund Matthew 54

Luz Eden 460

Lyons Gilly 787

Lytle Denise 42

MacArthur June 17

Madley Benjamin 652

Madrazo Angeles 341

Maize Dave 213

Major Jonathan 271

Maker Janet 671

Mander L 181

Mannan Nicole 340

Mannion Cynthia 343
Appendix G. Response to Comments 

Final Environmental Impact Statement – Appendices – 279

Last Name First Name Letter Number

Mannion Cynthia 359

Margulis Jason 553

Markus Patricia 198

Marsden Steve 523

Martin C. 740

Martin Dianne 230

Martz Charles 695

Mason Arne 134

Mason Barbara 149

Materi Sandra 432

Matranga Georgeanne 683

Mauvais Steven 485

Maza Tasunka 327

McAllister Joan 536

McCollim Patty 369

McCreary Jan 644

McCutcheon Meghan 440

McGillivary M 421

McGough Alice 465

McGregor Dallion 164

McLaughlin Michael 605

McQueen Suzanne 403

Mecke Ernst 688

Meehan Roger 538

Mefford Amanda 461

Melgarejo Marisol 257

Menighetti Laura 285

Mercer Michele 429

Mesa Annie 122

Messerschmitt Susan 98

Meyer Jane 815

Meyer Nancy 753

Meyer Twyla 613

Miettinen Anne 415

Mikasi Ayani 508

Miller Jennifer 218

Miller Ken 113

Miller Ken 237

Mills Shirley 89

Milne Martha 444

Mitchell Eileen 851

Mlynczak Raymond 554

Modjeki Jan 215

Moffatt Alden 182

Moffet Jeff 135

Mollen Phyllis 742
Appendix G. Response to Comments 

280 – Smith River National Recreation Area Restoration and Motorized Travel Management

Last Name First Name Letter Number

Montgomery Edith 254

Moore Vera 766

Moraiti Vicky 177

Moran Judy 703

Morley Dennis 454

Morris Teresa 741

Moszyk John 667

Mount Jean 96

Moy Jeanine 761

Mrkvicka Edward 678

Mulas Enzo 566

Mulcare James 221

Mulcare James 379

Mumby Robert 497

Nacrelli Michael 25

Nagel Lawrence 142

Nagel Lawrence 769

Navidad Susan 503

Neff Grace 675

Neihart Janet 606

Nelson Christie 50

Nelson Rochelle 706

Neste George 136

Neste Lisa 647

Nettleton John 552

Neus Marleen 797

Newman Natalia 596

Nichols Nancy 79

Nicodemus Sharon 501

Nicolazzo Fabio 245

Nix Kathy 352

Noel Letitia 582

Noland John 457

Norman-Jones Susan 800

Norup Paul 711

Nuessle Charlotte 405

Null Ciry 153

Null Hugh 434

O’Brien Donald 102

O’Neal Maureen 323

O’Rielly Julie 346

Oakey Victoria 278

Oggiono Nanette 602

Olivier Larry 515

Olson Allen 556

Olson David 241
Appendix G. Response to Comments 

Final Environmental Impact Statement – Appendices – 281

Last Name First Name Letter Number

Ouby Onsb 694

Padilla Melania 459

Paglia Claudia 347

Palmer Carol 391

Panayi Christopher 630

Paoluzzi Sara 601

Paoluzzi Sara 633

Pappalardo Sue 823

Pappalardo Susan (Sue) 822

Pappano Allie 732

Parker Robert 579

Parque Gideon 785

Parshall Sandra 19

Pascal Vercknocke 307

Pasqua John 696

Patten Jasmine 586

Paulson Robert 834

Pavlovska Eleonora 539

Pavlovska Eleonora 597

Paxton Dia 504

Pearson Simon 436

Peil Tom 235

Peranio-Paz Giana 375

Perry Mary 33

Peter Ware Diane 625

Peterson Sean 687

Phelan Linda 334

Phillips Stuart 144

Piasecka Ewa 283

Picchetti Gloria 396

Pierce Melody 587

Pietrowski-Ciullo Evelyn 450

Pinque Meryl 299

Pintagro Thomas 612

Pitchford Victoria 595

Platter Daniel 615

Poese David 430

Pollock Janelle 107

Potter Dave 255

Powell Gary 777

Powne Charles 354

Prehn Tyler 414

Preszler Keith 680

Prinz Johni 545

Pugliese Norman 26

Queener-Plourde Sarah 817
Appendix G. Response to Comments 

282 – Smith River National Recreation Area Restoration and Motorized Travel Management

