United States 

Department of 

Agriculture 

Forest Service

Wallowa-Whitman 

National Forest

R6

March 2012

Final Environmental

Impact Statement

Snow Basin Vegetation 

Management Project

Whitman Ranger District, Wallowa-Whitman National Forest

Baker County, Oregon
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Table of Contents

Summary.....................................................................................................................................................vii

Project Location......................................................................................................................................vii

Background.............................................................................................................................................vii

Existing Condition..................................................................................................................................vii

Purpose and Need ..................................................................................................................................viii

Proposed Action Summary......................................................................................................................ix

Issues and Alternatives Summary............................................................................................................ix

Issues to resolve and Decision to be Made...............................................................................................x

Abstract........................................................................................................................................................xi

Preface ........................................................................................................................................................xii

Document Structure................................................................................................................................xii

Chapter 1 – Purpose and Need for Action ....................................................................................................1

Introduction ..............................................................................................................................................1

Changes between the DEIS and FEIS ......................................................................................................1

Project Location........................................................................................................................................2

Current Condition.....................................................................................................................................3

Purpose and Need .....................................................................................................................................5

Proposed Action in Brief..........................................................................................................................8

Management Direction .............................................................................................................................9

Other related ongoing planning efforts...................................................................................................11

Public Involvement.................................................................................................................................11

Issues ......................................................................................................................................................12

Treaty Rights..........................................................................................................................................13

Decision Framework...............................................................................................................................14

Chapter 2 – Alternatives, Including the Proposed Action...........................................................................16

Introduction ............................................................................................................................................16

Range of Alternatives.............................................................................................................................16

Alternatives Considered in Detail...........................................................................................................16

Alternatives Considered but Eliminated from Detailed Study ...............................................................42

Alternatives Proposed by the Public during Scoping .............................................................................43

Identification of the Preferred Alternative..............................................................................................44

Comparison of Alternatives....................................................................................................................44

Chapter 3 – Affected Environment and Environmental Consequences......................................................49

Introduction ............................................................................................................................................49

Chapter 3 Guide to Resource Section Discussions.................................................................................53

Forested Vegetation ....................................................................................................................................54

Existing Conditions................................................................................................................................54

Vegetation Management History............................................................................................................54

Biophysical Environments......................................................................................................................55

Consistency with Laws, Regulations, and Policy...................................................................................62

Effects Analysis......................................................................................................................................70

Fire/Fuels Management ..............................................................................................................................86

Existing Condition..................................................................................................................................86

Consistency with Laws and Regulations................................................................................................87

Methodology and Measurement Indicators............................................................................................88

Effects.....................................................................................................................................................89

Monitoring Recommendations...............................................................................................................98

Soils ............................................................................................................................................................99
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Existing Conditions................................................................................................................................99

Methodology and Measurement Indicators..........................................................................................101

Effects Analysis....................................................................................................................................102

Monitoring Requirements.....................................................................................................................107

Watershed Aquatics..................................................................................................................................109

Regulatory Framework.........................................................................................................................109

Aquatic Habitat.....................................................................................................................................110

Forest Plan Aquatic Habitat / Riparian Desired Future Conditions......................................................110

Forest Plan Riparian Management Objectives .....................................................................................111

Direct and Indirect Effects to Watershed Processes.............................................................................116

Methodology and Measurement Indicators..........................................................................................117

Past and Ongoing Activities.................................................................................................................144

Global Climate Change ........................................................................................................................150

Aquatic Species....................................................................................................................................157

Consistency with Direction, Regulations, and Laws............................................................................178

Eagle Creek Wild and Scenic River Management Plan .......................................................................181

Endangered Species Act .......................................................................................................................183

Clean Water Act ...................................................................................................................................183

Summary of Effects Determinations for Aquatic Species....................................................................184

Biological Evaluation and Wildlife Specialist Report ..............................................................................186

Introduction ..........................................................................................................................................186

Regulatory Framework.........................................................................................................................186

Analysis Methods.................................................................................................................................187

Biological Evaluation................................................................................................................................189

Proposed, Endangered, Threatened, and Sensitive Species..................................................................189

Threatened, Endangered, and Sensitive Species Determinations.........................................................212

Management Indicator Species (MIS)..................................................................................................212

SALE AREA IMPROVEMENT PROJECTS......................................................................................262

Eagle Creek Wild and Scenic River Corridor.......................................................................................265

Habitat and Predicted Climate Trend ...................................................................................................265

Threatened, Endangered, and Sensitive Plant Species..............................................................................269

Regulatory Framework.........................................................................................................................269

Methodology and Measurement Indicators..........................................................................................269

Existing Conditions..............................................................................................................................270

Effects Analysis....................................................................................................................................272

Monitoring Requirements.....................................................................................................................280

Invasive Species........................................................................................................................................281

Existing Condition................................................................................................................................281

Climate Change ....................................................................................................................................294

Monitoring............................................................................................................................................294

Summary of Consistency Findings.......................................................................................................294

Rangeland Resource..................................................................................................................................296

Introduction ..........................................................................................................................................296

Existing Condition................................................................................................................................296

Effects Analysis....................................................................................................................................297

Mitigations and Monitoring..................................................................................................................300

Consistency and Compliance................................................................................................................301

Visuals/Scenery Resources.......................................................................................................................302

Executive Summary..............................................................................................................................302

Introduction ..........................................................................................................................................302

Regulatory Framework. ........................................................................................................................303
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Overview of Issues Addressed..............................................................................................................304

Affected Environment ..........................................................................................................................305

Desired Condition.................................................................................................................................307

Environmental Consequences...............................................................................................................312

Summary of Effects..............................................................................................................................322

Recreation Resources................................................................................................................................323

Executive Summary..............................................................................................................................323

Introduction ..........................................................................................................................................323

Forest Plan Recreation Goal.................................................................................................................326

Forest Plan Standards and Guidelines..................................................................................................327

Forest Plan Management Areas............................................................................................................328

Methodology and Measurement Indicators..........................................................................................330

Effects Analysis....................................................................................................................................331

Wild and Scenic River Resources.............................................................................................................336

Executive Summary..............................................................................................................................336

Introduction ..........................................................................................................................................336

Consistency with Laws, Regulations and Policy..................................................................................338

Desired Future Conditions....................................................................................................................339

River Plan Standards and Guidelines ...................................................................................................341

Methodology and Measurement Indicators..........................................................................................343

Effects Analysis....................................................................................................................................344

EFFECTS COMMON TO ALL ALTERNATIVES ............................................................................344

Monitoring Requirements.....................................................................................................................347

Heritage and Paleontological Resources...................................................................................................348

Heritage Resources...............................................................................................................................348

Paleontological Resources....................................................................................................................348

Environmental Consequences...............................................................................................................349

Wild and Scenic River History.............................................................................................................351

Social and Economics...............................................................................................................................352

Affected Environment ..........................................................................................................................352

Transportation System ..............................................................................................................................360

Introduction ..........................................................................................................................................360

Existing Condition................................................................................................................................361

Effects Analysis....................................................................................................................................363

Mitigations and Monitoring..................................................................................................................372

Consistency and Compliance................................................................................................................373

Potential Wilderness/Unroaded Areas......................................................................................................375

Inventoried Roadless Areas, Potential Wilderness Areas, and Other Undeveloped Areas..................375

Background...........................................................................................................................................376

Affected Environment ..........................................................................................................................378

Environmental Consequences...............................................................................................................380

Short-Term Uses and Long-Term Productivity ........................................................................................384

Air Quality............................................................................................................................................385

American Indian Rights........................................................................................................................385

American Indian Religious Freedom Act.............................................................................................385

National Historic Preservation Act.......................................................................................................385

Endangered Species Act and Regional Forester’s Sensitive Species...................................................385

Congressionally Designated Areas.......................................................................................................385

Energy Requirements and Conservation Potential of Alternatives ......................................................385

Environmental Justice in Minority Populations and Low-Income Populations ...................................386

Floodplains (Executive Order 11988) ..................................................................................................386
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National Landmarks .............................................................................................................................386

Municipal Watersheds..........................................................................................................................386

Parklands ..............................................................................................................................................386

Prime Farmlands, Rangelands, and Forestlands...................................................................................386

Research Natural Areas (RNA)............................................................................................................386

Social Groups .......................................................................................................................................387

Wetlands (Executive Order 11990)......................................................................................................387

Wild and Scenic Rivers ........................................................................................................................387

Chapter 4 – Consultation and Coordination.............................................................................................388

Preparers and Contributors...................................................................................................................388

Federal, State, and Local Agencies.......................................................................................................388

Tribes....................................................................................................................................................389

Adjacent Landowners...........................................................................................................................389

Others on Forest NEPA General Mailing List......................................................................................390

DEIS Respondents Contact List ...........................................................................................................391

Distribution of the Environmental Impact Statement...........................................................................394

Chapter 5 – Lists.......................................................................................................................................395

REFERENCES CITED ........................................................................................................................395

Acronyms .............................................................................................................................................408

Glossary................................................................................................................................................412

Appendix A – Project Maps......................................................................................................................428

Table of Contents..................................................................................................................................428

Project Maps.........................................................................................................................................429

Appendix B...............................................................................................................................................443

Appendix B-1 – Project Design Features/Best Management Practices / Mitigation Measures Applicable 

to all Alternatives..................................................................................................................................445

Appendix B-2 – Late and Old Structure Forest (LOS) – landscape Assessment .................................465

Appendix B-3 –Snags and Large Down Logs......................................................................................468

Appendix B-4 – Landscape Treated Comparison.................................................................................470

Appendix B-5 – Connectivity/Top 1/3 of Site Potential/UMZ-LMZ...................................................471

Appendix B-6 – Estimate Difference in Time (yrs) to Achieve LOS with and without Stand 

Management .........................................................................................................................................472

Appendix B-7 – Plant Association Crosswalk......................................................................................473

Appendix B-8 – Unit Treatments/Logging Systems ............................................................................474

Appendix B-9 – Management Area Direct Comparison ......................................................................484

Appendix B-10 – Potential Cumulative Activities List........................................................................491

Appendix B-11 – Transportation System-Road Maintenance and Reconstruction Segments .............497

Appendix B-12 – Transportation System: Road Closure and Decommissioning Definitions and 

Strategies ..............................................................................................................................................504

Appendix B-13 – List of Harvest Unit Activities Operations within RHCAs......................................508

Appendix B-14 Scoping Process..........................................................................................................511

Appendix B-15 – Potential Wilderness Areas – Undeveloped Areas Inventory Methodology............512

Appendix B-16 – Climate Change Synopsis for the Blue Mountain region of NE Oregon.................530

Appendix B-17 – DEIS Commenters...................................................................................................532

Appendix C – Response to Comments .....................................................................................................540

Comments used to modify alternatives in the FEIS .............................................................................540

Comments Used to Supplement, Improve, or Modify Analyses In the FEIS.......................................548

Comments used to make factual corrections in the FEIS.....................................................................590

Other Comments – Response Provided ................................................................................................591

Other Comments – No Response Provided ..........................................................................................653
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List of Tables, Figures, and Maps

Table S-1. Alternative Descriptions.............................................................................................................ix

Table 1. Subwatersheds in the Snow Basin project area...............................................................................3

Table 2. Acres by ownership for the Snow Basin project area .....................................................................3

Table 3. Wallowa-Whitman National Forest plan management areas..........................................................9

Table 4. List of alternatives and descriptions in brief.................................................................................17

Table 5. Summary of alternative 2 (proposed action) activities.................................................................25

Table 6. Sale area improvement projects....................................................................................................29

Table 7. Summary of Alternative 3 activities.............................................................................................34

Table 8. Summary of alternative 4 activities..............................................................................................41

Table 9. Comparison of alternatives: project objectives/key indicators.....................................................45

Table 10. Comparison of action alternatives activities...............................................................................45

Table 11. Comparison of alternatives significant issues/forest plan amendments......................................48

Table 12. Vegetation distribution. All NFS lands within the project area boundary..................................55

Map. Bio Physical Group Map ...................................................................................................................56

Table 13. HRV analysis for species composition (Percent)........................................................................58

Table 14. Existing forest structural stages (23,306 acres classified) ..........................................................59

Table 15. Historic range of variability- forest structure..............................................................................59

Table 16. Existing tree density in the Snow Basin planning area (Percent) ...............................................60

Table 17. Management Standards and Guidelines......................................................................................63

Table 18. Purpose and Need 1 ....................................................................................................................71

Table 19. Purpose and Need 2 ....................................................................................................................71

Table 20. LOS changes by biophysical environments in the treatment units.............................................73

Table 20a. Key indicators by alternative ....................................................................................................74

Table 21. Estimate of the number of large trees that would be removed ...................................................75

Table 22. Harvest by biophysical environments and LOS where LOS is below HRV...............................76

Table 23. Direct effects of the alternatives on species composition (treated units), (acres).......................77

Table 24. Indirect effects species composition (landscape) (percent) ........................................................77

Table 25. Direct effects tree density (percent)............................................................................................79

Table 26. Indirect effects tree density (landscape level).............................................................................79

Table 27. Direct effects for forest structural stages (Acres). Effects on the stages treated.........................80

Table 28. Indirect effects for forest structural stages. Effects on the landscape.........................................80

Table 29. HRV analysis for forest structural stages....................................................................................81

Table 30. Historical timber harvest activity................................................................................................84

Table 31. Fire Behavior Potential ...............................................................................................................92

Figure 1.......................................................................................................................................................93

Table 32. FRCC departure and fire regime condition class........................................................................94

Figure 2.......................................................................................................................................................95

Table 33. Treatments by project area..........................................................................................................97

Table 34. Soil effects model assumptions, summary of effects models ...................................................103

Table 35. Existing and proposed action detrimental soil conditions ........................................................106

Organic matter and nutrients.....................................................................................................................107

Table 36. RHCA widths for Snow Basin project area ..............................................................................111

Figure 3. INFISH stream categories and WWNF stream classes .............................................................112

Table 37. Major streams (Category 1 and 2) and miles in Snow Basin aquatic effects analysis area ......114

Table 38. Gradient of streams in the Snow Basin project area .................................................................114

Table 39. Habitat summary data for category 1 streams in the Snow Basin project analysis area...........115

Figure 4. Baseflow discharge per unit area for select tributaries..............................................................117

Table 40. Current Equivalent Clearcut Area (ECA) and Predicted ECAs for the Snow Basin Project....118

Table 41. WEPP results for timber harvest units with the highest potential for delivery.........................121
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Table 42. Estimated sediment delivery from roads in the Snow Basin project area using WEPP............123

Table 43. Proposed bridge work in the Snow Basin project area .............................................................124

Table 44. Culvert replacements on Category 1 stream segments in the Snow Basin project area............125

Table 45. Culvert replacements on category 2 stream segments in the Snow Basin project area ............125

Table 46. Acres of prescribe fire in RHCAs for Alternative 2 .................................................................127

Table 47. Comparison of activities for action alternatives with potential to increase erosion rates.........128

Table 48. Maximum seven-day mean maximum stream temperatures ....................................................132

Figure 5. Locations of water temperature monitoring sites......................................................................133

Table 49. Acres and percent of RHCA treated with thinning...................................................................136

Table 50. Delivery Mechanisms for LWD in the Snow Basin project area..............................................141

Table 51. Additions of LWD in streams in the Snow Basin project area .................................................142

Table 52. Riparian areas affected by timber harvest by harvest type and subwatershed..........................144

Table 53. The percentage of riparian areas affected by roads by subwatershed.......................................145

Table 54. Range allotments in the Snow Basin project area.....................................................................145

Table 55. Wallowa-Whitman NF recommended utilization levels to meet Forest Plan...........................147

Table 56. Summary of known past, present, and reasonably foreseeable actions ....................................156

Table 57. Aquatic species with special management status present or suspected ....................................158

Figure 6. Designated critical habitat for bull trout in the vicinity of the Snow Basin project area...........161

Table 58. INFISH RMO for pool habitat..................................................................................................176

Table 59. Standard and guidelines applicable to the fisheries ORV.........................................................181

Table 60. PETS species review, WWNF and Snow Basin project area....................................................189

Table 61. Silvicultural effects on available SSLT ....................................................................................195

Table 62. Acres of mapped lynx habitat and proposed treatment.............................................................199

Figure 7. Existing fisher suitable habitat ..................................................................................................203

Table 63. Existing and post-treatment habitat availability by alternative.................................................204

Table 64. Summary of Threatened, Endangered and Sensitive species determinations...........................212

Table 65. MIS and their primary habitats. ................................................................................................212

Figure 8. Existing LOS stand distribution ................................................................................................214

Figure 9. LOS and connectivity network, Snow Basin project area. ........................................................217

Table 66. Connectivity corridor summary ................................................................................................219

Table 67. Marten habitats amounts in Snow Basin project area and Eagle Creek Watershed..................220

Figure 10. American marten habitats, Snow Basin project area and Eagle Creek HUC ..........................221

Table 68. Proposed vegetation treatments in modeled marten habitats....................................................223

Table 69. Marten source habitat amounts untreated, Eagle Creek Watershed..........................................224

Table 70. Existing goshawk source and potential habitats .......................................................................227

Figure 11. Northern goshawk modeled source habitat..............................................................................228

Table 71. Summary of proposed treatments in goshawk source habitat...................................................229

Table 72. Residual LOS canopy closures within goshawk PFA...............................................................230

Table 73. Goshawk source habitats by alternative in Eagle Creek Watershed.........................................231

Table 74. Pileated woodpecker source and potential habitat amounts......................................................234

Figure 12. Pileated woodpecker modeled source habitat..........................................................................234

Table 75. Summary of proposed treatments in pileated source habitat ....................................................235

Table 76. Existing and post-treatment source Habitat amounts, Eagle Creek Watershed........................236

Table 77. Conservation status of cavity-nesting MIS ...............................................................................238

Table 78. Population trend data for cavity-nesting MIS...........................................................................239

Table 79. Long-term regional trend of PCE habitats................................................................................240

Table 80. Summary of sampled snags by tree species and diameter class................................................240

Figure 13. Results of snag surveys, Snow Basin project area, 2010.........................................................241

Table 81. Potential stand replacing fire, upland conifer, WWNF.............................................................242

Table 82. Snag and down log parameters and tolerance levels.................................................................243

Table 83. LRMP standards for down wood. .............................................................................................244
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Table 84. Reduction of risk to insect and wildfire disturbance, Snow Basin project area........................246

Figure 14. ODFW elk population estimates, Keating Unit.......................................................................248

Table 85. Subwatershed and project area hei using road density for all alternatives................................249

Table 86. HE values for the roads variable using distance banding. ........................................................250

Table 87. Summary of cover conversions by action alternatives (acres)..................................................251

Table 88. HEI by management area and alternative using road density...................................................251

Table 89. Summary of current road densities, Snow Basin project area ..................................................253

Table 90. Habitat relationships and biological objectives for focal landbird species, conifer forest........256

Table 91. Existing forest structure, Little Eagle and Eagle Creek-Paddy Creek subwatersheds..............258

Table 92. Landbird breeding periods and habitats....................................................................................259

Table 93. Silvicultural effects on single-storied large tree structure.........................................................260

Table 94. Silvicultural effects on mesic mixed conifer multi-storied large tree stands............................260

Table 95. Additions of large wood to streams in the Snow Basin project area ........................................264

Table 96. Downed woody Material by species and size ...........................................................................267

Table 97. Sensitive plants suspected to have suitable habitat within the Snow Basin analysis area ........270

Table 98. Carex cordillerana occurrences in the Snow Basin project area...............................................271

Table 99. Invasive plant inventory and Oregon designations...................................................................282

Table 100. Noxious weed proximity to activities in proposed action.......................................................282

Table 101. Element specific effects of the action alternatives..................................................................288

Table 102. Effects of prescribed fire on invasive non-native plants.........................................................289

Table 103. Cumulative effects determination for invasive non-native species.........................................291

Table 104: Summary of effects for all alternatives in the Snow Basin project.........................................293

Table 105. Monitoring ..............................................................................................................................294

Table 106. Livestock Grazing Allotments within the Snow Basin Project Analysis Area.......................296

Table 107. Summary of effects to rangeland resources by alternative .....................................................300

Table 108. Monitoring requirements for rangeland resources..................................................................300

Table 109. Comparison of effects by alternative for visual quality objective and scenic stability...........302

Table 110. River related visual objectives................................................................................................303

Table 111. Visual quality objectives and perceived alteration .................................................................305

Table 112. Risk and scenic stability..........................................................................................................306

Table 113. Visual quality objectives in the Wild and Scenic River corridor............................................309

Table 114. Travel route sensitivity levels.................................................................................................311

Table 115. Scenic class, visual quality objective, and scenic integrity level............................................311

Table 116. Treated acres visible within Eagle Creek River Canyon ........................................................318

Table 117. Treated visible acres within Eagle Creek River canyon .........................................................320

Table 118. Treated visible acres within Eagle Creek River canyon .........................................................321

Table 119. Summary of scenery effects and compliance..........................................................................322

Table 120. Developed trails......................................................................................................................325

Table 121. ROS goals...............................................................................................................................327

Table 122. Forest Plan Management Areas (MA) and recreation standards and guidelines....................328

Table 123. Indicators ................................................................................................................................330

Table 124. Comparison of alternatives (ALT)..........................................................................................334

Table 125. Developed recreation rites......................................................................................................337

Table 126. Developed trails......................................................................................................................338

Table 127. River Classifications and ROS Standards and Guideline #24 ................................................342

Table 128. Comparison of alternatives (ALT)..........................................................................................347

Table 129. Potential for effects of temporary road construction on paleontological resources................349

Table 130. Estimated cost of the alternatives ...........................................................................................357

Table 131. Economic analysis summary by alternative............................................................................358

Table 132. Average inland mill lumber prices (all grades) 2000 to 2009.................................................358

Table 133. Total timber harvest and non-commercial thinning jobs by alternative .................................359
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Table 134. Miles of road in the Snow Basin area by subwatershed..........................................................361

Table 135. Bridges along proposed haul routes and existing condition....................................................362

Table 136. Summarizes the various activities associated with the transportation ....................................364

Table 137: Existing material sources........................................................................................................368

Map A-1. Project Vicinity Map ................................................................................................................429

Map A-2a. Alternative 2 Vegetation Treatments......................................................................................430

Map A-2b. Alternative 2 Transportation System......................................................................................431

Map A-3a. Alternative 3 Vegetation Treatments......................................................................................432

Map A-3b. Alternative 3 Transportation System......................................................................................433

Map A-4a. Alternative 4 Vegetation Treatments......................................................................................434

Map A-4b. Alternative 4 Transportation System......................................................................................435

Map A-5. Subwatersheds and Wild & Scenic River Map ........................................................................436

Map A-6. Fish Distribution Map...............................................................................................................437

Map A-7. LOS/Old-Growth Stands and Connectivity Corridors..............................................................438

Map A-8. LOS and Old-Growth Stands with Alternative 2 Units............................................................439

Map A-9. Marten Habitat with Alternative 2 Units..................................................................................440

Map A-10. Management Areas and WUI Boundaries..............................................................................441

Map A-11. Cool/moist stands in project area ...........................................................................................442

Table B-1a. Project Design Features/BMPs/Mitigation Measures...........................................................445

Table B-1b. Monitoring Activities............................................................................................................462

Map B-2a. LOS Stands and Past Harvest on La Grande Ranger District.................................................466

Map B-2b. LOS Stands and Past Harvest on Pine (Whitman) Ranger District ........................................467

Figure B3-1. Wind damage Sparta Area...................................................................................................469

Table B-4a. All Ownerships Landscape Project Area - Treatments by Alternative..................................470

Table B-4b. NFS Ownership only Landscape Project Area - Treatments by Alternative ........................470

Table B-6. Estimated time needed to reach 21 inch DBH with and without management.......................472

Table B-7. Plant Association Cross Walk to Biophysical Group .............................................................473

Table B-8a. Commercial Treatments/Logging Systems Table by Alternative .........................................474

Table B-8b. Aspen Treatment Units.........................................................................................................481

Table B-8c. Non-commercial Harvest Units.............................................................................................482

Table B-8d. Prescribed fire Units .............................................................................................................482

Table B-9a. Management Area 1, 1W, and 3............................................................................................484

Table B-9b. Management Area 7 - Wild and Scenic- Recreational Section ............................................487

Table B-9c. Forest Plan Management Direction - Aspen Restoration......................................................489

Table B-9d. Comparison of Management Area Treated by Alternative ...................................................490

Table B-10a. Ongoing misc activities for the Snow Basin Project Area. .................................................491

Table B-10b. Ongoing Range Management Activities for the Snow Basin Project Area. .......................491

Table B-10c. Prescribed Fire Activities for the Snow Basin project area.................................................492

Table B-10d. Past Vegetation Management Activities.............................................................................492

Table B-10e. Planned Prescribed Fire Activities Adjacent to the Snow Basin Project Area....................494

Table B-11. Road System Maintenance and Reconstruction Segments - Condition and Inventory.........497

Table B-12. Decommissioning road segments .........................................................................................507

Table B-13 Harvesting operations within RHCAs....................................................................................508

Table B-14a. List of letters and emails comments on the proposed received during scoping period.......511

Table B-14b. Newspaper Media Articles about Snow Basin Project .......................................................511

Table B-15a. Summary of acres evaluated in the inventory process........................................................513

Table B-15b. Other undeveloped lands.....................................................................................................517

Table B-15c. Final Inventory of Potential Wilderness Areas...................................................................519

Map 1. Existing IRAs ...............................................................................................................................521

Map 2. Past Activities...............................................................................................................................522

Map 3. Road Buffers.................................................................................................................................523
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Map 4. Acres Not Containing Roads........................................................................................................524

Map 5. Potential Wilderness/Undeveloped Lands....................................................................................525

Map 6. Alternative 2 Potential Wilderness/Undeveloped Lands..............................................................526

Map 7. Alternative. 3 Potential Wilderness/Undeveloped Lands.............................................................527

Map 8. Alternative 4 Potential Wilderness/Undeveloped Lands..............................................................528

Table B-17. List of DEIS Commenters.....................................................................................................532
Summary Snow Basin Vegetation Management Project FEIS

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SUMMARY

Project Location

The Snow Basin Vegetation Management Project (hereafter referred to as the Snow Basin Project) is 

located on the Whitman Ranger District on the Wallowa-Whitman Nation Forest. The planning area is 

approximately 28,545 acres in size and is within Baker County, Oregon. The planning area is within T.7S, 

R.44E, all sections and T.8S R.44E most sections. The project is primarily located in Paddy Creek-Eagle 

Creek and Little Eagle Creek Subwatersheds, though it has minor acreages in three other subwatersheds. 

The planning area is located northwest of Halfway and Richland, Oregon. Approximately 9,500 acres of 

wildland urban interface designated by the Baker County Community Wildfire Protection Plan (Baker 

County 2006) surrounding the Surprise Springs, Sparta, East Eagle/Main Eagle and Carson/Pine 

communities are included in the planning area.

Background

Historically, frequent fire events actively influenced the vegetative patterns present on the Snow Basin 

planning area landscape. Forests with this type of fire return interval naturally developed mosaic 

vegetative conditions consisting of mostly open, park-like stands dominated by single storied stands of 

large ponderosa pine trees surrounding small patches of mixed conifer forest. An analysis of existing and 

historical vegetation has indicated that active management is warranted for upland forests in the Snow 

Basin planning area. High levels of insect and disease susceptibility, caused predominantly by overly 

dense stands of shade tolerant trees, are symptoms of impaired forest health and deteriorating ecosystem 

integrity. These symptoms are related to changes in three vegetation components: species composition, 

forest structure and tree density.

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

conditions due to fire suppression and other past forest management practices. Shade tolerant tree species 

have proliferated in the understory, particularly in the warm/dry biophysical environments (85-90 percent 

of the planning area). Trees from the shade tolerant understory, grand fir and Douglas-fir, have become 

dominant across the landscape while additional ingrowth has further increased stand density as a result of 

long periods without disturbance. Individual tree growth rates are low as a result of inter tree competition 

for limited resources. Desired trees species recruitment is inadequate to replace the existing large 

ponderosa pine and western larch trees as density dependent mortality rates increasingly remove them 

from the landscape. Another factor influencing current forest health is the high susceptibility of grand fir 

and Douglas-fir to insects, disease and detrimental fire effects compared to the large ponderosa pine and 

western larch trees that historically dominated this landscape during the mid 1800s. Overall, forest health 

has declined in the planning area due to overstocking and species composition alterations.

Existing Condition

The existing forested conditions are summarized as follows:

• A proliferation of shade tolerant tree species, multi-storied forest structure and overstocking of 

small diameter trees.

• An excess of stands in the understory re-initiation structural stage and too little of the single story 

with large trees common structural stage in dry forest environments.

• An excess of high density forest conditions and too little of low density forest conditions in dry 

forest environments.

• An increased risk and occurrence of outbreaks of defoliating insects and bark beetles.
Summary Snow Basin Vegetation Management Project FEIS

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• Mistletoe infection that has spread throughout the landscape in all host species with infection 

levels so high in some areas that stand development is jeopardized.

• Reduced growth rates and tree vigor resulting in reduced rates of future late and old structural 

stand recruitment.

• Ponderosa pine, western larch, and aspen are in decline due to competition with shade tolerant 

tree species and low seedling and sapling survival and recruitment.

• Substantial accumulations of live and dead fuel loads, in some cases more than twice the 

accumulations expected when fire plays a stand maintenance role on the landscape.

• Sawlog, pulp, biomass and fuelwood are generally scarce or unavailable to regional markets.

Purpose and Need

The purpose and need for action is generated by the difference between current conditions and desired 

conditions. Desired conditions are based on goals and management direction provided in the WallowaWhitman National Forest Land and Resource Management Plan (USDA 1990). The desired forested 

conditions are summarized as follows:

• Forest species composition is dominated by ponderosa pine and western larch across much of the 

landscape in warm/dry forest environments.

• Structural stages within the historical range of variability for their respective biophysical 

environments. The understory re-initiation stage accounts for a lower percentage of the planning 

area while single story structure is increased across the landscape, especially in warm/dry forest 

environments. 

• The amount of high density (closed) forest is reduced and the amount of low density (open) forest 

is increased to levels within the historical range of variability.

• Mistletoe infection levels are within the natural ranges expected in a fire maintained landscape. 

Mistletoe infections exist at an endemic level without threatening the development and 

maintenance of late and old structural stands.

• Insects and diseases operate mostly at endemic levels. Fluctuation occurs during normal outbreak 

cycles.

• Ponderosa pine, western larch and quaking aspen exist in the proportions found historically in the 

planning area. Existing hardwood sites are protected.

• Overall, less than 25 percent of the planning area has a high potential for supporting a stand 

replacing wildfire.

• Sawlogs, pulp, biomass and fuelwood are provided to private and public markets.

In order to move conditions in the planning area toward the desired condition, the following objectives 

have been identified.

Purpose and Need 1: Manage forest structure, composition and density towards landscape historic range 

of variability (HRV) and improve sustainability.

• Non-LOS: Create more single story structure; reduce stand densities to accelerate development of 

LOS characteristics; and balance species compositions to site capabilities and disturbance 

regimes.

• LOS: Create more single story structure, reduce threats to existing LOS caused by overstocking, 

ladder fuels, and encroachment of late seral species.
Summary Snow Basin Vegetation Management Project FEIS

ix

Purpose and Need 2: Maintain and increase landscape resilience to the risk of uncharacteristic 

disturbance.

• Wildfire: Reduce overall stocking, ladder fuels, multistory structure, overstory canopy closure 

and dominance of fire susceptible species that contribute to higher fire intensities, higher post-fire 

mortality rates and crow fire potential.

• Insects (bark beetles/defoliators): Reduce presence of insect host species, overall stand density 

and multi-layered stands.

• Disease: (dwarf mistletoe/Indian paint fungus): Reduce presence of infected trees, host tree 

species, overall stocking and multi-layered stands that contribute to accelerated levels of 

outbreak.

Purpose and Need 3: Provide a supply of forest products to the public to utilize forest resources and to 

provide a supply of materials to local markets. 

Proposed Action Summary

The proposed action (Alternative 1) would meet the purpose and need by implementing commercial 

harvest of timber (11,495 acres) to address uncharacteristic species composition, under-represented stand 

structures and unsustainable tree densities; post harvest noncommercial thinning (9,926 acres) to address 

uncharacteristic species composition, under-represented stand structures and unsustainable tree densities, 

and to reduce ladder fuels; noncommercial thinning only (81 acres) to address unsustainable stand 

densities and reduce ladder fuels; post harvest fuels treatments (10,467 acres, including 5,084 acres of 

grapple piling/burn and 146 acres hand pile/burn) to reduce natural and activity created fuels loadings; 

conifer removal within aspen (38 acres) to enhance and protect underrepresented stand types, and natural 

fuels prescribed fire (4,995 acres) to reduce natural fuel loading and lower crown mistletoe infection. 

Danger tree removal would occur along open system haul roads (230 miles). No new permanent road 

construction would occur. No inventoried roadless areas (IRAs) would be affected by this project. Three 

forest plan amendments would be needed in order to implement the proposed action.

Issues and Alternatives Summary

Two key issues were identified during scoping: impacts to late and old structure (LOS) stands and harvest 

of trees greater than 21 inches diameter at breast height (DBH). Three additional issues were identified 

during the review of comments received after the public release of the DEIS: temporary road 

construction, wildlife connectivity corridors, and American marten habitat.

The Forest Service developed four alternatives to respond to the key issues: no action, the proposed 

action, and two other action alternatives. The alternatives are described in detail in chapter 2. Alternative 

3 is the agency’s preferred alternative.

Table S-1. Alternative Descriptions

Alternative Brief Description

Alternative 1 

(no action)

The no action alternative is the baseline for comparing the action alternatives. No treatments are 

proposed for this alternative and biological and physical processes would be allowed to continue 

on their current trajectory.

Alternative 2 

(proposed action)

This is the initial agency proposed action that would respond to the purpose and need and 

accomplish the project’s objectives. Forest structure would be moved toward conditions 

historically present and the risk of high severity disturbance on the landscape would be reduced 

through a combination of commercial thinning, non-commercial thinning, and prescription

burning. Commercial products would be produced by these activities. Three forest plan 

amendments would be required to implement the activities proposed for this alternative.
Summary Snow Basin Vegetation Management Project FEIS

x

Alternative 3

(agency preferred 

alternative)

This alternative was developed in response to concerns regarding impacts to late and old 

structure (LOS) stands, temporary road construction, American marten habitat and wildlife 

connectivity corridors and to accomplish project objectives while still meeting the purpose and 

need. Activities proposed for alternative 3 would not result in a net loss of LOS stands in the 

project area. Temporary road construction would be reduced in the most sensitive areas and 

stand density would be retained above the forest plan minimum standards in wildlife connectivity 

corridors. American Marten habitat requirements would be protected in identified American 

marten habitat within the project area. Two forest plan amendments would be required to 

implement the activities proposed for this alternative.

Alternative 4

This alternative was developed in response to concerns regarding removal of large trees, 

impacts to LOS stands, temporary road construction, American marten habitat and wildlife 

connectivity corridors. Treatments proposed for alternative 4 would not result in a net loss of 

LOS stands and would not include the harvest trees 21 inches DBH or greater. No temporary 

roads would be constructed, and stand density would be retained above the forest plan 

minimum standards in wildlife connectivity corridors. American marten habitat requirements 

would be protected in identified American marten habitat within the project area. No forest plan 

amendments would be required.

Issues to resolve and Decision to be Made

Based upon the effects of the alternatives, the responsible official will decide to:

• Select the proposed action 

• Select an action alternative that has been considered in detail

• Modify an action alternative, or select the no-action alternative

• Identify what project design features, monitoring tasks and any additional mitigation measures 

would apply 

• Amend the Wallowa-Whitman National Forest Land and Resource Management Plan to 

incorporate selected forest plan amendments, or not.

The responsible official will evaluate the alternatives by:

• Examining how well they meet the underlying purpose and need for action

• Considering their responsiveness to the issues and concerns raised by the public and other 

agencies

• Reviewing their likely environmental effects and, in particular, their short and long term impacts 

and benefits to late and old structural stands, large tree retention and development, wildlife 

connectivity corridors and American marten habitat

• In addition, trade-offs concerning temporary road construction will be considered.
Abstract Snow Basin Vegetation Management Project FEIS

xi

FINAL ENVIRONMENTAL IMPACT STATEMENT

Snow Basin Vegetation Management Project

Baker County, Oregon

Lead Agency: USDA Forest Service

Responsible Official: Monica J. Schwalbach, Forest Supervisor

Wallowa-Whitman National Forest

Information Contact: Dea Nelson, NEPA Coordinator

Wallowa-Whitman National Forest

PO Box 907

1550 Dewey Ave. 

Baker City, OR 97814

(541) 523-6391

TDD (541) 523-1405

ABSTRACT

The Forest Service is proposing vegetation and fuels management to improve forest health, vigor and 

resilience to insects, disease and fire in upland forests that are outside their historical conditions for

species composition, structural stage and stocking densities. Proposed management activities would move 

stand conditions toward historical conditions while reducing fuel loadings, providing sawlogs and wood 

fiber products for utilization by regional and local industries and managing for wildlife habitat 

components.

This final environmental impact statement (FEIS) documents the detailed analysis of four alternatives, 

including the no action alternative, developed by the Forest Service to address resource conditions within 

the 28,545 acre Snow Basin Vegetation Management Project planning area. Alternative 1 is the no action 

alternative. If selected, none of the activities proposed in the action alternatives would be implemented 

and conditions in the planning area would continue on the current trajectory. Alternative 2 is the proposed 

action and would commercially harvest on approximately 11,495 acres and reduce activity and natural 

fuels on approximately 20,692 acres. Alternative 3 is the agency preferred alternative and addresses new 

information and concerns about maintaining late and old structural stage stands, wildlife connectivity 

corridors, American marten habitat and temporary road construction. Alternative 3 would commercially 

harvest on approximately 11,013 acres and reduce activity and natural fuels on approximately 18,995 

acres. Alternative 4 is designed to respond to concerns about the removal of large trees, impacts to 

wildlife connectivity corridors, American marten habitat and temporary road construction. Alternative 4 

would commercially harvest on approximately 9,228 acres and reduce activity and natural fuels on 

approximately 17,693 acres. 
Preface Snow Basin Vegetation Management Project FEIS

xii

PREFACE

Document Structure

The Forest Service has prepared this final environmental impact statement (FEIS) in compliance with the 

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

This FEIS discloses the direct, indirect and cumulative environmental impacts that would result from the 

proposed action and alternatives. The format of this FEIS follows the Council on Environmental Quality 

(CEQ) recommended format (40 CFR 1502.10). The document is organized into four chapters: 

Chapter 1 Purpose and Need for Action

This chapter includes information about the history of the project proposal, the purpose of and need for 

the project, and the agency’s proposal for achieving that purpose and need. This section also details how 

the Forest Service informed the public of the proposal and how the public responded. 

Chapter 2 Alternatives, including the Proposed Action

This chapter provides a more detailed description of the agency’s proposed action as well as alternative 

methods for achieving the stated purpose. These alternatives were developed based on significant issues 

raised by the public, the Forest Service and other agencies. This discussion also includes mitigation 

measures. Finally, this section provides summary comparison tables of the activities associated with each 

alternative, how well the alternatives respond to the purpose and need, and the alternatives responsiveness 

to key issues. 

Chapter 3 Affected Environment and Environmental Consequences

This chapter describes the affected environment and the environmental effects of implementing the 

proposed action and other alternatives. This analysis is organized by resource area. 

Chapter 4 Consultation and Coordination

This chapter provides a list of preparers and agencies consulted during the development of this final 

environmental impact statement (FEIS) and information regarding the distribution of this FEIS. 

Chapter 5 Lists

This chapter provides a glossary containing detailed information on terms and an acronyms list with 

definitions of the acronyms used in this document. This chapter also includes and index 

Other

This FEIS also includes a listing of literature cited section.

Appendices

The appendices provide more information to support the analysis presented in this FEIS. They include: 

appendix A: Maps of the Proposed Action and Alternatives, appendix B: Additional Information and 

Other Maps Supporting the Analysis and appendix C: Response to Comments

Additional documentation, including more detailed analyses of project-area resources, is available from 

the administrative record (project record) at the Whitman Ranger District Office, P.O. Box 947, 3285 

11th Street, Baker City, Oregon 97814.
Chapter 1 Snow Basin Vegetation Management Project FEIS

1

CHAPTER 1 – PURPOSE AND NEED FOR ACTION

Introduction

The Snow Basin Vegetation Management Project draft environmental impact statement (DEIS) was 

prepared by the Forest Service and published in April 2011. Comments received during the DEIS 45-day 

comment period and Forest Service responses to those comments are available in appendix C.

Review of comments by the interdisciplinary team and the responsible official for the project resulted in 

the identification of additional issues and the need for further analysis and modifications to alternatives. 

Any additions or changes between the DEIS and this FEIS are identified at the beginning of each chapter.

A vicinity map and other maps for this project are located in appendix A.

Chapter 1 includes a brief description of the project area, purpose of and need for action, the agency’s 

proposal for achieving the purpose and need and a list of what decisions are to be made. In addition, this 

chapter describes public involvement, key issues identified and resource issues analyzed for 

environmental effects.

Issues and Alternatives Summary

Two significant issues were identified during scoping: impacts to late and old structure (LOS) stands and 

harvest of trees greater than 21 inches diameter at breast height (DBH). Three additional issues were 

identified during the review of comments received after the release of the DEIS: temporary road 

construction, wildlife connectivity corridors, and American marten habitat.

The Forest Service developed four alternatives to respond to the significant issues: no action, the 

proposed action, and two other action alternatives. The alternatives are described in detail in chapter 2. 

Alternative 3 is the agency’s preferred alternative.

Changes between the DEIS and FEIS

Changes to chapter 1 include: 

• Editorial changes to the text and format in all sections of the chapter 

• Clarification of the purpose and need, including incorporation of recent agency guidance at FSM 

2020 that provides foundational policy for using ecological restoration to manage National Forest 

System (NFS) lands in a sustainable manner 

• Identification of additional key issues in response to comments 

• Identification of other resource issues that could have a cause and effect relationship with proposed 

activities and associated measures that are provided to compare environmental effects of the

alternatives

• Addition of the Treaty Rights section to address the Nez Perce Tribe and Confederated Tribes of the 

Umatilla Indian Reservation

Changes to chapter 2 include: 

• Editorial changes to the text and format in all sections of the chapter 

• Clarification of the proposed action and amendments

• The term “partial overstory removal” has been replaced by the term “overstory removal” in all 

instances
Chapter 1 Snow Basin Vegetation Management Project FEIS

2

• Adopted USDA Forest Service R6 old growth definition establishing 150 years of age as minimum 

age of old growth trees has been adopted. Trees exhibiting old growth characteristics following Van 

Pelt guidelines (Van Pelt 2008) would be retained in all areas regardless of size

• Elimination of all regeneration harvest in alternatives 2, 3 and 4

• Large wood additions to approximately 7.5 miles of stream has been added to alternatives 2, 3 and 4to 

enhance fisheries habitat

• The long term management of the stands surrounding the Paddy Creek seed orchard as a shaded fuel 

break has been clarified

• Addition of guidelines for retention of trees within 20 feet of large, old grand fir trees identified as 

wildlife trees

• Minor modification of treatments, acres and road miles in all action alternatives to reflect updates in 

the analysis and additional data gathering

• Change in acres treated by prescribed burning in all action alternatives to more accurately reflect 

expected accomplishments and smoke management guidelines

• A forest plan amendment allowing treatment in late and old structural stands with uncharacteristic 

species compositions was added to alternative 3

• Alternative 3 was modified to better protect wild and scenic river (WSR) values by eliminating 

temporary roads within the WSR corridor and associated harvest units

• Alternatives 3 and 4 were modified to better protect habitat for American marten by adjusting 

prescriptions to maintain 50 percent or greater canopy closure in areas identified as potential 

American martin habitat

• Alternatives 3 and 4 were modified to better protect wildlife connectivity corridors by retaining basal 

area at a level between the upper and mid management zone (approximately an additional 10-20 

square feet of basal area per acre)

• Comparison tables were updated to reflect modified alternatives and to display resource measures.

Changes made to chapter 3 between the DEIS and FEIS include: 

• Editorial changes to the text and format in all sections of the chapter 

• The results of new bird survey data was added to the wildlife effects analysis 

• Additional modeling of soil erosion hazard was added to the soils section

• Pre-implementation and post-implementation soils monitoring were added for all commercial harvest 

units with additional mitigations proposed for any units falling outside acceptable parameters. 

Complete descriptions of these activities can be found in appendix B.

• Modification and/or additions to most effects sections in response to public comments and additional 

information

• Modification of treatment prescriptions to meet wildlife connectivity corridor and American marten 

habitat objectives 

• Summaries of the effects analyses are included in this chapter; full reports can be found in the project 

record

• Additional silviculture analysis includes historic range of variability (HRV) for tree density and 

species composition

• New data was used to calculate estimates of 21 inch and larger trees that would be removed under the 

action alternatives

Project Location

The Snow Basin Vegetation Management Project planning area is located within in the WallowaWhitman National Forest Whitman Ranger District. It is 28,545 acres in size and is within Baker County, 
Chapter 1 Snow Basin Vegetation Management Project FEIS

3

Oregon. The towns of Richland and Halfway are located to the south and southeast and Medical Springs 

is to the west. A vicinity map of this project area is provided in appendix A. 

The project planning area is within portions of T7S, R44E, all sections, and T8S, R44E, most sections.

The project area is primarily located within two main subwatersheds (Paddy Creek-Eagle Creek and Little 

Eagle Creek) and has minor acreages in three other subwatersheds included (Goose Creek, Lower Eagle 

Creek and East Fork Eagle Creek). 

Table 1. Subwatersheds in the Snow Basin project area

Subwatershed Name Acres

Paddy Creek-Eagle Creek 20,168

Little Eagle Creek 8,142

Goose Creek 166

Lower Eagle Creek 68

East Fork Eagle Creek 1

Total 28,545

The Snow Basin project planning area is delimited primarily by subwatershed boundaries. On the west it 

follows the divide between Ruckles Creek- Powder River and Eagle Creek watersheds. On the northwest 

the boundary parallels the divide between East Fork Eagle and Paddy Creek. Along the east it follows the 

divide between Little Eagle Creek and Lower Eagle (Summit Creek and Skull Creek). On the south it 

follows the boundary between NFS and private lands. 

The Little Eagle Meadows inventoried roadless area (IRA) lies north of the planning area and the Eagle 

Cap Wilderness is north of the IRA. Approximately 9.5 miles of the main stem of Eagle Creek, 

designated under the national wild and scenic river system in 1988 with the Omnibus Oregon Wild and 

Scenic Rivers Act, lies within the project planning area. 

Primary access to the area includes forest system roads (FR) 77 from Richland, 67 from Medical Springs 

and 7710 from Halfway. The planning area includes 1,772 acres of private deeded in-holdings and 280 

acres owned by Baker County. 

Table 2. Acres by ownership for the Snow Basin project area

Ownership Acres

National Forest System (NFS) lands 26,493

Private (intermingled)* 1,772

Baker County (intermingled)* 280

Total 28,545

No treatments are proposed for private or county lands. 

Four communities, each comprised of private lands with widely spaced dwellings in a forested setting, lie 

within or adjacent to the planning area: Surprise Springs, Sparta, East Eagle/Main Eagle and Carson/Pine. 

Approximately 9,500 acres of wildland urban interface (WUI) associated with these areas of settlement, 

as identified in the Baker County Community Wildfire Protection Plan (Baker County 2006), are included 

within the planning area.

Current Condition

Pre-settlement fire actively influenced the vegetative patterns of this landscape. Most of the Snow Basin 

planning area is considered warm dry upland forest because of its generally south facing exposure and 

mid to low elevation. This area likely experienced high fire occurrence rates with a fairly frequent fire 

return interval. Forests with this type of fire return interval naturally developed mosaic vegetative 
Chapter 1 Snow Basin Vegetation Management Project FEIS

4

conditions consisting of mostly open, single storied structure dominated by large ponderosa pine trees

with minor components of mixed open and dense mixed conifer forests on cooler high elevation sites. 

The current landscape is characterized by deviations from the historic (natural) range of variability for

various biophysical environments, especially the warm dry forest environments, which comprise over 85-

90% percent of the planning area. Forests typical of more moist conditions occur mostly as small 

scattered patches across the landscape intermixed with the surrounding drier types. These stands represent 

the dry end of the classification for cool/moist/dry vegetation in this landscape. The adjacency and slope 

location of many of the moist stands proposed for treatment make it likely that stand conditions and fire 

frequency would have been similar, if not identical to those found on the adjacent drier sites. Modeling 

indicates that species composition is within historical norms, though the model may be underestimating 

the actual departure in these stands because of the proximity to dry sites and the mosaic occurrence of 

these stands. These cool/moist/dry stands are, however severely lacking in multi-story structure with large 

trees and are predominantly closed rather than predominantly open compared to historical norms.

The historic range of variability (HRV) is the expected range of tree species, tree density and forest 

structure under natural, unmanaged disturbance patterns. An analysis of existing and historical vegetation 

characteristics (forest vegetation section, chapter 3) indicates that there has been a large scale shift away 

from a landscape dominated by late and old structure (LOS) forest containing large diameter open grown 

ponderosa pine and western larch. This shift is especially pronounced in dry forest types. As a result of 

early seral past land management activities including aggressive fire suppression, current conditions in the 

planning area are dominated by dense, younger, multi-layered, late seral tree species, such as grand fir 

and Douglas-fir uncharacteristic of the HRV. Existing overstory ponderosa pine and western larch can’t 

compete with true firs in the existing overcrowded conditions. Replacement seedlings and saplings for the 

remaining desired overstory trees are not able to seed and grow in adequate numbers under these dense 

stand conditions. 

Tree density has increased throughout the project planning area because shade tolerant species, especially 

grand fir, have proliferated in the absence of fire on the landscape. Increased tree density also means that 

competition between trees for available resources such as water, sunlight and nutrients has increased

(Oliver and Larson 1990), weakening trees, and making them more susceptible to mortality from insects, 

diseases and climatic stresses. These changes in landscape condition have increased the potential 

occurrence for uncharacteristic disturbance patterns including high severity, stand replacing fire, and 

wide-spread insect outbreaks and disease. 

Due to their intolerance to shade and the lack of disturbance, ponderosa pine, western larch, and quaking 

aspen have all declined in health, vigor and abundance. Without disturbance, this trend is likely to 

continue and accelerate. This has also corresponded to an increase in live and dead fuel loads.

The existing forested conditions are summarized as having:

• A proliferation of shade tolerant tree species. All of the major biophysical environments in the 

planning area currently contain far more acres of grand fir and Douglas-fir dominated forest than 

existed historically. The warm grand fir and warm/moist Douglas-fir biophysical environments in the 

planning area currently contain less than half the ponderosa pine and western larch dominated forest 

that existed historically

• A surplus of stands in the understory re-initiation stage across all major biophysical environments in 

the planning area. These understory re-initiation stage stands comprise three to four times the amount 

that existed historically in the majority of the planning area

• A deficit of stands in the single story large trees common structural stage (averaging 5 percent) in

biophysical environments compared to historical conditions (15-55%)
Chapter 1 Snow Basin Vegetation Management Project FEIS

5

• A deficit of stands in the multi-story large trees common structural stage (approximately 17 percent) 

in cool/moist biophysical environments compared to historical conditions (30-60 percent)

• A very high departure from historical stand density conditions across the landscape. Currently the

majority of the planning area has more than four times the historical percent of high density forest

• Increased susceptibility of outbreaks of defoliating insects and bark beetles. Douglas-fir and grand 

fire are primary host species of defoliating insects and dominate far more stands in the planning area 

than they did historically

• Warm/moist Douglas-fir and warm/dry Douglas-fir biophysical environments in the planning area are 

experiencing elevated levels of ponderosa pine mortality from Western Pine Beetle

• Ongoing Douglas-fir beetle outbreaks recorded in the East Eagle Creek drainage, an immediately 

adjacent watershed to the project area, are causing high mortality in old growth forest stands

• Mistletoe infection has spread throughout the landscape in all host species; with infection levels in

some areas so high that stand development is jeopardized

• Reduced growth rates, which are affecting the rate of large tree development that will make up the 

future LOS

• Western larch, quaking aspen, and ponderosa pine are in decline due to competition with more shade 

tolerant tree species. There are 29 sites (approximately 38 acres) of hardwood stands that need 

management in order to be protected and restored

• The existing landscape has a high to moderate fire regime condition class departure of 64%

• Overall, 86 percent of the Snow Basin landscape has a high potential for supporting a stand 

replacement wildfire. This is uncharacteristically high as compared to the HRV for the area

• Existing predicted flamelengths (6-14 feet) and rates of fire spread (18-126 chains per hour) would 

make direct attack firefighting techniques ineffective and dangerous

Supply of sawlog, pulp, biomass and fuelwood is below demand regionally 

Purpose and Need

This section explains the purpose and need for project underlying the proposed action. The purpose and 

need for action is generated by the difference between current conditions and desired conditions. Desired 

conditions are based on forest plan direction and management direction, as amended, and quantified 

through scientifically based resource management principles and best available science information. The 

desired future condition can be described as a mosaic landscape that has a distribution of forested 

structural stages, species compositions, tree diameters, and relative densities within the natural (historic) 

range of variability for these sites. Returning stands to more characteristic conditions will create resilient1

and sustainable2 forest conditions, which are able to respond to disturbance processes and ensure

continued forest productivity. Specifically, the desired landscape is one comprised predominantly of 

large, open grown ponderosa pine and western larch forest intermixed with a diversity of other structural 

stages, species, and densities at varying scales. 

Specific components of the desired condition across this landscape include:

 1 Forest Service Manual 2020 - Ecological Restoration and Resilience (Effective date 08/30/2011) defines resilience

as “the ability of a social or ecological system to absorb disturbances, while retaining the same basic structure and 

ways of functioning, the capacity for self-organization, and the capacity to adapt to stress and change.” 

2 Forest Service Manual 2020 - Ecological Restoration and Resilience (Effective date 08/30/2011) defines 

sustainability: “Meeting needs of the present generation without compromising the ability of future generations to 

meet their needs. Sustainability is composed of desirable social, economic, and ecological conditions or trends 

interacting at varying spatial and temporal scales, embodying the principles of multiple-use and sustained-yield 

(FSM 1905).” 
Chapter 1 Snow Basin Vegetation Management Project FEIS

6

• In warm/dry grand fir, Douglas-fir/ponderosa pine and warm/moist Douglas fir biophysical 

environments the majority (75-90 percent) of forested stands would contain species compositions

dominated by ponderosa pine and/or western larch trees

• In cool/moist/dry grand fir biophysical environments 30-60 percent of forested stands would contain 

species composition dominated by ponderosa pine and western larch trees

• The understory re-initiation stage abundance would be reduced across the planning area to 5-25 

percent or less in all biophysical environments

• Between 15-55 percent of forested stands would be in the single story large trees common structural 

stage in the warm/dry grand fir, Douglas-fir/ponderosa pine and warm/moist Douglas fir biophysical 

environments

• The amount of high density (closed) forest would be between 5-15 percent of the planning area in 

warm/dry grand fir, Douglas-fir/ponderosa pine and warm/moist Douglas fir biophysical 

environments

• The amount of high density (closed) forest be between 15-30 percent in cool/moist/dry grand fir 

biophysical environments would 

• Insects and diseases would operate mostly at the endemic levels. Host species would occur in the 

same proportions that they occurred historically

• Mistletoe infection levels be within natural ranges of a fire maintained landscape; mistletoe infections 

would exist at an endemic level without threatening the development and maintenance of LOS 

• Trees in the planning area would have more vigorous growth rates as a result of low inter-tree 

competition, resulting in increased LOS recruitment

• Western larch, quaking aspen and ponderosa pine would exist in the proportions found historically in 

the planning area. The existing 29 hardwood sites in the planning area would be restored and 

protected

• The majority of landscape in the planning area would have fire regime condition classes (condition 

class 1) indicating a low departure from reference conditions

• Overall, less than 25% of the Snow basin landscape would have a high potential for supporting a 

stand replacing wildfire

• Predicted flamelengths would be less than 4 feet and rates of fire spread (2-16 chains per hour) would 

make direct attack fire fighting methods feasible

• The project area would provide more sawlogs, pulp, biomass and fuel wood available to private and 

public markets.

Objectives associated with the purpose and need are listed below, as well as key indicators that will be 

used to evaluate and compare how well the proposed action and alternatives to the proposed action would 

address the objectives.

Purpose and Need 1: Manage forest structure, composition and density towards landscape HRV 

and improve sustainability.

There is need to reestablish and retain ecological resilience and sustainability in the Snow Basin project 

area as a result of current vegetative conditions that are outside the historic range of variability and fuel 

conditions that clearly indicate the landscape is moderately to significantly altered from historic 

disturbance regimes. One purpose of the proposed action is to manage forest structure, composition and 

density towards landscape HRV to create a more resilient and sustainable-forested ecosystem. Objectives 

are:

Non-LOS

Create more single story structure; reduce densities to accelerate development of LOS sized trees, balance 

species composition to reflect historical norms and disturbance regimes. 
Chapter 1 Snow Basin Vegetation Management Project FEIS

7

LOS

Create more single story structure; reduce threats to existing LOS caused by over stocking, ladder fuels, 

and encroachment of late seral species. 

Key indicators

• Acres of non LOS structural stages treated to change stand development toward single strata with 

large trees

• Acres of LOS restored to characteristic conditions through density reduction and species shift

• Acres of multi-storied LOS changed to single storied LOS

• Acres of increased radial growth for accelerated large tree development

• Acres where tree species composition trending towards characteristic condition

• Acres where structural stages trending towards HRV 

Purpose and Need 2: Maintain and increase landscape resilience to reduce the risk of 

uncharacteristic disturbance.

There is a need to reduce stand densities, develop specific stand structures, manage species compositions 

and reduce fuel loading in order to reduce conditions favorable to insect and disease outbreaks and 

uncharacteristic wildfire damage. By moving these forest conditions toward the historic range of 

variability, ecosystem processes, such as response to wildfire, insects and disease, are more resilient and 

self-sustaining (Kaufmann et al. 1994, Egan and Howell 2001). The second purpose of the project is to 

move the landscape toward historical conditions to reduce the risk of uncharacteristic disturbance in both 

scope and magnitude. Objectives are:

Wildfire: Reduce overall stocking, surface and ladder fuels, multistory structure, overstory canopy closure, 

and fire susceptible species that contribute to higher fire intensities, high post-fire mortality rates and 

crown fire susceptibility. 

Insects (bark beetles/defoliators): Reduce presence of insect susceptible tree species, overall stocking and 

multi-layered stands. 

Disease (dwarf mistletoe/Indian paint fungus): Reduce presence of infected trees, host tree species, overall 

stocking and multi-layered stands that contribute to accelerated levels of outbreak. 

Key indicators 

• Acres where stand densities managed to reduce risk of bark beetles 

• Stand replacement potential (percent)

• Fire regime condition class of the landscape as measured by FRCC departure percent

• Acres of expected change in fire behavior potential

Purpose and Need 3: provide a supply of forest products to the public to utilize forest resources and 

to provide a supply of materials to local markets. 

Wood products play an important role in the local economy by providing employment and revenue. 

There is a need to provide wood products to help maintain the existing lumber and forest products 

infrastructure and to support local employment, providing for community stability. The Forest Plan 

includes direction to provide for the production of wood fiber consistent with resource objectives, 

environmental requirements and economic efficiency insofar as possible to meet projected production 

levels (Forest Plan p. 4-4, 4-5) while providing jobs to area residents.

Key indicators 

• Volume of forest products provided to forest industries and public
Chapter 1 Snow Basin Vegetation Management Project FEIS

8

To achieve the purposes of this project and the associated objectives, the forest plan, and in particular the 

Eastside Screens amendment to the plan, needs to be amended to allow for the removal of uncharacteristic 

and unsustainable large (greater than 21 inches diameter) trees in high risk biophysical environments. 

Current conditions interfere with the attainment of characteristic LOS conditions in warm dry forest. 

Mistletoe infection and grand fir jeopardize targeted reserve conditions, most particularly ponderosa pine 

and larch LOS, by increasing mortality, slowing growth, increasing the risk of uncharacteristic wildfire 

and insect attacks, and prohibiting the successful regeneration of pine and larch. 

Proposed Action in Brief

In response to the purpose and need, the Forest Service proposes to treat 16,571 acres of vegetation within 

the Snow Basin planning area to improve the health and vigor of upland forest and reduce fuel loads

across the landscape. 

Thinning from below would remove understory trees to address uncharacteristic species composition, 

under-represented stand structures and unsustainable tree densities. As a result, treated stands would be 

restored and the landscape would be moved toward HRV conditions. In addition, thinning would decrease 

competition and increase growth rates in the residual stand. Reduced competition would decrease the risk 

of uncharacteristic disturbance from insects, disease and wildfire by promoting resistant species and 

increasing crown spacing. Thinning would improve stand resiliency by promoting ponderosa pine, an 

early-seral, fire resistant species; promoting fire resistant single story stand structures and improving large 

tree recruitment through reduced stand density. Prescribed under-burning following commercial/non 

commercial harvest would reduce fire intolerant understory seedling and sapling densities and reduce 

activity created and natural surface fuels.

Prescribed fire would be used to reduce the intensity of future wildfire events by reducing existing woody 

debris accumulations, ladder fuels, and small fire susceptible species such as grand fir. Prescribed fire 

would also revitalize certain surface vegetation, such as grasses and herbaceous plants, recycle nutrients 

stored in debris, reduce dwarf mistletoe in lower tree crowns and prepare sites for natural regeneration. 

Burning following commercial/non commercial harvest would reduce fire intolerant understory seedling 

and sapling densities.

Aspen stands across the landscape would be improved by reducing competition from encroaching 

conifers. Release from competition has been shown to invigorate aspen clones, increasing their resistance 

to disease and their ability to expand via underground suckers. To further initiate suckering of root 

systems, units may be burned, or aspen may be girdled or felled. Where necessary to insure regeneration 

success, these sites may be fenced to exclude livestock and/or big game. By improving the health of 

individual aspen stands across the landscape the extent of the species is expected to increase through 

expansion of clones. 

In summary, these actions would be accomplished through commercial harvest of timber (11,495 acres), 

post harvest noncommercial thinning (9,926 acres), noncommercial thinning only (81 acres), post harvest 

fuels treatments (10,467 acres, including 5,084 acres of grapple piling/burn and 146 acres hand pile/burn), 

conifer removal within aspen (38 acres), and natural fuels prescribed fire (4,995 acres). Danger tree 

removal would occur along open system haul roads (230 miles). No new permanent road construction 

would occur. No inventoried roadless areas (IRAs) are affected by this project. Three forest plan 

amendments would be needed in order to implement the proposed action.

Connected Actions

In order for the proposed action to be implemented, the following connected actions would also need to 

be implemented.
Chapter 1 Snow Basin Vegetation Management Project FEIS

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Approximately 11 miles of temporary roads would be constructed and approximately 41 miles of existing 

permanent road would be reconstructed as necessary to support timber log hauling. Road maintenance, 

especially blading and brushing, would be performed on about 230 miles of Maintenance Level 1 and 2 

roads. One existing bridge would be replaced, abutment repair would occur on one bridge and 1 mile of 

system road would be realigned. Complete details of the proposed action and alternatives are disclosed in 

chapter 2 and appendix B. Appendix A maps A-2a and A-2b display the location of the treatments and 

associated transportation system. Snow Basin project documents, maps and associated information can be 

accessed online at http://www.fs.usda.gov/main/wallowa-whitman/home.

Management Direction

This FEIS is tiered to the Wallowa-Whitman National Forest Land and Resource Management Plan FEIS 

and ROD (USDA 1990) and incorporates by reference the accompanying Land and Resource 

Management Plan, as amended, as permitted by 40 CFR 1502.20.

This action responds to the goals and objectives outlined in the Wallowa-Whitman National Forest Land 

and Resource Management Plan (forest plan) (USDA 1990) and helps move the project area towards 

desired conditions described therein. The Snow Basin project was designed in response to goals for

maintaining historic plan communities and maintaining ecosystem function (4-30); minimizing insects 

and disease damage(4-48); minimize the risk of fire damage (4-48) and timber management consistent 

with various resource objectives, environmental requirements and economic efficiency (4-48 through 4-

51). The Wallowa-Whitman National Forest forest plan is available online at 

http://www.fs.fed.us/r6/uma/blue_mtn_planrevision/documents.

The forest plan (USDA 1990) made land allocations using management areas (MA), each of which 

emphasizes a particular desired future condition. Forest plan standards and guidelines provide direction 

for achieving desired future conditions. Management areas within the project planning area are shown in 

the following table.

Table 3. Wallowa-Whitman National Forest plan management areas for the Snow Basin project

Management Area and Description Forest Plan 

Page Reference

Acres in 

Project Area

MA 1

Emphasize wood fiber production while providing high levels of 

forage and recreational opportunities

4-56 16,388

MA 1W 

Timber production emphasis while meeting identified winter range 

habitat objectives

4-58 1,157

MA 3

Timber production emphasis while providing near optimum cover 

forage conditions on big game winter range

4-60 5,567

MA 7

Manage to not diminish the special values of the Wild and Scenic 

Rivers

4-71 2,702

MA 15

Maintain habitat diversity, aesthetic values, and provide old 

growth habitat for wildlife 

4-89 10

MA 15-7

Old growth preservation within a Wild and Scenic River corridor 

(MAs 7 and 15 combined)

4-91 592
Chapter 1 Snow Basin Vegetation Management Project FEIS

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Management Area and Description Forest Plan 

Page Reference

Acres in 

Project Area

MA 16

Meet administrative and recreation site retention objectives 4-71, 4-89 77

Total NA 26,493

A comparison of the existing conditions, desired conditions and objectives of Snow Basin project to 

forest plan standard and guidelines, desired conditions and objectives for the applicable management 

areas is detailed in appendix B-9 tables B-9a to B-9d. Also see appendix A map A-6 for a map of the 

management areas within the project area. 

Additional management direction provided by forest plan amendments approved since 1990 includes

three amendments in particular:

• “Interim Management Direction Establishing Riparian, Ecosystem, and Wildlife Standards for 

Timber Sales” (USDA Forest Service 1995; also known as the Eastside Screens). The Eastside 

Screens focuses on potential impacts of timber sales on riparian habitat, historical vegetation 

patterns and wildlife habitat connectivity.

• “Interim Strategies for Managing Anadromous Fish-Producing Watersheds on Federal Lands in 

Eastern Oregon and Washington, Idaho and Portions of California” (USDA Forest Service and 

USDI Bureau of Land Management 1994; also known as PACFISH). PACFISH establishes 

management direction designed to arrest and reverse declines in anadromous fish habitat.

• The Pacific Northwest Region Final Environmental Impact Statement for the Invasive Plant 

Program, 2005, hereby referred to as the R6 2005 FEIS. The R6 FEIS culminated in a Record of 

Decision (R6 2005 ROD) that amended the Wallowa-Whitman National Forest Land and 

Resource Management Plan with additional management direction relative to invasive plants

(USDA 1990).

• The Eagle Creek Wild and Scenic River Management Plan was completed with a decision on 

December 22, 1994. The Snow Basin project area includes approximately 6 miles of Eagle Creek 

that is designated as a Scenic River and 3.4 miles of Eagle Creek that is designated as a 

Recreational River (see appendix A map A-5). The Snow Basin project responds to the goals and 

objectives of this Wild and Scenic River plan and meets all management direction for Eagle 

Creek. The complete report and the most recent Wild and Scenic inventory can be accessed 

online at http://www.fs.usda.gov/detail/wallowa-whitman/specialplaces. 

In order to eliminate repetition and focus on site-specific analysis, this FEIS is also tiered to the 

Invasive Plants Treatment Project (EIS), Wallowa-Whitman National Forest, decision dated 2010, 

which approved additional invasive plant treatment methods for identified and future infestation sites.

Additional Direction Incorporated by Reference

The following documents are incorporated by reference in order to decrease the size of this document.

• The Eagle Creek Watershed Analysis was conducted during 1996 and completed in April 1997. 

The purpose of the analysis was to gain better understanding of the conditions, processes and 

interactions within the watershed. Priority projects and recommendations for the watershed were 

developed as an outcome of the analysis. The Snow Basin Project is consistent with the 

management recommendations from that analysis.

• National Fire Plan (August 2000) developed with the intent of responding to severe wildland fires 

and their impacts to communities while addressing five key points: firefighting, rehabilitation, 

hazardous fuels reduction, community assistance and accountability.
Chapter 1 Snow Basin Vegetation Management Project FEIS

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• Regional Forester letter of direction (2003) encouraging eastside forest managers to consider sitespecific forest plan amendments when needed to more effectively meet late and old structure 

preservation objectives by moving landscapes toward the historic range of variability.

• Other sources of information cited in this EIS and its analysis file, such as specialist reports, 

published studies and books. The analysis file is available for review at the Whitman Ranger 

District in Baker City, Oregon.

Analysis and documentation for this project has been prepared according to direction contained in the 

National Forest Management Act (NFMA), National Environmental Policy Act (NEPA), Council on 

Environmental Quality Regulations (CEQ), Clean Water Act (CWA), Clean Air Act (CAA), National 

Historic Preservation Act (NHPA), and Endangered Species Act (ESA).

Other related ongoing planning efforts

The Wallowa-Whitman National Forest forest plan is currently undergoing revision and is expected to be 

completed in fall 2013. Due to timing of the revised plan, the Snow Basin project is being analyzed under 

the existing 1990 plan. The most current information on forest plan revision can be accessed at 

http://www.fs.fed.us/r6/uma/blue_mtn_planrevision/. 

The Wallowa-Whitman National Forest has developed a new Travel Management Plan. A decision was 

signed on February 21, 2012 and the public notices issued on March 16, 2012. It is anticipated that this 

decision will be implemented summer 2012, with publication of a Motor Vehicle Use Map. The most 

current Travel Plan Management information can be accessed at http://www.fs.usda.gov/main/wallowawhitman/home.

Public Involvement

The Snow Basin project was first listed in the Wallowa-Whitman National Forest Schedule of Proposed 

Actions (SOPA) in July 2008, and has been posted in all subsequent SOPAs on a quarterly schedule. 

On December 3, 2008, a scoping letter with a detailed description of the proposed action, including maps, 

was mailed out to approximately 200 members of the public, other agencies, tribal governments and other 

organizations. Approximately 18 letters and emails were received from the public in response to the

scoping letter. FEIS appendix B lists the letters and emails received during the scoping period to date. The 

complete scoping mailing list and all scoping letters and emails received are in the project record.

A notice of intent (NOI) to prepare an EIS was published in the Federal Register (FR Vol. 73, No. 240, pg 

75667) on Friday, December 12, 2008. The NOI asked for the public to comment on the Snow Basin 

Vegetation Management Project proposal.

Newspaper articles regarding the Snow Basin project were published in local newspapers on several 

occasions. Appendix B lists these articles and the date of publications. Copies of these articles are in the 

project record.

On Friday, April 15, 2011, a notice of availability (NOA) for the Snow Basin Vegetation Management 

Project DEIS was published in the Federal Register (FR Vol. 76, No. 73, pg 21345). A legal notice was 

published in the Baker City Herald, the newspaper of record, to request comments on the same day. 

Additionally approximately 200 members of the public, other agencies, tribal governments and other 

organizations were notified of the availability of the DEIS for review and comment. Approximately 70 

letters and emails were received from the public in response to this solicitation. Appendix B lists the 

comments received during the comment period and how they were addressed in the FEIS. The complete 

mailing list and all letters and emails received are in the project record.
Chapter 1 Snow Basin Vegetation Management Project FEIS

12

Public meetings and field trips for interested parties, tribal governments, and other organizations were 

held on several dates, both prior to publication of the DEIS, and as a response to comments received. 

Approximately 40 members of the public attended or participated in these events. More detailed

information is available in the project record.

The Snow Basin project scoping documents, maps, Federal Register NOI, and other associated 

information can be accessed online at http://www.fs.fed.us/nepa/project_content.php?project=25454.

Using the comments from the general public, organizations, tribal governments, and other federal and 

state agencies, the interdisciplinary team (ID team) developed a list of issues and subsequently developed 

alternatives to address those issues. A summary and analysis of potential issues was completed by the ID

team and is in the project record.

Issues 

Comments from the public received in response to scoping and review of the DEIS were reviewed by the 

ID team and the deciding official. Issues with potential cause and effect relationships associated with 

proposed activities were identified. A summary comparison of effects by alternative to issues is presented 

at the end of chapter 2 and a detailed discussion of environmental effects is presented in chapter 3 of this 

FEIS. The ID team recommended and the deciding official approved the following issue topics for 

alternative development and detailed study.

Issues Recommended for Alternative Development

Issues serve to highlight potential effects or unintended consequences that may occur from the proposed 

action. Issues that could best be addressed by developing an alternative were identified and categorized as 

key issues. Two key issues were identified in the DEIS based on the review of responses to scoping. Key 

issue 1 was developed to address comments and concerns about the amount of late and old structure forest 

(LOS) and impacts of harvest in LOS to stand structure and habitat. Key issue 2 was developed to address 

comments concerning the impacts of harvest of trees greater than 21 inches DBH. 

Following review of comments received in response to the DEIS, additional issues were identified. Key 

issue 3 was developed to address concerns regarding the impacts of temporary road construction. Key 

issue 4 addresses concerns over impacts to connectivity corridors between patches of LOS, while Key 

issue 5 was developed to address concerns for impacts to American marten habitat. Units of measure, or 

indicators, were developed for each issue that would be useful in judging differences among actions (FSH 

1909.15, Chapter 10, and Section 12.5).

Key Issue 1: Structural changes in late and old structure forest

Proposed harvest and fuels reduction treatments have the potential to change forest stand structure over a 

large area. This may have positive effects for some wildlife species and negative effects for others. These 

changes would require a forest plan amendment to vary from Eastside Screens guidance. Several 

respondents were concerned that deviation from this guidance would negatively impact habitat for old 

forest associated wildlife species.

Differences in alternatives would be determined by comparing:

• Acres of LOS stands restored to characteristic conditions

• Acres of multi-storied LOS stands (MSLT) converted to single-storied (SSLT)

• Net loss of LOS acres

Key Issue 2: Harvest of trees greater than 21 inches DBH
Chapter 1 Snow Basin Vegetation Management Project FEIS

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Proposed treatment that includes commercial logging would remove trees greater than 21-inches DBH, 

requiring a forest plan amendment to vary from Eastside Screens guidance. Some respondents were 

concerned that contributing to an existing deficit of large trees would result in habitat changes that would 

be undesirable for some species.

Differences in alternatives would be determined by comparing:

• Acres of treatment that harvest trees greater than 21 inches DBH 

• Estimated weighted average of trees per acre greater than 21 inches DBH remaining after treatment

Key Issue 3: Temporary roads

The proposed action includes construction of temporary roads to support harvest activities. Some 

respondents requested that fewer miles of temporary road be constructed while others asked that no 

temporary road construction occur. There was concern that constructing of temporary roads would result 

in undesirable effects including habitat fragmentation, losses to soil productivity, delivery of sediment to 

streams. 

Differences in alternatives would be determined by comparing:

• Miles of temporary road construction 

• Temporary road construction related disturbed soil conditions 

Key Issue 4: Connectivity corridors

Proposed treatments in stands identified as corridors connecting isolated patches of LOS would reduce 

canopy cover. Some respondents were concerned that canopy cover reductions in these corridors would 

negatively impact their function.

Differences in alternatives would be determined by comparing:

• Acres treated within connective corridors

• Acres within harvest units within connective corridors retaining basal area at the lower management 

zone

• Acres within harvest units within connective corridors retaining basal area between middle and upper 

management zone

Key Issue 5: American marten habitat

American marten are known to occur within the project area, particularly in the cool moist forest on the 

northern boundary of the project area. Treatments are proposed in areas identified as marten habitat. 

Some respondents were concerned that treatments within identified marten habitat would reduce the 

quality of habitat for this species.

Differences in alternatives would be determined by comparing:

• Acres of harvest within marten habitat 

• Acres harvested and retaining canopy closure and structural complexity needed to retain marten 

habitat characteristic

Treaty Rights

The Forest Service, through the Secretary of Agriculture, is vested with statutory authority and 

responsibility for managing resources of the National Forests. Commensurate with the authority and 

responsibility to manage is the obligation to consult, cooperate, and coordinate with Indian tribes in 

developing and planning management decisions regarding resources on NFS lands that may affect tribal 

rights.
Chapter 1 Snow Basin Vegetation Management Project FEIS

14

The Snow Basin project planning area is within the interest areas of the Nez Perce Tribe and the 

Confederated Tribes of the Umatilla Indian Reservation (CTUIR).

Elements of respective American Indian cultures, such as tribal welfare, land, and resources, were 

sometimes entrusted to the United States government as a result of treaties. Trust responsibilities resulting 

from treaties dictate, in part, that the United States government facilitates the execution of treaty rights 

and traditional cultural practices of American Indians by working with them on a government-togovernment basis in a manner that attempts a reasonable accommodation of their needs without 

compromising the legal positions of the respective tribes or the federal government. Specific treaty rights 

applicable to the land base managed by the Wallowa-Whitman National Forest are generally articulated in 

Article III of the 1855 Nez Perce Treaty:

“The exclusive right of taking fish in all the streams where running through or bordering said 

reservation is further secured to said Indians: as also the right of taking fish at all usual and 

accustomed places in common with citizens of the territory, and of erecting temporary buildings 

for curing, together with the privilege or hunting, gathering roots and berries, and pasturing 

their horses and cattle upon open and unclaimed land.”

And as part of Article I of the 1855 Walla Walla, Cayuse, and Umatilla Treaty:

“Provided, also, That the exclusive right of taking fish in the streams running through and 

bordering said reservation is herby secured to said Indians, and at all other usual and 

accustomed stations in common with citizens of the United states, and of erecting suitable 

buildings for curing the same; the privilege of hunting, gathering roots and berries and pasturing 

their stock on unclaimed lands in common with citizens, is also secured to them.” 

For this project, a government-to-government scoping letter was sent to tribal members of the Nez Perce 

Tribe and the CTUIR on December 4, 2008, informing them of the Snow Basin proposed project and 

requesting comment or concerns. A copy of the DEIS for Snow Basin Vegetation Management Project 

was sent to the Chairman of the Board of Trustees (CTUIR) on April 11, 2011. The project was also 

included in the Wallowa-Whitman National Forest 2012 program of work presentation to the CTUIR on 

February 22, 2012, as well as program of work presentations in 2008, 2009, 2010, and 2011. Project 

information was also presented at the Nez Perce Tribe tribal council, as part of the annual program of 

work presentation during the three previous years.

General concerns received from tribal staff members include:

• Potential effects to archaeological and traditional properties and traditional food resources

• Potential effects to water quality

• Potential effects to fish habitat, including salmonid species federally listed as threatened or 

endangered under ESA

• Potential effects to wildlife habitat, including elk security

• Potential effects to economic recovery

• Potential effects to treaty rights

Because tribal trust activities often occur in common with the public, the Forest Service will strive to 

manage tribal ceded land to enable the execution of tribal rights, as far as practicable, while still providing 

goods and services to all people.

Decision Framework

This is not a decision document. Its main purpose is to disclose the potential consequences of 

implementing a proposed action and alternatives to that action. Comments on the DEIS were used to 
Chapter 1 Snow Basin Vegetation Management Project FEIS

15

prepare this FEIS. After reviewing the FEIS and public comments, the responsible official will issue a 

record of decision (ROD) documenting which alternative has been selected and why. 

The scope of the project and decisions to be made are limited to: 

• Vegetation management activities including commercial harvest, noncommercial thinning, prescribed 

fire, aspen regeneration and reforestation

• Road activities including new temporary road construction, road reconstruction, road maintenance, 

haul routes and bridge improvements

• Potential forest plan amendments

• Project design features, best management practices (BMPs) and monitoring tasks

This project and any subsequent decisions are limited to NFS lands. The responsible official for this 

proposal is the Forest Supervisor of Wallowa-Whitman National Forest in Baker City, Oregon. The 

decision would be based on a consideration of public comments, responsiveness to the purpose and need, 

and a comparison of how each alternative responds to the issues. Given the purpose and need, the 

responsible official reviews the proposed action, the other alternatives, and the environmental 

consequences in order to make the following decisions.

The responsible official can decide to: 

• Select the proposed action 

• Select an action alternative that has been considered in detail

• Modify an action alternative, or select the no-action alternative

• Identify what project design features, monitoring tasks, and any additional mitigation measures would 

apply 

• Amend the Wallowa-Whitman National Forest forest plan to incorporate selected forest plan 

amendments
Chapter 2 Snow Basin Vegetation Management Project FEIS

16

CHAPTER 2 – ALTERNATIVES, INCLUDING THE PROPOSED ACTION

Introduction

This chapter provides a clear explanation of the activities proposed for the alternatives developed for the 

Snow Basin project. This chapter describes and shows a comparison of four alternatives selected to be 

analyzed in detail, including the proposed action and the no action alternative. This section also presents 

some alternatives considered but eliminated from detailed study. The alternatives studied in detail were 

designed to address or resolve issues identified through public involvement. Maps displaying activity 

areas for the alternatives considered in detail are in appendix A. This chapter concludes with a 

comparative synopsis of the alternatives considered in detail as presented in the environmental 

consequences disclosed in chapter 3.

Range of Alternatives

Alternatives for this project were designed to provide a range of possible actions. The ID team developed 

the range of alternatives, project design features, and mitigation measures presented in this chapter based 

on the purpose and need for action and key issues described in chapter 1. Forest plan goals and objectives, 

standards and guidelines, requirements under the Endangered Species Act and other Federal and state 

laws and regulations also influenced the development of alternatives. In total, 7 alternatives were 

considered, 3 were eliminated from detailed study and four were analyzed in detail. The ID team 

recommended and the responsible official approved three action alternatives and a no action alternative.

Alternatives Considered in Detail

The Forest Service developed four alternatives to respond to the key issues identified: no action, the 

proposed action, and two other action alternatives. The four alternatives considered in detail for this 

analysis are summarized in table 4. Each alternative is discussed in detail in the following sections of this 

chapter. 
Chapter 2 Snow Basin Vegetation Management Project FEIS

17

Table 4. List of alternatives and descriptions in brief

Alternative Brief Description

Alternative 1

(no action)

The no action alternative is the baseline for comparing the action alternatives. No treatments are 

proposed for this alternative, and biological and physical processes would be allowed to 

continue.

Alternative 2 

(proposed action)

This is the initial agency proposed action that would respond to the purpose and need and 

accomplish the project’s objectives. Forest structure would be moved toward conditions 

historically present and the risk of high severity disturbance on the landscape would be reduced 

through a combination of commercial thinning, non-commercial thinning, and prescription 

burning. Commercial products would be produced by these activities.Three forest plan 

amendments would be required to implement the activities proposed for this alternative.

Alternative 3

This alternative was developed in response to concerns regarding impacts to late and old 

structure (LOS) stands, temporary road construction, and wildlife connectivity corridors and to 

accomplish project objectives while still meeting the purpose and need. Activities proposed for

alternative 3 would not result in a net loss of LOS stands in the project area. Temporary road 

construction would be reduced in the most sensitive areas, and stand density would be retained 

above the forest plan minimum standards in wildlife connectivity corridors. Two forest plan 

amendments would be required to implement the activities proposed for this alternative.

Alternative 4

This alternative was developed in response to concerns regarding removal of large trees, 

impacts to LOS stands, temporary road construction, and wildlife connectivity corridors. 

Treatments proposed for alternative 4 would not result in a net loss of LOS stands and would not 

include the harvest trees 21 inches DBH or greater. No temporary roads would be constructed,

and stand density would be retained above the forest plan minimum standards in wildlife 

connectivity corridors. No forest plan amendments would be required.

Alternative 1 No Action 

The no action alternative serves as the baseline used to compare the effects of the proposed action and 

alternatives.

Purpose and design

No new management activities are proposed.

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

with associated risks and benefits.

Alternative 1 description 

None of the management activities described in the Proposed Action or the other action alternatives 

would be implemented to accomplish project goals. Commercial thinning, fuels treatments for activity 

and natural fuels, and prescription burning would not be authorized. There would be no temporary road 

construction or treatment of fuels in riparian habitat conservation areas. Hardwood restoration and road 

decommissioning activities would not be authorized. There would be amendment to the forest plan to 

allow specific treatments needed to increase stand health and resilience in the planning area. Under the 

No Action alternative, current management plans would continue to guide management of the project 

area. Other approved projects would continue in the project area. In addition, other public uses such as 

recreation, hunting and firewood gathering would continue as permitted. Appendix A does not include a

map for alternative 1 (no action).

Alternative 2 Proposed Action

Alternative 2 is the proposed action. Alternative 2 has been modified from the proposal included in the 

draft environmental impact statement included in the April, 2011 release of the draft environmental 
Chapter 2 Snow Basin Vegetation Management Project FEIS

18

impact statement. The modifications responded to new information concerning the current conditions in 

the analysis area and comments received during the comment period. These modifications include:

• Riparian habitat conservation areas have been field verified and updated. Treatment units have been 

updated to reflect the field verified data.

• All harvest treatments within riparian habitat conservation areas would use a forwarder harvester to 

reduce impacts to soils (units 1, 33A, 34, 57, 213, 301, 303, 311A, 314A, 316A, 342, 401).

• Winter harvest restrictions were added to commercial harvest activities in unit 121.

• All regeneration units were dropped.

• Alternative 2 would maintain stand density at the lower management zone of site potential in 

identified connectivity corridors between late and old structure stands and forest plan designated old 

growth to address connectivity concerns.

Alternative 2 purpose and design

Alternative 2 was designed to address the purpose and need for action by thinning overstocked stands to 

promote forest resiliency and reduce the likelihood of uncharacteristic disturbance in the analysis area. 

Treatments in alternative 2 are designed to:

• Move forested stands toward historical range of variability for species composition, stand densities 

and stand structures on a landscape scale. Thinning treatments are proposed to reduce tree density, 

modify species composition, promote the development of single story late/old structure, and reduce 

insect and disease susceptibility by improving tree and stand vigor. 

• Reduce fuel loading (surface, ladder and canopy fuels) to a level that facilitates future use of lowintensity surface fire to maintain stand health and vigor while reducing the risk of uncharacteristically 

intense wildfire and associated resource damage.

• Overstory removal is proposed to reduce overstory competition so that established regeneration (e.g. 

existing seedlings and saplings) can develop.

• Maintain and enhance underrepresented aspen stands by reducing conifer competition and reducing 

browsing pressures.

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

This alternative has been designed to address the large scale shift that has occurred in the planning area 

from a landscape dominated by large diameter, open grown late and old structure ponderosa pine and 

western larch stands, to one dominated by dense, younger, multi-layered, shade tolerant grand fir and 

Douglas-fir forests. Ponderosa pine, western larch and quaking aspen have all declined in health, vigor 

and abundance as a result of their intolerance to shade and the lack of disturbance within the planning 

area. A corresponding increase in live and dead fuel loads has occurred. These changes in landscape 

condition have increased the potential occurrence for uncharacteristic disturbance patterns including high 

intensity, stand replacing fire, and insect and disease attacks. 

Vegetation and prescribed fire treatments for alternative 2

Alternative 2 would implement the following treatments. Table 6 summarizes the types of vegetative 

treatments (and approximate acres) and transportation actions (with approximate miles). See maps A-3a 

to A-3b in appendix A that display the locations of the treatments and associated transportation system. 

Three forest plan amendments would be needed to implement alternative 2. The management activities 

for alternative 2 are described in the following sections.

Commercial harvest

Commercial harvest is proposed on approximately 11,495 acres using a combination of intermediate 

thinning and overstory removal. Intermediate commercial thinning from below is the primary stand 

prescription proposed. This alternative would result in a potential yield of 58 MMBF.
Chapter 2 Snow Basin Vegetation Management Project FEIS

19

Intermediate thinning from below

Intermediate thinning from below on 10,506 acres would remove understory trees to address 

uncharacteristic species composition, under-represented stand structures and unsustainable tree densities. 

These treatments would decrease competition and increase growth rates in the residual stand. Thinning 

from below would also decrease the risk of uncharacteristic disturbance from insects, disease and wildfire 

by promoting resistant species and increasing crown spacing. Thinning from below would remove trees 

from the lowest crown class first followed by the next lowest crown class until the target stocking is 

reached. Ponderosa pine trees at least 21 inches DBH with severe dwarf mistletoe infections (ratings 5

and 6) would be removed. Ponderosa pine trees less than 21 inches DBH with dwarf mistletoe in the 

upper two thirds of the crown would be removed. Western larch of any size with moderate dwarf 

mistletoe infections (ratings 3 and 4) would be removed. Severely infected (ratings 5 and 6) western larch 

would be retained because they do not spread infection effectively as a result of their small crowns and 

their high probability of mortality within a few years.

Warm/dry Douglas-fir – ponderosa pine types

Intermediate thinning from below is proposed on approximately 4,291 acres of warm/dry Douglas-fir -

ponderosa pine forest types in the planning area. Thinning from below will improve stand resiliency by 

promoting ponderosa pine, an early-seral, fire resistant species, promoting fire resistant single story stand 

structures and improving large tree recruitment through reduced stand density.

Warm/moist Douglas fir types

Intermediate thinning from below is proposed on 897 acres of warm/very moist Douglas fir types. 

Thinning from below would maintain existing ponderosa pine, provide gaps for regeneration, and protect 

late and old trees. 

Warm/dry grand fir types

In order to restore ponderosa pine and western larch species composition in the warm/dry grand fir types, 

all viable existing ponderosa pine and western larch of any size would be retained. Intermediate thinning 

from below is proposed on approximately 4,033 acres of warm/dry grand fir forest type in the planning 

area. All grand fir trees with severe defect (broken tops, Indian Paint conks, weeping frost cracks, etc.) 

would be protected to provide snag dependent wildlife habitat.

Cool/moist/dry grand fir types

Thinning from below is proposed on 736 acres of cool/moist/dry grand fir forest type in the planning area. 

In order to retain a characteristic tree species mix in cool/moist/dry grand fir types, large grand fir (greater 

than 21 inches DBH) would only be harvested within 30 feet of a ponderosa pine or western larch. All 

grand fir trees with severe defect (broken tops, Indian Paint conks, weeping frost cracks, etc.) would be 

protected to provide snag dependent wildlife habitat. 

The Paddy Creek seed orchard is a high investment genetic study area within a cool/moist/dry grand fir 

type. Stands surrounding this genetic study area will be managed as a long-term shaded fuel break to 

protect the seed orchard from wildfire. Activities proposed in this area would be designed to maintain 

single-story open ponderosa pine and/or larch dominated stands.

Overstory removal

For the purposes of the Snow Basin Vegetation Management Project, overstory removal is defined as the 

removal of some overstory trees. This prescription is used to increase the growth and vigor of understory 

trees and reduce shade tolerant seed source trees to promote stand health and increase resistance to stand 

replacing fires, insects and disease. Overstory removal on 951 acres would allow early seral tree species 

regeneration currently present in the understory to grow at an increased rate in stands that were 
Chapter 2 Snow Basin Vegetation Management Project FEIS

20

historically dominated by early seral species but have converted to grand fir dominated sites. These 

treatments would focus on retention of the healthiest ponderosa pine and western larch regardless of size. 

Residual overstory trees of adequate size will be retained to provide replacements for snags and logs 

through time via natural mortality (green tree replacements). At least 16 trees per acre ranging from 10 to 

36 inches DBH, primarily ponderosa pine and Douglas-fir, would be retained to provide a source for 

green replacement trees for snag dependent wildlife. All ponderosa pine and western larch infected with 

dwarf mistletoe would be removed to protect the understory from infection.

Aspen restoration conifer overstory removal 

Aspen restoration conifer overstory removal would remove all conifers except old ponderosa pine and 

Douglas-fir from 29 sites covering a total of 38 acres to address conifer competition in declining aspen 

stands. Approximately 25 acres of aspen treatments are located within commercial thinning units.

Conifers within 100 feet of the south and west edges of the aspen stands and within 50 feet on the north 

and east edges of the aspen stands would be removed. Whole tree yarding would be used to limit slash 

concentrations within the aspen stands. Excessive slash would be hand piled and burned. To initiate 

suckering of the root system, units may be burned or aspen girdled or felled. Where necessary to insure 

regeneration success, these sites may be fenced to exclude livestock and/or big game until the aspen reach 

6 feet in height. In aspen unit 28 (approximately 1 acre), commercial harvest would not occur. 

Harvest methods

Commercial harvest would include ground-based harvesting utilizing a tractor or skidder that would 

operate on designated trails with selected spacing criteria in combination with whole tree yarding on 

approximately 8,256 acres on slopes up to and including 35 percent. Skyline cable yarding would use 

leave tops attached yarding on 2,284 acres on slopes exceeding 35 percent. A forwarder harvester and in 

woods processing would be used on 955 acres to reduce soil impacts, landing numbers and landing size.

Grapple pile and burn

Activity created fuels may be grapple piled and burned on approximately 5,084 acres following 

commercial treatments in order to reduce post-harvest surface fuels where those fuel loadings exceed the 

capacity for treatment by burning alone.

Hand pile and burn

Activity created fuels would be treated by hand piling and burning on approximately 146 acres (in 

commercially treated areas close to private lands and within aspen restoration stands).

Elements common to all commercial harvest units for alternative 2

Snags and down logs

All existing snags would be protected except those that are a risk to the public or forest workers. Down 

logs greater than 12 inches DBH would be protected. Prescribed fire would be conducted with low 

intensity fire when weather conditions minimize the loss of existing large down logs.

Green replacement trees

All prescriptions maintain a full stocking of trees of various sizes except for the overstory removal units. 

In overstory removal units 16 green replacement trees per acre greater than 10 inches DBH would be 

retained.

Identification of old trees

The R6 Old Growth Definitions (Lowe J. E. 1992) establish 150 years of age as the minimum age of an 

old growth tree. Trees exhibiting true old growth characteristics would not be removed regardless of size. 

The typical characteristics of old growth are a combination of visual indicators including; stem diameter, 
Chapter 2 Snow Basin Vegetation Management Project FEIS

21

large diameter limbs, crown characteristics and bark characteristics. Visual indicators coupled with age 

sampling using increment boring would be used to estimate age. Assessing age based on visual 

characteristics would be tree species specific. Ponderosa pine, western larch and Douglas-fir visual age 

indicators would be based on guidelines in Identifying Old Trees and Forests in Eastern Washington (Van 

Pelt, R. 2008). Old grand fir identification would be based on a local age/DBH guide in development by 

the Whitman Ranger District.

Dwarf mistletoe management

All prescriptions manage dwarf mistletoe to reduce dwarf mistletoe severity through removal of infected 

trees in order to increase normal development, diameter growth and survival of residual uninfected trees. 

Proposed treatments would protect uninfected understory trees by removing infected overstory trees of 

the same species and by spacing infected trees away from same species uninfected trees. All infected 

Douglas-fir trees less than 21 inches DBH would be removed. All uninfected Douglas-fir trees less than 

21 inches DBH within 30 feet of an infected Douglas-fir would be removed. All Douglas-fir trees at least 

21 inches DBH within 30 feet of ponderosa pine or western larch 21 inches DBH or larger would be 

removed. Dwarf mistletoe would be retained at endemic levels in order to provide biodiversity on the 

landscape.

Operational hazard trees

Operational hazard trees are those standing trees, live or dead, that need to be removed for safe harvest 

operations. Most operational hazard tree removals occur at landing locations. Operational hazard trees are 

designated and approved Forest Service personnel prior to felling. Operational hazard trees would be 

commercially removed for biomass, except in riparian habitat conservation areas where they would be left 

in place on the ground to provide large woody debris.

Danger tree removal

Danger tree removal would occur along 233 miles of open system haul roads. Danger trees would be 

identified by qualified personnel using an established protocol (Toupin et. al. 2008). Trees that threaten 

the road and public or forest worker safety would be felled. Trees within 1.5 tree lengths of the road prism 

would be evaluated for risk and felled when presenting an unacceptable risk.

Non-commercial thinning and fuels treatments

Non-commercial thinning would remove trees up to 7 inches DBH to increase growth rates and tree vigor, 

promote historical species compositions and reduce ladder fuels in residual stands on approximately 9,926 

acres following commercial harvest treatments. 

Non-commercial thinning is proposed on approximately 81 acres as a stand-alone treatment in order to 

increase growth rates, tree vigor, promote historical species compositions and reduce ladder fuels. This 

treatment is proposed in stands where most of the trees needing removal are seedling and sapling sized, 

up to a maximum size of 9 inches DBH. Trees would be thinned from below to 100-200 trees per acre 

depending on the plant association and site characteristics. Some areas may require post-treatment piling 

and burning. On slopes with less than 30 percent rise, machine piling may be used. 

Prescribed underburning 

Prescribed underburning is proposed on 10,467 acres following commercial/non commercial harvest to 

reduce fire intolerant understory seedling and sapling densities, raise base canopy height, reduce mistletoe 

infection and to reduce activity-created and natural surface fuels3

. 

 3 These treatments would begin approximately 1-2 years after the mechanical activities are completed and would 

take an estimated 7-10 years to finish (based on 2,500 acres treated by Rx fire on avg. on the district.) Actual acres 

of fuels treatments are less than shown due to different fuels treatments occurring on the same acres.
Chapter 2 Snow Basin Vegetation Management Project FEIS

22

Prescribed underburning as a stand-alone treatment is proposed on 4,995 acres to reduce the potential fire 

intensity of future wildfire events by reducing existing woody debris accumulations, ladder fuels, and 

small fire susceptible species such as grand fir. Prescribed fire will be used to limit mistletoe infection 

within lower one third of crowns as a result of crown scorch. Prescribed fire would also revitalize certain 

surface vegetation, recycle nutrients stored in debris and prepare sites for planting or natural regeneration. 

More than one prescribed fire entry may be needed within the first 10 years of treatment depending upon 

the success of the initial burn treatment in meeting project objectives. Follow-up maintenance burning is 

planned on an average 10 year cycle on the warm and hot dry sites within the analysis area.

Underburn units may require preparatory work to protect trees prior to ignition, particularly for areas 

around large ponderosa pine. This could include reducing ladder fuels and/or physically removing surface 

fuels from selected trees. Burn prescriptions may also be tailored to reduce surface and ground fire 

intensity to provide similar protection. 

Prescribed fire unit boundaries would use natural fuel breaks whenever possible; however, containment 

lines may be constructed on some units to provide boundaries for burning and to separate units into 

manageable sizes. Slopes ranging from zero to 30 percent rise may be lined by tractor (maximum fireline, 

to mineral soil, width of less than 4 feet) or all-terrain vehicle plow (18 inches width). Slopes with rise 

exceeding 30 percent are normally fire line by hand (18 inches width). Units are ignited to allow fire to 

burn through a majority of the area. Underburns may occur in the spring or fall depending on weather 

conditions and specific objectives. 

Within riparian habitat conservation areas, fire would be allowed to continue to burn and spread, usually 

as a backing fire, without further influence from ignition sources. Under circumstances where unmanipulated fire activity threatens to exceed maximum prescription parameters and/or control of the burn 

is threatened, hand ignition would continue into the riparian habitat conservation areas as necessary. 

Wildlife connectivity corridors

Harvest units within wildlife connectivity corridors between late/old structure areas and MA 15 areas 

would maintain canopy closure within the upper one third of site potential. The resulting overstory 

canopy closure would be maintained above 40 percent within dry forest PVGs and above 50 percent in 

cold forest PVGs. Approximately 2, 972 acres containing wildlife connectivity corridors would be treated 

in alternative 2. In addition, the extensive riparian habitat conservation system would maintain existing 

canopy closure between many late/old structure areas and MA 15 areas.

Riparian habitat conservation areas

Intermediate harvest treatments, as described above, are proposed on approximately 50 acres within 

riparian habitat conservation areas (RHCAs) to improve conditions in the treated stands while facilitating

treatment in adjacent upland units. This represents approximately 0.9 percent of the total acreage of 

riparian habitat conservation areas in the planning area. Forwarder trails would be established within an 

additional 68 acres of riparian habitat conservation areas where an existing Forest Service system road is 

used to access units outside the riparian habitat conservation area above the road. This represents 

approximately 1.3 percent of the total acreage of riparian habitat conservation areas in the planning area. 

Forwarder trails and landings would be minimized by maximizing skid trail spacing in these areas. Only 

existing Forest Service system roads outside the inner 100 foot buffer of a Category 1-2 stream and 50 

feet of a Category 4 stream within riparian habitat conservation areas would be used. Existing landings in 

riparian habitat conservation areas above these roads would also be used. An estimated 28 landings would 

be used within riparian habitat conservation areas impacting approximately 7 acres. Use of existing Forest 

Service system roads and existing landings would reduce the need for construction of additional 

temporary roads within riparian habitat conservation areas. Prescribed fire treatment unit boundaries 
Chapter 2 Snow Basin Vegetation Management Project FEIS

23

within RHCAs would rely on natural barriers and minimize constructed line where practical. Fire would 

be allowed to back into RHCAs where natural barriers do not exist.

Wild and Scenic River corridor

Activities within the Eagle Creek Wild and Scenic River corridor consist of 275 acres of prescribed fire 

and 245 acres of commercial harvest in the Recreation section and 1,084 acres of prescribed fire and 124 

acres of commercial harvest in the Scenic section.

Follow-up treatments proposed for alternative 2

Intermediate commercial thinning and overstory removal would usually be followed by non-commercial 

thinning to treat the non-commercial sized understory trees (generally seedlings to 7 inches DBH). 

Depending on slash and debris levels, may be followed by grapple or hand piling. It is common for this 

harvest treatment to be followed by prescribed burning.

Non-commercial thinning units where the felled trees are primarily less than 2 inches DBH are usually 

left to deteriorate naturally. Areas where the felled trees pose an unacceptable hazard would be either 

piled and burned or underburned. Machine piling would occur on slopes less than 30 percent and hand 

piling would occur on slopes greater than 30 percent.

Transportation system activities for alternative 2

Approximately 230 miles of road within and near the project area would be used for haul. Broken down 

by jurisdiction, 227 miles are forest service and 3 miles are private. Additionally, there are 6.5 miles of 

Baker County Roads that will be used for haul in the project area. Outside of the project, area an 

additional 33 miles of Forest Service and County road would be utilized for haul between the project area 

and State Highway 86. No new permanent specified road construction is proposed. Danger trees would be 

removed from the haul road system for public and forest worker safety and would include some 

commercial removal for biomass.

Approximately 6.9 miles of new temporary road construction is proposed and an additional 4.0 miles of 

existing non-system routes would be utilized for project activities. These temporary roads are short 

segments ranging in length from less than 0.1 mile to 0.6 miles, and the average length is 0.2 miles. 

Temporary roads would be closed and completely rehabilitated prior to the closure of the timber sale. 

Rehabilitation would consist of decompaction, planting with native seed, adding surface cross drains, 

removal of temporary culverts and scattering with slash as needed.

All NFS roads would be maintained in accordance with standard timber sale road maintenance 

specifications. Of the estimated 227 miles of NFS haul roads, approximately 108 miles are currently 

closed roads (maintenance level 1) and would be re-closed when harvest and post-sale activities are 

completed. 

Reconstruction is proposed on approximately 41 miles of NFS roads. Here, the term reconstruction refers 

to road work outside the scope of timber sale maintenance specifications and would be listed in the timber 

sale contract for specified road reconstruction and applicable to contract clause BT 5.2. Types of activity 

included under reconstruction include a bridge replacement (on FSR #7735 across Little Eagle Creek in 

Section 24); repair of an abutment on one bridge (FSR #7735450) across Little Eagle Creek in Section 

30); realign road location which would create new ground disturbance (1.0 mi); restore roads to a 

serviceable standard by clearing heavily overgrown roads, removing slides and slough and repairing 

slumps greater than 10 cubic yards, repairing and improving drainage structures, drainage and subgrade 

reinforcement for seeps and springs, install culverts, and rock surfacing (39.8 miles). Of the roads 

proposed for reconstruction, approximately 14 miles are currently closed roads (maintenance level 1) and 

26 miles are open roads maintained for high clearance vehicles (maintenance level 2). Reconstruction is 
Chapter 2 Snow Basin Vegetation Management Project FEIS

24

also proposed (by agreement) for 2.4 miles of Baker County Road 923 consisting of clearing, drainage, 

and rock surfacing. 

Six existing larger sources have been identified for proposed crushed rock aggregate sites. Each of these 

sites has been previously developed for crusher and stockpile sites and approximately 5,000-15,000 cubic 

yards would be crushed from these sources. Rock crushed from various sources is estimated to be 

approximately 30,000 CY total. The pit development area may be increased by 1-2 acres. In addition, 

there are numerous smaller sites that may be used for aggregate sources. No aggregate sources within the 

wild and scenic river corridor would be used for this project. The project record file contains detailed lists 

of all potential material rock sources. 

In holdings of private land where National Forest system roads cross without permanent easements, the 

Forest will proceed with permanent easement acquisition. In the event a permanent easement cannot be 

acquired before project implementation, the Forest will seek a temporary road-use permit. In the event 

that no easement or permit can be acquired, alternative routes will be used. None of these outcomes 

change the decision or effects of the project. This applies to a total of 1.3 miles of road.
Chapter 2 Snow Basin Vegetation Management Project FEIS

25

Table 5. Summary of alternative 2 (proposed action) activities

Management Activity Measure

Forested Stand Treatments Rx (only on N FS lands) Acres

Intermediate commercial thinning acres 10,088

Intermediate commercial thinning acres in riparian habitat 

conservation areas 50

Intermediate commercial thinning acres in Wild and Scenic 

River corridor 369

Total Intermediate Commercial Thinning 10,506

Partial over story removal 951

Aspen restoration/conifer removal 38

Total commercial harvest treatment 11,495

Non-commercial thinning post-harvest 9,926

Non-commercial thinning only Rx 81

Total Non-commercial Thinning 10,007

Fuels Treatments (only on NFS lands) Acres

+Post activity prescribed fire fuels treatments in commercial 

harvest acres 10,467

+Natural fuels prescribed fire 4,995

Post-harvest machine grapple pile and burn 5,084

Post-harvest hand pile and burn 146

Total Fuels Treatments 20,692

Logging System Activities Acres

Tractor logging system 8,256

Skyline/cable logging system 2,284

Forwarder harvester 955

Total Logging System 11,457

Transportation Activities Miles

Maintain NFSRs for log hauling 229.6

Open (maintenance level 2-3) 121.9

Closed (maintenance level 1) 107.7

Danger tree removal (along system haul roads) 230

Total temporary road construction 10.9

New construction 6.9

Existing non-system roads 4.0

Reconstruction of NFSRs 41

Open (maintenance level 2) Miles/Structures

Deferred maintenance/repairs 26.3

Bridge replacement (1 bridge) 1 bridge

Bridge abutment repair (1 bridge) 1 bridge

Closed (maintenance level 1) Miles

Deferred maintenance/repairs 13.7

Realignment NFSRs 1.0

Total NFSRs reconstruction 41.0
Chapter 2 Snow Basin Vegetation Management Project FEIS

26

Proposed forest plan amendments to Eastside Screens for alternative 2

Three non-significant forest plan amendments would be proposed as part of alternative 2. These 

amendments are being made using the provisions of planning regulation and associated Forest Service 

policy found in the Forest Service Manual at FSM 1926.51. These amendments would be needed to 

manage trees of all sizes in order to return managed stands to characteristic species composition and stand 

structure. Returning forested stands to the conditions historically present would enhance stand resilience 

in the planning area.

Forest plan amendment 1

A site-specific non-significant forest plan amendment is proposed to allow timber harvest activities within 

late and old structural stages that are below the historic range of variability in particular biophysical 

environments. Treatments are needed in these stands to change multi-story stands dominated by large 

grand fir trees to single story stands dominated by large early-seral ponderosa pine and western larch 

trees. In addition, treatments are needed to maintain declining desired tree species such as ponderosa pine 

and western larch by reducing competition with over represented large grand fir.

This amendment is considered non-significant because it does not significantly alter the multiple-use 

goals and objectives for long-term land and resource management on the Wallowa-Whitman National 

Forest. The existing long-term objectives of increasing the number of large trees and late and old 

structural stands on the landscape would not be altered by the proposed amendment. Stands treated under 

this amendment would experience a short-term reduction in large tree numbers, however more rapid 

recruitment of sustainable large trees would be promoted over the long-term. The proposed amendment 

would allow timber harvest activities on 661 acres of qualifying late and old structural stands. This 

amounts to approximately 15 percent of the late and old structural stands within the planning area and less 

than 0.1 percent of the 1.09 million acres classified as suitable for timber management activities on the 

Wallowa-Whitman National Forest. This is a minor change in management prescriptions resulting from 

on-site analysis that revealed the need to manage specific uncharacteristic forested stands. Proposed 

management activities are needed in order to effectively meet the objectives of maintaining characteristic 

large tree stands to provide habitat for associated wildlife species over the long term. This amendment is a 

minor change in standards and guidelines as a result of the limited acreage affected and the short-term 

duration of the exception. 

This amendment would update the Regional Forester’s Forest Plan Amendment 2 as specified.

Page 9, Appendix B Revised Interim Direction: 

“DO NOT allow timber sale harvest activities to occur within LOS stages that are BELOW HRV.”

Amended direction would read:

“DO NOT allow timber sale harvest activities to occur within LOS stages that are BELOW HRV except 

within Snow Basin project area during implementation of Snow Basin Vegetation Management Project 

activities as described in the Snow Basin Vegetation Management Project Record of Decision, dated 

March 2012.”

This plan amendment is being prepared under the 2000 planning rule as amended with transition wording 

at 36 CFR 219.35 that allows the use of the 1982 rule procedures. [See 65 FR 67568, Nov. 2000, as 

amended at 66 FR 1865, Jan. 10, 2001; 66 FR 27554, May 17, 2001; 67 FR 3543, May 20, 2002; 68 FR 

53297, Sept. 10, 2003; 69 FR 58057, Sept. 29, 2004]. The 1982 planning rule and the 2000 planning rule

as amended are available online at http://www.fs.fed.us/emc/nfma/2000_planning_rule.html.
Chapter 2 Snow Basin Vegetation Management Project FEIS

27

Forest plan amendment 2

A site-specific non-significant forest plan amendment is proposed to allow harvest activities that would 

result in a net loss of late and old structural stages. Stands that currently contain a significant component 

of large (at least 21 inches DBH) and relatively young (approximately 90 years old) grand fir that qualify 

them for late and old structure classification are uncharacteristic in species composition and structure. In 

region 6, the Forest Service requires 20 trees at least 21 inches DBH in cool/moist/dry and warm/dry 

grand fir vegetation types and 8 trees per acre at least 21 inches DBH in Douglas-fir and ponderosa pine 

vegetation types to meet old-growth definitions. Without disturbance, these stands would continue to 

progress toward an uncharacteristic pure grand fir species composition that would be very susceptible to 

uncharacteristic disturbance from insects, disease and wildfire. This amendment would allow removal of 

uncharacteristic grand fir trees and the seed source they provide. As a result the number of acres in the 

project area that qualify as late and old structure would be reduced in the short term in order to restore 

historic species compositions and stand structures over the long term. This amendment is needed to 

promote the long term development of resilient late and old structural stands composed of characteristic 

large trees species. 

This amendment is considered non-significant because it makes a minor change in standards and 

guidelines that does not alter the multiple-use goals and objectives for long-term land and resource 

management on the Wallowa-Whitman National Forest. This amendment would allow harvest activity in 

a total of 67 acres of qualifying stands in units 5,106, 248, 249, 406 within the Snow Basin planning area 

for the duration of Snow Basin project implementation. This amendment would allow a short-term 2.6 

percent reduction in stands qualifying for late and old structure within the planning area. This amounts to 

a reduction of less than 1 percent of the late and old structural stands on the Wallowa-Whitman National 

Forest and does not have an important effect on the land management plan or affect the land and 

resources throughout a large portion of the planning area. This change is of a small scale and would not 

significantly alter projected outputs for the Wallowa-Whitman National Forest over the long term. This 

amendment would update the Regional Forester’s Forest Plan Amendment 2 as specified.

Page 9, Appendix B Revised Interim Direction: 

“If either one or both of the late and old structural (LOS) stages falls BELOW HRV in a particular 

biophysical environment within a watershed, then there should be NO NET LOSS OF LOS from that 

biophysical environment.”

Amended direction would read:

“If either one or both of the late and old structural (LOS) stages falls BELOW HRV in a particular 

biophysical environment within a watershed, then there should be NO NET LOSS OF LOS from that 

biophysical environment except for 109 acres in units 5, 106, 244, 248, 249 in the Snow Basin project 

area during implementation of Snow Basin project activities.”

This plan amendment is being prepared under the 200 rule as amended with transition wording at 36 CFR 

219.35 that allows the use of the 1982 rule procedures. [See 65 FR 67568, Nov. 2000, as amended at 66 

FR 1865, Jan. 10, 2001; 66 FR 27554, May 17, 2001; 67 FR 3543, May 20, 2002; 68 FR 53297, Sept. 10, 

2003; 69 FR 58057, Sept. 29, 2004]. The 1982 rule and the 2000 rule as amended are available online at 

http://www.fs.fed.us/emc/nfma/2000_planning_rule.html.

Forest plan amendment 3

A site-specific non-significant forest plan amendment is proposed to remove a limited amount of conifers 

of any size from all units proposing commercial harvest. This amendment is needed to remove conifers 

within harvest treatment units based on the greatest benefit to residual tree survival and stand 

sustainability rather than based on conifer diameter. The removal of conifers from forested stands is 
Chapter 2 Snow Basin Vegetation Management Project FEIS

28

needed to manage stands toward their characteristic stand structures and tree species compositions. 

Removal of uncharacteristic early-seral trees greater than 21 inches DBH is needed to move multi-storied 

stands toward the desired condition of single storied late and old structure stands. Currently, large 

ponderosa pine trees in the warm/dry and cool/moist/dry grand fir ecotypes are being out competed by an 

increasing number of immature grand fir. Removal of these large grand fir trees would maintain the 

existing ponderosa pine by reducing competition and reducing the amount of readily available seed source 

for grand fir. Large mistletoe infected trees would also be removed to promote the growth and health of 

desirable understory tree species. In addition, large shade tolerant conifers would be removed to protect 

declining aspen stands. 

This proposed amendment is considered non-significant because it makes a minor change in the standard 

to retain all existing trees at least 21 inches DBH. On-site analysis indicates that large tree removal is 

needed to maintain viable regeneration of shade-intolerant desirable tree species throughout the planning 

area. This amendment would not significantly alter the long-term land and resource management goal of 

maintaining and enhancing late and old structural components on the Wallowa-Whitman National Forest. 

This amendment would apply to 11,495 acres, or approximately 43 percent of the 26,494 acre Snow 

Basin planning area, which accounts for approximately 1 percent of the 1.09 million acres considered 

suitable for timber management on the Wallowa-Whitman National Forest. Activities authorized by this 

amendment would allow the removal of trees at least 21 inches DBH from all forested stands proposed 

for commercial treatments within the Snow Basin project area for the duration of Snow Basin project 

implementation. This amendment would not reduce potential timber output level projections over the long 

term because the exemption would accelerate the development of sustainable late and old structural stand 

types. The removal of trees at least 21 inches DBH associated with this amendment would be consistent 

with direction provided in the Regional Forester’s letter (June 11, 2003). This direction encourages 

eastside forests to consider site-specific forest plan amendments where needed to more effectively meet 

late and old structural stand maintenance and enhancement objectives. This amendment would update the 

Regional Forester’s Forest Plan Amendment 2 as specified.

Page 10, Appendix B Revised Interim Direction:

“Scenario A: Outside of late and old structural stages, many types of timber sale activities are allowed. 

Intent is still to maintain and/or enhance late and old structure components in stand subject to timber 

harvest such as possible, by adhering to the following standards: a) Maintain all remnant late and old seral 

and/or structural live trees greater than 21 inches DBH that currently exist within stands proposed for 

harvest activities.”

Amended direction would read:

“Scenario A: Outside of late and old structural stages, many types of timber sale activities are allowed. 

Intent is still to maintain and/or enhance late and old structure components in stand subject to timber 

harvest such as possible, by adhering to the following standards: a) Maintain all remnant late and old seral 

and/or structural live trees greater than 21 inches DBH that currently exist within stands proposed for 

harvest activities, except within 11, 945 acres of proposed commercial harvest units in the Snow Basin 

project for the duration of Snow Basin project implementation.”

This plan amendment is being prepared under the 2000 rule as amended with transition wording at 36 

CFR 219.35 that allows the use of the 1982 rule procedures. [See 65 FR 67568, Nov. 2000, as amended at 

66 FR 1865, Jan. 10, 2001; 66 FR 27554, May 17, 2001; 67 FR 3543, May 20, 2002; 68 FR 53297, Sept. 

10, 2003; 69 FR 58057, Sept. 29, 2004]. The 1982 rule and the 2000 rule as amended are available online 

at http://www.fs.fed.us/emc/nfma/2000_planning_rule.html.
Chapter 2 Snow Basin Vegetation Management Project FEIS

29

Project design features and monitoring tasks for alternative 2

See appendix B-1, tables B-1a and B-1b for a complete list of design features as applicable to the 

alternatives and the list of specific monitoring tasks.

Sale area improvement (SAI) activities

The following projects and opportunities have been identified as possible candidates to receive funding 

under the Knutsen-Vandenburg Act. These are commonly referred to as KV funds and are collected from 

the sale of timber. If KV funds are limited, appropriated funding would be pursued for the implementation 

of these activities. KV/SAI projects associated with the implementation of Alternatives 2, 3, or 4 are 

analyzed for environmental effects in chapter 3 of this document.

Table 6 displays the potential sale area improvement projects associated with the action alternatives for 

the Snow Basin project. The acres and miles for each would depend upon the alternative selected.

Table 6. Sale area improvement projects 

Class Project

TSI Non-commercial thinning within tractor harvest units

HF Grapple piling of non-commercial thinning slash in tractor harvest units

TSI Non-commercial thinning Units 

HF Grapple pile 

Roads Road reconstruction 

Wildlife Decommissioning 6 miles of roads no longer needed*

Wildlife Revegetation of decommissioned roads 

Wildlife Wildlife habitat mechanical treatment: felling of non-commercial sized conifers to release 

aspen from competition

Wildlife Non-range fences: fencing aspen restoration areas to exclude livestock and/or big game

Wildlife Wildlife habitat snag creation if needed.

Wildlife Wildlife habitat monitoring associated with snag habitat and road decommissioning 

TSI Non-commercial thinning skyline harvest units

HF Spot burn skyline harvest units

Weeds Monitor and treat noxious weeds outside of activity areas but within the project planning 

area**

Fisheries Whole tree additions for fisheries habitat enhancement in Holcomb Creek (2.0 miles)

Fisheries Whole tree additions for fisheries habitat enhancement in Paddy Creek (2.5 miles)

Fisheries Whole tree additions for fisheries habitat enhancement in Little Eagle Creek (3 miles)

*Roads identified for decommissioning are displayed on the transportation maps in appendix A and described route 

by route in appendix B.

**Weed treatments are implemented as part of the district program, authorized under the Wallowa-Whitman 

National Forest Invasive Plants Treatment Project (WWNF 2010).

Alternative 3 

Alternative 3 has been modified from the alternative 3 proposed in the draft environmental impact 

statement released in April 2011. This alternative responds to the key issue identified during the scoping 

period, impacts associated with structural stages in late and old structure forest. This alternative also 

responds to new information concerning conditions in the analysis area and additional key issues 

identified during the comment period. Modifications to alternative 3 respond to key issues concerning 

impacts to connectivity corridors, temporary road construction, and impacts to American marten habitat. 

Modifications to alternative 3 since the public release of the DEIS include:
Chapter 2 Snow Basin Vegetation Management Project FEIS

30

• Riparian habitat conservation areas have been field verified and updated. Treatment units have been 

updated to reflect the field verified data.

• All treatments within riparian habitat conservation areas would use a forwarder harvester to reduce 

impacts to soils (units 1, 33A, 34, 57, 301, 303, 311A, 314A, 316A, 342, 401).

• Winter harvest restrictions were added to commercial harvest activities in unit 121.

• All regeneration units were dropped.

• Alternative 3 would retain stand density between the mid and upper management zone in identified 

connectivity corridors between late and old structure stands and forest plan designated old growth to 

address connectivity concerns. This would result in the retention of an additional 10-25 square feet of 

basal area per acre in identified connectivity corridors over that retained in alternative 2. 

• Alternative 3 was modified to include an American marten prescription for cool/moist/dry stands 

containing potential American marten habitat to maintain existing American marten habitat 

requirements.

• Alternative 3 was modified to eliminate temporary road construction within the Eagle Creek wild and 

scenic river corridor in order to address public concerns regarding the impacts of temporary road 

construction. In response to associated access issues, commercial harvest treatments were eliminated 

in some units.

• Commercial treatments were eliminated in specific units to address harvest viability concerns.

• A forest plan amendment to allow harvest in late and old structure stages that are currently below the 

historic range of variability was added to alternative 3 to allow harvest in late and old structure stands 

that were historically comprised of ponderosa pine and western larch and are currently dominated by 

large grand fir trees.

Alternative 3 purpose and design 

Alternative 3 was designed to respond to the agency’s purpose and need for action by thinning 

overstocked stands to move forested stands toward the historic stand structures and species compositions 

to increase forest resiliency and reduce the risk of uncharacteristic disturbance while responding to the 

key issues concerning, maintaining LOS, connectivity corridors, American marten habitat and temporary 

road construction. Proposed treatments included in alternative 3 respond to land and resource 

management objectives established for the Snow Basin project, and to a lesser extent, meet the objectives 

previously described for alternative 2. Treatments in alternative 3 are designed to:

• Implement project activities that provide increased protection in wildlife connectivity corridors 

between late and old structure stands and management area 15 (old growth) stands.

• Implement project activities that maintain existing American marten habitat requirements while 

reducing the risk of uncharacteristically severe wildfire in these areas.

• Reduce the impacts of temporary road construction.

• Move forested stands toward historical range of variability for species composition, stand densities 

and stand structures on a landscape scale. Thinning treatments are proposed to reduce tree density, 

modify species composition, promote the development of single story late/old structure, and reduce 

insect and disease susceptibility by improving tree and stand vigor. 

• Reduce fuel loading (surface, ladder and canopy fuels) to a level that facilitates future reintroduction 

of natural fire severities (low to mixed) and reduce fuels that would contribute to uncharacteristic 

wildfire and resource damage.

• Overstory removal is proposed to improve forest sites where early-seral species are no longer present 

in ecologically viable amounts as a result of grand fir conversion.

• Maintain and enhance underrepresented aspen stands by reducing conifer competition and reducing 

browsing pressures.

• Provide sawlogs and wood fiber products for utilization by local and regional industry.
Chapter 2 Snow Basin Vegetation Management Project FEIS

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Vegetation and prescribed fire treatments for alternative 3

See the Vegetation and Prescribed Fire Treatments section of alternative 2 for detailed descriptions of 

proposed activities and objectives. The same activities described for alternative 2 would occur for 

alternative 3 with the following differences and exceptions:

Commercial harvest

Commercial harvest is proposed on approximately 11,013 acres using a combination of intermediate 

thinning and overstory removal. This alternative would result in a potential yield of 48 MMBF.

Intermediate thinning from below

Intermediate thinning from below is proposed on approximately 10,257 acres.

Warm/dry Douglas-fir - ponderosa pine types

Intermediate thinning from below is proposed on approximately 4,135 acres of warm/dry Douglas-firponderosa pine forest types in the planning area.

Warm/moist Douglas fir types

Thinning from below is proposed on 879 acres of warm/very moist Douglas fir types. 

Warm/dry grand fir types

Intermediate thinning from below is proposed on approximately 3,969 acres of warm/dry grand fir forest 

type in the planning area. All grand fir trees with severe defect (broken tops, Indian Paint conks, weeping 

frost cracks, etc.) would be protected to provide snag dependent wildlife habitat.

Cool/moist/dry grand fir types

Thinning from below is proposed on 732 acres of cool/moist/dry grand fir forest type in the planning area. 

• Harvest treatments are proposed for 39 acres in American marten source habitat within the 

cool/moist/dry grand fir type. The prescription in American marten habitat is designed to maintain 

existing American marten habitat requirements (50 percent canopy closure, large trees and large 

down logs), ponderosa pine and western larch while reducing the risk of uncharacteristic 

disturbance. Within American marten habitat all grand fir within 30 feet of a viable ponderosa 

pine or western larch would be removed. All cull grand fir would be retained. All trees within 20 

feet of a cull grand fir would be retained. Created slash would be spot burned after harvest. All 

large down logs would be protected.

Overstory removal

Overstory removal is proposed on approximately 718 acres.

Aspen restoration conifer overstory removal 

Aspen restoration conifer overstory removal would remove conifer competition in underrepresented aspen 

stands on a total of 38 acres in 29 sites.

Harvest methods

See alternative 2 for a detailed description.

Grapple pile and burn

Grapple pile and burn on approximately 4,577 acres to reduce activity created fuels. 
Chapter 2 Snow Basin Vegetation Management Project FEIS

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Hand pile and burn

Hand pile and burn on approximately 124 acres (in commercially treated areas close to private lands in 

the WUI and within aspen restoration stands).

Elements common to all commercial harvest units for alternative 3

Snags and down logs

See alternative 2 for a detailed description.

Green replacement trees

See alternative 2 for a detailed description.

Dwarf mistletoe management

See alternative 2 for a detailed description.

Operational hazard trees

See alternative 2 for a detailed description.

Non-commercial thinning and fuels treatments

Non-commercially thin (NCT) approximately 8,945 acres following commercial harvest treatments. 

Non-commercial thinning of approximately 74 acres would occur as a stand-alone treatment.

Prescribed underburning

Prescribed underburning would occur on 10,322 acres to reduce fuels following commercial treatments. 

Prescribed underburning only would occur on 3,972 acres. 

Wildlife connectivity corridors

Harvest units within wildlife connectivity corridors between late/old structure areas and land designated 

by the forest plan for old-growth preservation (management area 15) stands would maintain stand density 

between the mid and upper management zone. This would retain an additional 10-25 square feet of basal 

area per acre over the retention proposed in alternative 2. Approximately 2,784 acres of wildlife 

connectivity corridor would be treated in alternative 3. In addition, the extensive riparian habitat 

conservation system would maintain existing canopy closure between many late/old structure areas and 

management area 15 stands.

Riparian habitat conservation areas

Silviculture treatments are proposed on approximately 43 acres within RHCAs in order to improve stand 

conditions while facilitating treatment in adjacent upland units. This represents approximately 0.8 percent 

of the total acreage of riparian habitat conservation areas in the planning area. Forwarder trails would be 

established within an additional 61 acres of riparian habitat conservation areas where an existing Forest 

Service system road is used to access units outside the riparian habitat conservation area above the road.

This represents approximately 1.2 percent of the total acreage of riparian habitat conservation areas in the 

planning area. Existing landings in riparian habitat conservation areas above these roads would also be 

used. An estimated 25 landings would be used within riparian habitat conservation areas impacting 

approximately 5 acres. See alternative 2 for a more detailed description.

Wild and Scenic Rivers corridor

Activities within the Wild and Scenic River corridor consist of 72 acres of prescribed fire and 154 acres 

of commercial harvest in the Recreation section of the river and 493 acres of prescribed fire and 107 acres 

of commercial harvest in the Scenic section.
Chapter 2 Snow Basin Vegetation Management Project FEIS

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Follow-up treatments proposed for alternative 3

See alternative 2 for a detailed description.

Transportation system activities for alternative 3

Within and in close proximity to the project area, approximately 224 miles of road would be used for haul

(221 miles are NFSRs and 3.0 miles are private). There are 6.5 miles of Baker County roads that will be 

used in the project area. Outside of the project area, there are 33 miles of NFSRs and county roads that 

will be utilized for haul between the project area and State Highway 86. No new permanent road 

construction is planned. Danger trees would be removed from along the haul roads for public and worker 

safety and would include some commercial removal for biomass.

Approximately 5.3 miles of new temporary road construction is proposed and in addition the project 

would utilize 3.7 miles of existing non-system routes. These temporary roads are in short segments 

ranging in length from less than 0.1 mile to 0.6 miles, and the average length is 0.2 miles. Temporary 

roads would be closed and rehabilitated prior to the closure of the timber sale.

Replace Little Eagle Bridge 2 as described for alternative 2.

All NFS roads would be maintained in accordance with standard timber sale road maintenance 

specifications. Of the estimated 224 miles of NFS haul roads; approximately 105 miles are currently 

closed roads (maintenance level 1). Roads currently closed, would be opened to allow harvest activities to 

occur and closed upon completion. Most of these roads, 93 miles, need only normal maintenance to be 

usable. The other 12 miles will need some reconstruction work; those are described in detail in appendix 

B-10. Under normal operations, only a few harvest units are active at a time. It is estimated that up to 5 

miles of closed road may be open at one time. These roads would be re-closed when harvest operations 

are completed, normally within four to eight months of opening. Post-sale activities such as planting and 

thinning may present the need to reopen some of these roads temporarily. They would be reclosed upon 

completion and would likely be open for a period of two to four months. Firewood gathering along closed 

roads would be considered on a case by case basis and made under another decision.

Alternative 3 proposes 39.4 miles of road reconstruction. For this alternative, road reconstruction on 

approximately 13 miles of road will not be funded through the timber sale and will be funded through a 

different means. See alternative 2 for a description of reconstruction activities.

Pit development and rock sources would be as described for alternative 2. 

Easement acquisition would be as described for alternative 2.
Chapter 2 Snow Basin Vegetation Management Project FEIS

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Table 7. Summary of alternative 3 activities

Management Activity Measure

Forested Stand Treatments Rx (only on N FS lands) Acres

Intermediate commercial thinning acres 9,955

Intermediate commercial thinning acres in riparian habitat 

conservation areas 43

Intermediate commercial thinning acres in Wild and Scenic 

River corridor 261

Total Intermediate Commercial Thinning 10,257

Partial over story removal 718

Aspen restoration/conifer removal 38

Total Commercial Harvest Treatment 11,013

Non-commercial thinning post-harvest 8,945

Non-commercial thinning only Rx 74

Total Non-commercial Thinning 9,019

Fuels Treatments (only on NFS lands) Acres

+Post activity prescribed fire fuels treatments in commercial 

harvest acres 10,322

+Natural fuels prescribed fire 3,972

Post-harvest machine grapple pile and burn 4,577

Post-harvest hand pile and burn 124

Total Fuels Treatments 18,995

Logging System Activities Acres

Tractor logging system 7,912

Skyline/cable logging system 2,165

Forwarder harvester 936

Total Logging System 11,013

Transportation Activities Miles

Maintain NFSRs for log hauling 224.5

Open (maintenance level 2-3) 119.6

Closed (maintenance level 1) 104.9

Danger tree removal (along system haul roads) 225

Total temporary road construction 9.0

New construction 5.3

Existing non-system roads 3.7

Reconstruction of NFSRs 39.4

Open (maintenance level 2) Miles/Structures

Deferred maintenance/repairs 26.3

Bridge replacement (1 bridge) 1 bridge

Bridge abutment repair (1 bridge) 1 bridge

Closed (maintenance level 1) Miles

Deferred maintenance/repairs 12.1

Realignment NFSRs 1.0

Total NFSRs reconstruction 39.4
Chapter 2 Snow Basin Vegetation Management Project FEIS

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Proposed forest plan amendments for alternative 3

Alternative 3 would require two forest plan amendments. See the alternative 2 Proposed Forest Plan 

Amendment section for additional details concerning the following amendments.

Forest plan amendment 1

A site-specific non-significant forest plan amendment is proposed to allow timber harvest activities within 

late and old structural stages that are below the historic range of variability in particular biophysical 

environments. Treatments in these stands are needed to change multi-story stands dominated by large 

grand fir trees to single story stands dominated by large early-seral ponderosa pine and western larch 

trees. In addition, treatments are needed to maintain declining desired tree species such as ponderosa pine 

and western larch by reducing competition with over represented large grand fir. 

The proposed amendment would allow timber harvest activities on 626 acres of qualifying late and old 

structural stands. This amounts to approximately 15 percent of the late and old structural stands within the 

planning area and less than 0.1 percent of the 1.09 million acres classified as suitable for timber 

management activities on the Wallowa-Whitman National Forest. This amendment would update the 

Regional Forester’s Forest Plan Amendment 2 as specified.

Page 9, Appendix B Revised Interim Direction: 

“DO NOT allow timber sale harvest activities to occur within LOS stages that are BELOW HRV.”

Amended direction would read:

“DO NOT allow timber sale harvest activities to occur within LOS stages that are BELOW HRV except 

within Snow Basin project area during implementation of Snow Basin Vegetation Management Project 

activities as described in the Snow Basin Vegetation Management Project Record of Decision, dated 

March 2012.”

Forest plan amendment 2 would not be proposed

For alternative 3, treatments in late and old structure stands would retain sufficient late and old structure

to meet Region 6 Interim Old Growth Definitions resulting in no net loss of late and old structural stands 

in the project area. Therefore, no amendment would be proposed to allow a net reduction of late and old 

structure stands.

Forest plan amendment 3

A site-specific non-significant forest plan amendment is proposed to remove a limited amount of conifers 

of any size from all units proposing commercial harvest. This amendment is needed to remove conifers 

within harvest treatment stands based on the greatest benefit to residual tree survival and stand 

sustainability rather than based on conifer diameter. 

This amendment would apply to 11,013 acres, or approximately 41 percent of the 26,494 acre Snow 

Basin planning area, which accounts for approximately 1 percent of the 1.09 million acres considered 

suitable for timber management on the Wallow-Whitman National Forest. 

This amendment would update the Regional Forester’s Forest Plan Amendment 2 as specified.

Page 10, Appendix B Revised Interim Direction;

“Scenario A: Outside of late and old structural stages, many types of timber sale activities are allowed. 

Intent is still to maintain and/or enhance late and old structure components in stand subject to timber 

harvest such as possible, by adhering to the following standards: a) Maintain all remnant late and old seral 

and/or structural live trees greater than 21 inches DBH that currently exist within stands proposed for 

harvest activities.”
Chapter 2 Snow Basin Vegetation Management Project FEIS

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Amended direction would read:

“Scenario A: Outside of late and old structural stages, many types of timber sale activities are allowed. 

Intent is still to maintain and/or enhance late and old structure components in stand subject to timber 

harvest such as possible, by adhering to the following standards: a) Maintain all remnant late and old seral 

and/or structural live trees greater than 21 inches DBH that currently exist within stands proposed for 

harvest activities, except within 11, 013 acres of proposed commercial harvest units in the Snow Basin 

project for the duration of Snow Basin project implementation.”

Project design features and monitoring tasks for alternative 3

See FEIS Appendix B-1, Table B-1a and Table B-1b for a complete list of design features as applicable to 

all alternatives and the list of specific monitoring tasks.

Sale area improvement activities for alternative 3

See the description of sale area improvement activities disclosed for alternative 2.

Alternative 4 

Alternative 4 has been modified from the alternative 4 proposed in the draft environmental impact 

statement released in April 2011. This alternative responds to one of the key issues identified during the 

scoping period, harvest of trees greater than 21 inches DBH. This alternative also responds to new 

information about the analysis area and additional key issues identified during the comment period. 

Modifications to this alternative respond to key issues concerning impacts to connectivity corridors, 

temporary road construction and impacts to American marten habitat. No forest plan amendments would 

be needed to implement alternative 4. Modifications to alternative 4 since the public release of the DEIS 

include:

• Riparian habitat conservation areas have been field verified and updated. Treatment units have been 

updated to reflect the field verified data.

• All treatments within riparian habitat conservation areas would use a forwarder harvester to reduce 

impacts to soils (units 1, 33A, 34, 57, 301, 303, 311A, 314A, 316A, 342, 401).

• Winter harvest restrictions were added to commercial harvest activities in unit 121.

• All regeneration units were dropped.

• Alternative 4 would retain stand density between the mid and upper management zone in identified 

connectivity corridors between late and old structure stands and forest plan designated old growth to 

address connectivity concerns. This would result in the retention of an additional 10 to 25 square feet 

of basal area per acre in identified connectivity corridors over that retained in alternative 2. 

• Alternative 4 was modified to include an American marten prescription for cool/moist/dry stands 

containing potential American marten habitat to maintain existing American marten habitat 

requirements.

• Alternative 3 was modified to eliminate temporary road construction. As a result of associated access 

issues, commercial harvest treatments were eliminated in some units.

• Commercial treatments were eliminated in specific units to address harvest viability concerns.

Alternative 4 purpose and design

Alternative 4 was designed to respond to the agency’s purpose and need for action by thinning 

overstocked stands to move forested stands toward the historic stand structures and species compositions 

to increase forest resiliency and reduce the risk of uncharacteristic disturbance while responding to the 

key issues concerning connectivity corridors, American marten habitat and temporary road construction. 
Chapter 2 Snow Basin Vegetation Management Project FEIS

37

Proposed treatments included in alternative 4 respond to land and resource management objectives 

established for the Snow Basin project, and to a greatly reduced extent, meet the objectives previously 

described for alternative 2. Treatments in alternative 4 are designed to:

• Eliminate the removal of trees greater than 21 inches DBH while providing a short-term reduction in 

stand density and reduced movement toward sustainable historic stand conditions.

• Implement project activities that provide increased protection in wildlife connectivity corridors 

between late and old structure stands and MA 15 (old growth) stands.

• Implement project activities that maintain existing American marten habitat requirements while 

reducing the risk of uncharacteristically severe wildfire in these areas.

• Eliminate the impacts of temporary road construction.

• Move forested stands toward historical range of variability for species composition, stand densities 

and stand structures on a landscape scale. Thinning treatments are proposed to reduce tree density, 

modify species composition, promote the development of single story late/old structure, and reduce 

insect and disease susceptibility by improving tree and stand vigor. 

• Reduce fuel loading (surface, ladder and canopy fuels) to a level that facilitates future reintroduction 

of low-intensity surface fire and reduce fuels that would contribute to uncharacteristic wildfire and 

resource damage.

• Overstory removal is proposed to improve forest sites where early-seral species are no longer present 

in ecologically viable amounts as a result of grand fir conversion.

• Maintain and enhance underrepresented aspen stands by reducing conifer competition and reducing 

browsing pressures.

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

Vegetation and prescribed fire treatments for alternative 4

See the Vegetation and Prescribed Fire Treatments section of alternative 2 for detailed descriptions of 

proposed activities and objectives. The same activities described for alternative 2 would occur under 

alternative 3 with the following exceptions. See map attachments (Appendix A, Maps A-4a to A-4b) for 

alternative 4 vegetation treatments, logging systems and transportation actions.

Commercial harvest

Commercial harvest is proposed on approximately 9,228 acres using a combination of intermediate 

thinning, overstory removal and regeneration cuts, with a potential yield of 32 MMBF of timber.

Intermediate thinning from below

Intermediate thinning from below is proposed on approximately 8,644 acres.

Warm/dry Douglas-fir-ponderosa pine types

Intermediate thinning from below is proposed on approximately 3,667 acres of warm/dry Douglas-firponderosa pine forest types in the planning area

Warm/moist Douglas fir types

Thinning from below is proposed on 662 acres of warm/moist Douglas fir types.

Warm/dry grand fir types 

Intermediate thinning from below is proposed on approximately 3,380 acres of warm/dry grand fir forest 

type in the planning area. All grand fir trees with severe defect (broken tops, Indian Paint conks, weeping 

frost cracks, etc.) would be protected to provide snag dependent wildlife habitat.
Chapter 2 Snow Basin Vegetation Management Project FEIS

38

Cool/moist/dry grand fir types

Thinning from below is proposed on 439 acres of cool/moist/dry grand fir forest type in the planning area.

• Harvest treatments are proposed for xxx acres in American marten habitat within the 

cool/moist/dry grand fir type. See the prescription description presented in alternative 3.

Overstory removal

Overstory removal is proposed on approximately 546 acres.

Aspen restoration conifer overstory removal

Aspen restoration conifer overstory removal would remove conifer competition in underrepresented aspen 

stands on a total of 38 acres in 29 sites. See alternative 2 for a detailed description.

Harvest methods

See alternative 2 for a detailed description.

Grapple pile and burn

Grapple pile and burn would occur on approximately 4,258 acres to reduce activity fuels following noncommercial treatments.

Hand pile and burn

Hand pile and burn would occur on approximately 125 acres (in commercially treated areas close to 

private lands in the WUI and within aspen restoration stands).

Elements common to all commercial harvest units for alternative 4

Snags and down logs. 

See alternative 2 for a detailed description.

Green replacement trees 

See alternative 2 for a detailed description, except trees 21 inches DBH and larger would not be removed.

Dwarf mistletoe management 

See alternative 2 for a detailed description, except trees 21 inches DBH and larger would not be removed.

Operational hazard trees 

See alternative 2 for a detailed description.

Non-commercial thinning and fuels treatments

Non-commercial thinning of approximately 7,157 acres would occur following commercial harvest 

treatments.

Non-commercial thinning would occur on approximately 74 acres as a stand-alone treatment.

Prescribed underburning

Prescribed underburning would occur on 8,692 acres to reduce harvest activity fuels following 

commercial treatments. 

Prescribed underburning only would occur on 4,618 acres.

Wildlife connectivity corridors

Harvest units within wildlife connectivity corridors between late/old structure areas and land designated 

by the forest plan for old-growth preservation (management area 15) stands would maintain stand density 
Chapter 2 Snow Basin Vegetation Management Project FEIS

39

between the mid and upper management zone. This would retain an additional 10-25 square feet of basal 

area per acre over the retention proposed in alternative 2. Approximately 2,564 acres in wildlife 

connectivity corridors would be treated in alternative 4. In addition, the extensive riparian habitat 

conservation system would maintain existing canopy closure between many late/old structure areas and 

management area 15 stands. Trees 21 inches DBH and larger would not be removed.

Riparian habitat conservation areas 

Silviculture treatments are proposed on approximately 43 acres within RHCAs in order to improve stand 

conditions while facilitating treatment in adjacent upland units. This represents approximately 0.8 percent 

of the total acreage of riparian habitat conservation areas in the planning area. Forwarder trails would be 

established within an additional 61 acres of riparian habitat conservation areas where an existing Forest 

Service system road is used to access units outside the riparian habitat conservation area above the road.

This represents approximately 1.2 percent of the total acreage of riparian habitat conservation areas in the 

planning area. Existing landings in riparian habitat conservation areas above these roads would also be 

used. An estimated 25 landings would be used within riparian habitat conservation areas impacting 

approximately 5 acres. These treatments are the same described for alternative 2, except trees 21 inches

DBH and larger would not be removed.

Wild and Scenic River corridor 

Activities within the Eagle Creek Wild and Scenic River corridor consist of 72 acres of prescribed fire 

and 105 acres of commercial harvest in the Recreation section and 493 acres of prescribed fire and 107 

acres of commercial harvest in the Scenic section. 

Follow-up treatments proposed for alternative 2

See alternative 2 for a detailed description of follow-up treatments.

Transportation system activities for alternative 4

Within and in close proximity to the project area, approximately 214 miles of road would be used for haul 

(211 miles are NFSRs and 3.0 miles are private). There are 6.5 miles of Baker County roads that will be 

used in the project area. Outside of the project area, there are 33 miles of NFSRs and county roads that 

will be utilized for haul between the project area and State Highway 86. No new permanent road 

construction is planned. Danger trees would be removed from along the haul roads for public and worker 

safety and would include some commercial removal for biomass.

There is no temporary road construction proposed for this alternative.

Replace Little Eagle Bridge 2 as described for alternative 2.

All NFS roads would be maintained in accordance with standard timber sale road maintenance 

specifications. Of the estimated 214 miles of NFS haul roads; approximately 98 miles are currently closed 

roads (maintenance level 1). These roads would be opened to allow harvest activities to occur and closed 

upon completion. Under normal operations, only a few harvest units are active at a time. It is estimated 

that up to a maximum of 5 miles of closed road may be open at one time. These roads would be re-closed 

when harvesting is completed, normally within four to eight months of opening. Post-sale activities such 

as planting and thinning may present the need to reopen some of these roads temporarily. They would be 

reclosed upon completion and would likely be open for a period of two to four months. Firewood 

gathering along closed roads would be considered on a case by case basis and decided at a later date.

Alternative 4 proposes 37.6 miles of forest service system road reconstruction. Alternative 3 proposes 

39.4 miles of road reconstruction. For this alternative, road reconstruction on approximately 13 miles of 

road will not be funded through the timber sale and will be funded through a different means. See 

alternative 2 for a description of reconstruction activities.
Chapter 2 Snow Basin Vegetation Management Project FEIS

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Pit development and rock sources would be as described for alternative 2. 

Easement acquisition would be as described for alternative 2.
Chapter 2 Snow Basin Vegetation Management Project FEIS

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Table 8. Summary of alternative 4 activities

Management Activity Measure

Forested Stand Treatments Rx (only on N FS lands) Acres

Intermediate commercial thinning acres 8,391

Intermediate commercial thinning acres in riparian habitat 

conservation areas 43

Intermediate commercial thinning acres in Wild and Scenic 

River corridor 212

Total Intermediate Commercial Thinning 8,644

Partial over story removal 546

Aspen restoration/conifer removal 38

Total Commercial Harvest Treatment 9,228

Non-commercial thinning post-harvest 7,157

Non-commercial thinning only Rx 74

Total Non-commercial Thinning 7,231

Fuels Treatments (only on NFS lands) Acres

+Post activity prescribed fire fuels treatments in commercial 

harvest acres 8,692

+Natural fuels prescribed fire 4,618

Post-harvest machine grapple pile and burn 4,258

Post-harvest hand pile and burn 125

Total Fuels Treatments 17,693

Logging System Activities Acres

Tractor logging system 6,667

Skyline/cable logging system 1,470

Forwarder harvester 1,091

Total Logging System 9,928

Transportation Activities Miles

Maintain NFSRs for log hauling 214.3

Open (maintenance level 2-3) 116.7

Closed (maintenance level 1) 97.6

Danger tree removal (along system haul roads) 215

Total temporary road construction 0

New construction 0

Existing non-system roads 0

Reconstruction of NFSRs 37.6

Open (maintenance level 2) Miles/Structures

Deferred maintenance/repairs 25.1

Bridge replacement (1 bridge) 1 bridge

Bridge abutment repair (1 bridge) 1 bridge

Closed (maintenance level 1) Miles

Deferred maintenance/repairs 11.5

Realignment NFSRs 1.0

Total NFSRs reconstruction 37.6
Chapter 2 Snow Basin Vegetation Management Project FEIS

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Proposed Forest Plan Amendments for alternative 4

Alternative 4 would not require any forest plan amendments. 

Project design features and monitoring tasks for alternative 4

See Appendix B-1, Table B-1a and Table B-1b for a complete list of design features as applicable to all 

alternatives and the list of specific monitoring tasks. 

Sale area improvement activities for alternative 4

See the description of sale area improvement activities described for alternative 2.

Alternatives Considered but Eliminated from Detailed Study

Federal agencies are required by NEPA to rigorously explore and objectively evaluate all reasonable 

alternatives and to briefly discuss the reasons for eliminating any alternatives that were not developed in 

detail (40 CFR 1502.14). Public comments received in response to the Proposed Action provided 

suggestions for alternative methods for achieving the purpose and need. Some of these alternatives may 

have been outside the scope of the purpose and need for the Snow Basin project, duplicative of the 

alternatives considered in detail, or determined to be components that would cause unnecessary 

environmental harm. Therefore, a number of alternatives were considered, but dismissed from detailed 

consideration for reasons summarized below.

Maximize Use of Prescribed Fire Only

An alternative to maximize using prescribed fire instead of commercial logging was suggested by some 

respondents. Use of prescribed fire in dense, multi-storied, mixed species stand types is complex, difficult 

and expensive to apply because overstory mortality, mineral soil exposure, and smoke emissions are a 

concern. Without mechanically pre-treating the forest to reduce stocking and layering of the forest, the 

likely outcome of this approach would be large areas of mortality and exposed soil; burn characteristics 

resembling a wildfire more that a prescribed fire.

Additionally, the Whitman Ranger District currently manages a large burn program. Balancing these 

burns with the current backlog of maintenance burns; while meeting state and federal smoke management 

requirements as well as public acceptance of smoke impacts, would be very difficult.

This alternative would not meet the project goals stated in the purpose and need. Additionally, a 

significant loss of potential forest products would also occur. Based on this information, this alternative 

was considered but not analyzed in detail. 

Use of Non-commercial Thinning Only/No Commercial Harvest

An alternative to maximize using non-commercial thinning instead of commercial logging was suggested. 

Non-commercial thinning is effective in removing small trees only, up to a maximum size of about 7 

inches in diameter. Larger trees are very difficult to handle non-commercially and aren’t consumed 

during burning in small piles. To effectively reduce stand density, reduce uncharacteristic grand fir 

dominance, and to provide conditions conducive to effective prescribed burning, an operation that 

removes larger trees is required. 

An alternative similar to this was analyzed in depth on the Pine Valley Vegetation Management Project 

(decision notice signed December 13, 2005 is available from the project record). The findings of this 

analysis, as disclosed in the effects section of that EA, were unacceptable levels of soil disturbance due to 

repeated entries into stands to conduct staged understory thinning, piling, and burning operations. This 

analysis also disclosed only minor improvement in attributes associated with forest sustainability, such as 

reduced competition between residual trees, achievement of desired stocking levels, reduced bark beetle 
Chapter 2 Snow Basin Vegetation Management Project FEIS

43

susceptibility, and decreased crown closure that can contribute to the development of crown fires. Since 

the Snow Basin planning area has similar forest structure, composition and stocking to the Pine Valley 

planning area, the effects are expected to be similar. This alternative would not meet the project goals as 

stated in the Purpose and Need. Based on this information, this alternative was considered but not 

analyzed in detail.

Alternatives Proposed by the Public during Scoping

An alternative was suggested during a public meeting held in the scoping period. Most of the design 

elements identified during this meeting were considered in detail in one or more of the alternatives 

analyzed in detail. All of the alternatives eliminated harvest in the regeneration units. Alternative 4 

eliminated the removal of trees greater than 21 inches DBH which would maintain high mistletoe 

infection in LOS and Douglas-fir stands by removing mostly mid-canopy trees. In addition, Alternative 4 

would maintain existing snag recruitment levels and retain residual basal area above the recommended

management zone of stand density index in all cases. Alternatives 3 and 4 propose an individual tree 

release prescription in American marten habitat within cool/moist/dry grand fir biophysical types which 

would only remove grand fir trees less than 21 inches DBH within 30 feet of viable ponderosa pine or 

western larch trees. 

An alternative similar to alternative 4 that would manage mistletoe with fire rather than through harvest, 

would girdle trees at least 21 inches DBH instead of removing them, and would use an individual tree 

release prescription extensively in all grand fir biophysical types was considered. This alternative was 

eliminated from detailed study for the following reasons:

Manage mistletoe with fire

Fire can and would reduce dwarf mistletoe in the lower crowns, but research indicates that to achieve a 

meaningful reduction of dwarf mistletoe infection, scorch heights would have to be so high that direct 

mortality would result. This higher intensity fire would cause higher fire effects throughout the stand 

which would include the loss of large numbers of otherwise healthy trees 21 inches DBH and greater of 

all species rather than selecting only trees with high infection levels. One of the objectives of the project 

is to retain healthy large trees of desired species on the landscape in order to promote the development of 

late and old structure characteristics in these stands. High mortality rates of random tree species would 

move these stands away from the desired future condition.

Girdle trees 21 inches DBH and greater

This is an impractical approach for addressing issues of over stocking and species composition. At a 

landscape scale this could mean girdling tens of thousands of large trees. In the long term, over the next 7 

years, many of these trees could become structurally compromised and subject to breakage with the 

potential of falling on forest users, roads and developments. The existing high surface fuel levels in the 

project area would continue to increase as these large fuels collect on the ground. The thousands of 

girdled trees would reduce the impact of the proposed fuels and vegetation management activities on fire 

risk. This would not meet the project need to promote stand resilience and sustainability. Girdling is not 

currently part of any alternative although fungal inoculation and/or topping to create snags in overstory 

removal units may be considered in the event surveys indicate additional snag habitat is needed. 

Individual tree release prescription 

Extensive use of an individual tree release prescription would retain a well distributed grand fir seed 

source and promote the rapid regeneration of multistoried grand fir dominated stand conditions. This 

prescription has been attempted in other parts of the watershed and resulted in no long-term change in 

forest condition, no enhancement of LOS and no reduction in severe fire risk. These areas would continue 

to remain outside of their historical range of variability for species composition, density and structural 
Chapter 2 Snow Basin Vegetation Management Project FEIS

44

characteristics. The susceptibility of these areas to large scale insect and disease and uncharacteristically 

severe wildfire would not be reduced. As a result, this treatment would not meet the purpose and need of 

this project.

Identification of the Preferred Alternative

Alternative 3 is the agency’s preferred alternative.

Comparison of Alternatives

This section provides a tabular comparative summary of the effects of implementing each alternative as 

derived from chapter 3 effects analysis. Information in the following tables is focused on activities and 

effects where different levels of effects or outputs can be distinguished quantitatively or qualitatively 

among alternatives.

This section provides a tabular comparative summary of the effects of implementing each alternative as 

derived from chapter 3 effects analysis. Information in the following tables is focused on activities and 

effects where different levels of effects or outputs can be distinguished quantitatively or qualitatively 

among alternatives.
Chapter 2 Snow Basin Vegetation Management Project FEIS

45

Table 9. Comparison of alternatives: project objectives/key indicators

Project Objective/Key Indicator(s) Alternative 1

(no action)

Alternative 2

(proposed action) Alternative 3 Alternative 4

Manage forest structure towards landscape HRV

Acres of non-LOS moved toward single strata 

forest with large trees (SSLT)* 0 7,055 6,725 6,019

Acres of LOS restored to characteristic 

conditions** 0 1,865 1,784 868

Acres of MSLT changed to SSLT 0 1,249 1,158 868

Acres of increased radial growth for large tree 

development*** 0 7,730 7,356 6,526

Acres where tree species composition is moved 

towards characteristic conditions 0 11,495 11,013 9,229

Acres where structural stages are moved towards 

characteristic condition as determined by HRV. 0 8,428 8,039 6,593

Move the landscape toward a condition of reduced risk of high severity and extent of disturbance, taking into account changes in climate

Acres where stand densities managed to reduce 

risk of bark beetles. 0 11,495 11,013 9,229

Stand replacement potential (percent) 86 47 52 57

Fire regime condition class of the landscape as 

measured by FRCC departure (percent) 64 34 37 36

Acres of expected change in fire behavior potential 0 12,473 11,234 10,644

Provide a supply of forest products to the public 

Volume of forest products provided to forest 

industries (MMBF) 0 58 MMBF 48 MMBF 32 MMBF

*Acres changed to SEOC

**Acres of multi-storied LOS changed to single storied LOS added to harvest in biophysical environments with LOS stage below HRV 

***Acres changed to SEOC and SI and NCT only

Table 10. Comparison of action alternatives activities

Management Activity Alternative 2

(proposed action) Alternative 3 Alternative 4

Forested Stand Treatments Rx (only on N FS lands) Acres

Intermediate commercial thinning acres 10,088 9,955 8,391
Chapter 2 Snow Basin Vegetation Management Project FEIS

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Management Activity Alternative 2

(proposed action) Alternative 3 Alternative 4

Intermediate commercial thinning acres in riparian habitat conservation areas 50 43 43

Intermediate commercial thinning acres in Wild and Scenic River corridor 369 261 212

Total Intermediate Commercial Thinning 10,506 10,257 8,644

Partial over story removal 951 718 546

Aspen restoration/conifer removal 38 38 38

Total Commercial Harvest Treatment 11,495 11,013 9,228

Non-commercial thinning post-harvest 9926 8,945 7,157

Non-commercial thinning only Rx 81 74 74

Total Non-commercial Thinning 10,007 9,019 7,231

Fuels Treatments (only on NFS lands) Acres

+Post activity prescribed fire fuels treatments in commercial harvest acres 10,467 10,322 8,692

+Natural fuels prescribed fire 4,995 3,972 4,618

Post-harvest machine grapple pile and burn 5,084 4,577 4,258

Post-harvest hand pile and burn 146 124 125

Total Fuels Treatments 20,692 18,995 17,693

Logging System Activities Acres

Tractor logging system 8,256 7,912 6,667

Skyline/cable logging system 2,284 2,165 1,470

Forwarder harvester 955 936 1,091

Total Logging System 11,457 11,013 9,928

Transportation Activities Miles

Maintain NFSRs for log hauling 229.6 224.5 214.3

Open (maintenance level 2-3) 121.9 119.6 116.7

Closed (maintenance level 1) 107.7 104.9 97.6

Danger tree removal (along system haul roads) 230 225 215

Total temporary road construction 10.9 9.0 0

New construction 6.9 5.3 0

Existing non-system roads 4.0 3.7 0

Decommission existing NFSRs 6.0 6.0 6.0

Reconstruction of NFSRs 41 39.4 37.6
Chapter 2 Snow Basin Vegetation Management Project FEIS

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Management Activity Alternative 2

(proposed action) Alternative 3 Alternative 4

Open (maintenance level 2) Miles/Structures

Deferred maintenance/repairs 26.3 26.3 25.1

Bridge replacement (1 bridge) 1 bridge 1 bridge 1 bridge

Bridge abutment repair (1 bridge) 1 bridge 1 bridge 1 bridge

Closed (maintenance level 1) Miles

Deferred maintenance/repairs 13.7 12.1 11.5

Realignment NFSRs 1.0 1.0 1.0

Total NFSRs reconstruction 41.0 39.4 37.6
Chapter 2 Snow Basin Vegetation Management Project FEIS

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Table11. Comparison of alternatives significant issues/forest plan amendments

Significant Issue/Indicators Alternative 1

(no action)

Alternative 2

(proposed action) Alternative 3 Alternative 4

Issue: Impacts to late and old structure (LOS) stands and 

conversion of MSLT stands to SSLT stands

Net loss (acres) of LOS stands in short-term zero acres (67acres) zero acres zero acres

Acres of MSLT LOS stands changed to SSLT LOS zero acres 1,236 acres 1,156 acres 1,114 acres

Acres of LOS stands moved toward more sustainable 

conditions zero acres 1,865 acres 1,784 acres 868 acres

Issue: Harvest of trees 21 inches DBH or greater

Acres of treatments that harvest trees 21 inches DBH or 

greater zero acres 12,400 acres 11,200 acres zero acres

Estimate of weighted average trees per acre (TPA) 21 inches 

DBH or greater that would remain following treatment 7.8 TPA 4.3 TPA 4.3 TPA 7.8 TPA

Issue: Temporary road construction 

1) Miles of temporary road construction zero miles 10.9 miles 9.0 miles zero miles

Issue: Impacts to wildlife connectivity corridors

1) Wildlife connectivity corridor acres identified within 

planning area 7,608 acres 7,608 acres 7,608 acres 7,608 acres

2) Treatment acres within wildlife connectivity corridors zero acres 2,972 acres 2,784 acres 2,564 acres

3) Connectivity corridor treatment basal area retained No treatment Lower Management Zone Mid – Upper 

Management Zone

Mid – Upper 

Management Zone

Issue: American marten habitat

1) Acres marten habitat within planning area (source and 

secondary habitat combined) 1,032 acres 1,032 acres 1,032 acres 1,032 acres

2) Harvest acres within marten habitat 0 442 acres 437 acres 261 acres

3) Structural complexity retained in American marten

habitat No treatment All snags, all large logs, all 

high defect grand fir

All snags, all large logs, 

all high defect grand fir

All snags, all large 

logs, all high defect 

grand fir

Forest plan amendments required None 3 2 None
Chapter 3 Snow Basin Vegetation Management Project FEIS

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CHAPTER 3 – AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES

Introduction

This chapter summarizes the physical, biological, social, and human environments of the project area and 

the direct, indirect and cumulative effects of implementing each alternative on that environment. The 

effects discussions are organized by resource area. Additional information on each resource can be found 

in the project file. This chapter also presents the scientific and analytical basis for the comparison of 

alternatives presented at the end of Chapter 2. FEIS Appendix A contains project maps for the proposed 

action and alternatives.

Specialist Reports, Use of “Best Available Science” and Project Record

This Environmental Impact Statement hereby incorporates by reference the Forested Vegetation, 

Fuels/Fire Management, Soils, Wildlife, Watershed Aquatics (including Fisheries), Threatened, 

Endangered and Sensitive Plants, Range, Invasive Species, Recreation, Wild and Scenic River, Visual 

Resources, Heritage and Paleontological, Economics/Social, Potential Wilderness/Unroaded Areas, and 

Transportation sections in the Snow Basin Project Record (40 CFR 1502.21). These specialist reports are 

located in each specialist’s section of the project record and contain the detailed data, methodologies, 

analyses, conclusions, maps, references and technical documentation that the resource specialists relied 

upon to reach the conclusions in this environmental analysis.

The best available science is considered in preparation of this EIS. However, what constitutes best 

available science might vary over time and across scientific disciplines. As a general matter, we show 

consideration of the best available science when we insure the scientific integrity of the discussions and 

analyses in the project NEPA document. Specifically, this EIS and the accompanying project record 

identifies methods used, references reliable scientific sources, discusses responsible opposing views, and 

discloses incomplete or unavailable information, scientific uncertainty, and risk (See 40 CFR, 1502.9 (b), 

1502.22, 1502.24). 

The Project Record for the Snow Basin Project includes all project-specific information, including 

resource reports, the watershed analysis, and other results of field investigations. The record also contains 

information resulting from public involvement efforts. The project record (paper copy) is located at the 

Wallowa-Whitman National Forest in Baker City, Oregon, and is available for review during regular 

business hours. In addition, the project record would have many records available to the public as 

electronic files (Adobe PDF format) upon request.

Direct, Indirect and Cumulative Effects

Under NEPA, “direct effects” are caused by the action and occur at the same time and place. “Indirect 

effects” are caused by the action and are later in time or farther removed in distance, but still reasonably 

foreseeable. 

Under NEPA, cumulative effects are the incremental effects of the proposed action or alternatives when 

added to other past, present, and reasonably foreseeable future actions regardless of what agency (federal 

or non-federal) or person undertakes such other actions. Cumulative effects can result from individually 

minor but collectively significant actions taking place over a period of time. In the descriptions of 

cumulative effects of the proposed action, relevant related actions that are known are identified and 

discussed. The default temporal scale (time limits for past activities) selected for this project is from 

twenty years ago to the present. The default spatial scale to be considered for this project is within the 6th

Code HUC watersheds that may be affected by the proposed action and all alternatives. However, each 
Chapter 3 Snow Basin Vegetation Management Project FEIS

50

resource area cumulative effect area can be different and possibly larger or even smaller depending on the 

resource area. A full listing of relevant related actions is provided in Appendix B. Each cumulative effects 

analysis, for each environmental component or resource area, is guided by and consistent with the 

Council on Environmental Quality letter, “Guidance on the Consideration of Past Actions in Cumulative 

Effects Analysis” of June 24, 2005. 

Overview of the Project Area

The Snow Basin Vegetation Management Project (hereafter called Snow Basin Project) is located on the 

Wallowa-Whitman National Forest, Whitman Ranger District, Baker County, Oregon. The legal location 

is T.7S, R.44E, all sections, and T.8S, R44E, most sections (See project location map, FEIS Appendix A). 

Elevations within the project area range from approximately 4,400 feet on the southern boundary to 

approximately 6,500 feet at the northern boundary near the border with the Little Eagle Inventoried 

Roadless area and the Eagle Cap Wilderness. The project area primarily encompasses two main 

subwatersheds (Paddy Creek-Eagle Creek and Little Eagle Creek) and has minor acreage in two other 

subwatersheds included (Lower Eagle Creek and East Ford Eagle Creek) located northwest and north of 

Halfway and Richland, Oregon. The topography is dissected by numerous perennial drainages and 

includes Little Eagle, Twin Bridges, Conundrum, Spring, Paddy, Gold, Packsaddle, Holcomb, Empire 

Gulch, and Dempsey. 

The Eagle Caps Wilderness area (in the Wallowa Mountains) is to the north of the Snow Basin project 

and is the water source for the watersheds in the project. In addition, the Eagle Creek Wild and Scenic 

River corridor is an important management feature of the project area.

Eagle Creek Wild and Scenic River

Eagle Creek is a designated Wild and Scenic River. The project area drapes over the Recreation and 

Scenic sections of the river. The recreation segment is from the Eagle Cap Wilderness boundary near 

Humming Bird Creek to Paddy Creek. The designation covers a 1⁄4 mile width from the high water mark 

on both sides of the river. The scenic section is from Paddy Creek to Little Eagle Creek (See FEIS 

Appendix A for a map showing the Wild and Scenic River). Scenery is recognized as an outstandingly 

remarkable value (ORV) in the Eagle Creek corridor and thus requires protection and enhancement under 

the provisions of the Wild and Scenic Rivers Act. The scenery, described as an ORV is as follows: “The 

designated portion of Eagle Creek possesses a great deal of diversity in landform, water, color, and 

vegetation, notable in the geographic region. Some of the attractions that combine to create Eagle Creek’s 

scenic beauty are the glaciated landscape of the upper portion, the steep forested canyon with numerous 

rock pinnacles in the middle portion, and the terraced basalt canyon of the lower portion. In addition, 

there is the diversity of vegetation, including the lush meadows, mixed-conifer and ponderosa pine 

forests, and grassy openings; and the variety of the stream’s rapids, waterfalls and deep pools. Even 

though the Eagle Creek drainage has been a focus of human interest since the turn of the century, visual 

impacts due to modifications are relatively minor, and the drainage still presents an overall natural 

landscape pleasing to forest visitors. The preliminary finding agrees with Congress that scenery in the 

Eagle Creek corridor is an outstandingly remarkable river value (Eagle Creek Wild and Scenic River 

Management Plan, 1993).

Climate

Most of the precipitation across the watershed falls as snow. Over half of the annual precipitation falls 

during the months of November through March. Elevations within the project area range from 

approximately 4,400 feet on the southern boundary near Sparta Butte and Forshey Meadow up to 

approximately 6,500 feet at its northern boundary near the Eagle Cap Wilderness. The flows of Eagle 

Creek are influenced primarily by snowmelt. Stream flows typically peak around mid-May to early June.
Chapter 3 Snow Basin Vegetation Management Project FEIS

51

Geology and Soils

The granitic Wallowa batholith dominates in the upper Eagle Creek watershed in the Eagle Cap 

Wilderness. The Wallowa Mountains were glaciated at least three times and perhaps as many as seven 

times between 11.000 and 500,000 years ago. The numerous cirque lakes, steep ridges, and craggy peaks 

in the Eagle Cap Wilderness were created by the sculpting of valley glaciers flowing out from a central 

point near Eagle Cap Mountain. Some places in the Wallowa batholith have been mineralized and contain 

deposits of gold, silver and copper. Erosion of these mineral bearing rocks has resulted in the deposition 

of gold in the alluvial benches and stream gravels of Eagle Creek and its tributaries. The upper and 

middle reaches of the project area watersheds are dominated by metamorphosed greenstones and tuffs of 

the Clover Creek formation, fossiliferous limestones of the Martin Bridge formation and slates, shales, 

and sandstones of the Hurwal Formation. The three formations represent ancient sea floor sediments 

formed about 100 million years ago. Widespread volcanism resulted in the formation of basalt plateaus 

surrounding the Wallowa Mountains uplift. The lower reaches of the project area watersheds are 

dominated by columnar jointed olivine basalts of the Columbia River Basalt Group. Feeder dikes from 

some of the local eruptions can be seen exposed in the older rocks and in the glacially calved granites in 

the upper reaches of the project area watersheds. The watershed valley is geologically unstable. Freezing,

thawing and precipitation contribute to periodic landslides. Numerous landslides, slumps, earth flows and 

debris avalanches are evident in the upper reaches of the project watersheds.

Soils in the Snow Basin project area developed over layers of basalt, andesite and Columbia River 

bedrock. In much of the area the soil is buried under or mixed with a layer of volcanic ash deposited from 

the eruption of Mount Mazama approximately 6000 years ago. Soil depths in the project area range from 

very shallow (less than 10 inches) to deep (40 to 60 inches).

Early History and Mining

The Nez Perce, Cayuse, and Umatilla peoples were recorded in the area in early historic times during 

their seasonal migrations. Season movements followed the game and plant resources. From 1841 to 1863 

the Oregon Trail brought an influx of Euro-American emigrants to this area. There was no settlement in 

the area including Eagle Creek until the 1860's with the discovery of gold. Gold mining activity occurred 

along and near Eagle Creek in the 1860’s. The mining activity left a lasting impact on the land and 

attracted people into the area. Numerous gold seekers came into the area, including Chinese laborers. 

Mining camps were located at East Eagle, Paddy Creek, Sparta, Trouble Gulch and Shanghai Gulch. By 

1869 Sparta supported a population of 3,000 people. By 1873, 32 miles of the Sparta Ditch had been 

completed, bringing water from Eagle Creek to Sparta for mining activities. Eagle Creek continues to 

play a role in agriculture irrigation utilizing some of the ditches originally constructed for mining. The 

Snow Basin watersheds, including Eagle Creek, have had one form or another of placer mining going on 

since 1869. The countryside is covered with historic signs of lode workings and exploration. In 1900, 

hydraulic methods were used on the high bar gravels along the creek. Signs of this activity are still visible 

today in Eagle Creek Watershed. Mill sites existed on East Eagle, Main Eagle, Paddy Creek and Lily 

White. Today the most common placer equipment utilized in Eagle Creek from Eagle Forks to the East 

Eagle confluence is a portable floating suction dredge.

Fisheries

Historically, Eagle Creek was known to have been used by steelhead and spring chinook Spring chinook 

appeared to have used the creek as late as 1963. Construction of the Brownlee, Oxbow, and Hells Canyon 

dams (1955-1967) on the Snake River effectively ended the anadromous fish runs in Eagle Creek by

1964. Within the National Forest boundary along Eagle Creek, there are several ponds on private lands. 

Water from Eagle Creek is diverted into the ponds and the land owners use the ponds to raise bass and 

trout.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Vegetation Management

The project area vegetation is characterized by a mixture of forest and natural openings of various sizes. 

The forested stands range from high elevation subalpine fir/lodgepole pine to low elevation pure 

ponderosa pine. Coniferous tree species are ponderosa pine, grand fir, Douglas-fir, western larch, 

Englemann spruce, subalpine fir, and lodgepole pine. Deciduous tree species include quaking aspen and 

black cottonwood. The majority of the forested stands have a dense multistory stand structure. 

Major human influences have included timber management, fire suppression and domestic livestock 

grazing. The project area has seen vegetation management activity in the past, with the most recent being 

connected to three large vegetation management projects: Little Eagle, Eagle-Holcomb and Eagle-Paddy 

projects. These past actions included timber harvest, non-commercial thinning and fuels treatments 

including hand and machine piling, aspen restoration and prescribed fire, and were completed in the late 

1990s. The Eagle Valley, Goose Creek livestock grazing allotments are within the project boundary, and 

portions of Trouble Gulch, Boulder Creek, and Sheep Rock allotments are within the boundary as well. 

Currently all allotments with the exception of Sheep Rock are active.

The major influences on this area over the last 100 years are selective removal of large diameter high 

value trees beginning around 1900, fire exclusion, and selective cutting prescriptions over the last several 

decades in the true fir-dominated stands. Early logging removed the majority of the original pine forest 

and left grand fir. The reduction of pine seed sources and exclusion of fire created ideal conditions for 

establishment and proliferation of grand fir and Douglas-fir, which then became established and grew 

during the relatively warm and wet early half of the 20th century. The increases in host tree species for 

defoliating insects and root and stem disease and increase in dwarf mistletoe are now major factors in 

stand health. Most of the stands in the project area are overstocked, have uncharacteristic species 

composition and stand structure making them high risk for uncharacteristic disturbance. All of the project 

area has missed several fire cycles, severely departing from the historic fire-return intervals. 

Timber harvest in the planning area has removed most of the large ponderosa pine and western larch. It is 

estimated that approximately 94 percent of the planning area has had previous partial cutting, with 

approximately another 6 percent having been regenerated. This area has been intensively utilized for 

wood products since settlement (mid 1800s). Sheep and cattle grazing also began about this time. This 

area was originally part of the Wallowa Forest Reserve, 1906, moving to the Imnaha Forest Reserve 

(1907), to the Wallowa National Forest in 1908, to the Minam National Forest in 1911, to the Whitman 

National Forest in 1920, and finally the Wallowa-Whitman National Forest, 1954. Organized federal fire 

suppression began with the advent of the forest service including a system of lookout towers, guard 

stations, and fire trails. The Forest Service began selling wood products, early on, to meet local needs.

Organized timber management began in the mid-1940s to support the war effort. Past harvest treatments 

have included salvage, overstory removal, final removal, regeneration, and commercial thinning. Past 

logging has been accomplished using helicopter, tractor, and skyline systems. Noncommercial thinning 

has occurred on several hundred acres. The majority of which has occurred since 1980. Reforestation 

activities (tree planting, site preparation, and animal control) occurred from the 1950s to the present. All 

tree plantations are fully stocked many of which have been non-commercially thinned.

Wildfire History

There have been many past wildfires resulting from lightning. However, due to effective fire suppression, 

there has been one just recorded large fire in the area. Of the 82 fires that occurred within the analysis 

area 80% were caused by lightning, and 20% were human caused, primarily unattended camp/warming 

fires. With aggressive initial attack efforts 90 percent of all fire starts are kept small (< .25 acre). There 

has been one large fire greater than 100 acres within the analysis area from 1970-2007, the Eagle Fire in 

1984. This fire was a high severity, stand replacing event. Fire suppression has allowed the establishment 

and dominance of grand fir in the warm/dry grand fir type, where ponderosa pine was historically 
Chapter 3 Snow Basin Vegetation Management Project FEIS

53

naturally maintained as the dominant species by frequent low-severity fires. Immature grand fir have filed 

in the growing space, created multistory conditions and persisted during the fire exclusion period.

Recreation Use

To the north of the Snow Basin project area, the Eagle Cap Wilderness provides a wide variety of 

recreational opportunities. Recreational use begins as soon as the snow melts and continues into the late 

fall hunting seasons. A large portion of the visitors are from the local area, although some visitors come 

great distances to recreate in the Eagle Creek drainage, drawn by the exceptional scenery, excellent 

fishing, clean water, and the broad range of recreational opportunities available. Primary activities 

recreationists engage in are fishing, hunting, camping, sightseeing, hiking and picnicking. Dispersed 

camping associated with fishing, hunting and prospecting is very popular evidenced by the numerous 

dispersed camp sites within the roaded corridors of the project area. Other less pursued activities include 

horseback riding, photography, nature study, swimming, wildlife viewing, berry and mushroom picking, 

and various winter sports such as cross country skiing and snowmobiling. The Main Eagle Trailhead is a 

major south side access route into the Eagle Cap Wilderness providing opportunities for solitude and 

primitive recreation experiences in a Wilderness setting. Hazardous whitewater waterfalls and low 

seasonal flows preclude floating or kayaking opportunities on Eagle Creek proper. All of Eagle Creek on 

the National Forest is accessible by either gravel road or trail. Good quality gravel roads parallel the 

recreational segments of the river. The unroaded six-mile scenic segment of Eagle Creek is accessed by 

the Martin Bridge Trail, providing anglers, hikers and hunters access from early spring to late fall. During 

the winter, groomed snowmobile trails run the length of the main river road along with several other 

tributary routes. Recreational developments include Eagle Forks Campground and Martin Bridge 

trailhead to access the Martin Bridge Trail located up Eagle Creek.

Chapter 3 Guide to Resource Section Discussions

A detailed discussion of the existing condition and the effects of the alternatives on each resource area are 

presented below in Chapter 3.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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FORESTED VEGETATION

For more detail on the forested vegetation aspects of this project, please refer to the forested vegetation 

specialist report located in the project file.

Existing Conditions

The following discussion of existing vegetation conditions reflects the aggregate impact of all prior 

human actions and natural events that have affected the environment within this project area.

The forests of the Snow Basin project area today consists of mixed tree species stands intermixed with 

natural openings of various sizes. Major tree species present are Douglas-fir, grand fir, ponderosa pine, 

and western larch. Existing forested vegetation will be described by biophysical environment, species 

composition, structure, and density.

The major influences on vegetation within this planning area over the last 100 years are fire exclusion and 

selective cutting harvest practices of early seral ponderosa pine. Early harvesting activities in the true fir 

plant association types removed much of the original ponderosa pine that dominated or co-dominated 

these stands, and left grand fir. The reduction of pine seed sources and exclusion of fire created ideal 

conditions for establishment and proliferation of grand fir, as well as, Douglas-fir, which became 

established and grew during the relatively warm and wet early half of the 20th century. The increases in 

fir species support conditions for elevated levels of defoliating insects, root and stem disease and dwarf 

mistletoe and are currently major factors in decreased stand health and loss of resiliency to disturbances. 

Past timber harvest often targeted the large old trees of high value, resulting in stands of late and old 

structure being well below historical levels. 

Vegetation Management History

In the cool and warm/dry grand fir plant association types, past harvest accelerated the succession towards 

late seral pure grand fir. Approximately 94 percent of the planning area has had previous partial cutting, 

with approximately another 6 percent of the area having been regenerated. Past harvest treatments 

included salvage, over-story removal, final removal, regeneration, and commercial thinning. Past logging 

was accomplished using helicopter, tractor, and skyline systems. Noncommercial thinning occurred on 

several hundred acres, the majority of which occurred since 1980. Reforestation activities (tree planting, 

site preparation, and animal control) occurred from the 1950s to the present. 

Fire suppression

Fire suppression allowed the establishment and dominance of grand fir in the warm/dry grand fir 

vegetation type. Ponderosa pine was maintained historically as a major species through frequent lowseverity fires that thinned the understories of these stands and controlled establishment of trees. Frequent 

fire also increased the competitive advantage of ponderosa pine in these stands. Conversely fire exclusion 

allowed immature grand fir to have a competitive advantage and developed in the understories of stands 

and eventually created multistory conditions. True fir dominated, multi-storied stand conditions have 

persisted to today. 

Ponderosa pine was also historically maintained as the dominant species by frequent low-severity fires in 

the warm/moist Douglas-fir and warm/dry Douglas-fir types. Douglas-fir did not increase to the extent of 

grand fir under similar conditions in the warm/dry grand fir vegetation types. Multistory conditions have 

increased during the decades of fire exclusion and are present today in levels that are considered above 

the range of reference conditions considered ‘resilient’ for this landscape. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

55

Wildfire history

There have been many wildfires in the past as a result of lightning within this project area. Due to 

effective fire suppression, there have been just two recorded large fires in the area. The first of these 

recorded fires in 1910 covered a majority of the project area. The effects of the 1910 fire are unclear due 

to stand management from then to now; however, it is clear that trees that pre-date the fire exist 

throughout the planning area. The second recorded fire, the Eagle Fire in 1984 burned approximately 100 

acres which resulted in 53 acres of stand replacement conditions. These burned acres are within the 

warm/dry grand fir vegetation type and have been reforested to ponderosa pine. Today, this area is fully 

stocked with saplings. The Eagle Fire is located on the south facing breaks of Eagle Creek at T. 07 S., R. 

44. E. Section 35.

Biophysical Environments

Biophysical environments (Johnson C. G., 1993) are aggregations of plant associations (Johnson C. G., 

1987) based on moisture and temperature regimes. Table 12 describes the current state of forested 

vegetation according to biophysical groupings and the acres of each condition within the planning area. 

The biophysical group map below displays how these areas are distributed on the Snow Basin landscape. 

Hot/dry ponderosa pine and hot/moist ponderosa pine comprise less than one percent of the planning area 

and are excluded from further discussion.

Table 12. Vegetation distribution. All NFS lands within the project area boundary.

Biophysical 

Environments

Description Plant Associations % of NFS

forested 

Acre 23,244 

ac.

Cool/ moist/dry 

grand fir

Mid-elevation stands of mixed tree 

species of grand fir, Douglas-fir, 

ponderosa pine, and western larch.

grand fir/big huckleberry 7

Warm/dry grand 

fir

Mid-elevation stands of mixed tree 

species of grand fir, Douglas-fir, 

ponderosa pine, and western larch. 

grand fir/birchleaf spiraea

42

grand fir/pine grass

grand fir/elk sedge

grand fir/rocky mountain maple

grand fir/rocky mountain maple-ninebark

Warm/moist 

Douglas-fir

Low-elevation stands of Douglas-fir and 

ponderosa pine. 

Douglas-fir/mountain snowberry

Douglas-fir/rocky mountain maple- 9

ninebark

Douglas-fir/ninebark

Warm/dry 

Douglasfir/ponderosa 

pine

Low-elevation stands of Douglas-fir and 

ponderosa pine or stands of pure 

ponderosa pine. 

Douglas-fir/spiraea

Douglas-fir/common snowberry 42

Douglas-fir/pine grass

ponderosa pine/common snowberry

Source: GIS query of EVG Vegetation database- 2/24/2012

The dominant vegetation conditions for this project area are represented by the warm/dry Douglasfir/ponderosa pine and the warm/dry grand fir biophysical environments with over 84 percent of the area 

in one of these two groups. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Map. Bio Physical Group Map
Chapter 3 Snow Basin Vegetation Management Project FEIS

57

Species Composition

A Historical Range of Variability (HRV) analysis was completed for species composition of the forest 

vegetation in the planning area. Data is from the Continuous Vegetation Survey (CVS) and was modeled 

with the Vegetation Dynamics Tool (VDDT) (Countryman, 2008). The analysis describes species 

composition as seral stages. Seral Stages were adapted to describe the tree species vegetation in Snow 

Basin. The analysis is a look at how the landscape looked in the past, looking at the extent of the 

landscape and what species of trees were dominant on that landscape. The HRV and existing condition 

are displayed by biophysical environment in Table 16. 

Late seral species are Douglas-fir and grand fir for these plant association groupings, while early seral 

species are ponderosa pine, and western larch. The concept of “seral species” here is probably best 

described in terms of tolerance, to shade, fire, drought, and the relative ability of a species to regenerate 

and establish new plants, and survive in a forested environment.

For example, ponderosa pine and western larch are very intolerant to shading. These species simply do 

not thrive if the crowns are shaded. Grand fir on the other hand is very tolerant to shade, but can also 

thrive in full sunlight. Douglas-fir is considered intermediate in shade tolerance. 

Conversely, grand fir is generally intolerant of repeated fire, whereas, ponderosa pine and western larch 

are much more tolerant of fire. Again, Douglas-fir is intermediate in tolerance to fire. 

Ponderosa pine and western larch establish best following a disturbance where there is some level of bare 

mineral soil, or less organic matter as well as light, such as is the case following fire or logging. These 

species do not regenerate well in forest environments that have deep organic layers on the soil, and are at 

moderate to high density forest, or highly shaded, characteristics of forests that have not had a disturbance 

for long periods of time. Grand fir on the other hand establishes and thrives in open or shaded, bare 

mineral soil or deep organic layers. 

Due to the differences in tolerance to environmental factors, and in the absence of disturbance on sites 

considered “Grand fir sites” above, grand fir will eventually succeed to dominance. Likewise, on 

Douglas-fir sites, Douglas-fir will eventually become the dominant species. The succession of grand fir 

and Douglas-fir would result in ponderosa pine and western larch disappearing, or becoming very minor 

components of the ecosystem. Due to the long history of disturbance on the landscape, particularly fire, 

this has not occurred prior to human intervention. The primary form of human intervention has been fire 

suppression.

In an environment of high frequency disturbance, primarily fire, ponderosa pine and western larch

frequently have a competitive advantage over grand-fir and to some extent Douglas-fir. This is why the 

forests of the Blue Mountains were extensively dominated by ponderosa pine before European settlement.

Early seral species, in this context ponderosa pine, western larch, and Douglas-fir on some sites, are able 

to form stable, long lasting, large tree dominated stands referred to as Late and Old Structure (LOS). 

Historically on these sites frequent disturbance, usually fire, prevented the succession to grand fir.

The species composition analysis below is a way to look at the landscape and determine if it is out of 

balance.

Description of seral species class of dominant species

• Early seral class- dominance of shade intolerant species (western larch/ponderosa pine)

• Mid seral class- shade tolerant species (Douglas-fir/grand fir) are increasing and are approaching 

equal proportions with shade intolerant species (western larch/ponderosa pine)
Chapter 3 Snow Basin Vegetation Management Project FEIS

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• Late seral class- shade tolerant species (Douglas-fir/grand fir) are dominate, shade intolerant 

species (western larch/ponderosa pine) may still be present in low numbers

The information gathered from CVS data, silviculture field reconnaissance and stand exams is 

summarized below and suggests that Warm/dry grand fir, Warm/moist Douglas-fir, and Warm/dry 

Douglas-fir-ponderosa pine biophysical environments are currently below HRV reference conditions for 

early seral species of ponderosa pine and western larch and above HRV reference conditions for late seral 

species of grand fir and Douglas-fir. More detailed stand exam analysis and field verification suggests 

that the CVS data may be under estimating the late seral stages. The CVS data also suggests that 

cool/moist/dry grand fir is within HRV reference conditions for each seral stage. More detailed stand 

exam analysis and field verification supports these numbers in the cool/moist/dry grand fir biophysical 

environment. 

Table 13. HRV analysis for species composition (Percent).

Seral Stage Cool/moist/dry 

grand fir

Warm/dry grand 

fir

Warm/moist 

Douglas-fir

Warm/dry Douglasfir-ponderosa pine

HRV Existing HRV Existing HRV Existing HRV Existing

Early Class 30-60 42 75-90 36 75-90 39 75-90 67

Mid Class 20-40 23 0 8 0 10 0 0

Late Class 10-30 35 5-20 53 5-20 50 5-20 33

Source: CVS data from vegetation dynamics tool (VDDT) (Countryman, 2008).

Table 13 is showing that the planning area has far more of the landscape now in forest dominated by 

grand fir and Douglas-fir than thought to exist historically. In contrast, the landscape has much fewer 

acres in forest composed primarily of ponderosa pine and western larch.

This result can be compared to a similar analysis found in, “An Assessment of Ecosystem Components in 

the Interior Columbia Basin and Portions of the Klamath and Great Basin” (Quigley and Arbelbide, 

1997). For the Blue Mountains Ecological Reporting Unit (ERU), the dry Potential Vegetation Group, 

shows this same shift on the larger landscape. For example “Late Seral Shade intolerant Single-layer 

Forest” was estimated in 1997 to be one percent of the landscape, while historically it was estimated to 

occupy between 35 to 52 percent of the landscape. This percentage includes all of the Blue Mountains 

ERU in federal ownership. The Snow Basin project area being 84 percent Warm/Dry or Warm/Moist sites 

would be expected to have a higher percentage.

Forest Structure

An HRV analysis was used to evaluate forest structure for the Snow Basin planning area. Table 14

displays the abundance of current forested stand structures.

The stand structure descriptions below depict the physical structure of stands in terms of tree size, age and 

to some extent density. This description does lack a species composition dimension, and the density 

element is dependent on species composition. Stand Initiation (SI) can be thought of as an early or young 

stand of smaller trees. 

Stand Initiation (SI) would be most representative of a new stand following a major disturbance which 

removed or killed much of the pre-existing stand. Stem Exclusion (SE), the point where density prevents 

further seedling establishment, Understory Re-initiation (UR), the point in development where SE stands 

have developed to where seedlings are again able to establish themselves due to disturbance events, or 

mortality associated with high density, or a combination. Multi-story large trees uncommon (MSLTU), is 

where after understory re-initiation stands have developed distinct layers or strata. Together, SE, UR and 

MSLTU can be thought of as the mid-age structures. Multistory Large Trees Common (MSLT) and 
Chapter 3 Snow Basin Vegetation Management Project FEIS

59

Single Story Large Trees Common are the Late and Old Structural stages, or less precisely, referred to as 

old growth forest.

Table 14. Existing forest structural stages (23,306 acres classified)

Code Structure Stage Acres Percent of Total 

Forested area

SI

Stand Initiation

1,442 6

SEOC

Stem Exclusion Open 

Canopy 2,210 9

SECC

Stem Exclusion Closed 

Canopy 2,953 13

UR Understory Re-initiation8,675 37

MSLTU

Multistory Large Trees 

Uncommon 3,676 16

MSLT

Multistory Large Trees 

Common 3,428 15

SSLT Single Story Large Trees 

Common 923 4

Sources/Notes: Summarized from the vegetation database. Forest structural stages are described in O‘Hara et al. 

(O'Hara, Latham, Hessburg, & Smith, 1996). Structural stage, a derived, field in the database was calculated using 

WWNF structural stage model. 

Table 14 summarizes existing structural stages for forest vegetation in the Snow Basin planning area. It 

shows that the predominant forest surplus structural stage is understory re-initiation (37 percent) and the 

predominant deficit stage is single story large trees common (4 percent).

Reference conditions (HRV) are compared to existing forest structure and the results are provided in 

Table 15 which summarizes each forest structural stage by biophysical group. The historical range is also 

shown. The shaded fields are outside the range of historical reference conditions, or HRV. 

Table 15. Historic range of variability- forest structure

Includes all NFS lands in the planning area

Cool/moist/dry grand 

fir

Warm/dry grand fir Warm/moist 

Douglas-fir

Warm/Dry Douglasfir/Ponderosa pine

Stage Historical 

Range

Current 

Amount

Historical 

Range

Current 

Amount

Historical 

Range

Current 

Amount

Historical 

Range

Current 

Amount

% % Acres % % Acres % % Acres % % Acres

SI 1-10 9 152 1-15 8 811 1-15 4 89 1-15 4 364

SEOC 0-0 0 0 5-20 5 442 5-20 8 172 5-20 16 1,563

SECC 1-10 11 191 1-10 14 1,375 1-10 15 328 1-10 11 1,085

UR 5-25 38 645 1-10 42 3,961 1-10 47 1,011 1-10 33 3,040

MSLTU 20-50 25 415 5-25 19 1,800 10-30 4 93 5-25 12 1,198

MSLT 30-60 17 278 5-25 10 970 10-30 15 324 5-25 19 1,834

SSLT 0-0 0 0 15-55 2 230 15-55 7 144 15-55 5 460
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Source: GIS Query EVG Bio Phys Struct Stage Summary- 2/26/2012). (O'Hara, Latham, Hessburg, & Smith, 1996).

The information summarized in Table 19 indicates that the significant departures from HRV are:

• SI or early age structures are below the historical range in cool/moist/dry grand fir

• SECC and UR or mid-age stages are higher than the historical range in all biophysical 

environments

• MSLTU is less than HRV in warm/moist Douglas-fir MLST is under HRV in cool/moist/dry 

grand fir

• SSLT, the dominant Late and Old structure of the past, is less than HRV in all the biophysical 

environments in which it occurs

• MLST is less than the HRV in cool/moist/dry grand fir biophysical group

Recent bioregional assessments concluded that dry forest areas have vegetation that is out of balance 

when compared to historical conditions (Lehmkuhl, Hessburg, Everett, Huff, & Ottmar, 1994) (Hessburg, 

Smith, & Kreiter, 1999) (Quigley & Arbelbide, 1997). The data suggests that this landscape is out of 

balance in that there is too much of the landscape in mid-age stands and not enough in Late and Old 

stands, with the LOS deficit particularly acute in the SSLT structure. 

Tree Density

Suggested stocking guidelines (Cochran et al. 1994) were used to analyze existing tree density levels for 

the Snow Basin planning area. By using the stocking guidelines in conjunction with biophysical 

environments, it was possible to estimate how much forest acreage is currently overstocked. Density 

Classes used in this analysis are: Open - within or below the recommended management zone of SDI; and 

Closed - greater than the upper management zone of SDI (Countryman, 2008) (Powell D. C., 2009).

Results of the tree density analysis are summarized in Table 16. It shows the Snow Basin planning area 

has about 40 percent in Open Density and 60 percent in Closed.

Table16. Existing tree density in the Snow Basin planning area (Percent)

Vegetation 

Cover 

Type

Cool/moist/dry grand 

fir

Warm/dry grand fir Warm/moist DouglasfirWarm/dry Douglasfir-ponderosa pine

HRV Existing HRV Existing HRV Existing HRV Existing

Open 20-70 47 15-85 38 15-85 38 15-85 38

Closed 15-30 53 5-15 62 5-15 62 5-15 62

Source: GIS Query of CVS data resulting in EVG Veg Density Summary Tables – 02282012.xls (Countryman, 2008)

(Powell D. C., 2010)

This analysis indicates that high-density forest is much higher than was historically present, with the 

departure very high in the warm plant associations.

Quaking Aspen (Populus tremuloides)

Quaking aspen occurs throughout the project area in relatively small stands. These stands have varying 

degrees of declining health due to conifer invasion, lack of fire that promotes aspen regeneration, and 

browsing by ungulates. Similar declines in the abundance of aspen have occurred throughout the western 

states by 60 percent from historical level (Bartos, 2001). Most competition from conifers comes from 

trees less than 90 years of age coinciding with fire exclusion activities. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

61

Defoliating insects

Principal defoliators in the Snow Basin planning area are Spruce Budworm (SPBW) and Douglas-fir 

Tussock Moth (DFTM). Conditions favoring these species are directly related to; host species, multi-story 

structure, tree density (Stoszek, Mika, Moore, & Oorne., 1981) (Wulf & Cates, 1987) (Kegley, 

Livingston, & Gibson, 1997). The Snow Basin planning area has shown susceptibility to defoliators in the 

recent past with Spruce Budworm and Douglas-fir Tussock Moth defoliation in late 1980s to early 1990s 

and Douglas-fir Tussock Moth defoliation in the late 1990s to early 2000s. Both outbreaks were treated 

with insecticides as part of larger region wide suppression projects. 

Host species- The data in Table 13 suggests that the stands dominated by grand fir and Douglas-fir, the 

primary hosts for SPBW and DFTM are above HRV for all biophysical environments indicating that this 

portion of high defoliator susceptibility is above HRV. 

Multi-story structure- The data in Table 14 suggests that Understory Re-initiation is above HRV in all 

biophysical environments indicating that this portion of defoliator susceptibility is above HRV. While not 

above HRV, MSLTU and MSLT, both multi-strata, would also be high risk to these defoliaters, creating 

an additive risk along with the UR structures. 

Tree density- The data in Table 16 suggests that Closed density is above HRV in all biophysical 

environments indicating that this portion of defoliator susceptibility is above HRV.

Adding the factors together: stands dominated by host species, in multi-strata structures at high densities, 

this planning area has a significant potential for large scale defoliator outbreaks.

Bark beetles

Principal bark beetles in the Snow Basin planning area are Western Pine, Pine Engraver, Douglas-fir 

beetle, and Fir Engraver. Conditions favoring these species are directly related to an abundance of host 

species, multi-story structure stand conditions and high stand densities (Miller & Keen, 1960) (Berryman 

& Ferrell, 1988) (Wright & Lejeune, 1967). Vegetation types within this project area have shown 

susceptibility to a variety of insect outbreaks in the recent past such as the Pine Engraver outbreak in 1989 

which resulted in the salvage of 1 million board feet of ponderosa pine. In addition, there are currently 

elevated observations of ponderosa pine mortality from Western Pine Beetle, as would be predicted from 

high stand densities.

A Douglas-fir beetle outbreak occurred beginning in 1998 in the Snow Basin area. This past outbreak of 

Douglas-fir beetle coupled with the current outbreak in the adjacent East Eagle drainage emphasizes 

current stand conditions with an abundance of host species will likely continue to support beetle 

outbreaks.

Susceptibility to bark beetles will be analyzed using these factors:

• Host species (Indicated by Late and Mid seral stages) 

o Douglas-fir beetle- Douglas-fir

o Fir Engraver beetle- grand fir

o Western Pine and Pine Engraver beetles- ponderosa pine.

• Multi-story structure (MSLTU, UR, MSLT)

• Tree density (Indicated by Closed Density)

The warm/moist Douglas-fir and warm/dry Douglas-fir-ponderosa pine biophysical environments are 

most susceptible to Western Pine and Pine Engraver beetles while the cool/moist/dry and warm/dry grand 

fir biophysical environments are most susceptible to Douglas-fir beetle and Fir engraver.
Chapter 3 Snow Basin Vegetation Management Project FEIS

62

Host species- The data in Table 13 suggests that the stands dominated by grand fir and Douglas-fir are 

above HRV indicating that bark beetle susceptibility is also above HRV for Douglas-fir and Fir Engraver 

beetles. 

Tree density- The data in Table 16 suggests that Closed density is above HRV indicating that this portion 

of bark beetle susceptibility is above HRV.

Bark beetle risk is very high in this planning area, given that densities and structures in stands containing 

host species generally far outside the HRV.

Consistency with Laws, Regulations, and Policy

NFMA Consistency - The National Forest Management Act (NFMA) and the implementing regulations 

require specific findings to be made when implementing the Forest Plan. Those findings include the 

following.

Suitability for Timber Production

Proposed harvest units have been field reviewed by a certified silviculturist who determined these units 

are located on suitable land as identified in the Wallowa-Whitman NF Land and Resource Management 

Plan (Forest Plan). A suitability analysis was performed during the Forest Plan analysis with suitable 

timber production areas identified and mapped. The proposed harvest treatments fall within areas 

identified as suitable for timber production.

Regeneration Harvest and Even-Aged Management

No Regeneration harvest is proposed.

Green Tree Replacements (GTRs)

GTRs are trees that will be available to become snags through time. Snags can occur through natural 

mortality or can be created. Natural mortality occurs by competition, lightning strike, disease, insects, or 

wildfire. Induced mortality can occur through mechanical means or by using prescribed fire. All 

silviculture treatments being proposed would remove only a percentage of the existing trees leaving 

stands that are fully stocked or above the lower limit of the stand’s management zone as determined by 

plant associations. 

Vegetative Manipulation

NFMA provides that timber harvest and other silvicultural practices shall be used to prevent damaging 

population increases of forest pest organisms, and treatments shall not make stands susceptible to pestcaused damage at levels inconsistent with management objectives. Harvest of trees provides social and 

economic benefit, reduces potential losses attributed to insects and diseases, and manipulates forest 

vegetation to enhance wildlife habitat and/or meet associate objectives. The silvicultural prescription 

which directs the vegetative management process is designed to meet Forest Plan goals, objectives, and 

guidelines for forest productivity and wildlife habitat improvement while achieving ecosystem-based 

management. 

Harvest, non-commercial thinning, and prescribed fire are proposed for some stands in order to improve 

tree vigor in desired leave trees and to maintain or enhance plant diversity in grass, forbs and shrubs. 

NFMA provides for these treatments where they increase the growth rate of residual trees, favor 

commercially valuable species, favor species valuable to wildlife, or achieve some other multiple-use 

objective.
Chapter 3 Snow Basin Vegetation Management Project FEIS

63

Regeneration Potential

No regeneration treatments are proposed. 

Standards and Guidelines

All proposed treatments in Alternative 4 are consistent with Forest Plan standards and meet or exceed the 

standards and guidelines for vegetative management and timber management. Alternatives 2 and 3 

include forest plan amendments for the harvest of 21+ trees and management of Late and Old Structure 

stands. See chapter 2 of this FEIS for a full description of forest plan amendments. 

On August 18, 1993, the Regional Forester for the USDA Forest Service, Region 6 issued direction to 

screen timber sales to ensure that all sales are consistent with the National Forest Management Act 

viability requirements for old growth-associated species (Lowe, 1993). That direction was modified and 

extended on May 20, 1994 (Lowe, 1994) and further modified in 1995 (USDA Forest Service 1995a). 

The 1995 document amended the Wallowa-Whitman National Forest Land and Resource Management 

Plan (Forest Plan). That current direction, often referred to as the “Screens,” includes specific direction to 

pass each timber sale proposal through a set of interim ecosystem and wildlife standards. 

The following section describes how the timber sale activities proposed in the Snow Basin Environmental 

Impact Statement (EIS) complies with the Screens. In the following table, the left hand column displays 

specific direction from the Forest Plan and Screens. The column on the right describes how the Snow 

Basin EIS addresses that direction.

Table 17. Management Standards and Guidelines

Standard and Guideline Snow Basin

WWNF L&RMP/EIS

Management Areas 1, 1W, and 3.

Diversity. Provide and maintain an ecologically sound distribution 

and abundance of plant and animal communities and species... (FP 

4-30).

Snow Basin maintains and enhances tree, 

shrub, forb, and grass diversity across all 

biophysical environments by thinning the 

tree canopy, burning, and protecting western 

larch and ponderosa pine, restoring quaking 

aspen. Restoring quaking aspen also 

increases the diversity of forb and grass 

species commonly found beneath aspen 

stands. Opening the canopy would improve 

shrub, forb, and grass diversity and 

abundance at the forest floor.

Prescribed fire. In meeting the total resource objectives of forest 

management, the role and potential of fire as an integral part of the 

forest and rangeland will be considered where it furthers the 

management objectives... (FP 4-37)

Snow Basin would introduce fire over a large 

portion of the landscape. Fire objectives are 

to: improve forage, manage seedling and 

sapling sized trees where appropriate, 

reduce live and dead fuels, protect private 

land and forest developments, and improve 

public and fire fighter safety. 

Timber. Select silvicultural systems which will, to the extent possible 

and within the intent of the land, management objectives. (FP 4-48)

Timber. Permit the production of a volume of marketable trees 

sufficient to utilize all trees that meet utilization standards and are 

designated for harvest. (FP 4-48).

Alternatives 2/3/4 would produce wood 

products. Utilization would meet the 

maximum allowable based upon economic 

conditions at that time.

Timber. Promote a stand structure and species composition that 

minimizes serious risk of damage by mammals, insects, disease, or 

wildfire, and will allow treatment of existing insect, disease, or fuel 

Snow Basin prescriptions would improve 

stand structure, density, and species 

composition. They are designed to reduce 
Chapter 3 Snow Basin Vegetation Management Project FEIS

64

conditions. (FP 4-48) susceptibility to uncharacteristic disturbance 

including; insects, disease, and fire.

Timber. Be capable of achieving management objectives such as 

those for streamside protection, wildlife needs, and visual resources. 

(FP 4-49)

Snow Basin prescriptions would adhere to 

the Riparian Habitat Conservation Areas as 

described by INFISH, except where a site 

specific analysis would allow treatment and 

haul in portions of RHCAs facilitating 

treatment of an adjacent upland unit. 

Prescriptions meet the Visual Quality 

Objectives for the area. Prescriptions 

maintain current snags and large down logs, 

except for snags that pose a safety hazard 

to the public or forest workers. Prescriptions 

maintain habitat connectivity and sufficient 

green tree replacements to supply future 

snags and down logs (see Wildlife Report).

Timber. Any harvests which reduce stocking below the minimum crop 

tree stocking level will be considered a regeneration harvest. They 

will, therefore, require provisions for establishing new stands ......(FP 

4-50)

Regeneration harvest is not proposed.

Management Area 1. Even-aged management will normally be 

employed with tree spacing maintained to permit optimum growth 

towards the desired tree size. (FP 4 - 57)

Even-aged prescriptions are proposed. 

Growth would be improved by reducing 

current densities to within the 

Recommended Management Zone of SDI. 

Improved radial growth would accelerate 

development of LOS and target tree size of 

21” DBH average stand diameter over much 

of the area. 

Management Area 1. Tree spacings permit optimum growth towards 

the production of wood, consistent with other resource objectives. (FP 

4-57)

Growth would be improved by reducing 

current densities. Stands would be 

prescribed to within the Recommended 

Management Zone of SDI. 

Eagle Creek Wild and Scenic River Management Plan (Richmond).

Snow Basin intersects the Scenic and Trailed Recreational portions of 

Eagle Creek Wild and Scenic Corridor (ECW&S).

Landscape Management. 25. Manage visual resources to meet the 

following visual quality objectives...(Pg. 13)

Scenic- Retention

Recreational – Retention

Harvest units within the ECW&S meet 

Retention Visual Quality Objective (see 

Scenery Report). 

Vegetation Management. 59. Prescribed fire will generally be the 

favored tool to meet vegetation management objectives. Emphasis 

will be to perpetuate old growth and other late seral forested stands, 

large trees, and visually desirable species such as larch, ponderosa 

pine, and hardwoods (pg 16).

Prescribed fire within the ECW&S would 

pose a high risk of high intensity fire due to 

steep slopes, multi-story ladder fuel 

conditions, a continuous canopy of trees, 

and high fuel levels. Snow Basin would 

manage these elements using harvest and 

non-commercial thinning followed by 

prescribed fire. These prescriptions would 

maintain ponderosa pine and western larch 

especially those of large size. The 

prescriptions would result in the following:

1. Thinning would make larch and 

ponderosa pine more visually evident.

2. Old trees would not be harvested.

3. Thinning would increase tree diameter 

growth increasing the number of large trees 
Chapter 3 Snow Basin Vegetation Management Project FEIS

65

over time.

4. Current LOS would not be reduced.

5. Thinning would improve the ability to 

apply low intensity prescribed fire in the 

future (see fire/fuels report).

6. Thinning would reduce susceptibility to 

high severity wildfire (see fire/fuels report).

7. Favoring ponderosa pine and larch would 

reduce susceptibility to Spruce budworm 

and Douglas-fir Tussock Moth.

Vegetation Management. 61. Snags and other potential large woody 

debris would be protected.

Snags that pose a hazard to the public or

forest workers would be felled. 

The loss of dead trees and large down logs 

would be minimized:

1. Dead trees and large down logs would not

be removed for wood products. 

2. During prescribed fire, the burn 

prescription would minimize damage to 

snags and down logs. 

3. Desirable old growth trees would have 

fuels reduced around their base to minimize 

scorch and mortality. 

4. Burning prescriptions allow for 10% 

mortality in overstory trees providing future 

snags and down logs. 

Vegetation Management. 64. In the Wild River section and the trailed 

Recreational River segment no commercial timber harvest will occur.

Harvest would not occur in the Wild River 

segment under any alternative. Harvest 

would occur in the Trailed Recreational 

River segment in Alternatives 2/3. Harvest 

would not occur in this segment under 

Alternative 4. 

Vegetation Management. 66. Uneven-aged management will be the 

preferred and most commonly used silviculture system; even-aged 

management techniques may also be used to meet objectives (pg.

17)

Desirable trees of all sizes would be 

maintained giving an irregular appearance. 

Even-aged management would better 

improve stand resiliency given the existing 

stand conditions of closed density, late seral 

and multi-story structure. No regeneration 

harvest is proposed within the ECW&S. 

Vegetation Management. 67. Timber within the roaded Recreational 

and Scenic segments would remain in the regulated timber base (pg.

17)

Harvest would occur in these segments 

under alternative 2/3/4.

Vegetation Management. 72. Old Growth (pg. 17). Forest plan old growth (MA 15) is not 

proposed for treatment under any action 

alternative. The prescriptions are designed 

to maintain, protect, and enhance individual 

and groves of old growth trees in the MA7 

treatment units. Density reduction, favoring 

early seral species composition, and 

reducing ladder fuels would maintain and 

enhance old growth characteristics by;

Favoring fire and defoliator resistant 

tree species (ponderosa pine and larch)

Increasing average stand diameter
Chapter 3 Snow Basin Vegetation Management Project FEIS

66

Increasing diameter growth increasing 

the rate of large tree recruitment

Creating stand structure resistant to 

high severity fire

Insects and Disease. 103. Use integrated pest management 

principals and methods. (pg. 22)

1. Areas proposed for treatment would have 

reduced susceptibility to defoliating insects 

by reducing host species. 

2. Density management would reduce 

susceptibility to Western Pine Bark Beetles. 

3. Areas of Douglas-fir dwarf mistletoe 

would be reduced by favoring other tree 

species. 

East Side Screens. Wildlife Standards.

The interim wildlife standard has two possible scenarios to follow 

based on the Historical Range of Variability (HRV) for each 

biophysical environment within a given watershed. For the purposes 

of this standard, late and old structural stages (LOS) can be either 

"Multi-strata with Large Trees" (MSLT), or "Single Strata with Large 

Trees" (SSLT), as described in Table 1 of the Ecosystem Standard. 

These LOS stages can occur separately or in some cases, both may 

occur within a given biophysical environment. LOS stages are 

calculated separately in the interim ecosystem standard. Use 

Scenario A whenever anyone type of LOS is below HRV. If both types 

occur within a single biophysical environment and one is above HRV 

and one below, use Scenario A. Only use Scenario B when both LOS 

stages within a particular biophysical environment are at or above 

HRV.

Snow Basin falls within Scenario A. For the 

purpose of calculating HRV, all effect

analyses were calculated for the National 

Forest lands in the planning area within the 

Little Eagle Creek and Eagle Creek/Paddy 

Creek subwatersheds, by biophysical 

environment.

In dry forest biophysical environments, 

warm/dry grand fir, warm/moist Douglas-fir, 

and warm/dry Douglas-fir-ponderosa pine, 

SSLT was below the lower limit of HRV and 

MSLT was above the lower limit of HRV. 

Because SSLT is below HRV, these 

biophysical environments fall within 

Scenario A.

In the moist forest biophysical environment, 

cool/moist/dry grand fir, MSLT was below 

the lower limit of HRV. SSLT did not occur in 

this BPE. Because MSLT is below HRV, this 

biophysical environment falls within 

Scenario A.

a. The following types of sales will not be subject to the interim 

standards: personal use firewood sales; post and post sales; sales to 

protect health and safety; and sales to modify vegetation within 

recreation special use areas.

b. The following sale types were exempted from consideration of HRV 

through the interim ecosystem standard, but must still meet the intent 

of the wildlife standards by following the direction provided in 

Scenario A, 1) through 4) as applicable to the type of sale being

proposed, and regardless of whether the stand is LOS or not: pre

commercial thinning sales, sales of material sold as fiber, sales of 

dead material less than sawlog size (7-inch DBH) with incidental 

green volume, salvage sales with incidental green volume located 

outside currently mapped old growth, commercial thinning and/or 

understory removal sales located outside currently mapped old 

growth.

An HRV analysis has been completed for 

the Snow Basin Analysis Area. The HRV 

analysis is included in the analysis file for 

the project, and is summarized in the EIS.

Scenario A
Chapter 3 Snow Basin Vegetation Management Project FEIS

67

If either one or both of the late and old structural (LOS) stages falls 

BELOW HRV in a particular biophysical environment within a

watershed, then there should be NO NET LOSS OF LOS from that 

biophysical environment. DO NOT allow timber sale harvest activities 

to occur within LOS stages that are BELOW HRV.

During the early planning for this project, 

units recommended for treatment were 

compared with maps of structural classes. 

There would be harvest activities in LOS 

stages that are below HRV: cool grand fir 

MSLT and SSLT in warm grand fir, moist 

Douglas-fir, and warm Douglas-firponderosa pine. These treatments are 

analyzed under Snow Basin FP Amendment 

2 (SB1). There would be a net loss of LOS 

under alternative 2.

1) Some timber sale activities can occur within LOS stages that are 

within or above HRV in a manner to maintain or enhance LOS within 

that biophysical environment. It is allowable to manipulate one type of 

LOS to move stands into the LOS stage that is deficit if this meets 

historical conditions.

Dry forest MSLT is above HRV in the Snow 

Basin

Analysis Area. Many of the units proposed 

for treatment fall within dry forest MSLT 

stands. The proposed treatment for those 

units would move those stands closer to 

OFSS conditions. 

2a) Maintain all remnant late and old seral and/or structural live trees 

>= 21" DBH that currently exist within stands proposed for harvest 

activities.

As described in the EIS, live trees greater 

than or equal to 21 inches DBH would be 

removed based on the removal scenarios 

outlined in the Regional Forester’s 2003 

letter. This letter, titled “Guidance for 

Implementing Eastside Screen” dated 

September 5, 2003, gives five examples of 

situations for which site-specific Forest Plan 

amendments might be appropriate. Forest 

Plan amendments reflected in Alternatives 

2/3 are analyzed in the EIS. 

2b) Manipulate vegetative structure that does not meet late and old 

structural (LOS) conditions, (as described in Table 1 of the 

Ecosystem Standard), in a manner that moves it towards these 

conditions as appropriate to meet HRV.

The prescription for the units outside of LOS 

is thinning. Thinning those stands would 

speed the development of LOS conditions. 

This treatment would cut and remove many 

of the smaller trees within the stands and 

would save the larger, healthier, shade

intolerant trees. The effect would be to move 

the stands toward a single-stratum condition 

and would increase growth on the remaining 

trees so that they would grow to a large size 

more quickly. That combination of effects 

would enhance SSLT components in the dry 

biophysical environment and MSLT in the 

moist biophysical environment.

2c) Maintain open, parklike stand conditions where this condition 

occurred historically. Manipulate vegetation in a manner to encourage 

the development and maintenance of large diameter, open canopy 

structure. (While understory removal is allowed, some amount of 

seedlings, saplings, and poles need to be maintained for the 

development of future stands).

Dry forests in the Snow Basin Analysis Area 

would have historically had a high 

percentage of SSLT stands. SSLT stands 

are often described as “open, park like.” As 

described above, the proposed treatments 

maintain SSLT conditions or move stands 

toward SSLT conditions.

3) Maintain connectivity and reduce fragmentation of LOS stands by 

adhering to the following standards: INTENT STATEMENT: While 

data is still being collected, it is the best understanding of wildlife 

science, today, that wildlife species associated with late and old 

structural conditions, especially those sensitive to "edge,” rely on the 

connectivity of these habitats to allow free movement and interaction 

of adults and dispersal of young. Connectivity corridors do not 

Habitat connectivity was evaluated by 

overlaying maps of LOS stands, old growth 

stands designated by the Wallowa-Whitman 

Forest Plan, Management areas MA15; and 

timber harvest alternatives from the EIS.

During the planning stages of this project, 

stands were identified as connectivity 
Chapter 3 Snow Basin Vegetation Management Project FEIS

68

necessarily meet the same description of "suitable" habitat for 

breeding, but allow free movement between suitable breeding 

habitats. Until a full conservation assessment is completed that 

describes in more detail the movement patterns and needs of various 

species and communities of species in eastside ecosystems, it is 

important to insure that blocks of habitat maintain a high degree of 

connectivity between them, and that blocks of habitat do not become 

fragmented in the short-term.

corridors in the Analysis Area. Minimum 

vegetation requirements for connection 

corridors were considered in identifying 

areas to be thinned. Connectivity corridors 

between old forest habitat blocks and Forest 

Plan designated old growth meet Forest 

Plan standards and project specific project 

design features (PDF) for connectivity (see 

wildlife report).

3a) Maintain or enhance the current level of

connectivity between LOS stands and between all Forest Plan 

designated "old growth/MR" habitats by maintaining stands between 

them that serve the purpose of connection as described below:

(1) Network pattern - LOS stands and MR/Old Growth habitats need 

to be connected with each other inside the watershed as well as to 

like stands in adjacent watersheds in a contiguous network pattern by 

at least 2 different directions.

(2) Connectivity Corridor Stand Description Stands in which medium 

diameter or larger trees are common, and canopy closures are within 

the top one-third of site potential. Stand widths should be at least 400 

ft. wide at their narrowest point. The only exception to stand width is 

when it is impossible to meet 400 feet with current vegetative 

structure, AND these "narrower stands" are the only connections 

available; (use them as last resorts). In the case of lodgepole pine, 

consider medium to large trees as appropriate diameters to this stand 

type. If stands meeting this description are not available in order to 

provide at least 2 different connections for a particular LOS stand or 

MR/Old Growth habitat, leave the next best stands for connections. 

Again, each LOS and MR/Old Growth habitat must be connected at 

least 2 different ways.

(3) Length of Connection Corridors - The length of corridors between 

LOS stands and MR habitats depends on the distance between such 

stands. Length of corridors should be as short as possible.

(4) Harvesting within connectivity corridors is permitted if all the 

criteria in (2) above can be met, and if some amount of understory (if 

any occurs) is left in patches or scattered to assist in supporting tree 

density and cover. Some understory removal, stocking control, or 

salvage may be possible activities, depending on the site.

3b) To reduce fragmentation of LOS stands, or at least not increase it 

from current levels, stands that do not currently meet LOS that are 

located within, or surrounded by, blocks of LOS stands should not be 

considered for even-aged regeneration, or group selection at this 

time. Non-regeneration or single tree selection (UEAM) activities in 

these areas should only

proceed if the prescription moves the stand towards LOS conditions 

as soon as possible.

4) Adhere to the following specific wildlife prescriptions. These 

standards are set at MINIMUM levels of consideration. Follow Forest 

Plan standards and guidelines when they EXCEED the following 

prescriptive levels: a) Snags, Green Tree Replacements and Down 

Logs:
Chapter 3 Snow Basin Vegetation Management Project FEIS

69

INTENT STATEMENT - Most (if not all) wildlife species rely on 

moderate to high levels of snags and down logs for nesting, roosting, 

denning and feeding. Large down logs are a common and important 

component of most old and late structural forests. Past management 

practices have greatly reduced the number of large snags and down 

logs in managed stands.

(1) All sale activities (including intermediate and regeneration harvest 

in both even-age and uneven-age systems, and salvage) will maintain 

snags and green replacement trees of > 21 inches DBH, (or whatever 

is the representative DBH of the overstory layer if it is less than 21 

inches), at 100% potential population levels of primary cavity 

excavators. This should be determined using the best available 

science on species requirements as applied through current snag 

models or other documented procedures. NOTE: for Scenario A, the 

live remnant trees (>=21" DBH) left can be considered for part of the 

green replacement tree requirement.

Under Alternatives 2 through 4, all existing 

snags would be left. Except those that are a 

hazard to the public or forest workers. 

In intermediate harvest, green replacement 

trees will be left at a rate within the 

Recommended Management Zone of SDI. 

In the overstory removal harvest units, green 

replacement trees would be left at least 16 

trees per acre. These trees would range 

from 10” to 36” DBH and consist primarily of 

ponderosa pine and Douglas-fir. 

(2) Pre-activity (currently existing) down logs may be removed only 

when they exceed the quantities listed below. When pre-activity levels 

of down logs are below the quantities listed, do not remove downed 

logging debris that fits within the listed categories. It is not the 

intention of this direction to leave standing trees for future logs in 

addition to the required snag numbers, or to fall merchantable 

material to meet the down log requirements. The snag numbers are 

designed to meet future down log needs in combination with natural 

mortality. Exceptions to meeting the down log requirement can be 

made where fire protection needs for life and property cannot be 

accomplished with this quantity of debris left on site. The down log 

criteria are not intended to preclude the use of prescribed burning as 

an activity fuels modification treatment. Fire prescription parameters 

will ensure that consumption will not exceed 3 inches total (1 1/2 inch 

per side) of diameter reduction in the featured large logs (sizes 

below). Tools such as the CONSUME and FOFEM computer models, 

fire behavior nomograms, and local fire effects documentation can aid 

in diameter reduction estimates.

Leave logs in current lengths; do not cut them into pieces. Longer 

logs may count for multiple "pieces" without cutting them. Cutting 

them may destroy some habitat uses and also cause them to decay 

more rapidly. It is also not expected that the "pieces" left will be 

scattered equally across all acres.

Species PCS/ac Dia. small 

end

PC Length

&Total

Linear Length

Ponderosa 

pine

3 - 6 12” > 6 feet 20 - 40

Mixed

conifer

15 - 20 12” >6 feet 100 –

140 ft

The Snow Basin would not remove existing 

down logs. Prescribed fire prescriptions 

would be conducted with low intensity fire 

when weather conditions would minimize the 

loss of existing large down logs.
Chapter 3 Snow Basin Vegetation Management Project FEIS

70

Methodology and Measurement Indicators

The methodology utilized for this analysis used the Forest’s vegetation database to characterize existing 

vegetation conditions according to forest structural stages as described in O‘Hara et al. (O'Hara, Latham, 

Hessburg, & Smith, 1996). Structural stage is a derived field in the database and was calculated using 

WWNF structural stage model. Vegetation data was validated by completing field reviews from 2008 to 

2012.

Measures used to characterize the environmental consequences of implementing the silvicultural activities 

associated with each of the alternatives: acres by species composition (seral stages), acres of forest 

structural stages (including changes in LOS), and acres of tree density. 

Scale or geographical context 

The geographical context for estimating direct effects is forested National Forest System (NFS) lands 

within the planning area that are proposed for treatment through implementation of an alternative. 

Silvicultural activities described in Alternatives 2, 3, and 4 would directly affect these lands.

The geographical context for estimating indirect effects is suitable forested NFS lands located within the 

planning area. The analysis of indirect effects considers the effects of activities (actions) occurring at a 

different time or place than the action causing an effect. 

The geographical context for estimating cumulative effects is the entire Snow Basin planning area.

Temporal context for effects analysis 

The temporal context for evaluating environmental effects considers past, present, and reasonably foreseeable actions in the Snow Basin planning area as described below. 

Past management actions and natural events have influenced existing conditions in the planning area by 

changing species composition, stand structure and tree density. The field reviews found that existing 

conditions in the planning area appropriately reflect past changes resulting primarily from timber harvest, 

the historical influence of wildfire, insect and disease activity, and fire exclusion. 

There are no present (ongoing) actions occurring affecting vegetation. 

Reasonably foreseeable actions: See Appendix B for a list of reasonably foreseeable actions.

Effects Analysis 

Purpose and Need 1: Manage forest structure, composition and density towards landscape HRV and 

improve sustainability.

Key Indicators

1. Acres of non LOS Structural Stages treated to change stand development toward Single Strata 

with Large Trees (SSLT). 

2. Acres of LOS restored to characteristic conditions, through density reduction and species shift. 

3. Net loss of LOS acres

4. Acres of multi-storied LOS changed to single storied LOS

5. Acres of increased radial growth for large tree development

Purpose and Need 2: Maintain and increase landscape resilience to reduce the risk of uncharacteristic 

disturbance.
Chapter 3 Snow Basin Vegetation Management Project FEIS

71

Key Indicators

• Acres where tree species composition is trending towards HRV

• Acres where structural stages are trending towards HRV

• Acres where tree densities are trending towards HRV

The table below (Table 18) displays how the alternatives respond to the key indicators of Purpose and 

Need 1- Manage forest structure, composition and density towards landscape HRV and improve 

sustainability. Alternative 2 results in the most improvement and alternative 4 the least. 

In Alternative 2, 67 acres of grand fir vegetation would have enough trees 21 inch DBH and greater 

removed to fall below the R6 Old Growth definitions. These areas are succeeding towards pure grand fir 

due to the lack of disturbance. The trees removed would be grand fir competing with ponderosa pine and 

western larch. The treatment would reduce the grand fir competition with existing ponderosa pine and 

western larch and provide gaps for their regeneration. 

Table 18. Purpose and Need 1

Manage forest structure, composition, and density towards landscape HRV and improve sustainability. Key indicators 

Alternatives 1/2/3/4

Indicator ALT 1 Alt 2 Alt 3 Alt 4

Acres of non LOS Structural Stages treated to change stand 

development toward Single Strata with Large Trees (SSLT)* 0 7,055 6,725 6,019

Acres of LOS Restored to Characteristic conditions@ 0 1,865 1,784 868

Net Loss of LOS Acres 0 67 0 0

Acres of Multi-storied LOS Changed to single Storied 0 1,249 1,158 868

Acres of Increased Radial growth for large tree Development$ 0 7,730 7,356 6,526

Notes: @Acres of Multi-storied LOS Changed to single Storied plus harvest in biophysical environments whose LOS 

stage is below HRV (species related treatments), *Acres changed to SEOC, $Acres changed to SEOC and SI

Table 19 displays how the alternatives respond to the key indicators of Purpose and Need 2- Maintain and 

increase landscape resilience to reduce the risk of uncharacteristic disturbance. Alternative 2 results in the 

most improvement and Alternative 4 the least.

Table 19. Purpose and Need 2

Maintain and increase landscape resilience to reduce the risk of uncharacteristic disturbance. Key indicators 

Alternatives 1/2/3/4

Indicator Alt 1 Alt 2 Alt 3 Alt 4

Acres where tree species composition is trending 

towards characteristic condition @ 0 11,495 11,013 9,229

Acres where structural stages are trending towards 

HRV# 0 8,428 8,039 6,593

Acres where stand densities are being managed to 

reduce susceptibility to bark beetles $ 0 11,495 11,013 9,229

Notes: @ All harvest treatment acres, # Acres changed to SI, SEOC, and SSLT, $ All harvest treatment acres.

Direct and Indirect Effects of Alternative 1 - No Action

Under this alternative, existing management would remain unchanged. There are no direct effects to 

current vegetation conditions because there would be no treatments under this alternative. This alternative 
Chapter 3 Snow Basin Vegetation Management Project FEIS

72

does not meet the purpose and need to move the landscape towards historically sustainable conditions 

because forest structure, species composition and density would not be treated. In order to achieve the 

desired landscape that is dominated by large diameter ponderosa pine and western larch, dense stands that 

are currently dominated by fir need to be treated.

Fire suppression can be expected to continue and be highly successful until vegetation, fuels, weather 

conditions, and ignition events exceed initial attack capabilities. Current stand dynamic processes could 

be expected to continue until a large-scale natural disturbance of insects or fire alters forested stand 

conditions. The most likely large scale event would create larger areas of stand replacement effects at 

scales not seen in recent times (last 100 years).

Under the No Action alternative (Alt. 1), the existing conditions for species composition would not be 

expected to change measurably in the short term (15 to 20 years). Ponderosa pine and western larch 

would continue to decline in numbers in the biophysical environments that are Douglas-fir or grand fir 

climax. These vegetation types will continue to see periodic insect outbreaks that randomly kill patches of 

large and small trees. At some time, large populations of insects can be expected to build, given warmer 

winters, longer periods of summer drought and plentiful host trees. At some future time, landscape-scale 

outbreaks of defoliating insects and bark beetles can be expected to change vegetation patterns within the 

project area. Habitat characteristics for American marten and goshawk such as canopy closure values and 

multi-story stand structures would be at risk and are expected to decline as large fir trees are killed by 

bark beetles.

Under the No Action alternative, other stand strucutures such as understory reinitiation that is over 

represented on this landscape would not be treated. These stands would not be placed on a trajectory to 

develop more rapidly into stands having sufficient numbers of large trees with resilient stand structures. 

Stands would not be able to withstand natural fire in the short (0 to 30 years) or long term (30 to 50 

years). Stands would not be expected to provide important habitat to species dependant on large trees in 

the future (30 to 50 years) due to continued reductions in diameter growth.

Stand densities would not be reduced under the No Action Alternative. Stands would continue to be 

susceptible to disturbances due to both density related stress between trees competing for limited 

resources and from stand structures of having “ladder” fuels of smaller trees that are “packed” relatively 

densely. These conditions also contribute to crown fires which are particularly problematic for wildlife 

habitat dependant upon higher canopy closures.

Under the No Action alternative, quaking aspen stands would not be treated to remove competing conifers 

that have encroached and are now out-competing with these relatively short-lived trees. These stands 

would not be treated to create conditions where fire can be used to stimulate sprouting and promote 

regeneration of these stands. Quaking aspen would therefore continue to decline under this alternative, 

resulting in the loss of valuable wildlife habitat and the loss of this species within the planning area.

Indirect effects of the No Action alternative would include unpredictable changes to stands from natural 

disturbance and succession processes. Since changes in vegetation conditions would relate primarily to 

the timing, magnitude, duration, and intensity of future disturbance and because consideration of 

unpredictable change is speculative and beyond the scope of this analysis, no attempt was made to 

estimate the future effects of disturbance. 

For ease of comparison, each of the issues and measures identified in Chapter 2 of the FEIS are

summarized for Alternative 1 below, under sections for the action alternatives.
Chapter 3 Snow Basin Vegetation Management Project FEIS

73

Purpose and Need 1: Manage forest structure, composition and density towards landscape HRV and 

improve sustainability.

For Alternative 1 there would be no change in forest structure, composition and density as a result of this 

project, therefore, there are no direct or indirect effects of this alternative. 

Purpose and Need 2: Maintain and increase landscape resilience to reduce the risk of uncharacteristic 

disturbance.

For Alternative 1 there would be no change in landscape resilience to reduce the risk of uncharacteristic 

disturbance as a result of this project, therefore there are no direct or indirect effect of this alternative 

Cumulative effects for Alternative 1 - No Action 

Existing vegetation conditions reflect the aggregate impact of all prior human actions and natural 

disturbance events that have affected this project area. Therefore, this analysis relies on current 

environmental conditions as a proxy for impacts of past actions. Public scoping for this project did not 

identify any public interest or need for detailed information on individual past actions. In addition, the 

Council on Environmental Quality issued an interpretive memorandum supporting this approach on June 

24, 2005 regarding analysis of past actions, which stated that agencies can conduct an adequate 

cumulative effects analysis using the existing condition as the aggregate effects of past actions.

Past actions, including timber harvest and fire exclusion, helped create existing conditions in the planning 

area. There are no reasonably foreseeable future actions that would alter current forested vegetation 

conditions of the project area.

Direct and indirect effects of Alternatives 2, 3, and 4. 

Purpose and Need 1: Manage forest structure, composition and density towards landscape HRV and 

improve sustainability.

Key indicators

• Acres of non LOS Structural Stages treated to change stand development toward Single Strata 

with Large Trees (SSLT). 

• Acres of LOS restored to characteristic conditions, through density reduction and species shift. 

• Net loss of LOS acres

• Acres of multi-storied LOS changed to single storied LOS

• Acres of increased radial growth for large tree development

Existing Late and Old Structure would be affected by the action alternatives in two ways: a possible net 

loss of LOS and changing some MSLT stands to SSLT. Table 20 displays the effects by biophysical 

environment. Alternative 2 would result in a loss of 67 acres of LOS. Alternatives 2/3/4 would change 

some existing MSLT to SSLT. Alternative 2 would change the most and alternative 4 the least.

Table 20. LOS changes by biophysical environments in the treatment units

Key indicator- Change of MSLT to 

SSLT Acres

Key indicator- Net Loss of LOS- Alternative 2 

Only

BPE

Alt 1 Alt 2 Alt 3 Alt 4

Loss

acres

Pretreatment 

stage

Posttreatment 

stage

Unit 

Numbers

Cool/moist/dry grand fir 0 77 72 0 7 MSLT Stand 

initiation 248

Warm/dry grand fir 0 510 502 406 7 SSLT Stand 249
Chapter 3 Snow Basin Vegetation Management Project FEIS

74

Key indicator- Change of MSLT to 

SSLT Acres

Key indicator- Net Loss of LOS- Alternative 2 

Only

BPE

Alt 1 Alt 2 Alt 3 Alt 4

Loss

acres

Pretreatment 

stage

Posttreatment 

stage

Unit 

Numbers

initiation

Warm/moist Douglas-fir 0 104 104 68 0 - - -

Warm/dry Douglas-firponderosa pine0 558 480 394 53 MSLT Stand 

initiation 5, 106, 406

Total Acres 0 1,249 1,158 868 67

Table 20a displays how the alternatives respond to improving future LOS by manipulating existing nonLOS. This is accomplished by creating single-story from multi-story, favoring resilient tree species, and 

reducing tree density to improve diameter growth rates. These acres would be able to develop into LOS 

over time. The increased diameter growth in the action alternatives would decrease the time required for 

trees to reach large tree diameters. Alternative 2 improves the most acres and Alternative 4 the least.

Table 20a. Key indicators by alternative

Key Indicator Acres of non LOS Structural 

Stages treated to change stand 

development toward Single 

Strata with Large Trees (SSLT)*

Acres of LOS Restored to 

Characteristic conditions@

Acres of Increased Radial 

growth for large tree 

Development$

Alternative 1 0 0 0

Alternative 2 7,055 1,865 7,730

Alternative 3 6,725 1,784 7,356

Alternative 4 6,019 868 6,526

Notes: @ All harvest treatment acres, $ All harvest treatment acres.

In summary, of the action alternatives, only Alternative 2 results in a net loss of late and old structure 

(Table 20). The amount of lost LOS is anticipated to be 67 acres which represents less than one percent of 

the total LOS structure within the planning area. Table 20 displays the amount of change in LOS by 

biophysical environment. The warm/dry Douglas-fir bio-environment would be subject to 53 acres of 

multi-stratum LOS moving to stand initiation. The effects of these 53 acres would be spread across 3 

treatment units and occur in different locations which would diminish impacts of ‘intensity’ to any one 

location. In addition, current levels of multi-stratum LOS are currently within the range of variability for 

this bio-environment and levels would continue to remain within this historic range after treatment under 

Alternative 2. Because of such limited number of acres of LOS being lost compared to the total number of 

acres currently existing and because of the limited impact of this change to any one location, Alternative 2 

is considered to still meet the purpose and need of managing forest structure, composition and density for 

landscape objectives of meeting HRV and sustainability. 

Alternatives 2, 3 and 4 would also meet the purpose and need for maintaining or increasing landscape 

resilience and reducing the risk of uncharacteristic disturbances because varying levels of multi-stratum 

LOS would be treated to reduce densities and canopy layers which are risk factors. Removal of 

understory fir species through thinning would increase stand resiliency by removing host species for 

Douglas-fir bark beetles. 

Harvest of live trees >21 inch diameter-at-breast-height (DBH) (Large Trees) (Table 21)

Measures: 1) Acres of treatment that harvest large trees; and 2) estimated weighted average of large trees 

per acre remaining after harvest in the treatment units
Chapter 3 Snow Basin Vegetation Management Project FEIS

75

Assumptions for this analysis:

• The number of large trees is assumed to be the same today as the date of the exam or field survey. 

• Not all acres would experience removal of large trees. Affected acres were assumed to be a 

percentage of the treated acres by biophysical environment. Cool/moist/dry grand fir: 20 percent 

of treated area; warm/dry grand fir: 50 percent of treated area; warm/moist and warm/dry 

Douglas-fir-ponderosa pine: 10 percent of treated area; and aspen: 75 percent of treated area.

• The acres not affected by removal of large trees would remain unchanged at the existing number 

of trees per acre.

Methodology

The average number of large trees existing in the harvest units was determined by analysis and 

extrapolation of the most current data available from several different data sets. For cool/moist/dry and 

warm/dry grand fir biophysical environments, the data used was from the most current stand exam data. 

For the warm moist Douglas-fir and warm dry Douglas-fir/ponderosa pine bio-environments, the analysis 

was based on a 100 percent survey of trees on over 1,000 acres which was performed from 5/2010 to 

9/2010. Aspen stands were analyzed using a 100 percent tree survey on all 29 aspen units which was 

performed in September, 2011. The analysis was performed for each biophysical environment and then 

averaged over all harvest unit acres. This same analysis was performed for each alternative.

1. Acres of treatment that harvests 21+ trees: 

• Alternative 1 – 0 (no large trees cut)

• Alternative 2- 3,016

• Alternative 3- 2,891

• Alternative 4- 0 (no large trees cut)

2. Estimated weighted average large trees per acre remaining in the treatment units after harvest:

• Alternative 1 – 8 (no large trees are cut)

• Alternative 2- 7

• Alternative 3- 7

• Alternative 4- 8 (no large trees are cut)

Table 21. Estimate of the number of large trees that would be removed by bio-environment and large 

trees remaining after harvest in the treatment units. 

(Alt 1 – no change from existing condition)

Alt2 and Alt3

Bio Physical 

Environment

Existing 

21+ 

trees 

per acre

Harvest acres

Estimated 

percent 

of harvest 

acres 

affected

Acres of 

treatment that 

harvest 21+ 

trees

21+ trees 

per acre 

removed

Trees per 

acre 21+ 

inches 

DBH

remaining 

after 

harvest

Alt2 Alt3 Alt4 Alt2 Alt3 # % # %

cool/moist/dry grand 

fir 13 840 823 499 25 210 206 3 23 10 77

warm/dry grand fir 12 4,436 4,245 3,539 50 2,218 2,122 3 25 9 75

warm/moist Douglasfir 4 930 912 686 10 93 91 1 25 3 75
Chapter 3 Snow Basin Vegetation Management Project FEIS

76

Alt2 and Alt3

Bio Physical 

Environment

Existing 

21+ 

trees 

per acre

Harvest acres

Estimated 

percent 

of harvest 

acres 

affected

Acres of 

treatment that 

harvest 21+ 

trees

21+ trees 

per acre 

removed

Trees per 

acre 21+ 

inches 

DBH

remaining 

after 

harvest

Alt2 Alt3 Alt4 Alt2 Alt3 # % # %

warm/dry Douglas-fir 

and ponderosa pine 4 4,664 4,434 3,954 10 466 443 1 25 3 75

Quaking Aspen 9 38 38 38 75 29 29 5 56 4 40

Current weighted 

average of large trees 8 Total 3,016 2,891

Harvest in LOS by biophysical environments when LOS structure is below HRV. 

Timber harvest activity within multi-story late and old structure (MSLT) in cool/moist/dry grand fir or 

within any single story late and old structure (SSLT) would require a FP Amendment as harvest activities 

would occur in an LOS stage below HRV. Table 22 displays the biophysical environments where this 

would occur and the acres. 

Table 22. Harvest by biophysical environments and LOS where LOS is below HRV

BPE/Stage Alt 2 Acres Alt 3 Acres Alt 4 Acres

Cool/moist/dry grand fir - MSLT 99 71 0

Warm/dry grand fir - SSLT 141 134 0

Warm/moist Douglas-fir - SSLT 141 141 0

Warm/dry Douglas-fir-ponderosa pine - SSLT 280 280 0

Total 661 626 0

Purpose and Need 2: Maintain and increase landscape resilience to reduce the risk of uncharacteristic 

disturbance.

Key Indicators

• Acres where tree species composition is trending towards HRV

• Acres where structural stages are trending towards HRV

• Acres where tree densities are trending towards HRV

Maintaining and increasing landscape resilience to reduce the risk of uncharacteristic disturbance would 

be achieved by manipulating tree species composition, structural stage, and tree density. The existing 

condition and effects of the alternatives are compared to HRV. Tree species composition affects resilience 

to fire and defoliating insects. Tree density affects resilience to fire and bark beetles. Structure affects 

resilience to fire and defoliating insects.

Species Composition

Species composition, as represented using seral stage, is expected to change in response to 

implementation of silviculture activities proposed under Alternatives 2/3/4. Table 23 displays the direct 

effects of these activities on species composition. 

Seral stages
Chapter 3 Snow Basin Vegetation Management Project FEIS

77

Derived from Hall et al 1995 (Hall, et al., 1995).

• Early seral- dominance of shade intolerant species (western larch/ponderosa pine)

• Mid seral- shade intolerant species (Douglas-fir/grand fir) are increasing and are approaching 

equal proportions with shade tolerants (western larch/ponderosa pine)

• Late seral- shade intolerant species (Douglas-fir/grand fir) are dominate, shade intolerants 

(western larch/ponderosa pine) may still be present in low numbers.

Assumptions used for the analysis of how silviculture treatments change seral stage conditions for each of 

the biophysical environments can be found in the full silviculture report under the Environmental Effects 

section.

Most of the seral stages affected by implementation of silviculture activities in Alternatives 2, 3, 4 are 

late-seral (grand fir/Douglas-fir). A direct result of treatments would be to decrease the amount of late 

seral fir trees as these trees would be favored for removal. These treatments result in stand composition 

shifting towards the remaining ponderosa pine and western larch.

Table 23. Direct effects of the alternatives on species composition (treated units), (acres) 

Alternative Cool/moist/dry 

grand fir Warm/dry grand fir Warm/moist Douglas-fir

Warm/dry Douglas-firponderosa pine

Late 

Seral

-67%

Mid 

Seral

-12%

Early 

Seral

+89%

Late 

Seral

-98

Early 

Seral

+98

No 

Chang

e

2%

Late 

Seral

-98

Early 

Seral

+98

No 

chang

e

2%

Late 

Seral

-98

Early 

Seral

+98

No 

Change

2%

2 -207 -21 +228 -2266 +2266 87 -473 +473 18 -1308 +1308 93

3 -207 -21 +228 -2226 +2226 83 -463 +463 18 -1272 +1272 89

4 -133 -17 +150 -1852 +1852 41 -285 +285 14 -1155 +1155 79

Source: Determined % change analysis of stand exam (diagnosis spreadsheet) using key below. Applied % change 

to starting seral stage acres from GIS query of CVS data from vegetation dynamics tool (VDDT) (Countryman, 2008). 

Data located T: SnowBasin\GIS\EVGVegDensitySummaryTables-02282012.xlsx. 

Indirect effects for species composition

Having an ecologically appropriate representation of forest cover types well distributed throughout the 

Snow Basin planning area, each of which exists within its historical range of variability, is a desired 

future condition for forest vegetation. The information presented in Table 24 suggests that the 

silvicultural activities proposed for implementation in Alternatives 2/3/4 would change species 

composition:

• Before implementation, cool/moist/dry grand fir is above HRV for late seral. After 

implementation all seral stages would be within HRV (Table 26) for Alternatives 2/3/4. 

• Before implementation, warm/dry grand fir and warm/moist Douglas-fir is outside HRV for all 

seral stages. After implementation, all seral stages would move closer to HRV but remain outside 

HRV (Table 26) for Alternatives 2/3/4. 

• Before implementation, warm/dry Douglas-fir-ponderosa pine is above HRV for late seral and 

below HRV for early seral. After implementation: early seral would be within HRV for 

Alternatives 2/3/4, late seral would be within HRV for Alternatives 2/3, late seral would remain 

above HRV for Alternative 4 (Table 26). 

Table 24. Indirect effects species composition (landscape) (percent)

Cool/moist/dry 1,697 ac
Chapter 3 Snow Basin Vegetation Management Project FEIS

78

grand fir

Seral Stage HRV Current Alt 2 Alt 3 Alt 4

Early 30-60 42 55 55 51

Mid 20-40 23 22 22 22

Late 10-30 35 23 23 27

Data Missing 0

Warm/dry grand fir 9,623 ac

Seral Stage HRV Current Alt 2 Alt 3 Alt 4

Early 75-90 36 60 59 55

Mid 0 8 8 8 8

Late 5-20 53 29 30 34

Data Missing 3 3 3 3

Warm/moist 

Douglas-fir 2,162 ac

Seral Stage HRV Current Alt2 Alt3 Alt4

Early 75-90 39 61 60 52

Mid 0 10 10 10 10

Late 5-20 50 28 29 47

Data Missing 1 1 1 1

Warm/dry 

Douglas-fir 9,762 ac

Seral Stage HRV Current Alt2 Alt3 Alt4

Early 75-90 67 80 80 79

Mid 0 0 0 0 0

Late 5-20 33 20 20 21

Data Missing 0 0 0 0

Source: CVS data from vegetation dynamics tool (VDDT) (Countryman, 2008). Gray shading indicates tree density 

classes that are above or below the historical range of variability.

Tree Density

Direct effects for tree density

Table 25 displays the direct effects of the activities on tree density in the treatment units. Tree density 

classes are expected to change in response to implementation of silvicultural activities proposed for 

Alternatives 2/3/4. The direct effect is expected to be a consistent reduction in tree density for the 

treatment units. All of the Closed density condition is expected to be reduced to Open density condition 

after implementation on the acres treated. Alternative 1 below is the existing condition.
Chapter 3 Snow Basin Vegetation Management Project FEIS

79

Table 25. Direct effects tree density (percent)

Vegetation 

Cover 

Type

Cool/moist/dry grand 

fir

(%)

Warm/dry grand fir

(%)

Warm/moist Douglasfir

(%)

Warm/dry Douglas-firponderosa pine

(%)

Alt1 Alt2 Alt3 Alt4 Alt1 Alt2 Alt3 Alt4 Alt1 Alt2 Alt3 Alt4 Alt1 Alt2 Alt3 Alt4

Open 59 100 100 100 36 100 100 100 39 100 100 100 32 100 100 100

Closed 41 0 0 0 64 0 0 0 61 0 0 0 68 0 0 0

Sources: Existing- GIS query of CVS data. Query report- EVG Veg Density Summary Tables- 02282012.xlsx. HRV-

(Countryman, 2008) (Powell D. C., 2010). Density Classes- Open = within the recommended management zone of 

SDI and below, Closed= greater than the upper management zone of SDI.

Indirect effects for tree density

Having an ecologically appropriate representation of tree (stand) density classes well distributed throughout the Snow Basin planning area, each of which exists within its historical range of variability, is a 

desired condition for forest vegetation. The information presented in Table 26 suggests that the 

silvicultural activities proposed for implementation in Alternatives 2/3/4 would change tree density.

Before implementation Closed density exceeded HRV for all biophysical environments (Table 26). After 

implementation: Open density would be within HRV and Closed density would remain above HRV. 

Closed density would remain above HRV due to the amount of Closed density landscape not being 

treated.

Table 26. Indirect effects tree density (landscape level). 

Vegetation 

Cover 

Type

Cool/moist/dry grand 

fir

Warm/dry grand fir Warm/moist DouglasfirWarm/dry Douglas-firponderosa pine

Alt2 HRV Existing Post HRV Existing Post HRV Existing Post HRV Existing Post

Open 30-

40

47 58 80-

90

38 68 80-

90

38 67 80-

90

38 68

Closed 60-

80

53 42 5-20 62 32 5-20 62 33 5-20 62 32

Alt3

Open 30-

40

47 57 80-

90

38 68 80-

90

38 66 80-

90

38 67

Closed 60-

80

53 43 5-20 62 32 5-20 62 34 5-20 62 33

Alt4

Open 30-

40

47 57 80-

90

38 63 80-

90

38 63 80-

90

38 64

Closed 60-

80

53 43 5-20 62 37 5-20 62 37 5-20 62 36

Density Classes-Open: within the recommended management zone of SDI and below, Closed: greater than the upper 

management zone of SDI. 

Sources: Post treatment density class derived from VDDT data. Range of variation for density and density classes 

from Powell (Powell, 2009). Gray shading indicates tree density classes that are above or below the historical range 

of variability.
Chapter 3 Snow Basin Vegetation Management Project FEIS

80

Forest Structure

Table 27 displays the direct effects of these activities on forest structural stages for Alternatives 2, 3, and 

4. Stages are expected to change in response to implementation of silvicultural activities proposed for 

Alternatives 2, 3, and 4. The direct effect are expected to be increases in; SI, SEOC, and SSLT with 

decreases in SECC, UR, MSLTU, and MSLT.

Table 27. Direct effects for forest structural stages (Acres). Effects on the stages treated

cool/moist/dry grand 

fir

Warm/dry grand fir Warm/moist DouglasfirWarm/Dry Douglasfir/Ponderosa pine

curre

nt

Change curre

nt

Change curre

nt

Change curre

nt

Change

Stag

e

alt2 alt3 alt4 alt2 alt3 alt4 alt2 alt3 alt4 alt2 alt3 alt4

SI 152 +62 +55 +55 811 +191 +93 +36 89 +24 +24 +24 364 +214 +133 +129

SEO

C 0 +58

7

+58

4

+58

4 442 +3,059

+3,0

00

+2,6

50 172 +574

+55

5

+51

1

1,56

3

+2,5

43

+2,4

73

+1,7

36

SEC

C 191 -113

-

113 -30 1,375 -739 -733 -635 328 -185

-

186

-

177

1,08

5 -304 -302 0

UR

645 -

342

-

338

-

325

3,96

4

-

1,77

0

-

1,64

6

-

1,45

9

1,01

1

-

401

-

381

-

354

3,04

0

-

1,75

4

-

1,68

0

-

1,55

9

MSL

TU 415 -187

-

188

-

106

1,80

0 -734 -714 -592 93 -12 -12 -4 1,198 --646 -624 -306

MSL

T 278 -71 -71 0 970 -511 -502 -406 324 -104

-

103 -68 1,834 -557 -446 -367

SSLT 0 +64 +71 0 230 +504 +502 +406 144 +10

4

+10

3 +68 460 +504 +446 +367

Indirect effects for forest structural stages

Table 28 shows that the direct effects of implementing silvicultural activities associated with Alternatives 

2, 3, and 4 have indirect effects on forest structure when spread across the landscape. The most 

pronounced change is the increase of SEOC and SSLT decrease of UR. 

Table 28. Indirect effects for forest structural stages. Effects on the landscape

Stage PreImplementationPostImplementation

Percent Percent

Alt 1 Acres Alt 2 Alt 3 Alt 4

SI 6 1,442 8 8 7

SEOC 10 2,210 39 38 33

SECC 13 2,953 7 7 9

UR 38 8,675 19 20 21

MSLTU 15 3,676 8 9 11

MSLT 14 3,428 9 10 11

SSLT 4 923 9 8 8

Includes all NFS lands in the planning area. Source: Existing acres by stage is from a GIS Query of the vegetation 

database. Data for this query is found in EVG Bio Phys Structure Stage Summary- 2/26/2012.xls. 

An HRV analysis was completed for forest structure as it would exist after implementation of 

Alternatives 2/3/4 (Table 29). 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Table 29. HRV analysis for forest structural stages changes with implementation of alternative 2/3/4. 

(Percent)

Cool/moist/dry grand 

fir

Warm/dry grand fir Warm/moist DouglasfirWarm/Dry Douglasfir/Ponderosa pine

Stage HRV alt2 alt3 alt4 HRV alt2 alt3 alt4 HRV alt2 alt3 alt4 HRV alt2 alt3 alt4

SI 1-10 13 12 12 1-15 10 9 8 1-15 5 5 5 1-15 6 5 5

SEOC 0-0 35 35 24 5-20 36 36 32 5-20 35 34 32 5-20 42 42 35

SECC 1-10 5 5 10 1-10 7 7 8 1-10 7 7 7 1-10 8 8 11

UR 5-25 18 18 19 1-10 23 24 26 1-10 28 29 30 1-10 13 14 16

MSLTU 20-50 13 13 18 5-25 11 11 13 10-30 4 4 4 5-25 6 6 9

MSLT 30-60 12 12 17 5-25 5 5 6 10-30 10 10 12 5-25 13 13 15

SSLT 0-0 4 4 0 15-55 8 8 7 15-55 11 11 10 15-55 10 9 9

Having an ecologically appropriate representation of forest structural stages well distributed throughout 

the Snow Basin planning area, each of which exists within its historical range of variability, is a desired 

condition for forest vegetation. The information presented in Table 29 suggests that the silvicultural 

activities proposed for implementation in Alternatives 2, 3, and 4 would change the pre-implementation 

HRV results as follows:

Cool/moist/dry grand fir

• SI would go above HRV for Alternatives 2, 3, and 4. This would result from the reduction of 

overstory in the HORs. The released understory would be free to develop into another stage when 

average stand diameter reaches 5 inch DBH. Present understory average stand diameter is 2 inch

DBH. 

• SEOC would go above HRV for Alternatives 2, 3, and 4. This would result from improving the 

ponderosa pine and western larch component in the UR and MSLTU stages. Over time, SEOC 

would develop into other stages. 

• SSLT would go above HRV. This would result from improving the ponderosa pine and western 

larch component in MSLT. SSLT would be allowed to develop into MSLT in the future.

Warm/dry grand fir

• SEOC would go above HRV for Alternatives 2, 3, and 4. This would result from improving the 

ponderosa pine and western larch component and reducing tree density in the SECC, UR, and 

MSLTU stages. Over time, SEOC would develop into other stages. SEOC would provide a large 

source of recruitment for SSLT.

• UR and would remain above HRV.

• SSLT would increase but remain below HRV. 

Warm/moist Douglas-fir

• SEOC would go above HRV for Alternatives 2, 3, and 4. This would result from improving the 

ponderosa pine and western larch component and reducing tree density in the SECC, UR, and 

MSLTU stages. SEOC develop into other stages in the future. SEOC would provide a large 

source of recruitment for SSLT.

• UR and would remain above HRV.

• MSLTU would go below HRV. Over time, it would develop into other stages. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

82

• SSLT would increase but remain below HRV. 

Warm/dry Douglas-fir/ponderosa pine

• SEOC would go above HRV for Alternatives 2, 3, and 4. This would result from improving the 

ponderosa pine and western larch component and reducing tree density in the SECC, UR, and 

MSLTU stages. SEOC develop into other stages in the future. SEOC would provide a large 

source of recruitment for SSLT.

• MSLTU would go below HRV. Over time, it would develop into other stages. 

• SSLT would increase but remain below HRV. 

Quaking Aspen

Alternatives 2 and 3

Under Alternatives 2 and 3, all conifers less than 150 years of age would be removed. The conifers 

remaining are of sufficient age to have co-existed with the aspen before the fire exclusion period. 

Removal of all but these trees would approximate the historic condition of limited overhead shade to the 

aspen. Improved aspen growth and development, while co-existing with fewer conifers, would occur. 

This would meet the desired condition of quaking aspen stands free to grow, expanded to their biological 

limits, and able to successfully respond to future fire. 

Alternative 4

Alternative 4 would retain all live 21 inch DBH or more conifers. Aspen sprouting and growth and 

development would be less than Alternatives 2 and 3. Under Alternative 4 conifer encroachment back into 

the aspen sites would be accelerated as compared to Alternatives 2 and 3 due to the increased conifer seed 

source. While there would be some improvement, Alternative 4 would not meet the desired condition of 

quaking aspen stands free to grow.

Cumulative Effects of Alternatives 2, 3, and 4

Past actions and their effect on current conditions

Past vegetation management and fire exclusion has resulted in uncharacteristic conditions. Since these 

stands have been affected by fire exclusion, they are now thought to be unrepresentative of most natural 

stand development processes under a frequent low-severity to mixed-severity fire regime. Table 30

displays the known past vegetation management projects in the Snow Basin planning area.

Past actions in the Snow Basin project area, prior to 1990s

These actions focused on reducing the large tree component and releasing understories. They resulted in 

single story LOS below HRV and a proliferation of multi-story structure. Quaking aspen was not 

intentionally managed during this period. Since the early 1990s, past and ongoing silviculture treatments 

focused on density management favoring ponderosa pine and western larch, restoring single story 

structures, reducing dead fuels, and quaking aspen restoration. 

The more recent past actions, since 1990

Since 1994 treatments have been in compliance with Forest Plan Amendment 2 (SCREENS). Past 

regeneration harvest has been successfully reforested. These stands will soon transitioning to other stages. 

The SEOC and SSLT created on these recent past actions have re-established understories and are 

beginning to transition to multi-story. Improvements to radial growth through past thinning will begin to 

decline as densities increase. 

Past aspen restoration has been successful and has been actively maintained since the initial treatments.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Chapter 3 Snow Basin Vegetation Management Project FEIS

84

Table 30. Historical timber harvest activity

This table includes all sales, for which records exist at the Pine Office that occurred in the project area. In some 

cases the entire sale was within the Snow Basin area and in others just a portion

Years Name Harvest activity

1950 – 1959 Basin Creek, Little Eagle Creek Intermediate harvest- Commercial thinning/Final 

harvest

1960 – 1969 Lower Little Eagle, Gold Creek, Paddy 

Creek

Intermediate harvest- Commercial thinning/Final 

harvest

Regeneration harvest- Shelterwood

1970 - 1979 Blue Canyon, Cougar Ridge, Ethel 

Boulder, Twin Bridges

Intermediate harvest- Commercial thinning/Final 

harvest

Regeneration harvest- Shelterwood

1980 - 1989 Dempsey, Bronze, Orchid, Conundrum 

Summit, Holcomb, small sales

Intermediate harvest- Commercial thinning/Final 

harvest

Regeneration harvest- Shelterwood

 -Clear cut (seed orchards)

Salvage- insect mortality

1990 - 1999 Stringer, Biddy Beagle, Fizz Eagle, 

Walnut, Gold Eagle, Dark Red, Forshey 

Aspen, Small Sales

Intermediate harvest- Commercial thinning

Regeneration harvest- Shelterwood

Salvage- insect mortality

Aspen Restoration

2000 - 2009 Eagle Paddy, Little Eagle, Eagle 

Holcomb, Eagle Salvage

Intermediate harvest- Commercial thinning

Regeneration harvest- Shelterwood

Salvage- insect mortality

Aspen Restoration

2010 - Present None

Note: that historical activities are not mutually exclusive – some acreage was affected more than once by different 

activities through time.

Contrasting effects of proposed actions with past actions

The proposed action and other action Alternatives are similar to recent past actions as they proposed to 

manage species composition, tree density, and forest structure to improve landscape resiliency. All 

treatments are designed to improve the composition of fire, insect, and disease resistant stand conditions. 

The landscape level treatment is further designed to facilitate the maintenance and development of 

characteristic conditions through the use of prescribed and natural fire. 

Effects of ongoing and reasonably foreseeable actions

No vegetation management projects are ongoing in the Snow Basin Analysis Area (Little-Eagle, and 

Eagle Creek Paddy Creek sub watersheds). Similar projects are being carried out within other parts of the 

Eagle Creek watershed. The Tremble Environmental Assessment is an aspen restoration project using 

timber harvest to remove competing conifers. It has one unit totaling one acre within the Snow Basin 

project area. This unit is not within LOS.

Based on the Forest‘s schedule of proposed actions (SOPA), no other actions potentially affecting 

vegetation conditions in the Snow Basin planning area are anticipated over the next 5 years 

Combined effects from past, proposed, ongoing, and foreseeable actions

Proposed, ongoing, and foreseeable actions are all geared towards restoring ecosystem structure and 

processes, and undoing the effects of most of the previous management consequences, whether they were 

intentional or not. The proposed treatments would improve landscape resiliency. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

85

Monitoring Requirements

Monitoring would occur for both project implementation and to determine if the overall management 

objectives were met (effectiveness monitoring). Forest Service personnel would conduct monitoring in 

areas that have the highest probability of showing effects throughout the project’s implementation. 

The project silviculturist and presale lead would monitor implementation of the marking guides by presale 

crews. If marking results in a variance of more than 15 percent from the prescription, the project 

silviculturist will review the areas on the ground with presale and other specialists as needed to discuss 

the prescription and decide if modifications to the prescription are needed.

The Forest Service Presale Lead would also monitor harvest unit layout and design of the timber sale 

contract for compliance with NEPA and the silviculture prescription. Other specialists would also be 

involved at various stages of contract development, unit layout and marking to assist with questions and 

to monitor that all resource design criteria are included in the preparation phases and implemented.

Forest Service Sale Administrators would administer the timber sale contracts and monitor for 

compliance with NEPA and the silviculture prescription during all phases of sale contract activity. 

Forest Service Contracting Officer’s Representatives would monitor implementation of the silviculture 

prescriptions during service contracts that perform post sale work after harvest activities are completed.

The District Silviculturist would update the vegetation and FACTS databases with post activity data. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

86

FIRE/FUELS MANAGEMENT

For more detail on the fire and fuel management aspects of this project, please refer to the Fire/Fuels 

specialist report.

Existing Condition

Fuel Type Description

Fire suppression and past management practices over the last 100 years have resulted in forest 

communities that are denser overall, with more fuel available to burn. The ponderosa pine and mixed 

conifer stands within the project area are densely stocked with small diameter trees and have large 

accumulations of surface fuels. Much of the understory vegetation on the dry sites has developed a large 

component of non-fire tolerant vegetation (grand fir), which is currently a contributor to fire risk (as a 

ladder fuel) and in the long-term is undesirable as a dominant overstory species. Under these vegetation 

and fuels conditions, fire can easily reach the crowns of overstory trees and prevent direct fire suppression 

tactics, resulting in non-typical and high-severity stand replacing fires. 

Fire Regime Condition Class

Mixed conifer, Ponderosa pine and Ponderosa pine/Douglas-fir dominate the forested stands. When 

condition class is viewed from a landscape level, individual stands exist in varying stages of development 

within each biophysical environment to which it belongs. The fire regime vegetative type and structure of 

the predominant stands found within the analysis area include: ponderosa pine, Douglas-fir (Inland 

Northwest) (PPDF1), and Ponderosa Pine PNW/Great Basin (PPIN1) Potential Natural Vegetation 

Groups (PNVG). These two PNVG’s are fire regime I. Grand fir/Douglas-fir (GFDF) represented the 

majority of the fire regime III vegetation types, including both cool moist and warm moist stands. The 

majority of the non-forested sites across the landscape (approximately 16 percent) are represented by the 

Mountain Grassland with Shrubs PNVG (MGRA3), fire regime II. Subalpine fir occurs outside the 

analysis area, so was not included.

Throughout the project area there are a number of instances where moist stands are surrounded by dry site 

vegetation. These stands represent the dry end of the classification for cool/warm moist vegetation as they 

occur on this landscape. This mosaic of cool moist/warm moist vegetation, surrounded by dry vegetation, 

poses a challenge when modeling fire regime departure. These stands fit within the drier end of a mixed 

fire regime spectrum. The adjacency and location on slope of many of the moist stands proposed for 

treatment are such that fire frequency would have been expected to be similar if not identical to that found 

on adjacent dry plant associations. 

Agee in the PSW_GTR 181 states: Mixed-severity fire regimes had larger patch sizes and considerable 

edge (Figure 1). These fires maintained both a naturally fragmented forest structure and fuel structure. 

Patch size in the mixed-severity fire regimes is typically larger than for the low-severity fire regimes. 

Patch size for mixed-severity forests (including some drier Westside Cascade forests) ranges from 2.5 to 

250 ha (Agee, 1998b). Patch edge is typically much higher for mixed-severity fire regimes than for highseverity fire regimes (although the methods for defining a patch will significantly influence any edge 

metric). The result, both from fire and other disturbances, was considerable local-scale patchiness on the 

landscape (Taylor and Halpern, 1991). Patches burned with light fires had surface fuels removed and only 

understory trees killed. Patches burned with higher intensity fires had some overstory removed (similar to 

the first entry on a shelterwood), and resulted in a favorable environment for regeneration of a new age 

class of trees (generally shade-tolerant species: white fir [Abies concolor{Gord. and Glend.} Hildebr.] or 

grand fir [Abies grandis {Dougl. ex D. Don} Lindl.], Douglas-fir [on dry sites], red fir [Abies magnifica 
Chapter 3 Snow Basin Vegetation Management Project FEIS

87

A. Murr.], and/or sugar pine [Pinus lambertiana Dougl.]). Patches burned with very high intensity within 

the mixed-severity fire regime had all the overstory killed and created an environment for shrub fields or 

new shade-intolerant tree species (typically western larch (Larixoccidentalis Nutt.) or lodgepole pine 

(Pinus contorta Dougl.) (Antos and Habeck1981, Cobb 1988). Landscape position in part explains 

differential severity: Lower slope positions had the least amount of severe fire, while upper slopes, 

particularly of west or south aspect and ridgetops experienced more severe fire (Taylor and Skinner, 

1998).

Most of the mixed severity regimes in the analysis area show presence of large ponderosa pine older than 

150 years and smaller to large diameter grand fir less than 100 years in age. The area has not had fire 

within the last 100 years except some prescribed fire. The current stand composition of large, older 

ponderosa pine intermixed with large, younger (less than 100 year old) grand fir, supports this premise. 

The area is currently lacking in the open mid-seral structures. The areas generally burned at the same 

interval as surrounding warm/dry stands based on stand size and edge effect, which again would support a 

more open structure.

The landscape is currently at the high end of Condition Class 2, moderate alteration to the historic 

disturbance regimes are clearly evident, such as one or more missed fire return intervals, which may 

predispose the stand or ecosystem to disturbance events well outside the historic range of variability. Fire 

Regime and vegetative condition departure is very high on those portions of the landscape represented by 

vegetation types PPDF1, and PPIN1 (71 percent of the project area). These stands are typical of dry site 

vegetation that historically developed under the influence of low intensity, high frequency disturbance 

from wildfire. Mid Seral Closed stand structure is well above historic levels and Late Seral Open is well 

below historic levels for most species found on drier sites. Fire regime departure is moderate for 

vegetation typical of warm/moist and cool/moist to cold/dry sites(GFDF), which historically experienced 

moderate to long fire return intervals and higher associated fire intensities (13 percent of the landscape).

Vegetative condition departure for these moist sites is modeled at low, although given the proximity to 

dry sites and the mosaic nature of the occurrence of these stands (see above), the model may be underrepresenting the actual departure in this instance. Grass sites across the landscape (MGRA3), are at the 

low end of a moderate departure for both fire regime and condition class.

Consistency with Laws and Regulations

All proposed fuel treatments are consistent with Forest Plan standards as well as all applicable state laws 

and regulations. See the air quality section of the fire/fuels specialist report for more information relative 

to State of Oregon requirements for smoke management. See the Wild and Scenic River section for 

specifics on compliance with wild and scenic guidelines and policy.

The following are fire/fuels specific direction and guidance in the Land and Resource Management Plan 

pertinent to this project (Land and Resource Management Plan, 1990).

MA 1:

• Use prescribed burning to accomplish numerous resource management objectives including 

silvicultural, fire protection, and wildlife as appropriate. Where not appropriate, use non-fire 

treatment tools to reduce fuel accumulations as need to meet resource objectives.

• In general, use the lowest cost fuel treatment option available. 

• Design suppression practices to protect investment in managed tree stands and prevent losses of 

large acreage to wildfire. MA 1 is high priority for fire suppression. Minimum acceptable 

suppression response is contained at all Fire Intensity Levels (FIL).

MA 3:
Chapter 3 Snow Basin Vegetation Management Project FEIS

88

• Favor prescribed fire for treatment of slash fuels where feasible

MA 7:

• Fuel loading will consist of natural accumulations except as modified by prescribed fire.

MA 15:

• Minimal use of heavy equipment for fire suppression and prescribed burning will occur in order 

to protect old growth characteristics.

MA 16:

• Favor hand over machine firelines

• Prescribed fire may be used to improve the appearance of some sites to meet objectives

Methodology and Measurement Indicators

Key Indicators used to compare the Alternatives are: a) Fuel Loading and associated Fire Behavior 

Potential – Measured by Stand Replacement Potential and Flame Length; and b) Fire Regime Condition 

Class of the landscape as measure by FRCC departure. 

Fuel Loading and Fire Behavior Potential

Fire behavior modeling was used to predict the changes in fuel loading and fire behavior in the project 

area for the vegetation conditions that would exist for each alternative. Fire behavior model inputs were 

obtained from weather records at the Sparta Butte Remote Automated Weather Station (RAWS) and fuels 

models were assigned based on the existing or proposed treatment vegetation types. The modeling results 

show how Alternatives 2, 3, and 4 would change both surface and crown fire behavior within the project 

area.

Creating fire resilient forests with fuels treatments implies a three part approach: reduce surface fuels 

through prescribed burning, reduce ladder fuels through small diameter thinning and burning, and reduce 

crown density in both the understory and overstory (Agee, 2002; Skinner, 1996).

Fire behavior fuel models are used as input to the Rothermel (1972) fire spread model, which is used in a 

variety of fire behavior modeling systems. The Fuel models used in this analysis are from Scott and 

Burgan’s (2005) Standard fire behavior fuel models: a comprehensive set for use with Rothermel’s 

surface fire spread model.

Fuels Management Analyst Suite (FMA Plus 3) was used to make fire behavior predictions. A 97-

percentile fire danger day (only 3 percent of weather and environmental conditions are worse) was used

for the wildfire predictions. Stand exam data backed up by field recon were used to determine stand 

characteristics used in the fire behavior modeling.

A number of factors including crown and canopy bulk density, crown base heights, torching indices, 

crowning indices, crown fire potential, spotting potential, and flame lengths were analyzed in determining 

differences between alternatives (fire/fuels analysis file, 2011). Stand replacement potential and flame 

length were selected as the best measurements.

Fire Regime Departure

Modifications in vegetation resulting from treatment actions were evaluated and summarized following 

the protocols for determination of Fire Regime Condition Class (used in existing condition sections). 

Using inputs on the Fire Regime Condition Class Worksheet, factors such as departure of fire return 
Chapter 3 Snow Basin Vegetation Management Project FEIS

89

interval, fire intensity, stand structure, and stand composition were developed for each potential 

vegetation group and then combined for a total landscape analysis.

Incomplete and Unavailable Information

Wind speed and direction is highly variable and not well represented by the daily weather records used 

for fire behavior prediction analysis. A 20 foot wind speed of 12 mph is a moderate average 

representation of summer condition in the area and probably under-represents 97-percentile conditions. 

Wind direction was determined to not be a critical variable in the analysis given the complex terrain of the 

landscape. Fire behavior analysis was conducted assuming upslope winds.

Numerous comments have been received relating to the identified condition of and proposed treatments 

and their effects on the cool and warm moist stand types within the analysis area. These stands exist as a 

mosaic surrounded by warm dry sites and an assumption was made that fire spread, due to proximity and 

the juxtaposition of these sites to dry sites, would have historically been similar if not identical to that 

found on the surrounding stands.

Effects

Alternative 1 - No Action 

Direct and Indirect Effects 

Fuel loading and fire behavior potential

The “No action” alternative would result in no reduction in surface or aerial fuel loadings and as a result 

the potential for adverse effects from wildland fire will remain and may increase. Within the analysis 

area, multi-layered stand structures, tree densities and live vegetation continue to grow. Also, dead wood 

continues to accumulate, creating conditions that allow fire to move vertically from the ground level to 

the forest crown. Overstocked stand conditions will continue to increase the susceptibility of the stands to 

insects and disease (see Vegetation Effects Section), resulting in increased surface and crown fuel 

loadings and associated fire behavior potential. These conditions will continue to limit firefighting 

opportunities, pose undesirable risk to private property, firefighter and public safety, and continue the risk 

of damaging impacts to natural resources.

The direct effects of Alternative 1 are a continuation of heavy surface and canopy fuel loadings. Flame 

lengths exceeding 4 feet could be expected; continuing the risk of a crown fire initiation, active fire 

spread (including onto private property and homes), and decreased opportunities to fight fire direct with 

hand tools. Crown base heights would remain low, canopy bulk densities would remain high. The 

potential for crown fire would remain for both single and individual tree torching (passive) and tree crown 

to crown spread (active). In some instances fire suppression efforts would require backing off to areas of 

lighter fuels and natural breaks or using heavy equipment. Not having the opportunity to direct attack a 

fire combined with the limited access in the project area increases the potential for a large, 

uncharacteristic wildfire, the potential for resource damage from heavy equipment, and risk to firefighter 

and public safety (Table 31).

The direct effects of not treating acres with crown fire potential also increases the risk of mineral soil 

exposure during wildfire, increasing potential damage to soil, vegetation, and water quality. The 

continued risk of high intensity fire poses an increased risk to deterioration of the viewsheds along the 

Eagle Creek, the Eagle Cap Wilderness Area; along with the areas surrounding the communities of 

Sparta, Surprise Springs, Carson/Pine Valley, and East Eagle/Main Eagle.
Chapter 3 Snow Basin Vegetation Management Project FEIS

90

Fire regime condition class departure

The analysis area currently has approximately 28,543 acres in fire regimes one and three, which are 

identified as having a moderate to high FRCC departure of 64 percent (Figure2).

Without treatment, Fire Regime Condition Class departure will continue to increase. The likelihood of 

large-scale disturbances (fire, insect epidemics, etc.) will increase over time, compounded by anticipated 

changes in climate in the area. Fire exclusion would continue to extend the fire return interval, increase 

fuel loadings, change vegetation profiles, and increase the gap between historical conditions and current 

conditions. True fir establishment would continue in the absence of low intensity fire. These vegetative 

conditions will continue to place Late and Old structure, wildlife habitat, and riparian areas at risk to 

severe wildfire impacts.

Reliance upon natural disturbance to return the area to historic conditions could be expected to take years 

if not decades. Lacking treatment, the size and intensity of future natural disturbance is expected to be 

unacceptable on both federal and private land.

Air quality

Potential impacts of smoke generated from a wildfire will continue to increase as fuel loadings increase 

over time.

The direct effects of a wildfire burning under the existing conditions has the potential to produce smoke 

levels that exceed visual and health standards within Halfway and Richland, as well as the dispersed 

communities of Sparta, Surprise Springs, Carson/Pine Valley, and East Eagle/Main Eagle. Local research 

found PM10 smoke production was twice as high for wildfires as for prescribed fire. This is because 

wildfires generally occur during drought periods in which there are low fuel moistures. Research in the 

Grande Ronde River Basin found the levels of PM10 smoke emissions from wildfires were two times 

greater than from typical prescribed burns (Huff, Ottmar, et al, 1995).

Nearby areas that may be impacted by wildfire smoke include: 

• Communities of Halfway, Richland, Sparta, Surprise Springs, Carson/Pine Valley, and East 

Eagle/Main Eagle 

• Eagle Cap Wilderness Area (Class I Airshed)

• Wild and Scenic

Without treatment, fuel loading (live and dead) and associated fire potential is expected to worsen over 

time. Initial fire suppression response will not change, although the resistance to control of summer 

wildfires is expected to increase and potentially result in larger, more intense burns effecting both visual 

and water quality Outstanding Remarkable (OR) values (Environmental Assessment for the Eagle Creek 

Wild and Scenic River Management Plan, 1993).

The continued and increasing potential for larger, more intense fires may result in an increased use of 

heavy equipment (and associated ground disturbance) and aviation support, primarily outside riparian 

areas, in order to achieve suppression objectives.

Cumulative effects 

Values at risk including improvements, wildlife habitat, private lands, and visual concerns within and 

adjacent to the analysis area will continue to drive protection from disturbance events, primarily wildfire. 

Without treatment, fuel loading associated fire risk and fire regime departure will continue to increase, 

ultimately resulting in vegetative conditions that will support increasingly intense burning conditions. 

Climatological changes over time may compound these conditions if the predicted changes towards 

warmer, drier conditions come to pass. Resistance to control, suppression costs, and exposure or risk to 
Chapter 3 Snow Basin Vegetation Management Project FEIS

91

personnel managing wildfires can be expected to increase. Similarly, managing natural ignitions for 

beneficial objectives will become more difficult as fire intensity increases.

Alternatives 2, 3, and 4

Direct and indirect effects 

Fuel loading and fire behavior potential

The action Alternatives propose a combination of vegetation and fuel treatments that research has shown 

will be effective at reducing fire potential. Several authors and/or papers have supported vegetation 

treatment in conjunction with fuels reduction as tools to reduce fire behavior. The principle goal of fuels 

reduction treatments is to reduce fireline intensities, reduce the potential for crown fires, and improve the 

ability of forest stands to survive a wildfire (Agee, 2002). Stand structure and wildfire behavior are 

clearly linked (Biswell, 1960; Cooper,1960; Dodge, 1972; McLean, 1993; Rothermel, 1991; Van Wagner,

1977), so fuels reduction treatments are a logical approach to reducing extreme fire behavior.

Vegetation treatments that target canopy closure have the potential to reduce the development of all types 

of crown fires (Cruz et al., 2002; Rothermel, 1991; Scott and Reinhart ,2001; Van Wagner ,1977) if 

surface fuels are concurrently treated. Canopy and ladder fuels will be reduced by forest thinning 

operations that target crown classes, stand basal area, and canopy bulk density. Treatments would also 

maximize managing towards large trees that are resistant to insects, disease, and fire. Thinning of some 

large trees may be needed to reduce crown density (removing large trees is sometimes necessary to 

achieve overall fuel treatment goals). Relatively large trees of shade-tolerant species such as white fir 

(those 21 inch DBH or more) have developed on many productive mixed-conifer sites since fire 

suppression programs were instituted a century ago. These trees often provide the fuel ladders that put 

old-growth pine or giant sequoia trees at risk, as well as increasing overall stand canopy densities. Both 

conditions greatly increase the potential for stand-replacement fires. Restoring characteristic fuel loadings 

and wildfire behavior, to say nothing of prescribed burning programs, often requires removal of some of 

these larger, but relatively young trees (Franklin and Agee, 2003).

Surface fuels will be reduced by prescribed fire and/or a combination of mechanical treatments and 

burning that remove and reduce fuel (e.g. grapple pile and burn). Reducing surface and crown fuels will 

reduce crown fire potential and potential flame length.

Crown and canopy base heights will be increased through the thinning of the understory. Prescribed 

burning will also increase crown base heights by removing live limb wood in the lower portions of the 

crowns.

Thinning and prescribed fire is expected to modify the understory microclimate. Expected results include 

increased solar radiation, increased surface temperatures, decreased fine fuel moistures, and reduced 

sheltering from wind. An increase in fine fuels, primarily grass and forbs is also anticipated. Combined, 

these changes are expected to result in a change in fire behavior. Fire will shift from burning in heavier 

fuels, including ladder fuels, under a more sheltered condition and continuous canopy with potential for 

crown fire to fire burning in light fuels in a more exposed or unsheltered situation, where the predominant 

fire spread mechanism will be surface fire.

Fires in light fuels are expected to exhibit high intensity where fuel, weather, and topographical 

conditions align. These high intensities are short-lived as fire in light fuels spread relatively rapidly and 

burnout quickly, pose less resistance to control efforts, and are reactive to changes in fine dead fuel 

moistures. Reduced ladder fuels and open canopies reduce potential for crown fire initiation and spread. 

Fire in light fuels is less “severe” than those in heavy fuels as measured by consumption of surface fuels, 

soil heating, etc. In general, shifting a fire’s behavior from a crown to surface fire produces less severe 

effects and fewer impacts on resource values (Fitzgerald, 2002).
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Modification of understory conditions toward a higher proportion of light fuels with reduced surface fuel 

loading reduces the difficulty in application of prescribed fire, extending the time available when burning 

objectives can be met (prescription window), and reducing the need to burn when the relative risk of 

ignition is otherwise high (mid-season). Treatment and maintenance of thinned stands will be critical to 

maintaining surface fuel conditions and managing development of ladder fuels over time so as to manage 

future crown fire risk.

The three action alternatives have a similar impact on the acres undergoing treatment, the difference being 

in the acreage treated under each alternative. Stands treated under the prescriptions described under 

Alternative 4, where remaining large white fir (greater than 21 inches) are expected to move back toward 

pretreatment conditions in the absence of maintenance activities more rapidly due to grand fir 

regeneration than are stands treated as described in Alternatives 2 and 3.

Acres treated by prescribed fire only are expected to experience higher burn intensities and associated 

mortality under wildfire conditions as compared to those acres treated with a move comprehensive 

combination of vegetation and fuel reduction treatments. Application of 2 to 3 prescribed fire treatments 

on stand-alone burn units will reduce this difference. 

All treatments are expected to result in fuel loading modification in all stand types. Treatments that 

address surface, ladder, and canopy fuels will be the most effective at moving expected fires out of the 

crowns, especially where significant surface, ladder, and canopy fuels exist together. Burn only 

treatments addressing primarily surface and to some degree ladder fuels will be effective in reducing 

surface fire intensity, particularly where ladder and crown fuels are not a concern, but less effective in 

reducing crown fire potential under conditions where surface intensity is sufficient to move fire into 

crown fuels (summer season extreme weather) and crown fuels are continuous. Reducing crown fire 

potential of a surface fire will also reduce the potential for long range spotting. Table 31 represents the 

expected reduction in stand replacement potential, primarily crown fire, as measured by those stands that 

are converted from mid and later seral closed to mid and late seral open conditions.

Table 31. Fire Behavior Potential

Stand Type Alternatives Fire Type Flame 

Length

(ft.)

Rate of 

Spread 

(ch/hr)

Fire size in 1 

hour

(ac)

Mixed Conifer 

(GFDF)

Alt 1 

No Action

Passive Crown 8 18 12

Mixed Conifer 

(GFDF)

Post Treatment

Alts 2-4

Action

Surface 1 2.2 .2

Mixed Conifer

(PPDF1)

Alt 1 

No Action

Passive Crown 6 30 27

Mixed Conifer

(PPDF1)

Post Treatment

Alts 2-4

Action

Surface 4 16 7

Ponderosa Pine

(PPIN1)

Alt 1 

No Action

Passive Crown 14 126 460

Ponderosa Pine 

(PPIN1)

Post Treatment

Alts 2-4

Action

Surface 4 16 7
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Stocking level treatment effectiveness would last for 20 to 30 years (ladder and crown fuels), while 

surface fuel treatments are expected to remain effective for about 10 years. Maintenance burning would 

be used to maintain future stocking levels, control regeneration, and reduce surface fuel accumulation by 

maintaining fuel loading in the range of 7 tons per acre or less. 

Flame lengths would be reduced to 1 to 4 feet on treated acres (Table 12). Most fire behavior models 

show less than 10 percent mortality in overstory with flame lengths less than 4 feet. 