Last Name First Name Letter Number

Quillian Phoebe 708

R Ana 467

Rabikovich Slava 654

Ralph Carol 755

Randall David 629

Range Morgaine 92

Ranstrom James 315

Ray Chris 474

Raymer Terry 569

Reed Jennifer 253

Reeder Erich 751

Reeves Ella 290

Reeves Lenore 384

Rein Kari 345

Renneke Joe 37

Repova Jana 155

Rice Ashlee 51

Richert Victoria 673

Richkus John 191

Riha John 154

Ring Geraldine 744

Ringgaard Line 653

Robinson Janet 180

Robinson Joyce 52

Rodefer Marilyn 836

Roelof Georgia 167

Rogers Ruth 656

Rohrbaugh Stacey 567

Roland Jelica 111

Roper Dan 121

Ross David 210

Rossi Daniela 734

Rougemont Nicole 123

Rubin Spencer 249

Ruiz Kathleen 376

Ruiz Raul 568

Rush Charlene 643

Ruwe Ben 720

Ryzin Mark 759

Sable Rosalie 216

Sahnow Charlotte 784

Sales Linda 158

Salgado Natasha 727

Saunders Leigh 275

Savoie Suzanne 331

Savonen Carol 799
Appendix G.Response to Comments 

Final Environmental Impact Statement – Appendices – 283

Last Name First Name Letter Number

Schaefer Sandra 124

Scherer Michele 336

Scheve Dave 853

Schmidt Irene 41

Schneebeli Christine 117

Schneider Daniela 112

Schollhorn Maria 141

Schulz Terry 555

Schwartz Gloria 333

Schwartz Joyce 463

Sciver Michael 199

Scoles Barbara 132

Scott Drake 387

Scott J. 624

Scott Mary 603

Scott Vanessa 114

Seckendorf Michael 735

seeburger john 580

Seldon Wendy 684

Self Carolyn 58

Serra Ruth 62

Shallman Elsy 618

Sharfman William 172

Shaughnessy Diane 607

Shaughnessy Diane 623

Sheehy Steve 227

Sheppard Sandra 425

Sheridan Gabriel 650

Sherwin Reid 303

Shipley Donna 752

Shipley Doug 487

Shockey Kirsten 179

Shomer Forest 152

Showerman Linda 371

Shubert Sharyn 232

Sibakov Katja 87

Siler Bret 261

Siler Bret 764

Silvey Kevin 682

Simbrow Jennifer 80

Simmons Adriene 187

Simon Carrie 168

Simon Philip 737

Simpson Robert 423

Sims Sandra 240

Singer D. 317
Appendix G. Response to Comments 

284 – Smith River National Recreation Area Restoration and Motorized Travel Management