Long range spotting potential decreases as crown fire potential and flame lengths decrease and direct 

attack firefighting opportunities are increased.

Alternative 2, 3, and 4

As mentioned, the measure of percent landscape at risk of stand replacement fire (Figure 1) is directly tied 

to acreage treated, as most if not all treatments will have very similar effects on fuels across the three 

action alternatives. Alternative 2 will be the most effective at reducing the potential for stand replacement 

fire. Reduction in fire potential is seen in all biophysical settings. The overall landscape risk is reduced 

from an existing of 86 to 47 percent.

Alternative 3 is slightly less effective at reducing stand replacement potential, with a landscape risk of 52 

percent, while Alternative 4 is the least effective, with a residual landscape risk of 5 percent, 10 percent

higher than Alternative 2.

Figure 1

Fire regime condition class departure

Fire Regime Condition Class Departure is a measure, on a scale of 0 to 100, of the condition of both the 

vegetation and mean fire interval relative to historic averages. Treatment activities would reduce the 

departure of Fire Regime Condition Class (FRCC) on the existing landscape from 64 percent (high end of 

89

44

50

61

93

54

60 58

79

42

46

55

86

47

52

57

Existing Condition Alternative 2 Alternative 3 Alternative 4

% Biophysical Setting Predicted to Support 

Stand Replacement Fire

GFDF PPDF1 PPIN1 Landscape 
Chapter 3 Snow Basin Vegetation Management Project FEIS

94

Condition Class 2) to between 37 and 38 percent (low end Condition Class 2) (Table 32). This change 

when combined with future maintenance activities, primarily underburning, is expected to strengthen the 

capability of stands within the treated landscape to withstand disturbance events such as wildfire through 

reduced intensity and insect/disease outbreaks. Repeated application of surface fire as a maintenance 

process is expected to continue the reduction of Fire Regime Condition Class departure moving the 

landscape toward a condition class 1.

Alternatives 2, 3, and 4 all move FRCC departure from just below the FRCC 2-3 breakpoint, to the low 

end of FRCC 2. Alternative 2 will result in an improvement FRCC departure of 34 percent, followed by 

Alternatives 3 at 37 percent and Alternative 4 at 36 percent. FRCC modeling indicates an overall increase 

in departure for the cool/warm moist stands (GFDF) as a result of the proposed treatments, primarily due 

to the impact of more frequent fire return than called for by the models (Figure 2). This is a limitation of 

the model in this case small scale mosaic with dry site stands are not addressed by the FRCC system.

Table 32. FRCC departure and fire regime condition class

Landscape Existing-Alt 1 Alt 2 Alt 3 Alt 4

Percentile Landscape

FRCC Departure

64 34 37 36

Fire Regime Condition 

Class

2 (34-66%) 2 (34-66%) 2 (34-66%) 2 (34-66%)

Alternative 2

Alternative 2 treats the most acres and is a slightly more effective alternative relative to reduction of 

FRCC departure (Figure 2). Treatments in the two drier BpSs (PPDF1 and PPIN1) will be the most 

effective of the alternatives in improving both vegetative condition and fire regime departure. Treatment 

in the more moist sites GFDF will increase the vegetative condition and overall biophysical setting 

departure for the GFDF BpSs. 

Alternative 3 and 4

Alternatives 3 and 4 are slightly less effective in reducing FRCC departure, primarily due to reduced 

expected improvement in dry site FRCC departure, PPIN1. The removal of large trees that distinguishes 

alternative 3 from 4 will influence future regeneration and stand composition, but does not result in a 

change in current FRCC vegetation condition departure (the model does not capture this distinction).
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Figure 2

All treatment alternatives reduce the mid-seral closed stand component. Converting the mid-seral

component from a closed to open status in conjunction with maintenance burning will, over time, 

facilitate the development of late seral open structure. Treatment of dry site stands (PPDF1, PPIN1) will 

move that proportion of the landscape toward a more historical level of mid seral closed structure. 

Prescribed fire effects on moist sites (GFDF) are expected to reduce that portion of mid seral closed 

structure to below historical level for the GFDF BpS .

All treatment alternatives will reduce late seral closed stand structure on the landscape and result in an 

increase in late seral open structure. Perhaps more importantly, treatments modify stand structure such 

that prescribed fire can be used as a maintenance tool in the future to continue the shift toward the level of 

late seral open structure desired on the landscape.

Air quality

Several management techniques will be implemented to limit air quality impacts. The use of prescribed 

fire in this area would create a short-term smoke impact. This would be transient and may last for more

than 72 hours per occurrence. Prescribed burns would be planned so that factors such as wind direction 

and air mass stability would help limit the effects of smoke (e.g. smell, eye irritation) on local residents, 

campers, or the general public. In the evenings, the residual smoke would tend to follow the local wind 

patterns, flowing down slope in Eagle, Summit, or possibly the Pine Creek drainages towards Richland 

and Halfway. Experience from several burns in the area has shown that the effects of this smoke can be 

minimized by controlling length and time of ignition and burning under favorable mixing conditions for 

smoke dispersion. 

All burning will be conducted in compliance with Oregon DEQ requirements and applicable agreements. 

Burns will be registered, planned, accomplishment reported, and monitoring conducted as specified in the 

Oregon Smoke Management Plan (OAR 629-048, 2008). Burn plans will address smoke management 

concerns and requirements.

33

79

74

44

64

35

41 43

16

34

46

40

49

10

37

33

40

49

10

36

GFDF PPDF1 PPIN1 MGRA3 Landscape Departure

% FRCC Biophysical Setting Departure

No Action Alternative 2 Alternative 3 Alternative 4
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Wild and scenic river

Vegetation management and fuel reduction activities within the Wild and Scenic Corridor are expected to 

improve Scenic OR values by reducing the potential for large-scale, high-intensity fire that could impact 

the area. Specifically, management actions are expected to reduce the potential for the loss due to fire of 

desired vegetation described in the Wild and Scenic Plan, “late seral stages, large trees, and increased 

desirable species (ponderosa pine, larch, aspen, hardwoods) would be emphasized” (Environmental 

Assessment for the Eagle Creek Wild and Scenic River Management Plan, II-8).

In the short-term, visual impacts from prescribed burning are expected where burning is conducted within

the Wild and Scenic Corridor. Crown scorch, primarily in understory vegetation and the lower crowns of 

overstory trees, is expected to be evident following burning for 2 to 3 years. Mortality in brush, seedlings, 

and saplings will be evident (2 to 4 years). Some overstory mortality can also be expected and will be 

evident for 10 to 15 years. See the Wild and Scenic River Effects section and the Fire/Fuels specialist 

report for more detail.

Cumulative effects

Air quality

Air resources are somewhat unique in that, the past impacts to air quality are not usually evident. Smoke 

emissions during the spring and fall months primarily result from Federal prescribed fire activities (BLM 

and FS) in Northeast Oregon and Western Idaho. Federal land managers currently coordinate to manage 

the cumulative effects of prescribed burning across Northeast Oregon. Private landowners treating forest 

fuels in locations under the protection of Oregon Department of Forestry are required to follow the advice 

of the Department’s smoke management forecaster when burning.

Other emission concerns include summer wildfires, agricultural burning, and home heating in local 

communities. Both wildfires and agricultural burning typically occur mid- to late-summer. Home heating 

is generally limited to the winter months. In all three instances, the additional emissions produced are low 

and are not expected to impact air quality at the time prescribed fire activities are planned.

Under any alternative that calls for burning, there is a potential for future restrictions to meet air quality 

standards.

Climate change and fire

The combined effects of droughts and insects may lead to a pulse of tree mortality that increases the 

potential for intense fires. There are short- and long-term facets to the increase in potential fire intensity. 

In the short-term, warmer, drier conditions will limit the capacity of the ecosystem to maintain the 

quantity of vegetation currently growing on site. As this stress continues, vegetative capacity to resist 

insect, disease, and other disturbance mechanisms is reduced and the potential for mortality increases. 

Increased mortality provides additional available fuel for wildfire, thus increasing fire potential. Once the 

dead foliage drops, this danger may be considerably reduced for a few years. However, as the trees decay 

over the next decade or so following the pulse of mortality, they fall and can help create and accumulation 

of large, heavy fuels. These large fuels contribute to a longer-term potential for intense fires since they 

may take many years to decompose, especially in the dry environments of the West. 

Even in the absence of increased mortality from either drought or insects, a warming climate would likely 

alter fire regimes in ways that would make it more difficult to manage forests influenced by many 

decades of fire suppression and other activities. Climate change influences fire regimes in complex ways 

due to differentials in responses to variation in temperature and precipitation regimes. Both tree-ring 

records and modeling indicate that the probability of having fires is primarily driven by temperature, 

whereas the extent and intensity of fires is driven more strongly by precipitation patterns. Warmer 

temperatures lead to an earlier onset and later end for the drying period, thus increasing the probability of 
Chapter 3 Snow Basin Vegetation Management Project FEIS

97

a fire during the longer fire season. Precipitation influences the growth of vegetation (fuel). The amount 

of precipitation during the wet season will influence the amount of fuel produced.

All three action alternatives manage the forest ecosystem so that it is better able to accommodate climate 

change and to respond adaptively as environmental changes accrue. The action alternatives encourage 

gradual adaption to change to a warmer and drier environment by favoring disease and fire resistant trees, 

reducing stand density, and lowering fuel loadings. This would reduce the potential for catastrophic 

conversion due to climate change driven disturbance factors that are forecasted (see Forest Vegetation 

section).

Fuel treatments including prescribed fire

Past and ongoing Forest Service projects as well as adjacent ownerships and in-holdings of private 

property can influence management options for fuel treatments and prescribed fire. This applies to larger 

landscapes to be treated or wildland/urban interface areas that go untreated. Numerous recent fuel 

treatment activities have been planned and implemented or are pending implementation near the Snow 

Basin project area (Table 33). See Appendix B for a list of cumulative effects from projects/activities.

Table 33. Treatments by project area

Treatments Project Areas Names Acres Year Completed 

Rx Underburn Goose 348 2007, 2008, 2010

Rx Pile Burning Barnard, Sanger, East 

Eagle, Goose

1,384 2008-2010

Rx Underburning Barnard, East Eagle, 

Goose, Skookum

16,214 Planned, 2012-2019

Community assistance plans that identify additional wildland/urban interface and opportunities for fuels 

treatments in urban interface areas adjacent to national forests would enhance the Forest Service’s ability 

to treat areas adjacent to urban interface and in protecting high-risk, high-value areas. The ability to treat 

acres across agency boundaries and on private ownership contributes to long-term forest health, 

mitigation of large fires, reduction of suppression costs, and greater firefighter and public safety. The 

amount treated annually is difficult to predict due to a number of factors, but is predicted to increase. 

Management of wildfire

Other ownerships adjacent to or surrounded by lands administered by the Forest Service affect 

opportunities to use fire, and therefore to emulate historical wildland fire effects, on large landscapes. In 

general, private landowners use timber harvest rather than wildland fire to manage their vegetation. 

Wildland fire may be used to treat activity fuels, but treatments are often limited in extent and effect. 

Wildland Urban Interface (WUI)

Wildland urban interface will continue to change during the life of the forest plan. As community 

assistance plans are completed, additional WUI area can and will be added beyond what is currently 

identified. The trend indicates that people will continue to move to western states and build houses 

adjacent to NFS lands. This will have an effect on wildland fire and fuels projects with public input, in 

support or not, of those projects. It will also affect the use of wildland fire by limiting wildland fire in 

some areas because of social and political concerns. 

Other

Livestock grazing would continue to reduce fuel loading in fine herbaceous fuels and can limit fire spread 

rates. Fuelwood cutting would continue to remove large diameter fuels but this would have an 

insignificant effect on fuel loadings in the 0 to 3 inch diameter class, which is the fuels in which fire 

spreads.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Summary of Effects 

Vegetation and fuels treatments outlined in the three action alternatives all address, to differing degrees, 

the objective of, “Move the landscape toward a condition of reduced risk of high severity and extent of 

disturbance, taking into account changes in climate.”

The three action alternatives will result in a reduction in the intensity and severity of future summer 

wildfires. Through reduction of accumulated fuels and modification of stand structure toward a more 

open, fire-resilient spacing and species composition, treatments will increase management options for fire 

managers when determining how to deal with future wildfires.

Fire Regime/Condition Class departure is reduced from 62 to 37 percent across the landscape. The change 

in FRCC departure varies by biophysical environment, decreasing on treated dry sites and increasing on 

cool moist sites (due to fire frequency).

Reduced fire potential may increase opportunities to expand beneficial aspects of wildfires originating 

within the Eagle Cap Wilderness due to a reduced risk of adverse fire impacts and resistance to control for 

fire outside of the wilderness. Options to allow low-intensity fires to spread to existing or created barriers 

rather than containing at minimum acreage, particularly where fires have escaped initial suppression 

efforts, may allow for suppression strategies that increase firefighter safety and have potential to reduce 

both immediate and long term suppression costs.

Monitoring Recommendations

Fuels treatment effectiveness will be monitored using the Region 6 fuels monitoring protocol currently 

under development. The protocol uses a three-tiered system, involving a combination of short and longterm monitoring techniques. All Level 3 monitoring should be integrated with other resources. Final 

results will be documented using Fuels Quick Monitor or its replacement. A complete description of the 

Region 6 fuels monitoring protocol can be found in the Snow Basin Fire/Fuels Specialist Project File.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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SOILS

Existing Conditions

Soil Types 

In the Snow Basin project area, soils within the treatment units occur on 18 soil Landtype Associations. 

(LTAs) were mapped during a Terrestrial Ecological Unit Inventory (TEUI) assessment conducted on the 

Wallowa-Whitman National Forest (WWNF, 2002). The LTAs are a product of the interaction between 

soils, geology, landforms, vegetation, and climate. Soil types are useful because responses to management 

vary among soil types; including responses of vegetation, water quality and quantity, and soil itself. The 

TEUI integrates soils, geology, geomorphology, climate, and potential natural vegetation. Soil properties, 

suitability for forest management, landslide and erosion risk, and other management considerations were 

mapped. LTAs may consist of several soil series. LTAs are broad brush soil types, and usually contain 

contrasting inclusions. Thus an LTA with generally high erosion hazard soils probably has inclusions of 

low erosion hazard soils, and vice versa. 

In much of the area, residual soils were buried under, mixed, or have formed within a layer of volcanic 

ash deposited from the eruption of Mount Mazama approximately 6000 years ago. Soils with a high 

amount of ash in surface horizons are common in the project area. Ash cap soils are classified in the silt 

loam category. They are characterized by low bulk density, high porosity, and high water holding 

capacity. Because of the high water holding capacity, ash cap soils support vegetation that tends to require 

more moisture, such as grand fir, whereas soils that lack ash caps tend to support ponderosa pine or nonforest. Ash caps tend to be non-cohesive and because of their relatively low strength, are highly 

susceptible to compaction and displacement (Johnson, Page-Dumroese, and Han 2007). Soils on steep 

slopes are also susceptible to displacement.

Soil depth, combined with the depth of the unconsolidated material lying over bedrock in the project area 

ranges from very shallow (about a foot) to over ten feet. The surface soil layer is the layer that supports 

the root zone for fine and medium size roots. 

Parent material for soils includes basalts and other volcanic rocks, meta-sedimentary rocks, and glacial 

deposits. 

Detrimental Soil Conditions

Existing conditions

Existing conditions show the cumulative effects of past and on-going activities. 

Soil resource surveys for evaluation of soil conditions were completed on many proposed units by the 

project hydrologist during field seasons in 2008 to 2010. The results of the soil resource surveys are 

shown in Table 35. Most proposed units have a history of past timber harvest, with slash disposal, 

including some multiple entries on the same ground. Soil disturbance such as old skid trails and landings 

was widespread. Main skid trails were spaced approximately 50 to 100 feet apart. Compaction and 

displacement were primary types of detrimental impacts. However, some compaction from past activities 

is recovering due to root growth, burrowing of soil animals (such as rodents and arthropods), and freezethaw action. It was commonly observed that old skid trails typically had a high percent of ground cover. 

Old landings in many areas were re-vegetating, with some evidence of reduction in soil compaction. 

Roads, including abandoned roads, are also a significant source of detrimental impacts.

Road use and maintenance, livestock grazing, fuelwood cutting, activities associated with noxious weed 

treatments, recreation activities (including camping, All-Terrain Vehicle (ATV) use, snowmobile use, use 
Chapter 3 Snow Basin Vegetation Management Project FEIS

100

of trails), and past wildfire had minor impacts on soils within proposed units. The affected area is much 

less than 1 percent of the project analysis area.

Organic matter and nutrients

Decades of fire suppression have resulted in heavier forest floors, including more coarse woody debris, on 

most soils than would occur under the natural frequent fire regime. Thus, more nutrients are in the forest 

floor now. Thus, if moderate or high severity fires do occur, there is a potential for more loss of nutrients 

than under a frequent, low severity fire regime.

On many sites, water availability most likely limits productivity, rather than nutrients. For instance Shaw 

found that fertilization with nitrogen did not increase production in many ponderosa pine stands, though 

on moister sites basal area growth increased about 15 percent (1998).

Nitrogen probably has accumulated since fire suppression became effective, so that nitrogen levels 

probably are higher than in the 1800s. Fire usually decreases the amount of nitrogen on the land (though 

easily available nitrogen often increases for one to a few years). Significant underburning has not 

occurred in the area for many decades, so the loss of nitrogen during fires has not occurred. Nitrogen has 

accumulated as nitrogen from the atmosphere is stored in the organic matter of biomass, forest floor, and 

soil, especially due to the fixation of nitrogen by Ceanothus. On the other hand, some nitrogen has been 

removed by past harvests and fuel reductions. Boerner et al. found an average of about 140 lb/ac nitrogen 

removed in thinning and prescribed fire on six sites in western conifers (2008). Binkley indicates that 

nitrogen added in precipitation and free living fixation is about four lb/ac/yr (1991). So the nitrogen 

removed in a thinning would be replaced in about 35 years. With the added inputs from Ceanothus on 

many sites, nitrogen probably has accumulated above natural levels. 

Erosion and landslides

Surface erosion or recent slope instability was not evident in the project area outside of roads and trails, 

but many existing roads showed signs of surface erosion and rilling. Very little erosion was noted due to 

past timber harvest or prescribed burning activities. During soil resource surveys, it was commonly 

observed that there is little exposed mineral soil along re-vegetated skid roads, and old skid trails typically 

had a high percent of ground cover.

Slopes over 60 percent are at higher risk for landslides, and have been evaluated for landslide risks during 

TEUI mapping and by observations during soil resource surveys. Generally the project area is a stable 

landscape. Risk ratings for mass movement are mostly in the low to medium risk range. Some terrain is 

“hummocky,” indicating old healed deep-seated landslide deposits, but no recent mass failures such as

slumps or debris flows were found, even though much of the area has been previously harvested. Most 

sites are in the low to medium risk range for shallow, rapid landslides such as debris flows. Old landslide 

landforms were noted within the project area, especially on the east side. However, none appear active 

and none appear to be caused by past land management. There is evidence of very slow soil creep in 

steeper inner gorge areas, especially in the Little Eagle Creek drainage, but no evidence of recent larger 

scale mass soil movements were observed. The most unstable areas in the analysis area are found on 151 

unit acres in LTAs 168, 268, and 368 

Consistency with Laws, Regulations and Policy

The regulatory framework providing direction for protecting soil quality comes from the following 

principle sources. 

• FSM Region 6 USDA Forest Service 2520 – watershed protection and management R-6 

Supplement No. 2500.98-1
Chapter 3 Snow Basin Vegetation Management Project FEIS

101

• Wallowa-Whitman National Forest Plan (Forest Plan) and Regional Soil Quality standards (FSM 

R6 SUPPLEMENT 2500-98-1)

• “FSM Region 6 USDA Forest Service 2520 – watershed protection and management R-6 

Supplement No. 2500.98-1” provides soil quality standards that meet all legal and regulatory 

requirements for soil conservation. 

These standards give further definition to those in the Forest Plan. They require maintaining 80 percent of 

an activity area’s soil at an acceptable productivity potential with respect to detrimental impacts, 

including the effects of compaction, displacement, rutting, severe burning, surface erosion, loss of surface 

organic matter, and soil mass movement (USFS, 1984). The regional soil quality standards also state that 

the maintenance of sufficient organic matter and ground cover, both fine and coarse woody material, is 

essential for soil productivity.

The Wallowa-Whitman Forest Land and Resource Management Plan objective for soil is to manage the 

soil resource to maintain long-term productivity. The objective is that management activities on forest 

lands will not significantly impair the long-term productivity of the soil or produce unacceptable levels of 

sedimentation resulting from soil erosion. 

Soils

“Manage Wallowa-Whitman NF lands to maintain or enhance soil and land productivity,” (pg. 4-21).

Pertinent standards for this project include:

• Conflicts with other uses: Give maintenance of soil productivity and stability priority over uses 

described or implied in all other management direction, standards, or guidelines.

• Protection: Minimize detrimental disturbance to no more than 20 percent of an activity area.

• Protection: Re-establish vegetation following wild fire or management activities where necessary 

to prevent excessive erosion.

All alternatives will meet soil Forest Plan and Regional soil standards designed to maintain long-term soil 

productivity. Soil resource surveys, done during planning, indicate a current low to moderate level of 

detrimentally disturbed soil conditions (DSCs) from past activities (Table 35). All units sampled are now 

meeting the standard, and only one unit was identified as likely to exceed the standard after conventional 

dry season logging. This unit will have additional mitigation applied (required winter logging) to meet the 

standard. Predicted impacts are expected to increase the amount of DSCs, but are not expected to exceed 

the standard with the application of Project Design Criteria, Best Management Practices, and mitigation 

measures (see Snow Basin Vegetation Management Project Soils Existing Conditions and Projects 

Effects Report).

Methodology and Measurement Indicators

Detrimental Soil Condition

The indicator for this analysis is whether the alternatives are expected to meet the Standard of, “Minimize 

detrimental disturbance to no more than 20 percent of an activity area.”

The methodology used to analyze this indicator is the, “Interim Protocol for Assessment and Management 

of Soil Quality Conditions for the Wallowa-Whitman National Forest, Version 3.3.” This protocol is 

documented in Appendix A of the Soils Existing Conditions and Project Effects report for the Snow 

Basin Projects. This protocol was applied during the soil resource surveys from 2008 to 2010, by using

the transect method (Howes, 2001). For these assessments, each unit represents an activity area. Units 

were selected from throughout the project area to obtain a representative subsample of units proposed for 
Chapter 3 Snow Basin Vegetation Management Project FEIS

102

mostly ground-based treatments based on soil characteristics, past harvest amounts, and unit acreage. Soil 

resource surveys focused on units with prior logging, because effects of past harvest were expected to be 

greater in these units. Sampled units were thought to represent the full range of conditions in the project 

area. In units with non-existent or low (0 to 5 percent) adverse soil conditions, a Level 1 survey estimate 

of detrimental soil conditions (DSCs) was made visually. The contribution to DSCs from roads within 

harvest units was calculated and added to the DSC. For DSC calculations, GIS road mileage for each 

proposed harvest unit and prescribed fire unit was adjusted by excluding all roads that were adjacent to 

the units unless they were shared between units. 

Predicted DSCs for the action alternatives were calculated using models developed by soil scientists on 

the Wallowa-Whitman National Forest to describe effects forest management on soils. Effects of harvest 

and other treatments may be less or more pronounced in units located in different LTAs, depending on 

sensitivity. However, for this analysis it is assumed that the soil response to management impacts will be 

similar across different LTAs. Topographic factors, local soil texture, rock content, soil density, hill slope 

stability, and other factors all play a role in management response of soils and influence the effectiveness 

of soils effects models for predicting DSCs. For this analysis, these factors are assumed to be the same for 

all units. The models are based on post-project monitoring to estimate the DSCs generated by forest 

treatments (Bliss 2001, 2003, 2004). DSCs were calculated for units where soil resource surveys were 

done to determine the extent of post-project DSCs. 

The bounds of analysis for determining direct, indirect, and cumulative effects of the project’s activities 

on the soil resources are the project units. The temporal bounds for this analysis can be decades, however 

most detrimental soil impacts from this project will begin recovery after project activities are complete

Organic Matter and Nutrients

General knowledge of the area and scientific literature provide knowledge of organic matter and nutrients.

Erosion and Landslides

During soil resource surveys, observations about erosion and landslides were made. In addition, erosion 

processes are discussed in detail the Watershed Aquatics Specialist Report of this EIS including WEPP 

modeling of erosion from treatment units, as well as elsewhere in this chapter.

Effects Analysis

Direct and Indirect Effects

Alternative 1

Under Alternative 1 current management would continue. There would be no additional ground disturbing 

activities or vegetation removal; therefore there would be no potential for increasing detrimental soil 

conditions, erosion, or landslides above the existing levels. No nutrients or organic matter would be 

removed.

Implementation of Alternative 1 will not result in any new actions that cause a change affecting soils, and 

therefore will have no direct or indirect effects.

Alternatives 2, 3, and 4 

The indirect and direct effects of implementation of Alternatives 2, 3, and 4 on soil productivity in the 

project area are similar, but differ in degree. They will be discussed together in this section. Alternative 2 

(Proposed Action) has the greatest potential effect on soils, so this analysis will focus on Alternative 2 

effects, and contrast this alternative with the differences from Alternatives 3 and 4 (See Chapter 2 for 

descriptions of the alternatives).
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Detrimental Soil Conditions 

Table 34. Soil effects model assumptions, summary of effects models

Effects Model Disturbed soil conditions

Ground-based Harvesting Effects Model 10% new DSCs.

Skyline Yarding Effects Model 0-1% new DSCs.

Temporary Road Construction Effects Model 3.0 ac/mile DSCs.

Grapple Piling Effects Model 1-2% DSCs.

Grapple-Pile Burn Effects Model 1-2% DSCs.

Landing Slash Burn Effects Model 0.5-1% DSCs.

Hand-Piled Slash Burn Effects Model 0-1% DSCs.

Underburn Effects Model No DSCs.

Ground-based harvesting effects model

Local data (Bliss, 2003a) indicates felling, bunching, and skidding would disturb about 10 to 20 percent 

of the ground surface, with about 5 to 10 percent DSCs per unit before any subsoiling. Monitoring shows 

that about 50 percent of skid trail area to be detrimentally compacted and displaced. It is assumed that 

landings would occupy about 1 to 2 percent of a unit. The total effect of skid trails plus landings would 

generate 6 to 12 percent new DSCs. The range of possible effects is wide due to several variables 

including soil moisture, ground cover (vegetation type and woody debris tonnage), type of harvest 

equipment used, operator skill, layout, current infrastructure, past harvest effects, landform 

characteristics, and soil site conditions. 

New DSCs would be lower in units with DSCs from previous entries because old skid trails and landings 

that are detrimentally disturbed from past harvest can be reused. Based on conditions in Snow Basin 

units, an average of 10 percent DSCs are assumed to be generated by tractor/yarder harvest. 

Processor/forwarder harvest systems can be used in any ground unit, and are required in units with 

RHCAs, where processors and harvesters are proposed to be used to cross RHCAs. DSCs for 

processor/forwarder harvest are estimated to be 4 to 6 percent. Processor/forwarder effects are less 

because they use wider tires with less ground pressure, and operate on slash, which helps reduce soil 

compaction and displacement.

Skyline yarding effects model

Local data (Bliss 2004) indicates yarding would disturb 10 to 25 percent of the ground surface, and leave 

0 to 1 percent new DSCs in each unit. Most soil displacement would be less than 2 inches deep.

Temporary Road Construction Effects Model

Rehabilitation of temporary roads does not remove all DSCs, so temporary roads will leave 3.0 ac/mile 

DSCs.

Grapple piling effects model

The equipment to be used for grapple piling of woody debris would be a low ground pressure (5 to 6 psi) 

tracked excavator with a grapple on a 25 to 30 foot-long boom from the center of the vehicle. Normal use 

would track a maximum of about 8 percent of a treatment unit. Where fuels are less dense, less of the unit 

would be tracked. Total ground disturbance would be about 5 to 8 percent, with an estimate of 1 to 2 

percent DSCs (Kreger, 2004). 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Grapple-pile burn effects model

Burn effects are based on definitions in Debano et. al. (1998) and USFS (1998). Pile burn effects qualify 

as detrimental soil conditions if they are severe burns and occupy an area of at least 100 square feet 

(USFS, 1998). Local data from past projects in a similar area (Hanson, 2005) indicates grapple piles 

would occupy 1 to 2 percent of units (4 to 7 piles/acre up to 12 feet in diameter) and are typically more 

than 100 square feet. 

Landing slash burn effects model

Local data (Bliss, 2004) indicates slash piles at skyline landings are typically 100 to 1000 square feet in 

size (11 to 36 feet in diameter). When burned, these piles would cause about 0.5 to 1.0 percent DSCs. 

Slash piles in ground-based units can be larger, however DSCs from pile burning at landings would be in 

the same range.

Hand-pile burn effects model

Local data (Bliss, 2003a; Bliss, 2004; Hansen, 2005) indicates most of the area under hand piles would 

qualify as severe burn effects and burn piles typically occupy 1 to 4 percent of the ground surface, but are 

usually less than 100 sq. feet (11.3 feet) in diameter. Therefore, pile burning would cause only 0 to 1 

percent DSCs. 

Underburn effects model

Local data (Bliss, 2003a) indicates there would be 0 to 4 percent severe burn effects in underburn areas, 

but no DSCs, because severe burn areas would be less than 100 square feet.

Winter logging

Winter logging would cause an increase of about 3 percent DSCs, because landings and heavily used 

parts of skid trails would not be completely protected by two feet of snow.

Subsoiling

Subsoiling on skid trails within 150 feet of the landings would decrease DSCs. Subsoiling is not 

completely effective at loosening compaction, and does not restore displacement or detrimentally burned 

soil. But some of the existing compaction would be loosened, more than counterbalancing the new DSCs. 

Where all skid trails are subsoiled, the decrease in DSCs would be greater.

Summary of detrimental soil conditions

Direct and indirect effects

The most intensive treatment (ground based logging, with grapple piling and burning) proposed for this 

project is estimated to generate 13 percent new DSCs. Alternative 2 creates an estimated additional 1,163 

acres of detrimentally disturbed soil for ground-based logging, and 54 acres for skyline logging, with total 

detrimentally disturbed soils of 1,217 acres. Alternative 3 will create 1,108 acres of detrimentally 

disturbed soil, and Alternative 4 will create 1,056 acres of detrimental soil disturbance. 

Organic matter and nutrients

Some organic matter, including potential future coarse woody debris, and nutrients would be removed in 

logs and biomass, and they would be volatized during prescribed fires. See the Cumulative effects section 

below for further information.

Erosion and landslide potential

Logging increases erosion potential by removing ground cover and decreasing infiltration. For this project 

erosion is not expected to increase significantly as result of logging or prescribed fire, as indicated by 1)

past project monitoring, 2) WEPP model runs, 3) observations made during soil resource surveys by the 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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project Hydrologist, and 4) Region 6 ground cover standards will be met. Very little erosion was observed 

resulting from previous entries. The small, local increased erosion potential would return to pre-harvest 

levels as ground cover increases on bare areas (including temporary roads) over three years or less.

Alternative 4 would have the least potential for increased erosion, both due to lesser acres treated and the 

elimination of temporary road construction. 

Subsoiling would not increase erosion 1) because subsoiling increases infiltration, decreasing overland 

flow, and 2) because of the erosion mitigations, such as covering the subsoiled area with slash, and

avoiding a furrowed pattern. The action alternatives would not increase mass movement potential. One 

reason is the landscape is inherently stable to moderately stable, with relatively low precipitation. A 

second reason is that few units have even age regeneration harvest, so evapotranspiration and root 

strength will not be greatly decreased by harvest. Temporary roads will not be located on unstable 

landforms.

Cumulative effects

Cumulative effects common to all alternatives

Soils conditions in the project area reflect past impacts from vegetation management including timber 

harvest, road use and maintenance, livestock grazing, fuelwood cutting, activities associated with noxious 

weed treatments, recreation activities (including camping, ATV use, snowmobile use, use of trails), and 

past wildfire. Cumulative effects on soils from these other activities on project units are accounted for by 

soil resource surveys or estimates made and analyzed in the Soils Specialist Report. Cumulative effects 

from past management to soils are represented by DSCs, in that they reflect the cumulative impacts on 

soils from forest management. Cumulative effects include cumulative soil compaction, puddling, 

displacement, severe burning, erosion, mass wasting, and organic matter and nutrient loss. 

In the absence of additional impacts, DSCs usually naturally recover over time. DSCs can recover on 

some soil types in a few years to decades, while on other soil types DSCs require recovery times of 100 or 

more years without restoration treatments. Soil compaction will slowly decrease due to frost, plant roots, 

and animals (such as rodents and arthropods).

Ongoing actions

• Livestock Grazing (four allotments): represent much less than 0.1 percent existing DSCs from 

trails, water/salt areas, and no new DSCs since salting/watering areas and trails are established

• Fuelwood Cutting (annually): virtually un-measureable existing DSCs from this activity, any new 

impacts will be counterbalanced by recovery from existing impacts

• Noxious Weed Treatments along open roads (annually): noxious weed treatment causes 

negligible soil disturbance and no detrimental soil conditions, 0 percent DSCs

• Recreation (camping, ATV use, snowmobile use, use of trails to wilderness): DSCs amount very 

small, nearly un-measureable, may be locally significant, no new DSCs expected

Foreseeable future actions (in next 10 years):

• Private land development adjacent to project units: no soil impacts in units.

• Severe wildfire (if it occurs): erosion would increase due to reduced ground cover and possibly 

due to hydrophobic soils. Soil may be lost in the smoke plume. Nutrients would be volatized.

Alternative 1

Since there are no direct or indirect effects, there are no cumulative effects beyond those in the 

“Cumulative Effects Common To All Alternatives” section above. However, under Alternative 1, the 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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hazard of wildfire is higher than under the action alternatives (see Fire/Fuels Management Specialist 

Report), therefore the hazard of adverse effects from wildfire are higher under this alternative.

Alternatives 2, 3, and 4

Detrimental soil impacts

Cumulative effects to soils for this project are estimated by the existing and proposed future extent and 

amounts of detrimental soil conditions (DSC). DSCs estimate past soil cumulative effects, and are used in 

this report to show cumulative effects to soils from the proposed project, past activities, and other ongoing and future activities occurring in the project units. The extent and patterns of DSCs are an indicator 

and an effective way to determine how management has affected soils up to the present. Equipment use 

and soils effects models presented above provide a mechanism for determining specific future effects. 

Cumulative effects to soil are past, on-going, and reasonably foreseeable soil effects. See Appendix B for 

list of past, ongoing, and reasonably foreseeable activities considered. These impacts are most evidenced 

by increased soil compaction or soil displacement and other processes that lead to loss of soil 

productivity. Cumulative effects have been discussed in the Soils Existing Conditions and Project Effect 

Report for the Snow Basin Project for each project and non-project activity that affects soils. The results 

are summarized here. 

Existing DSCs were obtained from the soil resource surveys by the project Hydrologist. The results are 

shown in Table 35 below.

Using the models presented in the Methodology section above, effects of planned treatments were 

estimated for treatment units in the Proposed Action. The results of that analysis are shown in Table 35

below.

Table 35. Existing and proposed action detrimental soil conditions in surveyed treatment units based on 

soils resource surveys and effects models

Unit

Existing 

DSC's (%)

PostHarvest 

DSC's Unit

Existing 

DSC's (%)

PostHarvest 

DSC's

5 4 17 272 3 4

6 3 16 274 4 17

8 4 4 275 4 17

7 5 18 265 5 6

11 5 18 266 5 18

34 5 18 278 3 16

28 6 7 279 3 4

137 4 5 219 3 4

107 5 18 220 4 17

113 3 16 282 6 19

33 4 17 234 4 17

132 4 5 347 4 17

133 4 17 350 4 17

128 6 19 316 5 18

129 6 19 315 3 16

121 10 15* 319 3 16
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Unit

Existing 

DSC's (%)

PostHarvest 

DSC's Unit

Existing 

DSC's (%)

PostHarvest 

DSC's

50 3 16 307 4 17

87 4 17 310 4 17

88 4 17 311 4 17

48 2 15 314 4 17

49 5 18 313 4 17

57 6 19 303 4 17

235 6 19 300 2 15

54 4 17 301 2 15

75 4 17 400 3 16

240 3 16 403 3 16

241 3 16 404 3 16

244 5 18 407 3 16

245 5 6 411 2 15

253 4 5 412 4 17

262 2 15 415 4 17

269 4 17 420 4 17

270 3 16 237 2 15

271 3 16 239 2 3

Note: DSCs will not exceed 20 percent in unit 121 by requiring winter logging or other mitigation

DSC’s from sampled units range from 2 to 10 percent averaging about 4 percent. The average unit total 

cumulative post-project DSCs would be 17 percent for project units, ranging from 3 to 19 percent.

Organic matter and nutrients

Logging would remove nutrients and organic matter (including potential future coarse woody debris) in 

logs and foliage (where whole tree yarding is used), and fuel reduction treatments would remove nutrients 

and organic matter during burning and biomass utilization. The removal, especially removal of nitrogen, 

may decrease site productivity a few percent on some sites. However, on many or most sites, productivity 

likely is limited by drought, not by nutrients or surface organic matter. Also, removal of nutrients would 

be limited because most nutrients would remain in the soil, in the forest floor, and in the remaining trees. 

Before fires were suppressed, little forest floor or coarse woody debris existed because low severity fires 

burned it up. These high fire frequency ecosystems have persisted for thousands of years with low levels 

of organic forest floor and coarse woody debris. These ecosystems are adapted to low levels of organic 

matter, so removal of unnatural levels of organic matter would have little adverse effect.

Erosion and landslides

Since the direct and indirect effects on erosion and landslides are negligible, the cumulative effects are 

negligible.

Monitoring Requirements

BMPs and other methods for erosion control such as water bars, subsoiling limiting operating seasons, 

designated skid trails, or the use of existing landings and skid trails, etc. are effective measures for 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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rehabilitating or minimizing potential soil impacts. The analysis of effects included implementation of 

these mitigations to help reduce soil erosion and other effects, and help maintain DSC levels within Forest 

Plan standards for all action alternatives. Effectiveness monitoring of BMPs will take place during and 

after project activities for a percentage of units. BMP implementation monitoring, which is evaluation of 

whether BMPs are used during the project, is also going to take place. This monitoring will be carried out 

by the timber sale administrator, the district hydrologist, or soil scientist. 

Aerial photography interpretation was conducted for all units in the planning area to estimate detrimental 

soil disturbance, as part of pre-implementation monitoring on units. Aerial photo interpretation represents 

the potential worst case scenario, and because of the estimates for detrimental soil disturbance identified 

in Table 35, the Forest Service will conduct pre- and post-implementation monitoring to ensure project 

activities are compliant with Forest Plan standards and guidelines. This monitoring will be carried out by 

a soils scientist. Special emphasis for monitoring and additional field verification is recommended for the 

following units: Units 48, 49, 50, 51, 52, 87, 105, 106, 112, 117, 119, 121, 128, 129, 130, 134, 135, 248, 

249, 256, 262, 266, 269, 276,310, 315, 316, and 424. For any units found to not meet standards and 

guidelines mitigations will be implemented, restoring soil conditions to within acceptable parameters. 

Mitigations are described in Appendix B-1. Photo interpretation analysis is located in the project file. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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WATERSHED AQUATICS 

Regulatory Framework

The following laws, regulations, and management directives for fish and watershed resources apply to this 

project:

• The Wallowa-Whitman National Forest Land and Resource Management Plan (LRMP, 1990)

• The Interim Strategies for Managing Inland Native Fish producing Watersheds in Intermountain, 

Northern and Pacific Northwest Regions (INFISH, 1995) amendment to the LRMP. INFISH 

provides management direction in the form of Riparian Management Objectives (RMOs), 

Riparian Habitat Conservation Areas (RHCAs), and standards and guidelines for management 

activities.

• Eagle Creek is a Wild and Scenic River and managed under the Eagle Creek Wild and Scenic 

River Management Plan (1994). River segments within the Snow Basin Planning Area are 

designated Recreational and Scenic. The Scenic segment is from Paddy Creek south to Little 

Eagle Creek. The Recreational segment is from Paddy Creek north to the Eagle Cap Wilderness 

boundary.

• The National Forest Management Act (NFMA, 1976) requires the Forest Service manage for a 

diversity of fish habitat to support viable fish populations. Regulations of NFMA (219.12g) state, 

"Fish and wildlife habitats will be managed... to maintain and improve habitat of management 

indicator species." 

• Section 7 of the 1973 Endangered Species Act (ESA) includes direction that Federal agencies will 

not authorize, fund, or conduct actions that are likely to jeopardize the continued existence of any 

threatened or endangered species or result in the destruction or adverse modification of their 

critical habitat. 

o Note: There are no ESA-listed fish or aquatic invertebrates present in the project area.

However, critical habitat for bull trout is present.

• The Clean Water Act (CWA), also known as the Federal Water Pollution Control Act, represents 

landmark legislation for protecting water resources. Section 208 of the 1972 amendments to the 

Federal Water Pollution Control Act (Public Law 92-500) specifically mandated identification 

and control of non-point source pollution. The CWA delegates certain authorities to individual 

states. CWA Section 303(d) requires the State of Oregon to list Water Quality Limited 

Waterbodies (303(d) listed streams), and develop Total Daily Maximum Loads (TMDL) and 

Water Quality Management Plans (WQMP) to control the non-point source pollutants causing 

loss of beneficial uses. A beneficial use of water refers to the specific criteria required to support 

a specific use of water. For example, cold-water fisheries require cool or cold water temperatures 

and low turbidity.

o Section 313 of the CWA requires Federal agency compliance with water pollution control 

mandates that apply to “any nongovernmental entity” or private person. Federal actions shall 

comply with, “all Federal, State, interstate, and local requirements, administrative authority, 

and process and sanctions respecting the control and abatement of water pollution.” A 

Memorandum of Understanding (MOU) with ODEQ is developed to comply with State 

Water Quality Standards. The MOU outlines responsibilities for both the Forest Service and 

ODEQ. The Forest Service agrees to apply all reasonable land, soil, and water conservation 

practices, often referred to as Best Management Practices (BMPs). These “performance 

standards” are designed to protect and maintain soil and water resources, thus maintaining 

beneficial uses.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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o Note: There are no streams listed on the 2004/2006 ODEQ 303 (d) list as water quality 

limited in the Snow Basin project area.

• Forest Service Policy: Policy for protection and improvement of soil and water resources include: 

The National Non-point Source Policy (December 12, 1984); the Forest Service Non-point 

Strategy (January 29, 1985); and the USDA Non-point Source Water Quality Policy (December 

5, 1986). Soil and water conservation practices were recognized as the primary control 

mechanisms for non-point sources of pollution on National Forest System lands. This perspective 

is supported by the Environmental Protection Agency (EPA) in their guidance, “Nonpoint Source 

Controls and Water Quality Standards” (August 19, 1987). Policy is further defined by Forest 

Service Manual (FSM) direction. FSM sections 2532.02 and 2532.03 describe the objectives and 

policies relevant to protection and improvement of water quality on National Forest System 

Lands to maintain designated beneficial uses. Guidelines for data collection activities (inventory

and monitoring) are also described (USDA, 1990).

• Executive Order 11988 (Floodplain Management) requires that agencies avoid, to the extent 

possible, adverse impacts associated with occupancy and modification of floodplains. It applies at 

a minimum to areas within the 100-year floodplain (Executive Order 1977).

• Executive Order 11990 (Wetlands) states that agencies shall minimize destruction, loss, or 

degradation of wetlands and shall preserve and enhance their natural and beneficial values. 

Agencies are to avoid construction in wetlands unless it is determined there is no practicable 

alternative and all practicable measures are taken to minimize harm to wetlands (Executive Order 

1977).

Aquatic Habitat

Effects Analysis Area

The analysis area for watershed processes encompassed in the project area includes two main 

subwatersheds, Eagle Creek/Paddy Creek and Little Eagle Creek subwatersheds. Because effects to 

aquatic habitat are unlikely to stop at the downstream boundary of the project area, the aquatics effects 

analysis area (“analysis area”) includes all streams in the project area and Eagle Creek from the project 

area boundary downstream to the Forest Boundary (about one mile downstream from the project area).

Measurable effects to aquatic habitat from proposed activities are unlikely to extend downstream of this 

point. 

Time frames for the direct/indirect effects discussion for watershed processes and aquatic habitat are: 1) 

short-term, 0 to 5 years; 2) mid-term, 5 to 10 years; and 3) long-term, more than 10 years.

Forest Plan Aquatic Habitat / Riparian Desired Future Conditions

The WWNF Forest Plan was amended in 1995 with the INFISH Forest Plan Amendment. INFISH 

established goals for aquatic and riparian habitat (1995). The goals of INFISH are to maintain or restore:

• Water quality, to a degree that provides for stable and productive riparian and aquatic ecosystems

• Stream channel integrity, channel processes, and the sediment regime (including the elements of 

timing, volume, and character of sediment input and transport) under which the riparian and 

aquatic ecosystems developed

• Instream flows to support healthy riparian and aquatic habitats, the stability and effective function 

of stream channels, and the ability to route flood discharges

• Natural timing and variability of the water table elevation in meadows and wetlands

• Diversity and productivity of native and desired non-native plant communities in riparian zones

• Riparian vegetation to:
Chapter 3 Snow Basin Vegetation Management Project FEIS

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o Provide an amount and distribution of large woody debris characteristic of natural aquatic and 

riparian ecosystems

o Provide adequate summer and winter thermal regulation within the riparian and aquatic zones

o Help achieve rates of surface erosion, bank erosion, and channel migration characteristic of 

those which the communities developed

• Riparian and aquatic habitats necessary to foster the unique genetic fish stocks that evolved 

within the specific geo-climatic region

• Habitat to support populations of well-distributed native and desired non-native plant, vertebrate, 

and invertebrate populations that contribute to the viability of riparian-dependent communities

Forest Plan Riparian Management Objectives

Effects to riparian and aquatic habitats are minimized by restricting management activities in Riparian 

Habitat Conservation Areas (RHCAs) (INFISH, 1995). RHCA widths for the Snow Basin Project are 

displayed in Table 36. RHCA boundaries are estimated in GIS for planning and analysis purposes. 

RHCAs are delineated and marked during sale layout activities.

Table 36. RHCA widths for Snow Basin project area

RHCA Category Stream / Feature Type Description

1 Fish bearing streams

Distance equal to 2 site potential trees or 300 

feet slope distance from the edge of the active 

channel, whichever is greatest

2 Perennial non-fish bearing streams

Distance equal to 1 site potential trees or 150 

feet slope distance from the edge of the active 

channel, whichever is greatest

3 Ponds, wetlands (≥1 acre in size)

Distance equal to 1 site potential trees or 150 

feet slope distance from the edge of the active 

channel, whichever is greatest

4 Intermittent non-fish bearing streams, 

wetlands (<1 acre in size)

Distance equal to 1 site potential trees or 100 

feet slope distance from the edge of the active 

channel, whichever is greatest

4 Landslides and landslide-prone areas

Distance equal to 1 site potential trees or 100 

feet slope distance from the edge of the 

landslide or landslide-prone areas, whichever is 

greatest

Default INFISH RHCAs and RMOs are used in this analysis. INFISH allows the development of site 

specific RHCA widths and RMOs when justified by a watershed analysis (INFISH, 1995). A watershed 

analysis was completed for the Eagle Creek system in 1997. The Eagle Creek Watershed Analysis did not 

recommend changes in RHCAs widths or RMOs (1997). Analyses of INFISH RMOs for pool frequency 

and width-to-depth ratios compared to watershed conditions were completed but specific changes to the 

RMOs were not recommended. 

There are 10 fish-bearing (INFISH Category 1) streams in the analysis area (Figure 3). There are 27.6 

miles of Category 1 streams, 44.7 miles of Category 2 streams, and 18.9 miles of Category 4 streams in 

the project area. Major streams (Category 1 and 2) in the analysis area are displayed in Table 37.
Chapter 3 Snow Basin Vegetation Management Project FEIS

112

Figure 3. INFISH stream categories and WWNF stream classes (in parenthesis) in the Snow Basin 

project area
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Chapter 3 Snow Basin Vegetation Management Project FEIS

114

Table 37. Major streams (Category 1 and 2) and miles in Snow Basin aquatic effects analysis area

Major Stream Stream 

Category Miles Major Stream Stream Category Miles

Basin Creek 2 1.9 Long Creek 1 2.5

Cabin Creek 1 1.7 Packsaddle Creek 2 1.0

Conundrum Creek 1 3.1 Paddy Creek 1 1.9

Dempsey Creek 2 2.6 Puzzle Creek 2 1.7

Eagle Creek 1 10.5 Shanghai Creek 2 1.1

Ethel Creek 2 1.7 Snow Fork Creek 1 2.1

Gold Creek 1/2 2.5 South Fork Spring Creek 1/2 2.1

Holcomb Creek 2 4.6 Spring Creek 1 2.4

Little Eagle Creek 1 6.9 Twin Bridge Creek 2 1.6

A majority of streams in the analysis area, 92 percent, are higher gradient streams with gradients above 2 

percent (Table 38). Stream reaches with gradients <2 percent are normally considered to be response 

reaches (e.g. Rosgen C channels) whereas stream reaches with gradients >2 percent are considered to be 

transport reaches (e.g. Rosgen B and A channel types).

Table 38. Gradient of streams in the Snow Basin project area

Gradient Miles Rosgen Channel Type

≤2% 12.6 C

>2 & ≤ 4% 11.9 B

>4 & ≤6% 13.4 B/A

>6% 116.8 A

In general, perennial streams in the analysis area typically have well developed riparian areas and 

floodplains. Conifers are the dominant vegetation outside of RHCAs. The average height of site potential 

trees adjacent to both perennial and intermittent streams is 80 to 100 feet (Jim Gilsdorf, Silviculturalist, 

Whitman RD). Conifers typically provide shade and woody debris inputs to the channel and riparian area.

Riparian obligate vegetation such as willows, sedges, and alders provide bank stability, shade, and 

allocthonous nutrient inputs for streams. Intermittent drainages have less well-developed riparian 

vegetation, often not supporting riparian obligate vegetation due to the lack of year-round flow.

Ephemeral draws often have no riparian vegetation associated with them, because water is only present 

following large rainfall or spring snow melt events.

Critical aquatic habitat elements as defined by the Wallowa-Whitman National Forest 1990 Land and 

Resource Management Plan (“Forest Plan”; including the 1995 INFISH amendment) and the 1995/98 

Biological Opinions (BOs) for the Forest Plan include: 1) pool frequency, 2) water temperature, 3) large 

woody debris, 4) bank stability, 5) width to depth ratio, and 6) fine sediment levels. These habitat 

elements are important indicators of aquatic habitat function and health. 

Stream surveys have been completed on 6 of the 10 fish-bearing streams in the project area. The most 

recent stream survey data for fish-bearing streams data are summarized in Table 39. Stream survey data is 

dated for most of the streams, predating the 1996/97 New Year’s flood event, and is of limited usefulness. 

Cindy Cleveland (TEAMS Fish Biologist) surveyed stream conditions in the project area by walking 

drainages located in proposed treatment areas during June of 2009. Her observations of Category 4
Chapter 3 Snow Basin Vegetation Management Project FEIS

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streams indicate that these streams in general do not have adequate quantities of large woody debris 

(LWD) to support channel long-term stability and sediment retention.

Fish habitat in the analysis area generally does not meet INFISH RMOs for pool habitat and width-todepth ratio in the analysis area (Table 39). Pool habitat in particular is lacking in the project area. LWD 

levels generally meet the RMO. In general, pool habitat increases as LWD increases (Dollof and Warren, 

2003). However, there does not appear to be a relationship between LWD and pool habitat in steeper 

streams (Montgomery et al., 1995) or in streams with low stream power (Jackson and Sturm, 2002). As 

noted earlier, the majority of streams in the analysis area are high gradient streams (Table 38), including 

fish-bearing streams which have been surveyed (Table 40), which may reduce the pool forming function 

of LWD. Another confounding factor in the linkage between LWD and pool habitat is the lack of 

consistency in the definition of LWD used in various studies.

A pool habitat analysis was completed in the Eagle Creek Watershed Analysis (1997). Relationships 

between pool frequency, large woody debris, stream width, and stream gradient were analyzed to 

determine if these stream characteristics were correlated. Small woody debris (6 to 12 inch diameter, 20

to 35 feet long) and wetted stream width were found to be significant predictors of pool frequency. Pool 

frequency was not related to LWD and total LWD (i.e. sum of small and large size class LWD). (Note: 

INFISH LWD size class is >20inch diameter and >35 feet long) While a causative factor for low pool 

frequencies was not identified in the watershed analysis, pool habit has likely been reduced by past 

management activities (see Cumulative Effects Section).

Table 39. Habitat summary data for category 1 streams in the Snow Basin project analysis area

Shading indicates where a habitat element is meeting Forest Plan RMOs. N/D = No data.

Stream Name

Year of 

Stream 

Survey

Ave 

Wetted 

Width

Pools/Mile1 Pieces 

LWD/Mile

% 

Particles 

<6.3mm

W/D 

Ratio

Streambank 

Stability1 Median Gradient2

Eagle Creek 1991 27.7 5.4 34.0 N/D 21.0 >80% 2.6%

Conundrum 

Creek 1993 4.4 5.0 9.4 N/D 7.3 >80% 12.4%

Little Eagle 

Creek 2009 14.1 47.7 48.8 12.5 13.5 >80% 5.9%

Paddy Creek 1991 8.8 21.0 21.0 N/D 16.8 >80% 9.0%

Spring Creek 1993 8.5 12.2 47.0 N/D 5.1 >80% 9.9%

Snow Fork 

Creek 1993 4.6 12.5 24.2 N/D 8.5 >80% 7.1%

RMO/Indicator See Note 3 ≥20 <20% ≤10 ≥80 N/A

*1) Based on 2009 field observations 

*2) Based on GIS stream gradient analysis

*3) RMO based on stream wetted width: < 10 ft, > 96 pools/mile, 10 to 20 ft, 56 to 96 pools/mile, 25 to 50 ft, 26 to 47 

pools/mile

Fine sediment data for streams in the project area is limited. Stream survey data for Little Eagle Creek 

indicates fine sediment levels are moderate. Observations by Dave Salo (WWNF Forest Hydrologist) 

indicate general fine sediment levels in streams in the project area are at moderate levels (< 20 percent), 
Chapter 3 Snow Basin Vegetation Management Project FEIS

116

with higher levels in low gradient reaches in the project area. The Eagle Creek Watershed Analysis 

identified high fine sediment levels in Ethel Creek and Snow Fork Creek (1997).

Half of streams surveyed in the analysis area do not meet the INFISH RMO for width-to-depth ratio (<10,

Table 39). However, the INFISH RMO was developed prior to advances in our understandings of the 

relationship between width-to-depth ratios and natural channel forms (sensu Rosgen, 1996). Normal 

ranges for width-to-depth ratios (bankfull width) for Rosgen B and C channels are 12 to 20 and 13.5 to 

28.7 (Rosgen, 1996). All surveyed streams in the analysis area, except Eagle Creek, are within the normal 

range for width-to-depth ratios for their respective Rosgen channel types (Table 39). The width-to-depth 

ratio for Eagle Creek is slightly higher than the normal range; 21.0 compared to 20 for Rosgen B 

channels. Eagle Creek has a mix of Rosgen C and B channel types which may partially explain the 

slightly higher than normal width-to-depth ratio.

Observations made during the 2009 stream evaluations in the project area indicated that stream stability 

was generally high and met the 80 percent stability standard (Table 39). Many of the streams are located 

in inner gorges, and have rocky well-vegetated banks; typical of Rosgen B-type channels.

Direct and Indirect Effects to Watershed Processes

Water Yield and Streamflow

Existing condition

The climate of the project area has four distinct seasons and is characterized by dry warm summers and 

cold winters with a consistent snowpack forming each year. Annual precipitation amounts vary from near 

25 inches at lower elevations to over 40 inches at higher elevations. Most of the annual precipitation falls 

as snow. Streamflow discharges in project subwatersheds are characteristic of a snowmelt hydrograph, 

with late spring and fall rains contributing to the annual average flows. Peak flows usually occur in May 

and June and subside to baseflows by late July. Minimum discharges occur in late August and September. 

The Brooks Ditch is a major irrigation ditch running through project area that is fed by a network of 

smaller streams and Little Eagle Creek.

A cursory baseflow analysis was performed to determine a unit-area discharge during late summer, 

comparing tributaries west of Eagle Creek with those east of the mainstem (D. Salo, 2011). Flow 

measurements were made at select culverts, and correlated with drainage area. Puzzle Creek requires the 

most amount of acres to produce one gallon-per-minute (GPM) flow. It appears that the headwaters of 

Little Eagle Creek have a much higher unit-area discharge during low-flow periods than streams on the 

west side of the project area (Figure 4). However, the Brooks Ditch captures most of this flow during the 

irrigation season and delivers it to farm and ranchland in the Eagle Valley. As a result, flows in lower 

Little Eagle Creek are reduced by about 75 percent during late summer, based on 2011 summer field 

estimates.

The nearest continuous stream gage is located on the mainstem Eagle Creek near Newbridge, about six

miles downstream of Snow Basin. Data is available at the USGS website

(http://waterdata.usgs.gov/or/nwis/current?type=flow). This data is only an approximation of Eagle Creek 

flows during the irrigation season as diversions exist between the Forest Boundary and the gauging 

station.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Figure 4. Baseflow discharge per unit area for select tributaries

Source: D. Salo, field measurements 2011

Methodology and Measurement Indicators

The Equivalent Clearcut Area (ECA) methodology (King, 1989) provided an initial screening for any 

predicted changes in the streamflow regime as a result of proposed activities. If ECA thresholds are met 

or exceeded, further analysis and/or monitoring will help determine the degree of change and potential 

issues with stream function and stability. In general, an ECA >15 percent indicates that water yield may

have increased above background levels. 

Direct and Indirect Effects of Alternative 1-No Action

Alternative 1 does not implement any vegetation management, prescribed burns, temporary road 

construction, road maintenance, or aspen enhancement activities. All current management activities 

would continue in the project area. Activities include livestock grazing, diversion of water out of Little 

Eagle, Spring, and Ethel Creeks into Summit Creek via the Brooks Ditch for irrigation purposes, 

recreation, woodcutting, road maintenance, and wildfire suppression. While some repair of Forest Road 

(FR) 77 is planned for 2012, other road improvements including drainage and stabilization are not 

planned. Since current activities would continue, no changes in water yield or streamflows would occur in 

the short-term.

Without treatment of fuels and overstocked stands, the risk for fire, even uncharacteristic severe fire is 

subject to increase over time (see Fire/Fuels Management Specialist Report). Whether uncharacteristic 

high-severity fire could translate into a change in soil-water function at a scale sufficient enough to affect 
Chapter 3 Snow Basin Vegetation Management Project FEIS

118

the streamflow regime would require the entire sequence of events to occur: 1) A fire that covers a large 

enough portion of watershed to produce potential effects. 2) Burn severity of moderate to high on 50

percent or more within the burn perimeter. 3) A storm event or rapid snowmelt of sufficient intensity that 

occurs within three years of the fire. Recent wildfires in the western United States often result in up to 50 

to 60 percent of the burned area in moderate to high burn severity (Lentile et al., 2007). For these reasons, 

it becomes difficult to quantitatively predict risks to watersheds by not treating fuels and overstocked 

stands. Other potential future effects like changes in stream temperature or LWD recruitment are better 

correlated to deterministic post-fire situations, but remain subject to spatial and magnitude variations in 

fire behavior.

A large wildfire event could affect streamflow regimes with possible higher peak flows, higher base flows 

(due to reduced transpiration), and greater annual volume amounts. In the absence of large wildfires, 

stream discharges are expected to follow current flow regimes. 

Summary of Effects

In summary, the streamflow regime indicators will likely remain static. In the event of a wildfire with 

sufficient scope and intensity to produce watershed effects, all indicators would experience some degree 

of effects. Predicting those effects to any degree of certainty becomes very problematic due to all the 

variables involved.

Direct and Indirect Effects of Alternative 2, 3, and 4

The ECA analysis represents a coarse-scale approach for screening potential indirect effects to 

streamflow regime from timber harvest and roads (USDA, 1974). The Matrix of Diagnostics, Pathways 

and Indicators used in Biological Opinions and Evaluations (United States Fish and Wildlife Service) use 

a recommended value of >15 percent to indicate potential cumulative changes in peak flow, which could 

affect channel stability. Table 40 displays existing and projected ECA values in the project watersheds.

An acre of thinning treatment is equivalent to a fraction of an acre of clearcut harvest. Alternative 4 

would result in the least amount of overall disturbance in the project area, but essentially only 1 to 2

percent less than Alternatives 2 and 3. The result of considering all past and proposed treatment acres 

within each subwatershed retains ECA values below the 15 percent threshold of concern. No change in 

the streamflow regime is expected as changes in ECA are nominal, and total ECAs for Eagle Creek and 

Little Eagle Creek are below 15 percent.

Table 40. Current Equivalent Clearcut Area (ECA) and Predicted ECAs for the Snow Basin Project

Subwatershed Existing ECA

(%)

Alternative 2

ECA (%)

Alternative 3

ECA (%)

Alternative 4

ECA (%)

Little Eagle SWS 5 9 9 7

Paddy-Eagle SWS 5 11 10 10

Summary of Effects

All three action alternatives express similar direct, indirect, and cumulative effects with immeasurable 

variances between them for streamflows. The variances between action alternatives cannot be determined 

in terms of measureable effects between any of the indices. In other words, differences in actions like 

treatment acres of timber harvest or prescribed fire will not result in measureable differences in 

streamflow regime. Analyzing differences in streamflow effects for the different action alternatives on a 

project of this scale becomes inconclusive.
Chapter 3 Snow Basin Vegetation Management Project FEIS

119

Erosion and Sedimentation

Existing condition

Erosion and sedimentation are geomorphic processes that shape the physical appearance of the landscape 

and strongly influence aquatic ecosystems. The range of natural variability for sediment delivery to 

streams and wetlands within the planning area is considered to be very large because erosional processes 

are influenced by infrequent natural disturbance events such as floods and wildfire. Sedimentation rates to 

streams are typically inconsequential on a year to year basis, but can spike several orders of magnitude 

during large storm events. Land management has the potential to accelerate erosion rates and the volume 

of sediment entering streams and wetlands.

Timber harvest activities including harvest, yarding and haul can potentially increase the delivery of 

sediment to streams. The primary potential source of sediment from harvesting is derived from ground 

disturbing activities, primarily summer dry season tractor harvest systems and, to a much less degree,

winter logging.

Roads can also be a substantial source of sediment as well as a mechanism for delivering sediment to 

stream systems. Forest roads can affect surface runoff patterns, erosion, and sedimentation that may affect 

aquatic organisms (Trombulak and Frisell, 2000). Roads can also serve as a link between sediment 

sources areas and stream channels through sediment delivery (Wemple et al., 1996).

One of the important variables influencing the effects of project activities on hydrology and sediment is 

proximity of activities to stream channels (Rashin et al., 2006). A research study on buffers found that of 

212 erosion features within 10 meters (approximately 30 feet) of a stream, 67 percent of the features 

delivered sediment to the stream. Of 193 erosion features greater than 30 feet from a stream, 95 percent 

did not deliver sediment to the stream. 

Forest road impacts on sediment yield often correlate with road density within RHCAs and the number of 

stream crossings. Additionally, the connectivity between roads and streams can be affected by soil 

conditions, slope steepness, and road standards. The distance that sediment travels from road sources is a 

function of volume, obstructions, hill slope gradient, and source area (Megahan and Ketcheson, 1996). 

Roads can directly affect channel morphology by accelerating erosion and sediment delivery and by 

increasing the magnitude of peak flow (Furniss et al., 1991). 

Past timber harvest and associated roads have increased sediment delivery from logged watersheds during 

and after past projects in the project area. Excessive sediment can negatively affect beneficial uses of 

water including fish habitat, municipal water use, irrigation water, and other uses.

INFISH Standards and Guidelines for existing roads within RHCAs include minimizing sediment 

delivery to streams from the road surface; closing and stabilizing, or obliterating and stabilizing roads not 

needed for future management activities; improving stream crossings to accommodate a 100-year flood; 

and providing and maintaining fish passage at all road crossings of existing and potential fish-bearing 

streams.

Direct and Indirect Effects of Alternative 1

Alternative 1 does not implement any vegetation management, prescribed burns, temporary road 

construction, road maintenance, or aspen enhancement activities. All current management activities 

would continue in the project area. Activities include livestock grazing, diversion of water out of Little 

Eagle, Spring, and Ethel Creeks into Summit Creek via the Brooks Ditch for irrigation purposes, 

recreation, woodcutting, road maintenance, and wildfire suppression. While some repair of FR 77 is 

planned for 2012, other road improvements including drainage improvement are not planned.
Chapter 3 Snow Basin Vegetation Management Project FEIS

120

The amount of sediment entering the streams under the Alternative 1 is expected to remain the same 

unless there is: 1) an increase in grazing use and grazing pressure on the tributary stream banks, 2) road 

failures, 3) landslides, 4) increase in mining activity and/or 5) a wildfire. Inputs of sediment from 

livestock use in the analysis area are minimal because steep hill slopes, conifers, and narrow valley widths 

along tributary streams limit access to the stream banks in most places. 

Sediment inputs as a result of a wildfire will vary depending on the severity of the burn and its areal 

extent. Site factors contributing to post-fire soil erosion include burn severity (changes in soil-water 

function), loss of ground cover, slope, and magnitude/duration of precipitation events. Post-fire sediment 

delivery to streams can increase due to high erosion rates and less ability to capture sediment on hill

slopes. The recovery of sediment inputs to pre-fire levels is anticipated at about three years after a lowseverity wildfire and 7 to 14 years after a moderate or high-severity wildfire respectively (Robichaud et 

al. 2000). 

The risk for uncharacteristic, high intensity fire is higher under Alternative 1. This represents an increased 

risk of sediment delivery if a fire and subsequent storm event scenario occurred. Without treatment of 

fuels and overstocked stands, the risk for fire, even uncharacteristic high-severity fire is subject to 

increase over time (see Fire/Fuels Management Specialist Report). Whether uncharacteristic sever fire 

could translate into a change in soil-water function at a scale sufficient enough to affect flow and 

sediment regimes would require the entire sequence of events to occur: 1) A fire that covers a large 

enough portion of watershed to produce potential effects. 2) Burn severity of moderate to high on 50

percent or more within the burn perimeter. 3) A storm event or rapid snowmelt of sufficient intensity that 

occurs within three years of the fire. Recent wildfires in the western US often result in up to 50 to 60

percent of the burned area in moderate to high burn severity (Lentile et. al., 2007). For these reasons, it 

becomes difficult to quantitatively predict sediment risk to watersheds by not treating fuels and 

overstocked stands. 

Roads will continue to serve as a conduit for and source of fine sediment to the streams under this noaction alternative. The amount varies depending on road location, design, and maintenance. No increase 

in the road-related sediment to the stream is anticipated unless there is a road or culvert failure during a 

storm event or deterioration of a road due to lack of maintenance. Sediment inputs from the tributary 

streams are expected to be minimal because there are no ongoing activities that will remove vegetation 

along riparian buffer zones or stream banks. 

Direct and Indirect Effects of Alternative 2

Timber Harvest Activities

Under the proposed action, timber harvest activities using mechanical equipment will occur over about 

11,495 acres. Commercial harvesting activities will occur in accordance with the INFISH Forest Plan 

amendment. Standard INFISH RHCA widths (see Table 37) will be utilized to protect aquatic and 

riparian habitats in the project area from measureable increases in fine sediment. Commercial harvest 

units will be logged using a combination of ground-based and cable logging systems. Limited mechanical 

activities will occur within RHCAs where stand treatment area enter in the outer edges of RHCAs in 

order to meet the silvicultural prescription for the stand (INFISH S&G TM-1). To reduce potential for 

increase in fine sediment from landings and skid trails located in RHCAs, the following design criteria 

will be used:

• Minimize skid trails by maximizing spacing between trails.

• Locate Category 4 crossings at naturally hardened sites. Harden crossings with brush or logs to 

protect streambanks.
Chapter 3 Snow Basin Vegetation Management Project FEIS

121

• No new landings will be constructed in RHCAs. Existing landings in RHCAs will be used where 

a road is located between the landing and stream channel. In general, landings in RHCAs should 

be at least 100 feet from stream channels. Existing landings adjacent to stream channels will not 

be used.

• Use forwarder logging system to transport logs to landings located in RHCAs. 

Timber harvest activities in RHCAs proposed in the DEIS have been modified as a result of public 

comments regarding concerns over soil erosion and a reanalysis of activities proposed in RHCAs. About 

50 acres of thinning will occur in RHCAs. This represents 0.9 percent of the total acreage of RHCAs in 

the project area.

Skid trails and landings will be minimized in RHCAs (INFISH S&G RF-2). Skid trails for all harvest 

activities will disturb an estimated 68 acres in RHCAs. This represents 1.3 percent of the total acreage of 

RHCAs in the project area. The number of crossings will be minimized by maximizing skid trail spacing. 

Damage to streambanks at crossings will be minimized by choosing naturally harden sites for crossings 

and/or hardening crossings with brush or logs. 

An estimated 27 landings will be located in RHCAs impacting 7 acres. Only existing landings will be 

used in RHCAs with the restriction that landings located adjacent to stream channels will not be used.

Generally, landings in RHCAs will be at least 100 feet from stream channels. Forwarders will be used 

instead of other ground-based yarding equipment to transport logs to landings located in RHCAs. Use of 

forwarders will reduce disturbed soil conditions at landings located in RHCAs and on associated skid 

trails.

The Water Erosion Prediction Project (WEPP) model developed by the Rocky Mountain Research Station 

(USDA Forest Service) is a model that accounts for various processes that lead to erosion and sediment 

delivery. Processes include: statistical analysis of local climate data to generate rainfall and snowmelt 

events; infiltration and runoff; soil detachment, transport and deposition; soil moisture; and plant growth, 

senescence and residue decomposition. While WEPP predicts erosion and sediment delivery within ±50

percent of measured volumes it is useful for comparison purposes for vegetation management activities, 

prescribed burning, and roads (Elliot et. al., 2003).

Variables used for WEPP model inputs were gathered during site visits (David Salo, WWNF 

Hydrologist). Site visits were made in 2011 to validate WEPP model results, PDFs and other mitigation to 

determine whether the expected trends in sediment delivery from the model appeared correct.

Professional judgment and field validation of the WEPP analysis supports both WEPP model results and 

the choice of PDFs (David Salo, WWNF Hydrologist). 

WEPP was used to model harvest units with the highest potential for sediment delivery (Table 41). Ten 

years of climate was utilized as it allows the model to utilize appreciable storm events predicted within 10 

years for producing results. The model results show a very low risk of sediment delivery from harvest 

units.

Table 41. WEPP results for timber harvest units with the highest potential for delivery

Buffer distance refers to area in RHCA with no harvest activity

Unit Yarding 

System Stream Buffer Distance to Stream (feet)

Average annual sediment 

leaving buffer (tons/year) 

based on 10 years of climate

30 Skyline Little Eagle Creek 300 0.000

33 Forwarder Snow Fork Creek 50 0.004

34 Forwarder Little Eagle Creek 230 0.000
Chapter 3 Snow Basin Vegetation Management Project FEIS

122

213 Forwarder Eagle Creek 60 0.000

405 Tractor Trib. To Puzzle Creek 50 0.000

When INFISH was developed in 1995, the widths of RHCAs were thought to be sufficient to maintain or 

restore water quality and aquatic habitat (LWD, pools, fine sediment) (INFISH, 1995). Reviews by 

Rhodes et al (1994), Rhodes (1995), Moyle et al. (1996), and Quigley et al. (1997) questioned the 

effectiveness of the PACFISH/INFISH RHCA width for Category 4 streams for preventing the transport 

of non-channelized sediment to Category 4 stream channels and ultimately Category 1 streams. The main 

criticism of RHCA widths for Category 4 stream channels is that additional buffer width is needed on 

steeper slopes to protect against fine sediment reaching stream channels. Rhodes et al. (1994) and Rhodes 

(1995) suggest that to provide “completely natural levels” of fine sediment reaching streams a buffer 

width of 450 feet (slope distance) is required. Erman et al. (1996) suggests adding additional buffer width 

(slope distance) as slope and soil erodibility increase. 

In response to these reviews, the proposed decision for the Interior Columbia Basin FEIS provided a 

relationship developed for highly erodible soils and slope as a default for determining widths of Category 

4 RHCAs needed to achieve a low risk of sediment reaching stream channels (ICBEMP, 2000).

Compared to the “low risk” default widths recommended by ICBEMP, the width of INFISH Category 4 

RHCAs likely represents a moderate risk of fine sediment reaching Category 4 stream channels in the 

project area.

In addition to the importance of vegetated buffer widths for filtering fine sediment prior to reaching 

Category 4 streams, levels of LWD in Category 4 stream channels can also play an important role in 

trapping and storing fine sediment. As noted in the Aquatic Habitat section, LWD levels in Category 4 

streams are at low levels. However, WEPP predicts that there is little risk of fine sediment reaching 

stream channels adjacent to harvest units with the highest potential erosion in the project area (Table 41).

Harvesting in Category 4 RHCAs has the potential to remove some trees that would provide future LWD 

to Category 4 stream channels. A limited amount of thinning will occur in Category 4 RHCAs; less than 

15 acres total. Thinning will be restricted to the outer 50 feet of Category 4 RHCAs where this occurs.

These areas are located above roads therefore any trees that were to fall towards the stream channels 

would be cut up and removed from the road prism. Given that the majority of trees to be thinned in these 

areas are likely smaller than a site potential tree (100 feet tall) and the average road prism for a sevendigit Forest Service Road is 14 feet wide, a small reduction in future LWD levels in Category 4 streams 

may occur where proposed thinning occurs in Category 4 RHCAs.

INFISH standards and guidelines for timber harvest activities and RHCAs were developed to limit 

impacts to aquatic habitat from timber harvest activities. Additional design features have been 

incorporated into the proposed action to limit soil disturbance from proposed activities in RHCAs. There 

is a low likelihood that increases in fine sediment resulting from the proposed timber harvest activities 

will result in measureable increases in fine sediment in fish bearing streams in the analysis area.

Transportation System Improvements

Road reconstruction

Road maintenance and reconstruction activities would be conducted on 230 and 41 miles respectively, of 

system roads to bring haul roads up to standards prior to hauling. Activities would primarily include road 

blading/grading and cleaning out culverts as necessary before and after haul. Road maintenance 

improvements would be prioritized at stream crossings and along road segments paralleling streams. Road 

reconstruction of system roads would also include opening up, blading and “grubbing” out vegetation 

from 17 miles of closed roads that would be used for haul routes for the project and later closed. The 
Chapter 3 Snow Basin Vegetation Management Project FEIS

123

project will require implementation of BMPs and monitoring through timber sale contract clauses to 

reduce erosion risk (Appendix B). 

Road segments with existing erosion issues were modeled using WEPP to estimate the relative sediment 

delivery rates prior to reconstruction and after treatment. Road selections were based on proximity to 

perennial streams, the need to implement applicable BMPs, and routine maintenance required to meet 

operational maintenance levels. The analysis does not represent a sediment delivery budget for the project 

area but merely attempts to look at representative critical roads planned for improved maintenance to 

display potential sediment reduction. 

The most common issue found during road inspections was a lack of defined drainage either through poor 

design and/or lack of maintenance. Many critical road segments have a neutral profile, meaning they are 

neither out-sloped nor in-sloped. The result is water often tracks down the road surface for extended 

distances, creating more energy for scour and transport of road material.

WEPP was used to model soil erosion from roads that were identified as the greatest contributors of fine 

sediment to streams (Table 42). Three scenarios were modeled: 1) Existing condition; 2) With BMPs 

applied and high traffic level to represent log truck traffic; and 3) With BMPs applied and anticipated 

traffic levels given the forecasted Forest Travel Management Plan decision. Where roads presently deliver 

appreciable amounts of sediment, BMP upgrades could effectively reduce sediment delivery from road 

surfaces. The long-term projections of sediment delivery accounts for lower levels of traffic (no log haul).

Table 42. Estimated sediment delivery from roads in the Snow Basin project area using WEPP

Road / Stream

Alternative 1

Existing 

Condition

Alternative 2 

(BMPs w/ Haul)

Alternative 2

Long-term Long-term 

Percent 

Reduction

Avg. tons/year over 10 years

FR 7732-160 / Gold Creek 7.92 1.50 0.45 94%

FR 7730 / Cabin Creek 0.48 0.55 0.13 74%

FR 7015 Spurs / Torchlight Gulch 3.24 0.90 0.08 97%

FR77 / Paddy Creek 2.02 3.39 0.23 89%

FR 7735 / Little Eagle 11.45 1.60 0.77 93%

While the magnitude of changes in sediment delivery between the three scenarios may not be absolute 

due to model limitations in capturing actual site characteristics (± 50 percent), the direction and 

magnitude of change is very important to note. Small short-term increases are predicted for Cabin Creek 

and Paddy Creek during log haul. Better surface runoff control will be achieved through placement of 

additional drain dips among other maintenance items.

While modeling was done only on Alternative 2, results for Alternatives 3 and 4 would be similar except 

for slight decreases in short-term sediment production due to less haul under these alternatives. Long-term 

benefits would be slightly less under Alternatives 3 and 4 as FR 7015 Spurs/Torchlight Gulch would not 

be reconstructed under these alternatives. 

Road reconstruction activities will likely result in an increase in erosion rates in the short-term from road 

prisms as sediment is eroded from disturbed areas. The short-term effects from road maintenance

activities are minimized by following INFISH standards and guidelines and road maintenance BMPs. In 

the long-term, road maintenance activities reduce adverse effects to aquatic habitat by reducing overall 

erosion rates from the road system.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Fine sediment levels in streams have been shown to increase as the density of roads in a watershed 

increase (Cederholm and Reid, 1987). No new system roads will be constructed; however, 108 miles of 

currently closed roads will be reopened to access logging units. Road reconstruction activities will occur 

on about 41 miles of road to correct drainage problems and bring roads up to standards for haul traffic. 

Closed roads that are opened for timber sale activities will be closed following timber sale activities. 

Opening of closed roads for timber sale activities would occur in a phased manner with only a portion 

being open at any one time; estimated to be no more than 10 miles at one time.

To access logging units without existing access roads 6.9 miles of temporary roads will be constructed. 

Additionally, about 4 miles of temporary road will utilize existing non-system roadbeds. The temporary 

roads would not be constructed in RHCAs. The temporary roads will be obliterated/decommissioned 

following completion of haul activities. The WEPP model predicts that eroded material will not exit the 

buffers between the closest adjacent stream channels and the temporary roads.

The combination of new road construction, temporary road construction (and decommissioning), opening 

and use of closed roads, and log haul traffic will likely result in an increase in erosion rates in the analysis 

area. Increases in erosion rates will occur in the short-term and then trend towards background levels. A 

long-term decline in erosion from roads will likely occur as a result of road reconstruction activities. 

INFISH RHCAs will likely moderate much of the increase and the amount of sediment reaching stream 

channels will likely result in an immeasurable increase in fine sediment levels in streams in the analysis 

area for aquatic species. 

Bridge work

One bridge will be replaced on Little Eagle Creek on FR 7735000 in the project area for haul activities 

(Table 43). The in-water work window for Eagle Creek and tributaries is July 1 – October 31 (Powder 

River System).

Table 43. Proposed bridge work in the Snow Basin project area

Bridge Name Stream Fish Species Condition Comments

FR 7735000-

6.2, Little

Eagle #2

Little Eagle 

Creek

Redband Trout This bridge has extensive rot in the wood of the deck and 

extending into the stringers. There is currently a weight 

restriction posted at the bridge which will likely be further 

reduced after the next inspection. At a minimum, the deck 

and stringers, or superstructure would need to be replaced.

The existing abutments, while serviceable, create some 

channel restriction and would be evaluated as well. 

Increases in fine sediment and turbidity will result from the proposed bridge replacement on Little Eagle 

Creek. Little Eagle Creek provides habitat for redband trout in the vicinity of the proposed worksite. 

Replacing the abutments on the Little Eagle Bridge to eliminate the channel restriction would result in 

short-term measurable increases of fine sediment in the vicinity of the bridge site. Based on similar large 

culvert replacement projects that have occurred since 2006, the increase in fine sediment will likely 

extend downstream no more than 0.125 mile and last until the following spring runoff (Alan Miller, 

Fisheries Biologist, Wallowa Valley RD). Replacing the abutments would eliminate the channel 

restriction and resulting chronic streambank erosion thus resulting in a long-term reduction in fine 

sediment. 

The effects of sediment to aquatic habitat during bridge replacement will be reduced using sediment 

control measures during the construction phase, and timing the construction phase to coincide with the inwater work window for Eagle Creek and tributaries (July 1 – October 31). Aquatic habitat downstream of 

the bridge replacement site on Little Eagle Creek will be impacted due to a measureable increase in fine 
Chapter 3 Snow Basin Vegetation Management Project FEIS

125

sediment to 0.125 miles of aquatic habitat. The majority of impacts will occur along the channel margin, 

and last until the following spring runoff. 

Following replacement of the abutments, periodic spikes in sediment input are expected during the first 

winter season in response to precipitation events that may mobilize sediments from disturbed areas. 

Sedimentation may also occur throughout the site during the recovery period until fill slopes stabilize (2 

to three years following installation). These spikes will likely not result in measurable increases in fine 

sediment in aquatic habitat below the bridge site.

Culvert replacements

Culverts will be installed to reopen previously closed roads that cross streams in the project area for haul 

activities: 1) three temporary culverts on Category 1 streams (fish bearing), 2) 7 culverts on Category 2 

streams (perennial non-fish bearing), and 3) 8 culverts (1 permanent and 7 temporary culverts) on 

Category 4 streams (intermittent non-fish bearing) (tables 44 and 45). Culverts will be sized appropriately 

(i.e. pass a 100 year flood event) and will met Aquatic Organism Passage Criteria for fish bearing 

streams.

Table 44. Culvert replacements on Category 1 stream segments in the Snow Basin project area

Stream Road Number Species Comments

Conundrum Cr 7700274 Redband Trout

No culvert, perennial 

crossing; install temporary 

culvert

Conundrum Cr 7700285 Redband Trout

Culvert removed, perennial 

crossing; install temporary 

culvert

Little Eagle Cr 7700310 Redband Trout

Culvert removed, perennial 

crossing; install temporary 

culvert

Table 45. Culvert replacements on category 2 stream segments in the Snow Basin project area

Impacts to aquatic habitat are likely where culverts are located within 0.125 miles of fish bearing stream segments

Stream Road Number Distance to Fish Bearing 

Stream Segment (Miles) Comments

Torchlight Gulch 7015150 0..04

Culvert removed, perennial 

stream crossing, install 

temporary culvert

Spring Cr Tributary 7700268 0.64

Culvert removed, perennial 

stream crossing, install 

temporary culvert

Ethel Cr 7725065 1.24

Culvert removed, perennial 

stream crossing, install 

temporary culvert

Gold Cr 7730260 0.71

Culvert removed, perennial 

stream crossing, install 

temporary culvert

Ethel Cr 7725090 1.74

Culvert removed, perennial 

stream crossing, install 

temporary culvert

Gold Cr Tributary 7732270 1.23 Culvert removed, perennial 

stream crossing, install 
Chapter 3 Snow Basin Vegetation Management Project FEIS

126

temporary culvert

Blue Canyon 7730360 0.80

Culvert removed, perennial 

stream crossing, install 

temporary culvert

Increases in fine sediment and turbidity will result from installing four temporary culverts. Temporary 

culverts will be installed on two Category 1 streams; Conundrum Creek (two culverts) and Little Eagle 

Creek (one culvert). Additionally, installation of a temporary culvert on Torchlight Gulch, a Category 2 

stream, will impact downstream aquatic habitat. These four streams provide habitat for redband trout in 

the vicinity of the proposed worksites. 

During installation of the temporary culverts the effects of sediment to aquatic habitat will be reduced 

using sediment control measures during the construction phase, and timing the construction phase to 

coincide with the in-water work window for Eagle Creek and tributaries (July 1 to October 31). Following 

installation of the temporary culverts, periodic spikes in sediment input are expected during the first 

winter season in response to precipitation events that may mobilize sediments from disturbed areas. 

Sedimentation may also occur throughout the site recovery period until fill slopes stabilize (2 to 3 years 

following installation). An additional spike of sediment input will occur when the temporary culverts are 

removed. Measureable increases in fine sediment following culvert replacement projects on the Eagle Cap 

and the Wallowa Valley Ranger Districts rarely extend downstream more than 0.125 mile with the 

majority of impacts occurring along the channel margin, and last until the following spring runoff (Alan 

Miller, Fisheries Biologist, Wallowa Valley RD). 

Short-term measurable increases in fine sediment in the vicinity of the culvert installation/removal sites 

will likely occur. The installation of temporary culverts on: Conundrum Creek (two culverts), Little Eagle 

Creek (one culvert), and Torchlight Gulch (one culvert) will likely result in short-term measurable 

increases in fine sediment to 0.46 miles of redband trout habitat. The increases in fine sediment will likely 

last for up to 4 months. The temporary replacement of six culverts on Category 2 streams are not expected 

to result in measureable increases in fine sediment in redband trout habitat due to their distance from fishbearing stream segments (>0.125 miles from fish bearing stream segments, see Table 45). Replacement of 

culverts on Category 4 streams is unlikely to result in measurable increase in fine sediment in downstream 

fish bearing reaches because they will be replaced when the sites are dry.

Installation of the other six temporary culverts on Category 2 streams will result in immeasurable increase 

sin fine sediment because of culverts are greater than 0.125 miles from fish bearing stream reaches. These 

immeasurable increases will occur as fine sediment is routed through the watershed during the following 

spring runoff.

A majority of the temporary culvert installation sites that are located on Category 4 streams have low 

width-to-depth ratios and gentle approach slopes which favor minimal excavation and/or fill. The soils are 

very cohesive, and there is plenty of room to stockpile soil due to a wide valley bottom. Work will occur 

during the dry season on these intermittent streams therefore no impacts to Category 1 stream reaches are 

anticipated. The installation of 7 temporary and one permanent culvert on Category 4 streams will result 

in immeasurable increases in fine sediment during the following spring runoff. 

Road decommissioning

A total of 6 miles of road decommissioning is planned under the action alternatives. About 3.2 miles, or

53 percent, are within RHCAs. One of the planned road segments for decommission was modeled using 

WEPP. This road segment likely represents the highest sediment delivery of any road planned for 

decommission. The present sediment delivery is 7.92 tons/year. After project decommission, the sediment 

yield drops to 0.45 tons/year. This represents a 94 percent reduction.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Prescribed Fire Activities

Prescribed burning to reduce natural fuels levels will occur across about 4,995 acres in the project area. 

Additionally, post-harvest burning will occur in logging units to reduce activity fuels (10,467 acres). 

Natural fuels units include about 865 acres in RHCAs in the project area (Table 46). This represents about 

16 percent of the total acreage of RHCAs in the project area. The following design criteria will be used to

reduce impacts to aquatic habitat:

• Use low intensity prescribed fire to reduce fuels loads and reduce the risk of wildfire spread 

through RHCAs. Limit prescribed fire intensity and spread by using backing fire and not actively 

lighting in RHCAs.

• Avoid handpiling within 50 feet of Category 1, 2, and 4 stream channels.

• Avoid machine piling within RHCAs (except at approved landings in RHCAs).

Prescribed fire will not be ignited in RHCAs; however, fire will be allowed back into RHCAs from 

adjacent areas. The use of backing fires in RHCAs will reduce fire intensities while reducing fuel loading. 

Reduced fire intensities in RHCAs will 1) reduce the potential for mortality of trees that provide shade, 2) 

reduce the amount of downed woody material consumed, and 3) reduce the amount of burned area in the 

RHCAs thus reducing the amount of ground cover loss. Typically, only about 40 to 60 percent of the area 

in an RHCA is actually burned due to the use of backing fires and higher fuel moistures. See the 

Fire/Fuels Management section for a more detailed description of the expected post-burn conditions. 

Table 46. Acres of prescribe fire in RHCAs for Alternative 2

Category 1 RHCAs (acres) Category 2 RHCAs (acres) Category 4 RHCAs (acres)

227 231 407

Burn prescriptions have been built to minimize any fire within RHCAs, allowing buffers to capture any 

sediment generated from upslope areas. WEPP analysis of sediment delivery from expected prescribed 

fire activities showed zero sediment (average for 10-year return period) where 300 foot buffers exist on 

perennial streams and slightly more (0.004 tons/acre) for 150 foot buffers.

The burn prescription would target consumption of woody material three inches and smaller with nearly 

all material in this size class consumed. Therefore, fire severity would not be high enough to consume 

significant quantities of downed wood that play a role in trapping fine sediment on hill slopes, in 

intermittent stream channels and on floodplains. Some ground cover would be consumed, but would be 

quickly replaced as litter fall occurs in the first year following burning and herbaceous plants recover in 

the second year following burning. A measurable increase in fine sediment in stream channels as a result 

of burning activities is unlikely due to the combination of a predicted patchy, low severity burn in 

RHCAs and typical recovery of ground cover within two years of prescribed burning.

Direct and Indirect Effects of Alternatives 3 and 4

Although difficult to quantify, effects to the fine sediment aquatic habitat element under Alternatives 3 

and 4 would likely be less compared to Alternative 2. Compared to Alternative 2, area-wide activities (i.e. 

commercial harvest, prescribed burning) will occur over 1,505 acres less under Alternative 3 and 2,644 

acres less under Alternative 4 (Table 47). A reduction in commercial thinning activities (including 

associated activities such as haul traffic and road maintenance) and burning activities under Alternatives 3 

and 4 will result in overall lower erosion rates compared to Alternative 2.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Table 47. Comparison of activities for action alternatives with potential to increase erosion rates 

Activities with Potential to Increase Erosion Rates Alt 2 Alt 3 Alt 4

Area-wide Activities

Total Commercial Harvest & Post-Activity Fuel Treatments 

(acres) 11,495 11,013 9,228

Total Prescribed Fire Treatments (acres) 4,995 3,972 4,618

Total Acres 16,490 14,985 13,846

RHCA Activities

Total Commercial Harvest Activities in RHCAs (acres) 50 43 43

Total Prescribed Fire Treatments in RHCAs (acres) 865 405 405

Total Skid Trails in RHCAs (acres) 68 18 18

Total Acres of Landings in RHCAs 7 6 6

Total Acres 990 472 472

Transportation System Activities

Road Maintenance for Log Haul (miles) 219.0 212.0 205.0

Total Temporary Road Construction miles (miles) 11.0 9.0 0.0

Total System Road Reconstruction (miles) 41.0 38.3 37.6

Total Miles 271.0 259.3 242.6

Activities in closer proximity of stream channels are more likely to contribute fine sediment to streams 

than activities occurring farther away from stream channels. Compared to Alternative 2, RHCA-wide 

activities (i.e. commercial harvest, prescribed burning, skid trails) will occur over 518 less acres under 

Alternatives 3 and 4 (Table 47). A reduction in activities in RHCAs under Alternatives 3 and 4 will result 

in lower erosion rates in RHCAs compared to Alternative 2.

Overall, Alternatives 3 and 4 represent a reduction in erosion rates compared to Alternative 2 and a lower 

risk of immeasurable increases in fine sediment in streams in the analysis area. However, since WEPP 

predicts there is little risk of fine sediment reaching stream channels adjacent to harvest units with the 

highest potential erosion in the project area under Alternative 2, it is unlikely that that there will be a 

measureable difference in fine sediment levels between the three action alternatives.

Another factor that contributes to the lack of measurable differences in fines sediment levels between the 

three action alternatives is that only a portion of eroded soil will travel to stream channels (Walling, 

1999). The difference between soil erosion and the amount of sediment that reaches streams is called the 

sediment delivery ratio (Mutua and Klik, 2006). Each watershed has a unique sediment delivery ratio 

based on watershed characteristics influencing its buffering capacity, however, it is generally inversely 

proportional to watershed size; i.e. the larger the watershed the lower the sediment delivery ratio 

(Walling, 1988).

There is also a time lag factor that influences sediment delivery ratios that make it unlikely that 

measureable differences in fine sediment levels between the alternatives will be detectable: 1) as soil is 

eroded a portion of it can become trapped in sediment sinks prior to reaching stream channels, 2) a 

portion of sediment that reaches stream channels can be trapped by channel features such as LWD, and 3) 

portions of trapped sediment in both uplands and stream channels can be remobilized at a later date.

These factors can result in sediment delivery ratios that can be a fraction of the amount of soil that is 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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eroded in a watershed, and can create lag time between initial erosion and deposition in streams that make 

it difficult to effectively measure changes in fine sediment in streams in the analysis area based on the 

relative similarity of the three action alternatives.

Measurable increases in fine sediment are predicted as a result of the replacement of a bridge and 

installation and removal of temporary culverts on fish bearing streams. These increases are predicted to be 

short-term. Under Alternative 2, three culverts on Category 1 streams and one culvert on a Category 2 

stream will be replaced and will likely impact 0.46 miles of aquatic habitat. Under Alternatives 3 and 4, 

two culverts on Category 1 streams and one culvert on a Category 2 stream will be replaced and will 

likely impact 0.335 miles of aquatic habitat. Measurable increases in fine sediment will likely last for up 

to four months.

Channel Stability/Function

Existing condition

Channel stability helps define the level of function of stream systems. Inherent channel stability is 

characterized by recognizing channel classification. This means that inherent stability can vary by stream 

type. Streams in the project area are mainly Rosgen A and B type channels (see Table 39; Rosgen, 1996). 

These streams are characterized by entrenched to moderately entrenched (limited floodplain access), lowmoderate width/depth ratios, low-moderate sinuosity, and stream slopes less than 10 percent. Substrates 

generally consist of cobbles and gravels, with minor amounts of boulders and fines. Stream stability in 

these stream types depend on bank and bed rock content, with some stability a function of streamside 

vegetation and LWD. In a natural state, these stream types tend to show good to excellent stability. 

Stream stability is generally good throughout the project area (>80 percent), with some exceptions on 

Eagle Creek where the valley bottom width exceeds about 200 feet. These reaches often function as 

bedload deposition zones, causing increased lateral migration and braiding of the channels. While some of 

this instability is influenced by human activities, it appears that some natural instability is inherent with 

the system. For example, stream stability for the reach immediately above the Main Eagle Trailhead 

exhibits braiding and lateral migration. This reach is not influenced by management actions. The 

interaction of the stream and FR 77 has caused problems in terms of maintaining the road. During the 

flood event of June, 2010, partial loss of the road template occurred in four different places. The volume 

of material lost from the road template from these sites is in the thousands of yards, based on 

reconnaissance level estimates.

Management influences on channel stability/function

Management actions can influence channel stability. When assessing stability and function of stream 

channels, a comprehensive assessment is necessary to determine cause-and-effect relationships when 

stability appears compromised. Changes in stability from natural levels can result from changes in water 

supply and/or sediment supply (Lange, 1955). Changes can also result from disturbances or influences at 

the channel level. Channel stability changes may result from livestock management, timber harvest, 

placer mining, road construction, and other disturbances within the stream corridor. For example, roads 

located within the stream migration zone may interfere with established patterns of sinuosity, causing a 

cascade of effects that ultimately result in decreased stability. When multiple management actions occur 

within a watershed, it becomes more difficult to assign cause-and-effect relationships with respect to 

channel stability. A decrease in channel stability usually results in loss of habitat values for aquatic life. 

These changes can be quantified through stream attributes including width/depth ratios, pool frequency 

and pool volumes.

Effects from timber harvest activity typically relate to increased water and/or sediment yields. The ECA 

procedure represents a coarse-scale analysis to determine if sufficient cover removal at the watershed 
Chapter 3 Snow Basin Vegetation Management Project FEIS

130

scale has occurred through harvest or fire to alter the flow regime (see Water Quantity section). If 

sediment yields have substantially increased due to harvest, fire and road systems, channel stability can 

decrease as the stream system receives more sediment than it can effectively transport.

Measurement Indices: The Forest Plan RMO for channel stability is >80 percent. The analysis of 

alternatives will determine any changes in channel stability from the existing condition. The final 

determination will conclude whether channel stability will remain static, increase or decrease from 

existing condition.

Effects of the Alternatives

Any effects of the alternatives is based on best professional judgment, considering the existing condition, 

changes in water and sediment regimes, and changes to the stream channel or riparian area. Direct effects 

occur at the time and place of the action. For channel stability, direct effects consider any actions within 

the channel system, such as construction of a stream crossing or road fill intruding into the channel. 

Indirect effects occur later in time or removed from the activity area. Indirect effects from timber harvest, 

fire and roads result from increased water and/or sediment yields within the Eagle-Paddy and Little Eagle 

subwatersheds. A threshold of 15 percent ECA is used to determine whether increases in water yield 

might occur. Changes in fine sediment yield are associated with surface erosion occurring with timber 

harvest, prescribed burning, and roads. Changes in bedload sediment delivery are typically associated 

with severe gullying or mass failures, or decreased stream stability which results from increased water 

yields. Cumulative effects consider all the past, present and reasonably foreseeable future actions within a 

watershed and assimilate them into an assessment of channel stability/function. 

Alternative 1

There would no change in current management activities, therefore current conditions would be 

maintained through the mid-term. An increase in the likelihood of an uncharacteristic wildfire event(s) is 

predicted for the project area in the long-term (see Fire/Fuels Management Specialist Report). A wildfire 

event that occurs with sufficient scope and intensity to alter flow and sediment regimes could decrease 

channel stability. For example, a wildfire that removes 50 percent of the cover in Little Eagle Creek 

watershed could increase peak flows and deliver more sediment to Little Eagle Creek. The result would 

likely decrease channel stability, especially in lower gradient (<4 percent) reaches. An increase in 

width/depth ratios, and decrease in pool frequency and pool volumes would likely occur concurrently. 

The probability of this occurrence is difficult to predict, as many factors come into play.

Alternatives 2, 3, and 4

All action alternatives have similar levels of direct effects, namely culvert installations and removal on 

Maintenance Level 1 roads. The culvert actions occur on small (1st and 2nd order) perennial and 

intermittent streams. Alternative 2 has 22 installations/removals, and Alternatives 3 and 4 have 22 

installations/removal actions. The length of reach affected is approximately the length of pipe, about 20 

feet for each crossing. The effect will last as long as the road is used for haul, likely less than one year.

Proposed harvest activities under all action alternatives result in a total ECA of less than 15 percent (see 

Streamflow section). Because this is under the threshold considered for detecting a change in flow 

regimes, no change in stream stability from streamflow increases is expected. While short-term increases 

of fine sediment may occur from increased traffic due to logging on some road segments, the long-term 

fine sediment delivery will decrease due to road improvements and decommissioning of roads within 

RHCAs. The effect of fine sediment on stream stability is limited, especially on relatively high-gradient 

streams within the project area. While limited deposition may occur on low-gradient reaches, most fine 

sediment gets transported downstream to Brownlee Reservoir. Fine sediment has a bigger effect on 

habitat quality by filling in interstitial spaces of stream substrate. Channel stability is much more sensitive 
Chapter 3 Snow Basin Vegetation Management Project FEIS

131

to changes in bedload sediment. No change in bedload delivery is expected from any of the actions under 

all action alternatives because no gullying or increase in mass failures is expected.

Summary

Channel stability is generally good (>80 percent) for most streams within the project area. Exceptions 

include reaches of Eagle Creek where valley bottom widths exceed about 200 feet. These reaches tend to 

allow excessive bedload deposition which results in channel braiding and lateral migration. Reaches with

channel braiding and lateral migration often exhibit stability less than 80 percent. These reaches may 

interact with Forest Road 77 in places, causing substantial loss of road fill and surface. Delivery of road 

material to the stream system acts to exacerbate channel braiding and lateral migration.

The proposed action and its alternatives are not predicted to affect stream channel stability. This is due to 

no appreciable changes to any factors which affect channel stability. These factors include: streamflow 

regime, sediment regime, and any management changes within the stream corridor (especially road 

location). Relocation of roads outside the stream corridor, especially on Eagle Creek, would be necessary 

to achieve a measurable change in stream channel stability/function.

Stream temperature

Existing condition

To meet the Clean Water Act, the beneficial uses of waters must be identified and management activities 

planned so they will not interfere with or be injurious to the beneficial uses of adjacent and downstream 

waters. The relevant beneficial uses of the Powder/Burnt Basin and its tributaries as determined by 

Oregon Department of Environmental Quality are: 1) Public and private domestic water supply; 2) 

industrial water supply; 3) irrigation; 4) livestock watering; 5) fish and aquatic life; 6) wildlife and 

hunting; 7) fishing; 8) boating; 9) water contact recreation; 10) aesthetic quality (ODEQ, 2003). 

Beneficial uses within the project area include livestock watering, irrigation, and resident fish and aquatic 

life. There are no streams listed on the 2004/2006 ODEQ 303 (d) list as water quality limited in the 

project area.

The Oregon Department of Environmental Quality (ODEQ) water quality standards are applied to protect 

the most sensitive beneficial uses in a water body. Redband trout are considered the beneficial use most 

sensitive to stream temperatures. The biologically-based criterion requires that the seven-day moving 

average of the daily maximum temperature shall not exceed 68°F (20.0° C).

A Total Maximum Daily Load (TMDL) is being developed for the Powder Basin. Once the TMDL is 

approved, a Water Quality Restoration Plan (WQRP) will guide management activities within the basin. 

Federal lands managed by the USDA Forest Service in the Powder Basin will continue to follow 

standards and guidelines (S&G) as listed in the LRMP (amended by INFISH) and Best Management 

Practices (BMPs) to ensure water quality standards are met.

Limited water temperature monitoring has occurred in the Eagle Creek system, including the analysis area 

(Table 48; Figure 5). On Eagle Creek, five water temperature monitoring stations are located in the 

analysis area and two are located upstream of the analysis area (Table 48). In general, the water 

temperature standard for redband trout is being met in the analysis area. Water temperature data indicates 

that the redband trout standard (<68.0 °F) is being met in Eagle Creek in the analysis area (Table 48). 

However, the water temperature standard was exceeded three out of four years that water temperatures 

were monitored in Little Eagle Creek in the analysis area (Table 48). Water temperatures in Eagle Creek 

appear to be naturally warm based on temperature data from Eagle Creek Site 8 which is located near the 

wilderness boundary and about 11 stream miles above the project area. High water temperatures in Little 

Eagle Creek are likely related to water withdrawals for irrigation purposes (See Water Yield and 

Streamflow; and Cumulative Effects Sections). 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Table 48. Maximum seven-day mean maximum stream temperatures for Eagle Creek and Little Eagle 

Creek compared to ODEQ standards

N/D = No data

Stream Site # Elevation 

(ft)

1998 

(°F)

1999 

(°F)

2001 

(°F)

2002 

(°F)

2005 

(°F)

ODEQ

Standard 

(°F)

Eagle Cr EC-1 2800 N/D 62.5 N/D 64.7 66.2 <68.0

Eagle Cr EC-2 3180 N/D 62.3 68.3 65.0 N/D <68.0

Eagle Cr EC-3 3440 N/D N/D 66.0 62.9 64.5 <68.0

Eagle Cr EC-4 3680 N/D 60.3 67.6 61.5 N/D <68.0

Eagle Cr EC-5 3840 N/D 61.7 N/D 63.9 65.5 <68.0

Eagle Cr EC-8 5100 N/D N/D 63.3 59.7 61.3 <53.6

Little Eagle Cr LE-1 3180 71.3 66.4 70.7 68.9 N/D <68.0

Note Eagle Creek Sites 5 and 8 are located upstream of the analysis area. Site 8 is located near the wilderness 

boundary. All other sites are located in the analysis area.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Figure 5. Locations of water temperature monitoring sites in and adjacent to the Snow Basin project area
Chapter 3 Snow Basin Vegetation Management Project FEIS

134

*EC Site 8 is located near the Wilderness Boundary
Chapter 3 Snow Basin Vegetation Management Project FEIS

135

As noted in the Eagle Creek Watershed Analysis, East Eagle Creek has a cooling effect on Eagle Creek 

below their confluence of almost 4 degrees in some years (1997). The Eagle Creek – E.F. Eagle Creek 

confluence is located between Sites EC-4 and EC-5 (Table 48) and just above the analysis area (Figure 5). 

This cooling effect extends down to Site EC-3 located about one mile above the confluence with Paddy 

Creek (Figure 5). 

Little Eagle Creek is a warm water source based on the difference between sites LE-1 and EC-2 (Table 

48). However, the influence of this warmer water on the water temperature of Eagle Creek is low based 

on the differences water temperatures between sites EC-2 and EC-1. This is likely due to the reduced 

flows in Little Eagle Creek as a result of irrigation withdrawals (See Cumulative Effects Section).

Other streams where significant water withdrawals occur during the low water period are: 1) Ethel Creek, 

2) Conundrum Creek, and 3) Twin Bridges Creek. These streams are all tributaries to Little Eagle Creek 

(Figure 5). Water withdrawals are a contributing factor for high water temperatures during the summer 

low-water period (Beschta, 1997). 

Direct and Indirect Effects of Alternative 1

No change to current water temperatures is expected through the mid-term because current management 

activities within analysis area would continue. A majority of the timbered stands within the project area 

are represented by a fuel model that predicts an increased risk of wildfire with moderate to high severities 

in the long-term (see Fire/Fuels Management Specialist Report). A wildfire in the area could elevate 

water temperatures for up to 10 years, depending on the wildfire severity (Dunham et al., 2007). Elevated 

water temperatures for an extended period of time as a result of wildfire would reduce the survival of 

redband trout until sufficient regrowth of streamside vegetation occurs (See Water Temperature RMO and 

Aquatic Species Discussions). 

Effects of Alternative 2

Timber harvest activities

Sunlight is the primary energy source that heats streams (Brown and Krygier, 1970). Shading (vegetative 

and topographic) moderates stream temperatures by reducing the amount of solar radiation from reaching 

streams. Buffer strips (unharvested or minimally harvested areas) adjacent to streams have been shown to 

be effective in reducing or preventing increases in stream temperatures from adjacent timber harvest 

activities. Recommended widths for buffer strips for shading vary from 50 to 250 feet (Pollock and 

Kennard, 1998). Moore et al. concluded that based on the available studies, a one-tree-height buffer that 

preserves shading on each side of a stream should be reasonably effective in reducing harvesting impacts 

on both riparian microclimate and stream temperature (2005).

The majority of timber harvest activities are proposed for areas outside of RHCAs. A limited amount of 

commercial thinning activities, about 50 acres, will occur in the outer edges of RHCAs under the 

proposed action where treatment stands overlap with RHCAs (Table 49). In general, thinning will not 

occur within 200 feet of Category 1 stream channels (twice the height of a site potential tree) and 100 feet 

of Category 2 stream channels (height of a site potential tree). These distances meet the minimum 

requirements for INFISH RHCA widths for these stream categories and are sufficient to prevent removal 

of trees that provide stream shading. Restricting thinning activities to the outer edges of RHCAs will 

prevent adverse impacts to existing stream shading along perennial streams in the aquatic effects analysis 

area. Therefore, measurable increases in stream temperatures are not likely to result from proposed 

thinning activities.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Table 49. Acres and percent of RHCA treated with thinning

Alternative Acres of thinning treatment within 

RHCAs

Percent of RHCAs within project 

area treated

2 50 0.9%

3 43 0.8%

4 43 0.8%

Groundwater temperatures can also influence stream temperatures. Where groundwater is close to the 

surface, removal of the forest canopy may increase groundwater temperatures. Brosofske et al. showed a 

strong relationship between upland soil temperatures and stream temperatures for both preharvest and 

postharvest (clearcutting) conditions in their study area in Western Washington (1997). Soil temperatures 

following clearcutting can be up to 6°C warmer (Bhatti et al., 2000) and up to 1°C warmer in partial cuts 

(Brooks and Kyler-Snowman, 2008). Since timber harvest activities proposed under Alternative 2 are 

primarily commercial thinning, it is unlikely that an increase in soil temperature will occur. Thus, it is 

unlikely an increase in stream temperatures will occur as a result of thinning in areas outside of RHCAs. 

Transportation system improvements

Danger Tree Removal 

Danger trees will be removed from haul road corridors for public and forest worker safety. Danger trees 

in RHCAs will be felled and left on site in accordance with INFISH S&G TM-1. Felling of danger trees 

in RHCAs adjacent to perennial streams is not expected to result in a significant decrease in streamside 

shading.

Prescribed fire activities

Proposed burning activities will result in a low severity fire in RHCAs adjacent to perennial streams in 

the project area. This will be accomplished by burning when fuel moisture levels are high, not actively 

lighting fires in RHCAs, and allowing fires to back into RHCAs from adjacent upslope areas. These 

techniques result in low intensity fires that burn in a patchy distribution of burned and unburned areas in 

RHCAs. Trees killed by prescribed fire in RHCAs will primarily be understory trees (≤ 8 inch DBH). 

Understory trees of this size typically do not provide significant levels of stream shading. 

Few riparian shrubs are also expected to be killed as a result of the proposed burning because they are 

present in the moister riparian areas. Where the above ground portions of riparian shrubs are killed, they 

will likely sprout back relatively quickly because the low severity fire will not be hot enough to kill root 

crowns. 

The proposed burning in RHCAs adjacent to intermittent streams poses little risk of increasing stream 

temperatures, because these streams are normally dry during the summer and fall months. Based on these 

factors, the Snow Basin Project is unlikely to result in a measurable increase in water temperature and a 

degradation of water quality in streams in the aquatic effects analysis area. 

Effects of Alternatives 3 and 4

Effects on the water temperature aquatic habitat element from Alternatives 3 and 4 are similar as those 

described for Alternative 2 because the proposed activities are similar. As for Alternative 2, thinning 

activities will occur within the outer edges of RHCAs adjacent to Category 1 and Category 2 streams 

under Alternatives 3 and 4 but in general will not occur within 100 feet of stream channels (height of a 

site potential tree). Restricting thinning activities to the outer edges of RHCAs will prevent adverse 

impacts to existing stream shading along perennial streams in the aquatic effects analysis area. These 

distances meet the minimum requirements for RHCA widths for these stream categories and are sufficient 
Chapter 3 Snow Basin Vegetation Management Project FEIS

137

to prevent removal of trees that provide stream shading. Thinning activities outside of RHCAs will have 

no effect on stream temperatures. Therefore, measurable increases in stream temperatures will not result 

from proposed thinning activities under Alternatives 3 and 4.

Effects from prescribed burning activities under Alternatives 3 and 4 would be similar to effects from 

Alternative 2 because the acres and areas to be burned are similar.

Direct and Indirect Effects to Forest Plan RMOs

Based on the analysis of effects to watershed processes and proposed activities, the analysis of effects to 

Forest Plan RMOs will focus on: 1) fine sediment, 2) water temperature, and 3) LWD and pool habitat.

Fine sediment RMO

Ecological importance of RMO

Composition of the stream substrate is an important feature of aquatic habitat. Cobble and gravel 

substrates provide habitat for a diverse assemblage of benthic macroinvertebrates as well as eggs and 

early life stages of numerous fish species. Macroinvertebrates represent a substantial portion of the diet 

available to various fish species, particularly stream dwelling salmonids.

Fine sediment in streams is a normal component of salmonid habitat; however, major disruptions of 

aquatic ecosystems occur when sediment levels substantially exceed natural levels. Filling of interstitial 

spaces (i.e. the gaps between rocks on the stream bottom) with fine sediment (particles < 2 mm in size) 

eliminates habitat for many macroinvertebrates. Fish eggs and early life stages can also be buried and 

smothered when interstitial spaces are embedded with fine sediment. Studies have shown that an increase 

in 1 to 3mm size sand from 20 to 30 percent can decrease emergent survival of salmonid species from 65 

down to 40 percent (Phillips et al., 1975). Fine sediments are known to impact fry emergence and 

survival, and fine sediment (<6.5mm in size) levels above 40 percent can effectively eliminate salmonid 

populations and many macroinvertebrate species (Everest and Harr, 1982). Winter habitat for juvenile 

salmonids is also lost as interstitial spaces in cobble-sized and larger streambed material are embedded 

with fine sediment. 

Increases in fine sediment can occur from both increased transport of fine sediment from upland areas and 

from destabilized stream banks. Increases can result from both episodic sources such as wildfires or from 

chronic sources such a native surface roads. Episodic sources normally result in short-term increases that 

return to pre-disturbance levels through natural recovery processes. Chronic sources can result in longterm changes of stream channels and aquatic habitat. 

Standards and guidelines

Forest plan standards and guidelines

The Forest Plan (1990) standard and guideline for fine sediment is “Where natural stream characteristics 

permit...limiting fine inorganic sediment covering stream substrate to 15 percent...” (Wildlife S&G 1). 

Fine inorganic sediment is defined as sand and silty material less than 3.3 mm in size. The INFISH 

amendment did not include an RMO for fine sediment (1995). The Forest Plan standard was modified in 

1995 and 1998 as part of the ESA consultations for the Forest Plan to <20 percent fine sediment (particles 

<6.4mm in size) in spawning areas or < 30 percent embeddedness (NMFS 1995, 1998).

Existing conditions 

Fine sediment levels in Category 1 streams in the analysis area are at moderate levels and are less than the 

20 percent threshold commonly used to determine effects to salmonids and other aquatic species (Table 

39). 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Effects of Alternative 1

Fine sediment levels are generally below the 20 percent threshold in the analysis area (Table 41). Current 

fine sediment levels would likely be maintained in the short-term because current management activities 

would continue. Management activities in the analysis area that are likely to be contributing to elevated 

fine sediment levels are livestock grazing and roads (Eagle Creek Watershed Analysis, 1997). Changes in 

livestock management are in progress and a reduction in road densities are proposed under the WWNF 

Travel Management DEIS (see Appendix B). A majority of road maintenance activities proposed under 

the Snow Basin Project could be implemented under regular road maintenance (see discussion in 

Cumulative Effects Section). Replacement of the bridge on Little Eagle Creek would likely not occur in 

the short-term under Alternative 1. 

The majority of the timbered stands in the project area would be represented by a fuel model that is likely 

to exhibit moderate fire severities in the case of a wildfire. These conditions increase the likelihood of a 

large-scale wildfire in the project area in the future (see Fire/Fuels Management Specialist Report). 

Wildfires typically result in increases in fine sediment for 3 to 5 years, depending on the wildfire severity 

(Neary et al., 2005). Adverse impacts to aquatic habitat would likely occur where fine sediment levels 

exceed the 20 percent threshold. These levels would likely decrease spawning success for redband trout, 

and a decrease in survival of juvenile redband may occur.

Effects of Alternatives 2, 3, and 4

As detailed in the Watershed Erosion and Sedimentation Section, a combination of immeasurable and 

measurable increases in fine sediment is predicted to occur as a result of proposed activities under 

Alternative 2. Timber harvest and prescribed burning activities in general will result in short-term 

immeasurable increases in fine sediment. Road maintenance, road reconstruction and installation of six 

temporary culverts on Category 2 streams and eight culverts on Category 4 streams will also contribute to 

short-term immeasurable increases in fine sediment in the analysis area.

Measurable increases in fine sediment are predicted as a result of the replacement of a bridge and 

installation and removal of temporary culverts on fish bearing streams. These increases are predicted to be 

short-term. Aquatic habitat downstream of the bridge replacement site on Little Eagle Creek will be 

impacted due to a measureable increase in fine sediment to 0.125 miles of aquatic habitat. Under 

Alternative 2, three culverts on Category 1 streams and one culvert on a Category 2 stream will be 

replaced and will likely impact 0.46 miles of aquatic habitat. Under Alternatives 3 and 4, two culverts on 

Category 1 streams and one culvert on a Category 2 stream will be replaced and will likely impact 0.335 

miles of aquatic habitat. Measurable increases in fine sediment will likely last for up to four months from 

the bridge replacement and installation of temporary culverts.

Alternative 4 would likely have the least impacts to aquatic habitat because it has the least amount of 

ground disturbing activities. Alternative 3 would have fewer impacts to aquatic habitat than Alternative 2 

due to the lesser amounts of ground disturbing activities. All action alternatives would have short-term 

impacts as a result of proposed activities. The impacts to aquatic habitat would include: 1) short-term 

immeasurable increase in fine sediment as a result of timber harvest and prescribed burning activities and 

2) short-term measureable increases in fine sediment as result of replacing one bridge and installing three 

temporary culverts on Category 1 streams under Alternative 2, and two temporary culverts on Category 1 

streams under Alternatives 3 and 4. All action alternatives would result in a long-term improvement in 

aquatic habitat as a result of road improvements that will decrease overall erosion rates in the action area.
Chapter 3 Snow Basin Vegetation Management Project FEIS

139

Water temperature RMO

Ecological importance of RMO

Water temperature influences the metabolism, behavior, and health of fish and other aquatic organisms.

Fish can survive water temperatures near the extremes of their suitable temperature ranges. However,

growth is reduced at low temperatures because all metabolic processes are slowed. At the opposite 

extreme, growth is reduced at high temperatures because most or all energy from food must be used for 

maintenance needs. Fish are also more susceptible to diseases near the extremes of their suitable 

temperature ranges. A large range of temperature preferences for redband trout/rainbow trout has been 

reported in the literature, with substantial regional variability. In general, redband trout will occupy 

waterbodies with water temperatures from 55 to 64°F. Upper lethal temperature for redband trout is 

generally about 75°F.

Standards and guidelines

Forest Plan standards and guidelines

The Forest Plan water temperature standards are to meet state water quality standards and prevent 

measurable increases in water temperature (1990 Forest Plan, 1995 INFISH Amendment), and maintain 

maximum water temperatures below 64°F within migration and rearing habitat and below 60°F within 

spawning habitats (INFISH). The Forest Plan Watershed Standards and Guidelines are:

Standard 2: Water Quality Standards and BMPs. Meet Water Quality Standards for waters of the 

States of Oregon (Oregon Administrative Rules (ORAs), Chapter 340-41) and Idaho through 

planning, application, and monitoring of Best Management Practices (BMPs) in conformance 

with the Clean Water Act, regulations, and federal guidance issued thereto.

Standard 7: Stream Temperatures. Prevent measurable temperature increases in Class I Streams 

(less than a 0.5 degree Fahrenheit change). Temperature increases on stream management unit 

(SMU) Class II (and fishbearing Stream Management Unit Class III) streams will be limited to 

the criteria in State standards. Temperatures on other streams may be increased only to the extent 

that water quality goals on downstream, fish-bearing streams will still be met. Normally, stream 

shade management on Class III streams will differ little from treatment on Class II streams.

Oregon State water temperature standards 

In addition to meeting the Forest Plan standard, the Forest must meet Oregon water quality standards 

under the Clean Water Act. The EPA approved new water quality standards for Oregon in March 2004. 

Streams in the aquatic effects are considered “salmon and trout rearing and migration habitat” for Oregon 

water temperature standards. For the analysis area for aquatic habitat and species, the following water 

temperature standard applies: 

Eagle Creek and Tributaries downstream of the East Fork Eagle Creek Confluence:

(e) The seven-day-average maximum temperature of a stream identified as having Lahontan cutthroat 

trout or redband trout use on subbasin maps and tables set out in OAR 340-041-0101 to 340-041-0340: 

Tables 121B, 140B, 190B, and 250B, and Figures 180A, 201A, 260A and 310A may not exceed 20.0 

degrees Celsius (68.0 degrees Fahrenheit);

Existing conditions

Existing condition for stream temperatures is presented under Water Temperature in the Direct and 

Indirect Effects to Watershed Processes Section. In summary, water temperatures in the analysis area are 

generally meeting the ODEQ standard for redband trout. However, Little Eagle Creek does not meet the 

ODEQ standard for redband trout and redband trout likely experience thermal stress as a result of the high 

water temperatures.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Effects of Alternative 1

Current water temperatures would be maintained in the short-term because current management activities 

would continue. 

The majority of the timbered stands would be represented by a fuel model that is likely to exhibit 

moderate to high fire intensities and severities. These conditions increase the likelihood of a large-scale 

wildfire in the project area in the future (see Fire/Fuels Management Specialist Report). A wildfire in the 

area could elevate water temperatures for up to 10 years, depending on the wildfire severity (Dunham et 

al., 2007). If water temperatures exceeded 64o

F for an extended period of time as a result of wildfire, 

survival of redband trout would likely be reduced.

Effects of Alternatives 2, 3, and 4

As detailed in the Watershed Water Temperature Section, effects to aquatic habitat from water 

temperature increases are unlikely as a result of thinning and prescribed burning activities under the 

action alternatives. Thinning activities will occur in RHCAs; 50 acres under Alternative 2 and 43 acres 

under Alternatives 3 and 4. However, these activities will occur in the outer portions of RHCAs (greater 

than 100 feet from Category 1 and 2 streams) therefore stream shading is unlikely to be affected. Burning 

in RHCAs will occur under conditions that limit the severity and intensity of burning. Mortality of trees 

in RHCAs providing shading will likely be rare and limited to understory trees. Therefore, prescribed 

burning in RHCAs is unlikely to result in a measureable increase in water temperatures. 

LWD and pool habitat RMOs

Ecological importance of RMOs

LWD plays an important role in forested stream reaches. LWD aids in dissipating stream energy, trapping 

sediment and formation of pools and associated aquatic habitat. LWD also provides hiding cover for 

aquatic organisms. LWD is one of the most important sources of habitat and cover for fish populations 

(MacDonald et al., 1991). LWD provides suitable habitat over a wide range of streamflows and climatic 

conditions. LWD, habitat complexity, and salmonid production have been found to be related (Bisson and 

Sedell, 1984; Sedell and Swanson, 1984). LWD also functions as important colonization sites for aquatic 

macroinvertebrates and their food sources (Harmon et al., 1986; Dudley and Anderson, 1982).

LWD is a major component of channel form in smaller streams (Bisson et al., 1987). LWD can influence 

channel meandering, bank stability, variability in channel width, and affect the form and stability of 

gravel bars (Lisle, 1986). Megahan suggested that decreased LWD can result in less sediment storage and 

increased sediment routing and yield at the outlet of a watershed (1982).

Pool frequency is a gauge of aquatic habitat diversity, and is an indicator of the degree to which streams 

are capable of supporting a varied and complex community of fish species. Pools provide important 

habitat throughout all salmonid life stages (Bjorn and Reiser, 1991). Pools are important for providing 

rearing habitat for juvenile fish and cool water refugia areas for adult fish during periods of low flow and 

elevated temperatures. Pools slow the transport of nutrients and store them, fostering food production.

Pool tailouts provide optimal spawning areas for salmonids due to hydraulic gravel sorting and 

intergravel flow characteristics. Pools are persistent features of stream channels (Knighton, 1987). The 

presence and abundance of pools is an important indicator of aquatic habitat function (Sullivan et al. 

1987).

Effects of Alternative 1

Alternative 1 would maintain current levels of LWD and pool habitat in the short-term because current 

management activities would continue. As noted earlier, fish habitat in the analysis area generally meets 

the RMO for LWD but does not meet INFISH RMO for pool habitat (Table 39). Current management 

activities are required to meet INFISH Standards and Guidelines that promote improvement and recovery 
Chapter 3 Snow Basin Vegetation Management Project FEIS

141

of aquatic habitat. A gradual improvement in LWD and pool habitat will likely occur as riparian timber 

stands continue to develop and additional LWD is delivered to stream channels. It is uncertain whether 

the additional LWD will result in an increase in pool habitat (see aquatic habitat discussion). 

As noted earlier, fish habitat in the analysis area generally meets the RMO for LWD but does not meet 

INFISH RMOs for pool habitat (see Table 39). LWD in stream channels originate from both upslope and 

streamside zones (Naiman et al., 2000). Large-scale episodic events such as stand replacement fires 

(Harmon et al., 1986; Romme et al., 2011), landslides (Reeves et al., 2003), and the combination of the 

two events (Burton 2005) can supply large amounts of LWD that persists in stream channels for decades 

to centuries (Naiman et al., 2002). Since landslides are generally rare in the analysis area, the majority 

LWD reaching stream channels likely results from the streamside zone (Table 50). 

Table 50. Delivery Mechanisms for LWD in the Snow Basin project area

LWD Delivery Zone LWD Delivery Method Frequency Role in Analysis Area

Streamside Streambank Erosion Chronic / Episodic Primary

Wind Throw Chronic / Episodic Secondary

Disease Chronic / Episodic Secondary

Fire Episodic Rare

Upslope Landslide Episodic Rare

The majority of the timbered stands would be represented by a fuel model that is likely to exhibit 

moderate to high fire intensities and severities. These conditions increase the likelihood of a large-scale 

wildfire in the project area in the future (see Fire/Fuels Management Specialist Report). A wildfire in the 

area would likely result in an increase in LWD levels depending on the wildfire severity (Beschta et al.,

2004; Karr et al., 2004; Swanson et al., 2010, Romme et al., 2011).

Effects of Alternatives 2, 3, and 4

Timber harvest activities

Impacts to INFISH RMOs for LWD and pool frequencies are unlikely. About 50 acres in RHCAs will be 

included in commercial thinning units under Alternative 2 and 43 acres under Alternatives 3 and 4. In 

general, thinning activities will not occur within 200 feet of Category 1 stream channels and 100 feet of 

Category 2 stream channels. Given that an average site potential tree in the project area is 80 to 100 feet 

in height (J. Gilsdorf, Silviculturalist, Whitman RD), INFISH RHCA buffers should be sufficient to 

eliminate impacts to future LWD that originates from the streamside zone for Category1 and 2 streams. A 

majority of the proposed harvesting activities in Category 1 and 2 RHCAs will occur above roads; areas 

that are unlikely to provide LWD to stream channels.

Channel sinuosity and large roughness elements (e.g. boulders, tree roots, LWD, bedrock) create flow 

obstructions which result in the formation of pools. In general, pool habitat increases as LWD increases 

(Dollof and Warren, 2003; Montgomery et al., 1995). However, there does not appear to be a relationship 

between LWD and pool habitat in steeper streams (Montgomery et al., 1995) or in streams with low 

stream power (Jackson and Sturm, 2002). As noted earlier, the majority of streams in the analysis area are 

high gradient streams, including fish-bearing streams which have been surveyed (Table 39), which may 

reduce the pool forming function of LWD in the project area. 

Thinning units, skid trails, and landings will not be located adjacent to stream channels under the action 

alternatives. Restricting commercial thinning activities to at least 200 feet (twice the height if a site 

potential tree) for Category 1 streams is sufficient to prevent removal of trees with the potential to fall 

into stream channels as LWD and potentially create pool habitat. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

142

Small tributaries, such as Category 4 streams, can also transport LWD to streams, especially where debris 

flows occur (Naiman et al., 2000). However, debris flows do not appear to be a major process in the 

analysis area. The primary delivery area for LWD reaching Category 4 streams in the project area appears 

to be the streamside zone. 

Harvesting in Category 4 RHCAs has the potential to remove some trees that would provide future LWD 

to Category 4 stream channels. A limited amount of thinning will occur in Category 4 RHCAs; less than 

15 acres total. Thinning will be restricted to the outer 50 feet of Category 4 RHCAs where this occurs. 

These areas are located above roads, therefore any trees that were to fall towards the stream channels 

would be cut up and removed from the road prism. Given that the majority of trees to be thinned are 

likely smaller than a site potential tree (100 feet tall) and the average road prism for a seven-digit Forest 

Service Road is 14 feet wide, a small reduction in future LWD levels in Category 4 streams may occur 

where proposed thinning occurs in Category 4 RHCAs.

Danger trees will be removed from haul road corridors for public and forest worker safety. Danger trees 

in RHCAs will be felled and left on site in accordance with INFISH S&G TM-1.

Prescribed burning activities

Impacts to the LWD and pool frequency RMOs are unlikely. Proposed burning activities will not likely 

impact existing LWD or future LWD because the burn prescription will target consumption of material 

three inches and smaller. Fire intensities will not be high enough to consume trees or downed wood large 

enough to function as LWD (> 20 inch DBH) in stream channels. Therefore, burning activities will not 

result in a reduction of current or future levels of LWD or pool habitat under the action alternatives.

LWD additions

LWD will be added to about 7.5 miles of stream in the project area (Table 51). Stream segments that 

would benefit from additional LWD were selected based on stream survey information and professional 

opinion (Paul Boehne, WWNF Forest Fisheries Biologist). The sources of LWD will be from off-site

locations outside of RHCAs (e.g. conifers removed as part of aspen stand treatments, wind-thrown trees). 

The additional LWD would be placed in accumulations greater than four pieces. Each accumulation will 

contain at least one key piece (length > bankfull width, or > 12 inch diameter and > 35 feet in length; 

whichever is largest) with rootwad attached. Accumulations will span no more than 50 percent of the 

bankfull width of the stream channel. No cabling or rebar anchors will be used. Instead, stability of the 

LWD accumulations will rely on use of key-pieces and placement. Placement of LWD will occur with an 

excavator during the in-water work window (July 1 – October 31). The actual site designs will be 

completed prior to implementation of this activity.

Table 51. Additions of LWD in streams in the Snow Basin project area

Stream Miles Reach

Little Eagle Creek 3.0 Mouth to Forks

Paddy Creek 2.5 Mouth to Lost Cabin Creek

Holcomb Creek 2.0 On either side of PVT Land

Placement of additional LWD in Little Eagle Creek, Paddy Creek, and Holcomb Creek as described will 

improve channel stability, sediment storage, and aquatic habitat in the mid- to long-term. Short-term 

increases in fine sediment downstream of the activity sites will occur as the result of streambed and bank 

scour. However, these short-term increase are likely to be immeasurable as they will occur during high 

flow events.
Chapter 3 Snow Basin Vegetation Management Project FEIS

143

Additional Forest Plan RMOs

Effects of Alternative 1

Bank stability, lower bank angle, and width-to-depth ratio

Alternative 1 would maintain current levels of bank stability, lower bank angle, and width-to-depth ratios 

in the short-term, because current management activities would continue. As noted earlier, fish habitat in 

the analysis area generally meets the RMOs for bank stability, and width-to-depth ratios (see Table 39). 

Data on lower bank angles has not been collected. Current management activities are required to meet 

INFISH Standards and Guideline that promote improvement and recovery of aquatic habitat. 

Effects of Alternatives 2, 3, and 4

Timber harvest activities

Impacts to channel morphology RMOs (i.e. bank stability, lower bank angle, and width-to-depth ratio) 

will not occur because activities that could result in mechanical bank disturbance will not occur adjacent 

to Category 1 streams under the action alternatives. Thinning activities will occur in RHCAs; 50 acres 

under Alternative 2 and 43 acres under Alternatives 3 and 4. However, these activities will occur in the 

outer portions of RHCAs (greater than 100 feet from Category 1 and 2 streams). Skid trails for all harvest 

activities will disturb an estimated 68 acres in RHCAs. This represents 1.3 percent of the total acreage of 

RHCAs in the project area. The number of crossings will be minimized by maximizing skid trail spacing. 

Damage to streambanks at crossings will be minimized by choosing naturally harden sites for crossings 

and/or hardening crossings with brush or logs

Prescribed Burning Activities

Impacts to the other INFISH RMOs (i.e. bank stability, lower bank angle, and width-to-depth ratio) are 

unlikely. Some limited areas of decreased bank stability may occur where herbaceous vegetation along 

streambanks is top-killed during burning activities. These areas are likely to be small (less than 100 feet in 

length) and of limited duration (< 5 years). 

Cumulative effects

The cumulative effects analysis area for aquatic resources is the same as the analysis areas used for the 

direct and indirect effects analysis to watershed process and aquatic habitat. Time frames for this 

cumulative effects discussion are the same as those used for the direct/indirect effects analysis: 1) shortterm, 0 to 5 years; 2) mid-term, 5 to 10 years; and 3) long-term, >10 years. Refer to Appendix B for a list 

of projects and activities occurring in the analysis area that were considered for cumulative effects to 

aquatic habitat. Only activities that pose a risk of cumulative effects (adverse or beneficial) are discussed. 

The risks of cumulative effects with the activities proposed under the action alternatives are rated as:

• Low: insignificant or discountable cumulative effects on aquatic habitat may occur. Insignificant 

effects are defined as effects that a person, based on professional judgment, would not be able to 

meaningfully measure, detect, or evaluate. Discountable effects are those that are extremely 

unlikely to occur. 

• Moderate: insignificant cumulative effects on aquatic habitat are likely to occur. A moderate 

rating assumes potential effects on habitat. The level of effects will not result in measureable 

changes in survival rates or population levels of aquatic species with special management status 

(i.e. ESA-listed, MIS, or Sensitive).

• High: measureable cumulative effects on aquatic habitat are likely to occur. Measurable effects 

are likely to result in changes in survival rates and population levels of aquatic species with 

special management status (i.e. ESA-listed, MIS, or Sensitive). A high rating assumes obvious 

adverse effects on habitat and aquatic species with special management status. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

144

Alternative 1 would maintain current management activities therefore no additional cumulative effects to 

aquatic habitat would occur over the short- to mid-term (<10 years). Current watershed processes (water 

yield and streamflow, erosion and sedimentation, channel stability/function) would be maintained. The 

existing condition of aquatic habitat in the project area reflects the impacts of past management activities 

in the project area (See Aquatic Habitat Section). Improvements in the LWD and pool habitat elements 

will likely occur over the long-term (>10 years) as a result of changes in management activities resulting 

from the adoption of the INFISH Forest Plan Amendment (1995). The INFISH Forest Plan Amendment 

modified management activities to reduce impacts to aquatic habitat and to accelerate the recovery rate of 

aquatic habitat (INFISH, 1995). Pool habitat and LWD levels are likely lower than prior to the start of 

intensive timber harvest activities in the analysis area. Past vegetation management activities in the 

project area include 34 timber sales (green and salvage) from 1954 through 2003. Of the 34 timber sales, 

only six of the sales have occurred since 1995, when the Forest Plan was amended by INFISH. While 

specific habitat data is not available for the project area, trends in LWD and pool habitat in the project 

area likely mirror trends for LWD and pool habitat that have occurred in the Pacific Northwest and 

adjacent areas. Bilby and Ward found a significant decrease in LWD in managed streams compared to 

old-growth streams (1991). McIntosh et al. (1994) and Quigley et al. (1997) documented a general decline 

pool habitat since the 1930s in streams in the Columbia Basin. 

Past and Ongoing Activities

Vegetation Management Activities

The current stream and riparian conditions reflect past timber harvest and road building activities in the 

project area. The Eagle Creek Watershed Analysis provides information on activities that have occurred 

in the analysis area (1997). 

Past vegetation management activities in the project area includes 34 timber sales (green and salvage) 

from 1954 through 2003. Six of the sales occurred from 1990 to 1994 under the 1990 Forest Plan, and six 

of the sales have occurred since 1995, when the 1990 Forest Plan was amended by INFISH. Protection of 

aquatic habitat was not a major consideration during the design and implementation of sales prior to 1990. 

Timber harvest activities have occurred in about 40 percent of RHCAs (Table 52).

Table 52. Riparian areas affected by timber harvest by harvest type and subwatershed

Older subwatershed delineations used. (Data from Eagle Creek Watershed Analysis, 1997).

Subwatershed Total RHCA 

Acres

Selection Harvest 

(acres)

Regeneration 

Harvest (acres)

Total Area 

Harvested (%)

Eagle Creek – Skull 707 152 35 26

Little Eagle Creek 1,998 950 114 53

Eagle Creek – Holcomb 1,280 255 40 23

Eagle Creek – Paddy 1,561 300 387 44

Total 5546 1657 576 40

Current pool habitat and LWD levels are likely less in quantity, and width-to-depth ratios are higher than 

prior to the start of large-scale timber harvest in the project area. Erosion rates from the transportation 

system constructed for past timber sales are likely to be higher than prior to the start of large-scale timber 

harvest in the project area. 

Road building associated with past timber harvest activities in the analysis area has also likely impacted 

stream and riparian habitat. Percentages of riparian areas in the analysis area affected by roads ranges 

from a low of about 17 percent to a high of about 36 percent by subwatershed (Table 53). In some areas, 
Chapter 3 Snow Basin Vegetation Management Project FEIS

145

roads have caused channelization or filling of the floodplains (Eagle Creek Watershed Analysis, 1997). 

Roads located in riparian areas can also permanently alter the character of riparian areas and are chronic 

fine sediment sources.

Table 53. The percentage of riparian areas affected by roads by subwatershed

Older subwatershed delineations used. (Data from Eagle Creek Watershed Analysis, 1997)

Subwatershed Riparian Area Affected by Roads (%)

Eagle Creek – Skull 16.7 

Little Eagle Creek 33.4 

Eagle Creek – Holcomb 20.9 

Eagle Creek – Paddy 35.5 

Eagle Creek – Skull 16.7 

Road improvements and road decommissioning and addition of LWD activities proposed under the Snow 

Basin project will likely result in a decrease in erosion rates in the project area and a decrease in fine 

sediment levels in streams in the analysis area. Addition of LWD to 7.5 miles of streams in the project 

area will improve channel stability, sediment storage, and aquatic habitat in the mid- to long-term. These 

activities will result in an incremental improvement of impaired watershed processes and aquatic habitat 

conditions in the project area that have resulted from pre-INFISH timber sale activities. Therefore, 

activities proposed under the action alternatives for the Snow Basin Project are rated as having a moderate 

risk of positive cumulative effects on watershed processes, and aquatic species and their habitat.

Grazing Allotments

The analysis area for aquatic resources for the Snow Basin Project includes portions of five grazing 

allotments; four of which are active allotments (Table 54). Currently the majority of riparian areas in the 

project area are open to grazing. A majority of streams in the analysis area are Rosgen B channels that are 

resistant to impacts from livestock grazing. B channels are characterized by stable streambanks and are 

relatively insensitive to disturbance (Rosgen, 1996). Low gradient stream reaches (Rosgen C channels) 

are very sensitive to disturbance including grazing. About 11 percent of the stream miles in the analysis 

area are low gradient streams (see Table 39).

Impacts to riparian and stream habitat from grazing were identified in the Eagle Creek Watershed 

Analysis (1997). The assessment identified grazing as the likely source of high fine sediment levels in 

Ethel Creek and Snow Fork Creek. Grazing was identified as a cause for unstable streambanks in the 

analysis area. Areas where impacts were the greatest were characterized by low gradient stream reaches 

adjacent to roads (Eagle Creek Watershed Analysis, 1997).

Table 54. Range allotments in the Snow Basin project area

Allotment Name

National Forest 

Acres in project 

area

Livestock 

Numbers 

(Cow/Calf)

Dates of Use Type of Permit Grazing System

Boulder Creek 72 150 7/1-9/30 Term Deferred rotation

Trouble Gulch 592 16 6/1-9/30 Term Season-long

Eagle Valley 19,654 485 6/1-10/31 Term Deferred rotation

Goose Creek 8,155 487 6/1-10/30 Term Deferred rotation

Sheep Rock 41 Vacant n/a None None
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PACFISH/INFISH grazing guidelines (Enclosure B: Recommended Livestock Grazing Guidelines Rev. 

7/31/95; commonly referred to as “Enclosure B”) state that the “Influences of grazing must result in 

riparian restoration at a minimum of near natural rates.” This same reference, page 7, describes achieving 

a “near natural rate of recovery” in general, as avoiding effects that “carry over to the next year” so as to 

prevent the likelihood of cumulative, negative effects. In response to Enclosure B, the WWNF developed 

condition thresholds for utilization for herbaceous vegetation and shrubs (Enclosure: PACFISH/INFISH 

W-W Interpretations Pertaining to Livestock Management Activities [dated May 1996]; Table 55). By not 

exceeding these utilization levels, a near natural rate of recovery should be achieved.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Table 55. Wallowa-Whitman NF recommended utilization levels to meet Forest Plan

(INFISH) Standard and Guideline GM-1

Riparian Condition

(Based on PFC Assessment)

Riparian Utilization Levels

Grass and Grasslike (Greenline)

Sedge and Rush 

(Sinks)

Kentucky 

Bluegrass / 

Mixed Species 

(Terraces)

Woody 

Vegetation

Proper Functioning Condition 4 inches1 3 inches1 2 inches1 30%2

Functioning at Risk (Static or upward 

trend) 6 inches1 4 inches1 4 inches1 30%2

*Notes: 1) Remaining stubble height; 2) Current year’s growth

Implementation monitoring indicates that Forest Plan utilization standards are being met most years on 

the four active allotments (Teena Ballard, Range Program Manager, Whitman RD). There are areas where 

grazing impacts to streams have been identified in the analysis area and legacy effects from past grazing 

activities still evident; however, based on monitoring results, the current management strategy has 

generally been successful in allowing for the near natural rate of recovery of riparian/aquatic habitat 

components as required by INFISH GM-1. Therefore, ongoing grazing activities are rated as having a 

moderate risk of negative cumulative effects with the activities proposed under the action alternatives for 

the Snow Basin Project on watershed processes, aquatic species, and their habitat.

Noxious Weed Treatments

Noxious weed treatment is an ongoing activity that occurs within all project area subwatersheds. In 

general, these treatments have no effect to aquatic habitat because they occur outside of RHCAs. Weed 

treatments within RHCAs pose a risk to aquatic habitat and species. BMPs are used to minimize potential 

effects. Mitigation measures that include type of chemical treatments (using only herbicides that are 

labeled for use adjacent to aquatic areas), application rates, area treated, timing, and buffers on streams 

significantly reduce the risk of effects from this activity. Therefore, ongoing noxious weed treatment 

activities are rated as having a low risk of cumulative effects with the activities proposed under the action 

alternatives for the Snow Basin Project on watershed processes, and aquatic species and their habitat. 

Recreation Activities

Dispersed camping 

There are no developed campgrounds in the project area. Dispersed camping occurs in this area with 

camps located adjacent to Eagle Creek and Little Eagle Creek and other streams in the project area. 

Dispersed camp sites adjacent to streams are a source of fine sediment and camp wood cutting can reduce 

future LWD supplies. A short-term increase in erosion rates and an immeasurable increase in fine 

sediment are predicted to occur as a result of the action alternatives for the Snow Basin Project. 

Therefore, dispersed camping activities are rated as having a low risk of negative cumulative effects with 

the activities proposed under the action alternatives for the Snow Basin Project on watershed processes, 

aquatic species, and their habitat.

Transportation System Activities

Road maintenance

Regularly scheduled road maintenance occurs every 1 to 7 years depending on the condition of the road, 

the assigned maintenance level, and the maintenance priority. Other scheduled maintenance activities 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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occur as specific needs are identified. Maintenance levels for roads are determined by the road 

management objectives, the intended use, operational requirements, and budget levels. Maintenance 

activities occur primarily from late April to late November depending on the actual condition of the road 

and moisture level. Maintenance levels are summarized in the following paragraphs. 

Three types of road surfaces occur in the project area: 1) native (i.e. dirt surface), 2) improved (i.e. pit-run 

surface, spot-rocked), and 3) aggregate (i.e. crushed rock surface). The surface types vary for each 

maintenance level of road depending on the long-term objectives for the road.

Level 1 road maintenance occurs on roads closed to vehicle traffic and reoccurs on at least a seven-year 

rotation to protect adjacent resources such as soil, water, and fisheries. Roads and associated ditches are 

rehabilitated through natural re-vegetation and artificial seeding processes. Native species of grasses and 

forbs are seeded on selected areas. Maintaining drainage facilities and runoff patterns is emphasized. 

These roads may be reopened in the future to support management activities under a separate decision and 

analysis.

Level 1 road maintenance occurs in two steps. The first step blocks and disguises the entrance to close the 

road. Drainage structures, such as waterbars, are installed to minimize soil erosion. The second step 

involves annual inspection of the road closure method and maintenance of the drainage structures as 

needed. Culverts and waterbars are cleaned by hand since the road is closed to standard width vehicles 

and equipment. 

Level 2 road maintenance occurs on open roads managed for use by high-clearance vehicles. Level 2 

maintenance recurs on a 3 to 7 year rotation to protect adjacent resources such as soil, water, and 

fisheries. Level 2 maintenance entails cleaning culverts, maintaining or cutting water bars and drainage 

dips, outsloping road surfaces, grass seeding the entire road and ditch surfaces, and replacing culverts 

where needed. 

Level 3, 4, and 5 road maintenance occurs on open roads managed for use by low-clearance vehicles. 

Level 3, 4, and 5 maintenance recurs annually to protect adjacent resources such as soil, water, and 

fisheries. The difference between Levels 3, 4, and 5 depends on the degree of user comfort and 

convenience, surface types and treatments, and traffic management strategies. Level 3, 4, and 5 roads 

provide for long-term use and administration of National Forest System activities. 

Typical treatments for Level 3, 4, and 5 roads include patching pavement; chip sealing worn pavement 

surfaces; grading and/or replacing crushed aggregate surfaces; dust abatement on aggregate surfaces; 

creating drainage dips; maintaining and cleaning debris from water bars, drainage ditches, and culverts; 

seeding cut and fill slopes; trimming roadside brush; and felling incidental trees that pose hazards to 

passing motorists. 

Road maintenance practices can vary to provide additional protection to soil and water resources. Seeding 

of closed roads and low-use roads may be intensified. Keeping maintenance equipment away from 

streams and wet areas and limiting the number of stream crossings may be emphasized to protect soil and 

water resources. The use of pit-run (3 to 6 inches) rock on roadbeds may be used to increase protection 

from erosion. Emergency repair of roads may occur after natural disasters such as flash floods or 

unusually high spring runoff for all maintenance levels.

Road maintenance is an ongoing activity. Main gravel roads (such as FR 77, FR 7745) usually receive 

surface maintenance once a year. On about a five-year schedule, all other roads get inspected for deferred 

maintenance. Problems identified during inspections are taken care of within the year.

The short-term effects from road maintenance activities are minimized by following INFISH standards 

and guidelines, and road maintenance BMPs. In the long-term, road maintenance activities reduce adverse 

effects to aquatic habitat by reducing overall erosion rates from the road system. A short-term increase in 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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erosion rates and an immeasurable increase in fine sediment are predicted to occur as a result of the action 

alternatives for the Snow Basin Project. Therefore, ongoing road maintenance activities are rated as 

having a moderate risk of negative cumulative effects with the activities proposed under the action 

alternatives for the Snow Basin Project on watershed processes, aquatic species, and their habitat.

Harvest of Special Forest Products

Collection of fuelwood, Christmas trees, saw logs and house logs (up to three truck loads per permit), and 

posts and poles are permitted only in Management Areas 1, 3, 6, 10, and 11. Harvest of these products is 

not permitted in administratively prohibited areas such as developed campgrounds or within 100 feet of 

wet areas, seeps springs, bogs, and standing or flowing water. No trees are permitted to be cut within 300 

feet of perennial fish-bearing streams. Compliance with these regulations is monitored by USFS Special 

Forest Product Coordinators and Law Enforcement Officers. Therefore, harvest of special forest product 

activities are rated as having a low risk of negative cumulative effects with the activities proposed under 

the action alternatives for the Snow Basin Project on watershed processes, aquatic species, and their 

habitat. 

Prescribed Burning

About 1,036 acres of pile burning have occurred in the project area since 2007. Pile burning has a low 

risk of resulting in increases in erosion rates due to small patches of burned areas surrounded by large 

unburned areas. Typically, ground cover returns to burned patches 3 to 5 years after burning occurs. A 

short-term increase in erosion rates and an immeasurable increase in fine sediment are predicted to occur 

as a result of the action alternatives for the Snow Basin Project. Therefore, ongoing prescribed burning 

activities are rated as having a low risk of negative cumulative effects with the activities proposed under 

the action alternatives for the Snow Basin Project on watershed processes, aquatic species, and their 

habitat.

Private Land Activities

Timber harvest

Logging on private lands in Oregon falls under the Oregon Forest Practices Act. The Oregon Forest 

Practices Act, enacted in 1972 and amended numerous times through 2003, addresses, in part, roads, 

landslide potential, chemical applications, reforestation, and aquatic protection. It established Riparian 

Management Areas (RMA) of 100 feet from streams and lakes and 300 feet from wetlands; requires 

riparian area tree retention; restricts mechanical equipment within the RMA; and requires State Forester 

approval of a written plan for harvest activities within the RMA.

Private forest lands within and adjacent to the project area, with a couple of exceptions, have recently 

been heavily logged. The timing seems to have coincided with the reduction of harvest on NFS lands

occurring in the mid-1990s to early 2000s. These lands were tractor logged no matter the slope. They 

were harvested using a diameter limit apparently set at 10 inch DBH. All trees 10 inch DBH and greater 

were harvested leaving these areas at least minimally stocked with seedling to pole sized trees. Erosion 

rates from logged areas on private lands likely increased during and after logging activities. Impacts from 

these timber sales have likely abated since majority of the harvest activities occurred around 11 years ago.

A short-term increase in erosion rates and an immeasurable increase in fine sediment are predicted to 

occur as a result of the action alternatives for the Snow Basin Project. Therefore, timber harvest activities

on private lands are rated as having a low risk of negative cumulative effects with the activities proposed 

under the action alternatives for the Snow Basin Project on watershed processes, aquatic species, and their 

habitat.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Irrigation diversions/water withdrawals

The diversion for the Brooks Ditch is located on Little Eagle Creek. The diversion captures most of the 

flow of Little Eagle Creek during the irrigation season and delivers it to farm and ranchland in the Eagle 

Valley. As a result, flows in lower Little Eagle Creek are reduced by about 75 percent during late summer 

(Dave Salo, WWNF Forest Hydrologist). The loss of water to Little Eagle Creek results in a significant 

reduction in aquatic habitat for redband trout and other aquatic species. Water withdrawals also may be a 

contributing factor for high water temperatures in Little Eagle Creek (see Beschta, 1997). Other streams 

where significant water withdrawals occur during the low water period are: 1) Ethel Creek, 2) Conundrum 

Creek, and Twin Bridges Creek. These streams are all tributaries to Little Eagle Creek and flow is 

diverted into the Brooks Ditch. Proposed thinning and burning activities are unlikely to result in a 

significant increase in ECA in the project area therefore it is unlikely that the proposed activities will 

result in changes in water yield or streamflows. In general, direct/indirect effects to aquatic habitat from 

activities proposed under the action alternatives for the Snow Basin Vegetation Management are limited 

to short-term immeasurable increases in fine sediment and water temperature. Short-term measurable 

increases in fine sediment will occur as the result of bridge and culvert replacement activities. There is a 

low risk of cumulative effects with the diversion of irrigation water in the analysis area.

Global Climate Change

Global climate change has the potential to have impacts to aquatic habitat through increases in water 

temperature and changes in streamflows in response to changes in climates. The following information 

was developed by the Forest Service to highlight potential impacts to aquatic habitat in the Pacific 

Northwest:

Salmon and Trout in the Pacific Northwest and Climate Change

[Preparer: Pete Bisson, Aquatic and Land Interactions Program, Pacific Northwest Research 

Station. (http://www.fs.fed.us/ccrc/topics/salmon-trout.shtml, accessed 03/28/2011)]

Issue: One of the most important long-term threats to fish habitat resilience is climate change. A 

recent review of the effects of climate change on salmon (ISAB 2007) identified the following 

probable consequences of global warming along the Pacific coast of North America: 1) warmer 

temperatures will result in more precipitation falling as rain rather than snow, 2) snowpack will 

diminish and streamflow timing will be altered, 3) peak river flows will likely increase, and 4) 

water temperatures will continue to rise. Not all of these anticipated trends are necessarily 

harmful to aquatic habitat, and many pale in comparison to other anthropogenic factors, but they 

do have implications for salmon and trout populations.

Climate change scenarios predict an increase in large flood events, wildfires, and forest pathogen 

outbreaks, all of which have some potential to improve fish habitat complexity as a result of flood 

plain reconnection and large wood recruitment. Many effects of climate warming, however, will 

have negative habitat consequences for salmon. A higher frequency of severe floods will result in 

increased egg and alevin mortality owing to gravel scour, especially for fall- and winter-spawning 

species. Retreating winter snowpacks will run off earlier in the spring (Mote et al., 2003), 

potentially altering the life cycles of salmon whose seaward migration is timed to coincide with 

nearshore plankton blooms (Pearcy, 1997). Summer base flows will be lower, and the network of 

perennially flowing streams in a drainage system will shrink during the summer dry period, 

forcing fish into smaller wetted channels and less diverse habitats (Battin et al., 2006). Warmer 

water temperatures will increase physiological rearing costs and lower growth rates if warmer 

streams do not produce sufficient food resources to offset heightened metabolic demands. 

Additionally, summer temperatures may approach or exceed incipient lethal levels for salmon and 

trout (Crozier and Zabel, 2006; Crozier et al., 2008), and higher temperatures will likely favor 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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non-salmonid species that are better adapted to warmer water, including potential predators and 

competitors (Reeves et al., 1987).

As noted by Battin et al. (2006), climate change will force shifts in the distribution of salmon 

populations that will affect their ability to cope with natural disturbances, particularly drought. 

Streams located high in watersheds that historically provided some of the best habitat may no 

longer be accessible to salmon if snowpack is reduced, thus limiting available rearing areas and 

access to thermal refugia in summer. Crozier et al. (2008) modeled Chinook salmon 

(Oncorhynchus tshawytscha) population response to three climate scenarios in Idaho’s Salmon 

River and found that even moderate changes significantly increased the risk of local population 

extirpation. Crozier and Zabel (2006) suggested that two climate-related factors (temperature and 

streamflow) could affect habitat in different ways depending on local site characteristics; narrow, 

confined streams were more sensitive to flow changes, and wide streams were more sensitive to 

temperature changes. They concluded that different aspects of climate change were important at 

different spatial scales, and that a diversity of conditions was needed for metapopulation stability.

Trout and salmon within the interior Columbia River Basin may be especially sensitive to climate 

change, according to a recent report by a scientific panel (ISAB, 2007). Although the intensity of 

the effects will vary spatially, climate change will alter virtually all streams and rivers in the 

basin. Current predictions suggest that temperature increases alone will render 2 to 7 percent of 

headwater trout habitat in the Pacific Northwest unsuitable by 2030, 5 to 20 percent by 2060, and 

8 to 33 percent by 2090. Salmon habitat may be more severely affected, in part because these fish 

are usually restricted to lower, hence warmer, elevations within the region. Salmon habitat loss 

would be most severe in Oregon and Idaho with potential losses exceeding 40 percent by 2090. 

Loss of salmon habitat in Washington would be less severe, with the worst-case scenario 

indicating about 22 percent loss by 2090.

Likely Changes: Temperature records show that the Pacific Northwest has warmed 1.8 oF since 

1900, approximately 50 percent more than the average global warming during the same period. 

The warming rate for the region in the 21st century is projected to range from 0.2 to 1.1  ̊F per 

decade. Until late in the 21st century, precipitation changes for the region are projected to be 

relatively modest and likely to be indistinguishable from natural variability; however, some 

models suggest an increase in winter storm severity. Most climate models project long-term 

increases in winter precipitation and decreases in summer precipitation. These changes in

temperature and precipitation will alter the snowpack, streamflow, and water quality, particularly 

in the Columbia River Basin. Warmer temperatures will result in more precipitation falling as 

rain rather than snow. Snowpack will diminish, winter snow lines will retreat to higher elevations, 

and snowmelt timing will be altered. With earlier runoff, peak river flow will occur earlier in the 

year, and summer water temperatures will continue to rise as water levels drop.

Climate change has the potential to affect most freshwater life-history stages of trout and salmon. 

Increased frequency and severity of flood flows during winter will affect over-wintering juvenile 

fish and incubating eggs in the streambed. Eggs of fall- and winter-spawning fish, including 

Chinook, coho (Oncorhynchus kisutch), chum (O. keta), sockeye salmon (O. nerka), and bull 

trout (Salvelinus confluentus), may suffer higher levels of mortality when exposed to increased 

flood flows. Warmer winter water temperatures will accelerate embryo development and may 

cause premature emergence of fry. Bull trout require very cold headwater streams for spawning; 

therefore, a warming climate will disproportionately affect this species.

Options for Management: From a habitat resilience standpoint, maintaining as much water as 

possible in streams and lakes during periods of low flow will likely be the most effective way to 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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combat the harmful effects of climate change, but other management actions could also produce 

long-term benefits. Zabel et al. (2006) used population viability analyses to predict that,

“increasing the freshwater carrying capacity for juveniles is most likely important for recovery. 

This may include improving the quality of existing habitats and making areas currently 

unoccupied accessible or suitable.” Increased flooding associated with higher peak discharge in 

winter may result in greater societal pressure to prevent damage to homes and infrastructure by 

isolating rivers from their flood plains; therefore, habitat managers would be well served to ask 

where flooding can be allowed in a watershed and in particular where flooding will reconnect the 

river with flood-plain habitats of direct importance to overwintering salmon. Maintaining key 

flood-plain connections will also act as a hydrologic safety valve that helps reduce the scouring 

effect of high flows on redds.

Another management response to climate change involves restoring longitudinal connections 

throughout a drainage network, i.e., removing anthropogenic blockages to fish migrations up and 

down the watershed. With a constricted system of perennial stream channels in summer it will be 

important for all potentially usable habitats to be available.

A fourth management safeguard involves protecting and restoring riparian forests on valley floors 

and on alluvial terraces adjacent to stream channels. Riparian forests play an important role in the 

dynamics of the water table beneath and adjacent to streams, in moderating discharge during flow 

extremes, in controlling the concentration of soluble nutrients, in mediating the seasonal input of 

organic matter and terrestrial food items to aquatic ecosystems, and in regulating microclimate 

(Naiman et al., 2005).

Policies that explicitly maintain instream flows by limiting water withdrawals, enhancing floodplain connectivity by opening historically flooded areas where possible, removing anthropogenic 

barriers to fish movement and protecting riparian forests will be needed to conserve habitat 

resilience in the face of climate change. Without such policies in place, aquatic habitats are likely 

to become increasingly isolated, simplified, and less likely to recover after significant disturbance 

events.

Although options for forest managers to minimize the harm to aquatic resources from climate 

change are limited, there are several management actions that can help protect salmon and trout:

• Minimize anthropogenic increases in water temperature by maintaining well-shaded riparian 

areas. 

• Maintain a forest stand structure that retains snow, reduces the “rain on snow” effect 

associated with forest openings, and promotes fog drip. 

• Disconnect road drainage from the stream network to soften discharge peaks during heavy 

rainstorms. 

• Ensure that fish have access to seasonal habitats, e.g., off-channel wintering areas or summer 

thermal refugia. 

• Protect springs and large groundwater seeps from development and water removal, as these 

subterranean water sources will become increasingly important when surface flows are 

altered by climate change. 

Potential Impacts to Aquatic Habitat in the Analysis Area from Global Climate Change

Based on the above information, long-term changes to aquatic habitat in the analysis may occur as a result 

of global climate. These changes may include:

• Increases in water temperatures in response to increases in air temperature
Chapter 3 Snow Basin Vegetation Management Project FEIS

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• Changes in runoff patterns in response to an increase in the amount of winter precipitation that 

falls as rain

• Decreases in summer streamflows in response to a reduction in snowpack

• Reduced duration of spring runoff, but higher peak flows due to an increase the amount of winter 

precipitation that falls as rain

• Activities proposed under Alternatives 2, 3, and 4 are unlikely to have measureable cumulative 

effects with global climate change, because:

o The proposed thinning activities are unlikely to result in a change in runoff patterns, 

because a significant decrease in forested cover will not occur.

o Potential increases in water temperature as a result of proposed burning are unlikely to 

occur in the analysis area, and if increases do occur they are unlikely to be measureable.

An insignificant reduction in stream shading may result from prescribed burning activities proposed under 

the action for the Snow Basin Project. However, the reduction in shading is not likely to result in a 

measureable increase in stream temperatures in the analysis area. Therefore, climate change is rated as 

having a low risk of negative cumulative effects with the activities proposed under the action alternatives 

for the Snow Basin Project on watershed processes, aquatic species, and their habitat.

Foreseeable Future Activities

Wallowa-Whitman NF Travel Management Plan 

The upcoming Wallowa-Whitman National Forest Travel Management Plan (TMP), which has been in 

progress since 2006, will limit motor-vehicle use to designated roads, trails, and areas. It will also prohibit 

cross country travel and the use of closed roads by motor vehicles unless designated open for such uses 

(e.g. as OHV travel routes). Implementation of the travel plan is expected to begin in the summer of 2012 

with publication of the Motor Vehicle Use Map (MVUM). With the implementation of the TMP, some 

roads that are open now, but have had an objective to be closed when funding and opportunities allow, 

will be closed by promulgation (approximately 18 miles in the Snow Basin area). Some roads within the 

project area currently identified as closed (maintenance level 1), will be opened for motorized travel by 

full-size vehicles and/or OHVs (approximately 6 miles in Snow Basin). 

Closure of 12 miles (net) of road in the project area may lead to an improvement in aquatic habitat in the 

analysis area in the long-term. This activity is rated as having a low risk of positive cumulative effects 

with the activities proposed under the action alternatives for the Snow Basin Project on watershed 

processes, aquatic species, and their habitat.

Wallowa-Whitman NF Invasive Plants Treatment Plan 

Alternative 2 was the selected alternative for the WWNF Invasive Plants Treatment Plan FEIS. 

Alternative 2 uses integrated manual, mechanical, herbicide, and cultural treatments on approximately 

22,840 acres of mapped infestations, as well as on sites that may be detected in the future. Treatments will 

be completed following steps outlined in the Annual Implementation Planning process and Common 

Control Measures, according to Project Design Features and Herbicide Use Buffers that limit the extent 

and method of treatment appropriate to site conditions. In addition to these steps, the Early Detection, 

Rapid Response Decision Process will be followed for sites that may be detected in the future.

In 2005, the Pacific Northwest Regional Forester amended all Forest Plans in Region 6, adding new 

management direction, including an emphasis on early detection, and effective integrated treatment of 

invasive plants. The purpose of the Invasive Plants Treatment Plan EIS is to bring the treatment program 

on the Forest into compliance with the new standards and allow for effective treatments on all sites 

currently mapped and those that may be detected in the future. Initial treatments will rely more heavily on 
Chapter 3 Snow Basin Vegetation Management Project FEIS

154

herbicides, but the goal of this project is to reduce the use of herbicides over time as invasive plant 

objectives are met.

Effects on aquatic habitat conditions

Invasive plants are a threat to aquatic and riparian habitats due to their negative effects to native 

ecosystems. Currently, invasive plant infestations are limited in extent in the project area (see Invasive 

Plants Specialist Report). Infestations are mainly located in RHCAs and travel corridors (i.e. roads). 

Treatment of invasive plant infestations along roads will be treated as part of the prevention strategy for 

the Snow Basin Project. Impacts to aquatic and riparian habitats and aquatic species may result in shortterm adverse impacts but will improve riparian conditions in the long-term.

Weed treatments within RHCAs pose a risk to aquatic habitat and species and BMPs are used to minimize 

potential effects. Mitigation measures that include type of chemical treatments (using only herbicides that 

are labeled for use adjacent to aquatic areas), application rates, area treated, timing, and buffers on 

streams significantly reduce the risk of effects from this activity. Therefore, the WWNF Invasive Plants 

Treatment Plan is rated as having a low risk of cumulative effects with the activities proposed under the 

action alternatives for the Snow Basin Project on watershed processes, aquatic species, and their habitat.

Cumulative effects summary

Past and current management activities have had and are having impacts to aquatic habitat and aquatic 

species in the Snow Basin aquatic analysis area. These impacts have likely resulted in a decline in aquatic 

and riparian habitats in the analysis area compared to the period prior to intensive management activities.

Water temperatures, erosion rates, and fine sediment levels in the project area are likely higher today than 

prior to European settlement. Current activities (including livestock grazing and road maintenance 

activities) on Forest Service lands are managed under the standards and guidelines of INFISH, which 

were developed to speed the recovery of riparian and aquatic habitats.

Sediment produced from the Snow Basin Project would combine with sediment produced from other 

activities including recreation, grazing, logging, roads, fire, and private land activities. There will be a 

short-term increase in sediment production associated with project implementation moderated by 

effective BMP practices and mitigation measures. A long-term decrease in sediment is expected as a 

result of road reconstruction and fire risk reduction lessening cumulative effects.

No measureable change in channel stability/function is expected under any action alternative. This is 

because past, present, and reasonably foreseeable future actions are not predicted to appreciably resolve 

the negative human-caused influences on channel stability. The biggest contribution to stream instability 

within the cumulative effects analysis areas is the placement of roads within the stream migration 

corridor. These roads disallow streams to exhibit the pattern and profile they are wont to express in 

certain reaches of Eagle, and possibly Paddy and Little Eagle Creeks. There is no plan to remove and/or 

relocate these roads.

Livestock grazing and road maintenance activities in the project area are rated as a moderate risk for 

negative cumulative effects, with the activities proposed under the action alternatives for the Snow Basin 

Project on aquatic species and their habitat. This risk rating is based on the likelihood that immeasurable 

increases in fine sediment are likely to occur from the two activities that would be additive to potential 

immeasurable increases in fine sediment resulting from proposed activities for the Snow Basin Project. 

Measureable increases in fine sediment in aquatic habitat in the vicinity of the bridge replacement site on 

Little Eagle Creek and installation/removal of temporary culverts on Category 1 streams (three sites under 

Alternative 2 and two sites under Alternatives 3 and 4) and one culvert on a Category 2 stream will likely 

occur under the action alternatives of the Snow Basin Project. However, the predicted increases are likely 

to be limited in both area (extend less than 0.125 miles downstream of each site) and duration (dissipating 
Chapter 3 Snow Basin Vegetation Management Project FEIS

155

during runoff the following spring). Thus, it is unlikely that ongoing grazing or road maintenance 

activities will result in an additional measureable cumulative increase in fine sediment levels in the 

vicinity of the bridge and culvert sites. Therefore, there is a moderate risk of negative cumulative effects 

associated with these activities (Table 56). The risks of cumulative effects from nine other activities are 

rated as low (Table 56).
Chapter 3 Snow Basin Vegetation Management Project FEIS

156

Table 56. Summary of known past, present, and reasonably foreseeable actions with a risk cumulative 

effect on aquatic habitat and species

Project or 

Action 

Overlap Risk of 

Cumulative 

Effect?

Rationale

Time Space

Past and 

Ongoing 

Vegetation 

Management

No Yes Low

Impacts from timber harvests are mainly from sediment. The 

past harvests had INFISH standards and guidelines and 

BMPs to minimize sediment yield to streams. Road 

improvements, road decommissioning and LWD additions 

will result in incremental improvement in watershed 

processes and aquatic habitat. Cumulative effects would be 

beneficial.

Range Yes Yes Moderate

Potential impacts from cattle include damage to riparian 

areas and water quality. INFISH S&Gs and WWNF 

utilization levels minimize cattle impacts to aquatic habitat.

Invasive Plant 

Treatments 

(Ongoing)

Yes Yes Low

Weed treatments within RHCAs pose a risk to aquatic 

habitat and species and BMPs are used to minimize 

potential effects. Mitigation measures that include type of 

chemical treatments (using only herbicides that are labeled 

for use adjacent to aquatic areas), application rates, area 

treated, timing, and buffers on streams significantly reduce 

the risk of effects from this activity.

Dispersed and 

Developed 

Recreation 

(ongoing)

Yes Yes Low

Dispersed camp sites are located adjacent to fish-bearing 

streams. Dispersed camp sites adjacent to streams are a 

source of fine sediment and camp wood cutting can reduce 

future LWD supplies.

Road 

Maintenance 

(ongoing)

Yes Yes Moderate

The short-term effects from road maintenance activities are 

minimized by following INFISH standards and guidelines, 

and road maintenance BMPs. In the long-term, road 

maintenance activities reduce adverse effects to aquatic 

habitat by reducing overall erosion rates from the road 

system.

Special Forest 

Products 

(including 

firewood 

gathering)

Yes Yes Low

Harvest of these products is not permitted in administratively 

prohibited areas such as developed campgrounds or within 

100 feet of wet areas, seeps springs, bogs, and standing or 

flowing water. No trees are permitted to be cut within 300 

feet of perennial fish-bearing streams. Compliance with 

these regulations is monitored by USFS Special Forest 

Product Coordinators and Law Enforcement Officers.

Prescribed Fire 

(ongoing) Yes Yes Low

Pile burning has a low risk of resulting in increases in 

erosion rates due to small patches of burned areas 

surrounded by large unburned areas. Typically ground cover 

returns to burned patches 3 to 5 years after burning occurs.

Timber Harvest 

on Private 

Lands

No Yes Low

Erosion rates from logged areas on private lands likely 

increased during and after logging activities. Impacts from 

these timber sales have likely abated since majority of the 

harvest activities occurred around 11 years ago.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Project or 

Action 

Overlap Risk of 

Cumulative 

Effect?

Rationale

Time Space

Irrigation 

Diversions / 

Water 

Withdrawals

Yes Yes Low

Water withdrawals also may be a contributing factor for high 

water temperatures in Little Eagle Creek. However, 

direct/indirect effects to aquatic habitat from activities 

proposed under the action alternatives for the Snow Basin 

Vegetation Management are limited to short-term 

immeasurable increases in fine sediment and water 

temperature. ECA will not exceed 15% therefore water yield 

and streamflow unlikely to be affected by proposed 

activities.

Climate Change Yes Yes Low Potential for an increase in water temperatures in response 

to an increase in air temperatures.

WWNF Travel 

Management 

Plan

Yes Yes Low Decrease in road density may result in a decrease in fine 

sediment levels. Cumulative effects would be beneficial.

WWNF Invasive 

Plant Plan Yes Yes Low

Weed treatments within RHCAs pose a risk to aquatic 

habitat and species and BMPs are used to minimize 

potential effects. Mitigation measures that include type of 

chemical treatments (using only herbicides that are labeled 

for use adjacent to aquatic areas), application rates, area 

treated, timing, and buffers on streams significantly reduce 

the risk of effects from this activity.

Aquatic Species

This aquatic specialist report satisfies requirements of Forest Service Manual 2672.4 requiring the Forest 

Service to review all planned, funded, executed, or permitted programs and activities for possible effects 

on proposed, endangered, threatened, or sensitive species by completing a Biological Evaluation (BE). 

The BE process is intended to review the Snow Basin Project in sufficient detail to determine effects of 

alternatives on species in this evaluation and ensure proposed management actions would not:

• likely jeopardize the continued existence, or cause adverse modification of habitat, for a species 

that is proposed (P) or listed as endangered (E) or threatened (T) by the USDI Fish and Wildlife 

Service or NOAA National Marine Fisheries Service

• contribute to the loss of viability for species listed as sensitive (S) by USDA Forest Service, 

Region 6, or any native or desired, non-native species; nor cause any species to move toward 

federal listing (FSM 2672.4)

The following sources were used during the prefield review phase to determine the presence or absence of 

aquatic PETS species in the effects area for the Snow Basin Project: 

• Wallowa-Whitman N.F. GIS database

• Regional Forester’s (R6) sensitive animal list (Dated 01/31/2008) 

• ODFW stream survey and fish survey reports

• Forest Service stream survey reports, Wallowa-Whitman NF, Baker City, OR

• Oregon Natural Heritage Program (ORNHP) database

• Natural Heritage Conservation database (Biosource)

• Oregon Native Fish Report (2005 Public Review Draft)
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Analysis Area 

The analysis area for aquatic species is the same as the analysis area used for the direct and indirect 

effects analysis to aquatic habitat. Time frames for direct, indirect, and cumulative effects to aquatic 

species are the same as those used for the direct/indirect effects to aquatic habitat analysis: 1) short-term, 

0 to 5 years; 2) mid-term, 5 to 10 years; and 3) long-term, >10 years. 

Proposed, endangered, threatened, and sensitive aquatic species 

There are potentially seven Regional Forester sensitive species and critical habitat for one ESA-listed 

species in the analysis area (Table 57). The Snow Basin project will have no impact to aquatic sensitive 

species and no effect to ESA-listed fish species, as none are present, in the analysis area.

Table 57. Aquatic species with special management status present or suspected to be in the aquatic 

effects area

Status: MIS = Forest Plan management indicator species, R6S = Region 6 sensitive species, T = Threatened

Aquatic Species Status Documented in Analysis 

Area

Redband Trout (Oncorhynchus mykiss) R6S, MIS Yes

Western Ridged Mussel (Gonidea angulata) R6S Suspected

Inland Tailed Frog (Ascaphus montanus)

1 R6S Yes

Columbia Spotted Frog (Rana luteiventris)

1 R6S Yes

Shortfaced Lanx (Fisherola nuttalli) R6S Suspected

Columbia Pebblesnail (Fluminicola fuscus) R6S Suspected

Pristine Springsnail (Pristinicola hemphilli) R6S Suspected

Bull Trout (Salvelinus confluentus) Critical Habitat Designated Yes

See Snow Basin Wildlife Specialist Report for effects analysis for Columbia spotted frog and inland tailed frog.

Bull trout (Salvelinus confluentus) 

Bull trout have likely been extirpated from the Eagle Creek system since the 1990s. Dams, irrigation 

withdrawals, and interspecific interactions with introduced brook trout were likely the main reasons for 

their extirpation. The following information is from the 1997 ODFW Bull Trout Status Report (Buchanan 

et al., 1997):

Bull trout were documented in Eagle Creek and West Fork Eagle Creek in creel reports in 

1965. Angler reports indicate bull trout were caught in the Martin Bridge section of Eagle 

Creek (RM 19 – 29) during July, August, and September in the mid-1980s (ODFW, 

1993c). Oral histories taken from longtime residents indicate Dolly Varden “bull trout” 

were common in Eagle Creek in the 1940s and 1950s (Gildemeister, 1989). Sayre 

(Undated), reporting the results of a 1967 chemical poisoning project, stated that 

whitefish, rainbow, Dolly Varden (bull trout), and brook trout are found throughout the 

upper watershed. Extensive snorkeling surveys conducted between 1991 and 1994 failed 

to find bull trout in Eagle Creek (ODFW, 1995b).

Eagle Creek is located in the Hells Canyon Recovery Unit, Powder River Basin (Draft Recovery Plan, 

USFWS, 2002). According to the draft recovery plan there is foraging, migrating, and overwintering 

habitat present in Eagle Creek and may be considered as a site for transplanting bull trout (USFWS, 

2002). There are no current plans for reintroducing bull trout into Eagle Creek. [Note: USFWS 

redesignated recovery units. As of 2010 Eagle Creek is located in the Mid-Columbia Recovery Unit, 

Powder River Basin Critical Habitat Unit (USFWS 2010)]
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The following recovery actions have been identified that are applicable to the Snow Basin Project 

(USFWS 2002):

1.1.1) Reduce sediment production from roads and other sources (e.g., mines, over-grazed areas) known 

to be contributing sediment to streams. Roads and other sources of sediment delivery to streams have 

been identified in a number of assessments in the Pine-Indian-Wildhorse Core Area and Powder River 

Core Area (e.g., assessments conducted by the Powder River Basin Watershed Council, U.S. Forest 

Service, and Southwest Basin Native Fish Watershed Advisory Group). Activities such as removing 

unnecessary roads, stabilizing road crossings, relocating roads out of sensitive riparian areas, and altering 

grazing practices should be used to reduce sediment delivery to streams.

Actions Taken: Road maintenance and reconstruction will occur on roads used for the Snow 

Basin Project activities to correct drainage issues and reduce fine sediment production. Modeling 

suggests that road treatments will result in a reduction in fine sediment generated by roads (see 

Hydrologist report).

1.2.6) Provide fish passage at road crossings that have been identified as fish passage barriers. 

Assessments conducted on State- and County-owned roads and some public lands in the Pine Creek and 

Powder River basins have identified road crossings that are barriers to fish passage (see specific sites in 

Fedora (1998) and Mirati (1999)). Actions to provide fish passage at these sites should be implemented.

Actions Taken: Culverts to be replaced on fish bearing streams will meet Aquatic Organism 

Passage criteria.

1.5.1) Evaluate potential effects of degraded upland areas on stream and riparian habitats and implement 

actions to restore historic vegetation and processes where appropriate. Some land management practices 

(e.g., grazing and timber management) have degraded upland areas or produced conditions that have, or 

have the potential to negatively affect stream and riparian habitats. These areas should be evaluated and 

actions to restore historic vegetation and processes (e.g., fire regime) should be implemented to benefit 

bull trout and bull trout habitat.

Actions Taken: Thinning and prescribed fire activities proposed under the action alternatives for 

the Snow Basin Project have been designed to restore upland vegetation and fuel loads to HRV 

levels (see Vegetation and Fire/Fuels Management sections).

The Snow Basin Project (all alternatives) will have no effect to CR bull trout because they are not present 

in the analysis area. Action alternatives proposed under the Snow Basin Project will address three 

recovery actions for bull trout identified in the 2002 Draft Recovery Plan for Bull Trout (USFWS 2002).

Critical habitat

The USFWS issued a Final Rule for bull trout critical habitat for the coterminous United States on 

January 14, 2010 (75 FR 2270). The bull trout critical habitat designation includes approximately 5730.8 

miles of streams for the Mid-Columbia River Recovery Unit, including Eagle Creek and Little Eagle 

Creek in the project area. The Eagle Creek system has been identified for the reintroduction of bull trout 

as a recovery action for the species.

Critical habitat includes the stream channels within the designated stream reaches and a lateral extent as 

defined by the bankfull elevation on one bank to the bankfull elevation on the opposite bank. Bankfull 

elevation is the level at which water begins to leave the channel and move into the floodplain and is 

reached at a discharge that generally has a recurrence interval of 1 to 2 years on the annual flood series. If 

bankfull elevation is not evident on either bank, the ordinary high-water line must be used to determine 

the lateral extent of critical habitat. The lateral extent of designated lakes is defined by the perimeter of 

the waterbody as mapped on standard 1:24,000 scale topographic maps. Critical habitat for bull trout in 

the analysis area is displayed in Figure 6.
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Chapter 3 Snow Basin Vegetation Management Project FEIS

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Figure 6. Designated critical habitat for bull trout in the vicinity of the Snow Basin project area
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Primary constituent elements for bull trout

Based on the needs and current knowledge of the life history, biology, and ecology of bull trout and the 

characteristics of the habitat necessary to sustain the essential bull trout life-history functions, the 

following Primary Constituent Elements (PCEs) are essential for the conservation of bull trout and may 

require special management considerations or protection:

1) Springs, seeps, groundwater sources, and subsurface water connectivity (hyporheic flows) to contribute 

to water quality and quantity and provide thermal refugia.

Impacts to springs, seeps, groundwater sources, and subsurface water connectivity have occurred 

from livestock grazing and roads in the analysis area. Livestock tend to impact springs and seeps 

by hoof action when livestock are allowed to congregate in these areas. Subsurface flow has been 

intercepted by road cuts and ditches that result in minor disruptions of subsurface flow. 

Springs and seeps will be protected from adverse impacts using INFISH RHCA buffers from 

activities proposed under the Snow Basin Project. Buffer width will be 100 feet around the 

perimeter of springs and seep (Category 4 wetlands). Activities will not occur within these 

RHCAs.

2) Migration habitats with minimal physical, biological, or water quality impediments between spawning, 

rearing, overwintering, and freshwater and marine foraging habitats; including but not limited to 

permanent, partial, intermittent, or seasonal barriers.

Migration corridors for bull trout in the analysis area have been disrupted by irrigation diversions 

that have resulted in both physical and flow barriers. Water temperatures in Little Eagle Creek 

and Eagle Creek are warmer than the Oregon standard for bull trout.

Water quality will be protected by limiting activities in RHCAs and the use of BMPs and design 

features to limit the impacts from proposed activities. Increases in water temperature are unlikely 

because in general thinning activities will occur outside of INFISH RHCAs for Category 1 and 2 

streams. Thinning will occur in about 50 acres of RHCAs under Alternative 2 and 43 acres under 

Alternatives 3 and 4; however, thinning will be at least one site potential tree distance (100 feett)

from for Category 1 and 2 streams. Barriers to migration will not occur as a result of the proposed 

activities.

3) An abundant food base, including terrestrial organisms of riparian origin, aquatic macroinvertebrates, 

and forage fish.

Prior to the development of the hydropower system on the Snake River, Eagle Creek supported 

one of the largest runs of Chinook salmon in the Powder River system (Thompson and Haas, 

1960). Eagle Creek and its tributaries also supported a large run of steelhead. Both of these 

species provide an important food source for bull trout where the three species occur together.

The loss of these two species limits the forage base for a reintroduced bull trout population.

Activities proposed under the Snow Basin Project will not have measurable effects to aquatic 

habitat and therefore will not affect the potential food base for bull trout.

4) Complex river, stream, lake, reservoir, and marine shoreline aquatic environments; and processes that 

establish and maintain these aquatic environments with features such as large wood, side channels, pools, 

undercut banks and unembedded substrates, to provide a variety of depths, gradients, velocities, and 

structure.

Pool habitat and LWD levels are likely lower than prior to the start of intensive timber harvest 

activities in the analysis area. While specific habitat data is not available for the project area, 

trends in changes in LWD and pool habitat in the Pacific Northwest and adjacent areas have 
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likely occurred in the project area. McIntosh et al. (1994) and Quigley et al (1997) documented a 

general decline pool habitat since the 1930s. Bilby and Ward found a significant decrease in 

LWD in managed streams compared to old-growth streams (1991). Cover et al. documented 

increases in fine sediment in streams as the result of management activities in the Klamath 

Mountains of northern California (2008). Timber harvesting activities (including riparian 

harvesting) and the development of the current road system are likely causative factors in the 

decline in LWD, pool habitat, and increases in fine sediment compared to the pre-settlement 

conditions.

Activities proposed under the Snow Basin Project will not have measurable effects to aquatic 

habitat. Immeasurable increases in fine sediment are likely to occur as a result of the Snow Basin 

Project. Effects to LWD, pool habitat and streambanks will not occur because activities will not 

occur within 200 feet of fish bearing streams.

5) Water temperatures ranging from 2 to 15 °C (36 to 59 °F), with adequate thermal refugia available for 

temperatures that exceed the upper end of this range. Specific temperatures within this range will depend 

on bull trout life-history stage and form, geography, elevation, diurnal and seasonal variation, shading, 

riparian habitat, streamflow, and local groundwater influence.

Stream temperatures are likely higher than prior to the start of intensive timber harvest activities 

in the analysis area. While specific habitat data is not available for the project area, trends in 

changes in stream temperature in the PNW have likely occurred in the project area. For example, 

Beschta and Taylor documented a correlation between stream temperatures and the amount 

timber harvest activity that had occurred in a watershed (1988).

Limited water temperature monitoring has occurred in the analysis area (see Table 48). On Eagle 

Creek, four water temperature monitoring stations are located on Eagle Creek in the analysis area 

and two are located upstream of the analysis area (Table 48, Figure 5). The ODEQ water 

temperature for bull trout (<53.6 °F) is not being met in the analysis area or at the two water 

temperature monitoring stations upstream of the analysis area (see Table 48). Water temperatures 

in Eagle Creek appear to be naturally warm based on temperature data from Eagle Creek Site 8 

which is located near the wilderness boundary and about 11 stream miles above the project area.

A limited amount of commercial thinning activities will occur in the outer edges of RHCAs under 

the proposed action where stands overlap with RHCAs. Thinning activities will occur in RHCAs; 

50 acres under Alternative 2 and 43 acres under Alternatives 3 and 4. Thinning will not occur 

within 200 feet of Category 1 stream channels (twice the height of a site potential tree) and 100 

feet of Category 2 stream channels (height of a site potential tree). These distances meet the 

minimum requirements for RHCA widths for these stream categories and are sufficient to prevent 

removal of trees that provide stream shading. Restricting thinning activities to the outer edges of 

RHCAs will prevent adverse impacts to existing stream shading along perennial streams in the 

aquatic effects analysis area. Therefore, measurable increases in stream temperatures will not 

result from proposed thinning activities.

Proposed burning activities will result in a low severity fire in RHCAs adjacent to perennial 

streams in the project area. This will be accomplished by burning when fuel moisture levels are 

high, not actively lighting fires in RHCAs, and allowing fires to back into RHCAs from adjacent 

upslope areas. These techniques result in low intensity fires that burn in a patchy distribution of 

burned and unburned areas in RHCAs. Trees killed by prescribed fire in RHCAs will primarily be 

understory trees (< 8 inch DBH). Understory trees of this size typically do not provide significant 

levels of stream shading.
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Few riparian shrubs are also expected to be killed as a result of the proposed burning because 

they are present in the moister riparian areas. Where the above ground portions of riparian shrubs 

are killed, they will likely sprout back relatively quickly because the low severity fire will not be 

hot enough to kill root crowns.

The proposed burning in RHCAs adjacent to intermittent streams poses little risk of increasing 

stream temperatures because these streams are normally dry during the summer and fall months.

Based on these factors, the Snow Basin Project is unlikely to result in a measurable increase in 

water temperature and a degradation of water quality in streams in the aquatic effects analysis 

area.

6) In spawning and rearing areas, substrate of sufficient amount, size, and composition to ensure success 

of egg and embryo overwinter survival, fry emergence, and young-of-the-year and juvenile survival. A 

minimal amount of fine sediment, generally ranging in size from silt to coarse sand, embedded in larger 

substrates, is characteristic of these conditions. The size and amounts of fine sediment suitable to bull 

trout will likely vary from system to system.

Potential spawning areas for bull trout in the Eagle Creek system have not been identified. Eagle 

Creek in the project area is unlikely to serve as a spawning area for a reintroduced bull trout 

population due to its location in the system. Where bull trout populations are present in the 

Wallowa Mountains, bull trout spawning areas are generally located in the upper watersheds of 

stream systems. In the Eagle Creek system spawning habitat for bull trout would likely be present 

in Upper Eagle Creek SWS (upstream of the confluence if West Eagle Creek).

7) A natural hydrograph, including peak, high, low, and base flows within historic and seasonal ranges or, 

if flows are controlled, minimal flow departure from a natural hydrograph.

Irrigation diversions have greatly altered the summer hydrograph for Little Eagle, Ethel, 

Conundrum and Twin Bridge Creeks. The result is significant dewatering (estimated at 75

percent) of Little Eagle Creek during base flow periods (July to October) (see Water Yield and 

Streamflow Section)

The Snow Basin Project is unlikely to affect runoff or streamflows. As a result of the proposed 

harvest activities under Alternative 2, the predicted change in ECA for the Eagle Creek-Paddy 

Creek SWS is from the existing 5 to 9 percent. For the Little Eagle Creek SWS, the predicted 

change in ECA is from 5 to 11 percent. An ECA of ≥15 percent is the common threshold used for 

predicting a measureable change in streamflows.

8) Sufficient water quality and quantity such that normal reproduction, growth, and survival are not 

inhibited.

Irrigation diversions have greatly altered the summer hydrograph for Little Eagle, Ethel, 

Conundrum, and Twin Bridge Creeks. The result is significant dewatering (estimated at 75

percent) of Little Eagle during base flow periods (July to October). Water temperatures in Eagle 

Creek currently exceed the Oregon standard for bull trout. In part this is likely due to Eagle Creek 

being a naturally warm stream system. Water temperatures in Eagle Creek just below the 

wilderness boundary also exceed the bull trout standard, which is about 11 miles upstream from 

the project area.

The Snow Basin Project is unlikely to affect runoff or streamflows because the project is 

primarily a thinning project.

9) Sufficiently low levels of occurrence of predatory (e.g., lake trout, walleye, northern pike, smallmouth 

bass); interbreeding (e.g., brook trout); or competing (e.g., brown trout) species that, if present, are 

adequately temporally and spatially isolated from bull trout.
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Non-native brook trout are present in high numbers in the Eagle Creek system in the analysis 

area.

Activities proposed under the Snow Basin Project will improve, but not measurably, habitat for 

non-native fish species that could result in the establishment of new populations or the expansion 

of existing populations of non-native fishes.

Alternative 1

Watershed and aquatic habitat conditions would likely remain in their current condition for the next five 

years as the result of the continuation of current management activities. The current conditions of PCEs 

are unlikely to support the reintroduction of bull trout to the Eagle Creek system. The presence of an 

established brook trout population, the current irrigation system (dams and water withdrawals), and the 

absence of Chinook salmon and steelhead make the reintroduction of bull trout problematic.

The majority of the timbered stands in the project area would be represented by fuel models that are likely 

to exhibit moderate to severe fire severities in the case of a wildfire. Wildfires typically result in increases 

in fine sediment for 3 to 5 years, depending on the wildfire severity (Neary et al., 2005).

Alternative 1 may affect but would not likely adversely affect designated critical habitat for CR bull trout. 

Current habitat conditions and the presence of an established population of brook trout are unlikely to 

create conditions conducive to the reintroduction of CR bull trout. These conditions would persist under 

Alternative 1.

Alternatives 2, 3, and 4

Activities proposed under Alternatives 2, 3, and 4 of the Snow Basin Project (transportation system 

improvements, commercial harvest, non-commercial/thinning, aspen restoration, and prescribed burning 

activities) may affect but are not likely adversely affect critical habitat for bull trout. Anticipated effects 

to PCEs include short-term immeasurable increases in fine sediment and water temperature in the analysis 

area. A decrease in erosion from road surfaces will likely occur as a result of the proposed road 

improvements (see Watershed Aquatics Specialist Report). This decrease erosion rates will likely result in 

a mid to long-term decrease in fine sediment in Eagle Creek and Little Eagle Creek in the analysis area. 

Activities proposed under the Snow Basin Project are consistent with the Aquatic Conservation Strategy

(INFISH) of the Forest Plan, as amended.

There is a moderate risk of cumulative effects to critical habitat for bull trout from the proposed activities 

and ongoing road maintenance and grazing activities in the analysis area. Both of these activities can 

result in increases in fine sediment in aquatic habitat. Increases in fine sediment can reduce spawning 

success and overall fitness of bull trout. 

For ongoing road maintenance activities, short-term effects from road maintenance activities are 

minimized by following INFISH standards and guidelines, and road maintenance BMPs. In the long-term, 

road maintenance activities reduce adverse effects to aquatic habitat by reducing overall erosion rates 

from the road system.

For grazing activities, the potential cumulative effects are minimized by meeting INFISH Standards and 

Guidelines for grazing activities and WWNF PACFISH/INFISH utilization levels.

Redband trout (Region 6 Sensitive Species, Wallowa-Whitman NF Management Indicator 

Species) 

Redband trout, the resident form of Oncorhynchus mykiss, are a Region 6 sensitive species and a WWNF 

management indicator species. Redband trout in the project area likely shared a common gene pool with

Snake River steelhead prior to the construction of the Hells Canyon Dam Complex (Hells Canyon, 
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166

Oxbow, and Brownlee dams). Redband trout are widely distributed in the area and occupy all Category 1 

streams (Aquatic Habitat Section, Figure 3).

Life history

Redband trout are sensitive to changes in water quality and habitat. Adult redband trout are generally 

associated with pool habitats; although various life stages require a wide array of habitats for rearing, 

hiding, feeding, and resting. Pool habitat functions as important refugia during low water periods. An 

increase in sediment lowers spawning success and reduces the quantity and quality of pool and interstitial 

habitat. Other important habitat features include healthy riparian vegetation, undercut banks, and LWD.

Spawning takes place from March through May. Redband redds (i.e. spawning nests) tend to be located 

where velocity, depth, and bottom configuration induce water flow through the stream substrate, generally 

in gravels at the tailout area of pools. Eggs incubate during the spring and emergence occurs from June

through July depending on water temperatures. Redband trout may reside in their natal stream or may 

migrate to other streams within a watershed to rear.

Abundance in analysis area

Abundance surveys for redband trout have not occurred in the Eagle Creek system.

Effects of the alternatives

Alternative 1

Alternative 1 of the Snow Basin Project may Impact Individual redband trout and their habitat, but will 

not likely contribute toward federal listing or loss of viability to the population or species (MIIH). 

Watershed and aquatic habitat conditions would likely remain in their current condition for the next five 

years. The majority of the timbered stands in the project area would be represented by fuel models that 

are likely to exhibit moderate to severe fire severities in the case of a wildfire. Wildfires typically result in 

increases in fine sediment for 3 to 5 years, depending on the wildfire severity (Neary et al., 2005).

Adverse impacts to aquatic habitat would likely occur where fine sediment levels exceed the 20 percent 

threshold. These levels would likely decrease spawning success for redband trout, and a decrease survival 

of juvenile salmonids may occur. Increases in stream temperatures can last longer depending on the 

severity of fire in riparian areas. If water temperatures exceed 64o

F for extended periods as a result of 

wildfire survival of redband trout would likely be reduced. 

Alternatives 2, 3, and 4

Alternatives 2, 3, and 4 of the Snow Basin Project May Impact Individual redband trout and their Habitat 

(MIIH), but will not likely contribute toward federal listing or loss of viability to the population or 

species. Impacts to redband trout may occur as a result of short-term immeasurable increases in fine 

sediment and water temperature (see effects to aquatic habitat section). Short-term measurable increases 

in fine sediment will occur as a result of replacing one bridge, three culverts on Category 1 streams, and 

one culvert on a Category 2 stream under Alternative 2 (see Effects to Aquatic Habitat Section). Under 

Alternatives 3 and 4, the number of culvert replacements on Category 1 streams will be reduced to two.

Current levels of fine sediment in the majority of streams in the analysis area are below the 20 percent

threshold used to indicate adverse impacts to salmonids. In these areas short-term potential increases in 

fine sediment from proposed prescribed burning and thinning activities are unlikely to result in 

measurable increases in fine sediment in streams in the analysis area. 

Under Alternative 2, measureable increases in fine sediment in aquatic habitat will likely occur under the 

action alternatives of the Snow Basin Project in the vicinity of bridge replacement activities (one site), 

installation/removal of temporary culverts (three sites) on Category 1 streams and one culvert on a 

Category 2 stream. Under Alternatives 3 and 4, the number of culvert replacements on Category 1 streams 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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will be reduced to two. However, the predicted increases are likely to be limited in both area (extend less 

than 0.125 miles downstream of each site) and duration (dissipating during runoff the following spring). 

A decrease in erosion from road surfaces will occur as a result of the proposed road improvements (see 

Water Resources Specialist Report). This decrease erosion rates will likely result in a mid- to long-term 

decrease in fine sediment in Eagle Creek, Little Eagle Creek, Gold Creek, Cabin Creek, Torchlight Gulch, 

and Paddy Creek in the analysis area. The proposed action will also improve vegetative conditions and 

maintain the natural fire regime in the long-term in the project area. Both of these long-term outcomes 

will have beneficial impacts to redband trout and their habitat in the analysis area.

A limited amount of commercial thinning activities will occur in the outer edges of RHCAs under the 

proposed action where stands overlap with RHCAs. Thinning activities will occur in RHCAs; 50 acres

under Alternative 2 and 43 acres under Alternatives 3 and 4. Thinning will not occur within 200 feet of 

Category 1 stream channels (twice the height of a site potential tree) and 100 feet of Category 2 stream 

channels (height of a site potential tree). These distances meet the minimum requirements for RHCA 

widths for these stream categories and are sufficient to prevent removal of trees that provide stream 

shading. Restricting thinning activities to the outer edges of RHCAs will prevent adverse impacts to 

existing stream shading along perennial streams in the aquatic effects analysis area. Therefore, 

measurable increases in stream temperatures will not result from proposed thinning activities.

Placement of additional LWD in Little Eagle Creek, Paddy Creek, and Holcomb Creek on along 7.5 miles 

of stream will improve channel stability, sediment storage, and aquatic habitat in the mid- to long-term. 

Short-term increases in fine sediment downstream of the activity sites will occur as the result of 

streambed and bank scour. However, these short-term increase are likely to be immeasurable as they will 

occur during high flow events.

There is a moderate risk of cumulative effects to redband trout habitat from the proposed activities and 

ongoing road maintenance and grazing activities in the analysis area. Both of these activities can result in 

increases in fine sediment in aquatic habitat. Increases in fine sediment can reduce spawning success and 

overall fitness of redband trout. 

For ongoing road maintenance activities, short-term effects from road maintenance activities are 

minimized by following INFISH standards and guidelines and road maintenance BMPs. In the long-term, 

road maintenance activities reduce adverse effects to aquatic habitat by reducing overall erosion rates 

from the road system.

For grazing activities, the potential cumulative effects are minimized by meeting INFISH Standards and 

Guidelines for grazing activities and WWNF PACFISH/INFISH utilization levels.

Western ridge mussel (Region 6 sensitive species) 

Western ridge mussels were designated a Region Forester’s Sensitive Species during the development of 

the 2008 R6 Sensitive Species List. Initially, western ridge mussels were suspected to be present on the 

Wallowa-Whitman NF based a review of occurrence records. Additional record reviews and data searches 

by WWNF personnel revealed that western ridge mussels were historically present in large numbers in 

the Snake River and confirmed that western ridge mussels are currently present in the Snake River, Hells 

Canyon portion, on the Hells Canyon NRA. The current Snake River western ridge mussel population is 

suspected to be at very low levels compared to pre-European settlement. Relic shells of western ridge 

mussels were collected by WMO personnel during a monitoring trip on the Hells Canyon portion of the 

Snake River in October of 2010. Western ridge mussels were also documented in the Powder River 

(1963) and Grande Ronde River (pre-1929) downstream of the WWNF.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Life history

Western ridge mussels occur in streams of all sizes and are rarely found in lakes or reservoirs. They are 

found mainly in low- to mid-elevation watersheds, and do not often inhabit high elevation headwater 

streams where western pearlshells are found. They often share habitat with Margaritifera falcata (western 

pearlshell mussel) throughout much of the Pacific Northwest. They inhabit mud, sand, gravel, and cobble 

substrates. Western ridge mussels are more tolerant of fine sediments than western pearlshells and occupy 

depositional habitats and banks. They can withstand moderate amounts of sedimentation, but are usually 

absent from habitats with highly unstable or very soft substrates. Cursory evidence suggests that western 

ridged mussels are more pollution-tolerant than other native mussels.

Habitat for western ridge mussels appears to have fairly broad environmental gradients. In the John Day 

system western ridge mussels are more abundant in the mid and lower reaches of the M.F. and N.F. John 

Day Rivers compared to western pearlshell mussels (Brim Box et al., 2006). Habitat in the middle reaches 

of these streams in warmer and has higher levels of fine sediment compared to the upper reaches. In the 

Salmon River, Vannote and Minshall (1982) found western pearlshell mussels being replaced by western 

ridge mussels where fine sediment had increased as a result of timber management activities in the 

watershed.

Threats to western ridge mussels and other species of freshwater mussels include loss of host fish, 

introduction of non-native fish, dams, channel modification from channelization and suction dredge 

mining, thermal pollution, chemical pollution, sedimentation and siltation from silvicultural and 

agricultural practices, water withdrawal and diversion, and livestock grazing in riparian areas. Since 

western ridge mussels require stable habitats, they may be particularly threatened by dewatering and other 

activities that cause shifting substrates, water level fluctuations, and seasonal hypoxia or anoxia. Species 

that live for 20 to 30 years, as has been suggested for western ridge mussels, often appear to have healthy 

populations, when in reality only the older adults may be withstanding environmental changes and the 

population may no longer be reproducing.

Abundance in analysis area

The presence of western ridge mussels has been documented on the WWNF but has not been confirmed 

in the analysis area.

Effects of the alternatives

Alternative 1

Alternative 1 of the Snow Basin Project will have No Impact on Individual western ridge mussels and 

their habitat (NI), Watershed and aquatic habitat conditions would likely remain in their current condition 

for the next five years. Current aquatic habitat conditions in the analysis area are not likely limiting for 

western ridge mussels. 

The majority of the timbered stands in the project area would be represented by fuel models that are likely 

to exhibit moderate to severe fire severities in the case of a wildfire. Wildfires typically result in increases 

in fine sediment for 3 to 5 years, depending on the wildfire severity (Neary et al., 2005). Western ridge 

mussels would be vulnerable to impacts from large-scale wildfires that result in large increases in fine 

sediment and changes in peak flows. Western ridge mussels are adapted to habitats with fine sediment; 

however, large influxes of fine sediment could result in the burying of mussel beds and the death of 

individuals. Western ridge mussels require stable streambeds for mussel beds to develop. Increases in 

peak flows that scour streambed substrates destroy existing mussel beds. 

Alternatives 2, 3, and 4

Alternatives 2, 3, and 4 of the Snow Basin Project may Impact Individual western ridge mussels and their 

Habitat (MIIH), but will not likely contribute toward federal listing or loss of viability to the population 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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or species. Impacts to western ridge mussels may occur as a result of short-term immeasurable increases 

in fine sediment (see Effects to Aquatic Habitat Section).

Current levels of fine sediment in the majority of streams in the analysis area are below the 20 percent

threshold used to indicate adverse impacts to salmonids and other aquatic species. In these areas shortterm potential increases in fine sediment from proposed prescribed burning and thinning activities are 

unlikely to result in measurable increases in fine sediment in streams in the analysis area.

Impacts from activities proposed under Alternatives 2, 3, and 4 are unlikely to result in degradation of 

habitat for western ridge mussels. Anticipated immeasurable increases in both fine sediment and water 

temperature are within habitat tolerances for western ridge mussels.

Under Alternative 2, measureable increases in fine sediment in aquatic habitat will likely occur under the 

action alternatives of the Snow Basin Project in the vicinity of bridge replacement activities (one site), 

installation/removal of temporary culverts (three sites) on Category 1 streams and one culvert on a 

Category 2 stream. Under Alternatives 3 and 4, the number of culvert replacements on Category 1 streams 

will be reduced to two. However, the predicted increases are likely to be limited in both area (extend less 

than 0.125 miles downstream of each site) and duration (dissipating during runoff the following spring). 

A decrease in erosion from road surfaces will occur as a result of the proposed road improvements (see 

Watershed/Aquatic section). This decrease erosion rates will likely result in a mid- to long-term decrease 

in fine sediment in Eagle Creek, Little Eagle Creek, Gold Creek, Cabin Creek, Torchlight Gulch, and 

Paddy Creek in the analysis area. The proposed action will also improve vegetative conditions and 

maintain the natural fire regime in the long-term in the project area. Both of these long-term outcomes 

will have beneficial impacts to western ridge mussels and their habitat in the analysis.

A limited amount of commercial thinning activities will occur in the outer edges of RHCAs under the 

proposed action where stands overlap with RHCAs. Thinning activities will occur in RHCAs; 50 acres 

under Alternative 2 and 43 acres under Alternatives 3 and 4. Thinning will not occur within 200 feet of 

Category 1 stream channels (twice the height of a site potential tree) and 100 feet of Category 2 stream 

channels (height of a site potential tree). These distances meet the minimum requirements for RHCA 

widths for these stream categories and are sufficient to prevent removal of trees that provide stream 

shading. Restricting thinning activities to the outer edges of RHCAs will prevent adverse impacts to 

existing stream shading along perennial streams in the aquatic effects analysis area. Therefore, 

measurable increases in stream temperatures will not result from proposed thinning activities.

Placement of additional LWD in Little Eagle Creek, Paddy Creek, and Holcomb Creek on along 7.5 miles 

of stream will improve channel stability, sediment storage, and aquatic habitat in the mid to long-term. 

Short-term increases in fine sediment downstream of the activity sites will occur as the result of 

streambed and bank scour. However, these short-term increase are likely to be immeasurable as they will 

occur during high flow events.

There is a moderate risk of cumulative effects to western ridge mussel habitat from the proposed activities 

and ongoing road maintenance and grazing activities in the analysis area. Both of these activities can 

result in increases in fine sediment in aquatic habitat. Increases in fine sediment can reduce reproductive 

success and overall fitness of western ridge mussels. 

For ongoing road maintenance activities, short-term effects from road maintenance activities are 

minimized by following INFISH standards and guidelines, and road maintenance BMPs. In the long-term, 

road maintenance activities reduce adverse effects to aquatic habitat by reducing overall erosion rates 

from the road system.

For grazing activities, the potential cumulative effects are minimized by meeting INFISH Standards and 

Guidelines for grazing activities and WWNF PACFISH/INFISH utilization levels.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Shortfaced Lanx (Region 6 sensitive species)

Life history

The following species profile was downloaded from the Xerces Society website (Xerces Society Website: 

http://www.xerces.org/giant-columbia-river-limpet/ accessed September 29, 2011):

Fisherola nuttalli is a small pulmonate (lunged) snail in the family Lymnaeidae. It inhabits cold, 

unpolluted, medium to large streams with fast-flowing, well-oxygenated water and cobble and 

boulder substrate, and is generally found at the edges of rapids. It was historically present 

throughout much of the Columbia River drainage in Washington, Montana, Oregon, Idaho, and 

British Columbia, but most populations were extirpated due to habitat loss resulting from dams, 

impoundments, water removal, and pollution. Currently, large populations of F. nuttalli persist in 

only four streams: the lower Deschutes River in Oregon; the Okanogan River and the Hanford 

Reach of the Columbia River in Washington; and the Snake River in Oregon and Idaho. 

Additional small populations are found in Oregon in the John Day and Imnaha Rivers, and the 

lower Columbia River near Bonneville Dam; the Methow River, Washington; and the Grande 

Ronde River, Washington and Oregon. This species is threatened by habitat alteration and 

reduced water quality due to dams, impoundments, and siltation and pollution from agriculture, 

development, industry, and grazing.

Fisherola nuttalli is generally restricted to relatively large perennial streams ranging from 30 to

100 m (98 to 300 feet) wide. Within such streams it is found primarily at the edges of rapids or 

immediately downstream from rapids in areas that have suitable substrate. This species requires 

clean, cold, well-oxygenated water with gravel, cobble, and boulder substrate. In an assessment of 

Hells Canyon Dam (Snake River, Idaho), F. nuttalli was found on cobbles in higher velocity 

areas of the stream much more frequently than any other mollusk species; this was considered to 

reflect the species’ preference to attach themselves to hard surfaces in high velocities to avoid 

competition with other species (Richards et al. 2005). Fisherola nuttalli has not been found in 

areas with the following characteristics: slow flow; silt or mud substrates; extreme seasonal 

variations in discharge; an abundance of macrophytes (aquatic plants) or epiphytic algae; a 

bedrock substrate; or where dredging or mining occurs (Neitzel and Frest, 1992; Frest and

Johannes, 1995; Frest, 1999; Richards et al., 2005). The snails feed by scraping algae and diatoms 

from the surface of rocks and boulders.

Abundance in analysis area

The presence of shortfaced lanx has been documented on the WWNF but has not been confirmed in the 

analysis area. 

Effects of the alternatives

Alternative 1

Alternative 1 of the Snow Basin Project will have No Impact on Individual shortfaced lanx and their 

Habitat (NI). Watershed and aquatic habitat conditions would likely remain in their current condition for 

the next five years. Current aquatic habitat conditions in the analysis area are not likely limiting for 

shortfaced lanx. 

The majority of the timbered stands in the project area would be represented by fuel models that are likely 

to exhibit moderate to severe fire severities in the case of a wildfire. Wildfires typically result in increases 

in fine sediment for 3 to 5, depending on the wildfire severity (Neary et al., 2005). Shortfaced lanx would 

be vulnerable to impacts from large-scale wildfires that result in large increases in fine sediment.

Shortfaced lanx are adapted to habitats with low to moderate amounts of fine sediment. Large influxes of 

fine sediment could result in the loss of interstitial habitat and the death of individuals.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Alternatives 2, 3, and 4

Alternatives 2, 3, and 4 of the Snow Basin Project May Impact Individual Shortfaced lanx and their 

Habitat (MIIH), but will not likely contribute toward federal listing or loss of viability to the population 

or species. Impacts to shortfaced lanx may occur as a result of short-term immeasurable increases in fine 

sediment (see effects to aquatic habitat section).

Current levels of fine sediment in the majority of streams in the analysis area are below the 20 percent

threshold used to indicate adverse impacts to salmonids and other aquatic species. In these areas shortterm potential increases in fine sediment from proposed prescribed burning and thinning activities are 

unlikely to result in measurable increases in fine sediment in streams in the analysis area.

Impacts from activities proposed under Alternatives 2, 3, and 4 are unlikely to result in degradation of 

habitat for shortfaced lanx. Anticipated immeasurable increases in both fine sediment and water 

temperature are within habitat tolerances for shortfaced lanx.

Under Alternative 2, measureable increases in fine sediment in aquatic habitat will likely occur under the 

action alternatives of the Snow Basin Project in the vicinity of bridge replacement activities (one site), 

installation/removal of temporary culverts (three sites) on Category 1 streams and one culvert on a 

Category 2 stream. Under Alternatives 3 and 4, the number of culvert replacements on Category 1 streams 

will be reduced to two. However, the predicted increases are likely to be limited in both area (extend less 

than 0.125 miles downstream of each site) and duration (dissipating during runoff the following spring). 

A decrease in erosion from road surfaces will occur as a result of the proposed road improvements (see 

Watershed Aquatics Specialist Report). This decrease erosion rates will likely result in a mid- to longterm decrease in fine sediment in Eagle Creek, Little Eagle Creek, Gold Creek, Cabin Creek, Torchlight 

Gulch, and Paddy Creek in the analysis area. The proposed action will also improve vegetative conditions 

and maintain the natural fire regime in the long-term in the project area. Both of these long-term 

outcomes will have beneficial impacts to shortfaced lanx and their habitat in the analysis area.

A limited amount of commercial thinning activities will occur in the outer edges of RHCAs under the 

proposed action where stands overlap with RHCAs. Thinning activities will occur in RHCAs; 50 acres 

under Alternative 2 and 43 acres under Alternatives 3 and 4. Thinning will not occur within 200 feet of 

Category 1 stream channels (twice the height of a site potential tree) and 100 feet of Category 2 stream 

channels (height of a site potential tree). These distances meet the minimum requirements for RHCA 

widths for these stream categories and are sufficient to prevent removal of trees that provide stream 

shading. Restricting thinning activities to the outer edges of RHCAs will prevent adverse impacts to 

existing stream shading along perennial streams in the aquatic effects analysis area. Therefore, 

measurable increases in stream temperatures will not result from proposed thinning activities.

Placement of additional LWD in Little Eagle Creek, Paddy Creek, and Holcomb Creek on along 7.5 miles 

of stream will improve channel stability, sediment storage, and aquatic habitat in the mid to long-term. 

Short-term increases in fine sediment downstream of the activity sites will occur as the result of 

streambed and bank scour. However, these short-term increase are likely to be immeasurable as they will 

occur during high flow events.

There is a moderate risk of cumulative effects to shortfaced lanx habitat from the proposed activities and 

ongoing road maintenance and grazing activities in the analysis area. Both of these activities can result in 

increases in fine sediment in aquatic habitat. Increases in fine sediment can reduce reproductive success 

and overall fitness of shortfaced lanx. 

For ongoing road maintenance activities, short-term effects from road maintenance activities are 

minimized by following INFISH standards and guidelines, and road maintenance BMPs. In the long-term, 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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road maintenance activities reduce adverse effects to aquatic habitat by reducing overall erosion rates 

from the road system.

For grazing activities, the potential cumulative effects are minimized by meeting INFISH Standards and 

Guidelines for grazing activities and WWNF PACFISH/INFISH utilization levels.

Columbia pebblesnail (Region 6 sensitive species)

Life history

The following species profile was downloaded from the USFS / BLM Interagency Special Status / 

Sensitive Species Program (ISSSSP) website (http://www.fs.fed.us/r6/sfpnw/issssp/documents/planningdocs/sfs-ig-fluminicola-fuscus-2009-02.doc.; accessed September 29, 2011):

Originally known from the Lower Snake and Columbia River drainages in Washington, Oregon, 

Idaho, British Columbia, and possibly Montana (Frest and Johannes, 1995; Hershler and Frest,

1996). Probably extirpated from the middle and upper Columbia River in Washington, Montana, 

and British Columbia, and may be extinct in the lower Columbia River in Washington and 

Oregon (Frest and Johannes, 1995). It is still extant in some tributaries in Washington (Okanogan 

and Methow Rivers).

Found in larger tributaries and rivers, on upper surfaces of stable rocks, boulders and bedrock 

outcrops in fast current, in relatively shallow water. Species requires cold water with high oxygen 

content, so is not found behind impoundments, or where water is warm, slow, nutrient-enriched 

or turbid. Generally found in areas with few aquatic marcophytes of epiphytic algae.

Impoundments created by dams and other structures which create oxygen-poor conditions can 

create unsuitable habitat for this species. Waste-water or agricultural run-off into rivers can also 

create nutrient-rich conditions which are unfavorable to this species. Pollutants from pulp mill 

effluents or metal smelting discharges is harmful to Columbia pebblesnails.

Abundance in analysis area

The presence of Columbia pebblesnails has been documented on the WWNF but has not been confirmed 

in the analysis area. 

Effects of the alternatives

Alternative 1

Alternative 1 of the Snow Basin Project will have No Impact on Individual Columbia Pebblesnail and 

their Habitat (NI). Watershed and aquatic habitat conditions would likely remain in their current condition 

for the next five years. Current aquatic habitat conditions in the analysis area are not likely limiting for 

Columbia pebblesnails. 

The majority of the timbered stands in the project area would be represented by fuel models that are likely 

to exhibit moderate to severe fire severities in the case of a wildfire. Wildfires typically result in increases 

in fine sediment for 3 to 5 years, depending on the wildfire severity (Neary et al., 2005). Columbia 

pebblesnails would be vulnerable to impacts from large-scale wildfires that result in large increases in 

fine sediment. Columbia pebblesnails are adapted to habitats with low amounts of fine sediment and large 

influxes of fine sediment could result in the reduction in interstitial habitat and the death of individuals.

Alternatives 2, 3, and 4

Alternatives 2, 3, and 4 of the Snow Basin Project May Impact Individual Columbia Pebblesnail and their 

Habitat (MIIH), but will not likely contribute toward federal listing or loss of viability to the population 

or species. Impacts to Columbia Pebblesnail may occur as a result of short-term immeasurable increases 

in fine sediment (see effects to aquatic habitat section).
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Current levels of fine sediment in the majority of streams in the analysis area are below the 20 percent

threshold used to indicate adverse impacts to salmonids and other aquatic species. In these areas shortterm potential increases in fine sediment from proposed prescribed burning and thinning activities are 

unlikely to result in measurable increases in fine sediment in streams in the analysis area.

Impacts from activities proposed under Alternatives 2, 3, and 4 are unlikely to result in degradation of 

habitat for Columbia pebblesnail. Anticipated immeasurable increases in both fine sediment and water 

temperature are within habitat tolerances for Columbia pebblesnail.

Under Alternative 2, measureable increases in fine sediment in aquatic habitat will likely occur under the 

action alternatives of the Snow Basin Project in the vicinity of bridge replacement activities (one site), 

installation/removal of temporary culverts (three sites) on Category 1 streams and one culvert on a 

Category 2 stream. Under Alternatives 3 and 4, the number of culvert replacements on Category 1 streams 

will be reduced to two. However, the predicted increases are likely to be limited in both area (extend less 

than 0.125 miles downstream of each site) and duration (dissipating during runoff the following spring). 

A decrease in erosion from road surfaces will occur as a result of the proposed road improvements (see 

Watershed Aquatics Specialist Report). This decrease erosion rates will likely result in a mid- to longterm decrease in fine sediment in Eagle Creek, Little Eagle Creek, Gold Creek, Cabin Creek, Torchlight 

Gulch, and Paddy Creek in the analysis area. The proposed action will also improve vegetative conditions 

and maintain the natural fire regime in the long-term in the project area. Both of these long-term 

outcomes will have beneficial impacts to Columbia pebblesnail and their habitat in the analysis area.

A limited amount of commercial thinning activities will occur in the outer edges of RHCAs under the 

proposed action where stands overlap with RHCAs. Thinning activities will occur in RHCAs; 50 acres 

under Alternative 2 and 43 acres under Alternatives 3 and 4. Thinning will not occur within 200 feet of 

Category 1 stream channels (twice the height of a site potential tree) and 100 feet of Category 2 stream 

channels (height of a site potential tree). These distances meet the minimum requirements for RHCA 

widths for these stream categories and are sufficient to prevent removal of trees that provide stream 

shading. Restricting thinning activities to the outer edges of RHCAs will prevent adverse impacts to 

existing stream shading along perennial streams in the aquatic effects analysis area. Therefore, 

measurable increases in stream temperatures will not result from proposed thinning activities.

Placement of additional LWD in Little Eagle Creek, Paddy Creek and Holcomb Creek on along 7.5 miles 

of stream will improve channel stability, sediment storage, and aquatic habitat in the mid- to long-term. 

Short-term increases in fine sediment downstream of the activity sites will occur as the result of 

streambed and bank scour. However, these short-term increase are likely to be immeasurable as they will 

occur during high flow events.

There is a moderate risk of cumulative effects to Columbia pebblesnail habitat from the proposed 

activities and ongoing road maintenance and grazing activities in the analysis area. Both of these activities 

can result in increases in fine sediment in aquatic habitat. Increases in fine sediment can reduce 

reproductive success and overall fitness of Columbia pebblesnail. 

For ongoing road maintenance activities, short-term effects from road maintenance activities are 

minimized by following INFISH standards and guidelines, and road maintenance BMPs. In the long-term, 

road maintenance activities reduce adverse effects to aquatic habitat by reducing overall erosion rates 

from the road system.

For grazing activities, the potential cumulative effects are minimized by meeting INFISH Standards and 

Guidelines for grazing activities and WWNF PACFISH/INFISH utilization levels.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Pristine springsnail (Region 6 sensitive species)

Life history

The following species profile was downloaded from the USFS / BLM Interagency Special Status / 

Sensitive Species Program (ISSSSP) website (http://www.fs.fed.us/r6/sfpnw/issssp/planningdocuments/species-guides.shtml; accessed October 20, 2011):

Duncan (2008) states this species of snail is semelparous (reproduce a single time before dying) 

and males and females live 1 to 2 years. Pristinicola hemphilli is completely aquatic and breathe 

using gills. Snails feed upon algae, yeast, bacteria and diatoms from rocks and woody surfaces, 

although they have been known to feed upon other plant surfaces. Plant matter transported by 

birds and mammals as well as mud passively moving downstream may help aid in downstream 

dispersal.

Duncan (2008) states current sites are dominated by small cold streams which are undisturbed.

Populations at many of the sites contain hundreds of individuals, although numbers vary 

considerably from year to year due to environmental factors. Colonies are scattered through the 

Colombia and Snake River basins into western Idaho. Pristinicola hemphilli can also be found in 

interior Oregon in the Deschutes, Umatilla and John Day River basins. They are also known to 

occur in the Rogue, Umpqua and Smith River basins in southern Oregon and Del Norte County in 

northern California. Coastal drainages and undisturbed portions of the Willamette River basin 

may also contain some populations of this snail.

Frest and Johannes (1999) state habitats supporting this species tend to be small cold springs or 

seeps which are in a pristine condition and contain coarse gravel/cobble substrate. Sometimes 

snails are found in larger springs or areas of small streams which are affected by springs. Plants 

commonly found in association with the species include Rorippa, Mimulus and bryophytes. Sites 

tend to occur at low-medium elevation and are in semiarid sage scrub. Also, fairly dense 

Douglas-fir forests at low-medium elevation in the Cascades and Southern Oregon contain this 

species of snail

Duncan (2008) recommends that vegetative cover should be maintained, as well as water quality 

and the current hydrologic regime at sites known to contain this species of snail. Close 

monitoring and management of grazing should be enforced to assess the effects upon hydrologic 

patterns and the aquatic habitat. Activities which lower the flow rate or raise the water 

temperature such as diversions or pumping of groundwater should be restricted.

Abundance in analysis area

Has been documented on the WWNF but the presence of pristine springsnails has not been confirmed in 

the analysis area.

Effects of the alternatives

Alternative 1

Alternative 1 of the Snow Basin Project will have No Impact on Individual pristine springsnails and their 

Habitat (NI). Watershed and aquatic habitat conditions would likely remain in their current condition for 

the next five years. 

The majority of the timbered stands in the project area would be represented by fuel models that are likely 

to exhibit moderate to severe fire severities in the case of a wildfire. High severity wildfires typically burn 

through seeps and springs. Pristine springsnails would be vulnerable to during high severity wildfires. 

Alternatives 2, 3, and 4 
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Alternatives 2, 3, and 4 of the Snow Basin Project will have No Impact on Individual pristine springsnails 

and their Habitat (NI). Springs and seeps that provide habitat for pristine spring snails would be protected 

using Category 4 RHCAs (100 feet) around springs and seeps. Commercial harvest and ground disturbing 

activities will not occur within the RHCA surrounding springs and seeps. Therefore, no impacts to habitat 

for pristine springsnails or their habitat is anticipated.

Aquatic Management Indicator Species 

MIS selection

The following aquatic MIS species have been documented in the analysis area: redband trout. Redband 

trout are widely distributed across the WWNF occupying streams in both anadromous and nonanadromous stream systems. MIS species are indicators of riparian and aquatic habitat health. Monitoring 

for these MIS species consists of field inventory of stream conditions (WWNF Forest Plan Ch. 5, p 11). 

Current inventory methods for stream and riparian conditions include: stream surveys, Properly 

Functioning Condition (PFC) assessments, pebble counts, and Multiple Indicator Monitoring (MIMs).

Project relationship to Forest Plan

Forest Plan Habitat Desired Conditions/Objectives: “Riparian health will be maintained or enhanced 

through more stringent livestock management requirements to the benefit of wildlife and salmonid 

fishes.” (WWNF Forest Plan Ch. 4, p 13)

The WWNF Forest Plan was amended in 1995 by the direction of the Regional Forester with the Interim 

Strategy for Managing Anadromous Fish-Producing Watersheds in Eastern Oregon and Washington, 

Idaho, and Portions of California (INFISH). The goals of INFISH establish an expectation of the 

characteristics of healthy, functioning watersheds, riparian area, and associated fish habitats. Riparian 

management objectives (RMOs) were developed under INFISH to describe good habitat for anadromous 

salmonids. Data from Level II stream surveys are used to compare existing stream habitat conditions to 

Forest Plan RMOs. The WWNF uses default RMOs from the INFISH amendment rather than developing 

watershed specific RMOs. These default RMOs were developed from extensive Pacific Northwest and 

Intermountain (now Rocky Mountain) Research stations data collected in Oregon and Washington and 

stream inventory data collected by BLM and USFS units. The default RMOs were also developed prior to 

research that linked stream channel morphology to stream channel features such as pool spacing and 

width to depth ratios. 

Streambank Stability: Stable streambanks are an important component of streams and aquatic habitat. 

Stable streambanks reduce the likelihood of excessive streambank erosion and channel migration. Stable 

streambanks also result in the creation of undercut streambanks in certain stream channel types (i.e. 

Rosgen E and C channel types) that provide important habitat for salmonids. The INFISH Forest Plan 

amendment established an RMO for bank stability for streambanks to be >80 percent stable (1995). The 

INFISH RMO was modified in 1995 and 1998 for streambanks to be >90 percent stable as part of the 

ESA consultations for the Forest Plan (NMFS 1995, 1998).

Fine Sediment: The INFISH amendment did not include an RMO for fine sediment (1995). As a result of 

ESA consultation for Forest Plans in the range of Snake River (SR) Chinook salmon (1995) and SR 

steelhead (1998) an RMO was developed for fine sediment. The RMO is <20 percent fine sediment 

(particles <6.8mm in size) in spawning areas or <30 percent embeddedness in rearing areas as part of the 

ESA consultations for the Forest Plan (NMFS 1995, 1998).

Pools per Mile: The INFISH RMO (pools/mile) is based on wetted stream width (Table 58). 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Table 58. INFISH RMO for pool habitat

Stream 

Wetted 

Width 

(ft)

10 20 25 50 75 100 125 150 200

Number 

of Pools 

per Mile

96 56 47 26 23 18 14 12 9

LWD per Mile: The INFISH RMO for streams east of the Cascade crest is greater than 20 pieces per mile; 

with piece size greater than 12inches in diameter and greater than 35feet in length. 

Wetted Width-to-Depth Ratio: The INFISH Forest Plan amendment established an RMO for width-todepth ratio of <10 (1995).

Water Temperature: The Forest Plan water temperature RMO directs the Forest to meet state water 

quality standards and prevent measurable increases in water temperature (1995 INFISH Water 

Temperature RMO), and maintain maximum water temperatures below 64°F within migration and rearing 

habitat and below 60°F within spawning habitats (INFISH).

Standards and guidelines for aquatic MIS habitat 

Watershed Standard and Guideline 6: Timber Management. Harvest will not occur, on a scheduled basis, 

within 100 feet of the high water line on either side of Class I and II streams. Under the action 

alternatives for the Snow Basin Project, timber harvest and thinning activities will not occur within 100 

feet of Class I and II streams.

Watershed Standard and Guideline 7: Stream Temperatures. Prevent measurable temperature increases in 

Class I streams (less than a 0.5 degree Fahrenheit change). Temperature increase on SMU Class II (and 

fish bearing SMU Class III) streams will be limited to the criteria in State standards. Under the action 

alternatives for the Snow Basin Project, timber harvest and thinning activities will not occur within 100 

feet of Class I and II streams therefore no measurable changes in water temperature are likely. 

Prescribed burning activities may result in the loss of shading but a measureable change in water 

temperatures is not expected to occur.

Watershed Standard and Guideline 8: Channel Stability. Maintain natural LWD, plus trees needed for a 

future supply, to protect or enhance stream channel and bank structure, enhance water quality, and 

provide structural fish habitat in all SMU classes. Under the action alternatives for the Snow Basin 

Project, timber harvest and thinning activities will occur in RHCAs to meet silvicultural objectives for 

improving the condition of the stands (see Vegetation section). 

INFISH TM-1: Prohibit timber harvest, including fuelwood cutting, in RHCAs except: (b) Apply 

silvicultural practices for RHCAs to acquire desired vegetation characteristics where needed to attain 

RMOs. Apply silvicultural practices in a manner that does not retard the attainment of RMOs and that 

avoid adverse effects on inland native fish. Under the action alternatives for the Snow Basin Project, 

timber harvest and thinning activities will occur in RHCAs to meet silvicultural objectives for improving 

the condition of the stands. Thinning will not occur within 100 feet of Category 1 and 2 streams and 

within 50 feet of Category 4 streams (See discussions in Aquatic Habitat Section, Fine Sediment RMO, 

Stream Temperature RMO, and LWD/Pool Habitat RMOs)

INFISH RF-2b: For each existing or planned road, meet the RMOs and avoid adverse effects to inland 

native fish by minimizing road and landing locations in RHCAs. Under the action alternatives for the 

Snow Basin Project, use of skid trails and landings will be minimized in RHCAs. Existing landings in 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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RHCAs will be used where a road is located between the landing and stream channel. Existing landing 

adjacent to stream channels will not be used. No new landings will be constructed in RHCAs. Use 

forwarder logging system in units identified for ground-based yarding systems where activities enter into 

RHCAs. This will reduce disturbed soil conditions where landings and skid trails are located in RHCAs.

INFISH RF-3a and b: a) reconstructing road and drainage features that do not meet design criteria or 

operation and maintenance standards, or that have been shown to be less effective than designed for 

controlling sediment delivery, or retard attainment of RMOs, or do not protect priority watersheds from 

increased sedimentation; b) prioritizing reconstruction based on the current and potential damage to 

inland native fish and their priority watersheds, the ecological value of the riparian resources affected, and 

the feasibility of options such as helicopter logging and road relocation out of RHCAs. Under the action 

alternatives for the Snow Basin Project, roads that will be used for proposed vegetation management 

activities will have drainage problems repaired and will be brought up to standards prior to haul.

INFISH FM-1: Design fuel treatment and fire suppression strategies, practices, and actions so as not to 

prevent attainment of RMOs, and to minimize disturbance of riparian ground cover and vegetation. Under 

the action alternatives for the Snow Basin Project, fire severity will be limited to a low fire severity in 

RHCAs adjacent to perennial streams in the project area by burning when fuel moisture levels are high, 

not actively lighting fires in Category 1 and 2 RHCAs, and allowing fires to back into RHCAs from 

adjacent upslope areas.

INFISH FM-4: Design prescribed burn projects and prescriptions to contribute to the attainment of 

RMOs. Under the action alternatives for the Snow Basin Project, the burn prescription for Snow Basin 

will result in a low intensity burn within RHCAs.

Project-level MIS effects analysis 

Fish habitat generally does not meet INFISH RMOs for pool habitat and width-to-depth ratio in the 

analysis area (Table 39). Pool habitat in particular is lacking in the project area. LWD levels generally 

meet the RMO. In general, pool habitat increases as LWD increases (Dollof and Warren, 2003). However, 

there does not appear to be a relationship between LWD and pool habitat in steeper streams (Montgomery 

et al. 1995) or in streams with low stream power (Jackson and Sturm, 2002). As noted earlier, the 

majority of streams in the analysis area are high gradient streams, including the fish-bearing which have 

been surveyed (Table 39), and may reduce the pool forming function of LWD in the analysis area. 

Based on observations made during the 2009 stream evaluations, streams in the project area indicated that 

stream stability was generally high and met the 80 percent stability standard (Table 39). Many of the 

streams are located in inner gorges, and have rocky well-vegetated banks; typical of Rosgen B-type 

channels. 

The Snow Basin Vegetation Management avoids adverse impacts to riparian and aquatic habitats by 

designing the project to be consistent with Forest Plan Standards and Guidelines for aquatic habitat. 

Effects (direct, indirect, and cumulative) of proposed activities on habitat for redband trout are disclosed 

in the Aquatic Habitat section of this report. Effects (direct, indirect, and cumulative) to redband trout and 

steelhead resulting from the Snow Basin Project are disclosed in the Proposed, Endangered, Threatened,

and Sensitive Aquatic Species Section of this report. 

In summary, under Alternative 2, measureable increases in fine sediment in aquatic habitat will likely 

occur under the action alternatives of the Snow Basin Project in the vicinity of bridge replacement 

activities (one site), installation/removal of temporary culverts (three sites) on Category 1 streams and one 

culvert on a Category 2 stream. Under Alternatives 3 and 4, the number of culvert replacements on 

Category 1 streams will be reduced to two. However, the predicted increases are likely to be limited in 

both area (extend less than 0.125 miles downstream of each site) and duration (dissipating during runoff 

the following spring).
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Additional impacts to redband trout may occur as a result of short-term immeasurable increases in fine 

sediment and water temperature as a result of activities proposed under Alternatives 2, 3, and 4 of the 

Snow Basin Project (see the Aquatic Habitat and Aquatic Species sections of this report). 

A decrease in erosion from road surfaces will occur as a result of the proposed road improvements (see 

Watershed Aquatics Specialist Report). This decrease erosion rates will likely result in a mid to long-term 

decrease in fine sediment in Eagle Creek, Little Eagle Creek, Gold Creek, Cabin Creek, Torchlight Gulch, 

and Paddy Creek in the analysis area. The proposed action will also improve vegetative conditions and 

maintain the natural fire regime in the long-term in the project area. Both of these long-term outcomes 

will have beneficial impacts to redband trout and their habitat in the analysis area.

The level of effects anticipated to result from the Snow Basin Project will not result in the loss of viability 

of redband trout.

Consistency with Direction, Regulations, and Laws

Wallowa-Whitman Forest Plan 

The Snow Basin Project is consistent with the WWNF Forest Plan including the 1995 INFISH 

amendment. In addition to meeting standards and guidelines for water quality (see effects to aquatic 

habitat discussion), the proposed activities are consistent with all Forest Plan Watershed and INFISH 

standards and guidelines.

Watershed standards and guidelines

1. Conflicts with Other Uses. Given management and enhancement of water quality, protection of 

watercourses and streamside management units, and fish habitat priority over uses described or 

implied in all other management standards or guidelines. Met through application of BMPs, 

mitigation measures including project design features (PDFs) and INFISH RMOs.

2. Water Quality Standards and BMPs Meet Water Quality Standards for waters of the States of 

Oregon (Oregon Administrative Rules, Chapter 340-41) and Idaho through planning, application, 

and monitoring of Best Management Practices (BMPs) in conformance with the Clean Water Act, 

regulations, and federal guidance issued thereto. Met through application of BMPs, mitigation 

measures including project design features (PDFs) and INFISH RMOs.

3. Use the following process in cooperation with the States of Oregon and Idaho

a. Select and design BMPs based on site-specific conditions, technical, economic, and 

institutional feasibility, and the water quality standards for those waters potentially 

impacted (See Watershed Management Practices Guide for Achieving Soil and Water 

Objectives, Wallowa-Whitman NF).

b. Implement and enforce BMPs

c. Monitor to ensure that practices are correctly applied as designed.

d. Monitor to determine the effectiveness of practices in meeting design expectations and in 

attaining water quality standards.

e. Evaluate monitoring results and mitigate where necessary to minimize impacts from 

activities where BMPs do not perform as expected.

f. Adjust BMP design standards and application when it is found that beneficial uses are not 

being protected and water quality standards are not being achieved to the desired level. 

Evaluate the appropriateness of water quality criteria for reasonably assuring protection 

of beneficial uses. Where appropriate, consider recommending adjustment of water 

quality standards.

g. Met through BMP development during project design and analysis. Implementation and 

monitoring of BMPs will occur when project implementation proceeds.
Chapter 3 Snow Basin Vegetation Management Project FEIS

179

4. State Water Quality Management Plans. Implement (Oregon) State Water Quality Management. 

Plans on lands administered by the USDA Forest Service as described in Memoranda of 

Understanding between The Oregon Department of Environmental Quality and US Department 

of Agriculture, Forest Service (2/12/79 and 12/7/82), and "Attachments A and 8" referred to in 

this MOU (Implementation Plan for Water Quality Planning on National Forest lands in the 

Pacific Northwest 12/78 and Best Management Practices for Range and Grazing Activities on 

Federal Lands, respectively). Beyond the scope of this project. A Water Quality Restoration Plan 

will be developed after the TMDL is completed for the Powder River Basin.

5. Mitigation. Mitigate negative impacts causing reduction in water quality to return water quality to 

previous levels in as short a time as possible (It is recognized that short-term reductions in water 

quality may result from some activities. For example, turbidity may increase for several days 

following bridge or culvert installation). BMPs and PDFs have been designed as effective 

mitigation for the project.

6. Timber Management. Harvest will not occur, on a scheduled basis, within 100 feet of the high 

water line on either side of Class I and II streams. Harvest may occur along these streams, for 

other than timber management purposes, when doing so would maintain or enhance water quality, 

fish habitat, and wildlife habitat Along Class 111 and IV streams, manage tree stands to maintain 

the vegetative characteristics needed for water quality protection or improvement and to maintain 

or enhance stream channel stability Only those treatments that maintain or enhance water and 

riparian quality and are consistent with riparian management and fish habitat goals will be applied 

Actual harvest levels will be determined on a site-specific basis and will be governed by needs to 

protect and improve the riparian-dependent resources. The FEIS shows how timber harvest will 

not occur within RHCAs, with limited exceptions. The maintenance and enhancement of water 

and riparian quality is shown in the FEIS.

7. Stream Temperatures. Prevent measurable temperature increases in Class I Streams (less than a 

0.5 degree Fahrenheit change). Temperature increases on SMU Class II (and fishbearing SMU 

Class Ill) streams will be limited to the criteria in State standards. Temperatures on other streams 

may be increased only to the extent that water quality goals on downstream, fish-bearing streams 

will still be met. Normally stream shade management on Class 111 streams will differ little from 

treatment on Class II streams. No increases in stream temperatures as shown in the FEIS.

8. Channel Stability. Maintain natural large woody debris, plus trees needed for a future supply, to 

protect or enhance stream channel and bank structure, enhance water quality, and provide 

structural fish habitat within all SMU classes. Quantities and sizes will be determined on a caseby-case basis. No change in channel stability or LWD supplies as shown in FEIS.

9. Enhance streambank vegetation and/or large woody debris where it can be effective in improving 

channel stability or fish habitat. No change in streambank vegetation or LWD as shown in the 

FEIS.

10. Give areas in which water quality or channel stability are being adversely impacted high priority 

for treatment to minimize the effects of the impact or to correct the impacting activity. No 

adverse impacts to water quality or channel stability as shown in the FEIS.

11. Conduct Cumulative Effects Analyses. When project scoping identifies an issue or concern 

regarding the cumulative effects of activities on water quality, stream channels, or fish habitat a 

cumulative effects assessment of these effects will be made. This will include land in all 

ownerships in the watershed Activities on National Forest System lands in these watersheds 

should be dispersed in time and space to the extent practicable, and at least to the extent necessary 

to meet management requirements. On intermingled ownerships, coordinate scheduling efforts to 

the extent practicable. No concerns regarding cumulative effects on water quality, stream 

channels or fish habitat were identified during scoping. A cumulative effects analysis was done in 

the FEIS.
Chapter 3 Snow Basin Vegetation Management Project FEIS

180

12. Alter watershed conditions only to the extent that aquatic and riparian goals will still be met and 

other valid water uses, such as irrigation, will not be adversely affected. When planned projects 

are likely to adversely affect watershed conditions, a hydrologic analysis will be conducted 

considering past, present, and future activities. If the results of this analysis indicate that the 

proposed project would adversely affect watershed condition, the project will be altered. This 

may include such things as deleting or rearranging harvest units in timber sales, selecting 

different prescriptions, or delaying activities for one or more decades. No alterations of 

watershed conditions are expected.

13. Groundwater: All projects or activities (including but not limited to pesticide application, 

fertilizer application, or storage of potentially hazardous volumes of fuels and other chemicals on 

National Forest System land) with the potential to adversely affect surface or ground waters, will 

include constraints and/or mitigation measures designed to prevent contamination, and will 

include a plan for dealing with accidental spills. No effects to groundwater are expected.

14. Floodplains: Address in all project environmental analyses the presence of, and potential impacts, 

to any floodplain within the project area. No impacts to floodplains are expected.

15. Invest in major structures, roads, or other facilities within floodplains only if no feasible 

alternative site outside the floodplain exists. No investments within floodplains will occur.

16. Permit short-term adverse impacts on floodplains only in conjunction with specific mitigation 

measures designed to minimize the impacts. Where activities adversely affect natural floodplains, 

the floodplains will be restored, to the extent practicable, shortly after the activity has ceased. No 

adverse impacts on floodplains will occur.

17. Wetlands: Address in all project environmental analyses the presence of, and potential impacts to, 

any wetlands within the project area. Particular attention will be paid to protection of springs 

during road location, timber sale plans, and range allotment management plans. Adverse impacts 

to wetlands will be avoided or mitigated. No adverse impacts to wetlands will occur.

18. Roads and Skid Trails. Do not construct roads through the length of riparian areas Roads crossing 

riparian areas will not alter stream or ground water flow characteristics to a degree which will 

impact the riparian characteristics. No road construction through riparian areas will occur. No 

alteration of stream or groundwater will occur. No impact of riparian characteristics will occur.

19. Design and maintain road drainage to prevent the influx of significant amounts of road sediment 

runoff into streamcourses. Road drainage design has been done to reduce sediment delivery to 

streams.

20. Manage roads currently located in riparian areas or streamside management units to minimize 

impacts to water quality and wildlife habitat. In some instances, this will require higher levels of 

maintenance, road surfacing, or drainage than would normally be justified on the basis of road 

use alone. Roads may be closed, obliterated, and rehabilitated when it is determined, through an 

environmental analysis considering all resources, to be the best alternative. Road management 

has been designed to minimize impacts to water quality and wildlife habitat. Decommission of 6 

miles of roads has been included for all action alternatives.

21. Locate skid trails and roads to avoid paralleling stream channels in streamside management units. 

Log landings will not be placed in riparian areas. Skidding logs down streamcourses or ephemeral 

draws will not occur. Skid trails have been located so they do not parallel stream channels. Only 

existing roads will be used. Log landings are outside of riparian areas. No skidding will be 

allowed down streamcourses or ephemeral draws.

22. Avoid the use of heavy equipment (such as crawler tractors and skidders) within riparian 

ecosystems. When such use is unavoidable (as in the construction of bridges or other stream 

crossing devices or during the construction of stream channel improvements) the activity will 

include mitigation measures designed to minimize adverse effects on the riparian zone and 

downstream values. Ground disturbing activities will normally be limited to 10 percent exposed 
Chapter 3 Snow Basin Vegetation Management Project FEIS

181

soil or less within riparian ecosystems. No use of heavy equipment (such as crawler tractors and 

skidders) will occur within riparian ecosystems. The construction of stream crossings (culverts) 

necessary for hauling logs will include all appropriate BMPs.

23. Manage recreation activities to prevent site deterioration within riparian areas. Trails will be 

designed and maintained to minimize riparian impacts. No recreation activities are planned.

24. Fuel Treatment. Remove slash created as the result of an activity within the normal high water

zone of Class I and II streams unless needed for soil protection or other purposes. Slash removal 

from other streams may be required where resource damage would otherwise result. Slash piles 

normally will not be located within riparian areas. No slash will be created within the normal 

high water zone of Class I and II streams.

INFISH standards and guidelines

INFISH TM-1: Mechanical thinning activities will occur in RHCAs to meet silvicultural objectives for 

stands. Thinning will not occur within 200 feet of Category 1 and 2 streams and within 50 feet of 

Category 4 streams.

INFISH RF-2a: No new system roads to access logging units are proposed. Temporary roads will be 

decommissioned following completion of timber haul activities.

INFISH RF-2b: Impacts from proposed skid trails and landings in RHCAs are minimized by the use of 

forwarders. No new landings will be constructed in RHCAs. Only exiting landings that are not adjacent to 

stream channels (i.e. located above a road) will be used.

INFISH RF-3a and b: Roads that will be used for proposed vegetation management activities will have 

drainage problems repaired and will be brought up to standards prior to haul.

INFISH FM-1: Proposed activities (noncommercial and commercial thinning, prescribed burning) would 

not retard the attainment of Forest Plan RMOs for aquatic habitat (pool frequency, water temperature, 

LWD, bank stability, lower bank angle, and width-to-depth ratio). Proposed burning activities may result 

in short-term increases in fine sediment and decreases in shading in RHCAs adjacent to streams in the 

aquatic effects areas. However, the magnitudes in the increases in fine sediment or reduction of shading 

are unlikely to result in measurable changes in fine sediment levels or water temperatures in the aquatics 

effects area.

Eagle Creek Wild and Scenic River Management Plan 

Fisheries and water quality have been designated as Outstanding Remarkable Values (ORVs). 

Management direction applicable to the Snow Basin Project regarding the Fisheries ORV is presented in 

Table 59.

Table 59. Standard and guidelines applicable to the fisheries ORV for the Eagle Creek Wild and Scenic 

River Plan

Standard and 

Guideline Description Consistency check with S&G, including rationale

4. Protection and enhancement of ORVs Yes. Long-term reduction in sediment from 

roads.

31

Utilize current and additional direction for 

maintaining and improving water quality 

(water quality at the time of river designation 

or closest estimate) as it relates to fish 

habitat, including but not limited to 

sediment, stream temperature, shading, and 

large woody debris.

Yes, the Snow Basin Project incorporates 

Forest Plan Standards and Guides, INFISH 

Standards and Guidelines and project specific 

design features and best management 

practices to limit short-term impacts to water 

quality. Long-term improvement of water 

quality is anticipated due to a reduction in 

sedimentation. Additional LWD will be placed 

along 7.5 miles of tributary streams.
Chapter 3 Snow Basin Vegetation Management Project FEIS

182

32. Maintain and improve water quality. Yes. Long-term reduction in sediment from 

roads.

33. Maintain stream flows. Yes. No change in water uses planned with 

this project.

34. Manage dispersed recreation to reduce 

sediment.

Yes. This project does not make a decision on 

managing dispersed recreation.

38

Manage for high levels of LWD in the 

channel.

Yes, the Snow Basin Project avoids impacts to 

LWD by implementing INFISH RHCAs and 

limiting thinning activities to 50 acres outside 

the zone of influence for LWD. Additional LWD 

will be placed along 7.5 miles of tributary 

streams.

47. Protection of watersheds. Yes. Protection of watersheds is met through 

project design features and BMPs.

48. No measureable reduction in water quality. Yes. Long-term reduction in sediment from 

roads.

51. Maintain existing interim buffers. Yes. Interim RHCA buffers will be used.

54. Do a Water Development Analysis if any 

impacts to Eagle Creek.

Yes. Because no measureable impacts are 

expected, no WDA will be done.

56. Improve roads to reduce sediment. Yes. Long-term reduction in sediment from 

roads.

96. Correct sediment problems on roads 77, 

7735, 7750-025, and 7755.

Yes. Road improvements scheduled for 77 

and 7735.

106. Address any potential effects to the river 

corridor and ORVs.

Yes. The FEIS examines all potential effects.

The Snow Basin Project is consistent with the Eagle Creek Wild and Scenic River Management Plan. 

Mechanical thinning activities will occur in RHCAs to meet silvicultural objectives for stands. Thinning 

will not occur within 200 feet of Category 1 and 2 streams and within 50 feet of Category 4 streams. No 

impacts to shading or future LWD levels will occur as a result of the proposed thinning adjacent to 

Category 1 and 2 streams, because a site potential tree is about 100 feet in height. There is a potential risk 

that increases in fine sediment may occur because ground disturbing activities will occur in RHCAs 

(skidding and landings). Measures (minimizing and restricting location of lands, requiring use of 

forwarders, minimizing the number of skid trails, and hardening crossings) will be used to restrict 

increases in fine sediment levels to immeasurable levels.

Measurable increases in fine sediment are predicted as a result of the replacement of a bridge and 

installation and removal of temporary culverts on fish bearing streams. These increases are predicted to be 

short-term. Aquatic habitat downstream of the bridge replacement site on Little Eagle Creek will be 

impacted due to a measureable increase in fine sediment to 0.125 mile of aquatic habitat. Under 

Alternative 2, three culverts on Category 1 streams and one culvert on a Category 2 stream will be 

replaced and will likely impact 0.46 miles of aquatic habitat. Under Alternatives 3 and 4, two culverts on 

Category 1 streams and one culvert on a Category 2 stream will be replaced and will likely impact 0.335 

miles of aquatic habitat. Measurable increases in fine sediment will likely last for up to four months from 

the bridge replacement and installation of temporary culverts.

Placement of additional LWD in Little Eagle Creek, Paddy Creek, and Holcomb Creek on along 7.5 miles 

of stream will improve channel stability, sediment storage, and aquatic habitat in the mid- to long-term. 

The additional LWD would be placed in accumulations greater than four pieces. Each accumulation will 

contain at least one key piece (length >bankfull width, or >12 inch diameter and >35 feet in length; 
Chapter 3 Snow Basin Vegetation Management Project FEIS

183

whichever is largest) with rootwad attached. Accumulations will span no more than 50 percent of the 

bankfull width of the stream channel. No cabling or rebar anchors will be used. Instead, stability of the 

LWD accumulations will rely on use of key pieces and placement. Placement of LWD will occur with an 

excavator and will occur during the in-water work window (July 1 to October 31). The sources of LWD 

will be from off-site locations outside of RHCAs (e.g. conifers removed as part of aspen stand treatments, 

wind-thrown trees). Short-term increases in fine sediment downstream of the activity sites will occur as 

the result of streambed and bank scour. However, these short-term increase are likely to be immeasurable 

as they will occur during high flow events. 

Endangered Species Act 

ESA consultation for the Snow Basin Project was completed on January 11, 2012. The USFWS Letter of 

Concurrence (USFWS reference 01EOFW00-2012-I-0026) for the project concludes that the proposed 

activities may affect, but are not likely to adversely affect designated critical habitat for bull trout.

Clean Water Act 

Consistency with the CWA and State Water Quality Law for the No Action Alternative

There are no streams listed on the 2004/2006 ODEQ 303 (d) list as water quality limited in the project 

area. Consistency lacks on existing road segments where applicable BMPs are not in place to reduce 

sediment delivery to the extent practicable. Assumptions made for the no action alternative include a 

continuation of existing road management practices (or lack thereof), which do not reduce sediment 

delivery to the extent practicable. Consistency lacks with LRMP Watershed Standards and Guides 2, 3, 

and 19 for the same reason (lack of applicable BMPs on existing roads). Consistency with all other 

LRMP Standards and Guides and Executive Orders 11988 and 11990 is met because no actions will be 

taken.

Consistency with the CWA and State Water Quality Law for all Action Alternatives

There are no streams listed on the 2004/2006 ODEQ 303 (d) list as water quality limited in the project 

area. Consistency will be met through implementation of BMPs, considered as a performance standard for 

control of non-point source water pollution. Because the project includes actions to reduce long-term 

sediment delivery from roads, it meets compliance required by CWA and the State of Oregon. This 

project complies with the Wallowa-Whitman National Forest Plan as amended by INFISH by not 

impeding attainment or progress of objectives for habitat conditions within RHCAs and supporting all 

other applicable LRMP standards and guidelines listed in the Regulatory Framework.

Floodplains and wetlands

The proposed action alternatives would have no impact on floodplains or wetlands as described in 

Executive Orders 11988 and 11990. Floodplains and wetlands will be protected by applicable INFISH 

RHCA buffers. 

Recreational fisheries 

The Snow Basin Project will not result in reductions in quantity, function, sustainable productivity, and 

distribution of recreational fisheries as directed under Executive Order 12962, Recreational Fisheries.

Irreversible/irretrievable effects 

Irreversible effects are not expected. Reduced population viability for redband trout is not expected.

INFISH established explicit goals and objectives for anadromous fish habitat condition and function. By 
Chapter 3 Snow Basin Vegetation Management Project FEIS

184

following INFISH standards and guidelines as well as design criteria specific to this project, it is believed 

irretrievable commitment of this resource can be avoided. The goal of INFISH is to achieve a high level 

of habitat diversity and complexity through a combination of habitat features.

Summary of Effects Determinations for Aquatic Species

Following is an occurrence matrix of aquatic species with special management status in the Snow Basin 

project area and effects determinations:

Common Name Scientific Name Status

Occurrence

Effects 

Determination

WWNF Snow Basin 

Analysis Area Alt 1 Alts 2,3,&4

SR Steelhead Oncorhynchus 

mykiss

ESA Threatened, 

WWNF MIS Present Not Present NE NE

Critical Habitat –

SR Steelhead Designated Present Not Present NE NE

SR Spring 

Chinook Salmon

Oncorhynchus 

tshawytscha ESA Threatened Present Not Present NE NE

Critical Habitat –

SR Spring 

Chinook Salmon

Designated Present Not Present NE NE

SR Fall Chinook 

Salmon

Oncorhynchus 

tshawytscha ESA Threatened Present Not Present NE NE

Critical Habitat –

SR Fall Chinook 

Salmon

Designated Present Not Present NE NE

CR Bull Trout Salvelinus 

confluentus ESA Threatened Present Not Present NE NE

Critical Habitat –

CR Bull Trout Designated Present Present NLAA NLAA

Inland Redband 

Trout (all stocks)

Oncorhynchus 

mykiss

R-6 Sensitive, 

WWNF MIS Present Present MIIH MIIH

Westslope 

Cutthroat Trout

Oncorhynchus 

clarki lewisi R-6 Sensitive Present Not Present NI NI

Western Ridge 

Mussel Gonidea angulata R-6 Sensitive Present Habitat Present MIIH MIIH

Shortface Lanx 

(Giant Columbia 

River limpet)

Fisherola nuttalli R-6 Sensitive Present Habitat 

Present MIIH MIIH

Columbia 

Pebblesnail

Fluminicola 

fuscus 

(=columbianus)

R-6 Sensitive Present Habitat 

Present MIIH MIIH

Pristine 

Springsnail

Pristinicola

hemphilli R-6 Sensitive Present Habitat 

Present NI NI

Effects Determinations: NI = No Impact, MIIH = May Impact Individuals or Habitat, NE = No Effect, NLAA = Not Likely 

to Adversely Affect, LAA = Likely to adversely Affect
Chapter 3 Snow Basin Vegetation Management Project FEIS

185
Chapter 3 Snow Basin Vegetation Management Project FEIS

186

BIOLOGICAL EVALUATION AND WILDLIFE SPECIALIST REPORT 

Introduction

This analysis summarizes the terrestrial wildlife species found in the project area and the effects of the 

alternatives on these species. Rather than addressing all wildlife species, discussions focus on LRMP

management indicator species (MIS), threatened, endangered and sensitive (TES) species, LRMP featured 

species, and landbirds (see individual species lists below). The existing condition is described for each 

species, group of species, or habitat. Direct, indirect and cumulative effects of alternatives are identified 

and discussed. The full wildlife specialist report and supporting wildlife documentation is located in the 

Project Record, and includes detailed data, methodologies, analyses, conclusions, maps, references and 

technical documentation used to reach conclusions in this environmental analysis. For more details on the 

project area and project alternatives, see chapter 2 of the FEIS. 

Regulatory Framework 

The three principle laws relevant to wildlife management are the National Forest Management Act of 

1976 (NFMA), the Endangered Species Act of 1973 (ESA), and the Migratory Bird Treaty Act (MBTA) 

of 1918 (as amended). Direction relative to wildlife is as follows:

• NFMA requires the Forest Service to manage fish and wildlife habitat to maintain viable 

populations of all native and desirable non-native vertebrate wildlife species and conserve all 

listed threatened or endangered species populations (36 CFR 219.19).

• ESA requires the Forest Service to manage for the recovery of threatened and endangered species 

and the ecosystems upon which they depend. Forests are required to consult with the US Fish and 

Wildlife Service if a proposed activity may affect the population or habitat of a listed species.

• MBTA established an international framework for the protection and conservation of migratory 

birds. This Act makes it illegal, unless permitted by regulations, to “pursue, hunt, take, capture, 

purchase, deliver for shipment, ship, cause to be carried by any means whatever, receive for 

shipment, transportation or carriage, or export, at any time, or in any manner, any migratory 

bird.”

Forest Service Manual (FSM) direction provides additional guidance: identify and prescribe measures to 

prevent adverse modifications or destruction of critical habitat and other habitats essential for the 

conservation of endangered, threatened and proposed species (FSM 2670.31 (6)). 

The Forest Service Manual also directs the Regional Forester to identify sensitive species for each 

National Forest where species viability may be a concern. Under FSM 2670.32, the manual gives 

direction to analyze, if impacts cannot be avoided, the significance of potential adverse effects on the 

population or its habitat within the area of concern and on the species as a whole. 

The principle policy document relevant to wildlife management on the Forest is the Wallowa-Whitman 

Land and Resource Management Plan (USDA Forest Service 1990), referred to as the LRMP for the 

remainder of this analysis. The LRMP provides standards and guidelines for management of wildlife 

species and habitats. Standards and guidelines are presented at the Forest level (LRMP, pp. 4-18 to 4-56) 

or Management Area level (LRMP pp. 4-56 to 4-98).

The 1995 Regional Forester’s Eastside Forest Plan Amendment #2 (Eastside Screens) amended Forest 

Plans for the National Forests in Eastern Oregon and Eastern Washington, including the WallowaWhitman National Forest. Amendment # 2 established interim wildlife standards for old growth, old 

growth connectivity, snags, large down logs, and northern goshawks. The Regional Forester has 
Chapter 3 Snow Basin Vegetation Management Project FEIS

187

periodically distributed letters clarifying direction in Amendment #2 (Regional Forester, October 2, 1997; 

October 23, 1997; and June 11, 2003).

Additional management direction is provided for the conservation of migratory landbirds. This direction 

is consolidated in the Forest Service Landbird Strategic Plan and further developed through the Partners 

in Flight Program. The Oregon-Washington Partners in Flight Conservation Strategy for Landbirds in the 

Rocky Mountains of Eastern Oregon and Washington (Altman 2000) identifies priority habitats, and focal 

species and habitats for the Blue Mountains of Oregon.

Analysis Methods

Two different scales of analysis are used in this document to analyze the effects of the treatment activities 

on wildlife, and include the following: 

• Snow Basin Project Area perimeter at 28,545 acres (26,493 acres on National Forest System 

lands).

• The cumulative effects area encompassing the Snow Basin Project varies by species and is 

described within sections dedicated to individual species analyses.

The project area boundary occurs predominately within the Eagle Creek watershed. About 160 acres 

occurs within the Powder River-Ruckles Creek fifth field watershed. Because this area represents only 

0.09 percent of total area within the watershed, potential cumulative impacts to habitats were not analyzed 

for the Powder River-Ruckles Creek watershed.

The existing condition is described for each species, group of species, or habitat. Direct, indirect and 

cumulative effects of alternatives are identified and discussed. Incomplete or unavailable information, 

scientific uncertainty, and risk are disclosed where applicable.

Management Indicator Species (MIS)

The geographic ranges of the MIS are larger than the project area, thus the analysis of adequacy of 

habitats for viable populations of MIS needs to be done at a scale larger than the individual project. 

“Habitat must be provided for the number and distribution of reproductive individuals to ensure the 

continued existence of a species generally throughout its current geographic range” (FSM 2620.1).

Provisions for contributing to viable populations are determined at the level of the LRMP through 

management requirements, goals and objectives, standards, guidelines, prescriptions, and mitigation 

measures to ensure that habitat needs of MIS will be sufficiently met during plan implementation at the 

project level (FSM 2621.4). Analysis for each MIS includes an assessment of consistency with the 

provisions identified in the LRMP. Cumulative effects of proposed management activities on habitat 

capability for MIS are evaluated (FSM 2620.3). Best available science is considered in this analysis in 

assessing project impacts to MIS.

Threatened, Endangered and Sensitive (TES) Species

An endangered species is an animal or plant species listed under the Endangered Species Act that is in 

danger of extinction throughout all or a significant portion of its range. A threatened species is an animal 

or plant species listed under the Endangered Species Act that is likely to become endangered within the 

foreseeable future throughout all or a significant portion of its range. A sensitive species is an animal or 

plant species identified by the Forest Service Regional Forester for which species viability is a concern 

either a) because of significant current or predicted downward trend in population numbers or density, or 

b) because of significant current or predicted downward trends in habitat capability that would reduce a 

species’ existing distribution. The R6 Sensitive Species list pertinent to this project is dated January, 
Chapter 3 Snow Basin Vegetation Management Project FEIS

188

2008. Threatened, endangered, and sensitive species effects are summarized in this report by TES status 

and species. Landbirds including Neotropical Migratory Birds (NTMB)

Landbirds, including neotropical migratory birds, are discussed since many species are experiencing 

downward population trends. Discussion can be found in the section titled Landbirds including 

Neotropical Migratory Birds (NTMB).

Analysis Tools and Surveys

Species presence/absence determinations were based on habitat presence, past wildlife surveys, recorded 

wildlife sightings, the Oregon Natural Heritage Information Center wildlife sightings database (2008), 

scientific literature, and status/trend and source habitat trend documented for the Interior Columbia Basin 

(Wisdom et al. 2000).

Vegetation analysis and estimates of stand conditions were completed using silviculture analysis tables, 

results described within the Snow Basin Forest Vegetation Management Report, aerial photo 

interpretation, vegetation database, and/or ground reconnaissance.

Analysis Methodology

Alternative 1 - No Action 

Alternative 1, the No Action Alternative, is required by NEPA. It is used as a benchmark to compare and 

describe the differences and effects between taking no action and implementing action alternatives. The 

No Action Alternative is designed to represent the existing condition; resource conditions are then 

projected forward in time to estimate resource changes expected in the absence of the proposed 

management activities.

Effects on species will be determined by assessing how the No Action Alternative and action alternatives 

affect the structure and function of vegetation relative to current and historical distributions. Some 

wildlife habitats require a detailed analysis and discussion to determine potential effects on a particular 

species. Other habitats may either not be impacted or are impacted at a level which does not influence the 

species or their occurrence. The level of analysis depends on the existing habitat conditions, the 

magnitude and intensity of the proposed actions, and the risk to the resources. 

Past, ongoing and foreseeable future activities used in cumulative effects analysis are listed in Appendix 

B. Where the species’ cumulative effects analysis area is larger than the two subwatersheds encompassing 

projects listed in Appendix B, other sources are used to quantify these activities.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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BIOLOGICAL EVALUATION

Proposed, Endangered, Threatened, and Sensitive Species 

Introduction

As part of the National Environmental Policy Act (NEPA) decision-making process, biological 

evaluations (BE) are required to determine how proposed FS management activities may affect Proposed, 

Endangered, Threatened, or Sensitive (PETS) species or their habitats (U.S. Forest Service Manual [FSM] 

2670). This evaluation presents existing information on PETS species and their habitat in the project area, 

and describes the anticipated direct, indirect, and cumulative effects resulting from the proposed project.

The review is conducted to ensure that FS actions do not contribute to the loss of species viability or 

cause a species to move toward federal listing (43 U.S.C. 1707 et seq). Threatened and Endangered 

species are managed under authority of the Federal Endangered Species Act (ESA) (36 U.S.C. 1531-

1544) and the National Forest Management Act (NFMA) (16 U.S.C. 1600-1614). The ESA requires 

Federal agencies make certain all actions they authorize, fund, or carry out will not likely jeopardize the 

continued existence of any threatened or endangered species. Sensitive species are those recognized by 

the Region 6 Regional Forester as needing special management to meet NFMA obligations. FS policy 

requires a BE to determine possible effects to sensitive species from proposed management activities.

Pre-field Review

The list of federally-listed species applicable to the planning area was obtained from the U.S. Fish and 

Wildlife Service (USDI Fish and Wildlife Service 2011). No proposed or federally-listed terrestrial 

wildlife species were described for Baker County, Oregon. The USFS Region 6 Regional Forester’s 

Sensitive Species List, dated January 31, 2008 (USDA Forest Service 2008) was reviewed for sensitive 

species potentially applicable to the Snow Basin Project.

The project area was evaluated for PETS species to determine which species might occur in or near it, 

based on scientific literature, habitat availability, and Whitman Ranger District (RD) records of each 

species. No population surveys were conducted for any of the species addressed in this BE. Only those 

PETS known or suspected to occur, or with Upland Forest habitat, on the Whitman RD, Baker County, 

are addressed in this BE (Table 60). Sensitive species lacking potential distribution or suitable habitats 

within the analysis area are not addressed further in the analysis, and all alternatives would have No 

Impact on these species and/or habitats. 

Table 60. PETS species review, WWNF and Snow Basin project area

Common name Scientific name

USFWS 

status

USFS

status

WWNF 

Occurrence1/ Snow 

Basin occurrence2

Addressed 

further in 

this BE

BIRDS

UPLAND SANDPIPER

BARTRAMIA 

LONGICAUDA SEN D/N

Suitable habitats in Oregon consist of large montane meadows ranging from 1,000 to 30,000 acres, generally 

surrounded by lodgepole pine (Marshall et al. 2003). The project area lacks suitable habitat, and no known sightings 

are reported for the area.

BUFFLEHEAD

BUCEPHALA 

ALBEOLA SEN S/H

Known breeding range in Oregon is restricted to the Cascades. Breeding habitat consists of high-elevation lake or 

pond habitat surrounded by forest (ODFW 2006). The project area lacks suitable habitat, and no known sightings 

are reported for the area.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Common name Scientific name

USFWS 

status

USFS

status

WWNF 

Occurrence1/ Snow 

Basin occurrence2

Addressed 

further in 

this BE

GREATER SAGEGROUSE

CENTROCERCUS 

UROPHASIANUS

CANDID

ATE SEN S/N

Suitable habitats are associated with sagebrush. The project area lacks suitable habitat and known sightings for 

sage-grouse.

AMERICAN PEREGRINE 

FALCON

FALCO 

PEREGRINUS 

ANATUM SEN D/H X

Suitable nesting habitat consists of cliffs, usually within 900 meters of water (Pagel 1995). Potential habitat exists 

along the Eagle Creek drainage outside the project area, especially in the Eagle Cap Wilderness, and in the 

adjacent East Eagle drainage. No nest sites or suitable nesting habitats are known within the project area. However, 

the project area contains open areas that could serve as potential foraging habitat.

BALD EAGLE

HALIAEETUS 

LEUCOCEPHALUS

DELIST

ED SEN D/H X

Nesting habitat consists of large conifers within 1 km of water containing adequate supply of medium to large fish 

(Johnsgard 1990). No known nest sites exist within the project area. Nearest nest sites are located more than 10 

miles from the project area. The project area does contain potential foraging habitat and the potential for species 

occurrence.

LEWIS' WOODPECKER

MELANERPES 

LEWIS SEN D/H X

Primary breeding habitats include open ponderosa pine, riparian cottonwood, and logged or burned pine (Tobalske 

1997). No sightings are reported for the project area; however, sightings are reported for private lands adjacent to 

the south. The project area contains potential suitable habitat and the potential for species occurrence.

WHITE-HEADED 

WOODPECKER

PICOIDES 

ALBOLARVATUS SEN D/K X

Nesting habitat consists of open-canopy stands with mature and overmature ponderosa pine (Buchanon et al. 

2003). Species sightings and suitable habitat occur within the project area.

COLUMBIAN SHARPTAILED GROUSE

TYMPANUCHUS 

PHASIANELLUS 

COLUMBIANUS SEN D/N

Potential habitats consist of bunchgrass prairies interspersed with stream bottoms containing deciduous shrubs and 

trees. The species was extirpated from Oregon, but has been reintroduced into northern Wallowa County (ODFW 

2010). No sightings or potential suitable habitat occur within or adjacent to the project area. Occurrence within the 

project area is unlikely.

MAMMALS

CANADA LYNX LYNX CANADENSIS T D/N X

The species is classified as “not present” on the WWNF

GRAY WOLF CANIS LUPUS D SEN D/H X

Gray wolves are habitat generalists inhabiting a variety of plant communities, typically containing a mix of forested 

and open areas with a variety of topographic features.

FISHER MARTES PENNANTI SEN S/H X
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Common name Scientific name

USFWS 

status

USFS

status

WWNF 

Occurrence1/ Snow 

Basin occurrence2

Addressed 

further in 

this BE

Preferred habitat consists of late-successional conifer forests. No sightings have been reported for northeastern 

Oregon since 1976, leaving no evidence for an extant population in the Wallowa Mountains (Aubrey and Lewis 

2003). Potential occurrence within the project area is unlikely, but suitable habitat does exist within the project area.

CALIFORNIA WOLVERINE

GULO GULO 

LUTEUS C SEN D/H X

Preferred habitat consists of alpine and subalpine areas with little or no human presence. Confirmed sightings have 

been reported north of the project area, and suitable habitats exist in proximity to the project area.

Mollusks

FIR PINWHEEL

RADIODISCUS 

ALBIETUM SEN S/H

Most often found in moist and rocky Douglas-fir forest at mid-elevations in valleys and ravines (Frest and Johannes 

1995). Known distribution in Oregon is limited to extreme NE (above Weston, Umatilla Co.; Duncan 2008). No 

sightings are reported within or adjacent to the project area. Lack of sightings and distance between project area 

and known distribution make occurrence unlikely.

HELLS CANYON LAND 

SNAIL

CRYPTOMASTIX 

POPULI SEN S/N X

Land snail found in rather open and dry large-scale basalt taluses, generally at lower elevations. Most colonies 

occur at slope bases along the major river corridors, not in major tributaries. Associated vegetation includes Celtus, 

Artemisia, Prunus, Balsamorrhiza, and Seligeria. Surrounding vegetation is generally sage scrub. Generally in steep 

north or east-facing taluses, often only at the base. Occasionally found in metasedimantary taluses as well (Frest 

and Johannes 1995). T.

INSECTS

MEADOW FRITILLARY BOLORIA BELLONA SEN S/N

The only known site in Oregon is located in Umatilla County (Fleckenstein 2006). The project area is located outside 

the known distribution of this species.

SILVER-BORDERED 

FRITILLARY BOLORIA SELENE SEN S/H

Suitable habitat consists of bog and marshes, often willowy sites, sometimes tall wet grass (Pyle 2002). Only three 

sites are reported for Oregon, one of which is located north of the town of Halfway on private land. The Halfway site 

is located about 5 air miles east of the project area. No larval host species are reported for the project area, and 

suitable habitat for this species is unlikely.

JOHNSON'S 

HAIRSTREAK 

CALLOPHRYS 

JOHNSONI SEN S/S X

Suitable habitat includes mistletoe on ponderosa pine, which is present in the project area. The species has not 

been reported for the project area, but has been reported in adjacent areas to the west and east, making occurrence 

likely.

SEN = Sensitive. 1D = Documented occurrence, S = Suspected occurrence (USDA Forest Service 2009). 2 K = 

Known to occur. S = Suspected to occur. H = Not known to occur, but habitat present. N = No habitat present and/or 

not present. C = candidate for federal listing. DE=delisted. T=threatened
Chapter 3 Snow Basin Vegetation Management Project FEIS

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American Peregrine Falcon

Existing condition

In northeastern Oregon, a total of six nest sites are known to occur, all of which are located in Wallowa

and Union counties (ODFW 2007). No known nest sites are located within the Snow Basin project area.

A site is identified in southern Wallowa County (ODFW 2007), and is located approximately 7 miles 

from the project area. The project area contains no known suitable nesting habitat. The project area does 

not contain water resources sufficient to attract large concentrations of birds, but does contain open 

upland areas that may serve as potential, but marginal, foraging habitat.

Direct and indirect effects

Alternative 1

There will be no direct or indirect adverse effects to peregrine falcons from the No Action Alternative 

because no timber harvest, fuels treatments, or transportation activities will occur. 

Alternatives 2, 3, and 4

Potential impacts to peregrine falcon are similar under all action alternatives because none of the 

alternatives alter peregrine nesting habitat and the difference in treatment of peregrine foraging habitat is 

insignificant between alternatives. Pagel (1995) described a potential effects boundary as the area within 

3 miles of nest sites, based on average foraging distance. Cursory review of terrain within three miles of 

the project area boundary does show that potential nesting habitat may exist at the upper elevations of 

Cornucopia Peak. While no known nesting occurs there, it is unknown whether peregrine occupancy 

surveys have been conducted in the area.

Activities proposed under all action alternatives involve alteration of vegetation, production of smoke, 

and generation of noise. Vegetation alteration would decrease forest canopy densities, thereby increasing 

sightability of prey and potential foraging effectiveness for peregrines. Alternative 2 may open up slightly 

more foraging habitat than Alternatives 3 and 4. However, it is unlikely the difference would translate 

into an increase in productivity for peregrines under any action alternative. Nichols and Menke (1984 in

USDA Forest Service 2010) reported that fires near nesting cliffs could disturb peregrine young or 

nesting pairs. Due to the lack of nesting habitat within and directly adjacent to proposed treatments, it is 

unlikely that fuels treatments that produce smoke would impact nesting peregrines.

Noise and human presence have the potential to disturb nesting peregrines within one mile (Romin and 

Muck 1999). Potential nesting habitats are estimated to be more than one mile from proposed treatment 

areas. Therefore, noise and activity generated by proposed activities are not expected to impact nesting 

peregrines. Activities may, however, temporarily impact localized foraging by individuals or affect 

temporary changes in prey availability if the area is used by peregrines. 

Cumulative effects

All alternatives 

The area considered for cumulative effects is the project area, as well as the area within 3 miles of the 

project area boundary, within which the effects were described above for the action alternatives. Past, 

present and reasonably foreseeable future actions were analyzed for cumulative impacts to the species.

Activities in Appendix B have been considered for their cumulative effects on peregrine falcons and their 

habitat within the project area. Past activities such as timber harvest, road construction, and fire 

suppression have combined to create the current condition. In the area encompassing 3 miles outside the 

project area boundary, review of the Forest Service Activities Tracking System (FACTS) database for the 

WWNF shows that activities that may influence peregrine falcon foraging habitat and increase potential 

for disturbance within the past 10 years consist of low intensity underburning as well as various timber 
Chapter 3 Snow Basin Vegetation Management Project FEIS

193

harvest prescriptions including commercial thinning, partial removal, and overstory removal treatments.

Ongoing and foreseeable activities within the cumulative effects analysis include firewood cutting, 

summer and winter recreation, livestock grazing, and prescribed fire activities outside the project area.

Because these activities would have occurred more than 3 miles from a known peregrine nest site, no 

significant cumulative impacts to peregrine falcons are expected.

Determination

All action alternatives would have no impact to peregrine falcon nesting. Vegetation alterations may alter 

prey availability and improve foraging effectiveness. Noise and human activity may impact individuals or 

habitat, but will not likely contribute to a trend towards Federal listing or cause a loss of viability to the 

population or species (MIIH). 

Bald Eagle

Existing condition

There are no known bald eagle nest sites within the project area. Surveys and monitoring of known nest 

sites in the southern Wallowa Mountains show the nest site nearest to the project area is located about 11 

miles away. There are no known winter foraging areas within or adjacent to the project area (USDA 

Forest Service 2009). Review of the Oregon Natural Heritage database (ORNHIC 2009) shows no bald 

eagle sightings within or adjacent to the project area. The project area contains several streams, the largest 

of which (Eagle Creek) could possibly be utilized by bald eagles for occasional foraging. Eagle Creek 

transects the western portion of the project area for about 9.5 miles.

Direct and indirect effects

Alternative 1 

There will be no direct adverse effects to bald eagles from the No Action Alternative because no timber 

harvest, fuels treatments, or transportation activities will occur. 

Alternatives 2, 3, and 4 

Potential impacts to bald eagles are similar under all action alternatives because no timber harvest or 

active lighting of prescribed fire will occur within 300 feet of perennial fish bearing streams under any 

alternative and log hauling and smoke from fuels treatments will occur under all action alternatives. 

Potential foraging in the project area could occur at Eagle Creek, although the likelihood of occurrence is 

low based on the lack of reported sightings. Bald eagle perch trees usually consist of larger trees with an 

unobstructed view of the foraging area (Garrett et al. 1993). Most eagle use of perch trees near water 

occurs within 50 meters (164 feet) of shoreline (Chandler et al. 1995, Stalmaster and Newman 1979). 

Project design features do not allow timber harvest within 300 feet of perennial fish bearing streams; 

therefore, no impact to potential perch tree habitat would occur. Also, no active lighting of prescribed fire 

would occur in this zone, with the exception of pile burning and active lighting to reduce fire intensity. 

Intermediate treatments within one mile of Eagle Creek may benefit future bald eagle nesting habitat by 

accelerating tree growth and reducing risk of stand disturbance due to insect-outbreak and wildfire. 

Smoke generated by fuels treatments may be of sufficient density to temporarily displace foraging eagles, 

but the impact would be of short duration. Increased human activity along portions of Eagle Creek due to 

log hauling and transportation-related activities may displace foraging eagles if present in close proximity 

to activities. However, the impact would be localized and temporary. In addition, risk of disturbance to 

foraging bald eagles is low for all activities due to a lack of past occurrence in the project area. If bald 

eagle use of the project area changes, this new information would be assessed and mitigations developed 

to protect newly discovered nests or roost sites (see Appendix B-1).
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Cumulative effects

All alternatives

Past, present and reasonably foreseeable future actions were analyzed for cumulative impacts to the 

species. The area considered for cumulative effects is the project area, as well as the area within one mile 

of the project area boundary. One mile is the distance described as a threshold for disturbance of nesting 

bald eagles (USDA Forest Service 2009) and would encompass shorter disturbance distance for foraging 

eagles. All of the activities in Appendix B have been considered for their cumulative effects on bald 

eagles and their habitat. Past activities such as timber harvest, road construction, and fire suppression 

have combined to create the current condition in the analysis area. Ongoing and foreseeable activities 

considered in this cumulative effects analysis include firewood cutting, travel of open roads, summer and 

winter recreation, livestock grazing, and prescribed fire activities outside the project area. No significant

cumulative impacts to bald eagles are expected due to lack of negative impacts to available perching 

habitat.

Determination

All action alternatives would have no effect on bald eagle nesting or winter foraging/roosting. Due to the 

low level of eagle foraging activity along Eagle Creek, increased smoke levels due to fuels treatments and 

increased human presence associated with project activities may temporarily displace individuals, but will 

not likely contribute to a trend towards Federal listing or cause a loss of viability to the population or 

species (MIIH).

Lewis’ Woodpecker

Existing condition

Suitable habitat currently exists in approximately 923 acres of Single Story Large Tree (SSLT) stands 

with open canopy condition. Density of larger snags vary across the landscape, but sampled plots indicate 

that snags 15 to 21 inches DBH average about 1.3 per acre, and snags 21 inches or greater DBH average 

about one snag per acre within sampled stands. Potential habitat is present within ponderosa pine 

associations in the southern portion of the project area, although current condition of most stands consists 

of denser, multi-storied canopies that represent marginal conditions for Lewis’ woodpecker. The Oregon 

Natural Heritage database (ORNHIC 2009) does not contain sightings of this species within or adjacent to 

the project area; however, a flock was sighted in mid-summer, 2009 along Eagle Creek in riparian 

cottonwood, several miles south of the project area (D. Middlebrook, personal observation).

Direct and indirect effects

Alternative 1

There will be no direct adverse effects to Lewis’ woodpecker from the No Action Alternative because no 

timber harvest, fuels treatments, or transportation activities will occur. Indirectly, potentially suitable 

ponderosa stands would continue to contain dense, multi-storied conditions that reduce suitability for this 

species, but represent increased potential for suitable habitats generated by future stand replacement fire 

events. Currently suitable stands would remain unaltered.

Alternatives 2, 3, and 4 

Effects of proposed treatments vary by stand type and in magnitude by alternative. Suitable habitat for 

this analysis is considered those stands meeting the SSLT definition (i.e., single-storied large trees) where 

average tree diameter is greater than 21 inches, with at least 8 to 10 trees per acre (ponderosa pine and 

Douglas-fir) within biophysical environments (BPES) consisting of Warm/Moist Douglas-fir (G6), 

Warm/Dry Douglas-fir (G7) and Hot/Dry Ponderosa pine (G8) vegetation associations. The project area 

lacks open riparian cottonwood stands. All action alternatives propose treatments in MSLT (multi-storied 
Chapter 3 Snow Basin Vegetation Management Project FEIS

195

large trees) that reduce overstory densities and remove understories thereby moving MSLT to SSLT 

structural condition (Table 61). Overall availability of SSLT habitat would be highest after 

implementation of Alternative 2 (2,172 acres), followed in slightly decreasing magnitude by equal 

amounts under Alternative 3 (2081 acres) and 4 (1792). In addition, all action alternatives would 

transform some multi-storied, non-LOS stands to single-story condition (Table 61), thereby increasing 

potential for growth and transition to future SSLT stands. 

No loss of existing SSLT stands in BPEs G6-8 would occur under any alternative; however, removal of 

individual large trees (21+ inches DBH) would occur under Alternatives 2 and 3. Harvest of ponderosa 

pine and Douglas-fir infected with mistletoe as well as harvest of Douglas-fir competing with ponderosa 

pine is projected to remove an estimated 1 tree per acre (see Snow Basin Forest Vegetation Management 

Report). In existing open stands where mistletoe-infected trees comprise the majority of larger overstory, 

treatments under Alternatives 2 and 3 could degrade existing suitable nesting habitat or limit nesting 

opportunity locally for this species. Structural conversion of MSLT to SSLT structure is expected to 

compensate for local habitat impacts and losses in the short-term (within 20 years), while development of 

single-story non-LOS stands increases the potential for larger amounts of SSLT in the long-term (beyond 

20 years)(Table 61).

Removal of snags that pose a safety hazard to those working within timber harvest units is possible, but 

expected to occur at a very low level. The rate of snag removal due to timber harvest safety concerns is 

estimated at less than 1 percent (of total existing snags) for timber sales on the district (Sciarrino, pers. 

comm. 2010). If a snag removed for safety contained nesting woodpeckers, the action would cause nest 

failure and possible mortality of nestlings. Mechanized harvesting equipment is able work around snags 

more safely than conventional hand falling and skidding, leading to reduced need to cut snags down for 

safety. Given the current condition of habitats along with snag retention requirements, snag removal for 

safety represents a low risk to local populations of cavity nesting species.

In addition to changes due to vegetation treatments, prescribed burning would also affect available 

habitat. Burning within existing MSLT stands is expected to convert an estimated 15 percent of these 

acres to SSLT via consumption of understory vegetation. However, overall improvement of habitat due to 

prescribed burning in MSLT is questionable because reductions in overstory canopy closures to levels 

suitable for Lewis’ woodpecker may not occur. 

Table 61. Silvicultural effects on available SSLT

SSLT Existing Post-Treatment Change in SSLT LOS (acres)

Alternative 2 923 2172 +1249

Alternative 3 923 2081 + 1158

Alternative 4 923 1792 +869

Short-term (less than 20 years) and long-term effects (20 years or greater) of both silvicultural and fuels 

treatments include reductions in stand-replacement fire potential. All action alternatives would reduce the 

potential for pulses of burned forest that create suitable, but somewhat short-term, habitat for this species.