Last Name First Name Letter Number

Skibinski Emily 548

Skinner Caroline 590

Sky Gwendolyn 498

Slavin Krista 575

Smallberries John 776

Smith Jen 516

Smith Kellie 174

Smith Lindi 510

Smith Susan 780

Snitkin Barry 20

Sodfried Bianca 88

Soldic Ivana 646

Solomon Laurie 739

Somera Pam 104

Sonenshine Scott 194

Sorensen Lise-Lotte 120

Spar Jon 204

Spath Marian 5 

Spencer Nancy 532

Squance Lynn 530

Starr Kayla 274

Stasny Kathleen 145

Stefano Courtney 665

Steininger Lorenz 36

Steitz Jim 263

Steitz Jim 284

Steitz Jim 805

Sterling Kristin 118

Stern Matt 137

Stickney Karen 520

Stierlen Lorelei 320

Stone Jeff 332

Stone Jessie 698

Stout Steven 201

Stratton Judi 768

Stratton Judi 835

Stuebing Tamara 125

Stufflebeam J 342

Such Renee 801

Sullivan Sean 229

Sully John 486

Sumrall Amber 506

Svorenova Maria 39

Sylvester June 211

Szymanski Ron 408

Tanager Casey 809
Appendix G. Response to Comments 

Final Environmental Impact Statement – Appendices – 285

Last Name First Name Letter Number

Taudvin Diane 3 

Taylor Kamia 335

Taylor Lauren 424

Tedesco-Kerrick Terry 56

Terrell Shanin 294

Themistersnoid@aol.com Anon 127

Thiemann Eva 93

Thomas Debbie 295

Thomas Ron 356

Thompson Julie 324

Thompson Maggie 208

Thomson Wil 705

Tibbot Ann 288

Tichenor Steve 591

Tidwell Stephanie 435

Tiefer Hillary 610

Tinker Caroline 839

Tirado Luis 393

Tomczak Bartlomiej 577

Torres Tatiana 464

Torsander Camilla 622

Tran Danielle 269

Trauba Jeff 445

Tromble Lee 848

Trufan Hal 361

Tufts Jeffrey 692

Turner Kernan 593

Uglesich Peter 778

Uhtoff Pat 224

Usahanun Waltraud 76

Vaile Joseph 265

Vaile Joseph 286

Vaile Sarah 281

Valenta Mila 433

Van Wicklen Betty 83

Varga John 8 

vazquez andrea 662

Vazquez Patricia 267

Veraldi Anne 728

Vieira Barbara 564

Vileisis Ann 416

Viner Helen 758

Viviane Nervo 90

Vlasiadis Andreas 518

Volmar Doris 748

VrMeer Janice 659
Appendix G. Response to Comments 

286 – Smith River National Recreation Area Restoration and Motorized Travel Management

Last Name First Name Letter Number

Waber David 206

Wadland Sue 234

Wadland Sue 238

Wadland Sue 251

Wadland Sue 293

Wadland Sue 313

Wagner Donald 404

Wagner Kimberly 301

Wakefield Marie 446

Walderra Heidi 584

Walker Wandalea 636

Waller Julia 480

Walter Mr. 639

Walter-Schemahorn Angela 157

Walters Jacqlynn 770

Wanderley Amabilia 24

Ward Sheila 701

Ward William 628

Waring Sherman 318

Waters Michelle 188

Watola Danuta 640

Weaver Randy 500

Weaver Ronald 55

Weber Robert 699

Wei Annie 588

Wei Annie 657

weih jeffrey 745

wetzel nathan 95

Whorton Brooke 704

Wienert Mark 570

Wiley Kimberly 730

Wiley Mark 44

Wilhelm Martha 466

Williams John 2 

Williams Sara 679

Williamson Debbie 203

Willis Dave 398

Wilson David 724

Windh Dean 94

Winkle Jenny 512

Winnett Jason 560

Winnett Jason 578

Winter Edward 842

Wise India 441

Witt Lore 14

Wood Wendell 225
Appendix G. Response to Comments 

Final Environmental Impact Statement – Appendices – 287

Last Name First Name Letter Number

Wood Wendell 330

Wood Wendell 499

Woodall Sandra 166

Woodriff Elaine 409

Woolley John 91

Wright Pam 53

Yorkowitz Allan 337

Young Shelly 351

Yuen Yip 244

Zabini Alessandro 258

Zarafonetis Lisa 86

Zenti Jeannine 638

Zenti Jeannine 723

Zook Suzanne 573

Zucker Marguery 131
Appendix G. Response to Comments 

288 – Smith River National Recreation Area Restoration and Motorized Travel Management

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