Silviculture treatments alone would decrease stand susceptibility to crown fire, increase tree growth and 

bark resistance to surface fire. Overall however, the fire risk reductions create a more sustainable, less 

pulse-driven landscape that allows a steadier availability of suitable habitats in the long-term.

By decreasing tree density as a result of vegetation treatments, natural snag recruitment is likely to occur 

at lower rates than untreated stands due to reduced levels of in-stand competition for resources. However, 

commercial thinning and partial removal treatments are expected to accelerate development of larger trees 

that provide larger snags through natural mortality.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Aspen restoration on scattered individual sites would remove conifers on a total of 38 acres, a portion of 

which may occur in suitable Lewis’ woodpecker habitat. The majorities of aspen sites are one acre or less 

and are identified in Appendix A and on project maps. Hazard tree removal along haul routes totaling up 

to about 7 miles in existing SSLT habitats would potentially remove snags in proximity to roads where 

densities are already low due to past and ongoing firewood gathering. New construction of less than 0.01 

mile of temporary roads may remove less than 0.02 acre of suitable habitat under Alternatives 2 and 3.

These activities would potentially remove minor amounts of habitat and are not expected to impact 

Lewis’ woodpecker habitats at the project area level. Activities that increase overall human presence and 

project-related noise levels, including system road reconstruction, transportation-related activities and 

timber harvest, may temporarily displace the species locally in the short-term (i.e. during 

implementation), but are not expected to impact distribution within the project area in the long-term.

Cumulative effects

All alternatives: Lewis’ woodpeckers have relatively small home ranges (15 acres, Thomas 1979).

Therefore, the cumulative effects area is defined as the Eagle-Paddy and Little Eagle subwatersheds. All 

of the activities in Appendix B have been considered for their cumulative effects on Lewis’ woodpeckers 

and their habitat. Past activities such as removal of larger ponderosa pine and fire suppression have 

combined to create conditions that are largely marginal or unsuitable for this species, where historically 

habitat was more readily available. Firewood cutting could cause additional loss of snags along roads.

Livestock grazing has the potential to reduce shrub presence in suitable stands, but the predicted degree of 

impact is unknown. Future maintenance burning within treated stands will inhibit shrub layer 

development. None of these effects are expected to be significant because they are not likely to impact 

habitat availability at this scale.

Determination

All action alternatives enhance and increase suitable habitat structure within the project area in both the 

short and long-terms, with Alternative 2 providing the largest increase. Alternatives 2 and 3 have the 

potential to reduce or limit nesting structure in some stands due to removal of larger trees for mistletoe or 

density reduction while Alternative 4 would retain trees all trees larger than 21 inches. Nest failure and 

individual loss of nesting young is possible, but expected to be low risk to populations. Timber harvest 

treatments would have low potential to reduce snags on the landscape in the short-term. Long-term 

reductions in potentially available burned habitat are expected, but would be offset by a relatively steady 

availability of suitable green stands. In the long-term, maintenance burning would reduce shrub 

availability temporarily, but shrub growth and development that support insect prey populations is 

expected to occur between burning treatments.

Based on these factors, all action alternatives may impact individuals or habitat, but will not likely 

contribute to a trend towards Federal listing or cause a loss of viability to the population or species 

(MIIH).

White-headed Woodpecker

Existing condition

Type and availability of suitable habitat within the project area is similar to that identified above for 

Lewis’ woodpecker. Currently, the project area contains an estimated 591 acres of Single Story Large 

Tree (SSLT) ponderosa pine stands with open canopy condition. Density of larger snags vary across the 

landscape, but sampled plots indicate that snags 15 to 21 inches DBH average about 1.3 per acre, and 

snags 21 inches or greater DBH average about one snag per acre within the project area. Potential habitat 

is present within ponderosa pine associations in the southern portion of the project area, although current 

condition of most stands consists of denser, multi-storied canopies that present marginal or unsuitable 
Chapter 3 Snow Basin Vegetation Management Project FEIS

197

conditions for this species. The Oregon Natural Heritage database (ORNHIC 2009) does not contain 

sightings of this species within or adjacent to the project area; however, an individual white-headed 

woodpecker was sighted in mid-summer, 2008 within the south-central portion of the project area (D. 

Middlebrook, personal observation). In addition, white-headed woodpecker surveys conducted by The 

Forest Service within the project area during the summer of 2011 recorded a total of four white-headed 

woodpecker observations and identified one active nest site located in the northwestern portion of the 

project area.

Direct and indirect effects

Alternative 1

There will be no direct adverse impacts to white-headed woodpeckers from the No Action alternative 

because no timber harvest, fuels treatments, or transportation activities will occur. Indirectly, suitable 

habitat would continue to be less than amounts estimated to have occurred historically. Ponderosa stands 

would continue to contain dense, multi-storied conditions that reduce suitability for this species. Currently 

suitable stands would remain unaltered.

Alternative 2, 3, and 4

Effects of proposed treatments vary by stand type and in magnitude by alternative, and are similar to 

those identified for Lewis’ woodpecker. Suitable habitat for this analysis is considered those stands 

meeting the SSLT definition (i.e., single storied large trees) where average tree diameter is greater than 21 

inches, with at least 8 to 10 trees per acre (ponderosa pine and Douglas-fir) within biophysical 

environments G6, G7, and G8.

All action alternatives propose treatments in MSLT that reduce overstory densities and remove 

understories thereby moving MSLT to SSLT structural condition (Table 61). Within these BPEs, 

predominance of single-story late and old structure (LOS) is consistent with historical condition and 

therefore more sustainable than multi-storied LOS. Overall increase and availability of SSLT habitat 

would be highest after implementation of Alternative 2 (2172 acres), following in slightly decreasing 

magnitude by Alternatives 3 (2081 acres) and 4 (1792 acres). In addition, all action alternatives would 

transform some multi-storied, non-LOS stands to single-story condition (Table 61), thereby benefiting the 

species in the long-term by increasing potential for growth and transition to future SSLT stands. 

No loss of existing SSLT stands would occur under any alternative; however, removal of individual large 

trees (21+ inches DBH) would occur under Alternatives 2 and 3. Existing open stands where mistletoeinfected trees comprise the majority of larger overstory, treatments under Alternatives 2 and 3 could 

degrade existing suitable nesting habitat or limit nesting opportunity locally for this species. Structural 

conversion of MSLT to SSLT structure is expected to increase available habitat in the short-term (within 

20 years), while development of single-story non-LOS stands increases the potential for larger amounts of 

SSLT in the long-term (beyond 20 years)(Table 61).

Removal of snags that pose a safety hazard to those working within timber harvest units is possible, but 

expected to occur at a very low level. The rate of snag removal due to timber harvest safety concerns is 

estimated at less than 1 percent (of total existing snags) for timber sales on the district. Given the current 

condition of habitats along with snag retention requirements, snag removal represents a negligible effect 

to local populations of cavity users.

In addition to changes caused by vegetation treatments, prescribed burning would also affect available 

habitat. Burning within existing MSLT stands is expected to convert an estimated 15 percent of these 

acres to SSLT via consumption of understory vegetation. However, overall improvement of habitat due to 

prescribed burning in MSLT is questionable because reductions in overstory canopy closures to levels 

suitable for white-headed woodpecker may not occur. Because the known white-headed woodpecker nest 
Chapter 3 Snow Basin Vegetation Management Project FEIS

198

site is located within proposed RXF (underburn) Unit 10, a project design feature (PDF) has been 

incorporated that requires protection of the nest tree during prescribed burning (see Appendix B-1).

Short-term (less than 20 years) and long-term effects (20 years or greater) of both silvicultural and fuels 

treatments include reductions in stand-replacement fire potential. White-headed woodpeckers are not 

typically associated with high-intensity post-fire habitats, Wightman et al. (2010) indicate that a mosaic of 

burn severities across a landscape may improve habitat by opening forest canopies in higher severity burn 

areas, while retaining snags present prior to the burn as well as live, cone-producing trees in unburned or 

low-severity burn areas. Silviculture treatments alone would decrease stand susceptibility to crown fire, 

increase tree growth and bark resistance to surface fire. Overall, fire risk reductions create a more 

sustainable, less pulse-driven landscape that allows a steadier availability of suitable habitats.

By decreasing tree density as a result of vegetation treatments, natural snag recruitment is likely to occur 

at lower rates than untreated stands due to reduced levels of in-stand competition for resources, but the

difference is impossible to quantify due to ongoing levels of tree mortality factors unrelated to stand 

density. However, commercial thinning and partial removal treatments are expected to accelerate 

development of larger trees that provide larger snags through natural mortality.

Aspen restoration on scattered individual sites would remove conifers on a total of 38 acres, a portion of 

which may occur in suitable white-headed woodpecker habitat. The majorities of aspen sites are 1 acre or 

less and are identified in Appendix A and on project maps. Hazard tree removal along haul routes totaling 

up to about 7 miles in existing SSLT habitats would potentially remove snags in proximity to roads where 

densities are already low due to past and ongoing firewood gathering. New construction of less than 0.01 

mile of temporary roads within suitable habitat may remove less than 0.02 acre of suitable habitat. These 

activities would potentially remove minor amounts of habitat and are not expected to impact whiteheaded woodpecker habitats at the project area level. Activities that increase overall human presence and 

project-related noise levels, including system road reconstruction as well as timber harvest, may 

temporarily displace the species locally in the short-term (i.e. during implementation), but are not 

expected to impact distribution within the project area in the long-term.

Cumulative effects

All alternatives 

White-headed woodpecker home ranges are moderate in size, averaging about 257 to 524 acres in oldgrowth habitat, and extending out to 845 acres in fragmented habitat (Dixon 1995 in WDFW 2002).

Therefore, the cumulative effects area is defined as the Eagle-Paddy and Little Eagle subwatersheds. All 

of the activities in Appendix B have been considered for their cumulative effects on white-headed 

woodpeckers and their habitat. Past activities such as removal of larger ponderosa pine and fire 

suppression have combined to create conditions that are largely marginal or unsuitable for this species, 

where historically habitat was more readily available. Activities such as firewood cutting could cause 

additional loss of snags along roads. Access to firewood may change under the pending Forest Travel 

Management Plan. Potential loss of snags to firewood cutting would be reduced along roads not 

designated as open travel routes. Livestock grazing has the potential to limit shrub densities which may 

reduce risk due to nest predation, but the degree of benefit is unknown. Future maintenance burning 

within treated stands will inhibit shrub layer development, thereby benefiting this species by reducing 

cover for rodents that pose a threat via egg predation. Timber harvest on private lands within and adjacent 

to the project area is expected to continue with anticipated reductions of trees larger than 10 inches DBH.

None of these effects are expected to be significant because they not likely to impact habitat availability 

at this scale.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Determination

All action alternatives enhance and increase available habitat within the project area, both short-term and 

long-term, with Alternative 2 providing the largest increase. Alternatives 2 and 3 have the potential to 

reduce or limit nesting structure in some stands due to removal of larger mistletoe-infected trees.

Alternative 4 would retain existing large tree structure. Nest failure and individual loss of nesting young 

is possible, but expected to be of low risk to populations. Timber harvest treatments would have low 

potential to reduce snags on the landscape in the short-term.

Based on these factors, all action alternatives may impact individuals or habitat, but will not likely 

contribute to a trend towards Federal listing or cause a loss of viability to the population or species 

(MIIH).

Canada Lynx

Existing condition

The forest conducted extensive winter track surveys for wolverine and lynx from 1991 to 1994, and no 

lynx tracks were found on what was formally-called the Pine RD, presently part of the Whitman RD 

(Wolverine and Lynx Winter Snow Track Reports, 1991-92, 1992-93, 1993-94). Three unconfirmed lynx 

sightings were reported on the former Pine RD outside of the winter track surveys in the Wolverine and 

Lynx Winter Snow Track Report, (1992-93). Hair snares were used to survey for lynx, according to the 

National Lynx Survey, on the Forest during the summers of 1999 to 2001 and no lynx were detected.

Lynx habitat in northeastern Oregon is categorized as a “peripheral area,” meaning there is no evidence of 

long-term presence or reproduction that might indicate colonization or sustained use by lynx, but that it 

may enable the successful dispersal of lynx between populations or subpopulations. The Forest is 

considered “unoccupied” habitat because there has not been a verified lynx observation since 1999.

“Occupied” habitat is defined as requiring at least 2 verified observations or records since 1999 on the 

Forest or evidence of lynx reproduction on the forest.

Portions of the Snow Basin project area occurs within the Eagle Creek Lynx Analysis Unit (LAU). Lynx 

habitat on the WWNF has been mapped. The northern portion of the Snow Basin project area occurs 

within the southern fringe of mapped lynx habitat. No Canada lynx designated critical habitat occurs 

within or adjacent to the project area.

Direct, indirect, and cumulative effects

Alternative 1 

The No Action alternative would have no direct, indirect, or cumulative effects on lynx or lynx habitat 

since no management activities are proposed.

Alternatives 2, 3, and 4

Lynx habitat on the Forest has been mapped and 3 of the treatment units proposed under alternative 2 

(units 248, 249, RXF 23) totaling 25.2 acres occur in mapped lynx habitat (Table 62). The remaining 

units are in non-habitat. Alternatives 3 and 4 do not proposed treatment in units 248 and 249; both 

Alternatives 3 and 4 would therefore treat a total of 1.8 acres of mapped lynx habitat with prescribed fire.

Lynx habitat equates to snowshoe hare habitat; the same criteria generally defines habitat for both species. 

Table 62. Acres of mapped lynx habitat and proposed treatment

Unit1 Acres RX

Alternative 

proposing 

treatment

Mapped 

Lynx 

habitat Subwatershed

Acres of Mapped lynx habitat by 

subwatershed

248 10.0 HOR 2 Yes Eagle Creek- 77
Chapter 3 Snow Basin Vegetation Management Project FEIS

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249 13.4 HOR 2 Yes Paddy Creek

RXF 

23 1.8

Rx 

Fire 2, 3, 4 Yes Little Eagle 1,054

Ground reconnaissance of units 248 and 249 was conducted by the Doug Middlebrook in early 

September, 2008. Although the stands are mapped as lynx denning habitat, actual conditions consist of 

open overstory grand fir (seed tree or shelterwood stocking) with almost no understory conifers present 

and scattered individual down logs. The structural definition of denning habitat is defined as stands 

containing large amounts of down wood providing escape and thermal cover for kittens (Ruediger et al. 

2000). Further information provided by the Interagency Lynx Committee (1999) describes lynx as 

denning most commonly in jack-strawed logs within mature forests. Additional attributes included 

overstory canopies of 60 percent. Conditions currently found in units 248 and 249 do not meet the 

structural definition of denning habitats described by Ruediger et al. (2000) or the Interagency Lynx 

Committee (1999), nor do conditions meet the definition of foraging habitat due to the lack of conifer 

understory. Conditions most accurately reflect the definition of lynx habitat currently in unsuitable 

condition.

Although amounts and densities of jack-strawed down logs and understory conifer are unknown, 

conditions mapped on 1.8 acres within unit RXF 23 appear to more accurately reflect lynx habitat 

conditions, with higher canopy closures present. Prescribed burning within unit RXF 23 may reduce 

existing understory on 1.8 acres of mapped lynx and snowshoe hare habitat. However, existing large 

down wood is likely to remain due to project design features prescribing large wood retention.

None of the action alternatives would contribute to cumulative effects due to the minor amount of 

unoccupied lynx habitat that would be affected by this project.

Determination

There would be No Effect (NE) to the Canada lynx from any of the alternatives for this proposed project 

because this species is not considered present on the Forest (Wallowa-Whitman National Forest Lynx 

Strategy Letter April 19, 2007).

Gray Wolf

Existing condition

The WWNF occurs within the historic range of the gray wolf, and a breeding pack (Imnaha Pack) has 

been identified for the northern portion of the Forest. Localized wolf activity has also been documented 

on the WWNF near Dug Bar, Mount Emily, and the Little Minam River. Habitat and disturbance effects 

are of concern near denning and rendezvous areas, but no such features have been identified in or adjacent 

to the project area. In early 2009, wolf depredation on domestic sheep was confirmed in Baker County. In 

November 2010, a wolf track was positively identified in the northern portion of the Keating Unit 

(ODFW 2010). Potential habitat and adequate prey occurs throughout the project area, and movement 

through the project area is likely.

Direct and indirect effects

Alternative 1

There would be no direct, indirect, or cumulative impacts to wolves under the no-action alternative 

because no project activities would occur.

Alternatives 2, 3, and 4 

The primary threats to wolves are human disturbance, mortality from shooting and vehicle collisions 

(Wisdom et al. 2000). Primary concerns for the Forest Service are 1) disturbance to denning or 
Chapter 3 Snow Basin Vegetation Management Project FEIS

201

rendezvous sites, and 2) providing adequate habitat for populations of prey species such as elk (USDA 

Forest Service 2009).

None of the action alternatives would affect wolves or their habitat because there is an abundance of prey 

and prey is not a limiting factor, and most FS management activities are compatible with breeding wolf 

populations with relatively minor considerations for disturbance at dens and rendezvous sites. No known 

den or rendezvous sites are located within the Snow Basin project area. For all action alternatives, 

treatments are not expected to impact big game prey availability (see Rocky Mountain Elk discussion).

Cumulative effects

All alternatives

Because the home range of a colonizing wolf population can average 3012 miles (Bangs and Fritts 1993) 

with dispersal movements up to 522 miles (Boyd and Pletscher 1999), the Eagle Creek, Powder RiverRuckles Creek, and Pine Creek watersheds (7562 miles) define the cumulative effects analysis area. The 

only activity with potential cumulative impacts to wolves is implementation of the Forest Travel 

Management Plan (TMP). The selected TMP alternative could have a positive effect on the distribution of 

elk, a primary prey resource for wolves. The TMP preferred alternative will reduce density of designated 

motorized routes in all three watersheds as well as preclude cross-country travel. Reduced road densities 

would distribute elk across seasonal ranges during the proper season and may reduce the likelihood of 

wolves coming into contact with livestock on private lands. Ongoing livestock grazing on WWNF lands 

in the watersheds presents the potential for wolf-livestock interaction on these lands. However, potential 

wolf-livestock interaction is not cumulative to activities proposed under this project, because project 

activities are not expected to affect wolves.

Determination

Common to all alternatives

There would be No Impact (NI) to the gray wolf from any of the alternatives from this project due to a 

lack of effects resulting from management activities.

California Wolverine

Existing condition

Suitable habitats consist of alpine, subalpine, and mixed conifer with available food sources, with little or 

no human intrusion (Banci 1994). On the WWNF, core habitats are expected to occur within roadless and 

wilderness areas. There are no known den sites on the Forest (USDA Forest Service 2009). The Forest 

conducted extensive winter track surveys for wolverine and lynx from 1991 to 1994, and no wolverine 

tracks were found on what was formally-called the Pine RD, presently part of the Whitman RD 

(Wolverine and Lynx Winter Snow Track Reports, 1991-92, 1992-93, 1993-94). One unconfirmed 

wolverine sighting was reported on the former Pine RD outside of the winter track surveys in the 

Wolverine and Lynx Winter Snow Track Report (1993-94). Surveys conducted on the WWNF during the 

winter of 2010/2011 detected 3 different wolverines, one of which was located in the southern Wallowa 

Mountains, north of the Snow Basin project area. Wolverine tracks were also confirmed near Summit 

Point (immediately northeast of Snow Basin project area) during the winter of 2010/2011. Nearly all of 

the project area is well-roaded, facilitating human disturbance though access by motorized vehicles.

Existing suitable habitat is located primarily in roadless and wilderness areas, north of the project area.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Direct and indirect effects

Alternative 1

There will be no direct impacts to wolverine from the No Action Alternative because no timber harvest, 

fuels treatments, or transportation activities will occur.

Alternatives 2, 3, and 4

All action alternatives propose increases in road densities as timber harvest activities move through the

project area over an estimated 10 year period. However, no temporary roads or increased activity is 

proposed in areas that are not already within the bounds of human disturbance. Due to higher 

temperatures and increased summer human traffic, it is unlikely that wolverines would occupy portions of 

the project area that lie at lower elevations, south of the northern boundary, but movement through the 

project area is possible. The lack of lingering snowpack within the project area also minimizes the 

potential for wolverine denning. Forays into the project area would be more likely during the winter when 

human presence decreases due to snow, and potential food sources such as large ungulates move to lower 

elevations. Timber harvest operations, if conducted during the winter, could impact local presence and 

pattern of wolverine via disturbance, but impacts would be temporary. Other proposed activities are not 

expected to impact wolverine distribution or suitable habitat.

Cumulative effects

All Alternatives

Wolverines have large home ranges, estimated from studies in central Idaho to range from 26,000 to 

128,000 acres (Banci 1994); corresponding to a cumulative effects area encompassing the project area 

and lands within a distance of 4.5 miles. Past, present and reasonably foreseeable future actions were 

analyzed for cumulative impacts to the species. Effects of past activities including road construction, fire 

suppression, prescribed fire, and timber management on WWNF lands have been incorporated into the 

existing conditions for amounts and locations of wolverine habitats in the analysis areas. Review of the 

FACTS database for the WWNF indicate that activities that may impact wolverine habitat within the 

Eagle Creek watershed and outside the project area within the past 10 years consist of underburning, precommercial thinning, commercial harvest. Additional acres of commercial timber harvest is expected to 

occur in 2012 (Skookum Timber Sale). Because wolverines are known to avoid roaded areas, these 

activities occur in areas unlikely to impact the species.

Of the activities listed in Appendix B, past road construction and human access into subalpine portions of 

the project area have likely had the largest influence on potential presence and distribution of wolverine.

Ongoing access and human use within the project area, and on lands to the east and west, may continue to 

preclude at least seasonal use by this species. Roadless and wilderness areas on WWNF lands to the north 

would continue to provide suitable habitat. Lands to the south of the project area consist of grass and 

shrublands largely unsuitable for wolverine.

Determination

Past road construction has provided human access to portions of the project area that may have been 

utilized by wolverine historically. Activities proposed by the action alternatives would be undertaken 

primarily during the snow-free months when human presence is high and wolverine use unlikely. Winter 

timber harvest operations may impact presence and pattern of individual wolverine via disturbance.

Project activities would not impact core habitats located in wilderness or roadless areas. Therefore, all 

action alternatives may impact individuals or habitat, but will not likely contribute to a trend towards 

Federal listing or cause a loss of viability to the population or species (MIIH).
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Pacific Fisher

Existing condition

Based on studies conducted in northern Idaho, fisher generally avoid stands with less than 40 percent

canopy closure (Bull et al. 2005) and favor older, more complex stands consisting of spruce-fir and grand 

fir types (Powell and Zielinski 1994). Therefore, forested stands with at least 40 percent canopy closure in 

multi-storied late and old structure (MSLT) stands in BPEs G1-G5 are considered fisher habitat for this 

analysis. Approximately 1,160 acres currently comprise suitable habitat within the project area. The 

project area is located at the southern periphery of concentrations of suitable habitat located primarily in 

the northern half of the Eagle Creek watershed (Figure 7). 

Figure 7. Existing fisher suitable habitat 

source: WWNF existing vegetation database
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Direct and indirect effect

Alternative 1

The No Action Alternative will have no direct or indirect effects to fisher due to a lack of proposed 

management activities within suitable habitats. 

Alternatives 2, 3, and 4

Impacts to potential fisher habitat vary by alternative. Vegetation treatments under alternative 2 would 

treat and remove about 587 acres (51 percent) of MSLT in applicable BPEs (Table 63). Vegetation 

Treatments within Unit 50 (87 acres) will be maintained at or above 60 percent for Goshawk PFA 

considerations (see Goshawk discussion) and would continue to function as suitable fisher habitat under 

all alternatives. Vegetation treatments under Alternatives 3 and 4 would have less impact than Alternative 

2 by removing about 49 percent and 35 percent of suitable fisher habitat. Prescribed burning in MSLT is 

estimated to convert about 15 percent of underburned stands from multi- to single-story stands. Prescribed 

fire proposed under all action alternatives would transform less than 5 acres from MSLT to SSLT. 

Although habitat exists in the project area, fisher are not known or suspected to occur in this area. 

Therefore, direct impacts to fisher are highly unlikely. 

Table 63. Existing and post-treatment habitat availability by alternative

Alternative 2 Alternative 3 Alternative 4

BPE Existing

(ac.)

PostTreatmen

t (ac.)

BPE Existing 

(ac.)

PostTreatment 

(ac.)

BPE Existing 

(ac.)

PostTreatment 

(ac.)

G4/G5 1160 573 G4 1160 586 G4 1160 753

If fisher were utilizing the area, short-term human disturbance related to proposed timber harvest and 

transportation activities might displace transient or dispersing individuals from potential foraging habitat 

during the duration of the project. Treatments under Alternatives 2 and 3 would provide the least amount 

of habitat suitable for this species. Alternative 4 would maintain more suitable habitat in similar amounts. 

Due to snag and cull grand fir retention requirements, denning and resting structure in snags and live 

grand fir would be retained within treatment units, with the exception of snag removal for safety. 

Alternative 4 is likely to retain more opportunity for development of future denning and resting structure 

by retaining all trees greater than 21 inches. Other proposed activities are not expected to impact potential 

fisher distribution or suitable habitat.

Cumulative effects 

All alternatives: The fisher has relatively large potential home ranges (up to 19,500 acres, Powell and 

Zielinski 1994). Therefore, the cumulative effects area considered is the area extending out to 6 miles 

from the project area boundary. Areas to the north of the project area occur primarily within wilderness 

and roadless designation, and would likely retain existing habitats with the exception of periodic 

disturbances such as wildfire and insect-caused tree mortality. Areas to the east and west are managed for 

multiple-use and include activities such as livestock grazing, timber harvest, recreation, prescribed fire, 

and road infrastructure. Past activities such as fire suppression have likely led to an increase in potential 

habitat in some areas as once-open, single-story stands were allowed to transition to denser, multi-storied 

stands in the absence of fire. In other areas, harvest and removal of mature trees has likely reduced 

suitable habitats. Review of the FACTS database for the WWNF indicates that activities that may impact 

fisher habitat outside the project area within the past 10 years consist primarily of underburning and 

commercial timber harvest. Additional acres of commercial timber harvest are expected to occur in 2012 

(Skookum Timber Sale). Actions on adjacent private forest lands would likely continue to manage for 

reduced stem density and smaller tree diameters via rotation harvest strategies. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

205

Although commercial and non-commercial treatments may occur within fisher habitat, the scale of 

potential impacts is not substantial in comparison to fisher habitat within 6 miles of the project area, 

currently estimated to exceed 20,000 acres based on information in the WWNF Existing Vegetation 

database. Access within the analysis area may change pending the outcome of the Forest Travel 

Management Plan, under which the preferred alternative reduces miles of motorized access. With the 

implementation of the TMP, some roads that are open now will be closed by promulgation 

(approximately 18 miles in the Snow Basin area). Some roads within the project area currently identified 

as closed (maintenance level 1), will be opened for motorized travel by full size vehicles and/or OHVs 

(approximately 6 miles in Snow Basin). This will result in a net reduction of approximately 12 miles of 

open roads within the project area, which will provide additional habitat that is free from disturbance 

from motor vehicles. 

Determination

Aubry and Lewis (2003) found that extant fisher populations in Oregon are restricted to two disjunct and 

genetically isolated populations in the southwestern portion of the State. Human disturbance under all 

action alternatives could have short-term, indirect effects on fisher, although the risk of disturbance to 

fisher is considered extremely low. All action alternatives would remove potential habitat via timber 

harvest and prescribed burning. However, habitat available within 6 miles of the project area is abundant 

and habitat loss at levels occurring in Snow Basin is unlikely to substantially impact fisher habitat 

availability at the landscape scale. Action alternatives may impact individuals or habitat, but will not 

likely contribute to a trend towards federal listing or cause a loss of viability to the population (MIIH). 

Hells Canyon Land Snail

Existing condition

This species is currently known to occur as isolated colonies in roadless portions of the lower Salmon 

River canyon and northern Hells Canyon. It is replaced by related species in the central and southern parts 

of Hells Canyon. Much or all of the known and potential range has been surveyed in some detail (Frest 

and Johannes 1995).

Direct and indirect effect

Alternative 1

There would be no direct, indirect, or cumulative impacts to this species under the no-action alternative 

due to a lack of proposed management activities.

Alternatives 2, 3, and 4

No known potential habitat for this species occurs within the project area. Where unknown talus slopes 

may occur, they are would likely be avoided by proposed treatments due to a lack of vegetation. Project 

design features that prescribe retaining a buffer from management actions in proximity to talus habitats 

are expected to avoid potential impacts to species’ habitats if they do occur (see Appendix B-1).

Cumulative effects

All alternatives

Frest and Johannes (1995) describe grazing and roads along talus boundaries as impacting or extirpating 

former colonies. Grazing will continue within the project area in traditional areas, with no additional areas 

proposed under this project. Due to a lack of impact from activities proposed under the Snow Basin 

project, no cumulative impacts are expected.
Chapter 3 Snow Basin Vegetation Management Project FEIS

206

Determination

Given the habitat and distribution descriptions provided by Frest and Johannes, this species and its 

habitats have a low probability of occurrence within the project area. With implementation of Project 

Design Features that preclude management actions within suitable habitats, this project is expected to 

have no impact (NI) on individuals or habitats.

Columbia Spotted Frog (Rana luteiventris)

Existing conditions

Instream habitat and riparian areas have been changed from historical conditions due to many activities 

that have occurred over the years including grazing, wildfires, mining, road building, and logging.

Spotted frogs have not been documented in the project area but they occur west of the project area and 

suitable habitat exists within the project area.

On Eagle Creek, five water temperature monitoring stations are located in the analysis area and two are 

located upstream of the analysis area (see Watershed Aquatics Specialist Report). Water temperature data 

indicates that the redband trout standard (<68.0 °F) is being met in Eagle Creek in the analysis area. The 

water temperature standard was exceeded three out of four years that water temperatures were monitored 

in Little Eagle Creek in the analysis area. Water temperatures in Eagle Creek appear to be naturally warm 

based on temperature data from Eagle Creek Site 8 which is located near the wilderness boundary and 

about 11 stream miles above the project area. High water temperatures in Little Eagle Creek are likely 

related to water withdrawals for irrigation purposes (See Water Yield and Streamflow and Cumulative 

Effects Sections).

Direct and indirect effects

Alternative 1

Under alternative 1, the risk of wildfire or disease/insect outbreaks would continue to increase over time 

because there would be no changes to stand stocking levels or fuel loads from active management.

Assuming no uncharacteristic wildfires or disease/insect outbreaks, there would be no effect to spotted 

frogs other than potential benefits, including stream shading and lowered stream temperatures from 

increased densities of trees along channels. Current fine sediment levels would likely be maintained in the 

short term because current management activities would continue. Conifers currently supply most of the 

streamside shade in the project area and stream temperatures would either remain the same, cool slightly 

with increased shade, or increase as a result of a large-scale high intensity wildfire. Wildfires could affect 

spotted frogs and their habitat by burning through riparian areas and removing existing vegetation that is 

currently providing bank stability and preventing erosion and sedimentation. The impact to spotted frogs 

would depend on the size and severity of the disturbance.

Alternatives 2, 3 and 4

Discussion of these alternatives is combined because the effects of these alternatives would be similar.

Standard INFISH RHCA widths will be utilized to protect aquatic habitat from measurable increases in 

fine sediment. The majority of timber harvest activities are proposed for areas outside of RHCAs. A 

limited amount of commercial thinning activities, about 50 acres, will occur in the outer edges of RHCAs 

under the proposed action where treatment stands overlap with RHCAs (see Watershed Aquatics 

Specialist Report). In general, thinning will not occur within 200 feet of Category 1 stream channels 

(twice the height of a site potential tree) and 100 feet of Category 2 stream channels (height of a site 

potential tree). These distances meet the minimum requirements for INFISH RHCA widths for these 

stream categories and are sufficient to prevent removal of trees that provide stream shading. Restricting 

thinning activities to the outer edges of RHCAs will prevent adverse impacts to existing stream shading 
Chapter 3 Snow Basin Vegetation Management Project FEIS

207

along perennial streams in the aquatic effects analysis area. Therefore, measurable increases in stream 

temperatures are not likely to result from proposed thinning activities.

Proposed burning activities will result in a low severity fire in RHCAs adjacent to perennial streams in 

the project area. This will be accomplished by burning when fuel moisture levels are high, not actively 

lighting fires in RHCAs, and allowing fires to back into RHCAs from adjacent upslope areas. These 

techniques result in low intensity fires that burn in a patchy distribution of burned and unburned areas in 

RHCAs. Trees killed by prescribed fire in RHCAs will primarily be understory trees (≤ 8 inch DBH).

Understory trees of this size typically do not provide significant levels of stream shading.

The proposed burning in RHCAs adjacent to intermittent streams poses little risk of increasing stream 

temperatures because these streams are normally dry during the summer and fall months. Based on these 

factors, the Snow Basin Project is unlikely to result in a measurable increase in water temperature and a 

degradation of water quality in streams in the aquatic effects analysis area.

There is a low likelihood that increases in fine sediment from logging or burning will result in measurable 

increases in fine sediment in fish bearing streams in the analysis area (see Watershed Aquatics Specialist 

Report). The combination of temporary road construction (and decommissioning), opening and use of 

closed roads, and log haul traffic will likely result in an increase in fine sediment reaching streams in the 

analysis area. INFISH RHCAs will likely moderate much of the increase, and the amount of sediment 

reaching stream channels will likely result in an immeasurable increase in fine sediment levels delivered 

to streams (See Watershed Aquatics Specialist Report).

There is a possibility that direct mortality of spotted frogs may occur, particularly during periods of adult 

dispersal, as a result of log haul traffic and increased speed and traffic on roads. In addition, reductions in 

ground cover may increase their susceptibility to predation during overland dispersal. Wildlife connective 

corridors will mitigate these impacts by maintaining higher cover thus facilitating overland dispersal of 

frogs. Disturbance from proposed bridge and culvert replacements may temporarily displace individual 

spotted frogs from the area of disturbance. These activities will take place during the instream work 

window, which occurs after tadpoles have metamorphosed and become highly mobile and thus able to 

avoid direct mortality.

Sediment may increase following construction and may continue to spike periodically during the next 2 to 

3 years (see Watershed Aquatics Specialist Report). This increase in sediment will likely be insignificant 

in regard to the requirements of the spotted frog. Sediment control measures will be employed during the 

construction phase to mitigate the effect on aquatic habitat.

This project would not fragment wetland habitat, convert wetland habitat to upland habitat, or change the 

hydrology of a stream, spring, lake, or wetland habitat.

Cumulative effects

Alternative 1

There are no cumulative effects from selecting this alternative. Any changes that would occur over time 

as a result of selecting this alternative simply reflect the evolving baseline conditions for the area.

Alternatives 2, 3, and 4

Grazing is ongoing throughout the analysis area. Overgrazing can negatively impact spotted frog 

populations by removing riparian vegetation, introducing sediment into the stream, and by trampling of 

individual frogs. However, the moderate grazing levels that occur within the analysis area do not 

negatively affect spotted frogs or contribute to a cumulative negative effect. Previous timber sales, prior 

to implementation of the Screens standards, have likely caused a reduction in large woody debris and pool 

frequency in streams throughout the area, thereby reducing suitable habitat for spotted frogs. The Snow 
Chapter 3 Snow Basin Vegetation Management Project FEIS

208

Basin project will not further reduce the number of pools or large woody debris in the stream so there will 

be no cumulative effect. Road maintenance is an ongoing activity throughout the project area. Short-term 

effects from road maintenance are minimized by INFISH standards and guides and road maintenance 

BMPs. In the long-term, road maintenance reduces adverse effects to aquatic habitat by reducing overall 

erosions rates. The immeasurable additional increase in fine sediment from implementation of the Snow 

Basin action alternatives will not contribute to any measurable effect on spotted frog habitat quality 

because sediment will remain below the 20 percent threshold (see Watershed Aquatics Specialist Report). 

However, there may be a cumulative impact on direct mortality of dispersing individuals with improved 

road maintenance and subsequent increased speed and traffic. The Travel Management Plan may mitigate 

some of these effects by reducing the overall density of roads in the project area. 

Determination 

Common to All Alternative 

The Snow Basin project area may be inhabited by spotted frogs. However, none of the proposed activities 

(in any of the action alternatives) will degrade or impact potential habitat for this species. Any of the 

action alternatives may impact individual frogs (MIIH) but would not likely lead to a downward trend in 

the population or trend toward federal listing.

Inland Tailed Frog (Ascaphus montanus)

Bull and Carter (1996) sampled 80 streams within northeastern Oregon in 1992 including Big Creek and 

Jim Creek, which occur just northwest of the Snow Basin project area. They found that stream 

characteristics were more important than landscape characteristics in predicting the abundance of tailed 

frogs. They found no significant differences in numbers of larvae or adults when comparing streams with 

low, moderate, or heavy amounts of timber harvest. Larval abundance was best predicted by the 

percentage of cobble and fines in the stream. The percentage of cobble and boulders in the stream, the 

amount of a 2000 m stretch of stream with a buffer, and the stream gradient were the best predictors of 

adult abundance. 

Existing condition

Tailed frogs are not known to occur in the project area but there are high gradient streams within the 

project area that could provide suitable habitat, and tailed frogs have been documented in the upper 

reaches of the Eagle Creek drainage.

On Eagle Creek, five water temperature monitoring stations are located in the analysis area and two are 

located upstream of the analysis area (see Watershed Aquatics Specialist Report). In general, the water 

temperature standard for redband trout is being met in the analysis area (<20°C), with the exception of 

Little Eagle Creek. This standard is also the maximum temperature tolerated by tailed frogs. The water 

temperature standard was exceeded three out of four years that water temperatures were monitored in 

Little Eagle Creek in the analysis area. Water temperatures in Eagle Creek appear to be naturally warm 

based on temperature data from Eagle Creek Site 8 which is located near the wilderness boundary and 

about 11 stream miles above the project area. High water temperatures in Little Eagle Creek are likely 

related to water withdrawals for irrigation purposes. Because Little Eagle Creek is consistently above the 

temperature requirements of tailed frogs and also not a fast-flowing high gradient stream that tailed frogs 

prefer, it is unlikely that tailed frogs would be present in this stream.

Direct and indirect effects

Alternative 1

Under alternative 1, the risk of wildfire or disease/insect outbreaks would continue to increase over time 

because there would be no changes to stand stocking levels or fuel loads from active management. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Assuming no uncharacteristic wildfires or disease/insect outbreaks, there would be no effect to tailed 

frogs other than potential benefits, including stream shading and lowered stream temperatures from 

increased densities of trees along channels. Current fine sediment levels would likely be maintained in the 

short term because current management activities would continue. Conifers currently supply most of the 

streamside shade in the project area and stream temperatures would either remain the same, cool slightly 

with increased shade, or increase as a result of a large-scale high intensity wildfire. Wildfires could affect 

tailed frogs and their habitat by burning through riparian areas and removing existing vegetation that is 

currently providing bank stability and preventing erosion and sedimentation. The impact to tailed frogs 

would depend on the size and severity of the disturbance.

Alternatives 2, 3, and 4 

Discussion of these alternatives is combined because the effects of these alternatives would be the same.

Standard INFISH RHCA widths will be utilized to protect aquatic habitat from measurable increases in 

fine sediment. The majority of timber harvest activities are proposed for areas outside of RHCAs. A 

limited amount of commercial thinning activities, about 50 acres, will occur in the outer edges of RHCAs 

under the proposed action where treatment stands overlap with RHCAs (see Watershed Aquatics 

Specialist Report). In general, thinning will not occur within 200 feet of Category 1 stream channels 

(twice the height of a site potential tree) and 100 feet of Category 2 stream channels (height of a site 

potential tree). These distances meet the minimum requirements for INFISH RHCA widths for these 

stream categories and are sufficient to prevent removal of trees that provide stream shading. Restricting 

thinning activities to the outer edges of RHCAs will prevent adverse impacts to existing stream shading 

along perennial streams in the aquatic effects analysis area. Therefore, measurable increases in stream 

temperatures are not likely to result from proposed thinning activities.

Proposed burning activities will result in a low severity fire in RHCAs adjacent to perennial streams in 

the project area. This will be accomplished by burning when fuel moisture levels are high, not actively 

lighting fires in RHCAs, and allowing fires to back into RHCAs from adjacent upslope areas. These 

techniques result in low intensity fires that burn in a patchy distribution of burned and unburned areas in 

RHCAs. Trees killed by prescribed fire in RHCAs will primarily be understory trees (≤ 8 inch DBH).

Understory trees of this size typically do not provide significant levels of stream shading.

The proposed burning in RHCAs adjacent to intermittent streams poses little risk of increasing stream 

temperatures because these streams are normally dry during the summer and fall months. Based on these 

factors, the Snow Basin Project is unlikely to result in a measurable increase in water temperature and a 

degradation of water quality in streams in the aquatic effects analysis area.

The combination of new temporary road construction (and decommissioning), opening and use of closed 

roads, and log haul traffic will likely result in an increase in erosion rates in the analysis area. Increases in 

erosion rates will occur in the short-term and then trend towards background levels (see Watershed 

Aquatics Specialist Report). INFISH RHCAs will likely moderate much of the increase and the amount of 

sediment reaching stream channels will likely result in an immeasurable increase in fine sediment levels 

in streams in the analysis area for aquatic species (See Watershed Aquatics Specialist Report). There is a 

possibility that direct mortality of tailed frogs may occur, particularly during periods of adult dispersal, as 

a result of log haul traffic and increased speed and traffic on roads that have been improved. In addition, 

reductions in ground cover may increase their susceptibility to predation during overland dispersal.

Wildlife connective corridors will mitigate these impacts by maintaining higher cover thus facilitating 

overland dispersal of frogs. Disturbance from proposed bridge and culvert replacements may temporarily 

displace or harm individual tailed frogs from the area of disturbance. Sediment may increase following 

construction and may continue to spike periodically during the next 2 to 3 years (see Watershed Aquatics 

Specialist Report). This increase in sediment will likely be insignificant in regard to the requirements of 

the tailed frog. Sediment control measures will be employed during the construction phase to mitigate the 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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effect on aquatic habitat. This project would not fragment wetland habitat, convert wetland habitat to 

upland habitat, or change the hydrology of a stream, spring, lake, or wetland habitat.

Cumulative effects

Alternative 1

There are no cumulative effects from selecting this alternative. Any changes that would occur over time 

as a result of selecting this alternative simply reflect the evolving baseline conditions for the area.

Alternatives 2, 3, and 4 

Grazing is ongoing throughout the analysis area. Overgrazing can negatively impact tailed frog 

populations by removing riparian vegetation, introducing sediment into the stream, and by trampling of 

individual frogs. However, the moderate grazing levels that occur within the analysis area do not 

negatively affect tailed frogs or contribute to a cumulative negative effect. Previous timber sales, prior to 

the implementation of the Screens standards, have likely caused a reduction in large woody debris and 

pool frequency in streams throughout the area, thereby reducing suitable habitat for tailed frogs. The 

Snow Basin project will not further reduce the number of pools or large woody debris in the stream so 

there will be no cumulative effect. Road maintenance is an ongoing activity throughout the project area. 

Short-term effects from road maintenance are minimized by INFISH standards and guides and road 

maintenance BMPs. In the long-term, road maintenance reduces adverse effects to aquatic habitat by 

reducing overall erosions rates. However, there may be a cumulative impact on direct mortality of 

dispersing individuals with improved road maintenance and subsequent increased speed and traffic. The 

Travel Management Plan may mitigate some of these effects by reducing the overall density of roads in 

the project area. 

Determination 

Common to all alternatives

The Snow Basin project area may be inhabited by tailed frogs. However, none of the proposed activities 

(in any of the action alternatives) will degrade or impact potential habitat for this species. Any of the 

action alternatives may impact individual frogs (MIIH) but would not likely lead to a downward trend in 

the population or trend toward federal listing.

Johnson’s Hairstreak

Author: Lia Spiegel, Entomologist, Blue Mountains Pest Management Service Center

Existing condition

Targeted surveys in 2009 confirmed two new Johnson’s hairstreak locations. These areas had dwarf 

mistletoe in ponderosa pine and Douglas-fir. Surveys in the Snow Basin area did not confirm the presence 

of the Johnson’s hairstreak. However, as it is known to occur just east and west of the project area and 

both larval and adult food sources are present, it likely occurs in Snow Basin as well.

Direct and indirect effects

Alternative 1

No action would result in no direct effects but the indirect continued slow decline of western larch and 

ponderosa pine from the landscape until severe fire regenerates these stands. Historically light surface 

fires in seral stands killed trees with low-hanging dwarf mistletoe brooms, but trees with elevated brooms 

survived. Stands that are now dense with fir regeneration and low-growing crowns will experience more 

severe fire when they burn. Especially hot fires can effectively sanitize stands of dwarf mistletoe when all 

infected trees are killed. Significant reinfection then will take decades as birds reintroduce seeds and the 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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infection slowly spreads. No action over the long term would result in less hairstreak habitat as the 

confirmed host pines continue to decline.

Alternatives 2, 3, and 4

Alternatives 2 and 3 in the short term may impact individuals or habitat but will not likely contribute to a 

trend towards federal listing or cause a loss of viability to the population or species. The impact would 

occur to individuals as a direct result of removal of dwarf mistletoe infected trees during thinning, 

harvest, burning, and sanitation operations. Removals that retain some dwarf mistletoe-infected ponderosa 

pine will continue to provide habitat for the larvae by allowing ponderosa pine to regenerate over the long 

term. Sanitation of dwarf mistletoe in ponderosa pine generally allows for the retention of trees with 

infections in the lower half of their crowns. In addition, sanitation cuttings target trees with welldeveloped brooms. 

Approximately 50 percent of infected trees are not detected during sanitation cutting due to the lack of 

well-developed, conspicuous brooms (Shea and Lewis, 1971). The proposed action over the long term is 

likely to have a beneficial impact by promoting pine and larch regeneration and their associated dwarf 

mistletoes over a greater area than it currently occurs.

The refugia and stands with no management action planned also contain dwarf mistletoe. Some of these 

likely provide suitable habitat currently and will continue to provide it in the near term. Over the long 

term, where seral ponderosa pine and western larch occurs, these trees will eventually succumb to

succession and die from overcrowding and bark beetles and be replaced by shade-tolerant species. Based 

on the believed preference of hairstreak larvae for large dwarf mistletoe plants, the Douglas-fir dwarf 

mistletoe that may be perpetuated here would not provide an optimal food source. 

Alternative 4 in the short term may impact individuals or habitat but will not likely contribute to a trend 

towards federal listing or cause a loss of viability to the population or species. The direct short term 

impact would be less than either alternative 2 or 3, because fewer dwarf-mistletoe infected pines would be 

removed. Over the long term, the indirect effect of the retention of all large trees would inhibit the 

restoration of stands to early seral by maintaining higher stand densities and retaining a higher proportion 

of grand fir and Douglas-fir.

Thinning that targets stands for dwarf mistletoe reduction would likely result in some direct reduction of 

Johnson’s hairstreak individuals but would not impact the ability of the species to survive in the Blue 

Mountains. Management that retains dwarf mistletoe-infected ponderosa pine well-distributed across the 

landscape and promotes the regeneration of ponderosa pine will continue to provide habitat for the larvae 

of this butterfly.

Cumulative effects

Alternative 1

No action would continue the decline of ponderosa pine, the only documented host for the hairstreak in 

the Snow Basin project area, due to natural succession. This would continue the increased occurrence of 

grand fir, which does not have dwarf mistletoe in the Blue Mountains, and Douglas-fir, which is an 

unlikely host for the Johnson’s hairstreak due to its very small size.

Alternatives 2, 3, and 4

All action alternatives propose dwarf mistletoe reduction in ponderosa pine and Douglas-fir. In the short 

term there will be a reduction of host plants for hairstreak larvae to feed on within dwarf mistletoe 

treatment areas. However, dwarf mistletoe habitat is likely to remain well-distributed and abundant in 

lightly infected leave trees, where low severity fire is prescribed that does not kill trees, and in refugia and 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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riparian areas. Over the long term severe dwarf mistletoe infections will be less common but the range of 

dwarf mistletoe in pine and larch will increase with an increase in host trees.

Determination 

Common to all alternatives

All action alternatives will decrease the number of dwarf mistletoe clumps serving as larval food sources 

in the short term (less than 20 years) at a small scale. However, at the multistand scale of use of 

hairstreaks, dwarf mistletoe distribution will not be affected. Over the long term the distribution of 

ponderosa pine and western larch dwarf mistletoe will increase as the area of host trees increases with the 

opening of stands to allow seral regeneration. Thus, all action alternatives may impact individuals or 

habitat but will not likely cause a trend toward Federal listing or a loss of viability of the population or 

species (MIIH).

Threatened, Endangered, and Sensitive Species Determinations

The following determinations pertain to threatened, endangered, and sensitive species known to occur or 

potentially occurring within the Snow Basin project area.

Table 64. Summary of Threatened, Endangered and Sensitive species determinations

Species Status Alternative 1 Alternative 2 Alternative 3 Alternative 4

Peregrine Falcon FS Sensitive No Impact MIIH MIIH MIIH

Bald Eagle FS Sensitive No Impact MIIH MIIH MIIH

Lewis’ Woodpecker FS Sensitive No Impact MIIH MIIH MIIH

White-headed Woodpecker FS Sensitive No Impact MIIH MIIH MIIH

Canada lynx Threatened No Effect No Effect No Effect No Effect

Gray Wolf FS Sensitive No Impact No Impact No Impact No Impact

Wolverine FS Sensitive No Impact MIIH MIIH MIIH

Pacific Fisher FS Sensitive No Impact MIIH MIIH MIIH

Hells Canyon Land Snail FS Sensitive No Impact No Impact No Impact No Impact

Johnson’s Hairstreak FS Sensitive MIIH MIIH MIIH MIIH

Fir Pinwheel FS Sensitive No Impact No Impact No Impact No Impact

Meadow Fritillary FS Sensitive No Impact No Impact No Impact No Impact

Silver-bordered Fritillary FS Sensitive No Impact No Impact No Impact No Impact

MIIH = May Impact Individuals or Habitat, but will not likely contribute to a trend towards federal listing or cause a loss 

of viability to the population.

Management Indicator Species (MIS) 

The LRMP identifies 5 wildlife species, or groups of species, as MIS (Table 65) (US Forest Service 

1990). These species serve as indicators of the effects of management activities by representing habitat 

for a broad range of other wildlife species. The habitat requirements of MIS are presumed to represent 

those of a larger suite of species using the same type of habitat. All MIS are present in the project area.

Table 65. MIS and their primary habitats.

Species Habitat

American marten Old-growth and mature forest 

Northern goshawk Old-growth and mature forest 

Pileated woodpecker Old-growth and mature forest 
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Primary cavity excavators 1 Snags and logs 

Rocky Mountain elk Cover and forage 

1 Northern flicker; black-backed, downy, hairy, Lewis’, three-toed, and white-headed woodpeckers; red-naped and 

Williamson’s sapsuckers; black-capped, chestnut-backed, and mountain chickadees; and pygmy, red-breasted, and 

white-breasted nuthatches.

Old-Growth Associated Species

Existing conditions

Overview

The R-6 Regional Forester’s Forest Plan Amendment #2 contains standards and guidelines (S&Gs) that 

address the historical range of variability (HRV). Because the distribution, quality and quantity of habitat 

largely determines the potential for a wildlife species to exist at viable levels, HRV becomes an important 

habitat indicator for resident species. By managing habitat within the historical range of variability it is 

assumed that adequate habitat will exist for associated wildlife species since they existed at viable levels 

under those conditions previously. The larger the gap between current and historical conditions, the less 

likely that adequate habitat is being provided to sustain those associated species.

Both MSLT (multi-storied LOS) and SSLT (single-storied LOS) are present in the Snow Basin project 

area. Existing MSLT and SSLT total 3,586 and 961 acres, respectively. However, for several biophysical 

environments (BPEs), the HRV analysis identifies departure from HRV. All BPEs show that the amount 

of multi-storied LOS is within the range estimated to have existed historically, with the exception of hot, 

dry ponderosa pine stands. In contrast, single-storied LOS stands are currently deficient within the lower 

elevation, warm and dry ponderosa pine and Douglas-fir stands. 

In addition to departure from HRV in total acres, current patch size and spatial distribution of LOS within 

the Snow Basin project area show a somewhat fragmented arrangement of stands. Large gaps are present 

throughout the project area, with concentrations of LOS noted in the northeastern portion (Figure 8).

While natural vegetation patterns include an interspersion of large grass/forb/shrub openings, some gaps 

are the result of past timber harvests. Development of LOS condition within past regeneration harvest 

units is expected to take decades, depending on the existing age of forested stand. Nearest neighbor 

analysis shows that average distance between MSLT stands is 0.65 mile, while average distance between 

SSLT stands is 0.98 mile. Existing average patch sizes for MSLT and SSLT are 68 ac. and 57 ac., 

respectively. By comparison, Hessburg et al. (1999) estimated that historically, patch sizes for MSLT and 

SSLT in the Blue Mountains averaged 83 ac. and 82 ac., respectively. 
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Figure 8. Existing LOS stand distribution

Source: Snow Basin GIS project files.

The concept of source habitats provides a method to assess the effects of departure from HRV for late/old 

forest habitat to a particular wildlife species, at a larger scale. Wisdom et al. (2000) describe source 

habitats as, “... those characteristics of macrovegetation that contribute to stationary or positive 

population growth for a species in a specified area and time” and classified species into habitat-associated 

groups. The relevant groups for this late/old forest habitat discussion are group 1 (including white-headed 

woodpecker), group 5 (including American marten and summer habitat for northern goshawk), and group 

6 (including pileated woodpecker).

Generally source habitat has experienced dramatic decreases for groups 1, 5 and 6 across much of the 

Interior Columbia Basin with the exception of American marten and pileated woodpecker (see discussion 

below). In the Blue Mountains ecological reporting unit, more than 40 percent of the watersheds have 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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experienced a decrease of >60 percent in source habitats for groups 1, 5 and 6. Wisdom et. al. identified 

the following management issues related to conifer habitat conditions associated with groups 1, 5, and 6:

Group 1

1. Basin-wide decline in late seral interior and Pacific ponderosa pine.

2. Basin-wide loss of large-diameter snags (>21 inches)

3. High risk of additional loss of ponderosa pine habitat through stand-replacing fires.

Group 5

1. Reduction in the amount of old-forests and associated structures (snags, logs, and cavities), 

particularly within the montane and lower montane community groups.

2. Fragmentation of habitat.

Group 6

1. Reductions in the extent of late seral lower montane, montane, and subalpine forest.

2. Reductions in large snags and logs in landscapes that have been managed under traditional 

silvicultural practices.

3. Possible unsustainable conditions in late seral stage montane forests where there have been large 

transitions from shade-intolerant to shade-tolerant species.

Connectivity of LOS Habitat

Existing conditions

Connectivity between MA-15 “allocated old growth” and LOS stands was assessed utilizing field 

reconnaissance, aerial photographs and GIS mapping. The level of connectivity between MA-15 and LOS 

stands varies across the project area. Areas of non-forested vegetation in combination with past timber 

harvest have created gaps of varying size in the central and southeastern portions of the project area.

Several LOS stands are currently isolated by their adjacency to stands lacking a substantial forest cover 

component. Stands at upper elevations in the northern portion of the project area are currently well 

connected (Figure 9). There are connections to large areas of roadless and wilderness to the north. The 

LOS found in the southern portion of the project area is connected to the north, but not to the south where 

a natural gradation from forested to non-forested vegetation types occurs. This connectivity discussion is 

pertinent to all wildlife species mentioned elsewhere in this Wildlife Specialist’s Report, particularly 

those that utilize LOS habitat for any part of their life history. Pileated woodpecker, marten and their 

prey, goshawk and their prey, elk, and a variety of other vertebrates and invertebrates are affected by the 

level of connectivity between their source or preferred habitats. 

Refugia

The concept of “refugia” has been incorporated into project planning on the portion of the Whitman 

Ranger District that was formerly the Pine Ranger District. Refugia is described by Camp et al. (1997) as 

forested patches that have missed one or more disturbances that shaped the surrounding vegetation on the 

landscape. In the Snow Basin project area these typically occur on north and northeastern aspects which 

have higher moisture retention than other aspects. Higher moister levels generally lead to denser 

vegetation and higher fuel moisture. Higher fuel moisture influences fire behavior by causing a fire to 

burn in more of a mosaic pattern or to spare forested patches altogether. 

The connective corridor network for Snow Basin was delineated to not only connect LOS and MA 15 

areas, but to also link to many of the refugia stands. See page 52 of the Biological Evaluation and 

Wildlife Specialist’s Report, located in the project file, for more background on the concept of refugia. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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The connectivity network was established based generally on stand boundaries and connects, to the extent 

possible, all LOS and MA-15 stands within and outside the project area according to direction in the 

Forest Plan Amendment #2.

Direct and indirect effects

Although the Snow Basin project involves several types of activities that could alter the quality and 

function of connective corridors, this effects analysis focuses on the commercial vegetation treatments. 

Commercial timber harvest is the tool used to accomplish at least part of the vegetation objectives. 

Timber harvest is the primary activity that would reduce canopy closure and decrease structural 

complexity within treated stands. Other activities such as prescribed fire, non-commercial thinning, and 

mechanical fuels reduction can affect the quality and function of connective corridors, but to a much 

lesser degree than timber harvests. Also, the structural components affected by these less impacting 

activities can be replaced (grow back, recover) quickly relative to timber harvest. For example, noncommercial thinning, mechanical fuels reduction, and prescribed fire generally target the reduction of 

smaller diameter materials from forest duff to woody materials under 10 inches in diameter. An exception 

is prescribed fire which can consume all sizes of woody material, live and dead. Fire is an inexact tool, so 

there is the possibility that some larger woody structures will be consumed, and new ones created as trees 

are killed. However, prescriptions for fire are designed to retain the larger diameter woody materials, and 

consume smaller diameter materials.

Alternative 1

Alternative 1 will have no direct effect on connectivity between LOS habitat patches. The current level of 

connectedness would persist, and would improve in quality in the absence of large scale disturbances. In 

the absence of vegetation treatments that reduce tree stocking, the connective corridors will continue to 

increase in canopy closure and structural complexity. This condition in cold and moist upland forests 

would enhance connectivity for species like American marten. Although connectivity would be enhanced 

over time, risks from insects, diseases, and wild fire would increase.

Conversely, dry upland forests are inherently less structurally complex than cold and moist upland forests.

In the absence of vegetation treatments to reduce tree stocking, these stands would continue to allow the 

establishment of shade tolerant grand fir, increased canopy closure, and increased stress to competition 

for resources. In the long-term (30+ years) these drier stands would be subjected to increased risks from 

wildfire, insects and diseases that will kill trees in numbers and distribution that could negatively affect 

connectivity between patches of single strata LOS habitat.

To forego prescribed burning, non-commercial thinning, and mechanical fuels reduction would perpetuate 

higher tree densities, higher fuels loading, ladder fuels, and tree species compositions that are not 

sustainable for the biophysical setting. These indirect effects may contribute to uncharacteristic insect, 

disease, and wildfire events. The effects of wide scale tree mortality from these disturbances would have a 

much greater negative effect to connectivity than the prescribed treatments under alternatives 2, 3, and 4.

These negative effects could render the LOS and connective corridors unsuitable for the wildlife species 

that depend on them as habitat. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Figure 9. LOS and connectivity network, Snow Basin project area. 

Alternative 2

Alternative 2 will reduce the quality of connectivity corridors on 2,972 acres by reducing the canopy 

closure and structural complexity. Table 66 compares the acres that are proposed for vegetation 

treatments by alternative. Timber harvest units within connective corridors would be reduced to the lower 

management zone of basal area, which equates to the lower limit of tree stocking for full site occupancy, 

or the point at which a significant portion of a site’s resources can be captured as tree growth. The lower 

management zone also represents the condition at which a stand is considered fully stocked and the trees 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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are best able to defend against insects and diseases. The lower management zone has the lowest canopy 

closure and often the lowest structural complexity for a fully stocked condition.

Alternative 2 would apply prescribed fire to approximately 1,700 acres within connective corridors, but

outside of commercial timber harvest units. The large majority of these acres are within the dry upland 

forest types where periodic fire historically performed a maintenance function that shaped the structure, 

tree species composition, and wildlife value of these stands. Some snags and logs may be consumed by 

prescribed fire, while new snags and logs are recruited from fire killed trees. The burning, noncommercial thinning, and mechanical fuels reduction in connective corridors will not have a measurable 

negative effect on the quality or function of the corridors.

Alternatives 3 and 4

Alternatives 3 and 4 will reduce the quality of connectivity corridors on 2,784 and 2,564 acres 

respectively. Table 66 provides a comparison of acres treated within connective corridors by alternative, 

which is a key measure for comparison between alternatives. Timber harvest units within connective

corridors under Alternatives 3 and 4 will retain basal areas between the middle and upper management 

zone. Tree stocking that exceeds the upper management zone is where competition between trees leads to 

density induced mortality of some trees. This level of tree stocking would reduce competition between 

residual trees, increase tree growth rates, and increase trees’ ability to defend against insects and diseases, 

while retaining levels of canopy closure and structural complexity to facilitate movement of wildlife 

between LOS habitat patches.

Both Alternatives 3 and 4 would apply prescribed fire to approximately 1,400 acres within connective 

corridors, but outside of commercial timber harvest units. The large majority of these acres are within the 

dry upland forest types where periodic fire historically performed a maintenance function. Some snags 

and logs may be consumed by prescribed fire, while new snags and logs are recruited from fire killed 

trees. The burning, non-commercial thinning, and mechanical fuels reduction in connective corridors will 

not have a measurable negative effect on the quality or function of the corridors.

Cumulative effects 

Alternative 1

The no action alternative will not contribute to cumulative effects. Any effects of forgoing vegetation 

treatments and prescribed burning would occur later in time, and are addressed as indirect effects above.

Alternative 2

The reduction in connective habitat quality that results from vegetation treatments would be greater than 

for Alternatives 3 and 4 in both acres affected and degree of effects on specific acres. It is unknown 

whether the level of treatments in alternative 2 will compromise connectivity to a level that leads to 

isolation or fragmentation of wildlife habitat. The riparian habitat conservation area network, MA-15 

areas, wild and scenic river corridor (Eagle Creek), and the remaining forest matrix will combine to 

facilitate varying degrees of connectivity between distant LOS habitat patches.

The incremental effects of prescribed burning, non-commercial thinning, and mechanical fuels reduction, 

would be immeasurable relative to the quality and function of connective corridors. 

Alternatives 3 and 4

The reduction in connective habitat quality that results from vegetation treatments will be relatively short 

lived as tree canopies respond to the reduced competition, and seedlings establish in response to increased 

sunlight reaching the forest floor. The quality of connective habitat in treatment units would likely 

recover to pre-treatment conditions within fifteen years. In the interim, the network of connectivity 

corridors that is not being treated (riparian habitat conservation areas, MA-15 areas, and the matrix of 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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forested habitats) will facilitate movement of LOS associated wildlife species between source habitat 

patches.

Alternative 3 would reduce the quality of connective corridors on 220 more acres than alternative 4, but 

both alternatives would address connectivity to a greater level than alternative 2. 

This approach of addressing connectivity habitat is consistent with direction in the Regional Forester’s 

Forest Plan Amendment #2 to retain canopy closure in the upper 1/3 of site potential, and other criteria 

that define connective corridors. 

The incremental effects of prescribed burning, non-commercial thinning, and mechanical fuels reduction, 

would not compromise the quality or function of connective corridors. 

Table 66. Connectivity corridor summary

Alternatives

Alternative 1 Alternative 2 Alternative 3 Alternative 4

Acres of Vegetation 

treatments in 

connective corridors

0 2,972 2,784 2,564 

Acres of mapped 

connective corridors 

remaining untreated

7,608 4,636 4,824 5,044

Connectivity 

Prescription

N/A Retain basal 

area at LMZ

Retain basal 

area between

middle and 

UMZ

Retain basal 

area between 

middle and 

UMZ

American Marten

Life history, risk factors, conservation status and population trend, as well as habitat condition and species 

viability are described in detail in the American marten (Martes americana) Management Indicator 

Species Assessment, Wallowa-Whitman National Forest (Penninger and Keown 2011a). Portions of that 

assessment are summarized below.

Habitat

The marten is a MIS associated with old-growth habitat. It is an indicator of the abundance and 

distribution of mature and old-growth forest, and the contiguity of cover between old-growth stands.

Marten are closely associated with forested habitats that have complex physical structure near the ground 

(Buskirk and Powell 1994, Slauson et al. 2007) including coarse wood (Stevens 1997). Open areas, such 

as regeneration logging units, recent severely burned areas, and natural openings are avoided, especially 

during the winter. Forested riparian habitats are used disproportionately higher than they are available, 

which indicates their importance as travel corridors (Bull et al. 2005). Currently the WWNF contains 

129,943 acres of source habitat (90 percent of historical)(Penninger and Keown 2011a).

Preliminary survey results have detected marten in six of seven sample units on the WWNF in 2011, 

including multiple locations of marten where The Wolverine Foundation is conducting carnivore surveys 

around the Eagle Cap Wilderness. The WWNF conducted winter track surveys for wolverine and lynx 

from 1991 to 1994, and marten tracks were found during each survey on what was formerly-called the 

Pine RD (Wolverine and Lynx Winter Snow Track Reports, 1991-92, 1992-93, 1993-94). Approximately 

80 track detections were reported in the southern and western Wallowas, 53 of which occurred on the 

Pine RD. Photographs of marten were also taken by a remote camera at a bait station during the 1993/94 

survey. Sightings have occurred west and east of the Snow Basin project area. Marten presence in the 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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northeastern portion of the project area has been confirmed by recent ODFW trapping records (B. Ratliff, 

personal communication 2011). 

Landscape connectivity

Penninger and Keown (2011a) identified areas within the Blue Mountains containing larger expanses 

lacking overhead cover that may pose barriers to marten movement across larger landscapes. None of 

these areas are located within or adjacent to the Snow Basin project area. They also modeled landscape 

permeability at a finer scale, using cover types, road densities, housing density (human development), 

slope, and elevation and generated permeability coefficients, which ranged from 0.1 (nearly impermeable) 

to 1.0 (highly permeable). Permeability in the southern Wallowas varies, with lowest ratings occurring at 

lower elevations that lack suitable marten habitat, and highest ratings located at higher elevations below 

alpine habitats in areas with more mesic conifer stands and few or no open roads.

Analysis for Snow Basin and Eagle Creek Watershed

Based on analysis of habitats containing marten radio telemetry locations in the Blue Mountains, 

Penninger and Keown (2011a) modeled marten source, secondary, and potential habitats on the WWNF.

Source habitats are defined as an area containing vegetation condition capable of supporting stable or 

positive population growth. Characteristics of source habitat modeled by Penninger and Keown consist of 

forested stands in the Cold Dry and Cold Moist potential vegetation groups (PVGs) that have canopy 

closure equal to or greater than 50 percent, and tree sizes of 15 inch DBH or greater. Secondary habitats 

are defined as those areas where macro-vegetation conditions support foraging, dispersing, resting, or 

traveling between patches of source habitat, but lack the necessary structural components to qualify as 

source habitat. Modeled secondary habitat consists of forested stands in Cold Dry and Cold Moist PVGs 

with ≥50 percent canopy closure and tree size class ≥10 inch DBH. Potential habitat, which describes 

forested habitats that have the biophysical capability to develop into secondary or source habitat, consists 

of all forested stands in the Cold Dry and Cold Moist PVGs.

Habitat parameters described by Penninger and Keown (2011a) were applied to existing vegetation data 

to identify marten source and secondary habitats within the Snow Basin project area and Eagle Creek 

watershed. Furthermore, field review of selected stands modeled as source habitat was conducted in 

September 2011, resulting in changes in habitat classification of habitats modeled within the project area.

Based on the field review, it appears that stands capable of supporting marten exist primarily above 4,700 

feet elevation and those below 5,000 feet in the Snow Basin project area, and are restricted to moist stands 

on northerly aspects. Because the Snow Basin project area is predominately south-facing, presence and 

development of larger core habitat areas for marten is more likely to occur above 5,000 feet where stands 

of more neutral aspects are more moist. Review of existing conditions shows that suitable marten habitat 

in the Snow Basin project area is relatively sparse, with source and secondary habitats totaling only 233 

and 799 acres, respectively (Table 67).

Using parameters identified by Penninger and Keown (2011a), approximately 12,011 acres of source 

habitat and 4,735 acres of secondary habitat modeled and adjusted after field review in the Snow Basin 

project area, is estimated to occur within the Eagle Creek watershed (5th-level HUC). The majority of 

source and secondary habitat (96 percent) within the Eagle Creek watershed occurs north and west of the 

Snow Basin project area (Figure 10). The Snow Basin project area represents the southern periphery of 

marten habitat in the Eagle Creek watershed. 

Table 67. Marten habitats amounts in Snow Basin project area and Eagle Creek Watershed

Habitat Type Snow Basin Project Area Eagle Creek 5th-HUC

Source 233 acres 12,304 acres

Secondary 799 acres 4,735 acres
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Figure 10. American marten habitats, Snow Basin project area and Eagle Creek HUC

Review of other publications and habitat modeling

Analysis of wildlife habitat connectivity was conducted by the Washington Wildlife Habitat Connectivity 

Working Group (WHCWG 2011). The analysis is described as broadscale, encompassing Washington 

State and adjacent lands in Oregon, Idaho, and British Columbia, and uses relatively coarse-scale data for 

a first-step in identifying regionally important connectivity areas. The analysis described landscape-level 

connectivity for a number of wildlife species, including American marten. Modeled wildlife habitat 

outputs consisting of marten Habitat Concentration Areas (HCAs) outputs were viewed in ArcGIS in 

relation to the Snow Basin landscape. In addition, landscape parameters used to generate marten source 

habitats were also reviewed.

In general, marten source habitats are described in the connectivity analysis as consisting of forested 

stands in Cold-Moist and Cold-Dry associations dominated by subalpine and upper montane conifer 

species, with stand diameters greater than 15 inches and canopy closure in excess of 50 percent. Sources 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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for land cover/use consisted of NW GAP data with forest regeneration areas denoted with GAP or 

LANDFIRE modifiers. Forest structure data was derived from LANDFIRE existing vegetation cover and 

height layers. 

Spatial incorporation of the HCA into GIS showed substantial overlap with the Snow Basin project area, 

including portions extending south of the established distribution of Cold-Moist and Cold-Dry forest. 

Further examination of the HCA layer and data components indicated that spatial display of forest canopy 

closure and stand size was fairly accurate, but the land use cover values selected to display forest 

environments suitable for marten may have included “dry-mesic” conifer stands, which represents a broad 

vegetation association that appears to over-estimate the distribution of suitable habitat when viewed at the 

finer scale. Therefore, the HCA data was not incorporated into the Snow Basin analysis for marten 

habitat.

Other local studies

Marten habitat in the Snow Basin project area differs from the Starkey study area where Bull and Heater, 

and Bull et al. (2000, 2001, 2005) conducted telemetry, diet, and habitat studies in the 1990s. Bull et al. 

(2005) described their study area as, “... continuous forest covering 90 percent of the Watershed [La 

Grande Municipal Watershed] with wet meadows adjacent to the drainages.” Forest types in the La 

Grande Municipal Watershed portion of Bull’s study area were comprised of 55 percent lodgepole pine, 

19 percent subalpine fir, 16 percent grand fir, and 10 percent Douglas-fir. The portion of the study area 

that extended outside of the Watershed was comprised predominately of grand fir (cool/moist) and 

subalpine fir, and 80 percent of that area had some level of timber harvest.

This contrasts sharply with the ponderosa pine, Douglas-fir, and warm/dry grand fir forest types that 

occur on 88 percent of the Snow Basin project area. These differences in forest types translate to 

differences in the prey complex found in these two areas. 

Bull (2000) documented differences in diet for season and gender in martens in the Starkey study area.

When seasons and genders were combined, vole-sized prey (voles and mice) were present in 62.7 percent

of sampled marten scats, squirrel-sized prey were present in 28.2 percent, 22.4 percent insects, 19.5

percent birds, and 13.3 percent plant material.

Insects found in marten scats were yellowjackets and bald-faced hornets, both species considered 

common and widespread in both the Starkey study area and Snow Basin project area. 

At least 13 species of birds appeared in marten scats, with ruffed grouse occurring more than other 

species. Most bird species were represented by a single occurrence (Bull 2000). Because birds are highly 

mobile and exhibit a higher species richness than mammalian prey, the following discussion focuses on 

mammalian prey.

The following potential mammalian prey species occur in both Bull’s Starkey study area and the Snow 

Basin project area: Columbia ground squirrel; mantled ground squirrel; red tree squirrel; deer mouse; 

bushy-tailed woodrat; long-tailed vole; and western jumping mouse. These small mammals are habitat 

generalists and will inhabit a broad range of habitat conditions. Some potential prey species that may 

occur in the Starkey study area, but are absent or at very low abundance in Snow Basin include: water 

vole; northern flying squirrel; and snowshoe hare. Conversely, the following potential prey species are 

likely to occur in Snow Basin, but are absent or at very low abundance in the Starkey study area: 

mountain cottontail rabbit; great basin pocket mouse; and mountain vole. Although these species are of 

comparable size to marten prey documented by Bull, their habitat requirements overlap little with those of 

marten in the Snow Basin area.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Direct and indirect effects

Alternative 1

There will be no direct or indirect adverse effects to American marten from the alternative 1 because no 

timber harvest, fuels treatments, or transportation activities will occur. Existing marten source and 

secondary habitat would remain unchanged.

Alternatives 2, 3 and 4

In general, vegetation treatments have the potential to affect marten habitat suitability by reducing stand 

canopy closures and understory tree densities. Because of the relatively small amount of source and 

secondary habitats available within the project area, modifications in the original silviculture prescriptions 

were developed to maintain marten habitat within proposed treatment units while also reducing the risk of 

stand-replacement fire. These modified prescriptions would apply to marten habitat in Alternatives 3 and 

4, but not 2. Modifications are described in detail within the Snow Basin Silviculture Report. In summary, 

all trees within 20 feet of decadent grand fir would be retained. In addition, areas of pure grand fir would 

be retained as untreated patches within the treatment units. Grand fir within 30 feet of ponderosa pine and 

western larch would be removed. The resulting stands would contain forest structure consisting of dense 

patches interspersed with open gaps. Gaps created by treatments would vary in size depending on the 

existing amount and juxtaposition of grand fir, ponderosa pine, and western larch, but overall canopy 

closures would remain above 50 percent. Due to the likelihood of open gaps within residual stands under 

all alternatives, as well as potential removal of some larger grand fir under Alternatives 2 and 3, 

treatments are expected to reduce the quality of source habitat under all alternatives, with the greatest 

reduction under alternative 2, followed by 3 and 4 respectively. The modified treatment prescription is 

expected to maintain existing secondary habitat. Alternative 4 would retain slightly higher quality 

secondary and source habitat for marten since all trees greater than 21 inch DBH would be retained. 

Vegetation treatments proposed under Alternatives 2 and 3 would treat about 39 acres (17 percent of 

existing) of source habitat (Table 9). Source habitat treated under alternative 3 would continue to meet the 

definition of source habitat, however, the structural complexity of these stands will be more simplified, 

thus providing lower quality habitat. Alternative 2 would convert 39 acres of source habitat to secondary 

habitat for marten. Alternatives 2 and 3 would treat 50 percent (403 and 398 acres respectively) of 

secondary habitat. Following treatment, this habitat will retain the characteristics of secondary habitat, but

with less structural complexity. Alternative 4 would treat 27 acres of source habitat, but treatments are 

expected to retain a higher quality of source habitat due to retention of larger trees and the use of the 

modified prescription for marten habitat. Alternative 4 would also treat 234 acres (29 percent of existing) 

of secondary habitat within the project area. Impacts to marten source habitats are expected to last 

approximately two decades as canopy closure recovers and tree diameters increase during that period.

Application of prescribed fire outside of stands proposed for timber harvest has the potential to reduce 

understory and down wood densities, but is unlikely to substantially reduce stand canopy closures.

Therefore, prescribed fire-only treatments are expected to degrade, but not remove, marten habitat. 

Prescribed fire is proposed in 12 acres of source habitat and 39 to 40 acres of secondary habitat under all 

alternatives.

Table 68. Proposed vegetation treatments in modeled marten habitats

Habitat Type (Existing 

acres) on WWNF 

lands

Treatment Type by Alternative, Acres (Percent of 

Corresponding Habitat Type), Snow Basin Project Area

Alt 2 Alt 3 Alt 4

Silv. Rx Fire 

Only Silv. Rx Fire Only Silv. Rx Fire Only

Source 39 12 39 12 27 12 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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(233 acres) (17%) (<1%) (17%) (<1%) (12%) (<1%)

Secondary

(799 acres)

403

(50%)

39

(5%)

398

(5%)

39

(5%)

234

(29%)

40

(5%)

Source and 

Secondary Combined

(1,032 acres)

442

(43%)

51 (5%) 437

(42%) 51 (5%) 261

(25%) 52 (5%)

Where treatments are proposed within currently suitable marten habitat, removal of mistletoe-infected 

trees would degrade habitat suitability by reducing available resting structure for marten and potential 

prey species that use these structures. In some areas, removal may also limit recruitment of future down 

logs. This effect would be most pronounced for Alternatives 2 and 3. Retention of mistletoe-infected trees 

21 inches DBH or greater under alternative 4 would allow some treatment units to retain a level of resting 

structure likely to be more beneficial to marten and prey. 

Danger tree removal along haul routes totaling about 11 miles in source and secondary habitats would 

potentially remove snags and decadent trees in proximity to roads where densities are already low due to

firewood gathering. New construction of less than 0.1 mile of temporary roads may remove less than 0.25 

acre of secondary habitat under Alternatives 2 and 3. Activities that increase overall human presence and 

project-related noise levels, including system road reconstruction as well as timber harvest, may 

temporarily displace marten locally in the short-term (i.e. during implementation), but are not expected to 

impact marten distribution or productivity within the project area in the long-term.

Marten habitat at the watershed level

Source and secondary habitat parameters described by Penninger and Keown (2011a) were modeled for 

WWNF lands within the Eagle Creek watershed. Treatments under Alternative 2 would degrade about 0.4 

percent of source habitat available in the watershed. Source habitat impacts under Alternatives 3 and 4 are 

similar at 0.3 percent (Table 69).

Post-treatment availability of source habitats would continue to exceed the threshold of 40 percent of the 

historical amount in the Eagle Creek watershed under all action alternatives, thereby continuing to 

contribute to species viability at the watershed scale. In addition, post-treatment amounts of source habitat 

as a percentage of potential habitat would remain at 32 percent, well above the historic median of 16 

percent described by Penninger and Keown (2011a). 

Table 69. Marten source habitat amounts untreated, Eagle Creek Watershed.

Marten Source 

Habitat

Source Habitat Acreage Untreated by Alternative (% of 

Existing)

Existing 

Condition Alt. 2 Alt. 3 Alt. 4

12,304 12,265

(99.7%)

12,265

(99.7%)

12,277

(99.8%)

Marten habitat at the WWNF scale

Estimated habitat impacts at the project area and watershed scales (described above) are based on source 

habitat parameters modeled according to Penninger and Keown (i.e. 50 percent canopy closure and 15 

inch DBH criteria). Existing marten source habitat on the WWNF as modeled by Wales (2011a) totals 

129,943 acres. As a result of proposed activities under the Snow Basin project, source habitats would be 

degraded on 39 acres under Alternatives 2 and 3, and 27 acres under alternative 4. Because source and 

secondary habitats at the Forest level were modeled according to more conservative thresholds described 

by Wales (i.e. 60 percent canopy closure and 20 inch DBH criteria), it is reasonable to assume that the 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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source habitat impacts would actually be less than the estimate based on the 50 percent canopy closure 

and 15 inch DBH criteria. Therefore, source habitat impacts at the Forest level would equate to less than 

0.003 percent under Alternatives 2 and 3 and less than 0.002 percent for alternative 4.

Cluster analysis used to describe existing distribution of source habitats across the WWNF indicates that 

these habitats are well distributed across the Forest (Penninger and Keown 2011a). Post-treatment levels 

of source habitat under all Snow Basin action alternatives are expected to result in no change in the 

number of watersheds containing >40 percent source habitat that contribute to marten habitat distribution 

and viability.

Landscape permeability

Refer to the “Connectivity of LOS Habitat” section, beginning on page 51 of the Wildlife Specialist’s 

Report. 

Cumulative effects

Cumulative effects for marten are analyzed for the Eagle Creek watershed. Past, present and reasonably 

foreseeable future actions were analyzed for cumulative impacts to the species. Effects of past activities 

including road construction, fire suppression, prescribed fire, and timber management on WWNF lands 

have been incorporated into the existing conditions for amounts and locations of marten habitats in the 

analysis areas. Review of the FACTS database for the WWNF indicate that activities that may impact 

marten habitat within the Eagle Creek watershed outside the project area within the past three years 

consist of approximately 158 acres of underburning and 749 acres of pre-commercial thinning under 

various projects, In addition, about 683 acres of commercial timber harvest has occurred under the 

Skookum Timber sale within the Eagle Creek watershed. An additional 97 acres is expected to be 

harvested in 2012. Although some commercial treatments may occur within marten suitable habitat, the 

scale of potential impacts is not substantial in comparison to source habitats currently estimated to exceed 

12,000 acres.

Appendix B was reviewed for actions that might affect marten habitat within the Eagle Creek watershed.

Cumulative impacts of ongoing and foreseeable actions are projected out to 20 years from the present.

Ongoing and future livestock grazing is expected to have no effect on marten habitat because cattle tend 

to avoid areas with high amounts of down wood. On Forest Service lands within and outside the project 

area, firewood cutting will continue to reduce available snags and logs, but the effect is limited to areas 

adjacent to open roads. The upcoming Wallowa-Whitman National Forest Travel Management Plan 

(TMP) will limit motor-vehicle use to designated roads and trails. It will also prohibit cross country 

travel. Implementation of the TMP is expected to begin in the summer of 2012. With the implementation 

of the TMP, some roads that are open now will be closed by promulgation (approximately 18 miles in the 

Snow Basin area). Some roads within the project area currently identified as closed (maintenance level 1), 

will be opened for motorized travel by full size vehicles and/or OHVs (approximately 6 miles in Snow 

Basin). This will result in a net reduction of open roads within the project area, which will provide 

additional habitat that is free from disturbance from motor vehicles. Timber harvest on private in-holdings 

is expected to continue at some level, with anticipated reductions of trees larger than 10 inches DBH, but 

generally marten habitat does not occur on private in-holdings in the Snow Basin project area.

Conclusion

Because this project impacts less than 0.003 percent of suitable habitat across the Forest, the overall 

direct, indirect and cumulative effects will result in a small negative effect to marten habitat. The decrease 

in habitat quality will be insignificant at the scale of the WWNF. The Snow Basin project may reduce 

habitat permeability at a localized scale, but impacts at the WWNF scale would be immeasurable. Posttreatment availability of source habitats would continue to exceed the threshold of 40 percent of the 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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historical amount in the Eagle Creek watershed under all action Alternatives, thereby continuing to 

contribute to habitat distribution and species viability on the WWNF.

Northern Goshawk

The goshawk is a MIS with nesting requirements associated with old-growth habitat, but will use a 

variety of forest structure types for other life history needs. It is an indicator of the abundance and 

distribution of mature and old-growth forests.

Life history, risk factors, conservation status and population trend, as well as habitat condition and species 

viability are described in detail in the Northern Goshawk (Accipiter gentilis) Management Indicator 

Species Assessment, Wallowa-Whitman National Forest (Penninger and Keown 2011c).

Nest areas and post-fledging area (PFA)

Direction in the Regional Forester’s Forest Plan Amendment #2 requires that a nest area of at least 30 

acres be delineated around active goshawk nests. Timber harvest shall be deferred in these nest areas for 

as long as the nest is active. An active nest is defined as one that has shown evidence of use within the 

past five years. Potentially disruptive activities around the nest area should also be deferred until after the 

nesting season.

The PFA surrounds the nest area and is defined as the area used by the family group from the time the 

young fledge until they are no longer dependent on the adults for food (up to two months) (Reynolds et al. 

1992, Kennedy et al. 1994). PFAs typically include a variety of forest types and conditions. Reynolds et 

al. (1992) called for maintaining the PFA in forest conditions intermediate between the high foliage 

volume and canopy cover of the nest stands and the more open foraging habitats. PFAs have patches of 

dense trees, developed herbaceous and/or shrubby understories and habitat attributes (snags, down logs, 

small openings) that are critical for goshawk prey (Reynolds et al. 1992). Although PFAs generally 

include a variety of forest conditions, the vegetation structure resembles that found within nest stands 

(Reynolds et al. 1992).

Analysis of source habitat on the WWNF

Wales (2011c) analyzed source habitat of numerous wildlife species of interest in the Blue Mountains and 

WWNF in support of the Blue Mountains Forest Plan Revision.

Source habitats are defined by Wales as those stands that provide for a stable or increasing population and 

for all the life history needs of the goshawk including nesting, roosting, foraging, resting, travel, and 

dispersal. Potential habitat is defined as stands within dry Douglas-fir, dry grand fir, cool moist and cold 

dry potential vegetation groups that have the capability to provide source habitat but that currently do not 

provide the tree size, canopy cover, or structural conditions. Given time and lack of human intervention or 

disturbance these areas may provide source habitat.

Wales (2011c) estimated that approximately 466,679 acres of source habitat existing on the WWNF 

historically. Currently, approximately 440,696 acres (94 percent of estimated historical conditions) of 

source habitat occurs on the WWNF.

Quality and effectiveness of late successional habitat

Because of the importance of late-successional forest in the life history of the goshawk, the abundance of 

late-successional forest was used as a variable to assess the quality of goshawk source habitat. The 

definition of late-successional forest was very similar to the source habitat definition with the exception 

of tree size. To be considered late-successional forest, tree size needed to be greater than 20 inches DBH

rather than 15 inches DBH used to identify source habitat. Results showed that 51 percent of watersheds 

on the WWNF ranked “moderate” in habitat quality with >20 to 50 percent source habitat in late-
Chapter 3 Snow Basin Vegetation Management Project FEIS

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successional forest and 39 percent of watersheds ranked “high” with greater than 50 percent of source 

habitat in late-successional forest.

As a measure of habitat effectiveness, late successional goshawk habitat was assessed in proximity to 

open roads (within 200 meters) and non-motorized trails (within 100 meters) where goshawk nesting

could be influenced by human activity. Historically, the habitat effectiveness category was believed to be 

high due to the lack of roads and trails, and associated human disturbances. Currently, as a result of road 

and trail development, and human disturbance, habitat effectiveness is reduced. The majority (67 percent) 

of watersheds on the WWNF are in the low habitat effectiveness class, indicating that a high proportion of 

source habitat is within 200 meters of a motorized road or trail or 100 meters of a non-motorized trail.

Goshawk viability on the WWNF

The viability outcome scores described in the Goshawk MIS Assessment (Penninger and Keown 2010) 

indicate that suitable environments of the goshawk are broadly distributed and of high abundance and that 

the goshawk is likely well distributed throughout the WWNF. In conclusion, the viability assessment 

indicates that source habitat of the goshawk is still available in adequate amounts, distribution, and 

quality to maintain goshawk viability in the Blue Mountains and on the WWNF. (Penninger and Keown 

2011c). Source habitat at the watershed scale is described in detail beginning on page 74 of the Wildlife 

Specialist’s Report. In summary, the source habitat assessment found that nearly all (86 percent) of the 

watersheds on the WWNF had watershed index scores that were high. High watershed index values are 

indicative of low departure from the historical median amount of source habitat and relatively high 

amounts of source habitat that are also late successional. While there are generally high watershed index 

values, habitat effectiveness is still lower than historical habitat effectiveness due to the presence of roads 

and trails. The watershed index for the Eagle Creek watershed is ranked “high.”

Surveys within the Snow Basin project area

Surveys to determine presence of goshawks were conducted within portions of the Snow Basin project 

area during the summer of 2011. The species was detected in 3 locations, including one probable nest site 

located in the northeastern portion of the project area.

Habitat condition within the Snow Basin project area

Habitat characteristics and methodology selected for this analysis are described in the Northern Goshawk 

(Accipiter gentilis) Management Indicator Species Assessment, Wallowa-Whitman National Forest 

(Penninger and Keown 2011c), hereby incorporated by reference.

Goshawk habitats modeled by Penninger and Keown (2011c) include source and potential habitats.

Source habitats are defined as those stands that provide for a stable or increasing population and for all 

the life history needs of the goshawk including nesting, roosting, foraging, resting, travel, and dispersal.

Potential habitat is defined as stands within dry Dry Ponderosa Pine, Douglas-fir, Dry Grand Fir, Cool 

Moist and Cold Dry PVGs that have the capability to provide source habitat but that currently do not 

provide the tree size, canopy cover, or structural conditions. Given time and lack of human intervention or 

disturbance these areas may provide source habitat. Specifics regarding vegetative and structural criteria 

used to define source and potential habitat can be found beginning on page 76 of the Wildlife Specialist’s 

Report. 

Table 70. Existing goshawk source and potential habitats

Habitat Type Snow Basin Project Area Eagle Creek 5th HUC

Source 7,384 acres 27,058 acres

Potential 15,789 acres 40,323 acres
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Figure 11. Northern goshawk modeled source habitat

Direct and indirect effects

Alternative 1 

There will be no direct adverse effects to goshawks from the No Action alternative because no timber 

harvest, fuels treatments, or transportation activities will occur. Existing source habitat would remain 

unchanged. However, the no-action alternative maintains potentially unsustainable conditions in late-seral 

stage montane forests where there have been large transitions from shade-intolerant to shade-tolerant tree 

species. This has occurred in warm, dry ponderosa pine and Douglas-fir forest types that have missed one 

or more fire returns.

Alternatives 2, 3, and 4

Both timber harvest and prescribed fire treatments within and outside timber harvest units would occur in 

northern goshawk source habitat under all action alternatives. Intermediate (INT) harvest treatments are 

expected to increase average stand diameter due to removal of trees primarily in smaller size classes, but 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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across all size classes for Alternatives 2 and 3. Alternative 4 would retain the highest post-treatment stand 

diameters due to retention of trees 21 inches DBH and greater. Due to the minimal reduction in snag 

habitat for logging safety and potential consumption of down logs and snags during post-treatment 

burning and in prescribed fire-only units, treatments that retain sufficient canopy closures are still 

expected to degrade, but not remove, source habitat. Although some habitat elements may be reduced 

where habitat is degraded, sustainability of habitats is expected to increase as stand density reductions 

lower the risk of disturbance such as stand-replacement fire, especially in Dry Forest types. Table 71

shows acres and percent of source habitat proposed for treatment under each alternative.

Treatments proposed under Alternatives 2 and 3 would impact the greatest amount of goshawk source 

habitat. Harvest activities would occur within 3,412 acres of source habitat in alternative 2 and 3,325 

acres in alternative 3. These harvest activities may alter 49 to 50 percent of goshawk source habitat within 

the Snow Basin project area for approximately 20 years until canopy closure recovers and snags and logs 

begin to be recruited. Although the treated acres may no longer meet the definition of source habitat, they 

would still be available for goshawk foraging, roosting, and travel between other habitat patches.

Alternative 4 proposes harvest activities within 2,763 acres of source habitat in the project area, which is 

41 percent of total goshawk source habitat in the project area. Prescribed fire would occur within 1,020 

acres of source habitat in alternative 2, 679 acres in alternative 3, and 852 acres in alternative 4.

Prescribed fire will reduce structural complexity in the understory in 10 to 15 percent of goshawk source 

habitat in the project area, but it will still meet the requirements for source habitat.

Table 71. Summary of proposed treatments in goshawk source habitat

Alternatives

Alt 1

(Existing)

Alt 2 Alt 3 Alt 4

Harvest Rx Fire Harvest Rx Fire Harvest Rx fire

Acres

6,791 3412.0 1,020 3325 2,679 2,763 852

% of 

source 

habitat 

in 

project 

area

100% 50% 15% 49% 10% 41% 13%

Broom structures created by dwarf mistletoe have been identified as potential nesting substrate for 

goshawks. Moore and Henney (1983) reported that approximately 15 percent of goshawk nests studied in 

northeastern Oregon were located on mistletoe-created platforms. All action alternatives propose some 

level of mistletoe reduction in Douglas-fir and ponderosa pine. Where treatments are proposed within 

currently suitable goshawk nesting habitat, removal of mistletoe-infected trees would degrade habitat 

suitability by reducing available nesting platform structure. This effect would be most pronounced for 

Alternatives 2 and 3. Retention of mistletoe-infected trees 21 inches DBH and greater under alternative 4 

would allow some treatment units to retain mistletoe platforms in the largest trees, which are most likely 

to support goshawk nesting. However, most goshawk nests usually occur within close proximity to water, 

so the majority of potential nesting structures will be retained under all alternatives because RHCAs will 

retain all existing mistletoe brooms.

Aspen restoration on scattered individual sites would remove conifers on a total of 38 acres, a portion of 

which may occur in suitable goshawk habitat. The majorities of aspen sites are 1 acre or less and are 

identified in Appendix A and on project maps. Danger tree removal along haul routes totaling up to about 

159 miles in source habitats would potentially remove snags in next to roads where densities are already 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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low due to firewood gathering. Construction of up to about 5 miles of temporary roads (Alternatives 2

and 3) may remove an estimated 12 acres of source habitat, and alternative 4 involves no temporary 

roads. Activities that increase overall human presence and project-related noise levels, including system 

road reconstruction as well as timber harvest, may temporarily displace Goshawks locally in the shortterm (i.e. during implementation), but are not expected to impact distribution within the project area in the 

long-term.

In addition to impacts to available habitats, each action alternative poses potential for direct impact to 

nesting individuals. Both timber harvest and prescribed fire could cause individual harm or mortality if 

operations destroy a nest tree occupied by young of the year. If Goshawk nesting is discovered prior to, or 

during implementation, a no-activity nest area of at least 30 acres will be designated for active nests.

Because Goshawks were detected at several locations during 2011 surveys, and because the existing nest 

site was not confirmed with 100 percent certainty, additional goshawk surveys in these locations would 

occur prior to implementation of proposed vegetation and prescribed fire treatments (Appendix B-1).

Goshawk nest stand and PFA

Goshawk surveys conducted in 2011 discovered a potential goshawk nest along Little Eagle Creek in the 

northern portion of the project area. Because the nest was empty when found, with an adult goshawk 

nearby, nesting could not be confirmed. However, nesting at the site at some point within the last year or 

two is probable. Therefore, the nest stand (30 acres) and PFA (411 acres) were delineated as part of this 

analysis. Per direction under the Regional Forester’s Forest Plan Amendment #2, no harvest or disturbing 

activities will take place within the nest stand. Analysis of vegetation conditions within the PFA indicate 

that 240 acres (58 percent) consist of multi-storied LOS. Direction states that, while harvest can occur 

within the PFA, retain LOS stands and enhance younger stands towards LOS condition, as possible.

Harvest prescriptions under all action alternatives would not result in a net reduction of LOS, although 

some multi-storied stands would be restored to single-storied structure on warm, dry sites. Units 124 and 

125 were within the PFA, but were deferred from harvest for all action alternatives to retain goshawk 

habitat. 

Residual canopy closures within treatment units in the PFA are expected to equal or exceed 50 percent

under all action alternatives (Table 72). About 63 percent of LOS would retain canopy closures equal to 

or greater than 60 percent under Alternative 2. Alternative 3 retains a slightly higher average canopy 

closure with stands equal to or exceeding 60 percent canopy closure totaling approximately 67 percent of 

LOS acres. Alternative 4 would retain the highest canopy closure with all LOS acres exceeding 70

percent canopy closure. Reynolds et al. (1992) recommended that PFAs be managed to maintain an 

average of 40 percent of acres in mature and old forest condition. Within those mature and old stands, 

they also recommended that canopy closures equal or exceed 50 percent for ponderosa pine types, 60

percent for mixed conifer types, and 70 percent for spruce-fir types. Alternatives 2 and 3 provide a range 

of canopy closures, with Alternative 3 containing 80 acres at slightly below 50 percent. Both of these 

alternatives are expected to maintain suitable post-fledging conditions within the PFA with a 

corresponding reduction in potential for stand-replacement fire due to stand density reductions.

Alternative 4 would retain all trees greater than 21 inches DBH, thereby maximizing future nesting 

opportunities within the PFA outside the existing nest stand.

Table 72. Residual LOS canopy closures within goshawk PFA

Residual Structure

and Canopy Closure 

Classes, all PFA LOS 

acres (% of LOS)

Alt 2 acres (% of LOS) Alt 3 acres (% of LOS) Alt 4 acres (% of LOS)

MSLT ≥70% 55 (23%) 64 (27%) 65 (27%)

SSLT = 49% 0 80 (33%) 0
Chapter 3 Snow Basin Vegetation Management Project FEIS

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SSLT = 50% 89 (37%) 0 0

SSLT = 60% 96 (40%) 96 (40%) 0

SSLT ≥70% 0 0 175 (73%)

Goshawk habitat at the watershed level

Watershed indices reported by Wales (2011c) and further assessed by Penninger and Keown (2011c) for 

the existing condition showed that the Eagle Creek watershed currently contains a high amount of source 

habitat. Treatments proposed under Alternative 2 would reduce the amount of source habitat available in 

the watershed by approximately 12.6 percent (Table 73). Source habitat would be reduced by 12.3 percent

under Alternative 3. Alternative 4 would cause the least amount of source habitat reduction (10.2

percent). Post-treatment availability of source habitats would continue to exceed the threshold of 40

percent of the historical amount in the Eagle Creek watershed under all action alternatives, thereby 

continuing to contribute to species viability at the watershed scale.

Table 73. Goshawk source habitats by alternative in Eagle Creek Watershed

Habitat Type Existing and Post-Treatment Habitat Acreage Amounts by 

Alternative (% of Existing), Eagle Creek Watershed

Existing 

Condition Alt. 2 Alt. 3 Alt. 4

Source 27,058 23,646 

(87.4%)

23,734 

(87.7%)

24,295 

(89.8%)

Goshawk habitat at the WWNF Scale

Existing goshawk source habitat on the WWNF as modeled by Wales (2011c) totals 440,696 acres. The 

Snow Basin project would result in less than a 1percent reduction in source habitat under any of the 

alternatives.

Cumulative effects

Cumulative effects for goshawk are analyzed for the Eagle Creek watershed. Past, present and reasonably 

foreseeable future actions were analyzed for cumulative impacts to the species. Effects of past activities 

including road construction, fire suppression, prescribed fire, and timber management on WWNF lands 

have been incorporated into the existing conditions for amounts and locations of marten habitats in the 

analysis areas. Review of the FACTS database for the WWNF indicate that activities that may impact 

goshawk habitat within the Eagle Creek watershed outside the project area within the past three years 

consist of approximately 158 acres of underburning and 749 acres of pre-commercial thinning under 

various projects, and 18 acres of commercial thinning under the Skookum Timber Sale. An additional 

several hundred acres of commercial treatment is expected under the Skookum Timber sale, a portion of 

which would occur within the Eagle Creek watershed. Although some commercial treatments may occur 

within goshawk suitable habitat, the scale of potential impacts is not substantial in comparison to source 

habitats currently estimated to exceed 27,000 acres.

Appendix B was reviewed for actions that might affect goshawk habitat within the Eagle Creek 

watershed. Cumulative impacts of ongoing and foreseeable actions are projected out to 20 years from the 

present. Ongoing and future livestock grazing is expected to have a minimal effect on suitable habitats.

Additional grazing may occur in treated stands within the project area, but is not expected to alter suitable 

characteristics. Firewood gathering will continue to reduce available snags and logs, but the effect is 

limited to areas adjacent to open roads. Access within the watershed and across the WWNF will change 

when the Forest Travel Management Plan is implemented in the summer of 2012. Timber harvest on 

private inholdings is expected to continue at some level, with anticipated reductions of trees larger than 
Chapter 3 Snow Basin Vegetation Management Project FEIS

232

10 inches DBH. Lands to the south of the project area will continue to consist of open grassland habitats 

in private ownership.

Conclusion

Because this project impacts less than 1 percent of source habitat across the Forest, the overall direct, 

indirect and cumulative effects will result in a small negative effect to goshawk habitat. The loss of 

habitat will be immeasurable at the scale of the WWNF. Post-treatment availability of source habitats 

would continue to exceed the threshold of 40 percent of the historical amount in the Eagle Creek 

watershed under all action alternatives, thereby continuing to contribute to habitat distribution and species 

viability on the WWNF.

Pileated Woodpecker

The pileated woodpecker is a MIS associated with old-growth habitat, and represents species dependent 

on large diameter snags and logs in older-aged forests. It prefers dense, multi-story old growth habitats 

with high snag densities, but can be found in a broad range for mature forest conditions. It will use both 

coniferous and deciduous trees, but tends to be most common in old-growth ponderosa pine-mixed 

conifer forests in eastern Oregon (Csuti et al. 2001). Large snags are used for nesting, roosting, and 

foraging; logs are used for foraging. Ponderosa pines are highly preferred for nesting because of the rapid 

decay in the thick layer of sapwood; sapwood of other tree species in not sufficiently thick to nest in 

(Parks et al. 1997). Nesting occurs in live and dead trees that are at least 2 to 3 feet in diameter. Carpenter 

ants, which are found in decaying wood, are its main food item, but it also eats the larvae of wood-boring 

beetles, termites, berries, and acorns. More vegetable matter is consumed during the winter.

Roost trees are an important habitat feature for pileated woodpeckers. Local studies found the majority of 

roost trees were in grand fir (62 percent), both live and dead, were extensively decayed by Indian paint 

fungus and had a hollow interior. Conks of Indian paint fungus were seen on 92 percent of the roost trees 

in grand fir (Bull et al., 1992). Pileateds use multiple roost trees year round.

Potential short-term (less than 10 years) impacts of timber harvest and fuels treatments on pileated 

woodpecker foraging were investigated in northeastern Oregon and discussed by Bull et al. (2005).

Results showed post-treatment reductions in available logs and snags. Foraging within the mechanical 

treatment-only stands was less than in control stands, but both the control stands and those mechanically 

treated retained significantly more foraging habitat than stands mechanically treated and burned.

Consumption by prescribed fire did generate new snags otherwise unavailable in the control and 

mechanically treated stands, but variable conditions also led to fire consumption of known nest trees in 

one stand, despite retention efforts that included pulling fuels away from trees prior to burning.

Life history, risk factors, conservation status and population trend, as well as habitat condition and species 

viability are described in detail in the Pileated Woodpecker (Dryocupus pileated) Management Indicator 

Species Assessment, Wallowa-Whitman National Forest (Penninger and Keown 2011b). Portions of that 

assessment are summarized below to describe existing condition for the species.

Broad scale habitat analysis

Habitat trends of the pileated woodpecker were assessed at the Interior Columbia Basin, Blue Mountains 

ecological reporting unit (ERU), and WWNF scales using information provided by Source Habitats for 

Terrestrial Vertebrates of Focus in the Interior Columbia Basin (Wisdom et al. 2000) and the species 

viability assessment conducted by Wales (2011b) in support of the Blue Mountains Forest Plan revision.

In comparing existing amounts of source habitat to historical amounts, Wisdom et al. (2000) reported that, 

with the exception of the western larch cover type, all cover types in the Blue Mountains ERU that 

constitute pileated woodpecker source habitat have strongly increased. This is in contrast to the Basin 
Chapter 3 Snow Basin Vegetation Management Project FEIS

233

(private and public lands in the interior Columbia Basin) which has experienced a decrease in the 

percentage of area providing source habitat. Although Wisdom et al. (2000) documents a strong decrease 

in source habitat in the western larch cover type, this apparent decrease is not likely significant in regard 

to the abundance and distribution of source habitat for pileated woodpeckers in the Blue Mountains.

Stands dominated by western larch are not rare, but they represent a minor proportion of the forested 

landscapes in the Blue Mountains (Penninger and Keown 2011b).

Wales (2011b) analyzed source habitat of numerous wildlife species of interest in the Blue Mountains and 

WWNF in support of the Blue Mountains Forest Plan Revision. The analysis was conducted at the standscale, a much finer scale than the source habitat analysis conducted by Wisdom et al. (2000).

Historically (considering the HRV), it is estimated that at any one point in time there were approximately 

359,608 acres on the WWNF that provided source habitat for pileateds. Currently, there are 

approximately 206,374 acres (57 percent of historical conditions) that meet the source habitat definition.

Forty of the 49 watersheds (82 percent) analyzed for the pileated woodpecker on the WWNF have less 

source habitat than the estimated historical condition. The source habitat analysis determined that the 

abundance of closed-canopied forest with >20 inch DBH trees in the dry Douglas-fir, dry grand fir, cool 

moist, and cold dry forest types on the WWNF has declined from historical conditions. This is similar to 

the Basin-wide findings from the source habitat analysis conducted by Wisdom et al. (2000) but in 

contrast to the findings in the Blue Mountains ERU where the abundance of source habitat was strongly 

increasing.

Viability at the forest scale

A species viability assessment was conducted for the pileated woodpecker in the Blue Mountain region of 

northeast Oregon and Washington, as well as for the WWNF following Regional guidance (2010). A 

viability outcome model was utilized to assess species viability. The model provides a large-scale index 

of the capability of the environment to support population abundance and distribution. Results show a 66

percent probability that suitable environments are distributed frequently as patches and/or exist at low 

abundance. For comparison, historically, it was 70 percent probable that habitat was broadly distributed 

and of high abundance. However, the viability assessment indicates the WWNF still provides for viability 

of the pileated woodpecker. In addition, the species is distributed across the WWNF and there are 

adequate amounts, quality, and distribution of habitat to provide for pileated woodpecker population 

viability (Penninger and Keown 2011b).

Conditions at the watershed scale

Watershed index (WI) scores were incorporated in an analysis of habitat departure, snag density, and road 

density in order to assess pileated source habitat at the watershed scale. This process is discussed in detail 

in the Pileated Woodpecker MIS Assessment (Penninger and Keown 2010), and summarized in the 

Wildlife Specialist’s Report. The Eagle Creek watershed, which encompasses the Snow Basin project 

area, ranked high in both watershed index and weighted watershed index scores.

The Eagle Creek watershed currently exceeds the 40 percent threshold for source habitat when compared 

to what occurred there historically. Results indicate favorable pileated woodpecker source habitat 

conditions at the watershed scale, as well as distribution of habitats.

Current condition within the Snow Basin project area

Surveys to determine presence of pileated woodpeckers were conducted within portions of the Snow 

Basin project area during the summer of 2011. The species was detected in 4 locations, including one 

identified nest site located in the northwest corner of the project area.

Analysis of habitats modeled by Penninger and Keown (2011b) shows approximately 3,039 acres of 

source habitat within the Snow Basin project area and about 18,569 acres of source habitat within the 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Eagle Creek watershed (Table 74). Distribution of source habitats is patchy throughout the project area, 

with notable concentrations located north and west of Snow Basin in the Eagle Creek watershed (Figure 

12). Although source habitat appears “patchy,” the forest matrix between these patches is largely 

conducive to pileated movement, with varying levels of foraging and roosting habitat.

Table 74. Pileated woodpecker source and potential habitat amounts.

Habitat Type Snow Basin Project Area Eagle Creek 5th-HUC

Source 3,039 acres 18,569 acres

Potential 12,924 acres 39,496 acres

Figure 12. Pileated woodpecker modeled source habitat
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Direct and indirect effects

Alternative 1

There will be no direct adverse effects to pileated woodpeckers from alternative 1 because no timber 

harvest, fuels treatments, or transportation activities will occur. Existing source habitat for pileated 

woodpeckers would remain unchanged. The no-action alternative maintains potentially unsustainable 

conditions in warm, dry LOS forests where there have been large transitions from shade-intolerant to 

shade-tolerant species. In the near-term, these denser forests with greater structural complexity may be 

highly attractive to pileateds. However, large uncharacteristic wildfires could eventually render pileated 

habitat unsuitable.

Alternatives 2, 3, and 4

Both timber harvest and prescribed fire treatments within and outside timber harvest units would occur in 

pileated woodpecker source habitat under all action alternatives. Intermediate (INT) harvest treatments 

are expected to increase average stand diameter due to removal of trees primarily in smaller size classes, 

but across all size classes for Alternatives 2 and 3. Alternative 4 would retain the highest average posttreatment stand diameters due to retention of trees 21 inches DBH or greater. Treatments that retain 

canopy closures that meet the definition of source habitat would remain as source habitat. However, due 

to the possibility of minor snag reductions for logging safety, and potential consumption of down logs and 

snags during post-treatment burning and in prescribed fire units, treatments that retain sufficient canopy 

closures are still expected to degrade, but still function as source habitat. Although some habitat elements 

may be reduced where habitat is degraded, sustainability of habitats is expected to increase as stand 

density reductions lower the risk of disturbance such as stand-replacement fire, especially in warm, dry 

forest types. Table 75 shows acres and percent of source habitat proposed for treatment under each 

alternative.

Table75. Summary of proposed treatments in pileated source habitat

Alternatives

Alt 1

(Existing)

Alt 2 Alt 3 Alt 4

Harvest Rx Fire Harvest Rx Fire Harvest Rx fire

Acres

3,039 1,351 532 1,314 236 890 373

% of 

source 

habitat 

in 

project 

area

100 44.4 17.5 43.2 7.8 29.3 12.3

Treatments proposed under Alternatives 2 and 3 would impact the largest amount of pileated source 

habitat. Harvest activities would occur within 1,351 acres of source habitat in alternative 2 and 1,314 

acres in alternative 3. These harvest activities may alter 43 to 44 percent of pileated source habitat within 

the Snow Basin project area for approximately 20 years until canopy closure recovers and snags and logs 

begin to be recruited. Alternative 4 proposes harvest activities within 890 acres of source habitat in the 

project area, which is 29.3 percent of total pileated source habitat in the project area. Prescribed fire 

would occur within 532 acres of source habitat in alternative 2, 236 acres in alternative 3, and 373 acres 

in alternative 4. Prescribed fire will reduce structural complexity in the understory in 7 to 18 percent of 

pileated source habitat in the project area but it will still meet the requirements for source habitat.

Retention of all snags except for safety concerns minimizes the potential for direct impacts to nesting 

pileated woodpeckers. Under Alternatives 2 and 3, removal of trees 21 inches DBH or larger has the 
Chapter 3 Snow Basin Vegetation Management Project FEIS

236

potential to limit recruitment of future snags for nesting and down logs for foraging in some stands in the 

short-term (within 20 years). In the long-term, accelerated tree growth due to lower stocking densities is 

expected to develop large trees, and consequently large snags, at a faster rate than untreated areas. While 

long-term availability of total snag numbers may decrease, available snags will on average be larger in 

treatment units compared to untreated areas.

Aspen restoration on scattered individual sites would remove conifers on a total of 38 acres, a portion of 

which may occur in suitable pileated woodpecker habitat. The majorities of aspen sites are 1 acre or less 

and are identified in Appendix A and on project maps. Danger tree removal along haul routes totaling up 

to about 142 miles in source habitats would potentially remove snags close to roads where densities are 

already low due to firewood gathering. New construction of about 5 miles of temporary roads may 

remove an estimated 12 acres of source habitat under Alternatives 2 and 3. Activities that increase overall 

human presence and project-related noise levels, including system road reconstruction as well as timber 

harvest, may temporarily displace pileated woodpeckers locally in the short-term (i.e. during 

implementation), but are not expected to impact distribution or productivity within the project area in the 

long-term.

Pileated woodpecker habitat at the watershed level

Watershed indices reported by Wales (2011b) and further assessed by Penninger and Keown (2011b) for 

the existing condition showed that the Eagle Creek watershed contains a high amount of source habitat 

and a lesser amount of secondary habitat. Treatments proposed under Alternative 2 and 3 would reduce 

the amount of source habitat available in the watershed by 7.3 and 7.1 percent, respectively. Source 

habitat reduction under alternative 4 is 4.8 percent (Table 76).

Post-treatment availability of source habitats would continue to exceed threshold of 40 percent of the 

historical amount in the Eagle Creek watershed under all action alternatives, thereby continuing to 

contribute to species viability at the watershed scale.

Table 76. Existing and post-treatment source Habitat amounts, Eagle Creek Watershed.

Habitat Type Existing and Post-Treatment Habitat Acreage Amounts by 

Alternative (% of Existing), Eagle Creek Watershed

Existing 

Condition

Alt. 2 Alt. 3 Alt. 4

Source 18,569 17,218 

(92.7%)

17,256 

(92.9%)

17,679 

(95.2%)

Pileated woodpecker habitat at the WWNF scale

Existing pileated woodpecker source habitat on the WWNF as modeled by Wales (2011b) totals 129,943 

acres. As a result of projected habitat loss under the Snow Basin project, source habitats would decline by 

an estimated 1,351 acres under Alternative 2, about 1,314 acres under Alternative 3, and about 890 acres 

under Alternative 4. This results in a reduction in source habitat of 1.0 percent at the Forest level under 

Alternative 2 and a reduction of 1.0 percent and 0.7 percent under Alternatives 3 and 4, respectively, 

within the WWNF.

Cumulative effects

Cumulative effects for pileated woodpecker are analyzed for the Eagle Creek watershed. Past, present and 

reasonably foreseeable future actions were analyzed for cumulative impacts to the species. Effects of past 

activities including road construction, fire suppression, prescribed fire, and timber management have been 

incorporated into the existing conditions for amounts and locations of source habitats in the analysis area.

Review of the FACTS database for the WWNF indicates that activities that may impact pileated habitat 

within the Eagle Creek watershed outside the project area within the past three years consist of 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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approximately 158 acres of underburning and 749 acres of pre-commercial thinning under various 

projects. In addition, about 683 acres of commercial harvest has occurred under the Skookum Timber sale 

within the Eagle Creek watershed with an additional 97 acres expected to be harvested in 2012. Although 

some commercial treatments may occur within pileated woodpecker source habitat, the scale of potential 

impacts is not substantial in comparison to source habitats currently estimated to exceed 18,500 acres in 

the watershed. 

Appendix B was reviewed for actions that might affect pileated habitat within the Eagle Creek watershed. 

Cumulative impacts of ongoing and foreseeable actions are projected out to 20 years from the present.

Ongoing and future livestock grazing is expected to have no effect on suitable habitats. Additional 

grazing may occur in treated stands within the project area, but is not expected to alter source habitats. On 

Forest Service lands within and outside the project area, firewood cutting will continue to reduce 

available snags and logs, but the effect is limited to areas adjacent to open roads. Access within the 

watershed and across the WWNF will change when the Forest Travel Management Plan is implemented 

in the summer of 2012. There will be approximately 12 fewer miles of open roads where firewood

gathering can reduce snags and logs. Timber harvest on private inholdings is expected to continue at some 

level, with anticipated reductions of trees larger than 10 inches DBH. Lands to the south of the project 

area will continue to consist of open grassland habitats in private ownership.

Conclusion

Because this project impacts less than 1.0 percent of suitable habitat across the Forest, the overall direct, 

indirect and cumulative effects will result in a small negative effect to pileated habitat. The reduction of 

habitat would be immeasurable at the WWNF scale. Post-treatment availability of source habitats would 

continue to exceed the threshold of 40 percent of the historical amount in the Eagle Creek watershed 

under all action alternatives, thereby continuing to contribute to habitat distribution and species viability 

on the WWNF.

Primary Cavity Excavators (PCE)

The LRMP identifies 15 primary cavity excavators as management indicator species (MIS) for the 

availability and quality of dead and defective wood habitat: northern flicker; black-backed, downy, hairy, 

Lewis’, three-toed, and white-headed woodpeckers; red-naped and Williamson’s sapsuckers; blackcapped, chestnut-backed, and mountain chickadees; and pygmy, red-breasted, and white-breasted 

nuthatches. Pileated woodpecker is also a primary cavity excavator, but due to its reliance on larger snags 

and trees, it is addressed separately as an MIS. 

The abundance of cavity-using species is directly related to the presence or absence of suitable cavity 

trees. Habitat suitability for cavity-users is influenced by the size (diameter and height), abundance, 

density, distribution, species, and decay characteristics of the snags. In addition, the structural condition 

of surrounding vegetation determines foraging opportunities (Rose et al. 2001). Not every stage of the 

snag’s demise is utilized by the same species, but rather a whole array of species use the snag at various 

stages or conditions. Uses of snags include nesting, roosting, foraging, perching, courtship, drumming, 

and hibernating.

The distribution, habitat, and threats/risk factors are described for each of the PCEs mentioned above 

beginning on page 93 of the Wildlife Specialist’s Report.

Existing conditions

Conservation Status of PCE Species

Conservation status is assessed at the global, regional, and state level by several sources. Table 77 

summarizes conservation status at various levels. Species of highest concern consist of the white-headed 

and Lewis’ woodpeckers; both of which are classified as “Sensitive” in USFS Region 6 and by the 
Chapter 3 Snow Basin Vegetation Management Project FEIS

238

Oregon Department of Fish and Wildlife. Black-backed and three-toed woodpeckers are also listed as 

Oregon State Sensitive, but show a lower degree of concern, ranked “Vulnerable.” 

Table 77. Conservation status of cavity-nesting MIS

Species USFS 

Sensitive

NatureServe 

Ranks1

USFWS Birds of 

Conservation 

Concern2

ODFW3

Global OR

Black-backed 

woodpecker G5 S3 Vulnerable

Northern threetoed woodpecker G5 S3 Vulnerable

Downy 

woodpecker G5 S4

Hairy woodpecker G5 S4

Northern flicker G5 S5

Lewis’s 

woodpecker Yes G4 S2S3 BCR 9, BCR 10 Critical

White-headed 

woodpecker Yes G4 S2S3 BCR 9, BCR 10 Critical

Red-naped 

sapsucker G5 S4

Williamson’s 

sapsucker G5 S4B S3N BCR 9, BCR 10

Pygmy nuthatch G5 S4

Red-breasted 

nuthatch G5 S5

White-breasted 

nuthatch G5 S4

Black-capped 

chickadee G5 S5

Chestnut-backed 

chickadee G5 S5

Mountain 

chickadee G5 S4

1 NatureServe Ranks: (NatureServe 2010). G5 or S5 – Widespread, abundant, secure. G4 or S4 – Apparently 

secure. G3 or S3 – Vulnerable. G2 or S2 – Imperiled. 2 Species of Concern in any BCR (Bird Conservation Region) 

Listed (USFWS 2008). 3 Oregon Department of Fish and Wildlife Sensitive Species. 

(http://www.dfw.state.or.us/wildlife/diversity/species/docs/SSL_by_taxon.pdf) 

Population trend 

Population trend data is obtained for PCE species mainly from two sources. Breeding bird survey data 

collected long-term along established survey routes provides indices for species’ population trends at the 

state level. A stable trend in Oregon is shown for 10 of the 15 PCE species, with long-term decreases 

shown for two species (northern flicker and mountain chickadee). Trend information is inconclusive for 

three-toed and white-headed woodpecker, likely due to low overall detection rates. It is not uncommon 

for some species to be under-represented in multi-species survey techniques since some species are more 

easily detected than others. Regional indices of species’ security are also assessed under the Partners in 

Flight program. Scores for Bird Conservation Region 10, which includes the WWNF, are shown in Table 

78. Scores above 13 indicate a species may be of regional concern, and these include the black-backed 

woodpecker, Lewis’ woodpecker, pygmy nuthatch, red-naped sapsucker, white-headed woodpecker and 

Williamson’s sapsucker.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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The combination of the state and regional indices shows stability and regional scores below the threshold 

of concern for 6 of the 15 species. Increased concern, but stable state trend is shown for 4 species, while 

decreasing trend and lower regional concern is shown for 2 species. Both white-headed woodpecker and 

Lewis’ woodpecker show the highest regional concern without available trend information at the state 

level. Three-toed woodpecker also contains no state trend information, but the regional score is below the 

threshold of concern.

Table 78. Population trend data for cavity-nesting MIS

Species Breeding Bird Surveys1 Partners in Flight 

Database2

OR Reliability BCR 10

Black-backed woodpecker stable yellow 14

Downy woodpecker stable yellow 10

Hairy woodpecker stable blue 10

Lewis’s woodpecker no trend red 18

Northern flicker decrease blue 13

Northern three-toed woodpecker No data 13

Pygmy nuthatch stable yellow 14

Red-breasted nuthatch stable blue 11

Red-naped sapsucker stable yellow 17

White-breasted nuthatch stable blue 8

White-headed woodpecker no trend red 18

Williamson’s sapsucker stable blue 17

Black-backed chickadee stable blue 13

Chestnut-backed chickadee stable blue 11

Mountain chickadee decrease blue 12

1 Breeding Bird Survey – (Sauer et al. 2011) - watch reliability ratings (http://www.mbr-pwrc.usgs.gov/bbs/cred.html)

Increase = significant (p<0.05) increase from 1966-2009. Decrease = significant (p<0.05) decrease from 1966-2009. 

Stable = yellow or blue reliability and no significant increase or decrease. No trend = red reliability and no significant 

increase or decrease. Oregon - (http://www.mbr-pwrc.usgs.gov/cgi-bin/atlasa99.pl?ORE&2&07). 2 Partners in Flight 

(PIF) Database (http://www.rmbo.org/pif/scores/scores.html). Regional Combined Scores can range from 5 to 25.. 

Regional Combined Score > 13 may be a species of Regional Concern (Panjabi et al. 2005). Northern Rockies –

BCR 10

Habitat trend at the regional level

Wisdom et al. (2000) analyzed the current amount of available habitat in relation to historical availability 

for a range of species, producing a trend index by Ecological Reporting Unit (ERU). In the Blue 

Mountains, trend indices were reported for 8 of the 15 PCEs (Table 79). Decreasing or Strongly 

Decreasing trend is indicated for 6 of the 8 species. Strongest decreases are shown for species associated 

with mature ponderosa pine habitats with large snags (white-headed woodpecker, pygmy nuthatch) as 

well as single-story old forest, multi-storied Douglas-fir and western larch, and riparian cottonwood 

woodlands (Lewis’ woodpecker). Factors contributing to these declines include transition to shadetolerant tree species, past timber harvest, and increased roading that allowed snag removal for firewood 

(Wisdom et al. 2000). Black-backed woodpecker habitats, consisting of a range of green and burned 

forest condition, have also decreased at the regional level due to past timber harvest, firewood removal,

and fire suppression, The highest regional increase is shown for three-toed woodpecker, which is 

associated with late seral subalpine and montane conifer.
Chapter 3 Snow Basin Vegetation Management Project FEIS

240

Table 79. Long-term regional trend of PCE habitats 

Species Group

ERU Relative Change & Trend Category

Blue Mountains

Black-backed 

woodpecker 9 -30.96

Decreasing

Lewis’s 

woodpecker 2 -72.17 

Strongly decreasing

Northern 

three-toed 

woodpecker

11

100+ 

Strongly increasing

Pygmy 

nuthatch 1 -79.78 

Strongly decreasing

Whitebreasted 

nuthatch

1 -27.57

Decreasing

White-headed 

woodpecker 1 -79.26 

Strongly decreasing

Chestnutbacked 

chickadee

6 -3.08 

No change

Williamson’s 

sapsucker 6 -37.96

Decreasing

(Wisdom et al., 2000)

Snag habitat within the Snow Basin project area

Snag density surveys were conducted within 23 stands distributed across the project area during the 

summer of 2010. Sample results indicated an overall density of 4.73 snags per acre for snags 8 inches or 

greater in diameter and at least 10 feet in height. Density of snags greater than 21 inches averaged 1.32 

per acre (Figure 13). A summary of snags sampled by tree species and diameter class is provided in Table 

21. 

Table 79 indicates that grand fir snags occur in higher densities than other species in the areas sampled for 

snags. This is because grand fir trees are susceptible to a greater variety of insects and pathogens than 

other conifer species found in the Blue Mountains. Grand fir that have established on drier sites (more 

suited for ponderosa pine and Douglas-fir) are especially susceptible to insects and diseases. The value of 

grand fir snags to wildlife is largely dependent on the tree’s condition when it dies. A grand fir with 

heartrot is highly valuable as roosting and denning substrate for many species of birds and mammals.

Grand firs that die from defoliating insects and do not have heartrot, are of little utility for nesting, but 

may provide perching and foraging substrate for cavity excavators (Bull et. al. 1997).

The highest quality snags for primary cavity excavator nesting are ponderosa pine and western larch.

Western larch is also the most highly sought after snag for firewood. 

Table 80. Summary of sampled snags by tree species and diameter class

Tree Species

Diameter Classes in DBH

8-12 12-15 15-21 >21 Total

Grand Fir 0.32 0.89 0.16 0.66 2.03

Larch 0.02 0.05 0.20 0.07 0.34

Ponderosa Pine 0.21 0.23 0.57 0.46 1.47
Chapter 3 Snow Basin Vegetation Management Project FEIS

241

Douglas-fir 0.60 0.07 0.09 0.13 0.89

Total (per ac.) 1.15 1.24 1.02 1.32 4.73

Figure 13. Results of snag surveys, Snow Basin project area, 2010

Project-level snag densities in relation to forest-wide densities

Snag densities at the Forest level were summarized using Gradient Nearest-Neighbor (GNN) satellite 

interpretation data made available from the LEMMA (Landscape Ecology, Modeling, Mapping, and 

Analysis) team (LEMMA 2011). According to the data clipped to the Forest-wide extent, snags ≥10 inch

DBH average about 7.5 per acre, while snags ≥20 inch DBH averaged less than 2 per acre. For 

comparison, density of snags ≥ 8 inch DBH within sampled stands in the Snow Basin project area average 

4.73 per acre, and snags ≥21 inch DBH average 1.32 per acre. Lower snag averages for the project area 

could be a function of past management activities or a function of sampling level and design. Density 

estimates at the WWNF scale include wilderness and roadless areas where snag availability would not 

have been influenced by timber harvest or firewood gathering.

Another surrogate to actual snag densities is provided in the pileated woodpecker viability analysis, which 

can be found on page 82 of the Wildlife Specialist’s Report. This assessment characterizes snags in the 

Eagle Creek Watershed into low, moderate, and high densities relative to pileated woodpecker needs. The 

Eagle Creek Watershed has 26 percent of its area in low, 36 percent in moderate, and 38 percent in high 

snag densities. These do not directly translate to the 30 percent, 50 percent, and 80 percent tolerance 

levels from DecAID, but there is likely a general correlation between these levels. 

PCE habitats, WWNF

As part of the Blue Mountains Forest Plan Revision planning process, Countryman (2010) modeled 

potential fire severity for three national forests, including the WWNF. Current Vegetation Survey (CVS) 

plot data was run through the forest vegetation simulator and fire-fuels extension to generate fire metrics 

for each stake point. Data includes crown fire and torching index, potential fire type (active, passive, 

crown), and potential percent basal area mortality. The calculation for potential basal area loss in the 

event of a fire is the one that best represents an attempt to describe fire severity in relationship to the 

LANDFIRE reference estimates (The Nature Conservancy 2005). The summary of CVS data for percent 

stand replacing fire at the Forest scale is summarized in Table 81. Values were extracted from the FVS0.00

1.00

2.00

3.00

4.00

5.00

8-12 12-15 15-21 >21 Total

Snag Density per Acre

DBH Class

Snag Density by Species

Grand Fir

Larch

Ponderosa Pine

Douglas-fir

Total (per ac.)
Chapter 3 Snow Basin Vegetation Management Project FEIS

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fire/fuel extension, potential fire report (severe fire) percent basal area loss reports. The values for severe 

conditions used in the model include; wind speed of 20 mph, temp of 70f, 0 to .25 inch fuel moisture of 4

percent, 2.5 to 1 inch fuel moisture of 4 percent, 1 to 3 inch fuel moisture of 5 percent, >3 inch fuel 

moisture of 10 percent, duff of 15 percent, and live fuel moisture of 70 percent (Countryman 2010).

Results show that over 700,000 acres of upland conifer stands currently have the potential for standreplacement fire on the WWNF. Reduction of up to 13,334 acres in stand-replacement fire potential 

equates to approximately 2 percent of total WWNF acres in upland conifer currently at risk to standreplacement fire.

Table 81. Potential stand replacing fire, upland conifer, WWNF

Blue Mountains

Biophysical Setting

(Upland Conifer)

WWNF, 

Percentage of 

Biophysical 

Setting

Calculated Acres 

Based on % of 

Biophysical Setting 

Cold forest 55% 215,233 ac.

Moist forest 32% 136,606 ac.

Dry Douglas-fir forest 35% 113,420 ac.

Dry grand fir forest 42% 131,292 ac.

Dry ponderosa pine forest 57% 91,726 ac.

Hot dry pine forest 64% 20,491 ac.

Total WWNF Upland Conifer 

acres -- 708,768 ac.

*Value = percent of the biophysical environment that has the potential (based on CVS data) for greater than 75 

percent basal area loss in the event of a fire at 90th percentile conditions. Greater than 75 percent basal area 

mortality is defined as a stand replacing fire. Source of Percentage data: Countryman 2010.

Existing condition in relation to the R6 decayed wood advisor (DecAID)

Tolerance intervals are estimates of the percent of all individuals in the population that are within some 

specified range of values. In the case of the USFS Region 6 decayed wood advisor (DecAID) (MellenMcLean et al. 2009) , for example, they tell us what percent of pileated woodpeckers in a population use 

snags, up to or above certain diameters. Thus, an 80 percent tolerance level indicates 80 percent of the 

individuals in the population have a value for the parameter of interest (i.e. snag density) between 0 and 

the value for the 80 percent tolerance level. Or conversely, 20 percent of the individuals in the population 

have a value for the parameter of interest greater than the 80 percent level. The tolerance interval is the 

range between 2 tolerance levels. For example, the value for 80 percent is the level and the range of 0 to 

80 percent is the interval.

DecAID displays three tolerance levels (30, 50, and 80 percent) for density and DBH class of snags in 

various vegetation condition groups, used by wildlife species. Ranges of snag densities by DBH class are 

provided as a synthesis of data from various studies. In the Snow Basin project area, vegetation condition 

groups consist of Ponderosa Pine/Douglas-fir and Eastside Mixed Conifer habitats and include both Large 

Tree and Small/Medium tree habitat types. The ranges of snag densities by DBH class for each vegetation 

group and habitat types are shown in Table 82. Wildlife snag use levels shown in Table 82 exclude those 

estimated for white-headed woodpecker because the data are from a declining population (MellenMcLean et al. 2009).
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Table 82. Snag and down log parameters and tolerance levels 

Habitat Type/ 

Structure

Tolerance 

Levels

Snag Densities Used by 

Wildlife by Diameter Class

Ponderosa Pine/ 

Douglas-fir (Large)

80% 10-50 > 10” 

2.8-18 > 20” 

50%

4.7-30 > 10” 

1-8 > 20” 

30%

1.1-15 > 10” 

0-3.5 > 20” 

Ponderosa Pine/ 

Douglas-fir 

(Small/Medium)

80% 10-49 > 10” 

2.8-18 > 20” 

50%

4.7-30 > 10” 

1.6-8.4 > 20” 

30%

1.2-15 > 10” 

0-3.5 > 20” 

Mixed Conifer (Large)

80%

12.1-50 > 10” 

4-18 > 20” 

50%

5.6-56 >10” 

1.4-17 >20” 

30%

1.1-15 >10”

0-3.7 > 20”

Mixed Conifer 

(Small/Medium)

80%

12.1-50 > 10” 

4.0-18 > 20” 

50%

5.6-56 > 10” 

1.4-17 > 20” 

30%

1.1-15 > 10” 

0-3.7 > 20” 

source: DecAID

In comparison to snag density levels shown in Table 82, existing average snag densities in the sampled 

stands fall primarily into the 30 percent tolerance level. Snag densities for survey plots within the Snow 

Basin project area varied widely within and among stands sampled, indicating an uneven distribution on 

the landscape. For example, snag densities among surveyed stands ranged from a low of 0.8 per acre to a 

high of 9.5 per acre. For snags 21 inches or greater DBH, densities among stands ranged from zero to 3.7 

per acre. While overall densities of existing snags are low, there are areas of higher snag density where 

densities of smaller snags reach the 50 percent tolerance interval, and those of the largest snags approach 

or reach the 80 percent tolerance level. This distribution is consistent with uneven landscape distribution 

patterns of snags described by DecAID for “natural conditions” (i.e. unharvested plots). 

While DecAID provides data on wildlife use of snags, it does not measure the biological potential of 

wildlife populations. There is no direct relationship between tolerances, snag densities and snag sizes used 

in DecAID and snag densities and sizes that measure potential population levels (Mellen-McLean et al 

2009). Therefore, DecAID wildlife tolerance levels are only one component used to evaluate the effects 

of this project on dead wood habitats and associated species.

The Wallowa-Whitman LRMP direction originally provided to maintain snags and green tree 

replacements based on numbers provided in Thomas (1979). These included maintaining at least 40

percent minimum potential population (MPP) level for snags within upland conifer stands, and at least 60

percent MPP for snags within riparian settings. Several more recent studies have shown these snag 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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densities are too low to meet the needs of many primary and secondary cavity users. These inadequate 

standards contributed to the reduced number of large snags we see today. Since then, Forest Plan 

amendments have updated snag standards and guidelines to provide for 100 percent potential population 

levels. Bull et al. (1997) found 2.25 snags/acre were insufficient and that 4 snags/acre (2.8 snags between 

10 to 20 inch DBH and 1.2 snags >20 inch DBH) is more appropriate as a minimum density required by 

primary and secondary cavity users for roosting, nesting, and foraging needs. Harrod et al. (1998) 

determined a range of historic snag densities for dry eastside forests between 5.9 to 14.1 snags/acre (5 to 

12 are 10 to 20 inch DBH and 0.9 to 2.1 are >20 inches DBH). Korol et al. (2002) determined that HRV 

for large snags (20 inch DBH) for dry eastside mixed conifer forest with a low intensity fire regime was 

2.9 to 5.4 snags/acre. All snags within harvest units would be retained unless they present a safety hazard.

Live green trees of adequate size must also be retained to provide replacements for snags and logs 

through time. Generally green tree replacements (GTRs) need to be retained at a rate of 16 to 74 trees per 

acre, depending on biophysical group, estimated rotation, pre-commercial and commercial thinning, and 

average stand diameter (Schommer et al. 1993). Pre-activity levels of logs should also be left unless levels 

exceed amounts specified in Forest Plan Amendment #2 (Table 83). Larger blowdowns with intact tops 

and rootwads are preferred to shorter sections of tree boles.

Table 83. LRMP standards for down wood.

Stand type Pieces/acre1 Piece length Diameter small end Linear ft/acre

Ponderosa pine 3 – 6 >6' 12" 40'

Mixed conifer 15-20 >6' 12" 140'

Lodgepole pine 15-20 >8' 8" 260'

1 The table converts to about 0.4, 1.7, and 3.3 tons/acre for ponderosa pine, mixed conifer, and lodgepole pine, 

respectively.

Direct and indirect effects

Alternative 1 

The no action alternative retains existing snag densities by virtue of no timber harvest treatments, fuels 

treatments, or transportation activities. The indirect effects associated with this alternative is that snag 

recruitment mechanisms related to tree density and tree species composition will not be reduced through 

thinning and burning. This may result in higher snag recruitment, but over the long-term the average 

diameter of snags will be smaller than under the action alternatives. Additionally, the risks from 

uncharacteristic wildfire or insect and disease events would be higher with alternative 1 then with 

Alternatives 2, 3, and 4. Disturbances that result in high levels of tree mortality over large portions of the 

landscape would benefit a few PCE species (black-backed and Lewis’ woodpecker) for a period of time. 

However, a forested landscape with a steady and adequate supply of snag habitat over time likely 

contributes to the viability of more species over a greater period of time. 

Alternatives 2, 3, and 4

Snag availability 

All action alternatives have the potential to reduce snags within proposed treatment areas. However, the 

number of snags cut down to address hazards within timber harvest units and along haul routes is 

expected to be low. The rate of snag removal due to timber harvest safety concerns is estimated at less 

than 1 percent (of existing at the stand scale) for timber sales on the district (Sciarrino pers. comm. 2010).

Snags cut down to address human safety will be retained on site as large woody material.

Treatments in the form of prescribed fire will likely consume a portion of existing snags, while also 

creating new snags via fire damage to a small portion of existing green trees. The level and extent of 
Chapter 3 Snow Basin Vegetation Management Project FEIS

245

impact to the existing snag resource from prescribed fire is unknown. Harrod et al. (2009) described that 

burning treatments increased the probability of snag fall, but that these losses were offset by tree mortality 

caused by fire. Horton and Mannan (1988) reported a 50 percent reduction in snags greater than 20 inches 

due to prescribed burning in Arizona. Stephens and Moghaddas (2005) reported no significant difference 

in overall soft snag numbers when compared between controls, mechanically thinned, and mechanically 

thinned and burned stands in the Sierra Nevada. Project design criteria have been included to increase 

retention of larger snags and logs within units treated with prescribed fire (see Appendix B-1).

Post-treatment availability of snags within the project area is expected to be similar to existing conditions.

Danger tree removal would be emphasized along haul routes, but existing snags are already sparse near 

roads due to past and ongoing firewood cutting. In addition, areas near haul routes represent a very small 

portion of the overall project area acreage and therefore would not contribute to a sizeable reduction in 

snag numbers.

Alternative 2 would have the greatest potential for decreasing snag numbers through mitigating danger 

trees, because it involves the most treatment acres and the most miles of haul routes. Alternative 4 would 

have the lowest potential for decreasing snags, and Alternative 3 would fall between 2 and 4. 

PCE habitats, Snow Basin project area

Potential habitat impacts and benefits for Lewis’ woodpecker and white-headed woodpecker are analyzed 

within the Sensitive Species section of this report. In summary, all action alternatives enhance and 

increase suitable habitat structure within the project area in both the short and long-terms, with 

Alternative 2 providing the largest increase for both Lewis’ and white-headed woodpeckers. For Lewis’ 

woodpecker, all action alternatives are likely to reduce the potential for burned area habitats in the longterm, but would be offset by a relatively steady availability of suitable green stands. Stand density 

reductions and enhancement of ponderosa pine habitats would increase available habitat for hairy 

woodpecker, northern flicker, pygmy nuthatch, white-breasted nuthatch, and Williamson’s sapsucker. No 

treatments are proposed in suitable three-toed woodpecker habitats that consist of subalpine fir stands.

Aspen restoration treatments on 38 acres are expected to increase habitat available to aspen-associated 

PCEs which include: downy woodpecker; red-naped sapsucker; Williamson’s sapsucker; black-capped 

chickadee; chestnut-backed chickadee; and mountain chickadee. 

Stand density reductions may negatively impact red-breasted nuthatch by reducing structural diversity.

Because the species is known to use both unmanaged and managed forest stands, the level of impact 

within the project area is expected to be minor. This species is considered common and widespread on the 

WWNF. 

Currently, a large portion of acres within Snow Basin are at increased risk to insect mortality, disease, and 

stand-replacement fire relative to historic levels of disturbance. Such overstocked stand conditions also 

increase the potential for future pulses of conifer mortality that provide suitable habitat for black-backed 

woodpeckers. By reducing stand densities, the action alternatives would decrease the potential for habitat 

availability in the form of stand-replacement fires or large areas of insect-induced conifer mortality.

Alternative 2 produces the highest reduction, consisting of up to 13,334 acres where risk to severity and 

extent of future wildfire would be reduced (Table 84, also see Silviculture Specialist’s Report). Area 

remaining at elevated risk to wildfire totals 3,236 acres. Alternative 3 would reduce future wildfire risk on 

up to 12,240 acres, with 4,330 acres remaining at elevated risk. Alternative 4 reduces risk on the least 

amount of area, with risk reduction on about 11,755 acres. About 4,815 acres would remain at elevated 

risk under Alternative 4. Remaining potential black-backed woodpecker habitat would occur in untreated 

areas within and outside of wildlife refugia, RHCAs, and MA-15 (Old-Growth) areas as well as additional 

areas where higher stand densities are maintained within connectivity corridors.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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The commercial thinning and prescribed burning proposed in all action alternatives will reduce stress 

among residual trees, allowing them less competition for space and resources, and allowing their defenses 

against insects and diseases to function more effectively. Increased spacing between residual trees will 

also decrease the chances of broken limbs and boles from striking neighboring trees, creating wounds 

which are sites for heartrot fungi to take hold. Stress, competition between trees, reduced defense 

effectiveness, and wounds in bark all represent snag recruitment mechanisms. These will be reduced, but 

not eliminated in treated stands. It is important to note that all these snag recruitment mechanisms will 

continue to function across the Snow Basin project area, but to a lesser degree on treated acres. It is 

impractical to quantify the effects to snag recruitment from these changes. However, acres treated can be 

used as a relative measure to compare effects of alternatives. Alternative 2 treats the most acres, so this 

alternative will reduce snag recruitment over the largest area, followed by Alternatives 3 and 4, 

respectively. 

Because the project area currently lacks burned habitat or areas of high levels of insect mortality, it is 

likely that black-backed woodpeckers occur at very low densities within the project area, if at all.

Therefore, treatments are expected to have no immediate impact on the species. However, burned habitat 

for this species does exist to the east and northeast of the project area. 

Table 84. Reduction of risk to insect and wildfire disturbance, Snow Basin project area

Indicator

Existing 

Acres at 

Risk

Acres Treated

(% of Total at Elevated Risk)

Alt 2 Alt 3 Alt 4

Acres of reduction of risk to 

insect outbreaks 16,570 12,120 

(73%) 

11,197 

(68%)

10,954 

(66%)

Acres of reduction in severity 

and extent of future wildfire 

disturbance

16,570 13,334 

(80%)

12,240 

(74%)

11,755 

(71%)

Cumulative effects

The cumulative effects area considered for PCEs consists of the Eagle Creek watershed. Effects of past 

activities including road construction, fire suppression, prescribed fire, and timber management on 

WWNF lands have been incorporated into the existing condition.

Alternative 1

The no action alternative will not contribute to cumulative effects, except for those described under 

indirect effects above.

Alternatives 2, 3, and 4

Review of the FACTS database for the WWNF indicate that activities that may impact PCE habitats 

within the Eagle Creek watershed outside the project area within the past three years consist of 

approximately 158 acres of underburning and 749 acres of pre-commercial thinning under various 

projects. In addition, about 683 acres of commercial harvest has occurred under the Skookum Timber sale 

within the Eagle Creek watershed with an additional 97 acres expected to be harvested in 2012. Both 

commercial and non-commercial treatments are expected to reduce stand densities while maintaining snag 

densities consistent with LRMP direction. 

Appendix B was reviewed for actions that might affect PCE habitat within the central portion of the Eagle 

Creek watershed. Cumulative impacts of ongoing and foreseeable actions are projected out to 20 years 

from the present. Ongoing and future livestock grazing is expected to have no effect on snag and log 

habitats. Additional grazing may occur in treated stands within the project area, but is not expected to 
Chapter 3 Snow Basin Vegetation Management Project FEIS

247

alter snag and log characteristics. On Forest Service lands within and outside the project area, firewood 

cutting will continue to reduce available snags and logs, but the effect is limited to areas adjacent to open 

roads. Access within the watershed and across the WWNF may change pending the outcome of the Forest 

Travel Management Plan. Timber harvest on private inholdings is expected to continue at some level, 

with anticipated reductions of trees larger than 10 inches DBH. Lands to the south of the project area will 

continue to consist of open grassland habitats in private ownership.

Summary of effects

All proposed actions are consistent with LRMP standards and guidelines pertaining to primary cavity 

excavators. Current availability of snags in the project area is estimated to exceed minimum LRMP 

standards on average, but spatial arrangement of available snags is variable due to past activities. Timber 

harvest and prescribed burning proposed under all action alternatives have the potential to decrease snag 

availability, but that impact is expected to be minor within the project area and on the landscape as a 

whole due to snag retention requirements described in Project Design Features. Stand density treatments 

in conifer stands are expected to enhance habitats for Lewis’ woodpecker, white-headed woodpecker, 

northern flicker, pygmy nuthatch, white-breasted nuthatch, and Williamson’s sapsucker green-tree 

habitats. Aspen restoration treatments would enhance habitats for downy woodpecker, red-naped 

sapsucker, Williamson’s sapsucker, black-capped chickadee, chestnut-backed chickadee, and mountain 

chickadee. Although treatments would improve habitats for these species within the project area, the

effect to habitats Forest-wide would be small considering that the project area encompasses only 1.1

percent of WWNF acres. Proposed tree density reduction treatments would reduce risk to insect and 

wildfire disturbance on up to 13,334 acres within the project area, thereby reducing the potential for 

future pulses of habitat suitable for Lewis’, hairy, and black-backed woodpeckers within a large portion 

of the project area. However, reduction of potential habitat is small (2 percent) in relation to overall

availability Forest-wide. Therefore, no alternative considered for the Snow Basin Project would affect 

population trends or viability for primary cavity excavator species at the Forest-level or regional scale.

Rocky Mountain Elk

Existing conditions

Elk are the most popular big game species in northeastern Oregon and are an indicator of the quality and 

diversity of general forested habitat, the interspersion of cover and forage areas, and the security habitat 

provided by cover and low levels of human activity. Elk exploit a variety of habitat types in all 

successional stages and use patterns change both daily and seasonally. Disturbance due to roads is a major 

factor influencing elk distribution across the landscape as evidenced by the results from a variety of 

studies conducted in northeastern Oregon (Rowland et al. 2005). The Oregon Department of Fish and 

Wildlife manage elk and other big game species by wildlife management unit (WMU). The Snow Basin 

project is within the Keating WMU. 

Elk seasonal habitat within the Snow Basin project area consists primarily of summer range (21,820 

acres). An additional, 5,567 acres occur in MA-3 (wildlife/timber emphasis – big game winter range) and 

1,158 acres is designated MA-1W (Timber/Winter Range). Reconnaissance of the area during the midlate summer of 2008/2009 showed low levels of elk presence in the lower and mid-elevation areas, with 

recent elk sign observed in the extreme northern portion of the project area. This low level of elk presence 

was again observed during field reconnaissance in the late summer of 2011 (Penninger 2011, personal 

observations). Because winter range is identified south and east of Snow Basin, portions of the project 

area are utilized by elk for migration and areas within the project area serve as seasonal transition 

habitats. Based on annual elk census numbers from 2001 – 2011 in the Keating Wildlife Management 

Unit, the overall trend in total elk observed during the period is increasing (Figure 14). Elk numbers 

within the Keating WMU reached Management Objective (MO) in 2011.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Figure 14. ODFW elk population estimates, Keating Unit 

(ODFW, 2011)

Habitat effectiveness index (HEI)

Thomas, et al. (1988), developed a Habitat Effectiveness Index (HEI) model for estimating elk habitat 

effectiveness on the landscape. Overall habitat effectiveness (HEI) incorporates three variables or indices; 

cover quality (HEc), size and spacing of cover and forage (HEs), and open road density (HEr). A fourth 

value for forage quality, calculated by the model (HEf ) is omitted (upon advice from the model’s 

developer) from the calculation because current, reliable forage data is not available (Wisdom 2008, pers. 

com.). The LRMP establishes minimum standards for the overall index (HEI). In addition, the LRMP 

establishes minimum standards for retention of total cover and a threshold for maximum open road 

density. 

Table 85 displays the HEI model outputs for subwatersheds that occur within the Snow Basin project area 

boundary. Existing values for cover spacing are generally moderate-high within each subwatershed and 

open road values low-moderate. Thomas (1979) suggested an optimal cover/forage ratio of 40:60.

Existing cover:forage ratios show that conditions in all subwatersheds and the project area as a whole are 

within +/- 25 percent of the suggested optimum level. It is important to note that a simple cover:forage 

ratio provides very little information on the condition of elk habitat since it contains no information on the 

arrangement and size of cover and forage patches, nor does it consider the effects of motorized access to 

the effectiveness of cover and forage patches. Existing percent cover exceeds 30 percent in all 

subwatersheds and the project area as a whole. Satisfactory cover is highest in the Goose Creek 

subwatershed and lowest within Eagle-Paddy. Overall, HEI values in these areas are at or above 

thresholds described in the LRMP.

HEI values within Forest Management Areas (MAs) currently approach or exceed marginal thresholds 

(Table 85). Existing HEI in MAs 1 and 3/3A are .51 and .53, respectively, while HEI for MA-1W is .50, 

just at LRMP standards, largely due to high open road density and a general lack of satisfactory cover.

Existing HEI for the Snow Basin project area (all management areas combined) is 0.57.

0

50

100

150

200

250

300

350

400

450

Elk Numbers

Year

ODFW Elk Population Estimates 

Keating Unit 2001-2011

MO = 400
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Distance banding of roads

The HEI model developed by Thomas et al. (1988) relies on open road density as an indicator of relative 

effects from roads on elk habitat. More recent research in northeastern Oregon found that road density is a 

poor indicator of habitat effectiveness (Rowland et al. 2000). By contrast, the study described a strong 

linear increase in elk use as distance from roads increased. Therefore, a method using a distance-banding 

approach, as described by Rowland et al. (2005), is utilized here as an alternate indicator of road effects 

on elk habitat in the Snow Basin project area. Table 86 shows habitat effectiveness values for roads using 

distance banding (HEr-DB). Results indicate lower HEr values when using distance banding as compared 

to using road densities. These lower HEr values would equate to lower overall HEI values, which is likely 

a more accurate portrayal of HEI than when calculated using road densities. However, neither the road 

density or distance band methods of assessing disturbance from motorized access reflect the pending 

Travel Management Plan that would have an estimated net reduction in roads of 12 miles and eliminate 

unregulated cross country travel in the Snow Basin project area. The Travel Management Plan is 

discussed in more detail below. 

Table 85. Subwatershed and project area hei using road density for all alternatives

Alternative Hec Hes HEr HEI

Cover/ 

Forage 

Ratio

%CTotal

Cover 

%Satisfactory 

Cover

%Marginal 

Cover

Goose Creek Subwatershed

Existing 0.59 0.63 0.45 0.56 63/37 63% 11.3% 51.6%

PA Alt 2 0.59 0.63 0.45 0.56 63/37 63% 11.3% 51.4%

Alt 3 0.59 0.63 0.45 0.56 63/37 63% 11.3% 51.4%

Alt 4 0.59 0.63 0.45 0.56 63/37 63% 11.3% 51.4%

Eagle-Paddy Subwatershed

Existing 0.53 0.61 0.44 0.53 66/34 66% 4.5% 61.8%

PAAlt 2 0.52 0.65 0.45 0.54 62/38 62% 2.5% 59.7%

Alt 3 0.52 0.65 0.45 0.54 62/38 62% 2.7% 59.5%

Alt 4 0.52 0.65 0.45 0.54 63/37 63% 2.7% 60.0%

Little Eagle Subwatershed

Existing 0.57 0.64 0.52 0.58 59/41 59% 7.9% 51.0%

PA Alt 2 0.57 0.72 0.52 0.60 51/49 51% 6.9% 43.7%

Alt 3 0.57 0.72 0.52 0.60 51/49 51% 7.1% 43.6%

Alt 4 0.57 0.72 0.52 0.60 51/49 51% 7.1% 43.6%

Lower Eagle Subwatershed

Existing 0.64 0.67 0.47 0.59 35/65 35% 9.9% 25.0%

PA Alt 2 0.64 0.67 0.47 0.59 35/65 35% 9.9% 24.7%

Alt 3 0.64 0.67 0.47 0.59 35/65 35% 9.9% 24.7%

Alt 4 0.64 0.67 0.47 0.59 35/65 35% 9.9% 24.7%

Snow Basin – All Management Areas Combined

Existing 0.63 0.64 0.46 0.57 65/35 65% 17% 48%
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Alternative Hec Hes HEr HEI

Cover/ 

Forage 

Ratio

%CTotal

Cover 

%Satisfactory 

Cover

%Marginal 

Cover

PA Alt 2 0.61 0.73 0.46 0.59 50/50 50% 11% 39%

Alt 3 0.59 0.66 0.46 0.56 62/38 62% 11% 51%

Alt 4 0.71 0.60 0.46 0.57 63/37 63% 12% 51%

Table 86. HE values for the roads variable using distance banding.

Analysis Area HEr-DB

Project Area 0.27

Little Eagle Subwatershed 0.45

Eagle-Paddy Subwatershed 0.28

MA-1 0.26

MA-1W 0.25

MA-3/3A 0.28

Direct and indirect effects

Alternative 1

There will be no direct or indirect adverse effects to elk cover and forage from alternative 1 because no 

timber harvest, fuels treatments, or transportation activities will occur. The current condition consists of 

an abundance of marginal cover, low to moderate amounts of forage, and little satisfactory cover.

However, given the dry biophysical groups present in the majority of the project area, many of these 

stands are not capable of providing satisfactory cover. The no action alternative would maintain current 

conditions for elk habitat in the short-term (0 to 20 years). How elk habitat changes in the mid to longterm (beyond 20 years) would depend largely on the occurrence and scale of disturbances such as 

wildfire, and insect or disease epidemics, and changes in travel management and hunting. These events 

cannot be predicted with a reasonable level of certainty, but the risks associated with forgoing 

management actions can be described.

In the absence of restoring ponderosa pine and Douglas-fir on drier sites, and reducing grand fir through 

mechanical thinning, fuels reductions, and prescribed fire, cover will increase and forage will mature and 

lose palatability. Trees that are stressed from competition with adjacent trees will be more susceptible to 

insects and diseases. This could lead to decreases in cover as trees die and canopy closure decreases. 

Heavily stocked conifer stands will also decrease in canopy closure as self pruning occurs, and tree 

crowns become shallower and narrower from competition for space. In the absence of fire (prescribed or 

wildfire), forest fuels will build to a point that puts fire-resistant trees at risk. Large scale fire of 

uncharacteristic intensity would degrade elk habitat through a loss of cover, and through a reduction in 

edge habitat between cover and forage areas.

Alternatives 2, 3, and 4: All action alternatives would affect elk habitat. Due to minor amounts of 

treatment proposed within the Goose Creek and Lower Eagle subwatersheds, HEI values, cover:forage 

ratio, and available satisfactory cover are nearly identical for all alternatives (including alternative 1) 

within these subwatersheds (Table 85). Within the Eagle-Paddy and Little Eagle subwatersheds,

treatments reduce available satisfactory cover, but retain or slightly improve HEI values by improving the 

forage to cover arrangement (size and spacing HE variable). Treatments within MA-1, MA-1W, and MA3/3A reduce available satisfactory cover, but slightly improve or maintain HEI unchanged under all action 
Chapter 3 Snow Basin Vegetation Management Project FEIS

251

alternatives. All action alternatives meet or exceed LRMP standards for percent cover and HEI. The 

amount of satisfactory cover converted to marginal cover or forage, and marginal cover converted to 

forage is displayed in Table 87.

Table 87. Summary of cover conversions by action alternatives (acres)

Alternative 2 Alternative 3 Alternative 4

Satisfactory converted 

to marginal cover

1,022 1,236 1,171

Satisfactory cover 

converted to forage

546 164 140

Marginal cover 

converted to forage

4,418 1,341 1,131

Forest stand tree density reductions from commercial and non-commercial forest treatments (thinning) 

ranging from 11,495 to 9,228 acres, with additional prescribed fire-only treatment ranging from 3,972 to 

4,995 acres under the action alternatives would increase available elk forage. Treatments in Snow Basin 

occur on a majority of acres currently classified as elk marginal cover. Post-treatment tree densities are 

expected to be variable, consisting of denser patches interspersed with more open areas, but generally 

commercial thinning will convert marginal cover to forage. The amounts of forage, marginal and 

satisfactory cover remaining under each alternative does not reflect the finer scale mixture forage, hiding 

cover and small marginal cover patches that result from many intermediate commercial thinning 

prescriptions. As mentioned earlier in this analysis, the HEI calculations lacked a forage quality variable 

that would allow a better assessment of range conditions for elk. Cook et al. (1996) identify forage quality 

on late summer and fall ranges as an important factor in juvenile elk growth, and stress the importance of 

evaluating forage quality for assessment of habitat quality of these seasonal ranges. Elk forage analysis 

tools and data to input into such tools do not currently exist that are sensitive enough to identify 

differences between project alternatives. An elk habitat selection model is currently under development, 

but it will not be available for use until later in 2012. 

Table 88. HEI by management area and alternative using road density

Alternative HEc HEs HEr HEI

Cover/ 

Forage 

Ratio

%Total 

Cover

%Satisfactory 

Cover

%Marginal 

Cover

Snow Basin MA-1

Existing 0.52 0.61 0.43 0.52 70/30 70% 2.9% 66.8%

PA Alt 2 0.51 0.69 0.44 0.55 62/38 62% 1.6% 60.7%

Alt 3 0.52 0.69 0.44 0.55 62/38 62% 1.9% 60.4%

Alt 4 0.52 0.69 0.44 0.55 63/37 63% 1.9% 60.9%

Snow Basin MA-1W

Existing 0.51 0.6 0.38 0.50 64/36 64% 0.9% 63.5%

PA Alt 2 0.5 0.64 0.38 0.51 61/39 61% 0.1% 61.1%

Alt 3 0.5 0.64 0.38 0.51 61/39 61% 0.1% 61.1%

Alt 4 0.5 0.64 0.38 0.51 61/39 61% 0.1% 61.1%

Snow Basin MA-3/3A

Existing 0.56 0.64 0.45 0.55 64/36 64% 7.4% 56.9%

PA Alt 2 0.54 0.68 0.46 0.56 58/42 58% 4.6% 53.6%
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Alternative HEc HEs HEr HEI

Cover/ 

Forage 

Ratio

%Total 

Cover

%Satisfactory 

Cover

%Marginal 

Cover

Alt 3 0.54 0.68 0.46 0.56 58/42 58% 4.6% 53.6%

Alt 4 0.54 0.68 0.46 0.56 58/42 58% 4.6% 53.6%

Distance to cover size and spacing of forage and cover patches

All action alternatives would convert a portion of available cover to forage. None of the alternatives 

involve regeneration treatments, but Table 87 summarizes the amounts of cover that would be converted 

to forage. The Forest LRMP standards and guidelines state that: 

Vegetation manipulation that converts a site from satisfactory or marginal cover to a forage condition 

should:

• For MA-3: Have at least 80 percent of the treated area within 600 feet of a patch of satisfactory 

cover at least 40 acres in size.

• For MA-3A: Have at least 80 percent of the treated area within 600 feet of a patch of satisfactory 

or marginal cover at least 6 acres in size AND within 900 feet of a patch of satisfactory cover at 

least 40 acres in size.

Although cover would be converted to forage (Table 87) in all management areas, a high degree of 

interspersion of forage and cover stands would remain to meet the direction for cover in MA-3 or MA3A. The standards relating to thermal cover in MA-3 and MA-3A were developed during the time when 

regeneration harvests were common and there was concern over retaining adequate cover on winter 

ranges. These standards are challenging to assess when silvicultural prescriptions are used instead of 

regeneration. However, standards and guidelines that address overall HEI, the minimum 30 percent cover 

requirement, and road densities, combine to ensure at least a moderate level of cover, forage and security 

habitat.

Roads

Open road densities (miles/square mile) within various management areas in Eagle-Paddy and Little 

Eagle subwatersheds range from 0 in MA-3A to 3.21 in MA-1W (Table 89). Existing open road densities 

within MA-1, MA-1W, and MA-3 exceed LRMP direction. However, the Wallowa-Whitman National 

Forest’s Travel Management Plan (TMP) is nearing completion, and will likely have a signed decision 

before Snow Basin does. The TMP will limit motor-vehicle use to designated routes. It will also prohibit 

cross country travel and the use of closed roads by motor vehicles unless designated open for such uses 

(e.g. as OHV travel routes). Implementation of the travel management plan is expected to begin in the 

summer of 2012. With the implementation of the TMP, some roads that are open now will be closed by 

promulgation (approximately 18 miles in the Snow Basin area). Some roads within the project area 

currently identified as closed (maintenance level 1), will be opened for motorized travel by full size 

vehicles and/or OHVs (approximately 6 miles in Snow Basin). This will result in a net reduction of open 

roads within the project area, which will provide additional habitat that is free from disturbance from 

motor vehicles. The increase in elk security habitat that will result from the TMP could not be quantified 

at the time the Snow Basin analysis was being conducted because the final decision for the TMP had not 

been made. However, the net reduction of approximately 12 miles of roads and the elimination of 

unregulated cross country travel will result in a substantial improvement in elk security habitat in the 

Snow Basin project area. 

Alternatives 2 and 3 involve 10.9 and 9.0 miles of temporary roads, respectively. These roads will 

increase the chance for disturbance to big game during project implementation. This would be a short 

duration effect since temporary roads will be decommissioned following the project. Decommissioning
Chapter 3 Snow Basin Vegetation Management Project FEIS

253

will entail a range of treatments that will return the area to a vegetated condition and in most cases make 

use by motorized vehicles impossible. Alternative 4 does not construct temporary roads.

Table 89. Summary of current road densities, Snow Basin project area

Subwatershed/

Mgmt Area

LRMP

S & G

Open

Rd. Miles

Open Road

Density

Total Road

Density

Eagle CreekPaddy Creek 82.52 2.59 5.66

MA-1 2.5 45.07 2.67 6.28

MA-1W 1.51 7.29 3.21 5.83

MA-3 1.51 17.88 2.49 5.61

MA-3A 1.51 0.00 0.00 0.50

Little Eagle

Creek

31.45 1.71 4.27

MA-1 2.5 25.43 2.51 6.56

MA-3 1.51 5.06 1.99 4.27

1 1.5 miles per square mile during the time that the areas are being used by big game. On summer ranges this will 

require physically closing roads. On winter ranges (MA-1W) adequate road closure will normally result from snow.

In accordance with the Travel Opportunity Guide (1991) and Forest Order 442-01, there are two 

cooperative travel management areas and a restriction on the use of wheeled vehicles on designated 

snowmobile routes that overlap the Snow Basin project area. These areas are managed and enforced 

through an MOU between the Forest Service and ODFW: Summit Point, Eagle Creek, and Snowmobile 

routes on the 70 and 77 road systems.

The need for these cooperative travel management areas will be assessed in coordination with ODFW 

once the Forest’s TMP is implemented. The TMP reduces motorized route densities and eliminates 

unregulated cross country travel, which is essentially what occurred in the cooperative travel management 

areas. The cooperative travel management areas will remain in place for an undetermined period of time 

while the TMP is being implemented.

Cumulative effects

Alternative 1

The no action alternative will not have incremental, cumulative effects to other past, present and 

reasonably foreseeable future actions in this area. Any effects from alternative one would be indirect, 

which are described above. 

Alternatives 2, 3, and 4

The cumulative effects area considered for elk consists of the Eagle Creek watershed because it 

encompasses 500 km2

. The annual home range of an adult elk can be as much as 163 km and so the Eagle 

Creek watershed is roughly three times the size required to support one elk herd. Effects of past activities 

including road construction, fire suppression, prescribed fire, and timber management on WWNF lands 

have been incorporated into the existing condition. Review of the FACTS database for the WWNF 

indicate that activities that may impact elk habitats within the Eagle Creek watershed outside the project 

area within the past three years consist of approximately 158 acres of underburning and 749 acres of noncommercial thinning under various projects. In addition, about 683 acres of commercial harvest has 

occurred under the Skookum Timber sale within the Eagle Creek watershed with an additional 97 acres 

expected to be harvested in 2012. Both commercial and non-commercial treatments are expected to 

reduce stand densities and available cover while increasing available forage. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Current condition of elk habitats is largely a function of past activities. Historically, the area was 

unroaded, and forest stands were less dense and provided larger amounts of forage. The amount of closed 

roads, however, reveals that motorized access under the current condition is less than that which existed 

in recent decades.

Appendix B was reviewed for actions that might affect elk habitat within the Eagle Creek watershed.

Cattle grazing will continue within the project area. The majority of range acres in the project area are 

grazed from June 1 – October 30. Resource partitioning between elk and cattle in northeastern Oregon 

was studied by Stewart et al. (2002). Elk utilized steeper slopes and higher elevations than cattle when 

cattle were present, possibly indicating competitive displacement of elk by cattle. Diet overlap between 

cattle and elk has been described, and is most prominent when forage resources are limited (Stewart et al. 

2002). However, most of the rangeland on NFS lands contained within the analysis area is in satisfactory 

condition, fair to good, and in mid to late seral stage due to lack of disturbance from fire (see the

Range/Livestock Grazing section).

In early 2012 this area is expected to be under the Forest Travel and Access Management Plan that will 

increase security habitat with low levels of human intrusion. The preferred alternative under the draft plan 

reduces motorized accessibility within the project area. Existing open road density within the EaglePaddy and Little Eagle subwatersheds totals 2.6 miles/square mile. Under the draft Travel Management 

Plan preferred alternative, open motorized road and trail density would decrease to 1.9 miles/square mile. 

The presence of additional security areas would have a positive effect on elk distribution and bull 

escapement during hunting seasons. HEI values for all alternatives would also increase as a result of 

decreased road densities. However, these effects cannot be evaluated in detail until completion of the 

TMP. 

Summary of effects

Alternatives 2, 3, and 4 

All action alternatives are consistent with LRMP standards and guidelines pertaining to elk. Treatments 

proposed under all action alternatives are expected to maintain or slightly improve elk habitat 

effectiveness, as indicated by HEI values. Although no additional system roads are proposed, existing 

road densities currently exceed thresholds identified in the LRMP, and the action alternatives maintain 

these densities without proposals for additional closures. Existing cooperative travel management areas 

are expected to continue to benefit elk at least until the TMP is in place and will overlap the TMP for an 

undetermined period of time. Since the TMP is a reasonably foreseeable future project, it is reasonable to 

predict that implementation of the TMP will bring this area in line with road density standards.

Although all action alternatives at least meet minimum LRMP standards for elk, local knowledge of elk 

habitat conditions, elk distribution, and trends in the population are combined in the following ranking of 

alternatives relative to elk habitat. Alternative 4 would retain the most desirable combination of 

satisfactory cover, marginal cover, forage areas, and security areas for elk. Alternatives 2 and 3 are 

similar in their effects to elk habitat, but alternative 3 would retain a slightly more desirable combination 

of cover, forage and security areas for elk than Alternative 2.

Landbirds Including Neotropical Migratory Birds (NTMB) 

Landbirds, including neotropical migratory birds (NTMB), were analyzed based on high priority habitats 

identified in the Oregon-Washington Chapter of Partners in Flight, Northern Rocky Mountains Bird 

Conservation Plan (Altman, 2000). While the Forest has not conducted official NTMB surveys in the 

project area, the Oregon Breeding Bird Atlas (Adamus et al., 2001) includes observational data for this 

area. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

255

Under the National Forest Management Act (NFMA), the Forest Service is directed to, “provide for 

diversity of plant and animal communities based on the suitability and capability of the specific land area 

in order to meet overall multiple-use objectives.” (P.L. 94-588, Sec 6 (g) (3) (B)) The January 2000 

USDA Forest Service (FS) Landbird Conservation Strategic Plan, followed by Executive Order 13186 in

2001, in addition to the Partners in Flight (PIF) specific habitat Conservation Plans for birds and the 

January 2004 PIF North American Landbird Conservation Plan all reference goals and objectives for 

integrating bird conservation into forest management and planning.

In late 2008, a Memorandum of Understanding between the USDA Forest Service and the US Fish and 

Wildlife Service to Promote the Conservation of Migratory Birds was signed. The intent of the MOU is to 

strengthen migratory bird conservation through enhanced collaboration and cooperation between the 

Forest Service and the Fish and Wildlife Service as well as other federal, state, tribal and local 

governments. Within the National Forests, conservation of migratory birds focuses on providing a 

diversity of habitat conditions at multiple spatial scales and ensuring that bird conservation is addressed 

when planning for land management activities.

Opportunities to promote conservation of migratory birds and their habitats in the Snow Basin project 

area were considered during development and design of the Snow Basin project (MOU Section C: items 1 

and 11 and Section D: item 3).

Likely impacts to habitats and select migratory bird populations resulting from the project have been 

assessed in detail within the Biological Evaluation (for sensitive bird species) and MIS sections of the 

Wildlife Specialist’s Report. These impacts are summarized below.

Existing condition

Neotropical migratory birds breed in temperate North America and spend the winter primarily south of 

the United States-Mexico border. Of the 225 migratory birds that are known to occur in the western 

hemisphere, about 102 are known to breed in Oregon. They include a large group of species, including 

many raptors, cavity excavators, warblers and other songbirds, with diverse habitat needs spanning nearly 

all plant community types and successional stages. Long-term population data on many of these birds 

indicate downward population trends although not all species populations are declining (Altman 2000).

Habitat loss is considered the primary factor in decline of neotropical migratory birds.

In 2000, the Oregon-Washington Chapter of Partners in Flight published its Northern Rocky Mountains 

Bird Conservation Plan (Altman 2000). The plan provides conservation recommendations for the various 

species of landbirds that occupy the Oregon and Washington portions of the Interior Columbia Basin. The 

plan identified the following priority habitats for landbird conservation: Dry Forest (primarily ponderosa 

pine), Mesic Mixed Conifer (primarily late-successional), riparian woodland and shrubland, and unique 

habitats including alpine and subalpine forests, shrub-steppe, montane meadow and aspen habitats. For 

the Snow Basin Project, dry forest, mesic forest, subalpine forest, and aspen are applicable. Effects to 

riparian woodland and shrubland are not displayed due to the lack of proposed treatment within these 

vegetation types. Table 90 displays applicable habitats of conservation focus, associated focal species, 

vegetation structure characteristics, and considerations described by Altman (2000).
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Table 90. Habitat relationships and biological objectives for focal landbird species, conifer forest 

Conservation 

Focus

Focal 

Species

Key Habitat Relationships

Vegetative Vegetation Structure Patch 

Size Special Considerations

DRY FOREST

Large patches 

of old forest 

with large 

trees and 

snags

Whiteheaded 

Woodpecker

Ponderosa 

pine

>10 tpa > 21 in DBH 

with > 2 trees >31 in 

DBH; 10-40% canopy 

closure, > 1.4 snags/ac 

>8 in DBH with > 50% 

>25 in DBH

> 350 

ac or > 

700 ac

Patch size is smaller for 

old-growth forest

Old Forest 

with grassy 

openings and 

dense thickets

Flammulated 

owl

Ponderosa 

pine, 

Douglas-fir

>10 snags/100 ac >12 

in DBH and >6 feet tall; 

> 8 tpa >21 in DBH

>350 

ac

Thicket patches for 

roosting; grassy 

openings for foraging

Open 

understory 

with 

regenerating 

pines

Chipping 

sparrow

Ponderosa 

pine, 

Douglasfir, grand 

fir

10-30% canopy 

closure, 20-60% shrub 

cover with >20% 

sapling cover, 

especially pines

Non-agricultural/ grazing 

landscape due to 

cowbird parasitism

Patches of 

burned old 

forest

Lewis’ 

woodpecker

Ponderosa 

pine 

>2% of landscape as 

post-fire old forest; 

>50% of post-fire 

landscape as 

unsalvaged.

Soft snags for 

excavation; pesticide 

spraying may reduce 

insect prey base

MESIC MIXED CONIFER (LATE-SUCCESSIONAL) FOREST

Large snags Vaux's swift Grand fir, 

Douglas-fir

Snags 27 in DBH and 

82 ft. tall, in different 

stages of decay 

(including some hollow 

snags

Recruitment snags (live 

trees) with signs of 

defect; proximity to 

riparian areas

Overstory 

canopy 

closure

Townsend's 

warbler

Grand fir, 

Douglas-fir

Late successional 

forest dominated by 

grand fir (Blue 

Mountains) and 

Douglas-fir (Glaciated 

Mountains): >50% 

canopy closure

>100 

ac

Structurally 

diverse; multilayered

Varied thrush Grand fir, 

Douglas-fir

Multiple tree layers 

with mixed species 

composition including 

>25% deciduous 

cover; high canopy 

closure

>75 ac

Area sensitive; avoids 

edges: needs dense leaf 

litter for foraging

Dense shrub 

layer -

understory or 

openings

MacGillivray's 

warbler Douglas-fir

Dense shrub layer 

dominated by native 

species with >40% 

cover and/or >270 

stems/ac; tree canopy 

closure <25%; 

herbaceous ground 

cover 25%

Cowbird host; extensive 

grazing detrimental
Chapter 3 Snow Basin Vegetation Management Project FEIS

257

Conservation 

Focus

Focal 

Species

Key Habitat Relationships

Vegetative Vegetation Structure Patch 

Size Special Considerations

Edge and 

openings 

created by fire

Olive-sided 

flycatcher

Grand fir, 

ponderosa 

pine

>2% of the landscape 

as post-fire forest; 

>40% of post-fire 

landscape as 

unsalvaged

Patches of mix of live 

and dead; pesticide 

spraying may reduce 

insect prey availability

SUBALPINE FOREST

Patches of 

subalpine 

forest with 

multi-layered 

structure and 

dense 

understory 

shrub layer

Hermit 

Thrush Spruce-fir

Livestock grazing can 

reduce understory 

density; species shows 

lower abundance in 

treated stands

ASPEN

Large trees 

and snags 

with 

regeneration

Red-naped 

Sapsucker Aspen

>10% cover of saplings 

in understory for 

replacement; >4 trees 

and >4 snags > 39 feet 

tall and 10 in DBH; 

mean canopy closure 

30-70%

Livestock grazing can 

reduce understory 

density; species shows 

lower abundance in 

treated stands

(Altman, 2000)

Dry forests 

Altman (2000) identifies four habitat components of the dry forest types that are important to landbirds 

are associated with open stand conditions. Large-scale declines in open stands, especially those with large 

trees, have raised concern for such species as the white-headed woodpecker, flammulated owl, whitebreasted nuthatch, pygmy nuthatch, Williamson’s sapsucker, and Lewis’ woodpecker.

Stands within the Dry Forest category are described as coniferous forest composed exclusively of 

ponderosa pine or dry stands co-dominated by ponderosa pine and Douglas-fir or grand fir (Altman 

2000). A total of 869 acres of single-storied large tree structure in dry forests currently exists within the 

Little Eagle and Eagle Creek-Paddy Creek subwatersheds (Table 91), comprising only 4 percent of total 

dry forest acres. About 65 percent of dry forest acres consist of multi-storied stands.

Late-successional mesic mixed conifer 

Altman (2000) describes the Mesic Mixed Conifer category as consisting of late-successional forest 

occurring mostly at higher elevations, wetter sites, northerly aspects, and where soils are mesic and welldeveloped. This type is composed primarily of cool moist Douglas-fir/grand fir, cool dry Douglas-fir, 

western larch, and occasional ponderosa pine. This habitat does not include sites that were historically 

ponderosa pine, but have transitioned to mixed conifer due to fire suppression and encroachment of other 

conifers.

Multi-storied large tree structure in the mesic mixed conifer forests currently totals 372 acres. As 

described above, northerly aspects at moderate to higher elevations fit within this category (Table 91).

Elevations that contain the majority of mixed mesic conifer stands are similar to those identified for 

American marten (above 4,700 feet). Currently, approximately 49 acres of multi-storied large tree 

structure in the mesic mixed conifer forests occur within the Snow Basin project area.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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The PIF Conservation Strategy (Altman 2000) identifies five habitat components of the moist forest types 

that are important to landbirds; large snags, overstory canopy closure, structurally diverse; multi-layered, 

dense shrub layer in openings or understory, and edges and openings created by fire. Large snags are 

present on the landscape, as described in the Primary Cavity Excavator section of the Wildlife Specialist’s 

Report beginning on page 93. Dense overstories and multiple canopied stands are currently abundant, due 

largely to the lack of fire disturbance. Burned habitat is lacking within the project area, but exists to the 

north and east of the project area. Shrubs appear to exist on aspects and soils that are capable of 

supporting them, similar to the shrub distribution on other parts of the WWNF. 

Species that utilized these special habitats include: Vaux’s swift, Townsends’s warbler, golden-crowned 

kinglet, red-breasted nuthatch and MacGillivray’s warbler. Bird species associated with this forest type 

have been adversely impacted primarily by the loss and reduction of late-seral conditions and structural 

elements such as snags (Altman 2000).

Table 91. Existing forest structure, Little Eagle and Eagle Creek-Paddy Creek subwatersheds

Forest Type Stand 

Initiation

Single 

Story Multi Story

Multi Story 

Large 

Trees 

Common

Single 

Story Large 

Trees 

Common

Subalpine 0 0 125 938 48

Mesic Mixed 

Conifer 152 189 1,181 372 0

Predominately 

Dry Conifer, but 

includes *Mesic 

Conifer on north 

aspects 

880 1,770 5,820 1,093* 278

Dry Conifer 90 499 1,092 324 144

Dry Conifer 407 2,633 4,233 1,836 447

Dry Conifer 9 6 100 53 0

1,538 

(6%)

5,097 

(21%)

12,551 

(51%)

4,616 

(19%) %) 

*Approximately 49 acres is categorized as Mesic Mixed Conifer in the “Predominately Dry Conifer” forest type.

Direct and indirect effects

Alternative 1

Current conditions would persist under alternative 1. Activities including timber harvest, prescribed fire, 

and transportation activities would not occur. Stand conditions would remain denser than those estimated 

to have existed historically in warm and dry forest types, with elevated risk of stand-replacement fire. 

Alternatives 2, 3, and 4 

Timber harvest and prescribed burning treatments conducted during the primary nesting season present 

the potential for direct impacts to neotropical migratory birds nesting in stands proposed for treatment.

Potential direct effects include individual mortality or displacement from nests during treatment. The 

degree of impact varies by alternatives and is best correlated with the number of acres treated, with 

Alternative 2 treating the most acres, followed by Alternatives 3 and 4, respectively.

Table 92 shows a list of 14 landbird species known to occur within or adjacent to the project area. It 

includes those identified by Altman (2000) as priority for Blue Mountains conifer and aspen, as well as 

those identified as priority for conifer, riparian, and aspen habitats within the Central Rocky Mountains 
Chapter 3 Snow Basin Vegetation Management Project FEIS

259

physiographic area (Partners in Flight 2010). The breeding season for landbirds in the Blue Mountains 

varies by species, but generally extends from mid-May to mid-August (Table 92), with the majority of 

nesting completed by late July. For cavity nesting species (8 total), project design features that retain 

snags except for safety reasons are currently incorporated into the project (See Appendix B-1), and 

mitigate the risk of direct impact to these species. No treatments are proposed under any alternative in 

subalpine conifer; therefore no impacts to hermit thrush are expected. Aspen restoration treatments on 38 

acres would remove competing conifers and provide overall benefit for aspen-associated species.

At higher elevations, such as those occurring in Snow Basin, an estimated 10 percent of timber harvest 

operations would occur during the winter period (12/15-2/15; J. Jesenko, pers. comm.). At these 

elevations, the summer operating season is likely to occur from July 1 to October 31, whereby impacts to 

birds nesting during May and June would be avoided. In addition, timber harvest operations in any given 

year would occur only within a portion of the analysis area. Potential impacts to nesting birds would be 

localized within a given timber sale area within the years of operation. Additional PDFs that include 

avoidance of known raptor nest sites also apply (see Appendix B-1).

The spring prescribed burning season on the WWNF normally occurs from mid-April to the end of May.

Fall prescribed burning generally occurs from October 1 through early November. The prescribed fire 

program has generally consisted of burning an estimated 50 percent of acres in the spring and 50 percent

of acres within the fall period (N. Livingston, pers. comm.). For spring burning, applications from April 

through mid-May are unlikely to impact the majority of nesting birds of concern. However, prescribed 

burning during and after the latter portion of May has the potential to directly impact nests and 

individuals, primarily young of the year. Sallabanks (no date) described the onset of ground-nesting birds 

as occurring after spring vegetation leaf-out and recommended completion of spring burning prior to leafout. Therefore, design features have been incorporated into the project that require district or forest 

wildlife biologist review of prescribed burning that extends past May 20, as well as passive lighting and 

means of reducing potential for consumption of larger snags and logs (see Appendix B-1).

Table 92. Landbird breeding periods and habitats

Species

Predominate 

Incubation 

Start 

(Oregon)

Predominate 

Fledging Period 

(Oregon)

Source Habitat

Blue Grouse (gn) Mid May Early August Marshall et al. 2003; Adamus 

et al. 2001 Conifer

Flammulated owl

(cn) Early June Mid August Bull and Anderson 1978 Conifer

Vaux's swift (cn) Mid June Early September Bull and Collins 1993 in

Marshall et al. 2003 Mesic conifer 

Calliope 

hummingbird (tn) Mid-late May Late July Marshall et al. 2003; Adamus et al. 2001 Riparian

Olive-sided 

flycatcher (tn) Early-mid June Late July Adamus et al. 2001 Mesic conifer

Williamson's 

sapsucker (cn) Mid May Late July Adamus et al. 2001 Aspen

Red-naped 

sapsucker (cn) Early June Late July Adamus et al. 2001 Aspen

Lewis's 

woodpecker (cn) Early May Late July/ early August

Marshall et al. 2003; Adamus 

et al. 2001

Dry conifer/ 

riparian woodland

White-headed 

woodpecker (cn) Mid May Late July Adamus et al. 2001 Dry conifer
Chapter 3 Snow Basin Vegetation Management Project FEIS

260

Black-backed 

woodpecker (cn) Late May Mid July Adamus et al. 2001 Conifer

Hermit thrush (gn, 

tn) Early June End of July/ begin. August Adamus et al. 2001 Subalpine conifer

Varied thrush (tn) Mid May Late July Adamus et al. 2001 Mesic conifer

Townsend's 

warbler (tn) Early June End of July/ begin. August Adamus et al. 2001 Mesic conifer

MacGillivray's 

warbler (gn, sn) Early June Late July Marshall et al. 2003; Adamus et al. 2001 Mesic conifer

(cn) Cavity nester; (gn) Ground nester; (tn) Tree nester; (sn) Shrub nester

Table 93. Silvicultural effects on single-storied large tree structure within warm, dry forest types in Little 

Eagle and Eagle Creek-Paddy Creek subwatersheds.

Single-Storied 

Large Tree 

Structure

Existing (acres) Post-Treatment 

(acres) Change in SSLT LOS acres (%)

Alternative 2 869 2,068 +1,199 (138%)

Alternative 3 869 1,920 + 1,051 (121%)

Alternative 4 869 1,883 +1,014 (117%)

Single-story 

Non-LOS Existing Post-Treatment Change in Single-story acres

Alternative 2 4,903 12,081 +7,178 (130%)

Alternative 3 4,903 10,975 + 6,072 (124%)

Alternative 4 4,903 10,951 +6,048 (123%)

In mesic mixed conifer multi-storied large tree structure stands, treatments under all action alternatives 

would retain existing multi-storied large tree structure, but some trees greater than 21 inch DBH would be 

removed under Alternatives 2 and 3. The number of larger trees being removed under Alternatives 2 and 

3 would not be enough to cause these stands from continuing to function as habitat for species associated 

with multi-storied large tree structure. Treatments in these multi-storied large tree stands would remove 

an estimated 13 acres (3 percent) under alternative 2 and about 8 acres (2 percent) under Alternatives 3 

and 4 (Table 94).

Table 94. Silvicultural effects on mesic mixed conifer multi-storied large tree stands in Little Eagle and 

Eagle Creek-Paddy Creek subwatersheds

Multi-Storied 

Large Tree 

Structure

Existing 

(acres)

PostTreatment 

(acres)

Change in MSLT 

LOS acres (%)

Alternative 2 421 408 -13 (3%)

Alternative 3 421 413 -8 (2%)

Alternative 4 421 413 -8 (2%)

Prescribed fire presents both negative impacts and benefits to dry forest focal conditions by potentially 

creating and removing (consuming) snags, maintaining openings, and removing dense understory conifer 

thickets and developing shrub layers. Application of passive lighting near snags during prescribed 

burning would reduce the potential for consumption of snags. Down logs would be maintained at or 

above levels prescribed in the LRMP (See Appendix B-1). Project Design Criteria that retain all decadent 
Chapter 3 Snow Basin Vegetation Management Project FEIS

261

grand fir are expected to retain habitat components for Vaux’s swift and roost trees for pileated 

woodpeckers. None of the treatments would remove patches of burned forest, but silviculture and 

prescribed fire reduce the potential for burned habitat within the project area. Duration of effects due to 

density reduction is expected to last 10 to 30 years.

All action alternatives propose vegetation treatments that would restore aspen on 38 acres, thereby 

providing localized benefits for associated species. 

Subalpine conifer will not be treated under any of the alternatives. Neotropical migratory species that 

utilize subalpine fir habitat would not be affected.

Cumulative effects

The following discussion focuses on those past, ongoing and reasonable foreseeable future activities that 

may contribute adverse effects to the landbirds or their habitat within the Eagle-Paddy and Little Eagle 

subwatersheds (see Appendix B). Effects of past activities including road construction, fire suppression, 

prescribed fire, and timber management on WWNF lands have been incorporated into the existing 

condition.

Alternative 1

The no action alternative would not contribute to cumulative effects since no active management would 

occur that would change habitat for migratory or resident birds. 

Alternatives 1, 2, and 3

Livestock grazing is expected to continue within the analysis area. Habitat improvements afforded by the 

action alternatives for chipping sparrow may also increase access of areas to livestock and brown-headed 

cowbirds. The potential for increase in nest parasitism is expected to be most pronounced in areas 

adjacent to existing cattle operations and agriculture on private lands along the southern boundary of the 

project area.

Timber harvest on adjacent private lands is expected to continue, with little availability of late and old 

forest structure and large snags anticipated. Therefore, habitat on National Forest lands will be 

increasingly important as habitat on private lands is reduced.

Summary of effects

All actions alternatives have the potential to directly impact NTMBs via nest tree removal during the 

nesting season. The level of impact is unknown, but potential is highest for alternative 2, and less for 

Alternatives 3 and 4, respectively. The no-action alternative averts direct impacts to NTMBs but 

maintains habitat conditions that favor high-density forest stands that may not be sustainable in the longterm. Implementation of PDFs reduces potential for direct impact to nesting landbirds.

The Partners in Flight Conservation Strategy applicable to the Blue Mountains (Altman 2000) describes 

dry forest habitats as among the most reduced habitat types in the Interior Columbia Basin, with available 

old forest, single-storied ponderosa pine reduced by 96 percent in the Blue Mountains. Fire suppression 

and extensive timber harvest has led to the shift from areas dominated by late-seral ponderosa pine to 

mid-seral stands of Douglas-fir and grand/white fir. The PIF Conservation Strategy stresses the 

importance of restoring open single-storied stands with large trees for conserving associated landbird 

species.

The action alternatives increase dry focal forest habitats by restoring single-storied structure at levels that 

reflect the range that existed historically, consistent with recommendations from Altman (2000), thereby 

benefiting landbirds associated with this habitat type. Alternative 2 would restore the largest amount of 

dry forest habitat, Alternatives 3 and 4 also restore habitat, but at slightly lower amounts in comparison to 
Chapter 3 Snow Basin Vegetation Management Project FEIS

262

alternative 2. Alternative 4 would retain more large trees, including ponderosa pine, due to retention of all 

trees greater than 21 inches DBH. However, alternative 4 would also retain grand fir and mistletoe 

infected Douglas-fir in stands for which ponderosa pine restoration is the emphasis, thereby perpetuating 

the condition of encroachment by mixed conifer species. 

All action alternatives would decrease available mesic mixed conifer late-successional habitat, with 

alternative 2 removing about 13 acres (3 percent) and Alternatives 3 and 4 removing about 8 acres (2

percent). Because mesic mixed conifer multi-storied large tree structure treatment units consists primarily 

of scattered small patches averaging just over one acre in size, it is unlikely that proposed activities will 

compromise overall function of existing habitats.

All action alternatives have the potential to increase nest parasitism by opening up forest stands and 

increasing available forage for livestock. Overall, with implementation of project design features (see 

PDFs, Appendix A), the project is consistent with managing for dry forest habitats as well as maintaining 

existing mixed mesic late-successional habitat. Effects of stand treatments are expected to last 10-30 

years.

Unique habitats

A number of species in the Blue Mountains are associated with special, unique habitats that include caves, 

cliffs, and talus. Due to the geology of the area, caves are generally lacking within the project area. Cliff 

habitats are present to a limited extent, mostly as short duration rock faces associated with larger streams.

Most prominent cliff habitat is found outside the project area in the mountains to the north. Talus fields 

are not known to occur, but may occur, within the project area.

Summary of effects

In general, unique wildlife habitats will be protected by maintaining vegetative structure characteristic of 

the edge inherent to these areas, including cliffs and talus (See Appendix B-1). There will be no 

differences in how unique habitats are addressed between alternatives. 

SALE AREA IMPROVEMENT PROJECTS

The following stand area improvement projects are identified to address some restoration needs in the 

Snow Basin project area. Effects to wildlife species or their habitats are discussed.

Snag Creation 

Overstory removal treatments (HOR) will retain a minimum of 16 over story trees per acre as green tree 

replacements for future snag habitat. The need to create snags from some of these live trees will be 

determined through monitoring immediately following implementation of the Snow Basin project. Snags 

may be created from some of these over story trees through topping with a chainsaw or through 

inoculation with heartrot fungi. Inoculation would only be considered for individual trees that do not 

show signs of already being infected with heartrot. Inoculation does not kill trees instantly, but rather 

slowly creates soft heart wood and may weaken the tree and predispose it to other agents that will lead to 

death. Inoculated trees often live for decades, but may start providing some functions of snags while parts 

of the tree are still alive. Topping with a chainsaw creates a snag immediately, but the snag may be of 

limited value to wildlife if heartrot or other defects did not exist prior to topping.

Direct and indirect effects 

Alternative 1

Green replacement trees will remain in HOR units in their existing numbers, and will eventually die of 

disease, insects, or fire. There are no direct effects from the no action alternative. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Alternatives 2, 3, and 4

Snags created from over story trees in HOR units would begin to function as nesting and foraging 

substrate for some primary cavity excavator species, and later by secondary cavity users. There are 951 

acres of HOR stands in alternative 2, 718 acres in alternative 2, and 547 acres in alternative 4. Snags may 

be created at a rate of approximately one snag per every two acres of HOR stands the respective 

alternative. This represents a relatively small positive effect to primary and secondary cavity users, but 

effects would be neutral to other wildlife species discussed in this report. 

Cumulative effects

Alternative 1

Snag creation will not take place under the no action alternative; therefore there will be no cumulative 

effects.

Alternatives 2, 3, and 4

The cumulative effects of creating approximately one snag for every two acres of HOR treatments will be 

exceedingly minor. An increase in snag habitat on these HOR units will provide a small amount of habitat 

for primary excavator species that prefer snags in open settings. This is a relatively small number of 

species that are considered common and wide spread. The creation of some snags will slightly offset the 

reduced natural snag recruitment in commercial thinning units.

Road Decommissioning 

Approximately 5.83 miles of road have been identified for decommissioning under the Snow Basin 

project. The decommissioning of these roads will contribute to security habitat for big game, increased 

retention of snag habitat, and increase available forage and cover for wildlife as vegetation recovers on 

these former road beds. The roadways will be seeded and in some cases planted with deciduous or conifer 

species. The focus of re-vegetation for wildlife will be to restore conifer tree species on portions of road 

that pass through conifer habitat. Re-vegetating these road beds will also reduce invasion of noxious 

weeds.

Direct, Indirect, and cumulative effects

Alternative 1 

Road decommissioning will not occur under the no action alternative, so there will be no direct, indirect 

or cumulative effects.

Alternatives 2, 3, and 4

Decommissioning of 5.83 miles of road will have a minor positive effect to elk and many other species of 

wildlife. The positive effects result from taking compacted road beds that support very little vegetation, 

and restoring them to fully vegetated conditions. This represents a small increase in available forage for 

big game, ground cover for overland movement of spotted frogs and other amphibians and small 

mammals, and a long-term reduction in sediment produced from these roads. 

The cumulative effects of decommissioning these roads is very minor, but combines with other past, 

present and reasonably foreseeable future projects to improve habitat for several species. The WWNF 

travel management plan reduces total road densities, and eliminates unregulated cross country travel. The 

positive, cumulative effects from travel management and the decommissioning of 5.83 miles of road 

enhances habitat for amphibians, elk, and cavity excavators through reduced disturbance and retention of 

snag and log habitat. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

264

Large Woody Material Additions to Streams 

Large woody material additions to streams large woody material will be added to about 7.5 miles of 

stream in the project area (Table 95). Stream segments that would benefit from additional LWD were 

selected based on stream survey information and professional opinion (Paul Boehne, WWNF Forest 

Fisheries Biologist). The sources of LWD will be from off site locations outside of RHCAs (e.g. conifers 

removed as part of aspen stand treatments, wind-thrown trees). The additional LWD would be placed in 

accumulations greater than 4 pieces. Each accumulation will contain at least one key piece (length > 

bankfull width, or > 12 inch diameter and > 35 feet in length; whichever is largest) with rootwad attached. 

Accumulations will span no more than 50 percent of the bankfull width of the stream channel. No cabling 

or rebar anchors will be used. Instead, stability of the LWD accumulations will rely on use of key pieces 

and placement. Placement of LWD will occur with an excavator and will occur during the in-water work 

window (July 1 – October 31). The actual site designs will be completed prior to implementation of this 

activity.

Table 95. Additions of large wood to streams in the Snow Basin project area

Stream Miles Reach

Little Eagle Creek 3.0 Mouth to Forks

Paddy Creek 2.5 Mouth to Lost Cabin Creek

Holcomb Creek 2.0 on either side of PVT Land

Direct and indirect effects 

Alternative 1

The no action alternative will result in no effects to wildlife or wildlife habitat since large woody material 

will not be placed in streams to restore fish habitat and stream function. 

Alternatives 2, 3, and 4

Placement of additional large wood in Little Eagle Creek, Paddy Creek and Holcomb Creek will improve 

channel stability, sediment storage, and aquatic habitat. Short-term increases in fine sediment downstream 

of the activity sites will occur as the result of streambed and bank scour. However, these short-term 

increase are likely to be immeasurable as they will occur during high flow events.

The improvements in stream channel stability, sediment storage and aquatic habitats will also improve 

conditions for spotted frogs and a variety of wildlife species that utilize riparian areas. Since the large 

wood will come from upland areas that have an excess of large wood, and the total number of logs needed 

for this work is relatively small, there will be no measurable effects to upland habitats by the removal of 

this material.

Cumulative effects

Alternative 1 

There will not be cumulative effects from the no action alternative.

Alternatives 2, 3, and 4

Essentially the addition of large wood to these streams will begin to mitigate past effects of management 

that removed large wood and the reduced the source of down wood in some stream reaches. INFISH 

RHCAs are considered adequate to moderate the effects of upslope management activities, so the addition 

of large wood does not represent a cumulative or incremental effect when considered with other parts of 

the Snow Basin project.
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Eagle Creek Wild and Scenic River Corridor

Management activities are proposed within the Eagle Creek Wild and Scenic River Corridor under all 

action alternatives. Timber harvest treatment amounts for alternatives range from 370 acres (alternative 2) 

to 261 acres (Alternative 3) and 212 acres (alternative 4) of commercial thinning treatments that retain a 

full stocking of trees. In addition, all action alternatives would implement prescribed fire-only treatments 

ranging from 1360 acres under alternative 2 to 565 acres under Alternatives 3 and 4 within the Corridor.

Standards and guidelines specific to the area are stated in the Eagle Creek Wild and Scenic River Corridor 

Plan (USDA Forest Service 1993) and incorporated into the Wallowa-Whitman National Forest Land and 

Resource Management Plan (LRMP). Those pertaining to wildlife in addition to standards and guidelines 

applicable under LRMP are described below. Consistency review of proposed activities under Snow 

Basin is provided for each standard and guideline.

• Improvement projects for protection, conservation, rehabilitation, or enhancement of wildlife 

habitat may be pursued when not in conflict with Outstanding Remarkable Values (ORV).

Consistency: The Snow Basin project does not propose wildlife habitat improvement projects 

within the Wild and Scenic River Corridor. The project is consistent.

• Dead and down trees and snag habitat will be managed to provide or maintain 100 percent of the 

potential population level for all primary cavity excavators. The 100 percent level is defined in 

the LRMP.

Consistency: The Snow Basin project would retain existing snags, except to provide for safety.

Snag densities within the Corridor are expected to be similar to the project area as a whole where 

densities are estimated at over 3 snags per acre. Managing for 100 percent optimal population 

potential for cavity nesters equates to 2.25 snags per acre. Minimum coarse wood retention would 

be consistent with levels identified by Regional Forester’s Forest Plan Amendment #2 (Table 23).

The project is consistent.

• Actively manage for bald eagles and peregrine falcons. Over time, quality habitat will be 

maintained or increased for PETS species, with no reductions in PETS wildlife populations or 

habitats.

Consistency: Direct, indirect, and cumulative effects for bald eagle and peregrine falcon are 

analyzed in the Sensitive Species section of this report. No known active nesting occurs within 

the project area, including the Wild and Scenic River Corridor. Commercial thinning and fuels 

treatments proposed within the Corridor are expected to enhance development of future bald 

eagle nest trees and decrease risk to insect or wildfire disturbance, thereby benefiting bald eagle 

habitats. No potential peregrine falcon nesting habitat is known to occur within the Corridor, and 

proposed treatments are expected to have no impact on peregrine falcon habitats. The project is 

consistent. 

Habitat and Predicted Climate Trend

Gecy (2009) reviewed climate data for the Blue Mountains, and reports that the most notable trends 

consist of decline in winter precipitation and increase in winter and spring temperatures, are the most 

notable features of the data reviewed. The assessment states that continuation of these two trends could 

result in a number of potential adverse effects, including, but not limited to:

• Continued increase in the percentage of winter precipitation that occurs as rain, rather than snow.

• Earlier snowmelt.

• Extended growing seasons, resulting in lower soil moisture, and increased late-season moisture 

stress on vegetation.

• Earlier and longer fire seasons and higher likelihood of severe fire behavior.
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• Changes in vegetation patterns, species distribution, and species composition, and corresponding 

changes in the composition and distribution of wildlife habitats.

• Changes in the seasonal distribution of streamflow.

• Increased potential for higher flood peaks as well as more extended droughts.

Initial examination of available data indicates that changes in temperature and precipitation are not 

occurring evenly within the Blue Mountains (Gecy 2010). Direct and indirect effects of the long-term 

changes listed above are, therefore, uncertain due mainly to variations in climate trend at the local level.

Generalized implications to species’ habitats in Snow Basin are provided below.

For species known to PETS and MIS species known to occur or potentially occurring within the project 

area, the environmental implications listed above could mean long-term decreases in habitat available to 

species associated with alpine environments, as well as subalpine, and mesic forest associations. The list 

of species would include California wolverine, American marten, and three-toed woodpecker. As 

available moisture decreases and average temperatures increase, available snowpack may decrease, which 

could impact the wolverine by decreasing denning habitat, food sources, and dispersal ability (Brodie and 

Post 2010). The trend may also suggest a decrease or elevational shift in availability of mesic forest 

stands due to decreased moisture and increased potential for severe fire behavior.

Under alternative 1, no proposed management activities would occur. Current condition of habitats within 

the project area in warmer and drier biophysical settings is moderately or highly departed from historical 

condition, with increased risk to uncharacteristic disturbance events. Long-term decrease in available 

moisture and increase in susceptibility to disturbance increases risk and decreases potential for 

sustainability of green overstory forest components that provide habitat for most species considered in 

this analysis.

All action alternatives would reduce risk of disturbance, limit the extent and severity of future 

disturbance, and allow maintenance of these conditions with periodic fire. Tree species composition and 

stand/landscape structure at reduced densities creates favorable conditions now and for the predicted 

warmer and dryer climate (see Snow Basin Silviculture Report). Long-term sustainability of habitats for 

species relying on green forest vegetation in open and moderately-dense condition would be favored if 

these conditions are maintained through time. Density reductions and prescribed fire treatments would 

reduce susceptibility to large-scale disturbance, at least in the short-term (20 years), creating potential 

long-term reductions in habitats available to species associated with disturbance events, particularly 

black-backed woodpecker. Long-term response of habitats is difficult to predict and would largely depend 

on the amount of forested area treated in future decades to maintain lower risk to disturbance.

White-headed Woodpecker Nest Site

Ensure that the known white-headed woodpecker nest tree is protected during implementation of 

prescribed fire-only treatments in Unit RXF-10. Also, conduct prescribed fire treatments within Unit 

RXF-10 outside the nesting season (after July 31), unless the nest tree is known to be unoccupied.

Goshawk Nest Site

A portion of unit 50 and unit 124 in its entirety are deferred from harvest to provide a 30 acre nest area for 

a known goshawk nest. 

Goshawk PFA

Under burning and prescribed fire-only treatments within the goshawk PFA will be implemented outside 

the nesting period (after July 31).

Regeneration silvicultural prescription originally proposed for units 124 and 125 are deferred from 

harvest.
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Canopy closure in the portion of Unit 50 occurring within the delineated goshawk PFA will be 

maintained at a minimum of 60 percent.

Goshawk surveys

To determine goshawk nesting status within areas where goshawks were detected previously, conduct 

goshawk surveys within units 48, 50, 51, 87, 420, 422, and 423 prior to implementing timber harvest or 

prescribed fire-only treatments. If goshawk nesting is confirmed, apply appropriate mitigation measures 

identified in the Forest Plan Amendment #2.

Pileated Woodpecker Nest Site

Ensure that the known pileated woodpecker nest tree is protected during implementation of prescribed 

fire-only treatments in Unit RXF-34. Also, conduct prescribe fire treatments within Unit RXF-34 outside 

the nesting season (after July 31), unless the nest tree is known to be unoccupied.

Snags

All snags will be retained unless identified as posing a safety hazard.

Snags felled for safety reasons will be retained onsite to contribute to coarse wood where coarse wood 

amounts are deficient.

Down Woody Material

Where material is available, all treatment units (harvest and prescribed burn) will exceed the minimum 

levels for down woody material described in the table below for each species:

Table 96. Downed woody Material by species and size

SPECIES PIECES PER 

AC

PIECE LENGTH AND SMALL END 

DIAMETER TOTAL LINEAL 

LENGTH

Diameter Min Length

Ponderosa Pine 3-6 12" 6 ft 20-40 ft

Mixed Conifer 15-20 12" 6 ft 100-140 ft

Lodgepole Pine 15-20 6" 8 ft 120-160 ft

Green Tree Replacements (GTRs)

In addition to the guidelines for logs and snags, sufficient green trees of adequate size are to be retained in 

harvest units to provide replacements for snags and logs through time via natural mortality. Generally 

GTRs need to be retained at a rate of 16 to 74 trees per acre, depending on biophysical group. All harvest 

prescriptions in the project would retain GTRs within or above this range.

Raptors

Any raptor sightings or active raptor nests observed during reconnaissance, layout, marking, or project 

activities will be reported to the Unit Wildlife Biologist for further assessment and potential mitigation 

associated with project activities.

Big Game Winter Range

Logging operations in Big Game Winter Range will be conducted outside the period between December 

15 through April 30.
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Landbirds and Neotropical Migratory Birds

To reduce the potential for loss of snags during prescribed burning, employ passive lighting techniques 

near snags larger than 12 inches. Techniques include lighting at a slope position above snags, and avoid 

lighting directly adjacent to or at slope positions directly below snags. For larger snags (> 20 inches 

DBH) at higher risk due to heavy fuels accumulations at the base, pullback of fuels may be necessary 

prior to prescribed burning.

Landbirds and Neotropical Migratory Birds

To reduce the potential for impacts to nesting landbirds, prescribed burning activities projected to occur 

on or after May 20, and/or past the onset of vegetation leaf-out, will be reviewed by a district or forest 

wildlife biologist. The biologist will then provide recommendations concerning prescribed burning after 

May 20 and/or past the onset of vegetation leaf-out.

Cavity-nester/Denning Habitat

All cull grand fir will be retained within treatment units. 

Connectivity

All treatments within identified connectivity corridors will maintain canopy closure within the top 1/3 of 

site potential, where overstory canopy closure is maintained above 40 percent within Dry Forest PVGs 

and above 50 percent within Moist and Cold Forest PVGs. This will be accomplished through the 

retention of basal area as described in Appendix B of this Wildlife Specialist’s Report. 
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THREATENED, ENDANGERED, AND SENSITIVE PLANT SPECIES

This section evaluates the Pacific Northwest Region regional forester’s sensitive species (January 2008,

http://www.fs.fed.us/r6/sfpnw/issssp/agency-policy) and federally threatened, endangered, or proposed 

species known or with potential to occur on the Wallowa-Whitman National Forest. Although the 

regional forester updated the special status species list on December 9, 2011, projects initiated prior to 

this date may use the list that was in effect at the time of the project initiation (USDA Forest Service, 

2011). 

Regulatory Framework

Forest Service objectives for threatened, endangered, proposed, and sensitive species (FSM 2672.41) are 

to:

• Ensure that Forest Service actions do not contribute to the loss of viability of any native or 

desired non-native plant animal species or contribute to trends toward federal listing of any 

species.

• Comply with the requirements of the Endangered Species Act that actions of federal agencies not 

jeopardize or adversely modify critical habitat of federally listed species.

To meet Forest Service objectives for sensitive species, one of the following determinations, as analyzed 

through the biological evaluation, must be found for each sensitive species, or its habitat, that may be 

affected by the project (USDA Forest Service, 1995): 

• “No impact”

• “Beneficial impact”

• “May impact individuals or habitat, but will not likely contribute to a trend towards federal listing 

or cause a loss of viability to the population or species.” Activities or actions that have effects that 

are immeasurable, minor, or are consistent with conservation strategies would receive this 

conclusion.

For populations that are small or vulnerable, each individual may be important for short- and long-term 

viability. The loss of individuals or habitat can be considered significant when the potential effect on a 

species may:

• Contribute to a trend toward federal listing

• Result in a significantly increased risk of loss of viability to a species

• Result in a significantly increased risk of loss of viability to a significant population

If the project analysis concludes that impacts to individuals of a sensitive species would result in any one 

of these three conditions, then the appropriate finding is, “will impact individuals or habitat with a 

consequence that the action may contribute to a trend towards federal listing or cause a loss of viability to 

the population or species.” This finding would not be consistent with Forest Service objectives for 

sensitive species. 

Methodology and Measurement Indicators

The direct, indirect, and cumulative effects analysis area is equivalent to the project area boundary. The 

actions proposed within the project area boundary would not affect federally listed or regional forester 

sensitive species beyond the project area boundary.

The anticipated project effects of each alternative were evaluated in the biological evaluation (available in 

the project file) and a determination of “no impact”, “beneficial impact”, or “may impact individuals or 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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habitat, but will not likely contribute to a trend towards federal listing or cause a loss of viability to the 

population or species” was reached for each sensitive species known to exist or have suitable habitat 

within the project area. In situations where individual plants of a species may be affected by project 

activities, no standard exists by which to compare anticipated levels of impact before crossing the 

threshold where a loss of viability to the species or significant population would be expected. Professional 

judgment is used to analyze whether the magnitude of effects are immeasurable, minor, or rise to the level 

of significant loss of species or population viability. 

Existing Conditions

One threatened plant is known to occur in Baker County, Thelypodium howellii ssp. spectabilis (Howell's 

spectacular thelypody), which is confined to alkaline flats of the Powder River valley between Baker City 

and North Powder, Oregon. Habitat for Thelypodium howellii ssp. spectabilis is not present in the project 

area, and there would be no effect the species.

The Forest Geographic Information System, rare plant data base, and district files were examined to 

identify whether any threatened, endangered, or sensitive plants or potential habitat are known in or near 

the project analysis area boundary. Based on the available information, the analysis area contains suitable 

habitat for the sensitive plants listed below in Table 97.

Table 97. Sensitive plants suspected to have suitable habitat within the Snow Basin analysis area

Achnatherum wallowaensis Botrychium pedunculosum Lycopodium complanatum

Botrychium ascendens Calochortus macrocarpus var. 

maculosus Pellaea bridgesii

Botrychium campestre Carex cordillerana Phacelia minutissima

Botrychium crenulatum Carex retrorsa Phlox multiflora

Botrychium lineare Cheilanthes feei Platanthera obtusata

Botrychium lunaria Cypripedium fasciculatum Schistidium cinclidodonteum

Botrychium minganense Eleocharis bolanderi Tortula mucronifolia

Botrychium montanum Encalypta intermedia Trifolium douglasii

Botrychium paradoxum Jungermannia polaris

The biological evaluation (project file) includes an assessment by Duncan Thomas, Ph.D., (who was 

contracted to perform sensitive plant surveys in the project area) as to the degree of likelihood of these 

species occurring in the analysis area.

Field surveys

Field surveys for sensitive plants were conducted under three earlier projects in addition to surveys 

specific to the Snow Basin project. Three vegetation management projects have occurred within the Snow 

Basin analysis area. Intuitive controlled and intensive surveys were completed in the analysis area for 

three projects during the 1990s (Eagle Creek-Paddy, 1992; Eagle Creek Holcomb, 1996; and Little Eagle, 

1996). Descriptions of the survey methodology and results are included in the biological evaluations for 

these projects (included in the Snow Basin project file). For these projects, the 1991 regional forester’s 

sensitive plant list was used. Approximately 2,350 acres were surveyed during the 1990s, resulting in the 

documentation of several populations of Mimulus clivicola and Ranunculus oresterus, species no longer 

listed sensitive by the regional forester. In the period following these projects, the sensitive plant list was

revised, with several plant species being added while others were removed. Of the species on the 2008 

regional forester’s sensitive plant list identified as having the potential to occur in the analysis area, six 

were not considered in the earlier project’s biological evaluations: Carex cordillerana, Carex retrorsa, 

Encalypta intermedia, Jungermannia polaris, Tortula mucronifolia, and Schistidium cinclidodonteum.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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The 2008 regional forester’s sensitive plant list was used to conduct additional sensitive plant surveys 

during the summer of 2008 for the Snow Basin Vegetation Management project. Survey units were 

identified based on the location of proposed ground disturbing activities and areas with suitable habitat

for sensitive plants, as estimated from aerial photography. Fifteen proposed aspen restoration sites were

also included in survey maps. The total area surveyed was approximately 3,000 acres. The surveys were 

conducted by Enviro Consultants, Duncan Thomas, Ph.D., between July 9, 2008 and August 11, 2008, 

with approximately 200 hours spent in the identified areas. The intuitive, random meander (Nelson, 1985) 

was used during to conduct the surveys. With this method, the surveyor meanders throughout the area 

honing in on suitable habitat for plant species of interest. The intuitive meander is the Forest Service

standard for rare plant surveys and, as applied to this analysis area, is considered adequate to detect the 

target species. The intuitive meander was also used to survey the proposed prescribed fire units, but at a 

lower intensity, as prescribed fire poses a smaller risk of impacting rare plant habitats. Areas within 

RHCAs were surveyed at a low-intensity as there are very limited treatments proposed within them.

Although not every acre of every treatment unit was surveyed, the design was commensurate with the 

perceived level of risk of impacting the target species with treatment activities. Survey areas were 

selected to represent a proportion of suitable habitat in the analysis area among proposed timber 

management treatments. Approximately 20 percent of the acres proposed for commercial harvest and 

approximately 10 percent of the acres proposed for prescribed fire were surveyed. These surveys resulted 

in the discovery of eight new occurrences of Carex cordillerana. Table 98 summarizes data for each C. 

cordillerana occurrence and its proximity to proposed activities.

Table 98. Carex cordillerana occurrences in the Snow Basin project area

Site Name 

Number 

of 

plants

Number of 

subpopulations Proximity to Proposed Activities

Holcomb CreekCARCOR-1

(CAREX 

CORDILLERANA)

540 10

9 of the 10 patches located in harvest units 40, 41, 44, 45, 

100, 101. Plants are mostly in draws on lower slopes but also 

on mid-slopes in partial shade. Coniferous cover-30%; 70+% 

shrubs and forbs.

Little EagleCARCOR-2 240 2

One patch in prescribed fire (RxF) unit 30; one patch along 

edge and harvest units 11, 13. 20% coniferous coverage, 

80%+ shrub and forb cover.

Holcomb SpringCARCOR-3 20 1 On edge of large opening in RxF unit 13A; with 60% aspen 

cover, 55+% shrub/forb cover.

Holcomb SpringCARCOR-4 250 3

One patch between RxF 20 and harvest unit 109; second 

patch between RxF 19 and harvest unit 107; third patch 

between RxF unit 19 and harvest unit 142. 50% coniferous 

cover 70+% shrubs and forbs.

Spring CreekCARCOR-5 9 1 Located on Spring Creek, with half situated in harvest unit 57; 

45% coniferous cover, 25+% shrubs and forbs. In RHCA.

Little Eagle 

CARCOR-6 240 1 Located in harvest thinning unit 18 and RxF unit 1 along forest/grassland boundary. 

Lily WhiteCARCOR-7 600 1

Mostly in RxF unit 12; edge of population falls in skyline unit 

321. 10% coniferous cover, 85+% cover shrubs/forbs. In 

RHCA.

CARCOR-8 10 1

Tractor harvest unit 39; shaded PSME/SYAL/CARU-CAGE 

community. Wooded draw on ecotone between steppe and 

forest.

Across the Wallowa-Whitman National Forest there are 49 occurrences of Carex cordillerana. Eight 

occurrences are within the Snow Basin analysis area, where C. cordillerana populations were found 

growing in the following habitats:
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• West and east slopes of draws; mostly in the lower slopes but also mid-slope

• Dense shrub cover (average 60+ percent) with intermixed bare patches

• Light canopy cover (average 35 percent) of ponderosa pine and Douglas-fir;

• Dry grassland ridges and found in dry draws along the forest/grassland ecotone

• Aspen groves;

• Edges of Douglas hawthorn patches

Carex cordillerana occurrences were found underneath forest canopy and along the transition between 

grasslands and forest. The principal investigator for the project surveys, Duncan Thomas observed that 

these populations are probably declining from being overgrown. Thomas speculates that the species 

regenerates well after a disturbance, especially fire, and then declines in vigor as mature forest vegetation 

establishes, overgrowing the plants, thereby decreasing light and increasing competition for water.

Carex cordillerana occurrences were found predominately in three plant associations: Douglasfir/snowberry, grand fir/snowberry, and ponderosa pine/snowberry. The planning area contains 

approximately 13,850 acres of these plant associations (with 1,200 acres on privately deeded in-holdings), 

which provide the most likely suitable habitat for C. cordillerana. Approximately 13 percent of these 

plant associations were surveyed. Although these plant associations are common throughout the project 

area, not every acre within these communities necessarily provides suitable habitat for C. cordillerana. If 

additional occurrences are present in areas not surveyed, C. cordillerana would be most likely be found in 

small patches within these communities, in settings similar to where the species was detected in the 

analysis area: under the forest canopy in draws and along the forest-steppe ecotone.

Survey units 78, 126, 128, 142, and 156 were noted with potential Botrychium habitat. No Botrychium

species were found and no other sensitive plant species were detected during field surveys.

Based on the field surveys, habitat for Calochortus macrocarpus var. maculosus, Eleocharis bolanderi, 

Lycopodium complanatum, and Phlox multiflora is considered highly unlikely to occur in the project 

analysis area. Therefore, these species are presumed not present and project effects to these species are 

not further discussed.

Survey records, aerial photos, and sketch maps are included in the project file. 

Effects Analysis

Endangered and Threatened Species

The U.S. Fish and Wildlife Service provides species lists for actions carried out, funded, or authorized by 

Federal agencies via the Internet at: http://www.fws.gov/oregonfwo/Species/Lists/RequestList.asp. The 

species list fulfills the U.S. Fish and Wildlife Service's requirement, under section 7(c) of the Endangered 

Species Act of 1973, as amended (16 U.S.C. 1531 et seq.), to provide a list of threatened and endangered 

species upon request for Federal actions and National Environmental Policy Act (NEPA) compliance

(USDI FWS 2012). One threatened plant, Howell’s spectacular thelypody (Thelypodium howelli var.

spectabilis) is listed to occur in Baker County, Oregon.

Howell’s spectacular thelypody grows in relatively moist, alkaline meadows in or adjacent to valley 

bottoms of the Powder River in Baker County, Oregon. This plant’s range-wide distribution is limited to

private and Baker County lands near North Powder, Haines, and Baker City, Oregon (USFWS, 2002). 

The nearest populations of Howell’s spectacular thelypody are approximately 28 miles west of the 

analysis area. Suitable habitat for the species does not exist in the Snow Basin Vegetation Management 

analysis area.

Because habitat or populations of Howell’s spectacular thelypody does not exist in the analysis area, the

project would have no effect to this federally listed threatened species. 
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Regional Forester's Sensitive Species

Carex cordillerana (cordilleran sedge)

Carex cordillerana is a small, tufted sedge that grows in upland plant communities and forested stream 

terraces. It resembles a bunch-grass in appearance, about 6 to 14 inches tall, flowers during spring, and 

fruits in early summer. Fire suppression has been implicated in its scarcity, because competing vegetation 

has been observed to overgrow the plant in its habitat. Duncan Thomas (Carex Working Group, 2008) 

noted that following a fire, C. cordillerana can regenerate in the light soil throughout a draw. The plants 

thrive for a few years but are gradually crowded out by other understory plants, including C. geyeri and 

low shrubs. The population persists longest along the forest-grassland ecotone, where light may be more 

available. Decades of fire suppression may have adversely affected the abundance of C. cordillerana, 

although the species may be more abundant on the Wallowa-Whitman National Forest than records 

suggest. Wilson and others (2008) report that livestock grazing may also have affected the abundance of 

C. cordillerana because many plants are found in areas less suited to grazing, such as rocky sites, or 

under the protective cover of dense shrub canopy.

Direct and indirect effects

Alternative 1 – No Action 

Under Alternative 1, no activities would occur. Both known sites and possible undetected occurrences of 

Carex cordillerana would not be impacted by project activities. Given that lack of fire has been 

implicated in the species’ decline, continued overgrowth of competing vegetation may threaten this 

species’ ability to sustain itself in the project area in the long-term. 

Alternatives 2, 3, and 4

All 8 of the Carex cordillerana occurrences are within or adjacent to proposed activity units under 

Alternatives 2, 3, and 4, which include timber harvest, pre-commercial thinning and prescribed fire. 

While little information is available on the effects of logging or prescribed fire on Carex cordillerana, in 

the absence of mitigating actions, mechanical damage from tree felling, skidding, decking, and slash 

piling likely would severely impact populations. An indirect effect of harvest could be that opening of the 

canopy through harvest could have beneficial effects on this species allowing more light penetration. 

Similarly, the reduction of competitive vegetation through prescribed fire is also expected to benefit the 

species. 

Carex cordillerana sites CARCOR-1, CARCOR-2, CARCOR-3, CARCOR-4, CARCOR-6, and 

CARCOR-8 (Table 98) are located within or adjacent to proposed commercial harvest units and are at 

risk of being damaged or uprooted by skidding, skid trail construction, mechanical piling, and burning. To 

protect sensitive plant species, known population locations will be excluded from ground disturbing 

treatments by implementing a no-disturbance buffer, adequate to provide protection from implementation 

impacts, around each site (mitigation measure BO-1). Buffer size would be based on evaluation of the 

population and its particular location. Known occurrences will be depicted as “areas-to-protect” on 

implementation maps. These areas will be identified on the ground as needed for project implementation.

Carex cordillerana sites CARCOR 2, CARCOR-3, CARCOR-6, and CARCOR 7 are located within or 

adjacent to prescribed burning units. Although the species may benefit from the reduction by fire of 

competing vegetation, there is a risk of damage or of uprooting of plants through fireline construction 

prior to burning. Known occurrences will be depicted as “areas-to-protect” on implementation maps and 

will be identified on the ground, as needed for project implementation. Prescribed fire would not be 

ignited within the RHCA, but fires ignited outside the RHCA would be allowed to burn down slopes into 

them. A creeping, backing prescribed fire would reduce competing vegetation, increasing nutrient and 

water availability, thereby benefitting the species. A low intensity fire may impact the species, but given 
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its shallow rooting nature, accumulations of fuel on top of plants would likely prove lethal. The piling of 

fuels and slash and construction of control lines through Carex cordillerana sites would be avoided

(mitigation BO-1), thereby preventing mechanical damage.

Carex cordillerana site CARCOR-5 is located adjacent a timber harvest unit, but is situated entirely 

within the RHCA and would be avoided by timber harvest and associated activities. Prescribed fire would 

not be ignited within the RHCA, but fires ignited outside the RHCA would be allowed to burn down

slopes into them. A low intensity fire is not anticipated to impact the species, as explained above; 

however, given its shallow rooting nature, accumulations of fuel on top of plants would likely prove fatal.

It is likely that additional Carex cordillerana occurrences exist undetected in suitable habitat elsewhere in 

the analysis area, particularly in timber harvest and prescribed fire units in the central and southern

portion of the analysis area. Impacts to C. cordillerana could occur where timber management actions 

intersect with suitable habitat. Although light ground disturbance could benefit this species, the felling or 

skidding of trees across undetected occurrences is likely to impact individual plants. Under Alternative 2, 

timber harvest and thinning activities are proposed on approximately 6,800 acres within plant associations 

that provide suitable habitat for Carex cordillerana (54 percent of the suitable habitat on NFS lands). 

Alternatives 3 and 4 propose about 6,500 and 6,200 acres (51 and 49 percent of suitable habitat), 

respectively, of timber and vegetation treatments. However, any impacts to undetected occurrences of 

Carex cordillerana are not expected to lead to a loss of population viability of the species in the project 

analysis area, because: 1) the several known occurrences in the project area would be protected from the 

effects of timber harvest and the piling and burning of activity fuels; 2) nearly half the suitable habitat on 

NFS lands exists outside timber harvest and thinning units and would not be affected by the project; and 

3) suitable habitat within activity units would not likely impact every individual of Carex cordillerana, if 

present, because thinning actions would not disturb 100 percent of the ground cover. Although this last

factor would contribute less to conserving C. cordillerana, some plants would likely emerge unscathed, 

capable of colonizing disturbed areas. For these reasons, none of the thresholds triggering a trend to 

federal listing, or a significant risk of a loss of species or population viability would be reached. 

Prescribed fire would benefit suitable habitat and undetected C. cordillerana occurrences in the long term 

by reducing competing vegetation (Carex Working Group 2008). Alternative 2 would prescribe fire on 

1280 acres within plant associations that provide suitable habitat for Carex cordillerana (about 10 percent 

of the suitable habitat on NFS lands). Alternatives 3 and 4 would prescribe fire on about 1,530 acres (or 

12 percent of the suitable habitat on NFS lands).

The differences in effects to Carex cordillerana between alternatives is relatively small. Each alternative 

would protect the known populations of C. cordillerana. The effects to suitable habitat and possible 

undetected occurrences of C. cordillerana differ only slightly between alternatives. Alternative 4 would 

have (slightly) fewest impacts from timber and vegetation management, while proposing slightly more 

acres of prescribed fire in C. cordillerana suitable habitat, a potential benefit. In the short-term, 

Alternative 1 has no direct effects, but probably more indirect effects to the population viability in the 

long-term. Alternatives 2, 3, and 4 have more short-term effects but fewer long-term effects to the 

species’ population viability in the analysis area.

Cumulative effects

The known Carex cordillerana occurrences are within an active grazing allotment, Eagle Valley C&H. 

The species has been observed to be grazed by livestock in other areas of the forest. Grazing impacts 

could occur if the timing of grazing was during late spring or early summer. It is possible that Snow Basin 

project activities such as harvest and prescribed burning could open up suppressive vegetative cover and 

promote the plant’s growth, abundance, and vigor; as well as making plants more available to livestock. 

This indirect effect could increase grazing pressure on the plant thereby creating an increased net 

cumulative effect, although it is not possible to quantify the degree of this effect. As an activity within the 
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control of grazing allotment administration, the timing of grazing can be incorporated into annual 

operating instructions if monitoring indicates an adverse impact.

Other possible events within the analysis area such as severe wildfire or ongoing activities like recreation 

and fuel wood gathering have the potential to impact the Carex cordillerana populations and habitat, thus 

cumulative impacts are possible. Impacts from these actions are expected to be low, as recreation impacts 

have not been noted in the past and the area would serve poorly for fuelwood gathering. The reduction in 

fuels and competing vegetation from prescribed fire in around Carex cordillerana occurrences may help 

reduce the severity of impact from wildfire that may occur in the next 10 to 20 years. 

Previous harvest actions in the project analysis area may have impacted Carex cordillerana occurrences. 

However, the extent of such impacts could not be determined, because information on the distribution of 

the species on the Forest prior to 2000 does not exist. Given the number of current known populations and 

the fact that new occurrences of Carex cordillerana are being discovered on the national forest on a near

annual basis, previous actions in the project analysis area have, to date, not resulted in the local 

extirpation of the species within the analysis area. 

Climate change effects may be considered as a component of cumulative impacts. Changes in climate 

influence vegetation, water, and disturbance frequencies; and these changes, in turn, influence one 

another. A change in one aspect causes a cascade of responses that, in some cases, counteract and, in 

others, magnify the initial change. Such interactions make prediction of the likely effects of climate 

change difficult at the scale of the Snow Basin analysis area even if the nature of the climate change were 

known. For now, one can be certain that changes will occur at a continental scale; yet not know the mode, 

timing, or magnitude of changes or environmental responses at the project scale. Until these changes are 

better understood, it will be difficult to predict with accuracy the environmental outcomes of particular 

land-use activities. Species most at risk of climate change are those with small geographic ranges (e.g., 

local endemics), narrow physiological tolerances, limited dispersal abilities, stenotypic habitat 

associations, strong interspecific dependencies, low genetic diversity, and those that have recently 

experienced population declines. Carex cordillerana grows in a variety of habitat types including under 

forest canopy and ecotones between non-forest and forest. So it may possess some flexibility to localized 

climatic change, should the area get somewhat warmer, drier, or wetter; but to an unknown degree – and 

this is certainly speculative. Tools to predict the potential climatic changes as influenced by the Snow 

Basin activities over the next 10 to 15 years have yet to be devised, but it seems unlikely that measurable 

changes will occur relative to this species (potential temperature and precipitation increases being the 

most likely climatic change in this part of the continent) over the short life of this planning document.

Mitigation measures to protect known Carex cordillerana sites in harvest and prescribed fire units reduce 

direct and indirect effects. The largest factor influencing the ability to reduce or remove potential 

cumulative effects is assumed to be the reduction or elimination of potential direct and indirect effects 

through design features or mitigation measures on all current and future projects. Reduction or 

elimination of direct and indirect effects correspondingly reduces any additive impacts. For the known 

sites in this analysis area, direct and indirect effects have been substantially reduced by project design 

elements and mitigation measures. There are therefore, few direct and indirect effects from the project,

and cumulative effects are not anticipated except from livestock grazing that may make Carex 

cordillerana populations more available and palatable. 

Determination and conclusion

This project may impact individuals or habitat of Carex cordillerana, but will not likely contribute to a 

trend towards federal listing or cause a loss of viability to the population or species (MIIH).
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Achnatherum wallowensis (Wallowa ricegrass)

Although this species has not been documented on the Whitman Ranger District, it is believed that habitat 

could exist. Habitat is described as basalt scablands and lithosols; shallow rocky soils sometime with stiff 

sage, strict buckwheat and ponderosa pine surrounding the openings. This type of habitat exists in the 

analysis area. There are no activities planned in scabland habitat so no specific surveys were done in those 

areas. However, observations were made of adjacent scabland habitats.

Direct, Indirect, and cumulative effects

Impacts to habitat are not likely to occur because no activities are planned in scablands. Mitigations are 

included that avoid disturbance (i.e. roads, landing piles, etc) to this type of habitat. Other possible actions 

within the analysis area such as wildfire and ongoing activities like recreation, fuelwood gathering, and 

livestock grazing have the potential to impact scabland habitat and therefore have the potential to impact 

any undetected populations in the analysis area. Any potential impacts to undetected populations are 

unlikely as this plant has a low likelihood to occur in the analysis area and would be small Therefore, the 

cumulative impacts would not increase significantly.

Determination and conclusion

This project is expected to have no impact to Achnatherum wallowensis, due to its low likelihood of 

occurrence. 

Botrychium ascendens, B. campestre, B. crenulatum, B. lineare, B. lunaria, B. minganense, B. montanum, 

B. paradoxum, and B. pedunculosum

There are no known Botrychium populations within the analysis area but there is suitable habitat. 

Botrychium spp. are reported from floodplain terraces near perennial streams, mesic meadows, and damp 

ground in forested settings. They have been affiliated with semi-permanently flooded marshy meadows 

and small forb dominated openings adjacent to or within cool, moist forest stands of Engelmann's spruce, 

lodgepole pine, or grand fir. Surveys identified several proposed treatment units (Units 78, 120, 126, 128, 

142) containing suitable habitat for Botrychium species, but no plants were discovered. Survey occurred 

during an appropriate time of year to search for Botrychium species.

Direct, indirect, and cumulative effects

Suitable habitat for Botrychium species has limited potential to be directly impacted by the vegetation 

management activities proposed for the Snow Basin project, because nearly all the riparian areas and 

other mesic features are protected by INFISH buffers. A very limited amount of timber harvest and log 

skidding would occur in RHCAs. RHCA harvest would occur only in the outermost portion of RHCAs,

not within the riparian zone. Along Category 1 and 2 streams, a minimum 100 foot buffer would be 

maintained except when the road bed is within 100 feet of the stream channel. Botrychium habitat is not 

expected to be found in RHCAs at distances beyond 100 feet of the stream channel or on the upslope 

portion of an existing road within 100 feet of the stream channel; because at this distance from the stream 

channel, upland vegetation is encountered, which does not provide suitable habitat. Alternative 2 proposes 

50 acres of harvest within RHCAs and another 67.5 acres of log skidding through RHCAs. 

Approximately half the acres are in category 4 RHCAs (intermittent streams), which do not provide 

habitat for Botrychium species. Smaller amounts of RHCA skidding and RHCA harvest are proposed

under Alternative 3 (43 acres harvest; 17.8 acres skidding) and alternative 4 (43 acres harvest; 17.8 skid). 

Of a total RHCA area of 5,380 acres in the analysis area, 2.2 percent of the RHCA would be affected 

under Alternative 2, and 1.9 percent would be affected under Alternatives 3, and 4. Furthermore, skid 

trails are expected to impact only 4 percent of this area, further reducing the percentage of impacted 

ground closer to 1 percent. Although suitable habitat for Botrychium species is present in the analysis 
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area, it would not likely be impacted by the project, because those portions of RHCAs affected are further 

from the riparian zones that provide suitable habitat.

Other possible actions within the analysis area such as wildfire, road maintenance; and ongoing activities 

like recreation, fuelwood gathering, and livestock grazing may have the potential to impact undetected 

Botrychium populations. Any potential direct and indirect effects to potentially undetected populations are 

unlikely because Botrychium suitable habitat would not be affected. Therefore, cumulative impacts are

not expected.

Determination and conclusion

For reasons stated above, this project is expected to result in no impact to Botrychium ascendens, B. 

campestre, B. crenulatum, B. lineare, B. lunaria, B. minganense, B. montanum, B. paradoxum, and B. 

pedunculosum.

Carex retrorsa (retrorse sedge)

This sedge is documented on the Whitman Ranger District (East Pine Creek and Eagle Creek) and is often 

found along streams, marshes, sedge meadows; and shores of streams, ponds and lakes. Surveys of this 

type of habitat were not specified, but observations were made of riparian areas when encountered. There 

are no activities planned in riparian areas, as streams and other wetland features are protected by INFISH 

buffers.

Direct, indirect, and cumulative effects

Impacts to habitat are not likely to occur as no activities are planned in riparian areas. INFISH buffers are 

included in project design to protect aquatic features. Other possible actions within the analysis area such 

as wildfire and ongoing activities like recreation, fuelwood gathering, and livestock grazing have the 

potential to impact riparian habitat and possible undetected Carex retrorsa. Any potential effects to 

undetected populations are unlikely. Therefore any cumulative impacts are not expected to occur.

Determination and conclusion

Project activities would have no impact to Carex retrorsa as the habitat for this plant would not be 

affected directly or indirectly. 

Cypripedium fasciculatum (clustered lady-slipper)

This member of the orchid family occurs in moist, coniferous forest, often on northerly aspects with 

filtered sunlight. It occurs around springs and along riparian zones. Although there are no documented 

sites in Northeastern Oregon, a historical herbarium collection was made in 1957 from an area adjacent to 

the Snow Basin analysis area (East Eagle drainage) that has led to numerous unsuccessful attempts in 

recent years to relocate the species. It is unlikely that Cypripedium fasciculatum is present in the project 

area. 

Cypripedium fasciculatum has an intricate life cycle that is not fully understood. All orchids appear to 

require the presence of a fungus, usually a Rhizoctonia, before the seed will germinate in the wild (Arditti,

1967; Doherty, 1997; Wells, 1981). Doherty (1997) reports that orchid seedlings depend on the fungal 

symbiont to survive. Once an orchid reaches maturity and becomes autotrophic. The degree of 

dependence may change. Establishment of new populations requires suitable conditions for the fungus. 

What these conditions are is not known, but can be presumed to be moist and shady with adequate 

organic material to support growth of the heterotrophic fungus. 

Direct, indirect, and cumulative effects

Activities that remove canopy in large areas or patches close to C. fasciculatum populations could alter 

the microclimate of nearby sites by creating edge effects. Depending upon distance and exposure, there 
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could be changes in several microclimate variables such as air temperature, relative humidity, soil 

temperature, and moisture; which could impact C. fasciculatum (Chen, 1995). Low-intensity fire that does 

not eliminate the duff layer or destroy the canopy appears to have no adverse impact on C. fasciculatum

(Harrod and Knecht, 1996). In some cases, it appears to have benefited the species. High-intensity fire 

that eliminates the duff layer also destroys C. fasciculatum rhizomes (Harrod and Knecht, 1996). Other 

possible actions within the analysis area such as wildfire, road maintenance, and ongoing activities like 

recreation and fuelwood gathering have the potential to impact any undetected populations of 

Cypripedium fasciculatum. Any potential effects to undetected populations are unlikely and would be 

small. Therefore, the cumulative impacts would not increase significantly.

Determination and conclusion

Because the existence of the plant in the analysis area is very unlikely, this project would have no impact

to Cypripedium fasciculatum.

Pellea bridgesii (Bridge’s cliff-brake)

Suitable habitat for Pellea bridgesii consists of dry rock outcrops, ridgelines, or loose talus slopes. It can 

be found on southerly to easterly aspects in full sun but sometimes under trees, and is reported from 

moderate elevations of 5,000 to7,000 feet. There are no known sites in the analysis area, but habitat may 

exist in the area, mainly on limestone and granitic rock outcrops.

Direct, indirect and cumulative effects

This species is found mostly on rock outcrops in the analysis area and these habitats would not have 

machinery operating on the site. The only potential impact would be from prescribed fire that had escaped 

into wildfire characteristics. Other possible actions within the analysis area such as wildfire, and ongoing 

activities like recreation and fuelwood gathering have little potential to impact any undetected Pellea 

bridgesii. Any potential effects to undetected populations are unlikely and would be small. Therefore,

cumulative impacts would not increase significantly.

Determination and conclusion

This project would have no impact to Pellea bridgesii. 

Phacelia minutissima (dwarf phacelia)

Habitat for Phacelia minutissima is described as moist meadows and seep edges or on vernally wet open 

meadows and barren slopes. It occurs is gravely, clay-loam, well drained soils. This is a small annual 

species that is difficult to locate once its bloom season has passed. Suitable sites were searched 

thoroughly for any trace of this species, but none were found.

Direct, indirect, and cumulative effects

This species does not occur in the general forest so there would be no impacts to potential habitat or 

undiscovered populations from project activities. Other possible actions within the analysis area such as 

wildfire and ongoing activities like recreation, fuelwood gathering, and livestock grazing have the 

potential to impact any undetected dwarf phacelia populations. Any potential effects to undetected 

populations are unlikely and would be small. Therefore ,the cumulative impacts would not increase 

significantly.

Determination and conclusion

This project would have no impact to Phacelia minutissima.
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Platanthera obtusata (small northern bog-orchid)

Habitat for this rare bog-orchid is similar, but wetter and “boggier” than the other bog orchids recorded 

during the Snow Basin surveys (Habenaria dilatata, H. elegans, H. unalascensis). Potential habitat is not 

likely, but possibly exists in the analysis area. Habitat for Platanthera obtusata would be found primarily 

along the major streams of Eagle Creek or Little Eagle Creek. 

Direct, indirect, and cumulative effects

Any ground disturbing activities have the potential to impact rare plant species and habitat. During the 

course of surveys, no small northern bog orchids were discovered, but several other bog orchids were 

found. The bog orchids grow in wet sites as described above, sites which are protected from ground 

disturbing actions by riparian buffers. Due to the large size of the analysis area, there could have been 

undiscovered habitat and/or plants. Other possible actions within the analysis area such as wildfire and 

ongoing activities like recreation, fuelwood gathering and livestock grazing have the potential to impact 

undetected bog orchid populations. Any potential effects to undetected populations are unlikely and 

would be small. Therefore, the cumulative impacts would not increase significantly.

Determination and conclusion

This project may impact individuals or habitat, but will not likely contribute to a trend towards federal 

listing or cause a loss of viability to the population or species.

Trifolium douglasii (Douglas’cover)

This clover is described as inhabiting a variety of mesic habitats including moist meadows, prairie 

remnants, riparian areas along streams, and in vernally wet areas. Populations on the Wallowa-Whitman 

are located on the La Grande Ranger District, with a large population further to the west on the Umatilla 

Forest. It is possible that the Snow Basin analysis area is out of its range, but the habitat description 

makes it worthy of search.

Direct, indirect, and cumulative effects

Any ground disturbing activities have the potential to impact rare plant species and habitat. During the 

course of surveys, Douglas’ clover was not discovered but 7 other clover species were observed. Douglas’ 

clover therefore is unlikely to occur in the analysis area. Even if overlooked during surveys, the Douglas’ 

clover tends to inhabit mesic areas protected from ground disturbing actions by riparian buffers. Due to 

the large size of the analysis area, there could have been undiscovered habitat and/or plants. Other 

possible actions within the analysis area such as wildfire and ongoing activities like recreation, fuelwood 

gathering, and livestock grazing have the potential to impact undetected Douglas’ clover. Potential effects 

to undetected populations are unlikely and would be small. Therefore, the cumulative impacts would not 

increase significantly.

Determination and conclusion

This project may impact individuals or habitat, but will not likely contribute to a trend towards federal 

listing or cause a loss of viability to the population or species.

Schistidium cinclidodonteum

Not much is known about this species. It forms large, loose or dense sods on wet or dry rocks or on soil in 

crevices of rocks and boulders; often along intermittent streams, at elevations of 5000 to 11,000 feet. 

Little information is available on associated species. Habitats probably include Pinus ponderosa, Abies 

grandis, Abies amabilis, Abies lasiocarpa, and Tsuga mertensiana associations. At higher elevations it 

may also occur in Pinus albicaulis, Phyllodoce empetriformis, and Cassiope mertensiana associations. 

Suitable habitat for this species, if present, would most likely be found within RHCAs. 
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Direct, indirect, and cumulative effects

Warm/dry forest types make up a part of the analysis areas, with some above the 5,000 foot elevation 

range. Rocky habitat is not typically impacted by vegetation management activities as described for the 

Snow Basin project. Suitable habitat would be protected within RHCAs. The few proposed crossing of 

category 4 (intermittent) streams is not expected to impact this species, if present. Impacts from such a 

small area of disturbance combined with the low likelihood of the species presence are discountable. 

Escaped prescribed fire could possibly scorch rocks, although this is not expected to occur. Other possible 

actions within the analysis area such as wildfire, ongoing activities like recreation and fuelwood gathering 

have the potential to impact undetected Schistidium cinclidodonteum. Any potential effects to undetected 

populations are unlikely and would be small. Therefore, the cumulative impacts would not increase 

significantly.

Determination and conclusion

This project may impact individuals or habitat, but will not likely contribute to a trend towards federal 

listing or cause a loss of viability to the population or species.

Cheilanthes feei, Cryptogramma stelleri, Encalypta intermedia, Jungermannia Polaris, 

and Tortula mucronifolia

Direct, indirect, and cumulative effects

These species are not known to occur in the project area, but suitable habitat exists on limestone 

outcroppings in the northwest portion of the project area. Although impacts to rock outcrops of any kind 

are not expected from project activities, limestone outcrops would be further protected with mitigation 

measure WL-10, which would protect plant communities adjacent to sensitive habitats, including cliffs 

and talus, avoiding this unique habitat. 

Determination and conclusion

This project would have no impact to Cheilanthes feei, Cryptogramma stelleri, Encalypta intermedia, 

Jungermannia polaris, and Tortula mucronifolia.

Monitoring Requirements

To help determine whether assumptions for improving habitat conditions for Carex cordillerana are 

valid, monitoring to detect changes in population levels and plant community composition would be 

conducted in a sample of the known populations, in units proposed for intermediate thinning harvest 

followed by prescribed fire, and in units proposed for prescribed fire alone. Monitoring would be 

conducted prior to project activities to establish a baseline data for population levels (frequency or 

density) and plant community composition and cover (or frequency). Following project activities, Carex 

cordillerana population levels and plant community composition would be monitored for five years. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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INVASIVE SPECIES

Existing Condition

This report addresses the existing condition of non-native (invasive) species within the Snow Basin 

Project Area and the effects on these species from project activities. The Pacific Northwest Region 

Invasive Plant Program Record of Decision (ROD) (USDA, 2005) and the Wallowa-Whitman Land and 

Resource Management Plan (LRMP) (USDA, 1990) mandate prevention and management of non-native 

species under all planning efforts. Direction for site-specific treatment activities is covered under the 

Wallowa-Whitman Invasive Plant Treatment Program FEIS (USDA, 2010).

The LRMP as amended by the Region 6 ROD (amendment #RF5) outlines 23 standards for the 

prevention and management of invasive non-native plants that have been added to all regional Forest 

Plans and require consideration of invasive species in all planning efforts. The regional ROD does not, 

however, approve any site-specific treatment, instead requiring a completed analysis by each National 

Forest. Therefore, the Wallowa-Whitman ROD was completed to provide direction for a site-specific 

program to contain, control, and eradicate new and existing invasive species infestations found within 

NFS lands.

Of the 23 prevention and management standards in the LRMP (amendment #RF5), seven directly affect 

activities found in the Snow Basin project. These standards are:

1. Prevention of invasive plant introduction, establishment, and spread must be addressed in 

watershed analysis, roads analysis, fire and fuels management, grazing allotment management 

plans, and all other land management assessments.

2. Actions conducted or authorized by written permit by the Forest Service that operate outside the 

limits of the road prism, require cleaning of all heavy equipment prior to entering NFS lands.

3. Use weed-free straw and mulch for all projects conducted or authorized on NFS lands.

4. Use only gravel, fill, sand, and rock that are judged weed free by district weed specialists.

5. Conduct road blading, brushing, and ditch cleaning in areas with high concentrations of invasive 

plants in consultation with district or forest level invasive plant specialists and incorporate 

invasive plant prevention practices as appropriate.

6. Develop a long-term site strategy for restoring/revegetating invasive plant sites prior to treatment 

(if invasive plant treatment is needed prior to project activities as a prevention measure).

7. Native plant materials are the first choice in revegetation for restoration and rehabilitation where 

timely natural regeneration of the plant community is not likely to occur.

Under the Region 6 ROD, these standards apply to the prevention and management of all invasive nonnative species and not just those listed as “noxious weeds.”

Invasive plants are defined as non-native plants, whose introduction is likely to cause economic, 

environmental, or human health harm. An invasive species is distinguished from other non-natives by 

their ability to spread in native ecosystems. ”Noxious weeds” on the other hand is a legal term used by 

state, county, and federal agencies to denote plants that pose particular threats, generally to agriculture. 

Many undesirable non-natives can be invasive and pose threats to healthy native plant communities but 

do not meet the criteria for listing as a “noxious weeds.” For that reason, this analysis will focus on all 

invasive non-native plants and not just those listed as “noxious weeds.”

Invasive Plant Species Presence in the Project Area

There are 73 inventoried invasive non-native plant sites (7 different species) within the Snow Basin

project area. The inventoried acres within the project area are shown in the table below. Acreages reflect 

current information in the Forest INSP GIS layer (GID query, February 21, 2012). In addition to these 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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listed species the project area also includes Ventenata dubia, Bromus tectorum, and others that are 

potentially harmful invasive species but do not meet the requirement for listing on the state or county 

“noxious weed” lists.

Table 99. Invasive plant inventory and Oregon designations

Scientific Name Common Name Gross 

Acres

Baker 

County 

Designation

State 

Designation

Cardaria draba whitetop 90 A B

Centaurea diffusa diffuse knapweed 190 A B

Cirsium arvense Canada thistle 29 B B

Cynoglossum officinale gypsyflower 367 N/A B

Hypericum perforatum common St. Johnswort 12 B B

Lepidium latifolium broadleaved pepperweed 1 A B

Potentilla recta sulphur cinquefoil 27 B B

Total 717

“A” designated species is an invasive of known economic importance, which occurs in the state in small enough 

infestations to make eradication or containment possible; or is not known to occur, but its presence in neighboring 

states makes future occurrence in Oregon seem imminent.

Recommended Action: Infestations are subject to intensive control when and where found by Baker County with 

possible assistance from the Oregon Department of Agriculture.

“B” designated species – an invasive of economic importance, which is regionally abundant, but which may have 

limited distribution in some counties.

Recommended Action: Moderate to intensive control at the county level.

Baker County and the Oregon Department of Agriculture (ODA) designate listed invasive species status 

using a similar system.

ODA also has “T” designated species, which are a priority noxious weed designated by the Oregon State 

Weed Board for which the ODA will develop and implement a statewide management plan. “T” 

designated noxious weeds are species selected from either the state “A” or “B” lists.

Treatment and monitoring records document all site visits by invasive plant specialists, spanning the years 

since initial discovery and inventory of the site. These records are on file at the Whitman Ranger District 

Office in Baker City, Oregon. These sites are visited on a regular basis for treatment and monitoring and 

can be relocated and identified on the ground when necessary. 

During the course of project surveys, 3 new noxious weed sites were documented. Two sites contain 

diffuse knapweed (Centaurea diffusa), and the other contains field bindweed (Convolvulus arvensis). The 

new sites were identified with GPS points for later re-location and inventory by Forest Service weed 

specialists.

The following table provides site information in relation to activities in the proposed action for the Snow 

Basin project area. Many sites are linear, lying along roads, and in several cases multiple species occur 

within a single location. 

Table 100. Noxious weed proximity to activities in proposed action

Site Number Common Name Proximity to proposed activities

06160700002 diffuse knapweed

Linear site along open road 7005. Located within treatment unit 

411 (INT), 412 (INT), 418 (INT), 419 (INT), 420 (INT), 420A 

(INT), 421 (INT), 423 (INT), and 8 (RXF).
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Site Number Common Name Proximity to proposed activities

06160700004 Whitetop Linear on closed road. Located in treatment unit 408 (INT). 

06160700006 Whitetop Linear site along open Rd 7015. Found in treatment unit 3 

(RXF), 309 (INT), 314 (INT), 314A (INT), 323 (INT).

06160700008 Diffuse knapweed

Open road goes site and is along open road 7732220. Found 

within treatment unit 213 (INT), 215 (INT), 216A (INT), 219 

(INT), 219A (INT), 220 (INT), 24 (RXF)

06160700010 Diffuse knapweed

Linear and also large patch found within unit 13(RXF), 134 

(INT), 134A (RXF), 135 (INT), 136 (INT), 136A (RXF), 3 (RXF), 

308 (INT), 309 (INT), 312 (INT), 314 (INT), 314A (INT), 323 

(INT), 325 (INT), 4 (RXF). Found along open road 7735 and 

crosses Eagle Cr, up to Empire Gulch road. 

06160700027 Diffuse knapweed Located along Rd 7015-080, 084 closed road. Found in 

treatment unit 3 (RXF), 325 (INT), 326 (INT), 

06160700042 Whitetop

Patch and large linear feature. Rd 7735, Basin Cr. Open road, 

will be used. Found within treatment units 103 (INT), 105 (INT), 

107 (INT), 109 (INT), 115 (INT), 13 (RXF), 133 (INT), 133A 

(INT), 134 (INT), 135 (INT), 136 (INT), 136A (INT), and 13A 

(RXF).

06160700043 Canada thistle

Linear feature on open road 7735. Found in treatment units 

112 (HOR), 114 (HOR), 115 (INT), 13 (RXF), 13A (RXF), 33 

(INT).

06160700044 St John’s wort Found within treatment unit 103 (INT).

06160700047 Whitetop

Linear site along Rd 77. Found in treatment unit 115 (INT), 120 

(INT), 121A (INT), 128 (INT), 128A (INT), 129 (INT), 129A 

(INT), 129B (INT).

06160700048 Diffuse knapweed Patch found along closed. Located in treatment unit 301 (INT).

06160700052 Diffuse knapweed

Large linear site, mostly on closed roads off 7005 system. Near 

private land. Located within treatment unit 411 (INT), 424 (INT), 

425 (INT), and 6 (RXF).

06160700053 Whitetop Linear site along open road 7005. Found within treatment unit 

411 (INT), 412 (INT), 418 (INT), 420A (INT), and 8 (RXF). 

06160700066 Canada thistle Found within treatment unit 26 (RXF).

06160700073 Common houndstongue Adjacent open road within treatment unit 301A (INT), 303 

(HOR). 

06160700074 Whitetop Linear site along open road 7010. Found within unit 301 (INT), 

311 (INT), 311A (INT). 

06160700075 Common houndstongue Patch on closed Rd 7010-135. Found within unit 300 (INT) and 

9 (RXF).

06160700076 Whitetop Patch on closed road. Found within unit 301 (INT), 302 (HOR), 

.

06160700077 Whitetop Adjacent to open road 7000040. Found within treatment unit 

301 (INT).

06160700078 Common houndstongue Found along closed road. Located within treatment unit 301 

(INT). 

06160700079 Canada thistle Small patch along closed road 7735200. Found in unit 112 

(HOR).

06160700080 Common houndstongue Small patch along closed road 7735200. Found in unit 112 

(HOR), 115 (INT).

06160700081 Common houndstongue Found within treatment unit 13 (RXF).

06160700083 Diffuse knapweed Patch on closed road, off 7010 road. Located within treatment 

unit 9 (RXF). 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Site Number Common Name Proximity to proposed activities

06160700087 Common houndstongue Large patch near private land. Found within unit 2 (NCT). 

06160700089 Diffuse knapweed Located along open road 7700. Found in Treatment unit 111 

(INT). 

06160700090 Common houndstongue Large patch, found along a closed road system. Found within 

treatment unit 115 (INT) and 116 (INT).

06160700091 Diffuse knapweed Linear site, along bottom of Paddy Cr. Road. Found in 

treatment unit 134 (INT), 134A (RXF), 135 (INT).

06160700092 St John’s wort Patch in U. 404 (INT).

06160700099 Common houndstongue Linear along west project boundary. Located in treatment unit 

301 (INT), 401 (HOR), 403 (INT), 404 (INT), and 405 (INT).

06160700100 Canada thistle Patch in treatment unit 403 (INT).

06160700102 Sulphur cinquefoil Patch near open Rd. 7010. Located within treatment unit 408 

(INT).

06160700104 Common houndstongue Large patch near open Rd 7010. Located within treatment units 

405 (INT) and 406 (HOR). 

06160700105 Sulphur cinquefoil Patch in treatment unit 9 (RXF).

06160700106 Sulphur cinquefoil Small patch found in unit 134 (INT).

06160700107 Sulphur cinquefoil

Large linear site along open Rd. 77, Paddy Cr to Main Eagle, 

connects with Empire Gulch. Located within treatment unit 325 

(INT).

06160700108 Canada thistle Located within treatment unit 9 (RXF). 

06160700109 Common houndstongue Large patch. along Rd 7010-125. Located within treatment unit 

9 (RXF). 

06160700112 Common houndstongue Linear on closed Rd 7735200. Found within treatment unit 21 

(RXF), 413 (HOR), 414 (INT), 415 (INT), 416 (INT), 417 (INT). 

06160700113 Diffuse knapweed Located near open road 7005-020. Found within treatment unit 

408 (INT).

06160700114 Common houndstongue Patch, most is outside project area, some found in treatment 

unit 21 (RXF), 415 (INT), 418 (INT).

06160700115 Canada thistle Found within treatment unit 415 (INT) and 416 (INT).

06160700117 Diffuse knapweed Patch appears to be in small draw near open Rd 7010. Found 

in treatment unit 300 (INT), 406 (HOR).

06160700120 Diffuse knapweed Found in treatment unit 301 (INT).

06160700121 Sulphur cinquefoil Patch on edge of treatment unit 301 (INT). 

06160700123 Diffuse knapweed Near draw between closed roads 7010-135 and other. Found 

within treatment unit 307A (INT) and 9 (RXF). 

06160700124 St John’s wort Jct. 7735 at Snow Fork Cr. Riparian, along an open road.

Found in treatment unit 114 (HOR) and 33 (INT).

06160700131 Diffuse knapweed Small patch on closed road close to private land. Found within 

treatment unit 418 (INT) and 423 (INT). 

06160700133 Sulphur cinquefoil Patch and linear site along open Rd 7005. Found within 

treatment unit 418 (INT), 420 (INT), 420A (INT), and 423 (INT).

06160700151 Broadleaved pepperweed Small patch along closed Rd 7715-120. Found within treatment 

unit 61 (INT) and 65 (INT). 

06160700152 Sulphur cinquefoil Patch is on closed Rd 7715230. Located within treatment unit 

65 (INT).

06160700153 Whitetop Small patch, on closed road 7739-185. Found within treatment 

unit 26 (RXF).

06160700198 Common houndstongue Linear site along likely haul route. Found within treatment unit 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Site Number Common Name Proximity to proposed activities

408 (INT). 

06160700207 Diffuse knapweed Found within treatment units 103.

06160700212 Common houndstongue Found within treatment unit 21 (RXF), 26 (RXF).

06160700216 Canada thistle Found within treatment unit 20A (INT), 26 (RXF).

06160700221 Common houndstongue Located within treatment unit 34 (RXF).

06160700222 Canada thistle Located within treatment unit 34 (RXF).

06160700225 St John’s wort Located along open Rd 7737, and found in treatment unit 107 

(INT).

06160700228 Diffuse knapweed Linear and patch on open Rd 7000. Found within treatment unit 

313 (INT), 312 (INT)

06160700229 St John’s wort Found within treatment unit 312 (INT) and 314 (INT). 

06160700230 Whitetop Patch and linear site on boundary, closed Rd 7000045.

Located within treatment unit 404 (INT).

06160700249 Diffuse knapweed Small patch along closed Rd off of 7010. Located within 

treatment unit 301 (INT).

06160700252 Diffuse knapweed Patch on closed Rd 7739175. Found within treatment unit 12 

(INT). 

06160700254 Whitetop Small patch on open Rd 7005. Found within treatment unit 

420A (INT) and 421 (INT).

Environmental Effects

Invasive non-native plants pose a significant risk to healthy native plant communities and are currently 

damaging biological diversity. This can affect wildlife, habitat health, and recreation values (Vitousek, et 

al., 1996; Chapin, et al., 2000). Further, the presence of invasive species, both on and off NFS lands, can 

displace native species, reduce suitable habitat, reduce forage, destroy habitat and further the loss of TES 

species, increase soil erosion, reduce water quality, and significantly reduce soil productivity. However, 

predicting a specific response (direct or indirect) of non-native species to activities such as precommercial thinning, mechanical thinning, prescribed burning, and timber harvest is exceedingly 

complex. A variety of factors such as intensity and frequency of disturbance, ongoing activities in the 

area, and lack of consensus of biologically important changes in non-native species leads to difficulty in 

determining effects of specific projects (D’ Antonio, 2000). In general however, disturbance can increase 

the rate of invasion and chance of successful establishment of non-native species (Vitousek, et al., 1996; 

Mack and D’ Antonio, 1998; Chapin, et al., 2000; D’ Antonio, 2000).

The establishment and spread of non-native plants is a dynamic event that incorporates many diverse 

variables. Invasion theory, as it pertains to non-native species, contains three main principles: disturbance, 

propagule pressure, and competition (Hobbs and Huenneke, 1992; Lockwood, et al., 2005; Zouhar, et al., 

2008).

Invasive species are quick to colonize an area of disturbance, and can use their “weedy” life-history traits 

to establish within novel habitats. Disturbance such as fire, construction, and commercial timber harvest 

can alter native plant communities and increase the chance of invasion by non-natives. Several factors 

such as type of disturbance, proximity to propagule source, and size or magnitude of disturbance can 

increase the propensity for invasion of an otherwise healthy plant community by non-natives.

The second factor in the invasion theory is propagule pressure. Propagule pressure is defined as the 

number of possible individuals (seeds, seedlings, etc.) released into a region in which they are not native 

and the number of such release events (Lockwood, et al., 2005). In essence, the higher the propagule 

pressure (more seeds or more opportunities for a release) the greater the likelihood of a successful 

colonization. Many factors can lead to increased propagule pressure but the most likely cause is an 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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increase in the number of release events. Many of the activities conducted on NFS lands can lead to an 

increase in the propagule pressure including fire suppression activities, timber sales and salvage, road 

construction, recreation, and grazing.

Finally, the last principle of invasion theory is competition. Even though the ability of an invasive to 

spread to or colonize new sites is generally species dependant, all invasive non-natives are considered 

potential threats to native plant communities.

Methodology

The descriptions, resources, and effects (expected and potential) were assessed using field surveys, 

literature documentation, documented site information, and professional judgment. Throughout this 

document, the intensity of the effect is graded on a qualitative scale using the effect levels of low, 

moderate, and high. Those effects identified as low intensity will create little to no bare soils and 

extremely limited potential for introduction of invasive plant material to the project area. If left untreated,

invasive species within these areas would not spread from current locations or expand from current levels 

at rates higher than those found in the absence of project activities. Moderate level activities are those 

that, with proposed mitigation measures, could be treated and reduced to pre-project levels, but without 

the implementation of these measures could begin to spread beyond current levels. Finally, a high 

intensity effect is one that could create opportunities for spread and introduction of invasive species that 

could not be mitigated with normal effort or proposed measures. A high intensity effect, if controllable, 

would likely require significant increase in invasive treatment activities and funding in order to control 

the infestations. The risk from project level activities is analyzed within this report based on potential for 

new introductions and spread of existing infestations. The differences between alternatives will be 

displayed in a summary table using a qualitative assessment. The assessment is based on type/amount of 

proposed activities within each alternative.

The analysis for the Snow Basin project covers the entire area within the project boundary. Individual 

site-specific consultation with project managers must be conducted after all sale and burn plans are 

finalized. Mitigation measures contained in this document will be used to deal with specific issues after 

completion of final planning, and before landing, road, burn unit, and haul route activities are begun.

Alternative 1

This alternative is the no action alternative. All inventoried invasive sites would continue to be managed 

in accordance with the Wallowa-Whitman Invasive Plant Program EIS (USDA, 2010) and the WallowaWhitman Forest Plan as amended by Regional Forester Amendment #5 that incorporates the Pacific 

Northwest Region Preventing and Managing Invasive Plants Record of Decision (USDA, 2005).

Many vectors for the spread of known populations would still exist with recreation and vehicle travel, 

livestock and big game transport, and uncontrolled wildfire through suppression activities. However, the 

potential risk of spread from project related equipment used for harvest and road work and prescribed fire 

would not exist. Over time, with no additional disturbances to known sites, further treatment success, and 

no reduction to existing desirable vegetation cover and vigor the known sites could be eradicated or 

significantly reduced.

Alternatives 2 and 3

The proposed action for the Snow Basin Vegetation Management Project consists of vegetation 

treatments including commercial harvest, non-commercial thinning, and associated fuels treatments such 

as grapple pile, hand pile, and prescribed fire. The proposed action also includes temporary road 

construction, road reconstruction, and road maintenance. A summary of all activities is found in Chapter 

2.
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Alternative 2 is similar to Alternative 3 and does not vary significantly in the number of acres of 

commercial harvest, prescribed burning, re-opening of closed roads, temporary road construction, and 

road reconstruction. Because these activities have the greatest potential for affecting noxious weeds in the 

project area and the acres and miles of disturbance do not vary greatly between Alternatives 2 and 3, the 

effects would be similar and are discussed as such.

Direct and indirect effects

The effects of project activities on vegetation and habitats can be temporary or permanent with effects 

measured by duration as well as magnitude. Short-lived effects are those lasting 1 to 2 growing seasons,

while long-term effects are those lasting more than two years. Impacts to individual plants, soils, or 

habitat areas from the actions of animals, machinery, fire, or other human activities are direct effects,

while indirect effects are those associated with changes in habitat composition and plant community 

dynamics. For this analysis, specific project activities and the associated disturbance are direct effects, 

while changes in the competitive balance due to modifications of existing plant communities are indirect 

effects.

While direct effects of timber harvest projects on non-native plants are difficult to predict and quantify, 

they would occur through ground disturbance and introduction of invaders into new areas. Disturbance is 

defined as a punctuated event or series of events that kill or damage existing organisms, directly or indirectly increase resource availability, and create an opportunity for new individuals to become 

established (Sousa, 1984). Disturbance associated with timber harvest and fuels reduction projects are 

expected through movement of heavy equipment, soil displacement, vegetation compression, and burnt 

ground from prescribed fire activities; but the amount of disturbance can vary depending on activity 

density and type. For example, the effects of pre-commercial thinning are generally much less severe, due 

to the minimal level of soil disturbance, than the effects associated with commercial harvest or yarding 

activities. Further, project activities can introduce new species into areas by transporting non-native plant 

material on machinery or personnel. Many of the techniques used in harvest projects (Slash-busters, 

Thinning, Harvest, etc.) require the use of large machinery or equipment that disturb ground or transport 

invasive plant material if not cleaned properly prior to each use.

Indirect effects include the possible increase in “invasibility” of a plant community after disturbance. 

Invasive plants are estimated to spread at 8 to 12 percent a year on NFS land (USDA, 2005), but 

according to the R6 ROD (USDA, 2005) the adoption and use of the standards shown above should 

reduce the rate of spread of invasive plants by over 50 percent (down to 4 to 6 percent). We would expect

(without the implementation of the proposed mitigations and the above standards) changes in community 

dynamics (i.e. reduced competition) from project activities to continue or possibly increase the spread of 

invasive non-native species. The following table shows the effect and rationale of specific elements found 

within the Alternatives 2 and 3.
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Table 101. Element specific effects of the action alternatives

Alternative Elements Potential Effects Effect 

Intensity Rationale

Prescribed Fire (including 

Landing and Grapple Piles)

Increase in 

disturbance, 

available resources, 

and short-term 

reduction in 

competition

Moderate

-Prescribed burning has the potential to 

increase disturbance thus favoring 

invasive non-native plants. The shortterm reduction in fuels may also reduce 

competition of native plants allowing 

increased spread.

-The degree of disturbance from burning 

could, depending on timing, reduce the 

cover of existing invasive plants and 

retard seed set. Burning occurring in the 

summer can be beneficial when 

conducted in conjunction with ongoing 

invasive species treatment, but burning 

in the spring and fall are generally not 

adept at controlling invasive plant sites. 

-Mitigation BO-1, BO-3, and BO-4 would 

reduce the effect intensity from

“Moderate” to “Low” 

Non-commercial fuels reduction 

(NCT)

Small scale ground 

disturbance and 

introduction of plant 

material on vehicles

Low

-This activity generally includes 

hand/saw work to remove understory 

fuels, but can include the use of 

“slashbusters.” The possibility for ground 

disturbance as well as introduction of 

new plant materials with this type of 

activity exists but at low levels.

-Mitigation BO-1, BO-3 and standard 2 

would further reduce the risk involved 

with this activity element

Commercial treatments 

w/harvest (HPR, HSA, HTH, 

HOR, REG)

Ground disturbance 

and introduction of 

plant materials on 

people and vehicles

Moderate

-This activity generally includes 

hand/saw work to remove understory 

fuels. The possibility of ground and soil 

disturbance from treatments when 

coupled with the larger scale disturbance 

associated with harvest can increase the 

risk of non-native plant introduction and 

spread. The increase in traffic along haul 

routes can also compound the risk of 

introduction or movement of unwanted 

plant material.

-Mitigation BO-1, BO-3, and BO-4 and 

standard 2, 3 would reduce the risk 

associated with this element, but not 

enough to change the intensity from 

“Moderate” to “Low.”

Yarding Systems

(Ground, Cable, Ground & 

Cable,)

Ground disturbance 

and introduction of 

plant material

Moderate

-Mechanical aids to harvest increase the 

level of ground disturbance by producing 

skid trails and other bare ground areas.

The possibility of creating conditions 

favoring invasive plant introduction is 

increased with this type of activity.

Movement of plant material to new areas 

is also a risk.

-See mitigation associated with 
Chapter 3 Snow Basin Vegetation Management Project FEIS

289

Alternative Elements Potential Effects Effect 

Intensity Rationale

Commercial Treatments

Road Work

(Reconstruction, Construction, 

and Re-opening)

Increase in spread 

and new introduction 

of plant material

Moderate

-Road use creates situations that favor 

the spread of invasive plants by 

disturbing roadsides and carrying seeds 

to un-infested areas. Re-opening of 

roads can allow for the spread of 

invasive non-native plants to previously 

un-infested areas.

-Mitigations BO-1, BO-3 and standard 2, 

3, 7, 8 would help moderate the risk 

associated with this activity element, but 

would not reduce the intensity of that 

risk.

*Other activities involved with this project like aspen restoration, re-planting after harvest, and hazard tree falling will 

have “no effect” to current conditions of invasive plants within the Snow Basin project area.

Table 102. Effects of prescribed fire on invasive non-native plants (USDA Fire Effects Information)

Scientific/Common name Timing Effect

Cardaria draba

Whitetop Spring No effect on plant frequency or control

Fall

No effect on plant frequency or control

Centaurea diffusa

Diffuse Knapweed Spring Increased in seasons following fire

Fall Doubled two years after fire

Hypercium perforatum

Common St. Johnswort Spring Quickly increased after fire 

Fall Increased albeit at a lower rate than spring 

burning

Ventenata dubia

Ventenata Spring Unknown

Fall

Unknown

Bromus tectorum

Cheatgrass Spring Little effect due to the difficulty in burning early 

in the season.

Fall Trend of increased seed production in the 

seasons following the fire

Cirsium arvense

Canada Thistle Spring Potential discouragement of growth during late 

spring burning

Fall Frequency of fire can affect the growth of this 

and other thistles

Potentilla recta

Sulfur Cinquefoil Spring Plant density increased more slowly but was 

higher after 5 years

Fall Plant density was higher than spring burns 1 

year after fire but lower after 5 years

Lepidium latifolium Spring Unknown
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Perennial Pepperweed

Fall

Unknown

Convolvulus arvensis

Field Bindweed Spring Unknown

Fall

Unknown

For activities like prescribed fire and pre-commercial thinning, the effects can also vary depending on the 

specific technique and the timing of the activity. Prescribed burning can affect the invasive non-native 

plants differently (see table 103) depending on the time of occurrence. Fall burning has been shown to 

increase (although not significantly) the number of native species when compared to spring burning, 

while spring burning tends towards a decrease in the number of non-natives (Potts and Stephens, 2009). 

Effects of thinning treatments (i.e. NCT) also depend on the timing as well as the type of activity. Heavy 

equipment use has the largest possibility of disturbing soil and introducing plant material to an area, while 

mechanical thinning by way of mastication has the lowest chance. Timing of mastication however, can 

affect the non-native plants differently. Spring thinning by mastication could result in decreased nonnative introductions when compared to similar activities in the fall. Interestingly, thinning by hand crews 

has a slightly increased chance of negative effects. This generally occurs through a larger reduction of 

cover than compared to mastication treatments (Merriam, et al., 2006; Potts and Stephens, 2009). Timing 

of activities within this project should consider, when feasible, these variable effects.

Road use (including use and construction of temporary roads) can create situations that favor the spread 

of invasive plants by disturbing roadsides and carrying seeds to un-infested areas. Use and construction of 

temporary roads can allow the spread of invasive non-native plants to previously un-infested areas. The 

risk associated with road use and non-native species will increase as miles of temporary road use and 

construction increases. Exact estimates of this risk, however, are unknown and difficult to predict.

Alternatives 4

Alternative 4 is similar to Alternatives 2 and 3 but proposes slightly less overall treatment and zero miles 

of use and construction of temporary roads.

Direct and indirect effects

Effects on non-native species as a result of alternative 4 will be similar to those described in the previous 

section (see effects of alternative 2 and 3 above). The only identifiable difference between the effects 

resulting from alternative 4 and other action alternatives is the removal of temporary road use and 

construction. Effects identified as a result of temporary road use and construction will not occur as a 

result of activities in alternative 4. Risks to increased establishment and spread of non-native species 

under alternative 4 will be reduced, but not to levels found pre-project or under a no-action alternative.

Cumulative effects

This section will examine the cumulative effects on non-native plants as a result of proposed activities. 

For a specific description of other activities within the project area, see Table 103 below. The information 

in this table is followed by a more in-depth description of the cumulative effects within the Snow Basin

project area. Activities; past, present, and reasonably foreseeable future may present increased risks to 

non-native plant spread and establishment within the project area. These activities have influenced 

vegetation and habitat throughout the project area, and have created favorable situations for non-native 

plants to proliferate.
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291

Table 103. Cumulative effects determination for invasive non-native species in the Snow Basin project 

area

Project Potential Effects Overlap in: Effect

Intensity

Rationale

Time Space

Road 

Maintenance 

(ongoing) 

Increase in 

possibility of 

spread and new 

introduction

Yes Yes Moderate

Ongoing road maintenance creates situations 

that favor the spread of invasive plants by 

disturbing roadsides and carrying seeds to uninfested areas

Big Game 

Hunting, and 

other rec. 

activities 

(ongoing) 

Increase spread of 

non-native plant 

material

Yes Yes Low

The threat, however low, exists for the spread 

or new introduction of invasive plants through 

the movement of seeds on individual users.

Seeds attached to tools, clothes or equipment 

could be moved to novel habitats.

Past, Present, 

and Future 

Timber Harvest

Increase in 

disturbance and 

risk of introduction 

of invasive plant 

material

Yes Yes Moderate

The highest potential for cumulative effects on 

invasive non-native plants because of timber 

harvest is from an increase in disturbance due 

to the creation of log landings, skid trails, and 

increased access on roadways. Movement of 

heavy equipment increases the risk of 

introduction or spread of invasive plant 

material onto NFS lands.

Prescribed Fire 

and Fuels 

Reduction 

Increase in 

disturbance and 

short-term 

reduction in 

competition

Yes Yes Moderate

Prescribed burning has the potential to 

increase disturbance thus favoring invasive 

non-native plants. The short-term reduction in 

fuels may also reduce competition of native 

plants allowing the spread of the non-native 

plants. The burning could however, reduce the 

cover of the invasive plants all ready in place 

and retard seed set, and in conjunction with 

ongoing treatment allow native plants to 

establish.

Large Fires and 

Wildfire 

Suppression

Large scale 

disturbance and 

introduction of 

seeds and other 

plant material

Yes Yes High

The extreme size and temperatures of wildfire 

can create optimal locations for invasive plant 

establishment. The removal of native 

vegetation coupled with the speed of 

movement of non-native plants creates ideal 

invasion conditions. Introduction of weedy 

material is also a risk during suppression 

operations due to the movement of equipment, 

engines, aircraft, etc.

Dispersed 

Camping

Movement and 

introduction of 

invasive plant 

material

Yes Yes Low

Minimal risks involved with dispersed camping 

due to the movement and spread of invasive 

plant material by people and equipment. This 

risk is further minimized by a focused 

treatment of invasive plants in and around 

camping and gathering areas.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Project Potential Effects Overlap in: Effect

Intensity

Rationale

Time Space

Grazing

Ground 

disturbance or 

transportation of 

non-native plant 

material 

Yes Yes Moderate

Ground disturbance due to gathering or trailing 

livestock can create disturbance areas 

susceptible to invasive plant establishment.

Direct transport of invasive plant material could 

introduce new species or new infestations onto 

forestlands.

Improved management, alternative salting and 

trailing methods, and quarantine of livestock 

before moving to NFS lands can reduce the 

risk of invasive non-native plant establishment.

Ongoing treatment of infested sites and 

restoration of disturbed areas will also reduce 

the possibility of spread.

The above activities, as outlined in the table coupled with specific project activities can create situations 

for increased risk of introduction and spread of non-native plant material. Ongoing treatments of nonnative species help to mitigate the risks posed by management activities. Treatment continues on an 

annual basis within previously inventoried invasive sites as per the Wallowa-Whitman National Forest 

Invasive Plants Treatment Project Environmental Impact Statement (USDA, 2010) and direction from the 

Region 6 Preventing and Managing Invasive Plants Environmental Impact Statement (USDA, 2005). 

With the approval of the Invasives EIS (USDA, 2010), the early detection of new infestations can be 

treated. Cooperation with project personnel and forest invasive species specialists can increase the 

efficiency of this treatment by identifying areas early and beginning a treatment protocol prior to site 

expansion.

Wildfire combined with project activities has the greatest chance for cumulative effects on non-native 

plants within the Snow Basin project area, but predicting wildfire occurrence is problematic. Large-scale 

and intense wildfire disturbance would create ideal areas for the introduction and spread of non-native 

plants. With increasing numbers of wildfires, the numbers of non-native species could increase (Merriam, 

et al., 2006), the largest increases found in those areas with pre-existing non-native plant populations. One 

benefit of this project is the decrease of current fuel loading lowering the risks of uncontrolled wildfire, so 

future large-scale burns should be reduced. 

Of the activities with predictable timetables, this project coupled with roads, grazing, and timber harvest 

have the highest possibility of cumulative effects within Snow Basin. Roads are a vector of weed spread 

and transport, thus unregulated road use, construction of temporary roads, and re-opening of previously 

closed roads increases the risk. Travel management decisions (expected in the near future on this forest) 

should reduce this risk by ending unregulated road use and cross-country vehicle traffic. Further, the 

immediate closure and restoration of temporary and closed roads after project use will reduce the risk to 

non-native species. Grazing could also increase the risk of spread and introduction of non-native species. 

Livestock are vectors of plant material and can transport seeds and other plant reproductive material over 

distances. The possible increase in the number of non-natives due to project activities coupled with 

transport by livestock could increase the risk for areas outside of the actual project and treatment area 

boundaries (Merriam, et al., 2006). These impacts along with timber harvest disturbance; log landings, 

skid trails, etc.; could compound the situation for invasive plants. These disturbed areas are likely sites of 

invasive plant infestations and surveys of completed timber sales, restoration of disturbed areas, and 

treatment of infestations would reduce the overall risk of establishment and spread of invasive plants.

Increased flexibility and treatment options as part of the WWNF Invasive Plant EIS will increase the 

effectiveness of on-going treatment and mitigate many of the effects of project activities. Specific 
Chapter 3 Snow Basin Vegetation Management Project FEIS

293

mitigations within this project and the WWNF EIS can also help reduce the rate and risk of introduction 

of non-native species. Specific to the Snow Basin project there are several mitigation measures. These 

are:

1. Project personnel would inform invasive species personnel of upcoming project activities (i.e. 

temporary road openings, harvest, etc.), so reprioritization of treatment (if deemed necessary) and 

inventory can begin prior to the start of project activities.

2. New infestations would be inventoried and managed as rapidly as possible under early detection 

rapid response (EDRR) guidelines.

3. To reduce the potential spread from known invasive plant sites, these occurrences would be 

identified as Areas-To-Avoid for moderate to high-risk ground disturbance activities. 

Coordination will occur with invasive species specialists for exceptions.

4. All landing piles, created as part of a whole tree yarding system, would be rehabilitated and 

seeded with an approved native seed mix. Skid trails would also be reseeded following project 

activities.

These measures should reduce risks involved with project activities and reduce the cumulative impacts on 

the project area occurring through all management activities.

Summary of Effects 

The effects found in the above analysis can manifest in a variety of ways depending on the alternative. 

Each alternative has its own risks and effects that would be expected from project activities.

As stated earlier Alternative 1 will have no new effects due to project activities within the project 

boundary. However, continuing risks would exist from other types of activities occurring in the analysis 

area, and invasive non-native species would continue to spread and establish at the 4 to 6 percent

mentioned previously. The risk of a stand replacing wildfire, however, is increased due to increased fuel 

loading, and the potential for invasive species spread and establishment would increase beyond the rate 

found naturally. The conditions following a large-scale wildfire would favor the introduction and 

expansion of invasive species within the project area (Table 103).

Although risks are present with or without project activities, the danger of invasive species spread due to 

project activities under alternative 2 and 3 is increased. With implementation of project design features to 

reduce and control the introduction and spread of non-native species we can minimize the impacts that do 

exist. Specific mitigations and required standards (shown above) would continue to reduce the chances of 

new introductions, spread, and establishment of invasive non-native plants and we could predict a spread 

and establishment rate at the upper end of the natural level or about 6 to 8 percent (Table 103).

Alternative 4 would reduce the risk of invasive species spread and establishment from that predicted in 

the other action alternatives but would not likely reduce it to pre-project or no-action levels. While it is 

difficult to predict an exact percent risk, it would likely be around the lower end of the risk assessment 

found in the other action alternatives (Table 104).

Table 104: Summary of effects for all alternatives in the Snow Basin project

Est. Effect* No-Action Alt. 2 Alt. 3 Alt. 4

Establishment 

Potential

- -- -- --

Spread 

Potential

- -- -- -

* Estimated effect is based on increases (from pre-project levels) in establishment and spread of invasive non-native 

species due to project level activities. More ‘-‘ equate to higher risk.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Climate Change

The potential effects of climate change on invasive species are unclear. Studies have suggested that 

climate change could favor invasion by non-native plants, while others have found that some species may 

actually be reduced as a result of potential climate change effects (Bradley, et. al, 2009; Hellman, et. al, 

2008). It is safe to assume however, that invasions by non-native species would still be a concern.

With the unknown extent of climate change and the potential effect on non-native species, it is difficult to 

analyze the effects of climate change on invasive species in the Snow Basin project. However, it seems 

un-likely that the activities of this project when coupled with climate change would increase the risk of 

invasion of the Snow Basin project area beyond that outlined in this report. Further, it is possible that the 

Snow Basin project may actually reduce the likelihood of invasion through increases in the health of 

native plant communities by returning them to their historic range of variability. As stated, healthy native 

plant communities are generally more resistant to invasion by non-native plants.

Monitoring

Table 105. Monitoring

Type Activity Monitored Frequency and Timing Responsible Person

Implementation Noxious weed inspections, 

equipment cleaning, weed 

infestation avoidance, weed 

inventory, documentation and 

communication. 

Daily during active 

operations near noxious 

weed infestations.

Sale Administrator

Effectiveness Noxious weed survey and 

inventory

Annually for 3 years 

following project end.

Zone Invasive Plant 

Coordinator

Implementation Broadcast seeding of disturbed 

soil along roads, skid trails and 

landings.

Immediately following soil 

disturbance

Sale Administrator and 

Road Maintenance 

Foreman or COR

Implementation Road rock sources, pits and/or 

quarry noxious weed inspections

Prior to use for road 

construction, 

reconstruction, or 

maintenance

Zone Invasive Plant 

Coordinator; Zone 

Engineer

Implementation Noxious weed avoidance while 

prescribed burning

Prior to lighting burn FMO

Summary of Consistency Findings

Forest Plan 

The Forest Plan (as amended by the 2005 Region 6 ROD, amendment #RF5) provides direction for the 

control of noxious weeds and other competing vegetation where such activities are not precluded by 

management area direction. The goals focus on maintaining or enhancing ecosystem function to provide 

for long-term integrity and productivity of biological communities, treatment of priority infestations, and 

monitoring the effects of all activities to reduce the impacts of non-native plants. The site specific 

treatment requirements are further amended by the Wallowa-Whitman National Forest Invasive Plant 

Treatment Program EIS (USDA, 2010). The Snow Basin project is consistent with these goals through 

adherence to the EIS and the Forest Plan.

Wild and Scenic Rivers

The Eagle Creek drainage within the Snow Basin project area is designated as a Wild and Scenic River 

Corridor. Standards and guidelines specific to the area are stated in the Wallowa-Whitman National 
Chapter 3 Snow Basin Vegetation Management Project FEIS

295

Forest Land and Resource Management Plan (LRMP) (as amended by the Eagle Creek Wild and Scenic 

River Corridor Plan) with treatment requirements found in the Wallowa-Whitman National Forest 

Invasive Plant Treatment Program EIS (USDA, 2010). Standards and guidelines pertaining to invasive 

species state that we must recognize, promote, and enhance the qualities that preserve the ecological 

corridor. The Snow Basin project (for invasive species) is consistent with this plan because of the 

proposed mitigation measures, adherence to the EIS, and the Forest Plan.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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RANGELAND RESOURCE

Introduction

This analysis describes existing condition of the rangeland resources and livestock grazing management 

found within the proposed Snow Basin Vegetation Management Project (hereafter called Snow Basin 

Project) and the expected and potential effects of the alternatives on the range resources and management. 

Direct, indirect and cumulative effects of the alternatives are identified and discussed. Information 

sources used to complete this section include the following:

• Plant Associations of the Wallowa-Snake Province (Johnson and Simon, 1987)

• Wallowa-Whitman Land and Resource Management Plan (LRM, 1990), including Pacfish/Infish 

Biological Opinion and Wild and Scenic River amendments.

• Forest GIS Vegetation Layers and Oracle databases (based on stand exams and field 

reconnaissance)

Rangeland resource and management documentation is located in the Project File, and includes data, 

methods, analysis, conclusions, maps and references and technical documentation used to reach 

conclusions in the environmental analysis. 

Existing Condition

The boundary for the Snow Basin Project analysis area includes portions of the Goose Creek, Eagle 

Valley, Boulder Creek, Trouble Gulch and Sheep Rock allotments on the Wallowa-Whitman National 

Forest, Whitman Ranger District. Table 106 describes the total acres of National Forest Service lands 

within each allotment, acres of the project area within each allotment and the current management and 

carrying capacity of each allotment.

These allotments contain various range improvements, including fences, spring developments and cleared 

livestock trails. A map of the allotment improvements and the proposed project is in the project file for 

use during implementation of the Snow Basin project to avoid activities associated with the project 

unnecessarily affecting the livestock operations and integrity of range improvements. 

Most of the rangeland on National Forest System (NFS) lands contained within the analysis area is in 

satisfactory condition, fair to good, with an overall stable or upward trend, but in mid to late seral stage 

due to lack of disturbance from fire. Please refer to the Appendix B for a discussion of the management 

history of the project area.

Table 106. Livestock Grazing Allotments within the Snow Basin Project Analysis Area

Allotment 

Name

National 

Forest 

Acres

Total Acres 

within the 

Project Area

Current Management and Carrying Capacity

Livestock 

Numbers

(Cow/Calf)

Season of 

Use

Head 

Months*

AUMs**

Goose Creek 27,269 8,155 487 6/1 to 10/30 2,433 3,212

Sheep Rock 19,646 41 Vacant N/A N/A N/A

Trouble 

Gulch

1,111 592 16 6/1 to 9/30 64 84

Boulder 

Creek

1,565 72 150 7/1 to 9/30 454 599

Eagle Valley 32,569 19,654 485 6/1 to 10/31 2,439 3,219
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*Head months are calculated by multiplying the number of months livestock are on the ground by the total number of 

cow/calf pairs on the allotment.

**AUMs (Animal Use Months) are calculated by multiplying the total Head Months by 1.32. This figure is a measure of 

forage amount used by the livestock on the allotment.

Effects Analysis

Four alternatives were analyzed for this project: Alternative 1 (no action), Alternative 2, Alternative 3 

(proposed action), and Alternative 4 to determine the magnitude of direct, indirect, and cumulative effects 

on rangeland resources and livestock grazing. 

Alternative 2, 3, and 4 are similar in that they all propose acres of commercial harvest, prescribed 

burning, and aspen treatment (Chapter 2). Aspen stands across the landscape would be improved by 

reducing competition from conifers, and may be fenced to exclude livestock and/or big game. Aspen 

restoration on scattered individual sites would remove conifers on a total of approximately 38 acres and 

are generally about 1 acre per site. Alternative 4 however, does not propose temporary road construction. 

Use of temporary roads, road maintenance, and the like has very little effect to livestock grazing. The 

action items of all three alternatives could affect the rangeland resources and the management of the 

livestock grazing, but the alternatives do not vary extensively, the effects would be similar and are 

discussed as such.

The desired outcome of the Snow Basin Project is to move the project area landscape back to a mid to 

early seral stage, which will result in a reduction in canopy cover. This reduction in canopy cover over the 

mid- to long-term (4 to 20 years) will create a general shift in the plant association seral stage from late to 

early. This seral stage shift will result in increases in herbage production, available forage and overall 

desired ecological range condition (Andariese and Covington 1986, Moore et al. 2006, Bojorquez Tapia 

et al. 1990).

No Direct, Indirect or Cumulative Effects

The following activities associated with the Snow Basin project are of such limited and constrained nature 

they would have no effect on rangeland resources or range management activities.

These activities and their effects will not be discussed further in this section.

• Temporary Road Construction and reconstruction

• Roadside Danger Tree Removal

• Reconstruction of System Roads

• Non-commercial thinning only

Direct, Indirect Effects on Rangeland Resources/Range Management

Alternative 1 - No Action

There are no known direct effects on range resources because of the No Action Alternative. Effects 

related to this alternative on range resources are primarily indirect in nature. Benefits to Rangeland 

condition, livestock distribution and forage available will not occur because project activities will not 

occur. Further canopy closure and decreases in forage availability would continue and potential changes 

in livestock distribution through reductions in suitable rangelands would continue. Damage to range 

improvements would not occur as no project activities would be authorized.

Alternative 2, 3, and 4 - action alternatives

There are 28,514 acres used for livestock grazing within the Snow Basin project area. Portions of these 

lands are considered un-suitable for livestock use due to available forage or dense canopy cover. The 

commercial harvest activities with fuel treatments in alternative 2, 3, and 4 will convert unsuitable 
Chapter 3 Snow Basin Vegetation Management Project FEIS

298

rangelands (those currently not available for forage utilization due to dense canopy cover or lack of 

understory vegetation) to suitable by reducing the overstory canopy cover. Alternative 2 would convert 

11,452 acres, Alternative 3 - 10,956 acres, and Alternative 4 - 9,238 acres in the allotments within the 

Snow Basin project. This reduction in canopy cover will reduce competition for resources to the 

understory, and over the mid- to long-term (4 to 20 years) will create a general shift in the plant 

association seral stage from late to early and increase above ground biomass of the understory (Reigel et 

al., 1992). 

The acres treated with natural fuels prescribed fire only in alternative 2, 3, and 4 would reduce forage 

availability in the short-term (due to the low fire intensity objectives found in prescribed fire treatments 

this time would be approximately 1 to 3 years). However, in the long-term (4 to 20 years), the 

reintroduction of fire disturbance and thinning the overstory will create a general shift in the plant 

association seral stage from late to early. The shift in seral stage over time will result in an increase in 

herbage production (Andariese and Covington, 1986; Moore et al., 2006; Bojorquez Tapia et al., 1990) 

and available forage, enhancing overall desired ecological range condition through improved livestock 

distribution.

Forage quality and quantity would be increased short- and long-term by opening stands and through 

prescribed burning. Opening potential rangelands (not presently accessible due to dense canopy cover or 

lack of understory vegetation) to livestock would also provide opportunities for livestock to access 

previously treated stands and better utilize forage throughout the allotment, thus improving distribution. 

Enhanced livestock distribution will enable more even utilization of forage and potentially reduce impacts 

to areas of higher use that would continue to occur without treatment. 

The implementation of the Snow Basin project (burning activities) will potentially reduce forage 

availability to livestock in the short-term (1 to 3 years). The short-term risk of reduced forage availability 

due to prescribed fire treatments will be evaluated (post-burn) to determine the size of the treated area, the 

intensity of the fire and (if needed) necessary modifications to the annual permittee grazing instructions. 

In general, larger burn blocks that treat a larger proportion of an allotment would require more stringent 

restrictions to grazing activities over the short-term. Fire intensity, measured by average flame length, 2 to 

4 feet is considered optimum, would also affect possible modification of the grazing prescription. Flame 

lengths that surpass the 2 to 4 feet target would require more restrictive modifications to the grazing 

prescription. Modifications to grazing instructions could include altered rotation timing (to allow for 

regrowth and seed production on burned areas), decreases in allowable use through more stringent 

utilization standards, avoidance of burned areas or any combination of these. Pastures that receive burning 

treatments will be administered to Forest Plan Standards and Guidelines (See Wallowa-Whitman LMRP

4-51 and 4-54) following treatment to ensure regrowth of the vegetation in the treatment areas and ensure 

desired future conditions are met.

In the long-term (4 to 20 years) however, the decrease in the possibility of large scale wildfire will 

decrease due to reduced fuel loadings within the project area. Wildfire is the most likely cumulative effect 

for rangeland resources that has potential for negative impacts. This project would reduce the risk 

associated with large scale, uncontrolled wildfire.

Aspen treatment within the Snow Basin project will have very little effect to permittees, AMPs, or AOIs.

With the small number of acres involved in the project there will be no changes to grazing management 

within the project area due to aspen restoration treatment.

Cumulative Effects on Rangeland Resources/Range Management

Potential cumulative effects are analyzed by considering the proposed activities in the context of past, 

present and reasonably foreseeable future actions. Cumulative effects analysis is conducted in those areas 

where effects have or may occur. In addition, some activities have an influence that may extend 
Chapter 3 Snow Basin Vegetation Management Project FEIS

299

“downstream” in the subwatershed within the project area boundary. This broad area is referred to as the 

“cumulative effects analysis area.” In general, all alternatives are considered in the context of relevant 

past, present and reasonably foreseeable future activities in this area. The cumulative effects analysis area 

for this project is the area contained within the project boundary. A summary table of the past 

management activities that have occurred in the cumulative effects analysis area is located in Appendix B 

and has been used to assess the cumulative effects of implementing this project on Rangeland Resources. 

Of these possible cumulative effects, the only potential risk to rangeland resources within this project area 

is uncontrolled wildfire.

Alternative 1 - No Action

Treatment under project activities that would occur in the action alternatives will remain untreated for the 

foreseeable future. Benefits of these treatment activities are a reduction in fine and ladder fuels. These 

reductions generally reduce the risk of large-scale uncontrolled wildfire. The potential for uncontrolled 

wildfire may increase in the absence of controlled burning, non-commercial thinning and harvest 

treatment; thus leading to reductions in forage availability. Wildfire coupled with lack of project activities 

would increase the risk and reductions in livestock grazing by negatively impacting distribution, forage 

availability, destruction of range improvements and would necessitate major modifications to annual 

operating instructions.

Alternative 2, 3, and 4

Treatment under project activities would likely benefit rangeland resources and grazing activities. Since a 

major threat of negative effects to these resources is wildfire, the reduction in fine and ladder fuels should 

help to reduce the risk of impacts. Project activities should reduce the risk of reductions in livestock 

grazing by reducing the risks of uncontrolled wildfire.

Summary of All Effects 

Alternative 1 - No Action

Alternative 1 will have “No” direct effects from of project activities, because no project activities will be 

authorized. Indirect effects of the no-action alternative will have a negative effect on forage availability 

and livestock distribution because project activities that would modify the canopy cover and plant 

community seral stage will not be authorized. Wildfire is the only known cumulative effect in this project 

area and with occurrence would negatively affect all the indicators shown in Table 107. Risk of wildfire is 

potentially increased, because no project activities will be authorized.

Alternative 2, 3, and 4 - action alternatives

Direct effects will be similar under all action alternatives. There is a possibility that project activities will 

have a negative effect on annual grazing management. This effect is dependent on monitoring conducted 

after activities such as prescribed burning. Depending on the scale of activities (see rangeland resource 

report), annual operations may need to be altered following project activities. There will be no direct 

effect to rangeland improvements from project activities, because mitigations requiring avoidance and 

consultation with district range managers will be enforced. Indirect effects from project activities will be 

positive by increasing livestock distribution and forage availability. These positive effects will occur 

because of reductions in over story cover and shifts in seral stage of affected plant communities. There 

will be no additional cumulative effects from project activities or wildfire, because the benefits from fuels 

reductions should reduce the risk of large-scale wildfire.
Chapter 3 Snow Basin Vegetation Management Project FEIS

300

Table 107. Summary of effects to rangeland resources by alternative

Est. 

Effect*/Rationale

No-Action Alt. 2 Alt. 3 Alt. 4

Modification to 

Annual Grazing 

Management

0 - - -

Forage Availability 0 + + +

Livestock 

Distribution

0 + + +

Range 

Improvements

0 0 0 0

* Effect intensity: 0 designates no change from current, - designates potential negative affect, + designates potential 

positive affect.

Climate change

Livestock may impact climate change; however there is very little scientific data on the impacts of 

climate changes within the ecosystems present on the Wallowa-Whitman National Forest. Therefore, it is 

difficult to address how livestock grazing when coupled with Snow Basin project activities would affect 

climate change conditions. Our current management protocols allow the Forest Service and the Range 

Specialists to alter grazing management if a trend change in resource conditions is observed. Furthermore, 

annual and long-term monitoring protocols are in place to identify when vegetation dynamics and 

rangeland conditions need management changes.

Mitigations and Monitoring

Mitigations Measures

1. All range improvements must be protected during project activities. If fences are damaged, 

repairs must be made immediately to prevent livestock from entering areas outside of established 

allotments.

2. No trees used as anchor trees along a fence line shall be marked for harvest.

3. All gates must be closed while livestock are within the allotment adjacent to the harvest units.

4. Treatments located within Grazing Allotments will be coordinated with the district range 

management specialist prior to treatment to adapt the administration of the allotment (if needed).

5. The allotments will be administered to standard following treatment to ensure the Forest Plan 

Standards and Guidelines set for allowable use (Wallowa-Whitman Land and Resource 

Management Plan 4-51 to 4-54) are met.

6. All burning activity will be coordinated with the district range management specialist to identify 

needed adjustment to grazing activity based on the specifics of each burn block. 

Monitoring Recommendations

Table 108. Monitoring requirements for rangeland resources

Type Activity Monitored Frequency and 

Timing

Responsible Person

Implementation All activities to avoid damage 

to range improvements

Daily during active 

operations. 

Sale Administrator 

FMO

Effectiveness Forage utilization and 

administration to standard

Following treatment in 

active pastures

Range Manager
Chapter 3 Snow Basin Vegetation Management Project FEIS

301

Effectiveness Burning activity Following prescribed 

fuels treatments

Fuels management

Consistency and Compliance

Wallowa-Whitman National Forest Land and Resource Management Plan (as amended by: Eagle Creek 

Wild and Scenic River Plan)

Action Alternatives 1, 2, 3, and 4 would be consistent with the Wallowa-Whitman Land and Resource 

Management Plan (including the plan as amended by the Eagle Creek Wild and Scenic River Plan) as all 

range standards and guidelines would be met (Wallowa-Whitman Land and Resource Management Plan 

4-51 to 4-54 and the Eagle Creek Wild and Scenic River Management Plan pg. 17 standard 69-70). 

Standards and guidelines for the Eagle Creek Wild and Scenic River Management plan that apply to this 

project are: 

• Domestic livestock grazing levels and allotment management practices existing prior to 

designation of the river will generally be permitted, consistent with free-flow, water quality 

and/or values. Allotment management plans shall be modified when grazing practices or other 

activities are found to adversely impact Wild and Scenic river values.

• Range Allotment Management Plans which encompass part of the W&SR corridor will be 

considered high-priority for revision. AMPs will address protection and enhancement of water 

quality and/or values as they are revised.

The Wild and Scenic River plan identifies the following desired future condition:

• Each component of the Wild and Scenic River system will be administered to protect and 

enhance the values for which the river was designated and to provide public use and enjoyment of 

those values. Emphasis will be given to protecting the outstandingly remarkable (OR) values for 

which the river was designated. Thus, the OR values of fish, recreation, scenery, cultural

(historic) resources, geology/paleontology will be protected and enhanced. The entire river 

corridor will be free of impoundments.

• Enhancement of river corridor ecosystems, riparian vegetation and water quality will receive high 

emphasis, balanced with improved management of recreation uses in all future management 

activities in the Eagle Creek corridor. 

• Vegetation management within the corridor will emphasize maintaining a healthy and diverse 

river ecosystem. As time goes by, riparian vegetation will become more abundant as streamside 

management units receive more management emphasis. Range allotment management plans will 

be revised to incorporate river management objectives.

Rangeland resources and the Snow Basin project meet these condition requirements through enforcement 

of all utilization measures as outlined in the LRMP and all amendments. Enforcement and administration 

of these standards are achieved through allotment management plans and annual operation instructions 

that outline required actions of grazing permittees.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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VISUALS/SCENERY RESOURCES

Executive Summary

The no action alternative will not address the vegetation conditions that are the beyond the historic range 

of variability. Alternative 1 will not reduce the risk of uncharacteristic wildfire that could cause undue 

effects to scenery, nor will it move the stands toward the desired condition.

Alternatives 2, 3, and 4 will move stands toward desired future conditions within the historic range of 

variability and reducing the risk of uncharacteristic fire, while keeping effects to scenic integrity to a 

minimum, meeting all standards. By moving stand conditions toward the historic range of variability, the 

area will be more resilient if changes in climate bring drier and warmer conditions.

The vegetation management objectives will be achieved without creating unnatural appearing forms, lines 

or colors. The selective over story removal and thinning will create no openings that are dissimilar to 

existing openings in the area. Therefore, the retention visual quality objectives (VQO) of the Eagle Creek 

Wild and Scenic River will be maintained.

Table 109. Comparison of effects by alternative for visual quality objective and scenic stability

Alternative 1 Alternative 2 Alternative 3 Alternative 4

Visual Quality Objective

Partial retention Meets VQO Meets VQO Meets VQO Meets VQO

Modification Meets VQO Meets VQO Meets VQO Meets VQO

Scenic Stability

Overall project area existing 

condition is very low 

stability 

No 

improvement

Improves to 

high stability 

Improves to 

high stability

Improves to 

moderate

Ponderosa Pine No 

improvement

Improves to 

high stability

Improves to

high stability

Improves to 

high stability

Ponderosa Pine/mixed 

Conifer

No 

improvement

Improves to 

high stability

Improves to 

high stability

Improves to 

moderate 

stability

Introduction 

Scenery provides the setting for all activities experienced by forest visitors. Each setting is comprised of 

scenic attributes that are derived by the environmental context of topography, geology, and climate. These 

underlying factors are expressed and highlighted by the scenic attributes that they support. Scenery, just 

as any other resource, must be cared for and managed for future generations. The activities proposed by 

the Snow Basin Project potentially affect the current and future condition of these valued scenic 

resources. Managing scenery resources involves the process of analyzing effects, implementing scenic 

character goals, and applying scenic conservation design features to achieve the WWNF Land and 

Resource Management Plan (Forest Plan) desired conditions and direction for scenery resources.

The Eagle Creek Wild and Scenic River (WSR) runs through the project area. The outstandingly 

remarkable values are designated for unique, rare, or exemplary features significant at a regional or 

national level. Scenery is a designated outstandingly remarkable value for the highly diverse and scenic 

attractions of the Eagle Creek drainage and the overall undisturbed natural appearance of the valley. To 

protect and enhance this outstandingly remarkable value is a goal of this project. Harvest treatments that 
Chapter 3 Snow Basin Vegetation Management Project FEIS

303

are within this project are expected to meet the retention VQO, and to improve the resiliency of the stands 

surrounding the WSR corridor.

The primary purpose of this section is to disclose the effects of the alternatives to scenery resources.

Regulatory Framework.

The National Environmental Policy Act of 1969 (NEPA) states that it is the, “continuing responsibility of 

the Federal Government to use all practicable means to assure for all Americans, aesthetically and 

culturally pleasing surroundings.” NEPA also requires, “A systematic and interdisciplinary approach 

which would insure the integrated use of the natural and social sciences and the environmental design arts 

into planning and decision-making, which may have an impact on man’s environment.” To accomplish 

this, numerous Federal laws require all Federal land management agencies to consider scenery and 

aesthetic resources in land management planning, resource planning, project design, implementation, and 

monitoring. 

Several USDA handbooks have been developed to establish a framework for management of visual 

resources, including, but not limited to: 

• National Forest Landscape Management Volume 2, Chapter 1 the Visual Management System 

(Agriculture Handbook 462, USDA Forest Service 1974)

• Landscape Aesthetics, A Handbook for Scenery Management (Agriculture Handbook 701, USDA 

Forest Service 1995)

This evaluation applies current National Forest Scenery Management methodology in conjunction with 

existing Wallowa-Whitman National Forest (WWNF) Plan direction. This includes scenery sustainability 

concepts described in Scenery Management System (SMS) Handbook Appendix J – Recommended SMS 

Refinements. It relies on field studies and photography from inventoried sensitive viewpoints and other 

views of the project area, as well as coordination with project interdisciplinary team (ID Team) members 

and consideration of public preferences for scenic quality. Cumulative scenic quality was within the 

geographic scope of roadways and other viewpoints within and adjacent to the project.

Integration of this scenery analysis assures the Snow Basin project is consistent with scenery-related 

Wallowa-Whitman National Forest direction, Forest Service (FS) policies, and applicable elements of FS 

Visual Management and Scenery Management systems. Refer to Appendix B of the Scenery Management 

System Handbook #701 for a complete list of references requiring Forest Service management of scenery 

and aesthetics.

The Eagle Creek Wild and Scenic River Management Plan establishes standards and guidelines for the 

WSR corridor. These standards and guidelines are as follows for that portion of the corridor within the 

project area:

Landscape Management: Manage visual resources to meet the following visual quality objectives 

(VQO's) within the corridor and adjacent seen areas.

Table 110. River related visual objectives

River Classification Visual Quality Objective

Wild Preservation is the norm, all distance zones 

Scenic Retention foreground

Retention middleground 

Retention background

Recreational Retention foreground 

Retention middleground 
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Retention background

River corridor viewshed management direction has been established in the "Eagle Creek Viewshed 

Corridor Plan" completed by Walker and Macy, April 1992. The Viewshed Corridor Plan will be used to 

achieve protection and enhancement of the Scenic outstandingly remarkable value (ORV). In particular, 

the VQO maps, visual sensitivity maps, desired future condition (DFC) recommendations, and suggested 

mitigations will be considered in all activity planning. The DFC recommendations will guide 

management of overall landscape character and specific activities, including: Vegetation Management, 

Developed Recreation Sites, Dispersed Recreation Sites, Transportation Facilities, Administrative Sites, 

Private Land Development, and other uses, i.e. Utilities Right of Ways (ROW).

Analysis of the visual effects of proposed activities within the corridor will be considered from two 

vantages: all existing riverside viewpoints and from Sensitivity Level 1 travelways within the corridor 

(Forest Roads 77, 7755, 7735, Martin Bridge Trail, Main Eagle Trail). 

The Sensitivity Level of the Martin Bridge Trail and Road 7735 from Eagle Forks Campground to the 

National Forest Boundary near Skull Creek are upgraded to Sensitivity Level 1 to more accurately reflect 

the ORV status of Scenery.

Landscapes containing negative visual elements will be rehabilitated. Landscapes may be enhanced by 

opening views to distant peaks, unique rock forms, unusual vegetation, or other features of interest 

consistent with protection and enhancement of ORVs, water quality, and free-flow. 

Short-term visual impacts of prescribed fires that depart from established VQOs direction may be 

considered acceptable if necessary to protect and enhance scenic values and to meet the VQOs in the 

long-term. Such departures must be approved by a landscape architect (Eagle Creek WSR Management 

Plan Standards and Guidelines, pg. 13, 14).

This visual analysis was conducted from riverside viewpoints and the stated travelways. The proposed 

treatments were considered in light of these standards and guides. Thinning for desired species and for the 

health and vigor of the stands were designed to move the stands toward the desired future condition. 

Prescribed burning was designed to protect and enhance the scenic values by making the stands on the 

ridges above more fire resistant.

Overview of Issues Addressed

Issue Indicators

The two indicators used to measure the effects to scenery resources are scenic integrity and scenic 

stability. These two indicators evaluate the intensity and duration of effects as well as the degree to which 

the alternatives would affect the stability of scenery attributes over the long-term.

Scenic Integrity is the degree to which the scenery is free from visible disturbances that detract from the 

natural and socially valued appearance, including disturbances due to human activities or extreme natural 

events inconsistent with the historic range of variability (Fire Regime Condition Class, Sciarrino 

2003)(see Fire/Fuel Management section).

Scenic Stability is the degree to which the Desired Scenic Character can be sustained through time and 

ecological progression (Landscape Aesthetics, USDA 1995).
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Affected Environment 

Existing Condition 

Existing scenic integrity

Scenic Integrity is measured on the Wallowa-Whitman National Forest through Visual Quality Objective 

levels defined by the FS Visual Management System’s Chapter 1 USDA Handbook # 462. These levels 

and descriptors of how people perceive them are shown below.

Table 111. Visual quality objectives and perceived alteration

Visual Quality Objectives Scenic Integrity as people 

perceive it

Preservation Unaltered , visually complete or 

intact

Retention Unnoticeably altered

Partial Retention Slightly altered

Modification Moderately altered

Maximum Modification Heavily altered

Unacceptable Modification Unacceptably altered

The existing scenic integrity meets the visual quality objective of the Forest Plan. Within the project area 

there are evidences of past activities. Shelterwoods are apparent within areas of modification. Partial 

Removal treatments can be seen in partial retention areas, stumps are apparent. Along with the evidences 

of treatments, are the indirect effects of additional variety in color and texture as deciduous shrubs and 

larch species have begun to take hold. There are large areas of natural appearing landscapes. Overall, 

from middle ground and background views there is little evidence of man’s activities in this project area.

Sensitive viewsheds

Forest Road 70 runs north to south along the western edge of the project area. The road is located along 

the broad ridge, and views into the project are of the upper slopes and ridges of the landscape. The steeply 

incised drainages are for the most part not visible from this route. The scenery is primarily timbered with 

scattered openings varying from 1 to 10 acres in size. The openings are of grass slopes providing diversity 

in pattern, form, and color contrast. There is evidence of past project work which has created openings 

visible in foreground views. The openings have grasses and low growing deciduous shrubs. Western larch 

is also coming up in these openings. The vegetation in these openings provides dramatic fall color 

diversity. Currently, the scenery meets partial retention. The VQO’s along this route are partial retention 

and modification.

This road runs adjacent to Eagle Creek, then up the Paddy Creek drainage, then down the south fork 

Spring Creek. The landscape setting along Eagle Creek is a steeply incised drainage. This drainage runs 

slightly northwest to southeast. The west facing slopes currently have a pattern of grassy slopes amidst 

timbered slopes with rock outcrops that punctuate the vertical topography. The views to the upper 

portions are the slopes are limited to the openings in the deciduous vegetation in the riparian the road 

traverses. The opposite side of the canyon faces northeast and is heavily timbered with mixed conifer. 

Currently, the scenery meets retention in this viewshed. The VQO within the Eagle Creek corridor is 

foreground retention.

The sections of road in the Paddy creek drainage and south fork Spring Creek drainage are also steeply 

incised. Paddy Creek runs northeast to southwest. The upper portions of the southeast facing slopes are 

open grasslands. The lower portion is timbered and stringers of coniferous forest run up the minor 

drainages. The timbered sections are very densely stocked. Small stringers of deciduous trees run up the 
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riparian edges of Paddy Creek. The views are limited by the steep topography and timber. South fork 

Spring Creek drainage runs northwest to southeast. This drainage is generally timbered. Views are very 

limited by the densely stocked vegetation. Currently, the visual quality of these viewsheds meets 

retention. The viewsheds along these roads: Road 7725, Road 7732, and Road 7739 are within 

modification visual quality objective.

Existing scenic stability

A new scenery indicator has been developed for use within the FS Scenery Management System (applied 

in this analysis according to procedures described in the 2007 Recommended Scenery Refinements,

Appendix J of the SMS Handbook #701).

For the Snow Basin project area, the existing Scenic Stability analysis focuses on the single major scenery 

attribute of vegetation, addressing its ecosystem conditions and stresses identified by field observation 

and Fire Regime Conditon Class (FRCC) coarse-scale data on vegetation and fire history data (Fire 

Regime Condition Class, Sciarrino, 2003)(see Fire/Fuels Management section).

Scenic stability levels are defined as follows:

• Very High Stability: All dominant and minor scenery attributes of the valued scenic character are

present and are likely to be sustained.

• High Stability: All dominant scenery attributes of the valued scenic character are present and are 

likely to be sustained. However, there may be scenery attribute conditions and ecosystem 

stressors that present a low risk to the sustainability of the dominant scenery attributes.

• Moderate Stability: Most dominant scenery attributes of the valued scenic character are present 

and are likely to be sustained. A few may have been lost or are in serious decline.

• Low Stability: Some dominant scenery attributes of the valued scenic character are present and 

are likely to be sustained. Known scenery attribute conditions and ecosystem stressors may 

seriously threaten or have already eliminated the others.

• Very Low Stability: Most dominant scenery attributes of the valued scenic character are seriously 

threatened or absent due to their conditions and ecosystem stressors and are not likely to be 

sustained. The few that remain may be moderately threatened but are likely to be sustained.

• No Stability: All dominant scenery attributes of the valued scenic character are absent or 

seriously threatened by their conditions and ecosystem stressors. None are likely to be sustained, 

except relatively permanent attributes such as landforms (SMS Handbook, Appendix J –

Recommended SMS Refinements, 2007).

Table 112. Risk and scenic stability

Ecosystem risk

to dominant scenic attributes

Stability of the dominant scenic 

attributes

Scenic stability level

Low risk to all (Includes dominant 

and minor scenic attributes) All are stable Very high stability

Low risk to all All are stable High stability

High risk to a few Most are stable Moderate stability

High risk to some Some are stable Low stability

High risk to most Few are stable Very low stability

High risk to all None are stable No stability

ALL means 90-100 percent of all the dominant attributes, MOST means 60-90 percent of all the dominant attributes, 

SOME means 40-60 percent of all the dominant attributes, FEW means 10-40 percent of all the dominant attributes, 

NONE means 0-10 percent of all the dominant attributes. (SMS Handbook, Appendix J – Recommended SMS 

Refinements, 2007, pg.18).
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Biophysical Groups, Stand Structure, and Historical Range

There are definite trends in the species composition and stand structure that pose increasing risk to 

scenery resources. The project area has eight biophysical areas, well described in the Forested Vegetation

section; of which only two of the eight maintain a species composition that is within historical range. The 

implications of these trends are that the majority of the project area has shifted from low or mixed 

intensity fire behavior to high intensity fire potential. The stand structure of over 50 percent of the project 

area is outside the historical range. There are 12,616 acres of multi-story non-LOS stage, whereas the 

historical range is 2,620 to 9,939 acres. 

On the other end of the spectrum, the single story large tree stage is below the range (2,572 to 11,291) at 

1,122 acres. These trends confirm the reduced resiliency of these stands to uncharacteristic fire that would 

burn larger and more intensely. Within this project area the fire occurrence rates are high due primarily to 

lightning strikes (see Fire/Fuels Management section), which show the likelihood of a fire start is 

relatively high. With fuel loads and crown base heights as they are, the flame lengths can easily cause a 

crown fire, which makes direct fire suppression tactics feasible.

Existing Scenic Stability Summary

Trends and conditions that exist in the project area are creating greater and greater hazard to scenic 

resources. Species composition is becoming increasingly dominated by grand fir and Douglas-fir which 

are non-fire resilient species. These dense multi-layered stands are very susceptible to large stand 

replacement fire. Eighty six percent of the area presents conditions that support stand replacement fire.

These conditions pose a high risk of losing key components of the ecosystem, and dominant scenic 

attributes such as the open, park-like stands of ponderosa pine and minor scenic attributes such as the 

quaking aspen stands. More than 15,000 acres are found to be overstocked which makes these stands 

susceptible to bark beetle, and makes them less resilient to large stand replacement fire. The existing 

scenic stability of the Snow Basin area is very low.

Desired Condition 

Forest Plan Direction

Forest Goals-Landscape Management: To manage all National Forest lands to obtain the highest possible 

visual quality, commensurate with other appropriate public uses, cost, and benefits.

Standards and guidelines

1. VQO’s: Meet visual quality objective through management techniques described in National 

Forest Landscape Management, Volumes 1 and 2, and the Wallowa-Whitman National Forest 

Visual Management Plan (Visual Management System, 1974, Wallowa-Whitman National Forest 

Land and resource Management Plan, 1995).

2. Retention Foreground: In retention foregrounds the area regenerated per decade should not 

exceed 7 percent or be less than 3 percent of the suitable forest land within the viewshed. 

Maximum seen area disturbed at any one time should not exceed 10 percent within any viewshed. 

Limit regeneration unit size to that which meets retention and desired character including 

consideration of future entries and regrowth. The approximate range of sizes necessary to 

accomplish this is 0.5 to 2 acres in the immediate foreground (less than 500 feet) and 3 to 5 acres 

in the foreground greater than 500 feet from the road or trail. Units against road or trail edges 

should be shelterwoods or selection cuts rather than clearcuts. Target tree size is 36 inches where 

biologically feasible. (Note: Seen area disturbance requires visible evidences of disturbance that 

do not meet the VQO from a singular viewing platform identified as Sensitivity Level 1 roads.)
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3. Partial Retention Foreground and Retention Middle ground: In partial retention foreground and 

retention middle ground, the area regenerated per decade should not exceed 9 percent or be less 

than 5 percent of the suitable forest land within and viewshed. The maximum seen area disturbed 

at any one time should not exceed 14 percent of any viewshed. Limit regeneration unit size to that 

which meets partial retention and desired character including consideration of future entries and 

regrowth. The approximate range of sizes necessary to accomplish this is 0.5 to 2 acres in the 

immediate foreground (less than 500 feet) and 3 to 5 acres in the foreground greater than 500 feet 

from the road or trail. Target size tree in foreground is 26 inches where biologically feasible.

4. Partial Retention Middle ground: In partial retention middle ground, the area regenerated per 

decade should range between 8 and 10 percent. Limit maximum regeneration unit size to 10 

acres. Maximum area disturbed at any one time should not exceed 20 percent.

5. Created Openings: Consider a created opening to no longer be an opening, visually, when trees 

reach 20 feet in height. Rotation periods will be sufficient to grow large tree character in 

viewshed foregrounds.

6. Resolving Conflicts: Where conflicts develop between visual quality objectives and timber or 

range management objectives, these conflicts will be resolved in favor of meeting the visual 

objectives. Where conflicts occur between old growth objectives and visual objectives, old

growth will have priority.

7. Viewshed Plans: Plans will be prepared for all Level 1 viewsheds that will refine boundaries, 

establish protect design criteria, indentify opportunities for scenic enhancement, and set entry 

priorities and timing (Wallowa-Whitman National Forest Land and Resource Management Plan, 

1995).

Visual Resource Direction within the Wild and Scenic River Corridor

Eagle Creek is a designated Wild and Scenic River. The project area drapes over the Recreation and 

Scenic sections of the river. The recreation segment is from the Eagle Cap Wilderness boundary near 

Humming Bird Creek to Paddy Creek. The designation covers a 0.25 mile width from the high water 

mark on both sides of the river. The scenic section is from Paddy Creek to Little Eagle Creek. Scenery is 

recognized as an outstandingly remarkable value (ORV) in the Eagle Creek corridor and thus requires 

protection and enhancement under the provisions of the Wild and Scenic Rivers Act. The scenery, 

described as an ORV is as follows: 

The designated portion of Eagle Creek possesses a great deal diversity in landform, water, color, 

and vegetation, notable in the geographic region. Some of the attractions that combine to create 

Eagle Creek’s scenic beauty are the glaciated landscape of the upper portion, the steep forested 

canyon with numerous rock pinnacles in the middle portion, and the terraced basalt canyon of the 

lower portion. In addition, there is the diversity of vegetation, including the lush meadows, 

mixed-conifer and ponderosa pine forests, and grassy openings; and the variety of the stream’s 

rapids, waterfalls and deep pools. Even though the Eagle Creek drainage has been a focus of 

human interest since the turn of the century, visual impacts due to modifications are relatively 

minor, and the drainage still presents an overall natural landscape pleasing to forest visitors. The 

preliminary finding agrees with Congress that scenery in the Eagle Creek corridor is an 

outstandingly remarkable river value. (Eagle Creek Wild and Scenic River Management Plan, 

1993)

The desired future condition stated for the Retention in the Wild and Scenic River corridor is as follows:

The areas with a VQO of Retention would be characterized as a natural appearing landscape in 

which management activities are not visually evident. There will be a pleasing variety of open 

and closed forest spaces, with accentuation of views toward mountain tops, hillsides, and valley 

floor meadows. A pleasing mix of tree species and ages, including deciduous species, will also be 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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present. Emphasis will be to perpetuate a characteristic landscape that visually mimics natural 

processes. Late seral stages, large trees, and increased desirable species (ponderosa pine, larch, 

aspen, hardwoods) will be emphasized in the corridor. Campgrounds will be predominantly 

screened from the road and river. Activities will be subordinate or unnoticed by forest visitors. 

(Eagle Creek WSR Management Plan, 1993, pg. 9)

The standards for scenery within the Eagle Creek Wild and Scenic River corridor are shown in the table 

below:

Table 113. Visual quality objectives in the Wild and Scenic River corridor

River Classification Visual Quality Objective

Wild Preservation- all distance zones

Scenic Retention-all distance zones

Recreation Retention-all distance zones

Recreation (trailed river section) Preservation – all distance zones

The project area is comprised of scenic and recreation classifications; therefore retention is the VQO 

within the wild and scenic river corridor.

Sense of place:

Sense of place is addressed to display how the area is perceived by the public, and to display the physical 

setting in which the project area lies. The Wallowa-Whitman NF defines a Sense of Place as “The identity 

of a place created by people’s social meanings and attachments, including valued scenery and recreation 

settings, cultural and spiritual values, economic, social and biophysical characteristics,” (USDA 1995. 

Landscape Aesthetics). Managers using the concept of sense of place must define a specific framework 

for the definition and use of sense of place. 

The Forest Service has developed the Recreation Niche process for recreation facilities analysis. This 

process was developed to define the particular recreation niche the forest could provide for the public. 

The Forest defined spatial units that had particular characteristics which could support a defined set of 

recreational experiences. The WWNF conducted a recreation facilities analysis which characterized the 

forest and defined spaces in terms of use and sense of place.

The project area lies primarily within the Wallowa Mountains. The characterization of this area is as 

follows:

Wallowa-Whitman National Forest niche statement

A Forest’s recreational program niche is reflective of its, “defining or unique characteristics and abilities.” 

For the Wallowa-Whitman National Forest, this niche spans 2.3 million acres from the central Blue and 

Wallowa Mountains in Northeast Oregon across the Snake River into the Seven Devils Mountains in 

Western Idaho. These diverse landscapes distinguish the Forest’s three main areas, Hells Canyon, the 

Wallowa Mountains, and the Blue Mountains. Visitors and local residents return to the Forest each year to 

enjoy a unique blend of: outstanding rugged scenery, backcountry and wilderness exploration; a variety of 

wild and scenic rivers and mountain lakes; Native American and pioneer history. 

Wallowa Mountains: Home of the Eagle Cap Wilderness, this setting is classically pristine with high 

alpine areas and powerful landscapes. Several Wild and Scenic rivers and high elevation lakes serve as 

destinations. 

Eagle Creek: The diversity of landforms, water, color, and vegetation present throughout the designated 

portion of Eagle creek is one of the most attractive attributes of the river corridor. Rock outcroppings are 

abundant and at times dramatic. Dark forested hillsides facing north are contrasted by south facing grassy 
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slopes sparse of trees. The valley floor alternates between flat meadows and narrow gorges as the river 

changes from calm, meandering and sometimes deep, to swift and shallow (Eagle Creek Wild and Scenic 

River Management Plan, 1993).

Snow Basin project area: This landscape is a steeply incised canyon land at the base of steep sub-alpine 

peaks. The drainages are a major component of the scenery. Steep slopes are covered with a mosaic of 

coniferous forest and grassy south slopes. Western larch provides fall color, and ponderosa pine provides 

open park-like stands of large tree boles amidst understory grasses and shrubs. Riparian areas support 

deciduous trees and shrubs that provide diverse fall color. Aspen stands can be found in places where 

moisture is available. Rocky outcrops punctuate scenic views. Eagle Creek is a prominent visual feature 

in the canyon bottom.

Desired scenic character

Broad landscape: 

The Snow Basin area lies adjacent to the Eagle Cap Wilderness from which Eagle Creek flows down 

through a steeply incised canyon. The project straddles the canyon, and the scenic character is a 

compilation of scenic attributes that are supported by the ecological context. These scenic attributes make 

up the scenic character. In the Snow Basin area the scenery is influenced heavily by the steeply incised 

canyons. The basalt rock formations provide strong vertical features on the steep slopes. The deciduous 

vegetation in the riparian areas provides fall color and textual diversity, as well as shade for recreation 

sites. The ponderosa pine stands have a strong visual characteristic of large trees in open park-like stands. 

The mixed conifer stands provide multi-layered characteristics and small openings create a mosaic across 

the timbered landscape. Eagle Creek and its tributaries are aesthetically very striking. All these attributes 

create very attractive scenery. The major scenic attributes are the timbered vegetation that is diverse and 

viable, the streams and the riparian deciduous vegetation, and the steep mountainous terrain. The minor 

scenic attributes are the rocky outcrop formations.

Scenic character context

The Blue Mountains section is the western most section of the Middle Rocky Mountain Steppe. The 

terrain has been formed by metamorphic and volcanic activity, which developed mountainous landforms. 

Today, the mountains are dissected by glacial and fluvial erosion processes. The project area is dissected 

most prominently by Eagle Creek and Paddy Creek. Coniferous vegetation spreads across the broad ridge 

tops, down the drainages, and across north facing slopes. South and west facing terrain has open grassy 

slopes. Riparian vegetation along streams is deciduous poplar, alder, and willow. Basalt outcrops 

accentuate the steep faces of the stream corridors. 

Culturally, the area has been utilized by Native American tribes which performed burning practices to 

improve the production of berries, big game forage, and to drive game. These fires, as well as lighting 

caused fires, thinned the non-resistant tree species from the stands, creating an open forest dominated by 

large ponderosa pine and western larch. Small aspen stands are found where conditions support them 

(Ecological Subregions of the United States: Section Descriptions, 1994).

Scenic attractiveness

“Scenic attractiveness is the primary indicator of the intrinsic scenic beauty of a landscape and of the 

positive response it evokes in people,” (Landscape Aesthetics, USDA, 1995). Based on commonly held 

perceptions of the beauty of landform, vegetation pattern, composition, surface water characteristics, land 

use patterns, and cultural features; the scenery is rated on a three point scale: 

• Class A: Distinctive, where landform, vegetation patterns, water characteristics, and cultural 

features combine to provide unusual, unique, or outstanding scenic quality
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• Class B: Typical, where landform, vegetation patterns, water characteristics, and cultural features 

combine to provide ordinary or common scenic quality

• Class C: Indistinctive, where the landscape does not have characteristics that add to the variety, 

unity, vividness, mystery, intactness, order, harmony, or uniqueness of the scenery

The Snow Basin has areas of Class A and Class B scenic attractiveness. The scenic attractiveness rating is 

applied to the process of evaluating the value of the area’s scenery resource.

Landscape visibility

The area roads provide varying degrees of visibility of the project units. These roads are assigned 

sensitivity levels in the Forest Plan. These concern levels are the measure of the degree of public 

importance placed on landscapes viewed from travelways and use areas. Levels are attributed by use 

levels, viewer interest in scenery and duration of view. The sensitivity levels are used to determine the 

appropriate visual quality objective for areas visible from the particular road or use area.

This project is located in a steeply dissected landscape. Therefore the visibility is variable. The steep 

slopes of the Eagle Creek drainage are visible where roads are present on the opposite side of the 

drainage. The project units that are located on the upper plateaus are less visible. The timber along these 

roads limits visibility, and project units would be seen for short durations as one traverses the road. From 

higher elevations such as Summit Point, much of the Snow Basin area is visible from a mid to 

background distance. The following table displays the sensitivity level of each road identified in the 

Forest Plan. Level 1 roads are the primary viewing platforms used for this analysis. Level 2 roads are 

considered viewing platforms when a portion of the same road is Level 1. Trails in the Eagle Creek Wild 

and Scenic River corridor are also viewing platforms.

Table 114. Travel route sensitivity levels

Road Concern Level

70 1

7010 3

7015 1,2

7020 2,2

77 2

7720 2,3

7725 1,2

7730 2,3

1132 1

7735 3

7739 2

Scenic classes

Scenic classes are derived from the scenic attractiveness, visibility and sensitivity levels. The scenic 

classes are a system of classification describing the importance or value of a particular landscape or 

portions of the landscape. Scenic classes range from Class 1 of very high value, to Class 7 of low value. 

The forest has inventoried and classified the forestlands, and assigned visual quality objectives by scenic 

class. Class 1 was given a VQO of Preservation.

Table 115. Scenic class, visual quality objective, and scenic integrity level

Scenic Class Visual Quality Objective Scenic Integrity Level

1 Preservation Very High
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2 Retention High

3 Partial Retention Moderate

4 Modification Low

5 Maximum Modification Very Low

6 Unacceptable Modification Unacceptably Low

Scenic stability

Scenic stability is the degree to which the desired scenic character can be sustained through time and 

ecological progression. For the Snow Basin area, the existing scenic stability analysis focuses on the 

single major scenery attribute of vegetation, addressing its ecosystem conditions identified by field 

observation and Fire Regime Condition Class (FRCC) 7 coarse-scale data on vegetation and fire history 

data. Ecosystem changes to other minor scenery attributes such as landform, rock outcrops, and winter 

snowfall are not as critical to the Snow Basin project area’s scenic character as its vegetation, since these 

changes are relatively stable over time regardless of fire behavior and human activities

Evaluating scenic stability is done by considering conditions necessary to sustain desired scenic character 

of stands within the natural and historic range of the landscape. Appropriate stand density, species 

composition, and fuel loads are necessary for stands to maintain the inherent characteristics through their 

lifecycle. When trends such as increasing stand density, encroachment of less resilient species, increasing 

fuel loads, and high levels of mortality exist; the expected consequences are change in the scenic 

character that are beyond the historic scale. Examples of these consequences are large canopy openings 

from intense wildfires, large stands of dead and dying timber, and loss of distinctive characteristic; such 

as open, large tree character pine stands, lodgepole pine stand mosaic, and multi-layered mixed species 

stands. Gradual trends over time have altered the species composition, stand structure, and age classes of 

the forest vegetation. Stands of large mature ponderosa pine providing an open forest are diminished due 

to encroaching mixed conifer species and past harvest practices that removed pine to release shade 

tolerant species.

Much of the coniferous vegetation is trending toward unsustainable conditions. Stocking levels, fuel 

loads, and species composition have departed from the reference/historic conditions. The historic fire 

regime of the ponderosa pine type is one of frequent low-intensity fires which have maintained lower 

stand densities and fuel loads at a healthy sustainable level. This low-intensity fire regime maintains a 

sustainable species composition of predominantly fire-resistant ponderosa pine. These conditions are 

specifically rated as fire regime condition class 2 and 3 which indicate that a fire occurrence would most 

likely burn at higher severity and at a larger scale than that which is historically characteristic. There are 

18,967 acres classified as condition class 2 and 3. This is 65 percent of the total project acreage. In 

addition to this measure, 86 percent of the project area has stands in conditions that would support stand 

replacement fire at higher intensities than would be expected within historical range of variation.

These conditions are rated at very low scenic stability because known scenery attributes such as open 

stands of ponderosa pine and the aspen stands are threatened by uncharacteristic fire and insects and 

disease due to these conditions.

Environmental Consequences 

Methodology 

The scenery effects analyses used for this section are those found in the Scenery Management Handbook 

#701, Appendix J. Scenery management is based on the classic aesthetic factors of form, line, color, and 

texture; as well as the principles of sense of place. It says, “Scenic integrity measures the amount of 

natural or socially valued appearance in a landscape along with the amount of visual disturbance that 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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contrasts with and detracts from the appearance (the valued scenic character) existing at the time of 

measurement.” Also important, “Scenic stability is an indicator of the ecological sustainability of the 

scenic character’s valued attributes,” (Landscape Aesthetics, USDA, 1995, Appendix J, 2007).

Incomplete and Unavailable Information

Information necessary for evaluating scenery effects is sufficient.

Spatial and Temporal Context for Effects Analysis 

Effects on scenery resources are short- and long-term. Short-term is less than five years, and long-term is 

5 to 50 years. Effects that are eliminated by the natural course of a single growing season are not 

considered effects because they are a so short-lived. Most treatments have long-term effects while the 

logging activities such as cable yarding, skidding, and slash burning are usually short-term effects lasting 

less than five years.

The project analysis area is the area from which the proposed treatments can be visibly discerned. Most of 

the analysis is done within the project boundary with the exception of Summit Point, which is a Trailhead 

and Fire lookout that affords a broad view of the project area.

The Scenery Management Handbook #701 is the source for scenery resource analysis.

Effects Common to all Action Alternatives

The effects of specific prescriptions are described in this section.

Intermediated commercial thinning (INT)

Thinning from below opens up the stands by removing the smallest diameter trees. This provides greater 

viewing distances into the stand, which is preferable. The appearance of the stands is improved by this 

treatment by making them appear healthier. The reduction tree stocking levels improves the resilience of 

the stands by reducing stress and ladder fuels, which reduces the risk of insect and disease epidemic 

occurrence, and stand replacement wildfire. This prescription also targets species that are not fire 

resistant, therefore further improving the resiliency of the stands. These are benefits that contribute to the 

improvement of scenic stability when carried out at a landscape scale.

This treatment will create stumps, slash and duff disturbance will be visible from foreground views. 

These effects will be minor within the first 1 to 2 years. As regrowth of shrubs and grasses occur, these 

effects will be significantly reduced. This prescription does not create openings that are visible from 

middle ground or background distances. The effects of this prescription do not reduce the scenic integrity 

of the unit.

Overstory removal (HOR)

This prescription removes some of the overstory trees to release the more viable understory trees to keep 

the stand health and more resistant to stand replacement fires and insects and disease. Treatments such as 

these open up the canopy producing textural change visible for middle ground views. Foreground views 

will be affected by stumps, slash and occasional skid trails. The resulting open canopy will allow more 

light to reach the forest floor, creating a dappled shadow appearance. These effects are short-term impacts 

to the immediate foreground and are addressed with project design features.

Quaking Aspen restoration/conifer removal

Quaking aspen stands provide diverse color in the area. This treatment removes conifers within and 

around the aspen stands to reduce the depletion of soil moisture that kills the root system. This treatment 

will create no effects to middle ground or background views. Foreground views will be affected by 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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remaining stumps. Slash is limited by whole tree yarding. This treatment serves to preserve the scenic 

attribute of quaking aspen stands.

Underburning natural fuels or activity fuels (RXF)

Underburning natural fuels (RXF) is a treatment uses to reduce litter and ladder fuels. Effects to scenery 

are minimal and short-lived. A growing season reduces the effects to the remaining scorched tree trunks 

and dead saplings. This treatment most successfully conserves scenery resources when thorough site 

preparation is done prior to underburning. Fire at low intensity is a natural occurrence in this area, and its 

effects do not degrade the scenic quality. This treatment can greatly improve a stands resiliency to large 

stand replacement fire which would greatly affect the scenic quality.

Site preparation-underburning 

The effects of this treatment is similar to the underburning of natural fuels, however the scorching and 

soil exposure is more intense. These effects are consistent with low-intensity fire.

Site preparation-whip felling (SCN)

This treatment removes the small saplings and non-crop trees to increase the conditions for fire resistant 

trees to dominate these stands. Removing these trees improves the large tree character and opens view 

into the remaining stands.

Non-commercial thinning (NCT)

This treatment reduces stocking levels to promote growth of desirable species, limit the threat of future 

disease and insect outbreaks, and reduce ladder fuels that increase fire intensity and the occurrence of 

crown fires. Removal of these trees opens view into stands. The effects to scenery are limited to 

foreground view effects of stumps and slash. See project design features for mitigation of these effects.

Leave top attached (LTA) and whole tree yarding (WTY)

Slash is reduced when tops are left attached and trees are yarded whole to the landing. This effectively 

leaves the forest floor cleaner with less slash and ladder fuel, which helps reduce fire intensity and 

improves scenic character.

Alternative 1 – No Action 

The No Action alternative would allow existing conditions and trends to remain and continue. The project

area currently has approximately 20,669 acres that have conditions supporting stand replacement fire, 

which poses substantial risk to the scenic attributes of the area. This is 86 percent of the project area. 

Although a no-action alternative would create no effects to the scenic integrity and meet all the visual 

quality objectives, it would leave conditions that put scenic attributes at risk.

Direct effects 

A “no action” alternative would have no short-term effects to scenic integrity or stability. Existing scenic

integrity and stability would remain the same, and the visual quality objectives would be met.

Indirect effects 

The indirect long-term effects related to the existing conditions and trends could be substantial. Although 

effects of stand replacement fire are not permanent, they are certainly long-term. Overstocked stands are 

under greater and greater stress, which is likely to lead to insect and disease epidemics. Fuel loads within 

the stands increase the hazards of stand replacement fire. All of these conditions will continue to degrade 

the scenic stability as stands crowd out fire resistant species and quaking aspen stands.
Chapter 3 Snow Basin Vegetation Management Project FEIS

315

In the event of a stand replacement fire, the scenic integrity would likely be greatly reduced by 

uncharacteristic fire, because firefighting opportunities would be limited due to fuel conditions that effect 

flame lengths.

In addition to the loss of large stands of trees, there are also other effects such as those associated with 

fire suppression efforts in and around capital investments such as campground, trailheads, and along roads 

which serve as suppression points and fire lines. Noxious weeds are often another effect after a fire event 

has occurred. 

Cumulative effects 

Continuing trends of increased understory vegetation will reduce views in and through the forest at the 

eye level in foreground views, and thus reduce the diversity of color and texture available to viewers.

Within the next 20 to 30 years, acres identified as Condition Class 2 will convert to Condition Class 3

adding the existing acres in Condition Class 3which pose high risk to scenery resources.

Compliance with Forest Plan and other relevant laws, regulations, policies, and plans 

Alternative 1 is compliant with the Visual Quality Objectives that are Forest Plan Standards.

Alternative 2 – Proposed Action 

Alternative 2 is a set of stand and fuels treatments designed to address the purpose and need. This 

alternative is fully defined in Chapter 2. The treatments would improve the long-term scenic integrity by 

opening stands up for increased visibility and visual diversity.

Design features and mitigation measures

The mitigation measures that will minimize the effects of logging activities include:

• Screen landings from FS roads 77, 7755, 7735, Martin Bridge Trail, or the Main Eagle Trail.

• New temporary roads and landings may be evident, but must remain subordinate to the shape and 

pattern of the natural appearing forest canopy.

• Foreground clearings (not to exceed 2 acres) should not – except in specific circumstances – be to 

treat insect or disease infestations or to open views to scenic attributes such as a rock formations, 

large ponderosa pine or other components, or views to distant mountain peaks.

• Skid patterns, slash, soil exposure, and stumps should be visually minor or unnoticed (4 inches

maximum height of stumps).

• Slash pile locations shall not be located within, 50 feet of FS roads 77, 7755, 7735, Martin Bridge 

Trail, the Main Eagle Trail, or developed or dispersed recreation sites.

• Residue from slash piles burned at landing sites shall be scattered, and the area shall be seeded. 

Direct effects 

Alternative 2 will increase visibility into stands by opening up the mid canopy, creating greater 

foreground diversity. Partial removal and commercial harvest treatments will leave the pine and larch 

species that have the desired large tree character and greater fire resiliency. This effort will improve the 

scenic character and the scenic stability of the area. Alternative 2 will treat 76 percent of the project area 

to improve species composition, stand density, and reduce ladder fuels and canopy closure. These 

treatments will improve scenic stability from low to high where, “all dominant scenery attributes of the 

valued scenic character are present and are likely to be sustained,” (SMS Appendix J).

Scenic integrity

This historic character is more fire resistant which will improve the scenic stability by reducing the risk of 

large uncharacteristic fire. The logging activities will cause short-term effects that will reduce scenic 
Chapter 3 Snow Basin Vegetation Management Project FEIS

316

integrity for a period of 1 to 3 years. Tractor yarding and skyline cable yarding will create visible effects 

for the first year including ground disturbance, slash and debris. However, after a growing cycle these 

effects will be negligible. See Effects Common to All Action Alternatives.

Road 70

Road 70 runs through partial retention and modification. Units within the this viewshed have 

prescriptions that would primarily alter the visual density related to basal area to create a more open forest 

with increased sunlight coming into the understory views. There would be no openings developed to 

create changes in form, line, or color. These prescriptions would meet the VQO of partial retention.

Road 7015

The viewshed of Road 7015 includes VQOs of partial retention and retention. The prescriptions in this 

area include intermediate harvest and prescribed fire. The harvest units where stumps may be visible are 

very limited. Units 324 and 325 are adjacent to the road for approximately 0.2 miles. However, in that 

area the road traverses a cut bank of approximately 15 feet in height, which would screen any views to 

stumps that may remain. The prescribed fire will create some scorching and pockets of mortality which is 

expected in this landscape. Partial retention would be met.

Road 7020

The views from Road 7020 are within VQO levels from modification to partial retention. The unit 

prescriptions along this route include partial removal harvest, commercial thinning, and prescribed fire. 

These prescriptions will improve the scenic character by moving stands toward a more historically 

characteristic landscape with open pine stands. It is expected that short-term effects to scenic integrity 

related to logging activities will be negligible within a year. These effects are related to initial disturbance 

of soils and stumps. The stumps will be cut low, and new understory vegetation will minimize the visual 

impact meeting the most restrictive VQO of partial retention.

Road 77

This road runs adjacent to Eagle Creek, up the Paddy Creek drainage, and then down South fork Spring 

Creek. The VQO within the Eagle Creek corridor is foreground retention. The units that are in the 

foreground of this viewshed are upslope and screened by roadside vegetation. Therefore any stumps 

created would not be visible. Unit 214 would be skyline logged, which would create a short-term impact 

that would no longer be visible after a year. Units within the middle ground of this viewshed would create 

an increase in coarse texture do to greater basal areas. This impact would meet the partial retention VQO.

Road 7720

Road 7720 is entirely within modification, and all prescriptions would meet this VQO.

Road 7725

Road 7725 runs through partial retention and modification. All units within this viewshed have 

intermediate harvest prescriptions that would meet the VQOs. It is expected that duff disturbance and 

slash treatments would be the primary short-term impacts. Stumps are expected to be visible but cut low 

within the immediate foreground.

Road 7730

Road 7730 is within the retention middle ground, partial retention and modification. The prescriptions in 

this viewshed are intermediate harvest and prescribed fire. The harvest will create texture differences in 

the middle ground and stumps, duff disturbances, and slash in the foreground. The prescribed fire will 

create a mosaic of scorching and pockets of dead trees. These impacts would meet the Forest Plan VQOs.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Road 7732

Road 7732 is within partial retention VQO, and prescriptions would be intermediate harvest. However 

this road is a closed road, therefore it is not viewing platform used to analyze the project effects.

Road 7735

The viewshed of Road 7735 is classified as retention and modification. Prescriptions of overstory removal 

intermediate harvest will create visual impacts associated with duff disturbance, slash treatments, and 

stumps. Prescribed fire will create short-term effects of scorching and pockets of dead trees. Unit 134, an 

intermediate harvest unit, will create stumps adjacent to the road in a foreground retention area for 

approximately 0.2 miles. However, the cut-banks along this road are expected to screen views of the unit 

understory. Retention and modification would be met.

Road 7739

The prescriptions within the viewshed of Road 7739 are intermediate harvest and prescribed fire. The 

impacts associated with these prescriptions would meet the VQO of viewshed, which is modification.

Martin Bridge Trail

The prescriptions visible from the Martin Bridge Trail are intermediate harvest and prescribed fire. The 

effects associated with the intermediate harvest will be a variation in texture, which is consistent with 

variations existing elsewhere within the view, meeting the VQO. The prescribed fire units will create a 

mosaic of scorching, green unburned areas, and pockets of dead trees; which is an expected natural 

appearing effect.

Short-term effects that will occur are those related to skyline logging. These effects are expected to be 

minimal, being within retention after a season’s growth cycle. These cable corridors will be visually 

negligible at specific locations along the corridor. 

Eagle Creek Wild and Scenic River corridor

Alternative 2 proposes to treat 2078 acres within the WSR corridor. Of those acres, 1,773 acres would be 

visible from Road 77 and/or the Martin Bridge Trail. There is also 1,188 acres visible from the road 

and/or trail outside the WSR boundary. There were also 560 acres considered questionably visible due to 

some discrepancies found in the seen area analysis. The river corridor is in a deep canyon where the 

visibility is limited by the steep slopes and canyon rim. Some acres were noted as visible beyond the 

canyon rim, which seems highly unlikely. Therefore, they were considered questionable. The seen area 

analysis was digitally derived from digital elevation models and did not take into account any vegetation 

screen that would occur. Therefore the seen area analysis is a “bare earth” visibility model. This analysis, 

therefore, identifies acres that would not be visible due to vegetation likely to be in the foreground of the 

viewer.

Of the 2,478 treatment acres visible within the WSR corridor, 1,178 acres are prescribed fire. Prescribed 

fire is a preferred treatment for managing vegetation within the Eagle Creek WSR.

Of the 1,770 acres visible within the river canyon, but outside the WSR river corridor 593 acres are 

prescribed fire and 409 acres are intermediate harvest and partial overstory removal. These commercial 

harvest treatments will not create any unnatural appearing forms, lines, or colors. However, 5 units (227 

acres) will require skyline cable logging systems that would create a short linear corridor associated with 

each unit. The corridor feature would be a short-term effect appearing for approximately one year after 

harvest implementation. The remaining acres are noncommercial thinning, which would create no 

noticeable effects.

The units within the Eagle Creek Wild and Scenic River Corridor are within a retention foreground VQO. 

The effects of the intermediate harvest and prescribed fire prescriptions will meet the VQOs. The 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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intermediate harvest units are at a distance that no stumps, slash treatments, or duff disturbance would be 

visible. Changes in texture would be created, but would still meet retention. Unit 304, 348, 349, 351, and 

352 require skyline logging which will create a short-term effects associated with a skyline corridor that 

will not be visible after a year. The natural appearing scenery would be retained. Foreground views would 

not be affected by the treatments. The project improves the resiliency as well as improves a fire 

suppression effort, which is crucial to protecting the scenery resources of the Wild and Scenic River. This 

table shows a breakdown of treated visible acres.

Table 116. Treated acres visible within Eagle Creek River Canyon

Treated acres 

visible within 

WSR viewshed*

Treated acres 

visible within 

WSR corridor

Treated acres 

visible outside 

WSR corridor

Prescribed 

Fire

1770 1178 593

Commercial 

Harvest

707 297 409

Skyline Cable 

Units/ Acres

5 units/466ac. 5 units/238ac. 5 units/227ac.

Total visible 

treated acres

2,478 1,476 1,002

*Total visible acres from Road 77 and Martin Bridge Trail

Scenic stability

The harvest and prescribed fire prescriptions proposed in Alternative 2 are designed to address the closed 

canopy, high density, fire-prone conditions that support stand replacement fire. The treatments would 

serve to improve the overall scenic stability by addressing conditions that put scenic attributes at risk of 

stand replacement fire and insect and disease epidemics. It is not expected that the risk will be eliminated. 

However, the treatments would improve opportunities for firefighters to minimize fire’s effects.

By favoring the fire resilient ponderosa pine and western larch, this alternative will move the stands 

toward the desired scenic character which is more resilient to fire. By reducing stand density, the 

remaining stands are less susceptible to insect and disease infestations and epidemics. By reducing ladder 

fuels, crown lengths are minimized giving greater opportunity for fire fighters to control the fire before it 

becomes a crown fire that would burn a much larger area than is historically characteristic.

Currently, these conditions exist in 20,669 acres, which is 86 percent of the project area. Alternative 2 

will treat 12,669 acres in a manner that makes those acres more resilient to stand replacement fire. This 

would reduce the non-resilient conditions to 47 percent. This would be an improvement from very low 

stability to low stability (SMS Appendix J).

Indirect effects and cumulative effects 

Treatments reducing flame length such as prescribed fire (RXF) treatments that reduce ladder fuels create 

indirect effects to scenery by providing greater firefighting opportunities. This in turn will most likely 

indirectly affect the size and severity of fire events, thus reducing the effects to scenery resources. It is 

expected to be much more likely effects of fires in this area will remain within the size and severity 

characteristic to the historical range.

The timber sale history in this area includes sales from 1954 to 2003. Timber sales 20 years and older 

have no remaining effects to scenic integrity. Any openings create during this time have since been 

populated by trees, eliminating openings. The harvest activities since 1989 have been treatments that did 

not create openings or affect the scenic integrity in a negative manner. These treatments primarily 

addressed density and species composition in immature stands. This alternative will similarly address 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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these issues throughout the area to have a cumulative positive effect to scenic stability while maintaining 

the scenic integrity.

Compliance with Forest Plan and other relevant laws, regulations, policies, and plans 

It is expected that Alternative 2 will not reduce the scenic integrity. It will retain the existing visual 

quality objective standards established in the Forest Plan and the Eagle Creek Wild and Scenic River 

Management Plan.

Alternative 3

Alternative 3 will not treat units that would result in a net loss of Late Old Stands (LOS) in the project 

area. The units Alternative 3 would not treat are those with LOS characteristics, but which are not 

resilient to fire. These stands, which are primarily composed of non-fire resilient species, are not 

characteristic of the historical large tree character that is the scenic attribute of this area.

Design features and mitigation measures

These are the same as Alternative 2 above.

Direct effects 

Alternative 3 will also, like Alternative 2, increase visibility into stands by opening up the mid canopy, 

creating greater foreground diversity. The partial removal and commercial harvest treatments will leave 

pine and larch species that have desired large tree character and greater fire resiliency. This effort will 

improve scenic character and scenic stability of the area. However, the stands with LOS character that 

were proposed to be treated by Alternative 2 would not be treated in this alternative. The stands that 

would not be treated in this alternative have LOS character, but are of species that are not fire resilient 

and are not historically characteristic. Therefore, these stands would continue to have conditions that are 

susceptible to fire. This would not be a notable affect to overall scenic integrity or stability.

Scenic integrity

Short-term effects that will occur are those described in the effects common to all action alternatives. 

Foreground views will experience more open stands and greater viewing distance into the stands. Middle

ground views will have visible alteration to textures created by thinning units. Like Alternative 2, this 

alternative would meet the VQOs of the Eagle Creek WSR. There would be very little difference in 

effects to scenery between Alternatives 2 and 3. Units 348 and 352 that would be skyline cable logged in 

Alternative 2 would not be logged in Alternative 3. This would be reduced short-term impacts of the 

skyline cable corridor that would exist with implementation of Alternative 2.

Scenic stability

Currently, these conditions exist in 20,669 acres which is 86 percent of the project area. Alternative 3

would treat 11,443 acres in a manner making those acres more resilient to stand replacement fire. This 

would reduce the non-resilient conditions to 52 Percent, an improvement from very low stability to low 

stability. (SMS Appendix J).
Chapter 3 Snow Basin Vegetation Management Project FEIS

320

Eagle Creek Wild and Scenic River corridor

Table 117. Treated visible acres within Eagle Creek River canyon

Treated acres 

visible within 

WSR viewshed*

Treated acres 

visible within 

WSR corridor

Treated acres 

visible outside 

WSR corridor

Prescribed 

Fire 908 440 468

Commercial 

Harvest 624 217 407

Skyline Cable 

Units/ Acres 46 units/398ac. 19 units/173ac. 27 units/225ac.

Total visible 

treated acres 398 173 225

*Total visible acres from Road 77 and Martin Bridge Trail

Indirect effects and cumulative effects 

The treatments reducing flame length such as RXF treatments that reduce ladder fuels and canopy 

closure, create indirect effects to scenery by providing greater firefighting opportunities if a fire should 

occur. This alternative will not address the LOS stands that are not made up of non-fire resilient species. 

Many of these stands have characteristics in need of being addressed to provide firefighting opportunities. 

However, this alternative will indirectly affect the size and severity of fire events reducing the effects to 

scenery resources. It is expected it will be much more likely that effects of fires in this area will remain 

within the size and severity characteristic to the historical range.

Timber sale history in this area includes sales from 1954 to 2003. Timber sales 20 years and older have no 

remaining scenery effects to scenic integrity. Any openings create during this time have since been 

populated by trees and thus eliminated the openings. Harvest activities since 1989 have been treatments 

that did not create openings or affect the scenic integrity in a negative manner. These treatments primarily 

addressed density and species composition in immature stands. This alternative will similarly address 

these issues throughout the area to have a cumulative positive effect to scenic stability, while maintaining 

the scenic integrity. Avoiding LOS stands of non-fire resilient trees will perpetuate the existing condition 

in these stands, reducing the cumulative effectiveness of the treatments.

Compliance with Forest Plan and other relevant Laws, regulations, policies and plans 

It is expected Alternative 3 will not reduce the scenic integrity and will retain the existing visual quality 

objective standards established in the Forest Plan and the Eagle Creek Wild and Scenic River 

Management Plan.

Alternative 4

Alternative 4 will not remove trees larger than 21 inches, nor will treatments resulting in net loss of LOS 

stands would be implemented. A scenic attribute making up the scenic character are large diameter tree 

boles in the area. However, historic context for large tree character is for fire resilient tree species such as 

ponderosa pine and western larch to provide the large tree character. Today, many of the trees larger than 

21 inches diameter at breast height (DBH), such as grand fir, are not fire resistant species. These stands 

tend to be non-fire resistant.

Design features and mitigation measures

Same as Alternative 2.
Chapter 3 Snow Basin Vegetation Management Project FEIS

321

Direct effects 

Alternative 4 is similar to Alternatives 2 and 3 in that it will increase visibility into stands by opening up 

the mid canopy, creating greater foreground diversity, except within LOS stands. The partial removal and 

commercial harvest treatments will leave the pine and larch species that have the desired large tree 

character and greater fire resiliency. This effort will improve scenic character and stability of the area. 

However, stands made up of large trees over 21 inch DBH will not be treated.

Scenic integrity

Short-term effects that will occur are those described in the effects common to all action alternatives. 

Foreground views will experience more open stands and greater viewing distance into the stands. Middle

ground and background views will have visible alteration to textures created by thinning units. Units 348 

and 352 that would be skyline cable logged in Alternative 2 would not be logged in Alternative 4. The 

visual quality objectives are expected to be met.

Scenic stability

Currently, these conditions exist in 20,669 acres which is 86 percent of the project area. Alternative 3

would treat 10,276 acres in a manner making those acres more resilient to stand replacement fire. This 

would reduce the non-resilient conditions to 57 percent, an improvement from very low stability to low 

stability (SMS Appendix J).

Eagle Creek Wild and Scenic River

Table 118. Treated visible acres within Eagle Creek River canyon

Treated acres 

visible within WSR 

viewshed*

Treated acres 

visible within 

WSR corridor

Treated acres 

visible outside WSR 

corridor

Prescribed Fire 4,617 565 4,052

Commercial 

Harvest 9,190 212 8,978

Skyline Cable 

Units/ Acres 32 units/272ac. 14 units/125ac. 18 units/147ac.

Total visible 

treated acres 13,839 778 13,062

*Total visible acres from Road 77 and Martin Bridge Trail

Indirect effects and cumulative effects 

Treatments reducing flame length such as RXF treatments that reduce ladder fuels and/or reduce canopy 

closure create indirect effects to scenery by providing greater firefighting opportunities. This in turn will 

most likely indirectly affect the size and severity of fire events, reducing the effects to scenery resources. 

It is expected it will be much more likely that effects of fires in this area remain within the size and 

severity characteristic to the historical range.

Past management

Timber sale history in this area includes sales from 1954 to 2003. Timber sales 20 years and older have no 

remaining effects to scenic integrity. Any openings created during this time have since been populated by 

trees and openings eliminated. Harvest activities since 1989 have been treatments that did not create 

openings or affect the scenic integrity in a negative manner. These treatments primarily addressed density 

and species composition in immature stands. This alternative will similarly address these issues 

throughout the area to have a cumulative positive effect to scenic stability, while maintaining scenic 
Chapter 3 Snow Basin Vegetation Management Project FEIS

322

integrity. By not removing trees over 21 inch DBH, the treatments will not be as effective in reducing the 

canopy closure in non-fire resilient stands, reducing the cumulative effectiveness of the project.

Current management

There are two current ongoing vegetation projects on the Whitman Ranger District adjacent to the 

analysis boundary of this project: the Skookum Timber Sale and the Barnard Timber Sale. On industrial 

lands Forest Capital has recently harvested 440 acres within the analysis boundary. This harvest has 

reduced surface, ladder, and crown fuels. Private land owners in cooperation with Oregon Department of 

Forestry have implemented vegetation management projects on 1,029 acres and utilized prescribed 

burning on 370 acres adjacent to the forest boundary within the wildland urban interface (WUI). 

Approximately 626 acres of non-commercial thinning, piling, and prescribed burning has been 

accomplished in the Carson/Pine Valley WUI, which is adjacent to the project area. Avery small portion 

(32 ac) of this WUI boundary lies within the project.

Grazing and fuelwood cutting also reduce fuel loading which indirectly adds to the cumulative benefit to 

improving scenic stability.

The combined and continued fuel reduction efforts of all ownerships will reduce the potential for a large, 

high-intensity wildfire to spread through the area, which is essential to maintaining scenic stability. The 

majority of projects within the area are proving to be of minimal to no effect to scenic integrity. 

Compliance with Forest Plan and other relevant laws, regulations, policies, and plans 

It is expected that Alternative 4 will not reduce scenic integrity, retaining existing visual quality objective 

standards established in the Forest Plan and the Eagle Creek Wild and Scenic River Management Plan.

Summary of Effects

The action alternatives all meet Forest Plan VQOs and WSR objectives and standards. The alternatives all 

retain the existing VQOs and therefore meet the Forest Plan Standards and Guides for Scenery. They all 

achieve an improvement in scenic stability from very low to low.

The following table shows the summary and compliance of the action alternatives.

Table 119. Summary of scenery effects and compliance

Overall 

scenic 

integrity

Existing scenic 

stability

Achieved scenic 

stability

Forest plan 

compliance

Wild and scenic river 

compliance

Alt. 2

Partial 

retention to 

retention

Very Low Low Meets Forest 

Plan VQOs

Meets WSR objectives and 

standards

Alt. 3

Partial 

retention to 

retention

Very Low Low Meets Forest 

Plan VQOs

Meets WSR objectives and 

standards

Alt. 4

Partial 

retention to 

retention

Very Low Low Meets Forest 

Plan VQOs

Meets WSR objectives and 

standards
Chapter 3 Snow Basin Vegetation Management Project FEIS

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RECREATION RESOURCES

Executive Summary

Although the majority of recreation activities within the Snow Basin project area are predominately 

dispersed in nature, there is also an array of developed sites, trail use and special use permitted activities. 

Other than the presence of the wild and scenic river, the number of facilities, development scale of the 

recreation sites and predominant recreation uses are fairly typical for other areas across the forest. Harvest 

activities and fuel treatments may change the available recreation opportunities for the short-term (up to 

two years after treatments are initiated). Actions commonly associated with harvest activities and fuel 

treatments like increased traffic, operation of heavy equipment, noise, dust, fire and smoke may displace 

or discourage visitors from using areas until the activities diminish. Long-term effects of harvest and postharvest treatments will elicit various responses from recreationists. Recreationist seeking more open 

stands of forest may enjoy increased scenery views and improved opportunities like snowmobiling and

big-game hunting. Other visitors may view harvest activities with a reduction of large trees or more open 

canopies as a loss in opportunities to view natural features or observe wildlife. Associated road activities

also bring forth a mixture of effects for motor-vehicle based recreationist and non-motorized 

recreationists.

Introduction

This section covers recreational opportunities related to dispersed recreation, developed sites, trails and 

recreation special uses outside of the Eagle Creek Wild and Scenic River corridor. There is a separate 

section for the recreational uses in the Eagle Creek Wild and Scenic River (WSR), which is a 

congressionally designated area.

Existing Conditions

Forest niche

The Wallowa-Whitman National Forest (WWNF) developed a recreation program niche reflecting its 

defining or unique characteristics and abilities (WWNF, 2006). To define these characteristics, the niche 

focuses on setting descriptions and emphasis, site function, key activities, site types and capacity. The 

Snow Basin project area is within the “Wallowa Mountains” setting. The three settings for the forest were 

delineated based on large geographic areas with elements of landscape characteristics, common 

management themes, similar recreation activities and site developments. The “Wallowa Mountains” is 

characterized as: a mixture of backcountry roads and trails transitioning into wilderness. This designation 

is a mid-range recreation setting set between the “Hells Canyon” setting (a combination of river corridors, 

scenic byways, viewpoints and access into upland areas/wilderness and cultural sites) and “Blue 

Mountains” setting (more traditional uses along forest routes transitioning into the backcountry). Major 

activities identified in the “Wallowa Mountains” setting include; hiking, backpacking, horseback 

riding/packing, viewing wildlife and scenery, fishing, snowmobiling and hunting.

Recreation activities 

Although no specific recreation use studies were completed for Snow Basin, inferences can be made to 

the typical types of activities that occur in the project area based on a national recreation survey. In 2008 

the WWNF conducted the National Visitor Use Monitoring (NVUM) survey (WWNF, 2009) to gather 

information about recreation visitor satisfaction, activities and use levels. One product of the survey 

revealed the primary and overall participation levels for various activities. See the Recreation Specialist 

Report to view the participation in WWNF recreation activities and location of survey respondents.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Although inferences can be made from NVUM survey or from local manager’s observations about the 

types of uses that occur in Snow Basin, no specific information is available to better understand why 

visitors come to this area. One reason for visitation to an area may be linked to a visitors “sense of place.”

Sense of place is the human connection to a place, and may involve meanings and values that facilitate 

intimate connections with particular geographical area (Farnum, et al., 2005). This is an individual’s

attachment to a place based on both internal (i.e. emotional, personal, social, cultural, activity) and 

external factors (i.e. scenic, aesthetic, landscape). It also varies between local residents who often feel 

they have a unique, special, privileged sense of place and tourists or regular visitors who also have strong 

attachments to places. Since this is an individual’s “human connection” to a place, it is anticipated that a 

variety of comments and reactions to management proposals will be received. However managers face a 

challenge in that there will be multiple senses of place and a variety of possibly conflicting meanings and 

attachments amongst users.

Dispersed recreation

Visitors participating in dispersed recreation activities do not primarily use or rely upon developed sites 

such as campgrounds or picnic areas to conduct their activity. However, they may use a developed site to 

support their activity, such as parking at a trailhead or getting drinking water from a campground, but 

their main time is spent away from the developed sites. All of the recreation activities listed in the 

Recreation Specialist Report (except developed camping) could be viewed as dispersed recreation 

activities. Other ones which may be seen in the project area include activities like OHV use, 

snowmobiling, horseback riding and cross-country skiing. Visitation for these dispersed activities in areas 

known as “general forest areas” (non-wilderness areas) account for over 54 percent of the total forest 

visits according to the NVUM survey (WWNF, 2009). 

Dispersed camping is a popular activity for overnight users who do not camp in a developed campground. 

Outside the wild and scenic river corridor area there are 33 identified dispersed campsites. These 

campsites receive low to moderate use beginning in late spring with the majority of sites showing heaviest 

use during the fall hunting season. They are identified by their rustic user-built features such as rock fire 

rings, tables and meat poles (to hang big game). The campsites are primarily located in flat areas off main 

transportation systems adjacent to water sources like streams and meadows. Camp sizes vary but the

average ones can accommodate 1 to 2 vehicles with larger ones hosting 3 to 4 truck/trailer or RV units. 

Many of these campsites have been used for decades with some sites showing soil compaction and a loss 

of vegetation.

As shown in Recreation Specialist Report, other types of dispersed recreation occur year-round. Visitors 

enjoying these recreational pursuits may use forest roads as transportation networks (i.e. OHV riders, 

snowmobile riders, cross-country skiers, driving for pleasure, viewing wildlife), or just travel cross 

country away from roads and trails (i.e. hunters, viewing nature, fishing, hiking or walking). 

Recreationists who pursue dispersed activities often do so for a combination of desires to: be away from 

crowds, seek solitude, enjoy nature (scenery, geology, wildlife) and cultural sites, seek challenges or 

adventure, or wanting to be more self-reliant.

Currently OHV use can occur both on designated open roads, closed roads, trails and in many crosscountry locations in Snow Basin. Overall motor-vehicle use in the area is light yet it does increase during 

the big-game hunting season. There are two cooperative travel management areas which restrict motorvehicle uses during certain periods of the year. These areas are managed in conjunction with the Oregon 

Department of Fish and Wildlife within the project area (See the Recreation Specialist Report).

Developed recreation sites

There is only one developed recreation site located outside of the wild and scenic river corridor in Snow 

Basin. This small facility known as Summit Point Trailhead is located on the northeast edge of the project 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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area. The site has parking for about 5 truck and trailer vehicles (approximately 15 people) and some stock 

structures like hitching rails and loading ramps. It has a development scale of 2 which is defined as 

having minimum site modification, rustic or rudimentary improvements designed primarily for protection 

of the site rather than the comfort of the user. The site is used to access the Cliff River Trail (#1885) into 

the Eagle Cap Wilderness. Overall use of the facility is low except during fall hunting season when it may 

be used at a moderate level.

Developed trails

As typical in other areas on the WWNF, this area has both summer horse/hiker trails and winter 

snowmobile trails. 

Table 120. Developed trails

Trail Name and Number Miles in Project/ 

(Total Miles )

Designed Use Trail Class (USDAFS, 2008)

Sullivan (#1946) 0.4 mi (6.6) Pack saddle 3 – developed

Cliff River #(1885) 0.3 mi (10.5) Pack saddle 3 - developed

Forshey Snowmobile (#S-7000E) 0.8 mi (7.6) Snowmobile 3 – developed

Empire Gulch Snowmobile (#S-7015) 2.9 mi (4.7) Snowmobile 3 – developed

Lily White Snowmobile (#S-7020) 3.3 mi (4.5) Snowmobile 3 – developed

Eagle Drive (#S-7700E) 8.2 mi (27.8) Snowmobile 3 – developed

Little Eagle Snowmobile (#S-77150) 5.5 mi (10.1) Snowmobile 3 – developed

Project Area Totals = 21.4 miles

The trailhead for the Cliff River Trail is located at Summit Point. This trail receives moderate use in the 

summer and fall to access the Eagle Cap Wilderness. Sullivan Trail does not have an established trailhead 

and receives light use. The 21.4 miles of designated and groomed snowmobile trails are all located on 

existing open forest roads. They are part of a larger trail system that attracts touring snowmobilers 

throughout the winter months, December through April. Staging areas for these trails are located out of 

the project area in Halfway, Forshey Meadows and Catherine Summit. 

Permitted uses

Some recreational activities are managed under permits, which allow recreationists or operators to do 

certain activities under the terms of the permits. These permits include; gathering firewood, gathering 

forest products like mushrooms, hunting and recreation special use activities. Use of these permits can be

considered “recreational” since visitors often participate in them for primary or secondary forms of 

enjoyment.

Annually the WWNF sells over 2,500 personal use firewood permits and over 1900 forest product 

permits like mushroom and Christmas tree tags. Each permit has terms and conditions which guide uses 

and locations for the activities. Although no data is available for how many permits are used in Snow 

Basin, these activities can generally occur in most areas outside of riparian areas, old growth, tree

plantations and other special designated location described on the permits. There are no long-term 

recreation special use permits such as outfitter and guides inside the project area.

Snow Basin lies within the Keating Wildlife Management Unit. The area is popular during big game bow 

and rifle seasons in late summer and fall and turkey season in the late fall and early spring. Oregon 

Department of Fish and Wildlife will continue to offer hunting opportunities in this area as part of their 

management of big game.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Consistency with laws, regulation, and policy

Since this Recreation section of Snow Basin covers the areas outside of the Eagle Creek Wild and Scenic 

River corridor, management direction is primarily found in the 1990 Wallowa-Whitman National Forest

Land and Resource Management Plan (Forest Plan) (WWNF, 1990). The following direction pertains to 

the project’s harvest activities’ and fuel treatments’ effects on the recreation setting and visitor 

opportunities.

Forest Plan Recreation Goal

The recreation resource goal found in the Forest Plan is to, “...provide a wide variety of recreation 

opportunities in an attractive setting, and make those opportunities available to all segments of society.”

The project will meet this goal because the current wide variety of recreation opportunities will still be 

available to all segments of the public during and after project implementations. The elimination of any 

recreation opportunity is not part of the project alternatives. All action alternatives will meet the visual 

quality objectives as directed in the Forest Plan (See Visuals/Scenery Resource section).

Desired Future Conditions

The Forest Plan also describes a desired future condition (DFC) in 10 and 50 years. The following 

summarizes the 10 year DFCs that apply to Snow Basin:

• Providing an increased emphasis of recreational opportunities for users

• Retaining the range of current recreation uses, yet recognizing there will be changes in the 

amount and location of some opportunities

• Some semi-primitive opportunities will be lost to development, but quality semi-primitive areas 

will remain to meet demands

• Opportunities for trail-related recreation within other management areas will be available

• Dispersed recreation sites will retain their desired character although surrounding lands will often 

change significantly due to management activities

• Fuelwood will continue to be available, yet may be more difficult to obtain

The project will meet the DFCs because a wide variety of recreation opportunities will still be available to 

all segments of the public during and after project implementations. However there may be some changes 

in the amount and location of some opportunities in the short-term due to harvest activities and fuel 

treatments. Quality semi-primitive motorized opportunities will remain on most of the project area. Trail 

related activities will not be affected by the project. Harvest activities and fuel treatments will change the 

surrounding lands adjacent to some dispersed recreation sites. Fuelwood permits will still be issued under 

the terms of the permit areas for many locations within the project area.

Recreation Opportunity Spectrum

To guide project activities and ensure the Forest Plan recreation goal and DFCs are being followed, the 

Forest Plan uses the recreation opportunity spectrum (ROS) framework for stratifying and defining 

classes of outdoor recreation environments, activities and experience opportunities. There are seven ROS 

classes arranged along a continuum from primitive to urban. Snow Basin has two of these classes within 

the project area:
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Table 121. ROS goals

ROS Class & 

Acres outside of 

WSR

Summary of ROS Goals

Roaded Natural

(25,083 acres)

Timber harvest may be scheduled

Visual Quality Objectives (VQO) of “retention” and “partial retention” as seen from roads and 

trails are met

Access is generally single or double lane dirt/gravel roads

Road management objectives are to accept or encourage use by dispersed recreationist in 

highway vehicles

Dispersed recreation sites should be development scale 2 or less (i.e. sanitary facilities, 

interpretive sites)

Use densities in people at one time (PAOTs) per acre range between 0.04 and 0.25. Density 

includes averaging in developed sites

Norm for developed sites should be development scale 3

Interpretation is through forums such as signs, overlooks, boardwalks using native-like 

materials

Semi-primitive 

Motorized

(40 acres –

located near 

Conundrum Creek 

on northern side of 

project)

Vegetation management may range from no timber harvest to limited unscheduled 

regeneration cutting and sanitation salvage for the purposes of maintaining a healthy 

attractive semi-primitive setting.

Harvest units must meet “foreground retention” VQOs

Motorized harvesting may be done on primitive roads during low public use seasons

Public access on trails and primitive roads range from most difficult to easiest

Road management objectives will encourage high clearance 4-wheeel drive vehicles and trail 

bikes

Site development should be development scale 2 or less

Interpretation is very limited using on-site facilities, maps, brochures and other portable 

media

The ROS goals will be met for the Roaded Natural setting because the project involves timber harvest 

activities with compliance of the Visual Quality Objectives (VQO). (See Visuals/Scenery Resource 

section). Road management activities will continue to provide for dispersed recreation. The project does 

not propose any changes to the dispersed site development levels, developed site user densities or any 

interpretation developments. 

The ROS goals will be met for the Semi-Primitive Motorized setting because the project involves timber 

harvest activities with compliance of the VQOs (See Visuals/Scenery Resource section). Motorized 

harvesting from primitive roads will be conducted during low public use periods. Public access on road 

and trails will remain with the allowed difficulty range and road management objectives. The project does 

not propose any interpretation developments.

Forest Plan Standards and Guidelines

Other Forest Plan Recreation Standards and Guidelines that apply to the proposed activities in Snow 

Basin include:

Standard 6:

Recreation: Develop and maintain opportunities for winter recreation where needed.

There are no long-term proposals to decrease winter recreation opportunities. Some short-term limitations 

may result with winter time hauling.

Standard 7: 
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328

Provide networks of marked groomed snowmobile routes through agreement with snowmobile clubs.

Snowmobile trails have the potential to be impacted if a designated snowmobile route is plowed for 

winter haul. Coordination with the local snowmobile clubs may alleviate the concern if alternate 

temporary routes are groomed during the short-term

Standard 11:

Recreation Site Development: Develop recreation sites, by ROS class, using the descriptions found in the 

Forest Plan Table 4-6.

No changes are proposed that will modify the ROS classes at the developed sites.

Standard 13:

Outfitters and Guide: Outfitter guide activities may be considered within any management area, although 

outfitter camps will not be located within research natural areas.

There are no outfitter and guides in the project area.

Standard 14:

Special Areas: Protect special places on the Wallowa-Whitman National Forest: e.g. dispersed recreation 

sites, water features, rock or unique landform features, areas of unique vegetation, historic sites or other 

places which are special to Forest users commensurate with other Forest management Objectives.

Special areas will be protected as part of the harvest activities and fuel treatments.

Standard 15:

Road, Trail, and Area Closures: Road, trail, and area closures and off-road vehicle use will be in 

accordance with the Forest Travel Management Plan and 36 CFR 295 This plan will be reviewed annually 

and revised as necessary, considering management needs and public desires.

See Appendix B for a discussion on the Forest Travel Management Plan.

Forest Plan Management Areas

Forest Plan Management Areas for Snow Basin are found in the Snow Basin FEIS. Recreation Standards 

and Guidelines for these Management Areas are outlined in the table below.

Table 122. Forest Plan Management Areas (MA) and recreation standards and guidelines

Management Areas Applicable Recreation Standards & Guidelines

(Compliance response)

1 - Timber production 

emphasis

17. Recreation. Recognize undeveloped campsites, hunter camps or areas where 

concentrated recreation use occurs as being significant in producing and utilizing 

dispersed recreation opportunities. Prescriptions for timber harvesting, cleanup, site 

preparation and thinning will consider the environmental setting that contributes to the 

attraction of these sites for recreation purposes. The attempt will be made to retain 

this attractive character during and after treatments.

(Harvest and operational prescriptions will be developed to retain the attractive 

characteristics of the dispersed sites during and after treatments)

1W - Timber production 

emphasis with winter range 

habitat

Same as above

(See the above response)

15 - Old growth habitat 14. Recreation. Roaded natural and roaded modified recreation opportunities will be 

provided
Chapter 3 Snow Basin Vegetation Management Project FEIS

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(The project does not propose any change to the Roaded Natural ROS class in MA 

15 or other parts of the project area)

16 - Administrative and 

Recreation Sites

11. Provide roaded natural and rural recreation opportunities

(The project does not propose any change to the Roaded Natural ROS class in MA 

16 or other parts of the project area)
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Methodology and Measurement Indicators

Methodology

The method of analysis included:

• A review of the appropriate Forest Service policy and goals, objectives and standards of the 

Forest Plan

• An analysis of the Forest Plan recreation opportunity spectrum (ROS)

• Project site visits

• A review of Forest-level recreation use surveys

• A review of the USDA Forest Service literature related to recreation management (i.e. sense of 

place)

• Wallowa-Whitman National Forest GIS database queries (i.e. dispersed recreation points, 

developed recreation points, management areas)

• Database queries for the USDA Forest Service I-web database

The existing condition was compared with possible changes to recreation use if alternatives were 

implemented.

Measurement Indicators

To display the differences between alternatives, indicators have been identified that affect the recreation 

activities. The qualitative rationale for these analysis indicators are summarized below.

Table 123. Indicators

Indicators Effects Summary

Acres of timber harvest (commercial harvest of timber, 

post harvest noncommercial thinning and noncommercial 

thinning)

Restricts/discourages access into harvest units due to 

closures or work activity

Discourages/displaces use due to physical obstacles 

(i.e. slash), dust and noise

Decreases of habitat for forest products (i.e. berries) 

or increases habitat for forest-products (i.e. 

mushrooms)

Increases localized use by visitors wanting more open 

stands, and decreases localized use by visitors 

wanting more closed or untreated stands and larger 

trees

Loss or change of vistas, scenery, natural features or 

wildlife viewing opportunities from developed sites

Increases roadside safety from hazard tree removal

Acres of post-harvest fuels treatments (grapple pile, hand 

pile/burn)

Restricts/discourages access into units due to 

closures or post-harvest activity

Discourages/displaces use due to physical obstacles 

(i.e. slash piles) and noise

Decreases habitat for forest products (i.e. berries) and 

increases habitat for forest-products (i.e. mushrooms)

Increases localized use by visitors wanting more open 

stands, and decreases localized use by visitors 

wanting more closed or untreated stands and larger 

trees

Loss or change of vistas, scenery, natural features or 

wildlife viewing opportunities from developed sites
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Acres of Prescribed Fire (post-harvest activity fuels 

treatment and “stand alone” prescribed fire only)

Restricts/discourages access into treatment units due 

to closures or work activity

Discourages/displaces use due to active fire or 

residual smoke 

Loss or change of vistas, scenery, natural features or 

wildlife viewing opportunities from developed sites and 

dispersed areas

Miles of Road Reconstruction (Deferred maintenance on 

open/closed roads, road realignment)

Restricts/discourages access into dispersed area or 

developed sites due to work activity

Loss of access after temporary roads close

Increases roadside safety from hazard tree removal

Miles of Temporary Road Construction Temporarily decreases opportunities for dispersed 

activities away from motorized uses

Miles of Danger Tree Removal along Roads Increases visitor safety

Miles of Road Decommissioning Decreases motor-vehicles use when roads are 

decommissioned

Increased opportunities for dispersed activities away 

from motorized uses

Miles summer or winter road haul (for existing roads open 

to passenger car and high clearance vehicles)

Discourages access into harvest units, dispersed 

areas, developed sites 

Eliminates snowmobile use on haul routes

Increases forest products gathering and winter 

recreation on typically unplowed routes

Effects Analysis

Spatial and Temporal Context for Effects Analysis

The environmental effects will be discussed in different timeframes. For direct and indirect effects, a 

short-term for recreational visitors is viewed as occurring within two years (or two visitation seasons from 

the beginning of the implementation activity (i.e. harvest, post-harvest activities and prescribed fire

treatments are on-going). Long-term is viewed as a period of time ranging from two to ten years after 

initiating the implementation activity (i.e. harvest and post-harvest activities are done). 

Effects Common to All Alternatives

Past projects and actions

Past projects and actions which have affected recreation uses include timber harvest, road construction

and recreation uses. Residual effects of past timber harvest influences dispersed recreation activities by 

displacing some uses (i.e. big game hunters may go to areas with more denser canopy covering, berry 

pickers may go to areas where plants are more abundant), whereas it may have encouraged other uses (i.e. 

open areas allow better viewing background scenery). Road construction has had both a positive and 

negative effect. It has been viewed by some users as increasing access to areas, yet has had a negative 

affect for non-motorized users who may have previously used an unroaded area. The allowance of crosscountry travel has affected some non-motorized recreation activities due to sight, sound and emissions of 

vehicles. The establishment of dispersed camps has provided traditional camp sites by making user 

created routes to the sites and expanding the “campable” area.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Future projects and actions

See Appendix B-10 for a discussion on the Forest Travel Management Plan and the reconstruction of 

Forest Service road 77.

Alternative 1 - No Action

Direct/Indirect Effects: There would be no direct or indirect effects under Alternative 1-No Action. 

Vegetation densities or characteristics would not be modified, and the forest would continue to be 

influenced by natural processes and limited management actions, such as fire suppression. Since no 

implementation activities will result under this alternative, no change is anticipated in the number of 

visitors, frequency or season of use in dispersed recreation activities, developed recreation sites, trails or 

permitted uses. Recreational visits within the project area would remain near the same levels as previous 

years, and under this alternative traditional use patterns and recreational opportunities would not be 

impacted. Hunting, hiking and other dispersed recreation and permitted uses access and opportunities are 

expected to remain unchanged.

Effects common to Alternatives 2, 3, and 4

Direct/Indirect Effects: The specific project activities with potential to impact recreation are common to 

all the proposals in Alternatives 2 to 4. Each of these alternatives propose different levels of activities but 

the effects to the public involved in different recreation endeavors common to the area is relatively the 

same. Alternatives 2, 3, and 4 will include four main project activities that will affect recreation:

• Timber harvest (commercial harvest of timber, post-harvest noncommercial thinning and 

noncommercial thinning)

• Post-harvest activity fuels treatments (grapple pile, hand pile/burn)

• Prescribed fire (post-harvest activity fuels treatment and “stand alone” prescribed fire 

prescriptions)

• Road and Access activities (danger tree removal along open system haul roads, temporary road 

construction, permanent road reconstruction, road realignment, road decommissioning, bridge 

reconstruction and repair)

A review was made of the project proposal for Alternatives 2 to 4 with the Forest Plan Goals, Desired 

Future Conditions, and Standards and Guidelines. As discussed above in the “Consistency with Laws, 

Regulations and Policy” section, the project proposals are consistent with all elements of the Forest Plan.

Dispersed recreation

Dispersed recreation activities will be affected by all four types of project activities mentioned above. In 

the short-term; timber harvest, post-harvest and prescribed fire activities may restrict user access into a 

treatment unit due to safety purposes. Users may also be discouraged from entering a unit due to the 

presence of equipment and workers. This may occur in peak summer visitations or during the fall hunting 

seasons. Downed trees, slash piles, loss of forest-products (i.e. mushrooms, berries), active fire and 

residual smoke will also discourage visitor use in an area. Noise and other disturbances may affect the 

quality of the recreation experience for an individual regardless of the proximity to the activity. 

A change in natural features or landscape characteristics may elict different responses in visitors. One 

attraction to an area may be linked to visitors “sense of place” (Farnum, et al., 2005). A visitor’s sense of 

place includes attachments to external factors like natural features or landscape characteristics. Important 

landscape features may consist of large old growth trees and groves, variety of trees species, an open or 

closed tree canopy, rock formations, water bodies and natural appearing openings (USDA-FS, 1995). The 

proposed treatments such as harvesting large trees, reducing slash or altering canopy cover will change or 

remove some of these natural features. In some cases the changing landscape will displace or discourage 

certain types of dispersed recreational activities (i.e. studying nature, viewing wildlife). In other areas it 
Chapter 3 Snow Basin Vegetation Management Project FEIS

333

may encourage new dispersed recreational activities (i.e. big game hunting, photography) not available 

under the previous landscape.

For Alternatives 2 and 3 there are 14 dispersed camps that are within harvest units, and in Alternative 4 

there are 11 camps. Depending on when the timing and proximity of the treatment activities occur, 

campers at these sites may be displaced or have a less quality experience due to noise, equipment activity

and dust. For Alternatives 2 and 3 there are two dispersed camps within units scheduled for prescribed 

fire, and in Alternative 4 there are 5 camps. Similar to camps within harvest units campers again may be 

displaced or have a less quality experience due to smoke, active fire and equipment activity.

Direct effects to recreationists accessing the 33 dispersed camps or other areas will occur on roads during 

haul periods. The presence of large trucks or an increased frequency of traffic may discourage road use to 

these sites as well as associated activities outside the WSR corridor until the road work subsides. When 

roads are being constructed/reconstructed visitors may expect delays or closures during work periods. 

Once temporary roads are closed or system roads are decommissioned they will no longer be available for 

snowmobile access to backcountry areas. If roads are used for winter haul, they may be available for 

access by winter recreationist like cross-country skiers which is uncharacteristic in most years due to 

closure by snow.

Long-term effects of harvest and post-harvest treatments will elicit various responses from recreationists. 

Recreationist seeking more open stands of forest may enjoy increased scenery views, improved crosscountry skiing or snowmobiling and some types of big-game hunting and wildlife viewing. Other visitors 

may view a loss of large trees and denser forest as a reduction in opportunities to view natural features 

and scenery, observe wildlife, relax and take shaded hikes. Another long-term effect is safe and adequate 

roaded and trail access for the recreating public, through the cutting of danger trees and improving visitor 

travel. This is also long-term effect for Developed Recreation and Permitted Uses. 

Developed recreation

Although similar to the effects of dispersed recreation, developed recreation is more limited due to the 

number of sites in Snow Basin. Access to developed sites will be delayed or restricted during haul periods

or road construction. The presence of large log trucks and other equipment on haul routes may discourage 

users from driving the main access route to developed sites or to associated off-site recreation activities. 

The noise, dust, smoke and equipment activity during harvest, post-harvest and prescribed fires may 

affect the quality of the recreation experience for a visitor regardless of the proximity to the activity. The 

frequency and intensity of these activities may vary from a few hours to several weeks. Some loss or 

change of vistas, scenery, natural features or wildlife viewing opportunities may result with the vegetation 

treatments and prescribed fire activities visible from the developed sites. No long-term effects are 

expected.

Developed trails

There would be no direct or indirect effects to the summer pack saddle/ hiking trails since no activities are 

proposed on them. Snowmobile trails have the potential to be impacted if a designated snowmobile route 

is plowed for winter haul. Coordination with the local snowmobile clubs may alleviate the concern if 

alternate temporary routes are groomed during the short-term. 

Permitted uses

All permitted uses are authorized under the term and conditions of a permit which allows activities not 

available to a non-permitted user. Most of these uses are intrinsically tied to road access, and the removal 

of forest products is dependent upon specific areas or vegetation. Permitted uses will be affected by all 

four project activities mentioned above. Similar to dispersed recreation; timber harvest, post-harvest and 

prescribed fire activities have short-term effects and may restrict or discourage entry into a harvest unit. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

334

Depending on the level of treatment activity, permit users may be displaced to other areas inside or 

outside Snow Basin. Increased obstacles like downed trees and slash piles or loss of forest-products (i.e. 

mushrooms, berries) will also change harvest patterns. Residual smoke, dust, fire, noise and equipment 

activity is also not conducive to a quality recreation experience. The same effects for road use described 

in “Dispersed Recreation” are also applicable to this recreation use. If roads are used for winter haul, they 

may be available for access by winter recreationists like Christmas tree cutters who normally do not have 

access in many roads during the winter due to deep snow packs. Firewood cutters may find some benefits 

from roadside “salvage” but may lose opportunities if firewood is removed from a unit as part of the fuel 

reduction prescription.

Long-term effects of harvest and post-harvest treatments will solicit various responses from permit users. 

Permit holders like mushroom pickers, will find short-term benefits from open, disturbed mixed-conifer 

forest stands, whereas berry pickers may view the loss of berry patches as a negative impact. 

Cumulative effects

Wild and Scenic River: Unreasonably Diminish: Section 7 (a) of the Wild and Scenic River Act requires 

an evaluation of water resource projects outside the river corridor to determine if they, “...will not invade 

the area or unreasonably diminish the scenic, recreational and fish and wildlife values present in the area 

as of the date of designation...” In reviewing the project proposals as related to recreation, it has been 

determined they will not invade the tributaries since none are proposed in the tributaries. In addition they 

will not unreasonably diminish the recreation resource in the adjacent area outside of the WSR corridor 

because:

• The available types and annual use for dispersed recreation activities will not be affected 

unreasonably in the short- and long-term. No prohibitions are being made to the dispersed 

activities. Dispersed uses may fluctuate each year, but other factors like weather, choosing a 

different vacation destination, fuel prices and success/non-success of obtaining a hunting tag also

influences use in an area.

• The number, annual use and site capacity for developed recreation sites will not change in the 

short- or the long-term. All developed recreation sites will remain open, no individual 

campsites/grounds will be altered, and as mentioned above use varies depending on factors other

than the level of project activities.

• The number of trail miles and use will not change in the short- or long-term. No prohibitions are 

being made to the number of trail miles or trails open and available for use.

• The number of permits and areas will not change in the short- or long-term. No changes in the 

terms of the permits or available locations are part of this project.

Summary of Effects

The following table displays the quantitative differences in units (acres/miles) for each of the indicators 

discussed above in Table 123.

Table 124. Comparison of alternatives (ALT)

Indicators ALT 1 ALT 2 ALT 3 ALT 4

Acres timber harvest 0 11,163.9 10,782.3 9,082.1

Acres post-harvest fuels 

treatment 0 5,056.1 4,516.8 4,282.6

Acres prescribed fire 0 3,635.1 3,406.8 4,052.5

Miles of road reconstruction 0 36.0 34.8 32.9
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Miles of temporary road 

construction 0 9.5 9.0 0

Miles of road danger tree 

removal 0 218.0 213.5 203.2

Miles of road decommissioning 0 5.5 5.5 5.5

Miles road haul (summer/winter) 0 218.0 213.5 203.2

*Note: all numbers have been rounded up to 0.0)

Irreversible and irretrievable commitments of resources

There are no irreversible and irretrievable commitments to the recreation resource associated with any of 

the alternatives analyzed. The number, available types and use capacity for developed, dispersed and trail 

recreation activities will not be changed by the project proposal.

Monitoring requirements

Monitoring requirements are shown in Appendix B-1.
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WILD AND SCENIC RIVER RESOURCES

Executive Summary

The Eagle Creek Wild and Scenic River was designated under the national wild and scenic river system in 

1988 with the Omnibus Oregon Wild and Scenic Rivers Act (Public Law 100-557 and amended the Wild 

and Scenic River Act P.L 90-542). The river is currently managed under direction from the 1994 Eagle 

Creek Wild and Scenic River Management Plan (WWNF, 1993). A majority of recreational uses along 

the 9.5 miles of Wild and Scenic River (WSR) corridor in Snow Basin are dispersed activities, similar to 

the adjacent area outside of the corridor. There are also a few small developed recreation sites, trails and 

special use permitted activities. Eagle Creek is typical of other wild and scenic rivers on the WallowaWhitman National Forest (WWNF) for the number of facilities, development scale of the recreation sites

and common recreation uses. 

Harvest activities and fuel treatments may change or influence the available recreation opportunities for 

the short term of up to two years after treatments are initiated. Actions commonly associated with harvest 

activities and fuel treatments, like operation of heavy equipment, additional road use, dust, noise, fire and 

smoke may displace or discourage visitors from using areas until the activities diminish. Recreationists 

respond differently to the long-term effects of harvest and post-harvest treatments. Those seeking more 

open stands of forest may enjoy increased scenery views and improved opportunities like snowmobiling 

and big-game hunting. Other visitors may view harvest activities with a reduction of large trees or more 

open canopies as a loss in opportunities to view natural features or observe wildlife. Associated road 

activities also bring a mixture of effects for motor-vehicle based recreationist and non-motorized 

recreationists.

Introduction

This section covers recreational opportunities related to dispersed recreation, developed sites, trails and 

recreation special uses in the Eagle Creek Wild and Scenic River corridor. There is a separate section for 

recreational uses outside of the Eagle Creek WSR corridor in the Recreation Resource section.

Existing Conditions

Eagle Creek Wild and Scenic River

The Eagle Creek Wild and Scenic River was designated under the national wild and scenic river system in 

1988 with the Omnibus Oregon Wild and Scenic Rivers Act (Public Law 100-557 and amended the Wild 

and Scenic River Act P.L 90-542). The river is currently managed under direction from the 1994 Eagle 

Creek Wild and Scenic River Management Plan (WWNF, 1993). The River Plan provides direction for 

the designated river corridor, including the 3,422 acres of river corridor and 9.5 miles of river in the 

project area. This WSR is to be managed for the identified outstanding remarkable values (ORV) which 

include: recreation, scenery, geology/paleontology, fisheries and historic cultural resources. Recreation 

Opportunity Spectrum (ROS) classes in the project are: Scenic river sections – Semi-primitive Motorized 

(2,182 acres), and the Recreation river – Roaded Natural ROS (1,240 acres). The 3,423 WSR corridor 

acres within Snow Basin is about 12 percent of the project area.

Forest niche

Eagle Creek WSR is within the “Wallowa Mountains” setting as described in the WWNF recreation 

program niche. A summary of the forest niche can be found in the Recreation Resource section and 

Recreation Specialist Report.
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Recreation activities

The common recreation activities which are found outside of the WSR corridor are similar to those within 

the corridor. A summary of these recreation activities can be found in the Recreation Resource section 

and Recreation Specialist Report.

Dispersed recreation

As discussed in the Recreation Specialist Report (Recreation Activities, Dispersed Recreation section),

dispersed recreation activities in the project area includes uses such as viewing wildlife and natural 

features, hiking, fishing, dispersed camping, hunting and driving for pleasure. These are also common 

types of dispersed recreation observed within the WSR corridor.

Dispersed camping is popular along Eagle Creek because it offers flat camping and parking areas in 

shaded sites off Forest Service Road 77. Along the Recreation section of the river there are 17 identified 

dispersed campsites. (There are none identified in the Scenic river section). These campsites receive low 

to moderate use beginning in late spring with the majority of sites showing heaviest use during the fall 

hunting season. The sites are identified by their rustic user-built features such as rock fire rings, tables and 

meat poles (to hang big game). Like other dispersed camps on the forest, camp sizes vary. The average 

site can accommodate one or two vehicles. Larger sites can host three or four truck/trailer or RV units. 

Many of these campsites have been used for decades with some sites showing soil compaction and a loss 

of vegetation.

Eagle Creek and the adjacent riparian habitat also attract other types of dispersed recreation use unique 

from the upland project area. The river’s Outstanding Remarkable Value (ORV) along the 9.5 miles of 

river offer a natural appearing environment where visitors can experience solitude, self-reliance, 

challenge and risk. Typical use may include: viewing scenery, hiking, wildlife viewing, studying and 

viewing natural features such as riparian plants or birds.

Currently OHV use can occur both on designated open roads, closed roads, trails and although terrain 

discourages cross-country use it has not been prohibited in some areas in the WSR corridor. Overall 

motor-vehicle use in the area is light, yet it does increase during the big-game hunting season. The Eagle 

Creek Cooperative Travel Management Area lies in the southeast part of project area along Eagle Creek.

It is managed in conjunction with the Oregon Department of Fish and Wildlife, and includes 

approximately 1,108 acres within the WSR. The closure period restricts motor-vehicle uses from 

December 1 through April 15, except for snowmobiles.

Developed recreation sites

There are three developed recreation sites in the wild and scenic river corridor – Eagle Forks 

Campground, Martin Bridge Trailhead and Eagle Forks Trailhead. The Eagle Forks Campground and 

Eagle Forks Trailhead are located on the southern project boundary and on the edge of the Scenic and 

Recreation river line. Part of Eagle Forks Campground is outside the project boundary. This rustic 

campground has six single-family campsites, one group campsite, an accessible toilet and a well. District

Recreation Managers report overall use of the campground varies. Use is low in spring and early summer, 

moderate during the summer, and moderate to high on peak holiday weekends. The Eagle Forks Trailhead 

has a small pullout area and information board. The Martin Bridge Trailhead has a larger parking area for 

five truck and trailer vehicles and an information board. Both trailheads receive low amounts of use from 

spring through fall.

Table 125. Developed recreation rites

Recreation Site PAOTS Site Development 

Scale

River Section

Eagle Forks Campground 40 3 Scenic
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Eagle Forks Trailhead 7 2 Scenic

Martin Bridge Trailhead 16 2 Recreation

*PAOTS – “People At One Time” site capacity. Estimating an average of 5 people per campsite, and 3 to 4 people 

per trailhead parking site

Development Scale 2 = Minimum site modification: Rustic or rudimentary improvements designed primarily for 

protection of the site rather than the comfort of the user

Development Scale 3 = Moderate site modification: Facilities about equal for protection of natural site and comfort of 

users (USDA-FS, 2006)

Developed trails

As provided in the 1990 Wallowa-Whitman National Forest Land and Resource Management Plan 

(Forest Plan) ROS Standards and Guidelines and Desired Future Condition, there are summer horse/hiker 

and winter snowmobile trails in both the wild and scenic river sections. Only the Martin Bridge Trail has 

developed trailheads – a northern trailhead at Martin Bridge and a southern trailhead at Eagle Forks. 

Motor-vehicle use is currently allowed on the Martin Bridge Trail. The snowmobile trail segments are all 

located on existing open forest roads. They are part of a larger trail system both within and outside the 

WSR that attracts touring snowmobilers throughout the winter months, December through April. Staging 

areas for these trails are located in Halfway, Forshey Meadows and Catherine Summit. District Recreation 

Managers report that overall use of the winter and summer trail is low with users expecting few 

encounters with each other during the season.

Table 126. Developed trails

Trail Name and Number Scenic 

(mi)

Recreation 

(mi)

Total WSR

miles

Trail Class

Martin Bridge (#1878) 5.8 0.6 6.4 3 – developed

Empire Gulch Snowmobile 

(#S-7015)

1.0 0.7 1.7 3 – developed

Lily White Snowmobile (#S-7020) 0 1.1 1.1 3 – developed

Eagle Drive (#S-7700E) 0 3.8 3.8 3 – developed

East Eagle Snowmobile (#S-7745) 0 0.3 0.3 3 – developed

Project Area Totals = 6.8 6.5 13.3

Permitted uses

An overview of the same types of permitted uses that occur within the WSR corridor is found in the 

Recreation Resource section and Recreation Specialist Report. Permitted activities such as firewood and 

Christmas tree cutting are not authorized in designated campgrounds, wild and scenic river corridors, old 

growth areas, active timber sales units and other special designated locations described on the permits. 

There are no long-term recreation special use permits such as outfitter and guides inside the project area.

Snow Basin lies within the Keating Big Game Management Unit. The area is popular during big game 

bow and rifle seasons in late summer and fall, as well as for turkey hunting in the fall and spring. Oregon 

Department of Fish and Wildlife will continue to offer hunting opportunities in this area as part of their 

management of big game and turkey.

Consistency with Laws, Regulations and Policy

The management direction provided in the Forest Plan was intended to be interim direction until a river 

management plan was developed and the Forest Plan amended. In 1994 Eagle Creek Wild and Scenic 

River Management Plan (River Plan) was approved and amended as Forest Plan 15. The following 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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direction pertains to the project’s harvest activities and fuel treatments, and their effect on the recreation 

setting and visitor opportunities in the WSR.

Desired Future Conditions

A summary of the general Desired Future Conditions (DFC) from the River Plan are:

• The Outstandingly Remarkable Values (ORV) of fish, recreation, scenery, cultural (historic) 

resources, geology/ paleontology will be protected and enhanced. 

• The entire river corridor will be free of impoundments. 

• Enhancement of river corridor ecosystems, riparian vegetation and water quality will receive high 

emphasis, balanced with improved management of recreation uses.

• Vegetation Management within the corridor will emphasize maintaining a healthy and diverse 

river ecosystem.

• The corridor will have a predominance of late seral stands, abundant snags and old growth 

groves. 

• All vegetation management activities within the corridor will contribute to the protection and 

further enhancement of ORVs. 

• Prescribed fire will often be used to meet river management objectives. 

• Small selective cuts and timber sale units will be used in the regulated portion of the corridor to 

provide a highly diverse mosaic of vegetative types and enhance OR values.

• “Scenic” River segment: evidence of timber harvest and other of human activity may be present 

but will not detract from the near natural appearance and scenic qualities of the immediate 

environment.

• “Recreational” River segments: Although past and ongoing activities such as timber harvest and 

other developments may be evident near the river, the landscape will still appear to be 

predominantly natural appearing to the general forest visitor.

The project will meet the DFCs because the ORVS will be protected or enhanced (see 

Watershed/Aquatics, Visuals/Scenery Resource, Heritage/Paleontology sections). The project does not 

propose any impoundments. The purpose and need for the project is to maintain a more resilient and 

sustainable-forested ecosystem. Timber harvest activities will occur but will be planned to maintain and 

not detract from the natural appearance of the landscape. More information about how these DFCs are 

being met can be found in the Forest Vegetation and Fire/Fuels Management sections.

Recreation Desired Future Conditions

As detailed in the River Plan, Recreation is an ORV with specific Desired Future Conditions for this 

resource value. The applicable DFC conditions for Snow Basin include:

• The quality and diversity of recreation opportunities available, as well as excellent opportunities 

to interpret the area’s unique natural history and the region's gold mining history qualify 

recreational values in the corridor as outstandingly remarkable.

• Those conditions that contributed to the OR value finding will be enhanced over time.

• Visitors will find forested, uncrowded settings with rustic facilities and diversity of recreation 

opportunities that are dependent on or enhanced by the largely free-flowing nature of the river. 

• Recreation use would be monitored. Low to moderate increases would be allowed as long as 

consistent with protection and enhancement of river values and WRS and ROS use density 

guidelines are met.
Chapter 3 Snow Basin Vegetation Management Project FEIS

340

The project will meet the Recreation DFCs because the quality and diversity of recreation opportunities 

(ORV) will be maintained. It does not propose to restrict or eliminate the existing types of diverse 

recreation opportunities. The project will allow visitors to continue to find forested, uncrowded settings 

with rustic facilities since the developed recreation sites capacity and facilities will not be altered. 

Scenic River (Semi-primitive Motorized ROS)

• There is a moderate probability of experiencing solitude, closeness to nature, self-reliance, 

challenge and risk in using motorized equipment.

• The area is characterized as a predominately natural appearing environment.

• Access to the corridor is available by a main road, but most of the area is accessible only by trail.

• Off-road motorized opportunities are available yet discouraged and limited.

• Low to moderate increases in use would be allowed but user concentration would be low.

• Dispersed camping will be limited to current levels by controlling off-highway access.

• The area will be managed with minimum on-site controls and restrictions, but these would be 

subtle. Access for people with disabilities is difficult and challenging. 

• Interpretation will occur through maps or brochures rather than on site facilities. 

• Trails would be maintained at current design and maintenance levels. Some new trails may be 

constructed to accommodate increased use.

• No new major recreation facilities would be planned.

• Existing facilities would be rustic, rudimentary and primarily for site protection; and would use 

native, undimensioned materials. Emphasis would be on maintaining the quality and variety of 

recreational experiences rather than on adding facilities to accommodate increases in recreational 

use.

The project will meet the Scenic River DFCs because it does not propose to restrict or alter the probability 

of experiencing solitude, closeness to nature, self-reliance, challenge and risk along the WSR corridor. 

The area will remain characterized as a predominately natural appearing environment. (See 

Visual/Scenery Resources Specialist Report). The existing access to the corridor will remain on the main 

Forest Road 77 and most of the Scenic river section will be accessible only by the Martin Bridge Trail. 

There are no proposals for changing off-road motorized use, dispersed camping levels, site control, 

interpretation or adding new recreation facilities.

Recreational River Segments (Roaded Natural ROS)

• There is opportunity to affiliate with other users in developed sites with some chance for privacy. 

Self-reliance on outdoor skill is only of moderate importance. There is little challenge and risk.

• Area is characterized as a mostly natural appearing environment as viewed from the river or the 

main roads. 

• Access and travel is by conventional motorized travel including sedans, trailers, RVs and some 

motor homes. 

• Interaction between users at developed camp sites is of moderate importance. Dispersed sites 

would be limited to current levels by controlling off-highway access. 

• Obvious on-site controls of users will occur.

• Access for people with disabilities is available to all developed sites and is of only a moderate 

challenge. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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• Interpretation would be by wayside signs made out of rustic materials and some casual 

interpretation in campsites by forest staff. 

• Trails would be maintained at current design and maintenance levels. Some new trails may be 

constructed to accommodate increased use. 

• Off-road motorized opportunities would be readily available. 

• Recreation facilities would be available and designed for user comfort and convenience. Some 

synthetic but harmonious materials may be incorporated. 

• Recreation facilities would be maintained at current levels but would be modified to provide 

increased access for those with disabilities, to separate recreational stock users from non-stock 

users and to better protect and enhance ORVs. 

• Some increase in developed site overnight capacity would be allowed to accommodate some 

increased visitor use, but emphasis would be on maintaining the quality and variety of developed 

and dispersed recreational experiences rather than on adding facilities to accommodate moderate 

to large increases in recreational use. 

The project will meet the Recreation River DFCs because it does not propose to change interactions or 

privacy in developed/dispersed recreation sites nor change the opportunity for self-reliance and limited 

levels of challenge and risk. The area will remain characterized as a mostly natural appearing 

environment as viewed from the river or the main roads (See Visuals/Scenery Resource Specialist 

Report). There are no proposals for changing access for different vehicle types, off-road motorize use, 

dispersed camping levels, developed sites capacity, site control, interpretation or adding new recreation 

facilities. Recreation facilities would still be available for use. 

River Plan Standards and Guidelines

WSR Recreation Standards and Guidelines (S&G) that apply to the proposed activities in Snow Basin 

include:

Standard 4: 

ORVs of the river must be protected and enhanced. Give protection and enhancement of OR values, water 

quality and free-flow priority over uses described or implied in all other management direction and 

standards and guidelines. If potential conflicts arise between the OR values which cannot be resolved 

within the direction of the W&SR Act or this plan, then they shall be resolved according to the following 

priorities: 1) Fisheries, 2) Recreation, 3) Scenery, 4) Historic Cultural Resources, 5) 

Geology/Paleontology.

As stated above, the project will meet the DFCs because the ORVs will be protected or enhanced (See 

Watershed/Aquatics, Visuals/Scenery Resource, Heritage/Paleontology sections). The project does not 

propose any impoundments.

Standard 5:

The highest designated classification must be maintained. Activities, development and access in the river 

corridor cannot be allowed to increase to the degree that classification would be changed (i.e., 

classification cannot be changed from Wild to Scenic or Scenic to Recreational).

No activities are proposed that will change the river classifications.

Standard 7: 

Because the corridor is a congressionally designated area, an environmental assessment will normally be 

the minimum NEPA documentation for any ground or vegetation disturbing activity.

This Snow Basin Vegetation Management FEIS will satisfy this standard.
Chapter 3 Snow Basin Vegetation Management Project FEIS

342

Standard 8. Recreation: The following standards and guides apply to all three river classifications. Also 

refer to Forest Plan direction for Recreation, Management Area 4 (Wilderness), Management Area 16 

(Administrative and Recreation Site Retention) and FSM 2354. The most restrictive direction applies, 

unless there is an exception below: 

This Wild and Scenic River analysis is following the management direction in the Eagle Creek WSR Plan. 

None of the project boundary is within the wilderness area.

Standard 9:

Recreation use levels will be monitored. Low to moderate increases in recreation use will be allowed as 

long as consistent with protection and enhancement of OR values and WRS and ROS use density 

guidelines. Keep use increases at these lower levels by not adding major recreational developments and 

keeping road surfacing and road access at current levels. Management actions to limit use to protect river 

values may be required at some time in the future.

No recreation use monitoring is proposed as part of this project because no long-term changes are 

anticipated. Current activities will not be restricted and no developed or dispersed site capacity changes 

are proposed. 

Standard 11: 

Current mix of recreational opportunities would be maintained. New uses will be allowed but only if they 

ensure protection and enhancement of OR values. No major recreation developments not listed in the 

Forest Plan are proposed.

As stated above, the current mix of recreational opportunities will be maintained. Current activities will 

not be restricted and no developed or dispersed site capacity changes are proposed. No developments of 

recreation facilities are proposed.

Standard 14:

Existing facilities would be maintained at minimum levels. An active program to close and rehabilitate 

incompatible sites where resource damage is occurring would be pursued. 

Maintenance or closure of existing facilities is not part of this project.

Standard 19:

Trail reconstruction and maintenance is permitted in all classifications. Trail upgrades will be allowed for 

resource protection, user safety or to better accommodate existing uses.

Maintenance, reconstruction or upgrades of existing trails are not part of this project.

Standard 23:

Off-highway vehicle (OHV) use may be permitted on designated routes in the Scenic or Recreation 

segments south of the Main Eagle Creek Trailhead. Opportunities for OHV use in the Scenic River 

section would be reduced over current levels by not promoting motorized activities on the Martin Bridge 

Trail and by maintaining the trail primarily for pack and saddle use rather than motorized use.

There are no changes to OHV uses as part of this project, however the upcoming Forest Travel 

Management Plan will designated where motor-vehicle use including OHVs will be authorized and may 

change the existing condition.

Table 127. River Classifications and ROS Standards and Guideline #24

River Classification Applicable Recreation Standards & Guidelines

Scenic River (2,182 acres) 1) Manage areas for a Semi-primitive Motorized ROS setting.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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(Project activities will not change the ROS setting)

2) The existing access level will be maintained. No new access will be developed. 

Current road use and motorized use of Martin Bridge Trail will be allowed, but nonmotorized uses will be favored off the existing roads throughout the scenic river 

section. 

(See response for S&G 23 above)

3) Recreation developments are permitted but will not exceed development Scale 2. 

(The project does not propose to change the development level or scale for any 

recreation sites)

4) Recreation facilities will not exceed Development Scale 2.

(See above response. Eagle Forks Campground lies at the southern end of the 

project boundary in the Scenic and Recreation sections, although it is development 

scale 3 the project will not address this situation)

5) Interpretive materials will generally be off-site in nature (brochures, self-guided 

tours, etc.) and designed to protect and enhance ORVs. 

(Interpretation proposals are not part of this project)

Recreation River

(1,240 acres)

1) Manage areas for a Roaded Natural setting. However, activities shall be managed 

towards the less developed end of Roaded Natural spectrum. 

(Project activities will not change the ROS setting)

2) Road access will be provided to most areas along the Recreational sections. The

existing level of access will be maintained. No new access will be developed.

(The project does not propose new recreational road access or develop any new 

roads changing the development level or scale for any recreation sites)

3) Off highway vehicle use may be permitted on designated routes. New OHV areas 

will not be developed in the corridor. 

(See response for S&G 23 above)

4) Recreation developments are permitted but will not exceed development Scale 3. 

Native materials, or native appearing, will be the norm.

(The project does not propose to change the development level or scale for any 

recreation sites)

5) Interpretive brochures, turnouts, signs and displays may be developed, which are 

consistent with protection and enhancement of OR values. Favor ORVs or other 

river-related themes in developing displays. 

(Interpretation proposals are not part of this project)

The Existing Condition, Desired Future Conditions and effects analyses for the individual ORVs will be 

discussed in the Visual/Scenery, Fire/Fuels Management, Wildlife, and Vegetation Resource Specialist 

Reports.

Methodology and Measurement Indicators

Methodology

The method of analysis included:

• A review of the appropriate Forest Service policy and goals, objectives and standards of the 

Forest Plan

• An analysis of the Forest Plan recreation opportunity spectrum (ROS)

• A detailed review of the Goals, Desired Future Condition and Standards and Guidelines in the 

Eagle Creek Wild and Scenic River Management Plan (WWNF, 1993)

• Project site visits

• A review of Forest-level recreation use surveys
Chapter 3 Snow Basin Vegetation Management Project FEIS

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• A review of the USDA Forest Service literature related to recreation management (i.e. sense of 

place)

• Wallowa-Whitman National Forest GIS database queries (i.e. dispersed recreation points, 

developed recreation points, management areas)

• Data base queries for the USDA Forest Service I-web data base

The existing condition was compared with possible changes to recreation use if alternatives were 

implemented.

Measurement Indicators

The same measurement indicators that were used for project activities outside of the WSR are used inside 

the corridor. The qualitative rationale for these analysis indicators is found in the Recreation Resources 

section Table 123.

Effects Analysis

Spatial and Temporal Context for Effects Analysis

The same spatial and temporal context for the effect analysis cited in the Recreation Resources section is 

applicable for the Wild and Scenic River corridor.

Design Features and Mitigation Measures

Any design features, best management practices and/or mitigation measures are found in the individual 

sections for Fisheries/Aquatics Species, Visuals/Scenery, Forest Vegetation and Heritage/Paleontological. 

A Wild and Scenic River Act Section 7, “Evaluation of Proposed Water Resource Projects” was 

completed for the activities proposed in the Eagle Creek Wild and Scenic River Corridor. The evaluation 

concluded that a Section 7 Analysis would be needed for two types of proposals:

• Timber harvest, prescribed fire and post-harvest activities within the WSR Corridor

• Effects on the Scenery ORV that may invade or have an unreasonable diminution to this value.

EFFECTS COMMON TO ALL ALTERNATIVES

Cumulative Effects

The same cumulative effects discussed in the Recreation section apply to the WSR corridor area.

ALTERNATIVE 1 – NO ACTION

Direct/indirect effects

There would be no direct or indirect effects under Alternative 1-No Action. Vegetation densities or 

characteristics would not be modified, and the WSR corridor would continue to be influenced by natural 

processes and limited management actions, such as fire suppression. Since no implementation activities 

would result under this alternative, no change is anticipated in the number of visitors, frequency or season 

of use in dispersed recreation activities, developed recreation sites, trails or permitted uses. Recreational 

visits within the project area would remain near the same levels as previous years, and under this 

alternative traditional use patterns and recreational opportunities would not be impacted. Hunting, hiking 

and other dispersed recreation and permitted uses access and opportunities are expected to remain 

unchanged.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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EFFECTS COMMON TO ALTERNATIVES 2, 3, and 4

Direct/indirect effects

Specific project activities with the potential to impact recreation are common to all the proposals in 

Alternatives 2 to 4. Each of these alternatives propose different levels of treatments, but the effects to the 

public involved in different recreation activities common to the area is relatively the same. 

Alternatives 2, 3, and 4 include four main project activities that will affect recreation:

• Timber harvest (commercial harvest of timber, post-harvest noncommercial thinning and 

noncommercial thinning)

• Post-harvest activity fuels treatments (grapple pile, hand pile/burn)

• Prescribed fire (post-harvest activity fuels treatment and “stand alone” prescribed fire 

prescriptions)

• Road and Access activities (danger tree removal along open system haul roads, temporary road 

construction, permanent road reconstruction, road realignment, road decommissioning, bridge 

reconstruction and repair)

A review was made of the project proposal for all Action Alternatives with the Forest Plan and River Plan 

Desired Future Conditions (DFC) and Standards and Guidelines. As discussed above in the “Consistency 

with Laws, Regulations and Policy” section, the project proposals are consistent with all elements of the 

Forest and River Plan.

Dispersed recreation

Dispersed recreation activities will be affected by all four types of project activities mentioned above. In 

the short-term, timber harvest, post-harvest and prescribed fire activities may restrict user access into a 

treatment unit due to safety purposes, or users may be discouraged from entering a unit due to the 

presence of equipment and workers. This may occur in peak summer visitations or during the fall hunting 

seasons. Downed trees, slash piles, loss of forest-products (i.e. mushrooms, berries), active fire and 

residual smoke will also discourage visitor use in an area. Noise and other disturbances may affect the 

quality of the recreation experience for an individual regardless of the proximity to the activity. 

A change in natural features or landscape characteristics may elicit different responses in visitors. One 

attraction to an area may be linked to visitors “sense of place” (Farnum, et al., 2005). A visitor’s sense of 

place includes attachments to external factors like natural features or landscape characteristics. Important 

landscape features may consist of large old growth trees and groves, variety of trees species, an open or 

closed tree canopy, rock formations, water bodies and natural appearing openings (USDA-FS, 1995). The 

proposed treatments such as harvesting large trees, reducing slash or altering canopy cover will change or 

remove some of these natural features. In some cases the changing landscape will displace or discourage 

certain types of dispersed recreational activities (i.e. studying nature, viewing wildlife). In other areas it 

may encourage new dispersed recreational activities (i.e. big game hunting, photography) not available 

under the previous landscape.

For Alternatives 2, 3, and 4 there is only one dispersed camp that is within a harvest unit. Depending on 

when the timing and proximity of the treatment activities occur, campers at this site may be displaced or 

have a less quality experience due to noise, equipment activity and dust. In Alternative 2 there are three 

dispersed camps within units scheduled for prescribed fire, and no camps in Alternative 3 and 4. Similar 

to camps within harvest units, campers again may be displaced or have a less quality experience due to 

smoke, active fire and equipment activity.

Direct effects to recreationists accessing the 17 dispersed camps or other areas will occur on roads during 

haul periods. The presence of large trucks or an increased frequency of traffic may discourage road use to 
Chapter 3 Snow Basin Vegetation Management Project FEIS

346

these sites as well as associate activities outside the WSR corridor until the road work subsides. When 

roads are being constructed/reconstructed, visitors may expect delays or closures during work periods. If 

roads are used for winter haul, they may be available for access by winter recreationist like cross-country 

skiers, which is uncharacteristic in most years due to closure by snow.

Long term effects of harvest and post-harvest treatments will evoke various reactions from recreationists. 

Recreationists seeking more open stands of forest may enjoy increased scenery views, wildlife viewing 

and some types of big-game hunting. Other visitors may view a loss of large trees and denser forest as a 

reduction in opportunities to view natural features and scenery, observe wildlife and take self-discovery 

hikes. Another long term effect will be providing safe and adequate road and trail access for the recreating 

public through the cutting of danger trees improving visitor travel. This is also a long-term effect for 

developed recreation and permitted uses.

Developed recreation

No developed recreation sites are within the harvest units. However access to developed sites may be 

delayed or restricted during haul periods or road construction. The presence of large log trucks and other 

equipment on haul routes may discourage users from driving the main access route to the developed sites 

or to associated off-site recreation activities. The noise, dust, smoke and equipment activity during 

harvest, post-harvest and prescribed fires may affect the quality of the recreation experience for a visitor 

regardless of the proximity to the activity. The frequency and intensity of these activities may vary from a 

few hours to several weeks. Some loss or change of vistas, scenery, natural features or wildlife viewing 

opportunities may result with the vegetation treatments and prescribed fire activities visible from the 

developed sites. 

Developed trails

There would be no direct or indirect effects to the summer pack saddle/ hiking trails since no activities are 

proposed on them. Snowmobile trails have the potential to be impacted if a designated snowmobile route 

is plowed for winter haul. Coordination with the local snowmobile clubs may alleviate the concern if 

alternate temporary routes are groomed during the short-term. 

Permitted uses

The same effects for gathering forest products (i.e. mushrooms and berries) that are summarized in the 

Recreation Specialist Report apply to this area within the Wild and Scenic River corridor. Cutting of 

Christmas trees and firewood is not permitted in the WSR corridor.

Long-term effects of harvest and post-harvest treatments will solicit various responses from permit users. 

Permit holders, like mushroom pickers, will find short term benefits from open, disturbed mixed-conifer 

forest stands, whereas berry pickers may view the loss of berry patches as a negative impact.

Cumulative effects

Wild and Scenic River – direct and adverse effects 

Section 7 (a) of the Wild and Scenic River Act requires an evaluation of water resource projects in the 

WSR corridor to determine if they, “would have a direct and adverse effect on the values for which such 

river was established.” In reviewing the alternatives described in Chapter 2, as related to recreation, these 

projects will not have a direct and adverse effect to the recreation resource inside of the WSR corridor 

because:

• The available types and annual use for dispersed recreation activities will not be adversely 

affected in the short- and long-term. Dispersed uses may fluctuate each year but other factors like 

weather, choosing a different vacation destination, fuel prices and success/non-success of 

obtaining a hunting tag also influences use in an area. Visitors will continue to find a forested 
Chapter 3 Snow Basin Vegetation Management Project FEIS

347

natural appearing environment, and will find many locations across the project area for 

uncrowded settings.

• The number, annual use and site capacity for developed recreation sites will not change in the 

short- or the long-term. All developed recreation sites will remain open, no individual 

campsites/grounds will be altered and, as mentioned above, use varies depending on factors other 

than project activities.

• The number of trail miles and use will not change in the short- or long-term. No prohibitions are 

being made to the number of trail miles or trails open and available for use.

• The number of permits and areas will not change in the short- or long-term. No changes in the 

terms of the permits or available locations are part of this project.

• It is anticipated that the overall quality of the recreation opportunities will vary, but not be 

adverse to all users since they have an individual range of sense of place or human connection to 

any area.

Summary of effects

The following table displays the quantitative differences in units (acres/miles) for each of the indicators 

discussed in Recreation Resources section Table 123.

Table 128. Comparison of alternatives (ALT)

Indicators ALT 1 ALT 2 ALT 3 ALT 4

Acres timber harvest 0 369.5 261.1 212.4

Acres post-harvest fuels treatment 0 129.7 101.9 108.5

Acres prescribed fire 0 1,359.7 565.1 565.1

Miles road reconstruction 0 3.8 3.3 3.3

Miles temporary road construction 0 1.4 0 0

Miles danger tree removal along 

roads 0 11.6 11.0 10.9

Miles road decommissioning 0 0.4 0.4 0.4

Miles road haul (summer/winter) 0 11.6 11.0 10.9

Monitoring Requirements

Monitoring requirements will be shown in the FEIS appendices.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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HERITAGE AND PALEONTOLOGICAL RESOURCES

Heritage Resources

Affected Environment

There were no new sites located during the survey of Snow Basin. The Snow Basin project area has had 

numerous activities take place over the years. These activities have included logging, mining, and 

grazing. There were no new prehistoric or historic properties located within the area of potential effect. 

Many of the historic sites that were revisited were found to be in high states of decomposition. This 

decomposition is from natural causes. In not too many years most of the historic sites will no longer be 

visible. There are 7 linear features within the Snow Basin project as well. The linear features are in the 

form of ditches. Six of the ditches are in varying states of erosion. The erosion is naturally occurring. One 

ditch is still in use and is maintained by a local rancher for irrigation water. 

All acreage less than 15 percent slope within units was resurveyed for this project. Surveys transects were 

on 20 meter spacing. Transects of the survey followed the longitudinal line of the APE. Ground visibility 

was 100 to 30 percent. Much of the area (80 percent) had good ground visibility from a combination of 

cattle grazing to natural causes. The other 20 percent of the area utilized foot scrapes at 20 meter intervals 

to observe the ground.

Environmental Effects – All Action Alternatives

The Wallowa-Whitman National Forest zone archaeologist has determined that Snow Basin Vegetation

Management Project is considered an “undertaking” pursuant to the definition provided in section 301(7) 

of the National Historic Preservation Act. This undertaking will have a No Historic Properties Affected 

determination pursuant to 36 CFR 800.4, Stipulation III (B) 2 of the Programmatic Agreement, 

undertaking meets the criteria in the PA for a Historic Properties Avoided determination (See SHPO 

concurrence dated Aug. 31, 2010 in project files). 

There are seven historic mining ditches that cross through units of Snow Basin. One of the ditches is the 

historic Sparta Mining Ditch, dug by overseas Chinese in 1873 and which spans approximately 30 miles. 

All seven ditches are eligible for the National Register of Historic Places as previously determined. 

Therefore the Programmatic Memorandum of Agreement between the State Historic Preservation Office 

and the United States Forest Service for the management of historic water transportation ditches on the 

Wallowa-Whitman National Forest will be met. Historic Water Transportation Ditch Corridor 

Management Guidelines are for those units in Snow Basin involved with all seven ditches. Project Design 

Features to protect water transportation ditches are listed in Appendix B-1.

Treatment of lithic scatters that are appropriate to avoid impacting lithic scatter sites according to the 

Programmatic Memorandum of Agreement between the United States Forest Service, Oregon State 

Historic Preservation Office, and the Advisory Council on Historic Preservation.

The complete list of Project Design Features to protect Heritage resources are noted in Appendix B. 

Implementation of these design features would reduce or eliminate potential adverse impacts to cultural, 

historical, or heritage sites and resources.

Paleontological Resources

Mapping, field observations and research have been used to determine if the proposed alternatives will 

have any adverse impacts on paleontological sites located within the Snow Basin project area or affect 

any geologic unit producing paleontological resources. There is one known paleontological site located 

within the Snow Basin project area. All of the alternatives require ground disturbing activities, therefore
Chapter 3 Snow Basin Vegetation Management Project FEIS

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paleontological resources have the potential to be adversely impacted. However, ground disturbing 

activities likely to impact paleontological resources are limited to temporary road construction. Any 

ground disturbing activities will trigger a paleontological survey and development of conservation 

strategies for those projects.

Affected Environment

Existing condition

Of the eight geologic units within the Snow Basin project area, only one has yielded a vertebrate fossil to 

date. The geologic unit of concern is the Martin Bridge Limestone (MBL) formation, a late Triassic 

marine sediment layer, which is part of an exotic accreted margin (Blackburn, no date). The Snow Basin 

project area has many scattered outcrops of the Martin Bridge Limestone and some prominent cliffs. The 

Martin Bridge Limestone formation is an important resource because it is the only prominent Triassic 

limestone exposed in northeastern Oregon and adjacent Idaho (Stanley et. al. 2008). Along with the 

vertebrate fossil occurrence, many studies have been done on invertebrates forming ancient reefs in the 

Martin Bridge Limestone formation.

The vertebrate fossil discovered within the Martin Bridge Limestone formation was an Ichtyosaur 

species, and the oldest specimen of this kind found in Oregon to date. It was a large fishlike carnivorous 

reptile, sized 1.5 to 15 m in length, which lived during the Triassic and Jurassic periods (Orr, 1985). In 

1981, a field camp class from University of Oregon found 23 articulated vertebrae with ribs and natural 

arches intact in a single location (Orr, 185). The specimens have been curated and stored at the Museum 

of Natural and Cultural History in the Condon collection on the grounds of University of Oregon in 

Eugene, Oregon.

Paleontological Special Interest Areas are established when an area contains multiple rare or 

paleontological fossils. These areas become inaccessible for rock hounding or removal of any rock 

material. No Paleontological Special Interest Areas have been established on the Wallowa-Whitman 

National Forest due to lack of concentrated vertebrate fossil sites.

Environmental Consequences

Effects common to all alternatives

The 1981 discovery location is not within any treatment unit and therefore would not be affected by this 

vegetation management project. However the Potential Fossil Yield Classification (PFYC), according to 

Don Elder of the USDA Forest Service (Elder, 2010), of the Martin Bridge Limestone formation is rated 

as a 3a: Sedimentary units; often marine with scattered vertebrate fossils; fossil content varies in 

significance, abundance and predictable occurrence.

The project proposes creating temporary roads, which is a significant ground disturbing activity. Even 

though equipment isn’t supposed to go to a great depth, outcrops of the Martin Bridge Limestone would 

be affected by the blading of roads to get into locations. Temporary roads constructed in areas outside the 

Martin Bridge Limestone formation would not affect potential paleontological resources. Table 1 shows 

the roads within the formation, the evaluation of the proposed area, and potential to find paleontological 

resources.

Table 129. Potential for effects of temporary road construction on paleontological resources

Temporary road number Evaluation Potential

7015086-324 Fairly steep slope along a ridge, 

scattered outcrops that may be cut 

High
Chapter 3 Snow Basin Vegetation Management Project FEIS

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into

7015080-326 Fairly steep slope along a ridge, 

scattered outcrops that may be cut 

into

High

7015080-328 Fairly steep slope along a ridge, 

scattered outcrops that may be cut 

into

High

7015153-340 Steep slope, proposed along the 

edge of the ridge, possible cut

High

7015153-341A Steep slope, proposed along the 

edge of the ridge, possible cut

High

7015153-341B Steep slope, proposed along the 

edge of the ridge, possible cut

High

7730350-214 Steep slope, proposed along the 

edge of the ridge, possible cut

High

7730300-207 On edge of MBL, but on steep slope 

with possible cut/fill

High

7700345-226 Furthest away from original 

discovery, but proposed on steep 

slope at edge of MBL unit

High

7735075-131 Road closest to original discovery 

location, fairly low topographic profile

Highest

7735000-135 Along a fairly low topographic zone,

small scattered outcrops

Medium

Forty-one skyline and tractor units overlap the Martin Bridge Limestone formation. The other activities 

related to vegetation management projects (i.e., skidding, underburning, etc.) would have less effect on 

the paleontological resources because of the lack of contact with the bedrock in the Martin Bridge 

Limestone formation. However, tractor units would have the most effect to potential paleontological 

resources if tractors were continually running over outcrops. The tractor units partially or entirely within 

the Martin Bridge Limestone are: 119, 133, 135, 213, 215, 202, 203, 207, 208 and 228. Rubber tired or 

tracked tractors need to be used to prevent fracturing and crushing of the bedrock and therefore the 

vertebrate fossils inside. A paleontological trained person will be onsite to observe all temporary road 

building in the above units. During timber sale activities such as skidding and cross-country travel, all 

limestone outcrops should be avoided and a paleontological trained person should be notified during work 

in the above units to do spot checking.

Should further ground disturbing actions take place outside the proposed temporary roads and tractor

units or other activities come in contact and cut into bedrock, a Forest Service paleontologist or approved 

contract paleontologist will be contacted to determine if the resources onsite will be impacted. If 

paleontological resources are found to be impacted during vegetation management activities a survey will 

be required and further conservation strategies will be developed.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Cumulative Impacts

Unless other significant paleontological resources are located during the Snow Basin vegetation 

management project, there would be no cumulative effects for the areas being worked on within the 

Martin Bridge Limestone formation. If there are significant discoveries during the duration of the Snow 

Basin management project then those sites will have to be evaluated and avoided for this and future 

projects.

Wild and Scenic River History

Eagle Creek Wild and Scenic Management Plan for the Wallowa-Whitman National Forest of 1993 list 

cultural (historic) resources and paleontology as outstandingly remarkable value (ORV).

The settlement of Northeast Oregon is tied to the discovery of gold, and Eagle Creek has some evidence 

of this history. Outstanding opportunities exist to interpret a number of features located in fairly close 

proximity within the corridor. These features qualify historic cultural resources as an outstandingly 

remarkable value.

Historic and prehistoric sites are protected. Several historic cultural resource sites in the corridor will be

stabilized and interpreted for forest visitor enjoyment. Sites within the corridor related to regional mining 

activities will be emphasized. Sites that may be stabilized and interpreted include the Martin Bridge stage 

stop site, Sparta Ditch, and a representative hydraulic mine site.

The variety of exemplary geologic features in the corridor, particularly in the upper reaches of Eagle 

Creek, and the opportunities for paleontological research and interpretation merit the recognition of 

geology as an outstandingly remarkable value. The DFC for geology/paleontology will be a natural 

appearing landscape. All major geologic features will remain unchanged by human activity. The public 

visiting the area will be aware of some of the key geologic/ paleontological features in the area. Although 

research groups will continue to have access to fossil formations under special use permit requirements, 

protection of the fossil beds from unauthorized activities will be improved.

ORV of the river must be protected and enhanced. Give protection and enhancement of ORV, water 

quality, and free-flow priority over uses described or implied in all other management direction and 

standards and guidelines.

Direction for management is defined in the Forest Plan, Forest Programmatic Memorandum of 

Agreement (PMOA), FSM 2354, and in conference and agreement with the American Indian Tribes with 

treaty rights (Confederated Tribes of the Umatilla Indian Reservation and Nez Perce Tribe).

Snow Basin Vegetation Fuels Management Project is considered an “undertaking” pursuant to the 

definition provided in section 301(7) of the National Historic Preservation Act. This undertaking will 

have a No Historic Properties Affected determination pursuant to 36 CFR 800.4, Stipulation III (B) 2 of 

the Programmatic Agreement, undertaking meets the criteria in the PA for a Historic Properties Avoided 

determination. All historic properties will be avoided within the Eagle Creek Wild and Scenic River 

corridor during implementation of Snow Basin. Avoidance will protect the outstandingly remarkable 

values for the Eagle Creek River for all treatments.

Paleontology will be protected for the OR values that are associated with this resource in the Eagle Creek 

Wild and Scenic River corridor. All limestone outcrops will be avoided to protect the paleontological 

resources found within the Martin Bridge Limestone formation. With avoidance of the Martin Bridge 

Limestone formation there will be no effects during all treatments inside the Wild and Scenic River 

Corridor. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

352

SOCIAL AND ECONOMICS

This report analyzes the socio-economic effects associated with the Snow Basin Vegetation Management 

Project (hereafter called Snow Basin Project). It is divided into two parts, an economic impact analysis 

that includes an assessment of the financial and economic efficiency of the project and a social impact 

analysis that includes environmental justice. The affect of the alternatives on the social and economic 

conditions of people are discussed in terms of direct, indirect, and cumulative effects including short-term 

and long-term effects. Its purpose is to provide specific background information to help the Deciding 

Official in making a decision on which alternative to select.

The economic impact analysis is used to identify potential impacts to economic conditions such as 

employment and income. The efficiency analysis describes economic uses and values and identifies 

potential benefits and costs of alternative proposals for resource management.

The social impact analysis is used to identify potential changes in people’s social and cultural conditions 

that directly or indirectly result from Forest Service actions. The objective of the environmental justice 

analysis is to identify potential disproportionate impacts to minority populations, low-income populations, 

and American Indian tribes. 

Affected Environment

Affected Geographic Area

The communities most affected by the Snow Basin Project are the cities of Richland and Halfway, 

Oregon and the associated Eagle Valley and Pine Valley population. This easternmost portion or 

“Panhandle” of Baker County is mostly public land administered by the BLM and Forest Service. There 

are no Indian reservations within the area or established traditional use areas. Oregon State Highway 86 

bisects the two valleys. The closest city is Baker City, population 9,860, which is about one hour highway 

travel time away.

Communities, Lifestyle, Population, and Employment

These two small rural towns are primarily dependent on agriculture and tourism. There are no large 

private manufacturing businesses located in the two communities though some individuals who live in the 

Panhandle area commute to jobs in Baker City or around Northeast Oregon. Other Panhandle residents 

are employed by large manufacturers or have small wood processing businesses. Lumber and wood 

manufacturing businesses from the larger Northeastern Oregon geographical area usually buy timber sales 

such as those that would be created by the Snow Basin project.

There are about 16,741 residents in Baker County (U.S. Census Bureau, Census 2000) with an estimated 

2,500 of those people in the Panhandle area. The population of the area is more than 95 percent white of 

which between 2 and 3 percent is Hispanic. American Indians are about 1 percent of the population with 

other ethnic minorities making up the remainder. The median age in Baker County and in the City of 

Halfway is 42.7 and 44.9 years, respectively, while the City of Richland has the oldest median age in the 

state of Oregon, 62.9 years.

Poverty rates provide some indication of the percentage of the population with low incomes. Baker 

County has an average poverty rate of 16.9 percent (U.S. Census Bureau Quick Facts, 2008). The 

surrounding counties have 13.9 percent (Wallowa County), and 15.0 percent (Union County). The Oregon 

statewide average rate of persons living below poverty is 13.5 percent and the Washington statewide 

average is 10.6 percent (U.S. Census Bureau, Census 2000). In Halfway 28 percent and in Richland 18.4

percent of the population live below the poverty level. The median yearly income in the Panhandle area is 

about $27,813 compared to the Baker County median income of $37,282 (U.S. Census Bureau Quick 
Chapter 3 Snow Basin Vegetation Management Project FEIS

353

Facts, 2008). Only 8.8 percent of the workers in Halfway and 5.8 percent in Richland are employed in 

agriculture, forestry, fishing and hunting, and mining industry compared to 14.4 percent in Baker County 

as a whole (2000 Census Profiles for Oregon).

Effects

The effects of the four alternatives on economic conditions such as employment and income were 

analyzed by comparing the anticipated changes in employment in the Panhandle area and Baker County.

The effects of the alternatives on social and cultural conditions were analyzed by identifying any changes 

to human health and any environmental impacts to minorities. The changes could be direct such as jobs in 

the timber industry or traditional uses of the forest by the public; or they could be indirect effects such as 

secondary service jobs or declining air quality from smoke. Any cumulative effects were identified using 

trends in economic conditions and past, present, and future activities that affect environmental conditions 

in conjunction with the proposed activity.

Economic Impact Analysis-Economic Efficiency

Chapter 2 and Chapter 3 of the Wallowa-Whitman LRMP discussed the variety of ways in which the 

public values diverse forest ecosystems. Employment and receipts generated by National Forest uses and 

products are important to local economies. For example grazing cattle, hunting big game, snowmobiling, 

picking mushrooms, or cutting firewood all have value and produce revenue and jobs as a result of or in 

support of these activities. It is very difficult to measure changes in employment or the value of 

recreational pursuits such as hunting, especially at the scale of this project. 

Forest Service Handbook 2409.18 provides direction to analyze financial efficiency and, if needed, 

economic efficiency to identify the most efficient alternative that achieves the desired objectives of the 

project. Consideration of the proposal that maximizes net public benefits is an important element of the 

decision-making process.

An economic efficiency analysis of Alternatives 2, 3, and 4 was completed that focused on identifiable 

and quantifiable benefits and costs for each alternative in terms of the present net value (benefits minus 

costs) to assess which alternative comes nearest to maximizing net public benefits as defined in 36 Code 

of Federal Regulations Part 219.3. These analyses are attached to this report. An analysis of the No 

Action was not done since this alternative did not have identifiable and quantifiable ecosystem benefits 

and costs. Ecosystem functions provide a broad set of ecosystem services such as clean water or native 

forest stands that are valuable to both human and nonhuman components of the ecosystem. These 

ecosystem values may be assessed in economic and non-monetary terms. Economic valuation provides a 

partial measure of the full range of ecosystem values in commensurate terms for assessing economic 

tradeoffs. Non-monetary values are necessarily assessed in terms relevant to other disciplines such as 

ecology or ethics. Changes in ecosystem services must be measurable and quantifiable in like terms, 

preferably monetary measures, in order to assess a relevant change in economic value.

This analysis is based on identifiable and quantifiable economic benefits and costs and is more typically a 

financial comparison between revenues and costs. The objective of the economic efficiency analysis is to 

show a relative measure of difference between alternatives based on direct costs and values used. All 

dollar values have been discounted in terms of the present net value (2012 dollars). Discounting is a 

process whereby the dollar values of costs and benefits that occur at different time periods are adjusted to 

a common time period so that they can be compared. The real (exclusive of inflation) discount rate of four 

percent was used in the analysis over the planning period.

Present net value (PNV) is defined as the present (discounted) net value of project benefits minus the 

present (discounted) net value of project costs. The PNVs displayed by alternative will include the timber 

sale and related projects. The related projects include non-commercial thinning and prescribed fire within 
Chapter 3 Snow Basin Vegetation Management Project FEIS

354

timber harvest units. A benefit-cost ratio is the ratio of present net benefits to present net costs. Present 

net value is a more appropriate measure for comparison between alternatives when land and productive 

activities are limiting such as in an environmental analysis of alternatives. A benefit-cost ratio comparison 

is more appropriate when investment capital is limited, for example when considering budget allocation 

among a number of different activities. The only economic change that can currently be measured at the 

Snow Basin Vegetation Management Project scale is commercial timber harvest.

Social Impact Analysis-Environmental Justice

Executive Order 12898 (February 11, 1994) on Environmental Justice directs federal agencies to consider 

whether proposed alternatives may have disproportionately high and adverse environmental effects on 

minority populations, low-income populations, or Indian tribes. The order directs federal agencies to 

focus attention on the human health and environment effects to ethnic minorities (American Indians, 

Hispanics, African Americans, and Asian and Pacific Islander Americans), disabled people, and lowincome groups. 

Alternative 1 – No Action

Effects of Alternative 1 (No Action)

Alternative 1 proposes no treatments at this time. Fires would continue to be suppressed if possible. 

Ongoing activities such as camping, hunting, using snowmobiles, grazing livestock, road maintenance, 

use of the Brooks Ditch for irrigation, and gathering forest products such as firewood, berries, and 

mushrooms would continue.

Anticipated changes in employment and income

No logging of commercial timber or non-commercial treatments would occur. The employment and 

income associated with these activities would not materialize. This would directly affect employment by 

continuing the current low incomes in the area. The present net value and cost benefit ratio are not 

meaningful since no income is generated with the No Action. The current human uses such as hunting, 

camping and other recreational activities that generate employment or have value would continue at the 

current level or decline slightly depending on the availability of opportunities. Removal of miscellaneous 

forest products as well as grazing and other consumptive uses would continue at the current level. No 

long-term or short-term changes in the availability of forest products are anticipated resulting in no effect 

on traditional uses. Winter recreation, especially snowmobiling, would remain static or increase slightly 

as users reached the capacity of the trails and parking areas.

Changes to human health and any environmental impacts to minorities

There are no minority groups or Native American tribes living within the area, therefore No Action would 

not directly or indirectly affect these groups. The health of low-income residents in the surrounding area 

could be affected by smoke from a large wildfire that could occur as a result of No Action. Many of these 

low-income residents are older persons who could be adversely affected by smoke. All income groups 

would be affected but the Panhandle area has a larger proportion than other urban areas in Baker County 

or other parts of Oregon. See the Snow Basin Fuels report for a discussion of the risk of a large fire 

occurring. No other environmental impacts to low income residents have been identified that would result 

from the No Action alternative. The cumulative effects of smoke from other planned and unplanned fires 

could exacerbate the effects of the No Action Alternative on the health of low-income residents of the 

area.
Chapter 3 Snow Basin Vegetation Management Project FEIS

355

Alternative 2

Effects of Alternative 2

Alternative 2 incorporates vegetation treatments including cutting trees for commercial harvest and noncommercial management, prescribed fire, and connected activities such as rock source development, road 

reconstruction, and road maintenance. These proposed activities are described in detail in the Snow Basin 

EIS. Alternative 2 would produce an estimated 58 million board feet (MMBF) of saw timber and biomass 

material.

Anticipated changes in employment and income

The socio-economic effects of commercial timber harvest, non-commercial treatments, road 

reconstruction and maintenance will be beneficial to the local economy but would be less than 1 percent 

of the local economic output, in Baker County (see Table 133, Total Timber Harvest and Noncommercial Treatment Jobs by alternative). Alternative 2 would be the most beneficial to the local 

economy since it generates the most revenue and would create the most jobs. The present net value of the 

timber sale and related projects for Alternative 2 is $1,679,844, with a benefit to cost ratio of 1.74. The 

discounted revenue associated with the timber sale is $3,935,781. Estimated revenue for this sale is based 

on the current market conditions which are below the 10 year average (see Table 3, Inland Mill Lumber 

Prices (all grades) 2000-2009). If market conditions return to historic averages, revenues generated by the 

timber sales associated with this project would increase significantly. The total costs of all proposed 

activities are displayed in Table 130 below and the values in Table 132. It is difficult to calculate the 

monetary benefit of non-commercial treatments; therefore no value has been applied to the benefits of 

reduction in fire risk and suppression costs, and improvements to the road systems. The qualitative 

benefits of the non-commercial treatments will be discussed in their respective resource sections.

Changes to human health and any environmental impacts to minorities

There are no minority groups or Native American tribes living within the area, therefore Alternative 2

would not directly or indirectly affect these groups. The health of low-income residents and others in the 

surrounding area should not be affected by smoke from prescribed fire because prescribed burning is 

managed to comply with state air quality standards (Snow Basin EIS Fuels mitigations). The 

environmental impacts of Alternative 2 identified in the Snow Basin EIS are localized to the Snow Basin 

analysis area; therefore low income residents living in the Panhandle area would not be directly or 

indirectly affected. There would be no cumulative effects on the health of low-income residents of the 

area from smoke from the proposed prescribed fires in combination with other burning since air quality is 

managed across a large area.

Alternative 3

Effects of Alternative 3

Alternative 3 has fewer acres of vegetation treatments including the cutting trees for commercial harvest 

than Alternative 2. Alternative 3 also treats slightly less acreage than Alternative 2 through the use of 

prescribed fire. Alternative 3 would produce an estimated 48 MMBF of saw timber and non-saw material. 

These proposed activities are described in detail in the Snow Basin EIS.

Anticipated changes in employment and income

The socio-economic effects of commercial timber harvest, non-commercial treatments, road 

reconstruction and maintenance will be beneficial to the local economy but would be less than those 

generated by Alternative 2 due to the fact that less commercial treatment would be done (see Table 133, 

Total Timber Harvest and Non-commercial Treatment Jobs by Alternative). The present net value of the 

timber sale and related projects is $337,674, with a cost benefit ratio of 1.17. The discounted revenue 
Chapter 3 Snow Basin Vegetation Management Project FEIS

356

associated with the timber sale is $2,335,504. Estimated revenue for this sale is based on the current 

market conditions which are below the 10 year average (see Table 132, Average Inland Mill Lumber 

Prices (all grades) 2000-2009). If market conditions return to historic averages, revenues generated by the 

timber sales associated with this project would increase significantly. A comparison of the cost of all 

three alternatives is displayed in Table 130 below and the comparison of value in Table 131. 

Changes to human health and any environmental impacts to minorities

There are no minority groups or Native American tribes living within the area, therefore Alternative 3 

would not directly or indirectly affect these groups. The health of low-income residents and others in the 

surrounding area should not be affected by smoke from prescribed fire because prescribed burning is 

managed to comply with state air quality standards (Snow Basin EIS Fuels mitigations). The 

environmental impacts of Alternative 3 identified in the Snow Basin EIS are localized to the Snow Basin 

analysis area; therefore low income residents living in the Panhandle area would not be directly or 

indirectly affected. There would be no cumulative effects on the health of low-income residents of the 

area from smoke from the proposed prescribed fires in combination with other burning since air quality is 

managed across a large area.

Alternative 4

Effects of Alternative 4

Alternative 4 proposes the fewest acres of commercial harvest of the three action alternatives. Alternative 

4 also treats the least amount of acreage through the use of prescribed fire. Alternative 4 would produce 

an estimated 32 MMBF of saw timber and non-saw material. These proposed activities are described in 

detail in the Snow Basin EIS.

Anticipated changes in employment and income

The socio-economic effects of commercial timber harvest, non-commercial treatments, road 

reconstruction and maintenance will be beneficial to the local economy but would be less beneficial than 

Alternatives 2 and 3 due to less revenue and jobs being created (see Table 132, Total Timber Harvest and 

Non-commercial Treatment Jobs by Alternative). The present net value of the timber sale and related 

projects is negative ($977,750), with a cost benefit ratio of .35. The discounted revenue associated with 

the timber sale is $518,443. Estimated revenue for this sale is based on the current market conditions 

which are below the 10 year average (see Table 132). If market conditions return to historic averages, 

revenues generated by the timber sales associated with this project would increase significantly. A 

comparison of the cost of all three alternatives is displayed in Table 130 below and the comparison of 

value in Table 131. 

Changes to human health and any environmental impacts to minorities

There are no minority groups or Native American tribes living within the area, therefore Alternative 4 

would not directly or indirectly affect these groups. The health of low-income residents and others in the 

surrounding area should not be affected by smoke from prescribed fire because prescribed burning is 

managed to comply with state air quality standards (Snow Basin EIS Fuels mitigations). The 

environmental impacts of Alternative 4 identified in the Snow Basin EIS are localized to the Snow Basin 

analysis area; therefore low income residents living in the Panhandle area would not be directly or 

indirectly affected. There would be no cumulative effects on the health of low-income residents of the 

area from smoke from the proposed prescribed fires in combination with other burning since air quality is 

managed across a large area.
Chapter 3 Snow Basin Vegetation Management Project FEIS

357

Summary of effects

The current employment and income in the Baker County area known as the Panhandle is low. Baker 

County has an average poverty rate of 16.9 percent (U.S. Census Bureau, Census 2000). In the City of 

Halfway 28 percent and in the City of Richland 18.4 percent of the population live below the poverty 

level. The median yearly income in the Panhandle area is about $27,813 compared to the Baker County 

median income of $37,282 (2000 Census Profiles for Oregon). Alternative 1 (No Action) would not 

change this current condition. There are no minority groups or Indian tribes living within the area, 

therefore No Action would not directly or indirectly affect these groups. No other environmental impacts 

to low income residents have been identified that would result from the No Action alternative.

The socio-economic effects of commercial timber harvest and non-commercial treatments proposed under 

Alternative 2, 3, and 4 would be beneficial to the local economy but would be less than 1 percent of the 

local economic output, in Baker County. The present net value of the timber sale and related projects for 

Alternative 2 is $1,679,844, with a cost benefit ratio of 1.74. Commercial timber harvest would generate 

approximately $3,935,781 with a predicted high bid of $38.65/CCF. The present net value of the timber 

sale and related projects for Alternative 3 is $337,674, with a cost benefit ratio of 1.17. Commercial 

timber harvest would generate approximately $2,335,504 with a predicted high bid of 27.41/CCF. The 

present net value of the timber sale and related projects for Alternative 4 is negative ($977,750), with a 

cost benefit ratio of .35. Commercial timber harvest would generate approximately $518,443 with a 

predicted high bid of $9.14/CCF. Alternative 4 is the only alternative to generate a negative PNV. 

Alternative 4 generates significantly less revenue than Alternatives 2 and 3 due to the fact that it has a 

similar fixed cost for road maintenance and reconstruction, but generates 30 to 45 percent less 

commercial timber volume to help offset the cost of the road work. The commercial treatments proposed 

in Alternative 4 produce less volume per acre which increases logging costs and reduces revenues. 

Estimated revenues for this sale are based on the current market conditions which are below the 10 year 

average (see Table 132). If market conditions return to historic averages, revenues generated by the 

timber sales associated with this project would increase significantly. The harvest of timber, burning, road 

reconstruction, and other proposed projects would provide local employment (see Table 133). Table 130

displays the costs of the alternatives and Table 131 displays the values.

There are no minority groups or Native American tribes living within the area, therefore none of the 

action alternatives would directly or indirectly affect these groups. The health of low-income residents 

and others in the surrounding area should not be affected by smoke from prescribed fire from any of the 

action alternatives because prescribed burning is managed to comply with state air quality standards 

(Snow Basin mitigation measures). There would be no cumulative effects on the health of low-income 

residents of the area as a result of smoke from the proposed prescribed fires in combination with other 

burning since air quality is managed across a large area. The other environmental impacts of the action 

alternatives are identified in the Snow Basin Vegetation Management Project EIS and are localized to the 

Snow Basin analysis area; therefore low income residents living in the Panhandle area would not be 

directly, indirectly, or cumulatively affected.

Table 130. Estimated cost of the alternatives

COST ITEM NO ACTION ALTERNATIVE 2 ALTERNATIVE 3 ALTERNATIVE 4

Timber Sale 

Preparation $0 $700,980 $589,398 $390,420

Transportation 

Planning $0 $175,245 $146,600 $97,605

Timber Sale Admin $0 $467,320 $195,466 $130,140

Post Harvest $0 $992,600 $894,500 $715,700
Chapter 3 Snow Basin Vegetation Management Project FEIS

358

Non-commercial 

thinning

Prescribed Fire Post 

Harvest Acres $0 $471,015 $464,490 $391,140

TOTAL $0 $2,807,160 $2,290,454 $1,725,005

Table 131. Economic analysis summary by alternative

Project 

Type Entry Discounted Costs

Discounted 

Revenues

Present 

net value 

(PNV)

Benefit-Cost 

Ratio (B/C)

Predicted 

High Bid-

$/ccf

Notes

Alternative 

2 Timber 

Sales

Current $38.65 Sale appears 

viable

Timber 

Sale & 

related 

projects

$2,255,937 $3,935,781 1,679,844 1.74 Project is 

above cost

Project 

Type Entry Discounted Costs

Discounted 

Revenues

Present 

net value 

(PNV)

Benefit-Cost 

Ratio (B/C)

Predicted 

High Bid-

$/ccf

Notes

Alternative 

3 Timber 

Sales

Current $27.41 Sale appears 

viable

Timber 

Sale & 

related 

projects

$1,997,831 $2,335,504 $337,674 1.17 Project is 

above cost

Project 

Type Entry Discounted Costs

Discounted 

Revenues

Present 

net value 

(PNV)

Benefit-Cost 

Ratio (B/C)

Predicted 

High Bid-

$/ccf

Notes

Alternative 

4 Timber 

Sales

Current $9.14 Sale appears 

viable

Timber 

Sale & 

related 

projects

$1,496,194 $518,443 ($977,750) .35 Project is below 

cost

Table 132. Average inland mill lumber prices (all grades) 2000 to 2009

Year Ponderosa Pine 

$/MBF

Douglas-fir 

$/MBF White fir $/MBF

2000 $503.93 $349.51 $328.49

2001 $466.75 $328.16 $296.55

2002 $488.40 $317.89 $297.86
Chapter 3 Snow Basin Vegetation Management Project FEIS

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2003 $431.66 $333.91 $279.25

2004 $550.91 $430.21 $390.40

2005 $495.41 $388.37 $358.64

2006 $510.20 $354.99 $321.93

2007 $453.53 $288.72 $284.95

2008 $390.23 $243.56 $247.92

2009 $389.19 $217.95 $229.64

10 Year Average $468.02 $325.33 $303.56

Source: Data are compiled by Western Wood Products Association from copies of invoices submitted to the 

Association by mills accounting for about 65 to 70 percent of the region's production; individual groupings from Pacific 

Northwest Research Station.

Table 133. Total timber harvest and non-commercial thinning jobs by alternative

Work Activity NO ACTION ALTERNATIVE 2 ALTERNATIVE 3 ALTERNATIVE 4

Timber Harvest 0 55 46 31

Non-commercial 

Thinning 0 38 34 27

TOTAL 0 93 80 58

Note: Each job represents one year of full time employment. Estimate of timber harvest jobs derived from Region 6 

Log Cost 11.0 (03/1/2012). Estimate of Non-commercial treatment jobs based on past contract production on 

Whitman Ranger District. Jobs would occur over a 5-10 year period starting in 2012.
Chapter 3 Snow Basin Vegetation Management Project FEIS

360

TRANSPORTATION SYSTEM

Introduction

This analysis describes existing condition of the transportation system within the proposed Snow Basin 

Vegetation Management Project (hereafter called Snow Basin Project) and the expected and potential 

effects of the alternatives on the transportation system and its management. Where appropriate, it focuses 

on the portion of the system potentially impacted by the Snow Basin Project. It also describes 

transportation-related activities proposed as part of this project, including construction of temporary 

roads, maintenance and reconstruction of existing roads, and use of rock and aggregate sources. Direct, 

indirect and cumulative effects of the alternatives are identified and discussed. Information sources used 

to complete this section include the following:

• Wallowa-Whitman Land and Resource Management Plan (LRM, 1990)

• Forest GIS Roads Layers and INFRA databases, queried in 2008; collectively referred to as the 

Wallowa-Whitman National Forest Transportation Atlas (transportation atlas, 2008 and 2011)

Roads would be used to access commercial and non-commercial harvest units and to remove logs and 

other products. Roads would also be used to access units for prescribe fire activities, SAI activities, and 

monitoring.

Road Data

Road data is compiled from information (travel route data and routes) in the INFRA database and GIS as 

of 11/15/2008. This database and the associated GIS data are referred to in this report as the forest 

transportation atlas. Miles of road are represented as GIS miles, measured from the length of arcs in GIS.

These lengths will vary some from actual miles on the ground depending on such factors as the accuracy 

of the map alignment, road grades, and overall length. Some roads exist on the ground (such as user 

created roads, abandoned roads and some roads on private land) which are not system roads and have not 

been recorded in the database. Although presumed small, the quantity is unknown and these roads are not

accounted for in the data.

Maintenance levels are identified for each road in the system. In the atlas, roads are assigned both an 

operational maintenance level (reflecting existing conditions) and an objective maintenance level 

(identifying a needed change in maintenance level that has been analyzed and approved, but not yet 

implemented). Throughout this report, maintenance levels reported are operational unless noted 

otherwise. Maintenance levels assigned to roads in the project area are maintenance level (ML) 1, ML 2 

and ML 3:

• ML 1: closed roads that have been placed in storage between intermittent uses; 

• ML 2: roads open for use by high clearance vehicles;

• ML 3: roads open and maintained for travel by a prudent driver in a standard passenger car

Maps displaying location of proposed transportation system elements for each action alternative are 

provided in Appendix A. Details such as route numbers and miles proposed for use are presented in tables 

in Appendix B.
Chapter 3 Snow Basin Vegetation Management Project FEIS

361

Existing Condition

The primary routes accessing the area were likely established as wagon roads, during the decades 

following the first European settlement of Eagle Valley and prior to establishment of the national forest.

Beyond these valley-bottom routes, much of the existing transportation system was constructed primarily 

for timber harvest. Roads were located to facilitate ground-based skidding and, later, skyline logging 

systems. Early ground-based logging in the area skidded on slopes steeper than 35 percent, possibly up to 

45 to 50 percent. 

Open and Closed National Forest System Roads

The NFS (National Forest System) arterial and collector roads serving the project area are 7010, 7015, 

7020, 77, 7715, 7720, 7725, 7730, 7732, 7735, 7737, and 7739. Within the project, most of these roads 

(totaling 94 miles) are identified in the atlas as maintenance level 2 (maintained for high clearance 

vehicles). Two routes (7015 and 77 going north from 7015), totaling 7.5 miles are maintenance level 3 

(maintained for passenger cars). All have crushed aggregate surfacing or improved surface of rock base 

material. Baker County now has jurisdiction on two roads (6.5 miles) providing access to and within the 

project area: BAK-891 (NFSR 70) and BAK-923 (NFSR 7005). These roads are known locally as Collins 

Road or Forshey Meadows and Sparta Road respectively.

The following recreation and administrative sites lie within or in close proximity to the project area:

• Lily White Work Camp off Bridge abutment was repaired in October of 2011. 7020

• Martin Bridge Trailhead off NFSR 77 on Eagle Creek

• McBride Campground off NFSR 77

• Summit Point Trailhead, Lookout, and repeater site off NFSR 7715

• Eagle Forks Campground off NFSR 7735 on Eagle Creek.

Roads associated with these sites (including access roads, parking areas, and spur roads within the sites) 

are considered part of the road system.

The existing open road system is generally in fair condition. Maintenance work has been deferred to 

where trees and brush in the ditches and shoulders are getting large and thick enough to be beyond the 

scope of timber sale maintenance specifications (greater than 4 inch diameter). Surface and drainage 

conditions are varied. Some road sections exhibit surface rilling, indicating need for repair of surface 

cross drainage and, in some cases, need for additional drainage.

Approximately 145 miles of closed NFS roads (maintenance level 1) are within the Snow Basin area.

Most are suitable for use with some maintenance work, although only a portion are recommended for use 

in this project (see discussion below). The Transportation Atlas shows 14.1 miles NFSR have been 

decommissioned: 4.0 miles in Little Eagle Creek subwatershed and 10.1 miles in Eagle-Paddy.

Table 134. Miles of road in the Snow Basin area by subwatershed, jurisdiction, and operational 

maintenance level

Jurisdiction Subwatershed Total Miles

Little Eagle 

Creek

Eagle CreekPaddy Creek

Forest Service

Mtc. Level 3 0.1 7.4 7.5
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2 30.4 63.6 94.0

1 47.1 97.3 144.4

Total FS 77.6 168.3 245.9

County 0.0 6.5 6.5

Private and 

Unknown 0.4 7.4 7.8

Total Open 30.9 81.5 112.4

Total Closed (ML 1) 47.1 97.3 144.4

Total All Roads 78.0 182.2 263.3

Note: County, private and unknown roads are assumed open.

Four bridges are located along proposed haul routes. Existing conditions of each are described in Table 

135.

Table 135. Bridges along proposed haul routes and existing condition 

7020000-4.4, Main 

Eagle #2

This bridge has fill material raveling out from under the west abutment. Riprap 

needs placed to replace lost material and stabilize the fill. If this work is not done, 

holes may eventually develop in the roadbed where it meets the bridge deck. This 

road may or may not be used for haul.

7015000-4.6, Main 

Eagle #3

Repair work was completed in the fall of 2008 which replaced fill and large riprap 

that had scoured out from under the up-stream wing wall of the west abutment.

Flooding in early June, 2010 removed all materials associated with that repair and 

left a deeper scour on both the front and back of the abutment. Bridge abutment was 

repaired in October of 2011. Conditions are adequate to safely accommodate log 

haul.

7735000-6.2, Little 

Eagle #2

This bridge has extensive rot in the wood of the deck and extending into the 

stringers. There is currently a weight restriction posted at the bridge. At a minimum, 

the deck and stringers, or superstructure needs replaced. The existing abutments, 

while serviceable, create some channel restriction and should be evaluated as well.

7735450-0.1, 

Holcomb

Bridge is in satisfactory condition. Some minor road work is needed to repair fill 

slopes at the bridge approach.

Travel restricted areas

In accordance with the Travel Opportunity Guide (1991) and Forest Orders 233-01 and 442-01, there are 

currently areas of restricted travel which lie within the Snow Basin project area.

Three existing motorized-use closure areas occur within and adjacent to the project area:

1. Summit Point Cooperative Closure Area: Closed to all motorized vehicles yearlong except oversnow vehicles. Project roads affected are a portion of roads 7732150 and tributary roads in the 

northerly direction, and 7725 and tributaries. Open roads include 7725, 7725046, 7725042, 

7732150 to m.p. 2.5, 7715. The closure is to reduce wildlife disturbance, provide non-motorized 

hunting, and protect fragile soils. 

2. Eagle Creek: Closed to all motorized vehicles from December 1 through April 15 except routes 

designated open. Boundaries of the area are approximately Eagle Creek and roads 7735, 7737, 

7735450, and 7739. Open roads include 7735, 7739, 7737, 7737150 to m.p. 0.2, and 77. The 
Chapter 3 Snow Basin Vegetation Management Project FEIS

363

purpose is to reduce wildlife disturbance, protect fragile soils, calving and fawning, prevent 

harassment of big game while on their winter range.

3. Holcomb Creek: Closed 3 days prior to the opening of general deer season through March 31st

.

Boundaries of the closure area are from NFSR 7735 on the north and east, to Eagle Creek on the 

south and west. The purpose is to reduce wildlife disturbance, provide non-motorized hunting, 

protect fragile soils, calving and fawning, and to prevent harassment of big game while on their 

winter range.

Designated snow mobile routes

Snow mobile routes restrict non-over-snow vehicles during the time snow is groomed. Closure is posted 

on the ground to provide public safety, reduce user conflict, and identify motorized snow play 

opportunities. Roads restricted include 70, 7015, [7015150, 1715075], 7020, 77, 7720, 7735, [7739, 

7739125, 7700150]. Brackets indicate connecting segments to make one through route. 

Road densities 

Road densities were calculated as recommended in the forest plan (pg 4-35), which establishes open-road 

density guidelines for certain Management Areas (MAs) – MA 1, MA 1W, 3 and 18. The subwatersheds 

were clipped to the analysis area boundary to be comparable to the open road densities described in the 

Cumulative Effects. Miles of open roads are based on operational maintenance level 2-5 for NFS roads.

State, County, and private roads generally do not have data to indicate whether they are open or closed, 

but for this analysis, these roads are assumed to be open for road density calculations.

Land allocated to timber emphasis (MA 1) generally should not exceed 2.5 miles of open road per acre of 

land within the subwatershed (Forest Plan 4-58). Open road density values for MA 1 in both Little Eagle 

Creek and Paddy Creek-Eagle Creek subwatersheds are currently at this upper level.

MAs 3 and 1W (Timber and Wildlife Emphasis) are big game winter range. Standards and guidelines 

generally limit open road density to 1.5 miles per square mile during the time that the areas are being used 

by big game. Where snow normally will provide an adequate level of road closure on winter ranges, 

additional closures to meet the 1.5 mile per square mile standard will not be necessary (Forest Plan 4-62 

#10 and Record of Decision page 12). While open road density in these areas are at or somewhat above 

1.5 (from 1.95 to 2.10), many roads are within seasonal closures (see above) while others are closed by 

snow during winter.

Effects Analysis

Effects related to roads are generally addressed as impacts to other resources such as aquatics, soils, 

invasive weeds, and wildlife. To help support the analyses of these other resources, the effects described 

here will focus on providing information on road development needs and road density estimates. 

The analysis for determining the direct, indirect and cumulative effects of the project on the transportation 

system is generally bounded by the project area, except in consideration of haul routes. Effects to haul 

routes, and activities along those routes (danger tree removal), will extend to the point where the road 

leaves NFS lands and/or is no longer under NFS jurisdiction.

No Direct, Indirect, or Cumulative Effects

Prescribed fire activities (pile burning and underburning) associated with the Snow Basin project are 

anticipated to have little or no effect on the transportation system. Road use would be limited to access to 

and from harvest units and natural fuels units. While some burn units have been designed to take 

advantage of roads as existing fuel breaks, no disturbance of the road surface is planned. These activities 

and their effects will not be discussed further in this section.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Direct, indirect effects on transportation system

Alternative 1-No Action

This alternative would have no effect on the projects area’s existing road density because no NFS roads 

would be built or closed under this alternative. Conditions discussed for the affected environment (see 

existing conditions discussed above) would continue under this alternative. Routine maintenance and 

repairs would continue to be made on a cyclic basis, depending on funding level and forest-wide 

priorities. Opportunities to replace or upgrade road/stream crossing and improve road surface drainage 

would occur only as funding allows and on an incremental road by road basis. 

Alternative 2, 3, and 4 - action alternatives

Table 136. Summarizes the various activities associated with the transportation

Management Activity Alternative 2 Alternative 3 Alternative 4

Transportation Activities Miles Miles Miles

Maintain NF System Roads for log haul miles 229.6 224.5 214.3

Open (maintenance level 2-3) miles 121.9 119.6 116.7

Closed (maintenance level 1) miles 107.7 104.9 97.6

Danger Tree removal (along system haul roads) 230 225 215

Total Temporary Road Construction miles 10.9 9.0 0

New Construction 6.9 5.3 0

Existing non-system 4.0 3.7 0

Decommission of Existing NF System Roads miles 6.0 6.0 6.0

Reconstruction of NF System Roads miles

Open (maintenance level 2)

Deferred maintenance/repairs miles 26.3 26.3 25.1

Bridge replacement (1 bridge) 1 1 1

Bridge Abutment Repair (1 bridge) 1 1 1

Closed (maintenance level 1) miles

Deferred maintenance/repairs miles 13.7 12.1 11.5

Realignment System Road miles 1.0 1.0 1.0

Total System Road Reconstruction 41.0 39.4 37.6

Haul routes

The appraisal point for timber sales generated by the Snow Basin EIS will be La Grande, Elgin or John 

Day. The appraised haul route for approximately 60 percent of the project area will funnel to NFSR 77 

(Eagle Creek), then west on 7015 (Empire Gulch), then south on BAK-891 (FS 70), BAK-923 and BAK852 (Sparta) to State Hwy. 86, then west to I-84 at Baker City. The portion (approximately 20%) of the 

project to the far northeast will haul southeast down NFSR 77 (Summit Ridge) to State Hwy. 86 east of 

Richland, then west to I-84. The portion (approximately 20 percent) of the project to the far east and south 

of road 77 will haul south on NFSR 7735 (Little Eagle Creek), then BAK-969 to State Hwy. 86 at 

Richland, then west to I-84.

Alternative routes are possible to haul toward Medical Springs on roads 67, or 70, but there is a bridge 

weight restriction that would need addressed by conducting a new load rating to verify its capability to 

sustain highway legal loading, or repair/replacement of the bridge, if this route were chosen (Main Eagle 

Bridge #1). However, based upon a preliminary cost analysis and historical experience, the most likely 

routes will be to the south to State Highway 86 whether the final destination is La Grande, Elgin or John 

Day.
Chapter 3 Snow Basin Vegetation Management Project FEIS

365

The current Wallowa-Whitman N.F. Commercial Road Use Rules and Road Use Permit Requirements

apply to all commercial use of NFS roads. There are no specific road rules applicable to roads in the 

Snow Basin project area. Typically, timber sale contracts on the Wallowa-Whitman N.F, Whitman R.D. 

have restricted haul in the following manner:

• Haul during the normal operating season

• No haul on weekends and Federal holidays

• Dry or frozen ground conditions on native surface roads

• All use must cease when road damage begins to occur.

There are inholdings of private land within the project area that are crossed by through-roads that do not 

have permanent easements to the Forest Service. Those roads include segments of 7010250, 7020175, 

7020200, 7732220, and 7735325 which will be used for timber haul from proposed commercial units.

The Forest will proceed with permanent easement acquisition. In the event a permanent easement cannot 

be acquired before a project will be implemented, the Forest will seek a temporary road use permit. See 

table for locations and ownership information.

Roads associated with recreation and administrative sites within the project area (including access roads, 

parking areas, and spur roads within the sites) would not be used for log haul and would not be impacted 

by this project.

Road maintenance

The purchaser of a timber sale contract or contractor of a stewardship contract would be required to 

perform road maintenance commensurate with their use on all NFS roads. Maintenance would be 

performed as needed on all haul routes. Maintenance would be performed in accordance with timber sale 

contract specifications. In addition, deposits are collected on crushed aggregate roads for Road Surface 

Replacement (RSR). 

Typical maintenance activities include: snow plowing for winter haul, blading roadbeds, dust abatement 

(usually with water), surface rock replacement, ditch and culvert cleaning, removal or ramping over of 

small slumps and slides, road-side brushing of overhanging limbs and small diameter trees (<4 inch), 

logging out blown down trees, and felling danger trees. Felled danger trees would be left in place or 

removed if merchantable and marked for removal. 

During harvest activities, closed roads would be opened for project use and typically re-closed prior to 

acceptance of the harvest units. During use they would be maintained as needed to prevent resource 

damage. The most common needs on closed roads proposed for use in the project are clearing, logging 

out, and addition of surface cross drainage. Following use, water bars would be installed to provide 

drainage prior to closing. It is proposed to leave some roads open after commercial harvest to provide 

firewood gathering opportunities and/or provide access for other post-harvest activities. If this occurs, 

these roads will need consideration for funding and implementing their re-closure outside the timber sale 

contract if the traditional timber sale contract is used.

Open roads will remain open after harvest activities. Post-haul maintenance activities would include 

blading followed by water barring or cross-ditching on most maintenance level 2 (high clearance vehicle) 

roads. Post-haul blading would be performed on ML 3 roads.

Some roads would require reconstruction (see below). Road maintenance work is still required for 

reconstructed roads as use continues and maintenance levels are maintained. This is primarily for duringand post-haul needs. If a travel management decision is made and implementation started prior to 

completion of project activities, there may some additional changes (see Travel Management discussion 

below).
Chapter 3 Snow Basin Vegetation Management Project FEIS

366

Road reconstruction

Here, the term reconstruction refers to road work outside the scope of timber sale maintenance 

specifications and will be listed in the timber sale contract for specified road reconstruction and 

applicable to BT 5.2. No reconstruction work is planned that would raise the road standard to a higher 

level. This work is needed to support the removal of timber. It is necessary to provide safe and efficient 

access for timber harvest, along with recreational users, administrative and private land access, and 

permittee and special interest uses. Reconstruction would also provide resource stabilization and 

enhancements that would reduce sedimentation and improve water quality in the watershed.

Road reconstruction is proposed in all action alternatives associated with the Snow Basin project.

Approximately 40 miles of NFS road, comprised of maintenance level 1 and 2 routes, would be 

reconstructed as summarized in Table 136. As these road miles are very similar among alternatives, all 

three alternatives will be discussed together. See Appendix B-11 for route-by-route descriptions of 

reconstruction needs.

One portion of Baker County Road 923 is listed as needing reconstruction. This work may be done by the 

County Road Department, or it may be done by the timber sale using a Cooperative Road Maintenance 

Agreement/Project Agreement with the County. This agreement may be initiated for project work where 

rock would be acquired from a Forest Service material source and utilized on a County road. Or, it may 

be utilized if there is agreement for the county to provide materials such as culverts, and the purchaser 

would provide equipment and operators to reconstruct one segment of this road. Regardless of who 

performs this work, it would be conducted in accordance with Cooperative Agreement with Baker 

County, and Schedule A, currently in place. Work necessary on private roads will be addressed by road 

use agreements and permits.

Generally, road reconstruction will take place within the original footprint of the road template (i.e., 

between top of cut and toe of fill) and would be considered as heavy maintenance for the effects on other 

resource areas. Replacement of culverts and repair of one bridge abutment would be required. This work 

would remain in the original footprint of the road. Some closed roads are extensively grown in, have 

blown down trees, and slide material to the degree that they would be classified as reconstruction rather 

than maintenance. Closed roads have many springs that would need drainage work and subgrade 

reinforcement to be suitable for haul, and stream crossings commonly have had culverts removed which 

would need to be replaced.

There are two proposed road-related activities that are outside this general description. Relocation is 

proposed that would create a new road template approximately above the existing road and away from 

riparian habitat. The old road would be rehabilitated and recontoured after the relocation was complete.

Also, replacement of a bridge across Little Eagle Creek on NFSR 7735000 is proposed (Little Eagle 

Bridge #2). Specialized equipment and construction experience would be required for completion of this 

work. Agency Capital Investment Program funds have been approved to supplement a Timber Sale 

toward the replacement of the entire structure. The Timber Sale would be expected to provide for 50% of 

the construction costs. Neither the segment of road to be relocated or the bridge to be replaced are located 

in the Wild and Scenic River corridor. 

Temporary roads

By definition, temporary roads are authorized by contract, permit, lease, or other written authorization 

that is not a forest road and that is not included in a forest transportation atlas (FSM 7705). In the context 

of timber management, temporary roads include those roads needed only for the purchaser’s use for a 

given timber sale(s), such as roads used to haul timber from landings to permanent National Forest 

System roads. The Forest Service and the purchaser must agree upon the location, resource protection 

requirements for road construction, clearing widths, and closure or rehabilitation requirements (FSH 
Chapter 3 Snow Basin Vegetation Management Project FEIS

367

2409.18, Ch 43.2). Temporary roads are not constructed to serve long-term future uses and must be closed 

prior to closure of the timber sale. Temporary roads may only be used for short-term, non-recurrent use

by the purchaser. Purchasers would not be allowed to construct temporary roads in lieu of building 

specified roads needed for future recurrent management of the area (FSM 2432.34b). Temporary roads 

are addressed in the Timber Sale Contract in section BT6.63. Plans and criteria can be further specified in 

provision CT5.1#, Temporary Road and Landing Construction.

BT6.63 text: 

As necessary to attain stabilization of roadbed and fill slopes of Temporary Roads, Purchaser 

shall employ such measures as outsloping, drainage dips, and water-spreading ditches.

After a Temporary road has served Purchaser’s purpose, Purchaser shall give notice to Forest 

Service and shall remove bridges and culverts, eliminate ditches, outslope roadbed, remove ruts 

and berms, effectively block the road to normal vehicular traffic where feasible under existing 

terrain conditions, and build cross ditches and water bars, as staked or otherwise marked on the 

ground by Forest service. When bridges and culverts are removed, associated fills shall also be 

removed to the extent necessary to permit normal maximum flow of water.

Temporary road construction is planned to access harvest units where NFS roads do not exist. These 

roads are needed to provide access for logging and hauling equipment in the harvest unit. Skyline units 

must have yarders in key locations in order to log the unit. Roads to landings within tractor units reduce 

the skidding distances, may reduce the amount of soil disturbance created by skid trails, and enhance the 

economics of logging the unit. Particularly for skyline units, the unit cannot be harvested without an 

access road to the landings. Once logged, these units would not be logged again for at least 20 years.

Because the sole purpose and need for the road is timber harvest to a local unit, they are planned as 

temporary rather than system roads. See Haul Route Table for estimated miles planned. Temporary road 

access may be located on existing templates or undisturbed ground. For the purpose of analyzing the 

effects on soil conditions and hydrology, miles of temporary road are differentiated between known 

existing templates and new disturbance. All temporary roads will be closed and rehabilitated under the 

terms of the timber sale contract (BT5.1, CT5.1#, BT6.63) prior to acceptance of the associated units.

NFS road decommissioning 

Roads were identified in the Eagle Creek Watershed Analysis (USDA-FS, 1997) as a source of sediment 

to streams, especially roads located within riparian areas. Reducing the number of unneeded roads is 

expected to aid in reduction of sediment to riparian habitats and stream channels. The objective of road 

decommissioning is to stabilize, restore, and revegetate unneeded roads to a more natural state to protect 

and enhance NFS lands (FSM 7734.02). Decommissioned roads are removed from the forest 

transportation atlas. Road decommissioning treatments may range from simply administratively removing 

the road from the system to fully restoring the slope to near natural contours. The level of treatment is 

determined site-specifically based on the road’s current condition and location, and what is needed to 

meet the objective to hydrologically stabilize the road.

It was not the intent of this project to enter into travel management or planning. However, during road 

reconnaissance, a group of roads adjacent to harvest units was identified as candidates for 

decommissioning: 15 road segments totaling approximately six miles. Each of these has an operational 

maintenance level 1 and objective maintenance level 1. Most are located in draw bottoms or are in close 

proximity to stream channels, where stabilization treatments would benefit water quality. Others are in 

poor location for the aquatic resources and have naturally revegetated and restored to a level where it 

would be more prudent to construct a new road than to reconstruct the old road. Three roads, totaling 

approximately one mile, were found to be suitable for the logging system or haul and is proposed for use 

in this project and would be decommissioned following use. These roads are shown on transportation 
Chapter 3 Snow Basin Vegetation Management Project FEIS

368

system maps in Appendix A. Appendix B-11 includes a list of routes proposed for decommissioning and 

the treatment strategy for each. Treatment strategies are also described. Each road was checked against 

each alternative in the proposed Travel Management Plan and no alternative proposed these roads be open 

to motorized vehicles.

Timber sale funds cannot be expended for decommissioning system roads. The 1.0 miles of road planned 

to be used for haul would be treated under a timber sale in the same manner as closed roads. Additional 

treatments needed to decommission those roads as well as the remaining 4.8 miles would be treated under 

a separate contract or possibly a stewardship contract to accomplish decommissioning objectives.

Material sources

Six existing material sources have been identified for future use in the project area. Rock material 

produced from these sources would be utilized for pit-run, borrow, road surfacing, and subgrade 

reinforcement in areas where springs or wet areas have developed in the roadbed. Each of these sites has 

been previously developed for crusher and stockpile sites and approximately 5,000-15,000 cubic yards of 

material could be crushed and stockpiled from these sources. The pit development areas may be increased 

by 1-2 acres. In addition, there are numerous smaller sites that may be used for aggregate or roadside 

borrow sources. No aggregate sources/quarries within the Wild and Scenic River corridor would be 

developed for this project. The project record file contains detailed lists of all potential material rock 

sources. The main sources are listed below:

Table 137: Existing material sources

Material Source Name Legal Road

Cougar Ridge – Empire 

Gulch

T. 7 S., R. 44 E., Sec. 20, NW 

1⁄4

Rd. 7015075, MP 0.3

Snow Fork #1 T. 7 S., R. 44 E., Sec. 14, NW 

1⁄4

Rd. 7735175, MP 1.7

Snow Fork #2 T. 7 S., R. 44 E., Sec. 14, SW 1⁄4 Rd. 7735185, MP 0.1

Lily White T. 7 S., R. 44 E., Sec. 7, SW 1⁄4 Rd. 7020160, MP 0.1

Long-Gold #1 T. 7 S., R. 44 E., Sec. 10, NE 1⁄4 Rd. 7730040, MP 0.2

Dempsey T. 7 S., R. 44 E., Sec. 30, NE 1⁄4 Rd. 7700060, MP 0.2 

All gravel and fill stockpiles, quarry sites, and borrow material will be inspected for invasive plants 

before use and transport. Only gravel, fill, sand and rock that is judged to be weed free by the district or 

forest weed specialists would be used.

Open road density

Alternatives 2, 3, and 4 would not alter the NFS road system. Therefore, open road densities for MAs 1 

and 3 would remain the same as for Alternative 1, as described for the existing condition. There would be 

no construction of new permanent roads and no decommissioning or closure of roads that are currently 

open. Open road densities would remain the same as identified for the existing condition.

Travel restricted areas

Motorized use in closure areas during closure periods would need to be approved by the district ranger.

See Appendix B-1.
Chapter 3 Snow Basin Vegetation Management Project FEIS

369

Designated snow-mobile routes

Winter-use of these routes would need to be assessed and written approval provided prior to permitting.

Designation of alternative routes for snow mobiles would be considered.

Cumulative Effects on Transportation System

Potential cumulative effects are analyzed by considering the proposed activities in the context of past, 

present and reasonably foreseeable future actions. Cumulative effects analysis is conducted in those areas 

where effects have or may occur. In addition, some activities have an influence that may extend 

‘downstream’ in the sub-watershed within the project area boundary. This broad area is referred to as the 

‘cumulative effects analysis area’. In general, all alternatives are considered in the context of relevant 

past, present and reasonably foreseeable future activities in this area. The cumulative effects analysis area 

for this project is the area contained within the project boundary, with the addition of haul routes under 

NFS jurisdiction that extend beyond. A summary table of the past management activities that have 

occurred in the cumulative effects analysis area is located in EIS Appendix B and has been used to assess 

the cumulative effects of implementing this project on the resources addressed in this chapter. Several 

past, on-going and reasonably foreseeable actions are identified involving road maintenance, repair and 

management.

Alternative 1 - No Action

No direct or indirect effects to the transportation system are expected. Therefore, on-going and reasonably 

foreseeable road maintenance and repairs would not have additive impacts and there would not result in 

cumulative effects. 

Changes to use of the transportation system in the Snow Basin project are expected to result from 

implementation of the Wallowa-Whitman National Forest’s travel management plan (TMP) as follows: 

Travel management

A Record of Decision, describing the selected alternative for the Wallowa-Whitman National Forest 

Travel Management Plan (TMP), was signed on February 21, 2012. This decision will limit motor-vehicle 

use to designated roads, trails and areas. It will also prohibit cross country travel and the use of closed 

roads by motor vehicles unless designated open for such uses as OHV travel. This may have the effect of 

concentrating users to the designated road system. This may cause roads to need maintenance on a more 

frequent interval to maintain the standard of the roads. With the implementation of the TMP, many roads 

that are open now, but have had an objective to be closed when funding and opportunities allow, will be 

closed by promulgation. Consideration of the current declining road maintenance budget, this may have a 

positive effect by lowering maintenance costs on the transportation system resulting from maintaining 

less open (designated) roads. 

Implementation of the travel plan selected alternative is expected to begin later in 2012 with publication 

of the Motor Vehicle Use Map (MVUM). There are changes that the public and the commercial road 

users will encounter between the existing condition on the ground to what is designated on the MVUM. 

There are some roads currently open on the road system that will not be designated for motor vehicle use, 

and conversely, there are some roads that are currently closed that will be designated for vehicular use. 

Also, some closed roads will be designated as motorized trails, and some trails will no longer be 

designated. 

Use of undesignated roads will be allowed only by permit, regardless of administrative action, private 

land access or other. Only during times of emergencies, such as fires, flood, law enforcement, or potential 

for imminent death or disaster, will the permit requirement be waived. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Implementation of selected alternative for TMP will result in some changes to the NFS road system 

within the Snow Basin area. Approximately 18 miles of currently open roads will be closed by 

promulgation. Six miles of roads now closed will be opened to full-size motor vehicles and/or OHVs.

This will affect open road densities in the project area. Open road density in timber emphasis lands (MA 

1) will drop in both watersheds, from 2.5 miles of open road per square mile, to an average of 1.75. Open 

road densities in winter range (MAs 1W and 3) will be reduced slightly. In Little Eagle Creek, densities 

will closely approach the 1.5 miles per square mile. In Paddy Creek – Eagle Creek, open road densities in 

1W will be reduced from 2.1 to 1.8, while densities in MA 3 will be unchanged. GIS data used to 

calculate these numbers was clipped to the analysis area boundary to be comparable to the open road 

density figures discussed in the existing condition section. 

A list of route-by-route changes resulting from implementation of TMP selected alternative is provided in 

the project record.

Road 77 flood damage repair

Another proposed project in/near the project area is the reconstruction of National Forest Service Road 

77. Currently this road is closed to full-size vehicular traffic due to flood damage in three locations 

between the East Fork of Eagle Creek and Tamarack Campground. This project will reconstruct the three 

locations and utilize associated rock material sources. These sites are located at Mileposts 25.7, 26.3, and 

28.1, respectively, and are located about 4 miles northwest of the project area on the Main Fork of Eagle 

Creek. There are 2 sources for rock (riprap) located within the Snow Basin project area, and 2 sources 

located outside of the project area. All four sources have been utilized in the past and are located adjacent 

to NFSR 77. Due to the proximity of the stream and the Wild and Scenic River designation of this area, 

specific requirements to preserve the natural appearance of the corridor will be required (no quarries will 

be created). 

The proposed work would be consistent with forest plan management guidance for the wild and scenic 

rivers (Management Area 7) and specifically, for the Eagle Creek Wild and Scenic River. 

Standards and guides associated with all classifications in the Wild and Scenic River designation for 

Recreation (#9) states: “...Keep (recreational) use increases at these lower levels by not adding major 

recreational developments and keeping road surfacing and road access at current levels...” The proposed 

repair of flood damage is consistent with this guidance, because it would restore through-traffic along a 3-

mile section of NFSR 77 which is currently inaccessible to full-size motor vehicle use, and would replace 

the road surface to its previous condition.

One of the desired future conditions described in the management direction for the Wild and Scenic River 

Corridor states: “Water quality will improve over time with the emphasis on OR values and water quality, 

and the requirement to protect river values in all adjacent area activities. Watershed enhancement projects 

will continue to be identified and accomplished over time.” In addition, the standards and guides for 

Watersheds (#56) states: “Improve road maintenance levels on roads to reduce sedimentation.” Road 

repairs would address both of these by reducing sediment contributions to Eagle Creek, by stabilizing 

these presently unprotected washouts that erode directly into the channel. This reconstruction would 

replace the lost road fill with large, rock riprap which will buttress and contain the road fill. It will be 

keyed into the streambed in such a manner as to withstand high water flows of Eagle Creek, thus 

protecting the road, itself. This riprap also provides an armored slope for the dissipation of sheet flow off 

the roadbed which will slow down the velocity of runoff and allowing for sediment to be delivered into 

the fill (riprap) material, and not the stream.

In the short term, reconstruction of this road will affect road users by delaying traffic along the main road 

to and from recreation areas and homesites during construction periods. It will, however, result in a safer 

and more efficient road once the reconstruction work is completed, as this road is the main access to 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Eagle Creek and the private in-holdings along the corridor. There is one material source (quarry) located 

in the project area (outside of the wild and scenic river corridor) that will be utilized for borrow and 

crushed aggregate. This source is the Empire Gulch rock pit, located on NFSR 7015075 in T7S, R44E, 

Section 20. Haul operations on roads 7015 and 77 may impact public travel as users encounter large truck 

traffic during the construction season. Advance-warning signs would be in place during construction, and 

contractor haul operations would be restricted during weekends or holidays.

Some road damage repairs associated with the June, 2010 flood event were completed in 2010 and 2011. 

These are described in Appendix.

Minimum road system.

Under 36 CFR 212.5, Subpart A, the Forest Service was directed to identify the minimum road system 

needed for safe and efficient travel and for administration, utilization, and protection of National Forest 

System lands. This road system is to be identified by the responsible official (Forest Supervisor) by the 

end of FY2015, and should not only identify roads needed for these purposes, but also those roads no 

longer needed to meet forest resource management objectives and which therefore should be scheduled 

for decommissioning or considered for other uses. The WWNF embarked on this Minimum Road System 

(MRS) process in 2010, and is expected to have the analysis completed by then end of 2012. There are 

roads identified in the project area with recommendations for treatment (i.e., reconstruction, 

decommissioning, or conversion to OHV trail) in the MRS analysis. It should be noted that the MRS 

analysis is only a recommendation, and site –specific evaluation and verification of these 

recommendations should be completed during an appropriate NEPA process.

Alternative 2, 3, and 4

Travel management plan

As discussed above, implementation of TMP is expected later this year with publication of the MVUM.

There are two types of changes expected to occur at that time that would impact project activities. First, 

TMP would change the designation of some roads proposed for use in the project - some roads and road 

segments currently identified as open in the transportation atlas will no longer be designated open to 

motorized travel, and some that are now closed (maintenance level 1) will be designated as open to 

motorized use. Route-specific changes are identified in the project record.

Second, there would be a change in how the use of closed roads for project purposes will be authorized. 

During the implementation of a timber sale contract, roads designated on the MVUM (open roads) and 

closed roads will be identified in the timber sale contract, and the associated requirements for maintaining 

a road open to the general public for use will be specified accordingly. The timber sale contract is the 

mechanism that will permit the contractor and his employees and subcontractors to travel on roads 

otherwise not designated, and it will include requirements for the contractor to close roads via signing or 

physical closures will be implemented on these undesignated roads.

For roads that are designated on the MVUM, when the contractor opens these roads for project use, they 

will be maintained as open for joint use traffic unless otherwise stated in the timber sale contract (e.g. 

when the road is determined to be unsafe during periods of haul for joint use). In this case, the road would 

be open to public traffic during times when the contractor is not working. Upon completion of the timber 

sale activities on a road, if the road is not a designated road on the MVUM, it will have drainage devices 

installed and be physically closed in a manner consistent with its anticipated future use. If it is a 

designated road on the MVUM, it will have drainage devices installed appropriate to its maintenance 

level and will be left open to vehicular travel. Undesignated roads which have a designation for OHV use, 

that are used for timber harvest or haul, will be managed as maintenance level 1 roads during the life of 

the contract as described above. When final maintenance and closure activities take place on these types 

of road, the road and any barricade(s) shall remain passable by OHV’s less than or equal to 50” in width.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Summary of All Effects 

Alternative 1 - No Action

There would be no direct or indirect effects to the transportation system. There would be no change in 

open road density within the Snow Basin project area.

Alternative 2, 3, and 4 - action alternatives

There would be no change in open road density, as no new permanent road construction is proposed. 

Open road density will decrease with implementation of the TMP selected alternative.

The existing NFS road system will be used for project activities, with the greatest potential for effect 

resulting from log hauling. Proposed maintenance and reconstruction is described, and would result in no 

change in operational maintenance level. Two proposed changes to the road system – replacement of a 

bridge and relocation of a 1-mile segment of road out of a riparian area – would represent a long term 

benefit to the transportation system. Implementation of TMP will result in some changes to the system 

within the Snow Basin area, with approximately 18 miles of currently open roads to be closed by 

promulgation, and six miles now closed will be opened to full-size motor vehicles and/or OHVs. 

Mitigations and Monitoring

Project Design Features and Mitigation Measures

1. System roads planned for project use will be maintained to a standard needed for project use. 

Maintenance activities will be in accordance with the Wallowa-Whitman standard specifications 

for timber sales. Typical maintenance activities include; blading and shaping roadbeds, cleaning 

ditches and culverts, installing and replacing temporary culverts, removal or ramping over of 

small slumps and slides, road-side brushing of overhanging limbs and small diameter trees, 

logging out blow downs and felling danger trees. Haul activities may include; dust abatement on 

primary haul routes, and snow removal for winter haul. Post-haul maintenance includes; water 

barring and blocking closed roads; re-establishing and adding to cross ditches on lower standard 

open and closed roads, and final blading and shaping of all roads, as necessary.

2. System roads needing work beyond the intent of the road maintenance specifications will be 

reconstructed to the minimum standard needed to support haul. Typical reconstruction work 

includes heavy clearing, drainage work (springs, culvert replacements), removal and stabilization 

of landslides, placing rock subgrade reinforcement and surfacing. Non-typical reconstruction 

includes relocating road segments and removal and replacement of a bridge structure.

3. System roads that are closed will be opened for project use only and re-closed.

4. Temporary roads will be constructed and then stabilized and blocked under the terms of the 

contract. Location and clearing width, and any special construction requirements (including posthaul treatment) will be agreed to in writing prior to construction.

5. Existing roads that are not system roads will be used for the project under the timber sale contract 

terms for temporary roads. Location, clearing width, and any special requirements (including 

post-haul treatment) will be agreed to in writing approval prior to construction and they will be 

closed and stabilized after use.

6. Open and closed (ML1 and 2) system roads not necessary for public access may be closed to the 

public and signed for project use only during project operations.

7. Bridges and culverts will be installed during instream work window. Culverts to be installed on 

Category 4 streams will occur during dry channel conditions.
Chapter 3 Snow Basin Vegetation Management Project FEIS

373

8. Prevention of Pine Engraver Beetle (Ips pini) during road clearing and maintenance. Avoid 

leaving greater than or equal to 4” diameter small end ponderosa pine slash in the woods from 

December 1 through June 30th. Avoid piling or decking during this period.

Monitoring Recommendations

Implementation monitoring for transportation-related activities would be specified in the timber sale 

contract.

Consistency and Compliance

Wallowa-Whitman National Forest Land and Resource Management Plan as amended

Open Road Density: Alternatives 1, 2, 3 and 4 would be consistent with the Wallowa-Whitman Land and 

Resource Management Plan guidance to meet open road densities as directed for specific management 

areas (4-34), in MA 1 (4-57) and MA 3 (4-58-62). While open road densities for some of these MAs are 

exceeded in some subwatersheds, none of the alternatives include activities that would change open road 

density. As discussed under Cumulative Effects, open road densities will be reduced with implementation 

of the recent TMP decision. All alternatives are also consistent with other direction pertaining to

transportation system management (4-34-35).

There are not specific open road density standards or guidelines for Management areas 7 (Wild and 

Scenic Rivers) and 15 (Old Growth). Forest plan direction for MA 7 is that the transportation system must 

be consistent with wild, scenic, and recreational river objectives (4-71-75), which is discussed below.

Forest plan direction for MA 15 relative to transportation is to avoid new NFS road construction to 

manage new and existing roads to retain the old-growth characteristics of the area including solitude (4-

90). The proposed Snow Basin project would be consistent with this guidance because there would be no 

new permanent roads constructed.

Wild and Scenic Rivers: Alternatives 2, 3 and 4 would be consistent with forest plan guidance for wild 

and scenic rivers (MA 7), and specifically for Eagle Creek Wild and Scenic River as outlined in the river 

plan (Forest Plan Amendment 2). 

Road work (including maintenance) would be conducted in a manner consistent with the Wild and Scenic 

River designation. The proposed work would protect and enhance the outstandingly remarkable values 

associated with Eagle Creek. Specifically, road reconstruction would be aligned with the following 

desired future condition for the Eagle Creek Wild and Scenic River: “Water quality will improve over 

time with the emphasis on [outstandingly remarkable] values and water quality, and the requirement to 

protect river values in all adjacent area activities. Watershed enhancement projects will continue to be 

identified and accomplished over time.” In addition, the following standards/guide for watersheds (#56) is 

applicable: “Improve road maintenance levels on roads to reduce sedimentation.” Road reconstruction 

and maintenance projects identified in these alternatives address this guidance by:

• Reducing sedimentation by constructing and maintaining drainage devices, such as ditches, 

surface cross drains, and culverts, which not only reduce the volume and velocity of water flow, 

but also the duration upon which the flow lies on the road itself. This allows the deposition of any 

sediment in the flow to be released at more frequent intervals across the landscape, reducing or 

eliminating any direct deposits into the streams themselves.

• Reducing or eliminating rutting and channeling of water through road blading, thus reducing the 

volume and velocity of water being transported over the road, allowing it to be distributed slowly 

through sheet flow to the adjacent roadside vegetation.
Chapter 3 Snow Basin Vegetation Management Project FEIS

374

• Buttressing a roadbed by addition of crushed aggregate surfacing, thus allowing traffic to use a 

road without creating ruts, rills, or other road damage. Construction of blind drains where spring 

or other bogs have developed in the traveled way have a similar result.

Recreation standards and guides for the Recreational River classification (c. 2) states, “Road access will 

be provided to most areas along the Recreational sections. Existing level of access will be maintained.”

This standard and guide would be met by maintaining and/or reconstructing certain segments of NFSR 

7015, 7020, 77, and 7735, which are the main ingress and egress to Eagle Creek. This would enhance the 

recreational experience by providing a safer and more durable route to travel, by blading and providing 

drainage and surfacing as necessary to reduce the susceptibility to rutting, channeling, or concentration of 

water (mudholes) on these roads.

Travel Management Rule of 2005 (36 CFR parts 212, 251, 261, 295)

Forest-wide travel management planning to meet the requirements of this rule was recently concluded 

with signing of Record of Decision on February 21, 2012. See the Cumulative Effects section for 

discussion of the Wallowa-Whitman Travel Management Plan (TMP), scheduled implementation, and 

anticipated changes to the transportation system and its management relative to the proposed activities.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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POTENTIAL WILDERNESS/UNROADED AREAS

Inventoried Roadless Areas, Potential Wilderness Areas, and Other Undeveloped

Areas

This document discloses the affected environment and environmental consequences for Little Eagle 

Meadows inventoried roadless area (IRA), and Little Eagle Meadows potential wilderness area (PWA), 

and other remaining undeveloped lands. These three resource topics (IRA, PWA, other undeveloped 

lands) are grouped and discussed together because they share a complicated set of terminology and 

interrelated history. Appendix B discloses additional narrative and maps in support of these topics. 

During public involvement for this project, and in past similar projects, a wide range of terms have been 

used by respondents, the courts, and the Forest Service when referring to these topics. Some of these are 

roadless, inventoried roadless area, unroaded area, un-inventoried roadless, potential wilderness area, 

undeveloped lands, and roadless expanse.

From the mid-1970s through 2001 the Forest Service maintained a roadless area inventory of 

undeveloped lands that we used and updated for RARE, RARE II, and in support of Land and Resource 

Management Planning completed in 1990. During that time, these lands were called “roadless areas” or 

“inventoried roadless areas” (IRA). With completion of the Roadless Area Conservation Rule (RACR) in 

2001, these lands ceased being an “inventory”, and IRAs became a designation with fixed boundaries and 

prohibitions set by that rule and Forest Service regulation (36 CFR 294). Confusion ensued because the 

same areas were located on two Forest Service maps, meaning two very different things but with the same 

name; IRA. One map had fixed boundaries set by RACR, and the other had changeable boundaries based 

on inventory criteria.

To address the situation, the Forest Service created a new term for the inventory of undeveloped lands 

called “potential wilderness area” (PWA) to make a distinction between the IRA term used by the 2001 

RACR. This terminology addition was made policy by changing the 2006 handbook for wilderness 

evaluation (FSH 1909.12 Chapter 70) and is reflected in the 2008 Forest Service NEPA regulations (36 

CFR 220). In the regulations, potential effects to “inventoried roadless areas” and “potential wilderness 

areas” are factors in determining whether a CE, EA, or EIS is the appropriate NEPA document for a 

project. The term “other undeveloped lands” is presented and used in this document to provide a 

consideration for the balance of those remaining lands that did not meet the inventory criteria for PWA, 

were not designated an IRA under RACR, and do not contain roads and evidence of timber harvest (see 

definitions below).

In the early 2000s, Oregon Wild, a local interest group, conducted their own inventory across Oregon, 

including the Wallowa-Whitman National Forest, using inventory criteria they developed for their 

purposes. The Sierra Club, a national interest group, has also produced an inventory using inventory 

criteria they developed for their purposes. Polygons on both maps are referred to as “inventoried roadless 

areas” , “roadless areas”, “unroaded”, or “un-inventoried roadless areas”. Each map produced is based on 

different definitions and inventory criteria and looks very different from maps produced by the Forest 

Service based on the criteria from agency law, regulation, and direction. The Forest Service relies on 

agency policy, agency definitions of terms, and agency procedures for the inventory of resources and 

facilities. Inventory criteria and procedures for potential wilderness areas are found in Forest Service 

Handbook 1909.12, Chapter 71.

The terms and definitions as stated below will be used in this site-specific analysis. The four resource 

topics are based on current law, regulation, agency policy, and the Wallowa-Whitman Land and Resource 

Management as amended.
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Wilderness: A wilderness area is designated by congressional action under the Wilderness Act of 

1964 and other wilderness acts. Wilderness is undeveloped Federal land retaining primeval 

character and influence without permanent improvements or human habitation.

Inventoried Roadless Areas (IRA): These areas were identified by the 2001 Roadless Area 

Conservation Rule in a set of inventoried roadless area maps contained in Forest Service Roadless 

Area Conservation Final Environmental Impact Statement, Volume 2, dated November 2000. 

These areas were set aside through administrative rulemaking and have provisions, within the 

context of multiple use management, for the protection of inventoried roadless areas. Most IRA 

boundaries are substantially the same as those identified as “roadless areas” as referred to in the 

1982 planning rule (36 CFR 219.17) and identified in the 1990 Wallowa-Whitman Forest Plan, 

FEIS, Appendix C; however some localized, minor differences in boundaries may exist.

All roadless area acres were allocated to various management areas strategies as disclosed in the 

Wallowa-Whitman Forest Plan FEIS and described in the Record of Decision. 

Potential Wilderness Area (PWA): Areas of potential wilderness identified using inventory 

procedures found in Forest Service Handbook (FSH) 1909.12, Chapter 71 are called potential 

wilderness areas. The inventory is conducted by the Forest Service with the purpose of 

identifying potential wilderness areas in the National Forest System. The Wallowa-Whitman 

1990 Forest Plan, as amended, directs roadless areas be evaluated and considered for wilderness 

recommendation during the forest planning process. PWA is not a land designation decision. 

They do not imply or impart any particular level of management direction or protection. They are 

not an evaluation of potential wilderness (Chapter 72). Lastly, they are not preliminary 

administrative recommendations for wilderness designation (Chapter 73). PWA inventories do 

not change the administrative boundary of any IRA, but they may substantially overlap and/or be 

contiguous with an IRA. PWA may be contiguous with designated wilderness where the 

boundaries touch. Newly inventoried PWA may stand alone and my not have been previously 

identified in Appendix C of the 1990 Wallowa-Whitman Forest Plan or the 2001 RACR. PWA 

overlaps inventoried roadless areas only where those acres of land are consistent with the 

inventory criteria set out in the handbook, and may extend beyond IRA boundaries and 

wilderness boundaries where consistent with those criteria. 

Background

Oregon Wild submitted a map depicting the areas with the Snow Basin project area that meets the criteria 

they developed and used for their purposes. It identified unroaded, backcountry areas adjacent to the 

Eagle Cap Wilderness, as well as areas identified as Lower Eagle Creek and Skull Creek uninventoried 

roadless areas (see map and letter dated January 29, 2009 in the project file). Oregon Wild did not provide 

the inventory criteria they used to develop their map submitted during public comment for this project. 

Confusion surrounds this issue, because there are conflicts between Forest Service maps and the map

presented by Oregon Wild. Each map uses similar terms with very different definitions, as well as 

different methodology and criteria used for the inventory. Confusion continues with the request to 

disclose the impacts to “roadless characteristics” on lands that Forest Service determines does not meet 

agency inventory criteria. 

To resolve this confusion the Forest Service uses its discretion to rely on agency policy, agency 

definitions of terms, and agency procedures to the inventory. Inventory criteria and procedures for PWA 

are found in FSH 1909.12, Chapter 71, with the application of these procedures to the Snow Basin project 

found in Appendix B of this document. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

377

Appendix B

Appendix B of this document describes the process and rationale used to inventory for and identify 

potential wilderness and other undeveloped lands. It also considers the potential effects of the alternatives 

for the Snow Basin Vegetation Management Project. Maps included in Appendix B show a visual 

progression of the inventory process, final results, and any additions to the Potential Wilderness Area 

inventory in the final map. The inventory is based on, and consistent with criteria found at Forest Service 

Handbook (FSH) 1909.12 Chapter 71. The Forest Service used professional judgment and local 

knowledge regarding unique, site-specific conditions of each area being considered for placement in the 

inventory of potential wilderness areas.

The effect to inventoried roadless areas (IRAs), potential wilderness areas (PWAs), and other 

undeveloped lands are based on maps and polygons created using agency inventory procedures 

(Appendix B) and are considered disclosed here. The descriptions of environmental consequences 

disclosed in this section for IRA/PWA and other undeveloped lands applies to the areas of Oregon Wild 

polygons that overlap with IRA/PWA polygons and other undeveloped lands polygons. 

An outcome of the PWA inventory process was the identification of isolated polygons of other 

undeveloped lands. These polygons did not meet inventory criteria as potential wilderness areas and they 

are not inventoried roadless areas or a designated wilderness area. Each individual polygon of isolated 

land has no history of harvest activity and does not contain forest roads. They are stand-alone polygons of 

varying acreages which individually are less than or equal to 4,999 acres. Other undeveloped lands are 

displayed in Appendix B Map 5. The description of environmental consequences to the intrinsic physical 

and social values are disclosed in this chapter of the EIS for other undeveloped lands, which applies to the 

acres described in Oregon Wild’s scoping letter and map that overlap with other undeveloped lands 

polygons displayed in Appendix B. Timber harvest and prescribed fire are proposed within other 

undeveloped lands and the consequences are described. Proposed vegetation management treatments may 

affect characteristics of undeveloped lands within the Snow Basin Project area. This analysis will disclose 

any potential effects resulting from the proposed treatments. 

The Wallowa-Whitman National Forest, in coordination with the Umatilla and Malheur National Forests, 

is involved in a tri-forest plan revision process, referred to as the Blue Mountain Forest Plan Revision 

(BMFPR). During the revision process the BMFPR team conducted public meetings and accepted 

scoping comments on the Potential Wilderness Area inventory. The Little Eagle Meadows IRA was the 

starting point for creating the Little Eagle Meadows PWA. This process started in 2005, and follows the 

inventory criteria outlined in FSH 1909.12 Chapter 71. At that time, there were minor deletions and no 

additions to the total acres in the PWA when compared to the original IRA. However, the IRA is 

protected by the stipulations of RACR, and continues to be the starting point for this analysis, regardless 

of the deletions.

Little Eagle Meadows IRA and PWA

The Little Eagle Meadows Inventoried Roadless Area (IRA) referred to an area usually of at least 5,000 

acres, without developed and maintained roads, and substantially natural conditions was inventoried as 

part of the Land and Resource Management Planning process (LRMP 46 CFR 219.27 (c)). This IRA for 

the Wallowa-Whitman National Forest can be found in the LRMP Final EIS page IV-59. The Little Eagle 

Meadows roadless area is identified and mapped in Appendix C of the Wallowa-Whitman Forest Plan

Final EIS, and is also identified in the set of maps for IRAs in the Forest Service Roadless Area 

Conservation FEIS, Volume 2, dated November 2000. There are no meaningful differences between the 

boundaries identified in Appendix C of the Forest Plan and the RACR IRA boundaries, therefore these 

two topics will be discussed together.
Chapter 3 Snow Basin Vegetation Management Project FEIS

378

In the case of the Little Eagle Meadows, most of the IRA is a PWA, but not all acres meet the PWA 

inventory criteria, because the lands within the IRA were allocated to a 1990 Forest Plan management 

area that provided for timber harvest and road construction. The Little Eagle Meadows IRA and PWA are 

just north of the planning area, abutting it along the northern edge. As mentioned previously, the neither 

status nor the boundary of the IRA changes, because some acres do not meet the inventory criteria of a 

PWA. The boundary remains as mapped in the Forest Service Roadless Area Conservation FEIS.

Scope of Analysis

The scale of analysis is the Snow Basin project planning area and the Little Eagle Meadows PWA, which 

includes the Little Eagle Meadows IRA.

Indicators for IRA and PWA

These indicators show the values and features that often characterize inventoried roadless area:

1. High quality or undisturbed soil, water, and air

2. Source of public drinking water

3. Diversity of plant and animal communities

4. Habitat for threatened, endangered, proposed, candidate, and sensitive species and for those 

species dependent on large undisturbed areas of land

5. Primitive, semi-primitive, non-motorized, and semi-primitive motorized classes of dispersed 

recreation

6. Reference landscapes

7. Natural appearing landscapes with high scenic quality

8. Traditional cultural properties and sacred sites

9. Change in acres of IRA

10. Change in inventoried acres of PWA

Indicators for other undeveloped lands

1. Intrinsic physical and biological resources (soils, water, wildlife, recreation fisheries, etc.)

2. Intrinsic social values (apparent naturalness, solitude, remoteness)

3. Change in acres of other undeveloped lands

Affected Environment

Wilderness affected environment

There are no designated wilderness areas within the project boundary. Wilderness evaluation and 

wilderness recommendations are a forest planning issue and outside the scope of this site specific analysis 

and decision. Only Congress has the statutory authority to designate wilderness. It is within the authority 

of Congress to designate wilderness areas that do not meet the potential wilderness inventory criteria. 

Areas recommended to Congress for wilderness study or designation are those areas identified on the 

potential wilderness inventory and evaluated for wilderness suitability for potential addition to the 

National Wilderness Preservation System by forests during the Land Management Planning process using 

wilderness inventory criteria, outlined in Forest Service Handbook 1909.12, Chapter 71. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

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Inventoried Roadless Area affected environment

There is one Forest Service inventoried roadless area (Little Eagle Meadow) adjacent to but outside the 

project boundary. No changes were made to these boundaries. No activities or projects (timber harvest, 

prescribed fire, etc.) are proposed within the inventoried roadless area. Boulder Park inventoried roadless 

area is located northwest of the project area. It is not considered in this assessment because it is 

geographically separated from the project. East Eagle road and East Fork Eagle Creek, as well as national 

forest and private lands, lie between the Snow Basin project area and Boulder Park IRA. 

Potential Wilderness Area Inventory affected environment

Inventory of potential wilderness areas and identification of other undeveloped areas within the Snow 

Basin project area was done using a process and rationale described in Appendix B. The inventory is 

based on, and consistent with criteria found at Forest Service Handbook (FSH) 1909.2 Ch. 71.

There is one potential wilderness area (PWA) identified in the BMFPR potential wilderness inventory, the 

Little Eagle Meadows PWA (6,972 acres) associated with the Little Eagle Meadows IRA. No timber 

harvest, mechanical fuel activities, or road construction are proposed within this PWA. No acres of the 

PWA are within the project boundary. Lands with values and features that often characterize inventoried 

roadless areas are increasingly important within developed landscapes in order to provide clean drinking 

water and function as biological strongholds for populations of threatened and endangered species. They 

provide areas that are important for biological diversity, dispersed outdoor recreation; and also sever as 

bulwarks against the spread of non-native invasive species and provide reference areas for study and 

research. (36 CFR 294, pg. 3245).

Within PWAs human influences have had less impact on the natural appearance or long-term ecological 

process compared to managed lands. The current condition of soil, water quality, air quality; plant and 

animal communities; habitat for threatened, endangered, and sensitive species; and noxious weeds, 

recreation, and cultural resources are described in the various sections elsewhere in Chapter 3 of this EA. 

Disturbance by insects and fire has been and most likely, and will continue to be the factors with the most 

potential to impact the naturalness and undeveloped nature of the area. Opportunities for primitive 

recreation are limited to hiking, mostly cross-country, and hunting. 

The inventory for Snow Basin project identifies areas that meet potential wilderness inventory criteria 

within the Snow Basin analysis area and those lands lying adjacent to and abutting the Little Eagle 

Meadows IRA, totaling 797 acres. It also discloses effects of proposed project activities on those potential 

wilderness areas. The evaluation of potential wilderness, and review and approval of wilderness 

recommendations are steps that occur during the Land Management Planning process. All are outside the 

scope of this analysis. Criteria listed in FSH 1909.12, section 71.11 guided the inventory process for the 

Snow Basin Project analysis. ArcMap geographic information system (GIS) was used to identify past and 

proposed activities in regards to potential wilderness areas. The potential impacts to areas meeting 

potential wilderness inventory criteria from this project were determined based on use and interpretation 

of GIS data and review of proposed treatment locations for the following proposed treatments: overstory 

removal, intermediate harvest, and non commercial thinning. See the complete inventory process in 

Appendix B. 

Scoping

Oregon Wild provided a map depicting unroaded/undeveloped areas within the Snow Basin project 

according to undisclosed criteria that they used for their purposes. It identified unroaded, backcountry 

areas adjacent to the Eagle Cap Wilderness, as well as areas identified as Lower Eagle Creek and Skull 

Creek undeveloped areas (see map and letter dated January 29, 2009 in the project file). The Lower Eagle 

Creek (name used on Oregon Wild map) area closely matches polygon #52, identified through the PWA 
Chapter 3 Snow Basin Vegetation Management Project FEIS

380

analysis (see Appendix B Map 4). Effects on this area are disclosed in this assessment. The Skull Creek 

area, although not roaded has been harvested in the recent past and did not meet the criteria for PWA 

consideration so it was not analyzed further. 

Existing Condition

For about 100 years, lands within the Snow Basin Planning Area have been actively managed to meet a 

variety of resource objectives. Evidence of past management is quite apparent with the existence of roads 

and other developments for recreational activities such as campgrounds and trailheads. Recent evidence, 

within the last 35 years, of timber management exists across the entire analysis area in the form of cut 

stumps, skid trails, and log landings and roads. Appendix B Map 1, in the appendix, displays the position 

of the analysis area relative to the Eagle Cap Wilderness Area and the Little Eagle Meadows IRA. It also 

displays the roaded nature of the analysis area. Appendix B Map 2 depicts the recent past harvest areas 

within the Snow Basin Planning area. As shown by this map, most of the analysis area has been harvested 

in the recent past. Appendix B Map 3 is a combination of past harvest areas and existing system roads 

with identifiable 300 foot boundaries. Appendix B Map 4 shows those areas between roads and past 

harvest activities. Appendix B Table B-15b lists those polygons located between roads and harvested 

areas with their acreages. These were evaluated as Potential Wilderness Areas. Five polygons, totaling 

797 acres, met one criterion for potential wilderness (Appendix B Table B-15c), are contiguous with 

Little Eagle IRA.

Environmental Consequences

Alternative 1 – No Action

Direct and indirect effects – Alternative 1

Alternative 1 proposes no action and initiates no human caused changes to designated wilderness.

Alternative 1 proposes no action and initiates no human caused changes to the potential wilderness areas 

north of the project area. The areas meeting potential wilderness criteria as inventoried during this process 

would not be impacted under Alternative 1. Natural conditions and undeveloped character of the project 

area would be the same as the existing condition. Ongoing activities would not substantially alter the 

character of these areas that could hinder the future consideration as PWAs. 

Alternative 1 proposes no action that would result in human caused changes to other undeveloped areas 

with the project area.

Effects Common to Action Alternative (2, 3, and 4)

Direct and Indirect Effects – Alternatives 2, 3, and 4

Wilderness

Alternatives 2, 3, and 4 propose no action, and initiate no human caused changes to designated 

wilderness.

Potential wilderness area and inventoried roadless areas

No road construction would occur in the Little Eagle Meadows IRA or PWA. No roads exist in this area, 

therefore no road use or maintenance would occur. No timber harvest would occur in the Little Eagle 

Meadows IRA or PWA. With no activity occurring within the PWA or IRA, there will be no effect on the 

quality of soil, water, air, or sources of public drinking water within area. There will be no activity 

reducing the diversity of plant and animal communities, threatened and endangered species, and species 

dependent on large undisturbed areas of land. Recreation opportunities will not change in the PWA or 

IRA. There will be no changes to the scenic quality or traditional cultural properties.
Chapter 3 Snow Basin Vegetation Management Project FEIS

381

The differences in the location and amount of treatment between alternatives do not alter the impact to 

potential wilderness areas (PWAs), because the PWAs that meet one or more evaluation criteria are not 

impacted by the proposed harvest activities or associated roads under any action alternative. 

Approximately 25 acres within polygons overlapping the project boundary are proposed for prescribed 

burning. 

Change in PWA acres

All acres within the Little Eagle Meadows PWA would remain in the PWA inventory following the 

implementation of all action alternatives. With the new inventory that has been conducted for the Snow 

Basin project, additional acres associated with polygons 3, 4, 6, 8, and 97 would increase the size of Little 

Eagle Meadows PWA by approximately 800 acres. Thus, following implementation, all acres within the 

PWA would be available for consideration in an evaluation of potential wilderness (FSH 1909.12, Ch 72) 

and preliminary administrative recommendations for wilderness designation (FSH 1909.12, Ch 73) during 

forest plan revision.

The differences in the location and amount of treatment between alternatives do not alter the impact to 

PWAs, because the five polygons that meet one or more evaluation criteria are not impacted by the 

proposed harvest activities or associated roads under any action alternative. Appendix B Maps 6, 7, and 8, 

which show the PWA, demonstrate that none is overlapped by proposed harvest treatments. Two areas, 

identified as polygons 6 and 97 have treatment units abutting portions of the PWAs.

There would be no change in PWA acres.

Change in other undeveloped areas

There are no forest-wide or management area standards specific to other undeveloped lands on the 

Wallowa-Whitman Forest Plan. The Snow Basin project area consists primarily of acres allocated to 

management areas that provide for timber production (management areas 1 and 3). All action alternatives 

propose to harvest trees from approximately 40 percent of the project area and prescribe burn about an 

additional 14 percent, see Chapter 2 for specific acreages and locations under each alternative. The 

removal methods include ground-based logging, using tractor, forwarder, or skyline harvest systems. In 

some areas, temporary roads would be built to facilitate the removal of commercial logs. Most of these 

roads would be built within proposed harvest units. Landings associated with the ground-based systems 

would be located adjacent to existing and proposed roads and at existing landings where possible. 

Ground-based landings would range in size from 0.10 to about one acre. Where ground-based logging 

occurs, evidence of logging would be apparent. Possible effects include skid trails which often create 

exposed soils across the forest floor. These effects are generally noticeable until grasses and shrubs in the 

understory reestablish and lessen the effects of ground-based equipment. In this area that would take 3 to 

5 years.

Nearly one-half of the polygons identified on Map 5 as other undeveloped lands are less than 50 acres in 

size. Only one is larger than 50 acres. 

Polygon 52, which does not meet any of the PWA criteria, is the largest block of land (1,782 acres) within 

the Snow Basin analysis area that has no roads or recent evidence of harvesting. Five treatment units, 304, 

137, 103, 108 and 425 partially overlap this polygon, for a total of 27 acres of intermediate harvest under 

alternatives 2, 3, and 4. Effects to this area would be minimal, consisting of visible stumps and skid trails, 

but no new roads. Since this area does not currently meet PWA criteria, the proposed 27 acres of harvest 

would have no effect on its ability to qualify as a PWA. In addition, the values associated with this 

undeveloped area continue to be protected through management of the Eagle Creek Wild and Scenic 

River stipulations found in the Eagle Creek Wild and Scenic River Plan. See additional information in the 

Recreation portion of this chapter.
Chapter 3 Snow Basin Vegetation Management Project FEIS

382

Other undeveloped lands include soils, water, and fish and wildlife habitat not impacted directly by past 

harvest and road building. The current condition of soil, water quality, air quality, plant and animal 

communities; habitat for threatened, endangered, and sensitive species; noxious weeds, recreation, and 

cultural resources within the project planning area are described elsewhere in Chapter 3 of this EIS. 

Human influences have had limited impact to long-term processes within the other undeveloped lands. 

Disturbance by insects and fire has been and most likely will continue to be the factors with the most 

potential to impact the area. Opportunities for primitive recreation are limited to hiking, mostly crosscountry, and hunting. Opportunities for a feeling of solitude, the spirit of adventure and awareness, 

serenity, and self-reliance are limited by the size and shape of the polygon. Distance and topographic 

screening are also a factor. The optimum shape and location to retain solitude and a sense of isolation 

from noise and sights of other humans and their activities would be at the center of a circle. Most of the 

polygons within the project area are long and narrow, providing less distance from noise at their midpoint. 

Nearby, non-conforming sights and sounds of roads and timber harvest can be heard and seen from the 

undeveloped lands, because they are all much less than one square mile in size. 

The existing condition of all undeveloped areas within the Snow Basin project area presents a landscape 

that has been managed. It generally developed in nature, reflecting the multiple-use intent and decisions 

made in the Forest Plan (1990 as amended). It reflects consistency with Forest Plan Management area 

allocations. 

Danger tree removal

Danger trees would be removed from along haul routes used for timber sale activity and all roads within 

the project area that remain open after sale activities have finished. No danger tree removal is proposed in 

potential wilderness areas in any of the action alternatives. The potential wilderness inventory 

incorporates a 300 feet boundary from all forest roads. All danger tree removal would occur within 300 

feet of a forest road. Danger tree removal treatment would cause no effects on potential wilderness 

inventory areas. Firewood cutting also generally occurs within the 300 foot buffer of open roads and is 

expected to have no effect on PWAs. 

Prescribed burning

There would be no effect of prescribed burning to wilderness, potential wilderness areas, or other 

undeveloped lands due to the temporary nature of the effects. Effects of burning would be similar under 

each alternative. Evidence of burning includes charring on tree boles, scorched needles and some 

mortality, normally 10 percent of the standing trees or less. For a period of 2 to 5 years there would be 

some evidence of fire but no signs of other management activity related to the burning. Prescribed 

burning normally utilizes roads as control lines but occasionally installs fuel breaks to connect control 

features. These breaks cause minimal ground disturbance and normally recover within 1 to 3 years.

Summary of direct/indirect effects 

Through a systematic process of elimination, five areas of land were identified as meeting one PWA 

criteria. These areas are identified on Map #4 as polygons 3, 4, 6, 8, and 97. None of the treatment 

activities identified in the action alternatives would impact these areas so as to prevent their inclusion in 

future PWA inventory. Treatments adjacent to PWAs occur on lands previously harvested, still showing 

evidence of past harvest activities. If the past harvest activities were excluded for, the existing road 

system greatly limits the PWA.

The Little Eagle Meadows Inventoried Roadless Area PWA, although not evaluated as potential 

wilderness in this analysis (it was previously done by the Blue Mountain Forest Plan Revision), would not 

be affected by the action alternatives. No harvesting or road building would occur within the Little Eagle 

Meadows IRA altering its potential for wilderness consideration. Activities adjacent to the IRA are in 

keeping with activities occurring in the past and would not change the character of the Little Eagle 
Chapter 3 Snow Basin Vegetation Management Project FEIS

383

Meadows IRA. The largest polygon of other undeveloped lands identified on Map 4 and 5, #52, 

considerably overlaps a polygon identified by Oregon Wild during scoping for this project as Lower 

Eagle Creek unroaded area. No road construction and 27 acres of harvest is proposed within this area 

under alternative 2, 3 or 4. The area is largely contained within the Eagle Creek Wild and Scenic River.

Cumulative Effects

The cumulative effects analysis area for potential wilderness area criteria is the Snow Basin Analysis 

Area. Road building, which began in the early 1900s, has affected which lands meet potential wilderness 

criteria. Past harvest of timbered slopes is generally noticeable for up to 35 years depending on soils, 

aspect, and vegetative species composition. At the end of this time period, the re-growth of vegetation 

begins to develop characteristics of a closed canopy and begins to appear similar to surrounding uncut 

areas. The existing road system itself substantially limits the area available for PWA consideration. 

Past Activities

Past timber harvest and salvage operations have occurred throughout the project area, see Map 4 for a 

view of recent harvest activity and existing system roads. Areas with recent past timber harvest and 

salvage operations generally do not meet potential wilderness inventory criteria because there is extensive 

evidence of human activities.

On-going/present activities

Present activities in the analysis area include: firewood cutting, livestock grazing, use and maintenance of 

forest roads, fire suppression, noxious weed assessment and control, summer and fall recreation including 

hunting, hiking, driving for pleasure, gathering, and dispersed camping. Areas containing extensive forest 

roads, such as the Snow Basin Planning Area, would not meet potential wilderness inventory criteria. 

Other activities listed would not affect the inventory criteria for the identified potential wilderness areas. 

Reasonably foreseeable activities

Reasonably foreseeable future activities include: firewood cutting, livestock grazing, use and maintenance 

of forest roads, fire suppression, summer and fall recreation including hunting, hiking and dispersed 

camping, and noxious weed assessment and control. Other activities listed would not affect the inventory 

criteria for the identified PWA.

Summary of cumulative effects – Alternative 1

Natural conditions and undeveloped character of the PWA would be the same as the existing conditions. 

The No Action Alternative along with the projects and activities listed above would have no cumulative 

effects to the inventory criteria for the identified PWA. There are no irreversible or irretrievable 

commitments related to PWA from this alternative.

Summary of cumulative effects – Alternatives 2, 3, and 4

Proposed harvest and temporary road building activities described in Chapter 2 of this EIS would have no 

cumulative effects causing portions of identified potential wilderness areas to no longer meet potential 

wilderness inventory criteria. There would be no irreversible/irretrievable loss of potential wilderness 

suitability for any potential wilderness areas under alternatives 2, 3, or 4. Areas meeting potential 

wilderness inventory criteria would qualify for placement on the potential wilderness inventory, and 

therefore could be evaluated for wilderness suitability and possible recommendation to Congress for 

wilderness study or as a potential addition to the National Wilderness Preservation System during the 

ongoing Blue Mt Forest Plan Revision process.
Chapter 3 Snow Basin Vegetation Management Project FEIS

384

SHORT-TERM USES AND LONG-TERM PRODUCTIVITY

1 NEPA requires consideration of “the relationship between short-term uses of man’s environment and 

the maintenance and enhancement of long-term productivity” (40 CFR 1502.16). As declared by 

Congress, this includes using all practicable means and measures, including financial and technical 

assistance, in a manner calculated to foster and promote the general welfare, to create and maintain 

conditions under which man and nature can exist in productive harmony, and fulfill the social, 

economic, and other requirements of present and future generations of Americans (NEPA Section 

101).

There would be unavoidable, minor short-term adverse use effects to air quality, soils, watershed, range, 

fisheries, wildlife, and recreation/visuals from all action alternatives. There would be no adverse effects 

on long-term productivity, as all forested stands would be maintained with the purpose of better 

ecological conditions for the long-term. 

UNAVOIDABLE ADVERSE EFFECTS

There would be unavoidable short-term minor adverse effects to air quality, visuals, soils, watershed, 

fisheries and wildlife resources from all action alternatives. There would also be short-term adverse 

effects to recreation use and livestock grazing use of the project area, due to safety closures for project 

timber harvest and log haul. These effects would be limited in time and scale each year due to the 

implementation of the project activities on portions of the area each year. Effects are expected for 

approximately five years for the timber harvest actions and approximately 10 years for the prescribed fire 

activities. 

IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES

2 Irreversible commitments of resources are those that cannot be regained, such as the extinction of a 

species or the removal of mined ore. Irretrievable commitments are those that are lost for a period of 

time such as the temporary loss of timber productivity in forested areas that are salvaged after a large 

wildfire. 

3 There would be no irreversible commitment of resources from the action alternatives. The forested 

stands in the project would be maintained with a diverse mix of structural stages and would be viable 

and sustainable forests for the long-term. Human uses for grazing, logging, and recreation would 

continue. Wildlife and fisheries habitat would be maintained and would be viable and sustainable for 

the long-term.

4 There would be some short-term irretrievable loss of opportunities for grazing, recreation and other 

human uses during the timber harvest and prescribed fire actions that require safety closures. This 

would occur in parts of the project area each year, as only portions of the project area would have 

active timber harvest and prescribed burning each year.

OTHER REQUIRED DISCLOSURES

5 NEPA at 40 CFR 1502.25(a) directs “to the fullest extent possible, agencies shall prepare draft 

environmental impact statements concurrently and integrated with ...other environmental review 

laws and executive orders.” The following sections disclose those laws and executive orders.
Chapter 3 Snow Basin Vegetation Management Project FEIS

385

Air Quality

This proposal would have some short-term impacts on air quality levels for smoke; however National 

Ambient Air Quality Standards (NAAQS) would not be exceeded by any action alternatives. Air Quality 

impacts are addressed in Chapter 3, Fuels/Fire Management section.

American Indian Rights

This proposal would not conflict with any inherent rights or treaty provisions of any Tribal group.

American Indian Religious Freedom Act 

This proposal would not conflict with any religious freedom rights of any Tribal group.

National Historic Preservation Act

The Wallowa Whitman National Forest zone archaeologist has determined that Snow Basin Vegetation 

Management Project is considered an “undertaking” pursuant to the definition provided in section 301(7) 

of the National Historic Preservation Act. This undertaking will have a No Historic Properties Affected 

determination pursuant to 36 CFR 800.4, Stipulation III (B) 2 of the Programmatic Agreement, 

undertaking meets the criteria in the PA for a Historic Properties Avoided determination. See State 

Historic Preservation Office (SHPO) concurrence dated Aug. 31, 2010 in project files.

Endangered Species Act and Regional Forester’s Sensitive Species

The Endangered Species Act requires protection of all species listed as “threatened” or “endangered” by 

federal regulating agencies (Fish and Wildlife Service and National Marine Fisheries Service). Biological 

Evaluations/Biological Assessments for Endangered, Threatened, and Sensitive plant, wildlife, and fish 

species have been completed. Determinations were made that none of the proposed projects would 

adversely affect, contribute to a trend toward Federal listing, nor cause a loss of viability to the listed 

plant and animal populations or species. Details regarding the actual species found within the Snow Basin 

analysis area and the potential effects of proposed activities on those species and their habitat are 

contained under the Wildlife, Watershed Aquatics (including Fisheries), Threatened, Endangered and 

Sensitive Plants sections. 

Congressionally Designated Areas

• Wilderness: There are no lands designated in the project area as wilderness; therefore, there would 

be no impacts on Wilderness.

• Wilderness Study Areas: There are no lands designated in the project area as Wilderness Study 

Areas (WSA) or recommended for wilderness classification; therefore, there would be no impacts 

on any WSA.

• National Recreation Areas: There are no lands designated in the project area as National 

Recreational Areas; therefore, there would be no impacts on any National Recreational Area.

Energy Requirements and Conservation Potential of Alternatives

Some form of energy would be necessary for proposed projects requiring use of mechanized equipment:

Non-commercial thinning would involve small machines, while projects such as road repair could require 

heavy machinery for a small amount of time. All action alternatives would result in minor energy 

requirements. 
Chapter 3 Snow Basin Vegetation Management Project FEIS

386

Environmental Justice in Minority Populations and Low-Income Populations

Executive Order 12898 (Feb. 11, 1994) requires all federal agencies to make environmental justice part of 

each agencies mission, by identifying and addressing, as appropriate, disproportionately high, and 

negative human health or environmental effects on minority populations or low-income populations. The 

alternatives were assessed to determine whether they would disproportionately impact minority or lowincome populations, in accordance with Executive Order 12898.

Logging, mill production, and reforestation under all action alternatives are expected to help sustain 

employment and income opportunities within Baker County, including those of minority and low-income 

groups. Alternative 2 provides slightly greater potential for sustaining opportunities than the other action 

alternatives. No minority or low-income populations would be adversely impacted by implementation of 

any of the alternatives.

Floodplains (Executive Order 11988)

The project area and adjacent areas do not contain floodplains as defined in EO 11988.

National Landmarks

There are no National Landmarks in the project area. Therefore, no impacts would occur for any National 

Landmark. 

Municipal Watersheds

There are no municipal watersheds affected by the project; therefore, no impacts would occur on any 

municipal watersheds. 

Parklands

There are no lands within the proposed project area that would be characterized as parklands; therefore, 

there would be no impacts on any parklands.

Prime Farmlands, Rangelands, and Forestlands

• Prime Farmland: The project area is not located in or adjacent to prime farmlands; therefore, there 

would be no impacts to Prime Farmlands.

• Prime Rangeland: The project does not contain prime rangeland because of soils and climate, and 

none of the proposed activities in the project would convert rangelands to other uses. Therefore, 

there would be no impacts on Prime Rangelands.

• Prime Forestland: The project would not convert forestlands to other uses. All lands designated as

forested would be retained and managed as forested; therefore, there would be no negative 

impacts on Prime Forestland.

Research Natural Areas (RNA)

There are no research natural areas in the project area and therefore the project would not affect any 

research natural areas.
Chapter 3 Snow Basin Vegetation Management Project FEIS

387

Social Groups

The project would have no impacts on any social groups, including minorities, Native American Indians, 

women, or the civil liberties of any American citizen.

Wetlands (Executive Order 11990)

There are no wetlands meeting this definition and therefore the project would not impact any wetlands.

Wild and Scenic Rivers

The Eagle Creek Wild and Scenic River (WSR) was designated under the national wild and scenic river 

system in 1988 with the Omnibus Oregon Wild and Scenic Rivers Act (Public Law 100-557 and amended 

the Wild and Scenic River Act P.L 90-542). The river is currently managed under direction from the 1994 

Eagle Creek Wild and Scenic River Management Plan (WWNF, 1993). The River Plan provides direction 

for the designated river corridor, including the 3,422 acres of river corridor and 9.5 miles of river in the 

Snow Basin project area. This WSR is to be managed for the identified outstanding remarkable values 

(ORV) which include: recreation, scenery, geology/paleontology, fisheries and historic cultural resources. 

Recreation Opportunity Spectrum (ROS) classes in the project are: Scenic river sections – Semi-primitive 

Motorized (2,182 acres), and the Recreation river – Roaded Natural ROS (1,240 acres). The 3,423 WSR 

corridor acres within Snow Basin is about 12 percent of the project area. See the Wild and Scenic River 

section for further analysis information. A Wild and Scenic River Act Section 7, “Evaluation of Proposed 

Water Resource Projects” was completed for the activities proposed in the Eagle Creek Wild and Scenic 

River Corridor. Details regarding this evaluation are in the project record. 
Chapter 4 Snow Basin Vegetation Management Project FEIS

388

CHAPTER 4 – CONSULTATION AND COORDINATION

Preparers and Contributors

Interdisciplinary Team Members and Wallowa-Whitman Staff

NAME Role Location

WWNF- Staff

Ken Anderson / Jen Fitzpatrick / 

Jeff Tomac District Rangers - Line Officers Whitman RD, Baker City OR

Teena Ballard Range Staff/ Range Analysis Whitman RD, Baker City OR

Jim Gilsdorf Project Manager-Forest Planner Whitman RD, Baker City OR

Dea Nelson Forest Planner / Environmental 

Coordinator

Supervisors Office, Baker City 

OR

WWNF-IDT Members

Eric Harvey Archeologist Whitman RD, Baker City OR

Gayle Hammond Zone Engineer Whitman RD, Baker City OR

John Jesenko Logging Systems, Timber 

Forester, Economics Whitman RD, Baker City OR

Donna Mattson Landscape Architect / Recreation Whitman RD, Baker City OR

Kat Naughton Fuels Specialist to Jan 2010 Whitman RD, Baker City OR

Keith Dunn / Noel Livingston Fuels Specialists from Jan 2010 Whitman RD, Baker City, OR

Joe Sciarrino Silviculture Whitman RD, Pine Field Office, 

Halfway OR

Lynne Smith Botanist, Noxious Weeds Whitman RD, Pine Field Office, 

Halfway OR

Mike Hall Recreation Whitman RD, Baker City, OR

Margaret Durner / Melanie Sutton GIS Specialist Whitman RD, Pine Field Office, 

Halfway OR

FS TEAMS IDT Members

Greg D. Lind IDT Leader/ writer-editor TEAMS office in Boise ID. 

Doug Middlebrook Wildlife biologist TEAMS office in Powers, OR

Mike McNamara Soils/Hydrologist TEAMS office in Bellingham, 

WA 

Cindy Cleveland Fisheries Biologist TEAMS office in Santa 

Barbara, CA

The Forest Service mailed scoping letters to the following individuals, Federal, State, and local agencies, 

Tribal governments, and other organizations and individuals during the development of this FEIS. The 

list below is summarized from the project scoping mail lists with the specific mailing addresses removed. 

The complete project mail lists are in the project files. The list of agencies, tribes, organizations and 

individuals that provided comments during scoping is noted in FEIS Chapter 1. 

Federal, State, and Local Agencies

Bureau of Land Management

Baker City, OR 97814

Oregon Dept Environmental Quality

Portland, OR 97204

Oregon Dept of Fish and Wildlife

Baker City, OR 97814

Powder Basin Watershed Council

Baker City, OR 97814

Oregon Dept. of Revenue

La Grande, OR 97850

Oregon Dept of Fish and Wildlife

La Grande, OR 97850
Chapter 4 Snow Basin Vegetation Management Project FEIS

389

Baker County Extension Service

Baker City, OR 97814

Baker County Commissioners

Baker City, OR 97814

Baker County Empowerment Cmte

Baker City, OR 97814

Director of Public Works

Baker City, OR 97814

Baker City Mayor

Baker City, OR 97814

US Environmental Protection Agency

NEPA Review Unit

Region 10, Seattle, WA 98101

Tribes

Columbia River Intertribal Fish 

Commission, Portland, OR 97232

Nez Perce (NIMIIPUU) Tribe

Lapwai, ID 83540

Dept of Natural Resources

Nez Perce (NIMIIPUU) Tribe

Lapwai, ID 83540

Burns Paiute Tribes

Burns, OR 97720

Natural Resources and Habitat Bio

Confederated Tribes of Warm 

Springs

Warm Springs, OR 97761

Tribal Council

Confederated Tribes of Warm 

Springs

Warm Springs, OR 97761

Center for Tribal Water Advocacy

P.O. Box 1637

Pendleton, Oregon 97801

Confederated Tribes of the Umatilla 

Indian Reservation

Pendleton, OR 97801

Confederated Tribes of the Umatilla 

Indian Reservation

DRN/Environmental Planning

Pendleton, OR 97801

Adjacent Landowners

Tamara and Scott Green

Baker City, OR 97814

Ellingson Lumber Co

Baker City, OR 97814

Galen L Chandler, Trustee

Albany, OR 97321

Erica Rademaker

Ashland, OR 97520

Rennee J Hammons

Richland, OR 97870

Eileen Taylor

Gresham, OR 97030

Ralph and Alice Ward

Baker City, OR 97814

Harold and Kirsten Badger

Baker City, OR 97814

Andrew D Dennis

Haines, OR 97833

Timothy and Patricia Brewer

Boise, ID 83704-3319

Hideaway Hills

Baker City, OR 97814

Patricia Hanley

Baker City, OR 97814

Phillips Ranch

Baker City, OR 97814

Randell Guyer

Baker City, OR 97814

H.F. Fitch

Portland, OR 97239

Crney and Deborah Lansford

Baker City, OR 97814

Janis Yutzy

Beaverton, OR 97007-9021

Fayne and Jessie Ritch

Baker City, OR 97814

Emily Ciesielski

Salem, OR 97302

Donald D Cole

Eugene, OR 97408

Barry Huff

San Jose, CA 95151

Elma Williams Ziegler

Richland, OR 97870

Collins Pine Co

Portland, OR 97201

Michael Becker

LaGrande, OR 97850

George Gover

Halfway, OR 97834

Charles Neal Lincoln

Oxbow, OR 97840

Anthony and Jan Bonn

Richland, OR 97870

Jeffrey and Cindy Smith

Corbett, OR 97109

Andrew and Augusta Laidlaw

McCall, ID 83638

Young and Curry Mitchell

Baker City, OR 97814

Steven Shold

Richland, OR 97870

Larry and Roxanne McQuain

Silverton, OR 97381

Robert Estill 

Florence, OR 97439

Louis and Susan Gates

Corvallis, OR 97330

Lindsay Brakel

Haines, OR 97833

Joseph and Teresa Musgrove

Baker City, OR 97814
Chapter 4 Snow Basin Vegetation Management Project FEIS

390

Michael K Mahaffey, etal

Baker City, OR 97814

Crystal and Leland Sadlowsky

Burlington, WA 98233

Donald and Marianne Martin

Prineville, OR 97754

Mary L Weber

Salem, OR 97302-9406

Harold and Joan Weaver

Baker City, OR 97814

Sarah and Samantha Scharf

San Francisco, CA 94131

Eric and Barbara Anderson

Baker City, OR 97814

Leroy and Patricia Smith

Corbett, OR 97019

John and Dorothy Randall

Richland, OR 97870

Young and Curry Mitchell

Baker City, OR 97814

Randal K Stuchlik

Baker City, OR 97814

Madge Stephenson Grant

Richland, Or 97870

Rocky Randall

Richland, OR 97870

Randall Proctor Trust

Sandy, OR 97055

Betty Ann Erbesl

Central Point, OR 97502

Joseph and Janet Carucci

Whitesboro, NY 13492

Jory and Amanda Hearne

Baker City, OR 97814

Perry and Michele Powell

Baker City, OR 97814

John and Joan Barry

LaGrande, OR 97850

Thomas and Glenn Griffin

Spirit Lake, ID 83869

Gary and Sharon Chamberlin

Richland, OR 97870

Thomas K Smith

Richland, OR 97870

Gar Rovang

Richland, OR 97870

Keith A Martin

Baker City, OR 97814

Richard W Bickford

Dufur, OR 97021

George Christoffersen

Homedale, ID 83628

Clyde and Gretchen Makinson

Richland, WA 99354

Powell C Groner III

Lake Oswego, OR 97035

Jeff and Carrie Swanson

Baker City, OR 97814

Eagle Telephone System, Inc

Richland, OR 97870

Keith and Edra Dangerfield

Baker City, OR 97814

Others on Forest NEPA General Mailing List

Oregon Natural Resources Council

Bend, OR 97701

NW Forestry Assoc.

Bend, OR 97701-2957

Joseph Timber Co., LLC

Joseph, OR 97846

Oregonians for Food and Shelter

Salem, OR 97302-4668

NW Timber Workers

Wallowa, OR 97885

Juniper Sierra Group

La Grande, OR 97850

Pacific Legal Foundation

Sacramento, CA 95834

Dave Mader

Halfway, OR 97834

Power Engineers

Hailey, ID 83333

The Pacific Rivers Council

Portland, OR 97214-4201

Dick Artley

Grangeville, ID 83530

The Lands Council

Spokane, WA 99201

Peacock Lumber Co.

Imbler, OR 97841

Natural Resources Defense Council

San Francisco, CA 94104

Don Martin

Halfway, OR 97834

Prairie Wood Products

Prairie City, OR 97869

Oregon Natural Desert Association

Portland, OR 97205-2838

North Powder Lumber Co.

North Powder, OR 97867

David T. Rainey

Summerville, OR 97876

Oregon Natural Resources Council

Eugene, OR 97440-3848

NW Coalition for Alts. to Pesticides

Eugene, OR 97440-1393

Elwayne Henderson

Wallowa, OR 97885

Ellingson Lumber Co.

Baker City, OR 97814

David Evans and Associates

Bellevue, WA 98005

Henderson Logging, Inc.

Wallowa, OR 97885

Bob Forte

Halfway, OR 97834

OR. Guides and Packers Reg. #5

Richland, OR 97870

Mike and Donna Higgins

Halfway, OR 97834

John Garrigus

Oxbow, OR 97840

Barry Del Curto

Halfway, OR 97834
Chapter 4 Snow Basin Vegetation Management Project FEIS

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Ed and Carmelita Holland

Richland, OR 97870

Gary N. Smith Trucking, Inc.

Baker City, OR 97814

DR Johnson Lumber Co.

Riddle, OR 97469

Bruce Honeyman

Halfway, OR 97834

Stan Gulick

Halfway, OR 97834

DR Johnson Lumber Co.

Prairie City, OR 97869

Loren W. Hughes

La Grande, OR 97850

Guy Bennett Lumber Co.

Clarkston, WA 99403

Eastern Oregon Mining Association

Baker City, OR 97814

Idaho Sporting Congress

Boise, ID 83701

Guy Bennett Lumber Co.

Clarkston, WA 99403

Eastern Oregon Sportsmen’s Assoc.

Baker City, OR 97814

Bill and Charlene Immoos

Richland, OR 97870

Richard Harris

Baker City, OR 97814

Baker Record-Courier

Baker City, OR 97814

J&J Logging

Elgin, OR 97827

Hells Canyon Journal

Halfway, OR 97834

The Ecology Center

Missoula, MT 59802-3626

Hells Canyon Preservation Council

La Grande, OR 97850

Jim Reed

Halfway, OR 97834

Elton Saunders

Baker City, OR 97814

Alliance for the Wild Rockies

Missoula, MT 59807

Baker City Herald

Baker City, OR 97814

Boise Cascade Corporation

Joseph, OR 97846

Alpine Timber Corporation

Baker City, OR 97814

Wayne Chetwood

Halfway, OR 97834

Steve Brooks

Richland, OR 97870

Ken Anderson

Baker City, OR 97814

Hells Canyon Adventure II, Inc.

Boise, ID 83706

UNC Mining and Milling

Gallup, NM 87305

David Andruss

Halfway, OR 97834

Phegley Logging

Baker City, OR 97814

Tony Chetwood

Halfway, OR 97834

Robert A. Clark

La Grande, OR 97850

Blue Mtn. Environmental Council

La Grande, OR 97850

Columbia Helicopters

Portland, OR 97208

Mike Beidler

Halfway, OR 97834

Blue Mountain Native Forest Alliance

Baker City, OR 97814

Mike and Terri Hutton

Baker City, OR 97814

Vernon Bennett

Enterprise, Or 97828

Blue Mtn. Biodiversity Project

Fossil, OR 97830

Larry Cribbs

La Grande, OR 97850

Western Land Exchange Project

Seattle, WA 98145

Boise Building Solutions

La Grande, OR 97850

Oregon Sportsmen, Halfway Chapter

Halfway, OR 97834

Gary Timm

Baker City, OR 97814

Angie Johnson

La Grande, OR 97850

Meb Dailey

Baker city, OR 97814

Permittees, Eagle Valley and Goose 

Creek Allotments

Richland, OR 87870

Dwight Saunders

Richland, OR 97870

DEIS Respondents Contact List

Charles Burley

Bend, OR 97709

Robert Parker

Baker City, OR 9781

Robert Whitnah

Richland, OR 97870

Ken Bothems

Richland, OR 97870

Robert Wheeler

Baker City, OR 9781

Jeremy Simpson

Baker City, OR 9781

Charles Hill

Baker City, OR 9781

Janece Kennedy

Richland, OR 97870

Jacob J

Richland, OR 97870

Gene & Elva Chetwood

Richland, OR 97870

Ken Gard

Richland, OR 97870

Tony Sheld & Shirley Cochell

Richland, OR 97870
Chapter 4 Snow Basin Vegetation Management Project FEIS

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John E. Johnston

Richland, OR 97870

Ray Spencer

Halfway, OR 97834

Mary Edmondson

Richland, OR 97870

Roseanne Riggs

Richland, OR 97870

Marvin T. & Beverly A. Lee

Richland, OR 97870

Tom Thomason

Richland, OR 97870

Bud Terry

Richland, OR 97870

Jana Terry

Richland, OR 97870

Ken & Pearl E. DaMars

Richland, OR 97870

Lar Adeninker

Richland, OR 97870

Steve Passlor

Richland, OR 97870

Kurt Colnet

Richland, OR 97870

Bert Rogert

Richland, OR 97870

Terry A. Taiter

Richland, OR 97870

Evelyn Fisher

Richland, OR 97870

Mary Chanta

Richland, OR 97870

Luke Hearne

Richland, OR 97870

Tom Omann

Halfway, OR 97834

Rick Bryan

Halfway, OR 97834

Laura Bly

Halfway, OR 97834

Jory Hearne

Halfway, OR 97834

Tamera J. Tyler

Halfway, OR 97834

Donald R. Storm

Halfway, OR 97834

Joseph E. Young

Halfway, OR 97834

Stan M. Kaesennyn

Halfway, OR 97834

Wayne C. & Lena E. Chetwood

Halfway, OR 97834

Derrick S. Jerssay

Halfway, OR 97834

Frank Holbriten

Halfway, OR 97834

Mike Lattim

Halfway, OR 97834

Jennifer Davis

Halfway, OR 97834

Marcia Lincoln

Richland, OR 97870

Everett Devine

Richland, OR 97870

Ralph Devine

Richland, OR 97870

Connie Forsea

Richland, OR 97870

Sharry Dawning

Halfway, OR 97834

Cindy Thayer

Halfway, OR 97834

Amy Koskil

Oxbow, OR 97840

Pattie Barker

Portland, OR 97230

Linda Miller

Halfway, OR 97834

Rose Darting

Halfway, OR 97834

Mack & Angela Chetwood

Halfway, OR 97834

Gail Marteney

Halfway, OR 97834

Jody Leasey

Halfway, OR 97834

Brian D. Peniwick

New Bridge, OR

Alan Steele

Halfway, OR 97834

Jake Remey

Halfway, OR 97834

Dal Thomas

Halfway, OR 97834

Jim Chetwood

Halfway, OR 97834

Mitchell H. Weis

Halfway, OR 97834

Chay Rarm

Halfway, OR 97834

Todd Robertt

Halfway, OR 97834

Richard Harris

Baker City, OR 9781

David Mildrexle

La Grande, OR 97850r

Carmelita Holland

Richland, OR 97870

Forest Schroeder

Baker City, OR 9781

Bill Whitaker

La Grande, OR 97850

SOAR

Baker City, OR 9781

Dave Wiley

Sublimity, OR 97385

Arvid Anderson

Baker City, OR 9781

Bob Bastian

Klamath Falls, OR 97601

OR Small Woods Association

Salem, OR 97814

Cass Vanderwiele

Baker City, OR 97814

Kerns 

Haines, OR 97883

Irene Jerome 

John Day, OR 97845

Doug Heiken 

Eugene, OR 97440

Lane Parry

Baker City, OR 97814

Don Glerup

Baker City, OR 97814

Robert Black

Baker City, OR 97814

Eagle Valley Grange #656

Richland, OR 97870
Chapter 4 Snow Basin Vegetation Management Project FEIS

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Elizabeth Harmon

Richland, OR 97870

Brook A. Cruz

Richland, OR 97870

Irene M. Mead

Richland, OR 97870

Dave & D'Anna D. Yakel

Richland, OR 97870

Margaret Gristy

Richland, OR 97870

Kim Wright

Richland, OR 97870

Lee Chaffer

Richland, OR 97870

Gary Holland

Richland, OR 97870

Tim Dalt

Baker City, OR 97814

Brandon & Teresa Chaffee

Richland, OR 97870

James T. & Amanda Infor

Baker City, OR 97814

Herbert L. & Barbara A. Jones

Newport, OR 97365

Tonin Paul Dahan

Richland, OR 97870

Kyle Ransom

Richland, OR 97870

Barny Sumpter

Richland, OR 97870

J.J. Sutherlin

Halfway, OR 97834

John Randall

Richland, OR 97870

Brian Marshall

Halfway, OR 97834

Shawn Landers

Halfway, OR 97834

Dan Elkey

Richland, OR 97870

Larry Flescher

Halfway, OR 97834

Brad Plakil 

Adams, OR 97810

Alanas Lombank 

Adams, OR 97810

Eric Carlos 

Pendleton, OR 97801

Al Johnson 

Vancouver, WA 98685

Robert L. Peickert 

The Dalles, OR 97058

Jeannette Peickert 

The Dalles, OR 97058

Darl S. Whies 

Forest Grove, OR 97116

Baynl & Liz L. Landers

Richland, OR 97870

Larry & Shawn Speelman

Richland, OR 97870

Dwight & Debbie Saunders

Richland, OR 97870

Patricia L. Stichley

Richland, OR 97870

Robert Starl

Richland, OR 97870

Hill

Richland, OR 97870

Donnalee Moorcraft

Richland, OR 97870

Mary Maerien

Richland, OR 97870

Gar Rovanq

Richland, OR 97870

Alvin L.Simons 

Halfway, OR 97834

Brian R. Holland

Richland, OR 97870

Harold Dietzen

Richland, OR 97870

David Paulson

Richland, OR 97870

Travis Cannon

Richland, OR 97870

Angie Tucker

Richland, OR 97870

Brandon Langtz

Richland, OR 97870

Angela Hyatt

Richland, OR 97870

Slany Beiutis 

Clatskanie, OR 97016

Dray Hammack Clatskanie OR 

97016

Lyn E. Akinam

Richland, OR 97870

Tom Cast

Richland, OR 97870

Ryser Lrisn

Richland, OR 97870

Nancy Nelson

Richland, OR 97870

Tom Sherwood

Richland, OR 97870

Alexandra Fry

Baker City, OR 97814

Betty L. Cook 

Halfway, OR 97834

Gary Haran 

Halfway OR 97870

John Thomas

Richland, OR 97870

Lain Diren

Halfway, OR 97834

Alenepep Walfer 

Bend, OR 97702

Mark Cliff

Halfway OR 97870

Dick Artley 

Grangeville, ID 85530

Barbara Tomleson 

Portland, OR 97219

Lydia Garvey 

Clinton, OK 73601

Nighthawk Ranch 

Mitchell, OR 97750

John Fullerton

La Grande, OR 97850

Welms 

Lagrande, OR 97850

Associated Oregon Loggers Inc

Salem, OR 97309

Lyle Defrees

Baker City, OR 97814

Ray Badger

Baker City, OR 97814

Michael O. Ragsdale

Baker City, OR 97814
Chapter 4 Snow Basin Vegetation Management Project FEIS

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Milton Prowell

Baker City, OR 97814

Mike Higgens

Halfway OR 97870

Dan Warnock

Baker City, OR 97814

Lane Parry

Baker City, OR 97814

Randell C. Guyer

Baker City, OR 97814

Jon & Julie Sallquist

Baker City, OR 97814

Larry McCalden

Baker City, OR 97814

Walter Wood

Baker City, OR 97814

Valerie A. Omann

Baker City, OR 97814

BCPWA

Baker City, OR 97814

Blue Mt. Forest Coop.

Baker City, OR 97814

Gene & Cindy Cayser 

Richland, OR

Shyle Digs

Baker City, OR 97814

Chris Cipis

Baker City, OR 97814

Pete Sandrock 

Portland, OR 97202

Vernan & Alice Knapp

Baker City, OR 97814

Mac Kerns 

Haines, OR 97833

Glenn L. & Cindy Womack-Steele

Halfway, OR 97834

John Saylor

Halfway, OR 97834

Distribution of the Environmental Impact Statement

This Final environmental impact statement (FEIS) has been distributed to individuals who specifically 

requested a copy of the document among those who submitted comments in response to scoping. Calls 

were made and a postcard was sent to inquire if these individuals wanted a copy mailed to them. Copies 

of the FEIS have also been provided to baker County libraries to be made available for public viewing. In 

addition, copies have been sent to federal agencies, federally recognized tribes, state and local 

governments and organizations representing a wide range of views. A complete mailing list is in the 

project files.
Chapter 5 Snow Basin Vegetation Management Project FEIS

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CHAPTER 5 – LISTS 

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snag replacement guidelines. 

Sciarrino, J. Forester, Silviculture. US Forest Service, Halfway, OR. [Personal communication] 2010.

Scott, J.A. 1986. The Butterflies of North America. Stanford University Press, Stanford, California. 

583p.

Shea, K.R. and D.K. Lewis. 1971. Occurrence of dwarf mistletoe in sanitized ponderosa pine in southcentral Oregon. Northwest Science, 45:94-99.

Slauson, K. M., W. J. Zielinski, and J. P. Hayes. 2007. Habitat selection by American martens in coastal 

California. Journal of Wildlife Management 71:458–468.

Stalmaster, M.V. and J.R. Newman. 1979. Perch-site preferences of wintering bald eagles in 

northwestern Washington. Journal of Wildlife Management 43(1): 221-224.

Stephens, S.L. and J.L. Moghaddas. 2005. Fuel treatment effects on snags and coarse woody debris in a 

Sierra Nevada mixed conifer forest. Forest Ecology and Management 214:53-64.

Stevens, V. 1997. The ecological role of coarse woody debris: an overview of the ecological importance 

of CWD in B.C. forests. Res. B.C. Min. For., Victoria. Working Paper 30/1997. 26 pp.

The Nature Conservancy, USDA Forest Service, and Department of the Interior, LANDFIRE Rapid 

Assessment Modeling Manual, Version 2.1. January 2005. Boulder, CO. 72pp.

Thomas, J. W., ed. 1979. Wildlife habitats in managed forests: The Blue Mountains of Oregon and 

Washington. Agricultural Handbook No. 553. USDA Forest Service. Washington D.C. 512p.

Thomas, J.W., D.A. Leckenby, M. Henjum, R.J. Pederson, and L.D. Bryant. 1988. Habitat-Effectiveness 

Index for Elk on Blue Mountain Winter Range. USDA Forest Service, Pacific Northwest 

Research Station, General Technical Report PNW-GTR-218.
Chapter 5 Snow Basin Vegetation Management Project FEIS

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USDA Forest Service. 1990. Land and Resource Management Plan, Wallowa-Whitman National Forest. 

USDA, Forest Service, Pacific Northwest Region (R6), Wallowa-Whitman National Forest.

USDA Forest Service. 1993. Eagle creek wild and scenic river management plan. Wallowa-Whitman 

National Forest. 33 p.

USDA Forest Service. 1995. Regional Forester’s Forest Plan Amendment #2. 

PACFISH/INFISH/SCREENS Information Guide. USDA, Forest Service, Pacific Northwest 

Region (6), Wallowa-Whitman National Forest. 

USDA Forest Service. 2009. Wallowa-Whitman National Forest Travel Management Plant. Draft 

Environmental Impact Statement. Baker City, Oregon. 

USDA Forest Service. 2010. Fire Effects Information System. Accessed 01/2010 at: 

http://www.fs.fed.us/database/feis/animals/bird/fape/all.html. 

UDSI Fish and Wildlife Service. 2011. Federally listed, proposed, candidate species and species of 

concern under the jurisdiction of the Fish and Wildlife Service which may occur within Baker 

County, Oregon. Last updated October 8, 2011. Accessed online October 12, 2011 at 

http://www.fws.gov/oregonfwo/Species/Lists/ 

Wales, B.C. 2011a. American marten (Martes americana) Model Application and Assessment of Results. 

Wallowa-Whitman National Forest.

Wales, B.C. 2011b. Pileated Woodpecker (Dyrocopus pileatus) Model Application and Assessment of 

Results. Wallowa-Whitman National Forest.

Wales, B.C. 2011c. Northern goshawk (Accipiter gentilis) Model Application and Assessment of 

Results. Wallowa-Whitman National Forest.

WHCWG. 2011. Washington Wildlife Habitat Connectivity Working Group. Accessed online 

September 2011 at: http://waconnected.org/statewide-analysis/.

Wilson, B.L., R.E. Brainerd, D. Lytjen, B. Newhouse, N. Otting. 2008. Field Guide to the Sedges of the 

Pacific Northwest. Oregon State University Press, Corvallis. 

Wisdom, M.J. Research Wildlife Biologist, US Forest Service. PNW Lab. La Grande, OR. [Personal 

communication]. 2008.

Wisdom, M.J., R.S. Holthausen, B.C. Wales, C.D. Hargis, V.A. Saab, D.C. Lee, W.J. Hann, T.D. Rich, 

M.M. Rowland, W.J. Murphy, and M.R. Eames. 2000. Source habitats for terrestrial vertebrates 

of focus in the interior Columbia Basin: Broad-scale trends and management implications, Vol. 2 

– Group level results. Gen. Tech. Rep. Threatened and Endangered Species, Sensitive Species 

and Management Indicator Species and the level of analysis required. PNW-GTR-485.

Sensitive Plants

Arditti, J. 1967. Factors affecting the germination of orchids. Bot. Rev. 33, pp. 1-97.

Carex Working Group. 2008. Carex cordillerana ecology and range, October 29, 2008. 

http://www.carexworkinggroup.com/pages/october2008.html, downloaded January 18, 2012.

Doherty, J. W. 1997. The Genus Cypripedium: Part 1. North American Native Orchid Journal 3:5-116.

Nelson, J.R. 1985. Rare plant surveys: techniques for impact assessment. Natural Areas Journal, 5(3): 

18-30.

USDA Forest Service. 1995. Streamlining Biological Evaluations and Conclusions for Determining 

Effects to Listed, Proposed and Sensitive Species Streamlining Biological Evaluations and 

Conclusions for Determining Effects to Listed, Proposed and Sensitive Species. Regional 

Forester’s (Hal Salwasser, R-1, Dale Bosworth, R-4, John Lowe, R-6) letter to Forest Supervisor’s 

(File Code: 2670/1950), August 17, 1995.

USDA Forest Service. 2011. Kent P. Connaughton, Regional Forester, Letter to Forest Supervisors, 

Update of the Regional Forester's Special Status Species List, December 9, 2011, Pacific 

Northwest Region, Portland, Oregon.

USDI Fish and Wildlife Service. 2002. Section 7 Guidelines - Snake River Basin Office, Thelypodium 

howelli var. spectabilis, Updated, August 2002.

Wells TCE. 1981 Population ecology of terrestrial orchids. In: Synge, H ed(s). The biological aspects of 

rare plant conservation. Chichester etc., Wiley. pp. 281-295. En Proceedings of International 

Conference, King's College, Cambridge, 14 - 19 July 1980. Wilson, B., R. Brainerd, D. Lytjen, B. 
Chapter 5 Snow Basin Vegetation Management Project FEIS

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Newhouse, and N. Otting. 2008. Field Guide to the Sedges of the Pacific Northwest. Oregon State 

University Press, Corvallis, 431 pp.

Invasive Species

Bradley, B.A., Oppenheimer, M., & Wilcove, D.S. 2009. Climate change and plant invasions: restoration 

opportunities ahead? Global Change Biology, 15, 1511-1521.

Chapin, F.S., Zavaleta, E.S., Eviner, V.T., Naylor, R.L., Vitousek, P.M., Reynolds, H.L., Hooper, D.U., 

Lavorel, S., Sala, O.E., Hobbie, S.E., Mack, M.C., & Diaz, S. Diaz. 2000. Consequences of 

changing biodiversity. Nature, 405, 234-242.

D’Antonio, C.M. 2000. Fire, plant invasions, and global changes. Pages 65-93 in H.A. Mooney and R.J. 

Hobbs, editors. Invasive species in a changing world. Island Press, Covelo, California, USA.

Hellman, J.J., Byers, J.E., Bierwagen, B.G., & Dukes, J.S. 2008. Five potential consequences of climate 

change for invasive species. Conservation Biology, 22(3), 534-543.

Hobbs, R.J. & Huenneke, L.F. 1992. Disturbance, diversity, and invasion: implications for conservation. 

Conservation Biology, 6(3), 324-337.

Lockwood J.L., Cassey, P., & Blackburn, T. 2005. The role of propagule pressure in explaining species 

invasions. Trends in Ecology and Evolution, 20(5), 223-228.

Mack, M.C. & D’Antonio, C.M. 1998. Impacts of biological invasions on disturbance regimes. Trends in 

Ecology and Evolution, 13(5), 95-198.

Merriam, K.E., Keeley, J.E., & Beyers, J.L. 2006. Fuel breaks affect nonnative species abundance in 

californian plant communities. Ecological Applications, 16(2), 515-527.

Potts, J.B. & Stephens, S.L. 2009. Invasive and native plant responses to shrubland fuel reduction: 

comparing prescribed fire, mastication, and treatment season. Biological Conservation, 142, 

1657-1664.

Sousa, W.P. 1984. The role of disturbance in natural communities. Annu. Rev. Ecol. Syst., 15, 353-391

Zouhar, Kristin; Smith, Jane Kapler; Sutherland, Steve; Brooks, Matthew L. 2008. Wildland fire in 

ecosystems: fire and nonnative invasive plants. Gen. Tech. Rep. RMRS-GTR-42-vol. 6. Ogden, 

UT: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. 355 p.

USDA Forest Service, 1990. Wallowa-Whitman National Forest Land and Resource Management 

Plan Record of Decision. USDA Forest Service, Pacific Northwest Region, Wallowa-Whitman 

National Forest, Baker City, OR. April 1990.

USDA Forest Service, 2005. Pacific Northwest Region Invasive Plant Program Record of Decision. 

USDA Forest Service, Pacific Northwest Region, Portland, OR. October 2005.

USDA Forest Service, 2010. Wallowa-Whitman National Forest Invasive Plants Treatment Project 

Record of Decision. USDA Forest Service, Pacific Northwest Region, Wallowa-Whitman 

National Forest, Baker City, Or. May 2010.

Vitousek, P.M., D’ Antonio, C.M., Loope, L.L., & Westbrooks, R. 1996. Biological invasions as global 

environmental change. American Scientist, 84, 468-478.

Rangeland

Andariese, S,W., and W.W. Covington. 1986. Changes in understory production for three prescribed 

burns of different ages in ponderosa pine. Forest Ecology and Management 14:193-203.

Bojorquez Tapia, L.A., P.F. Ffolliott, and D.P. Guertin. 1990. Herbage production-forest overstory 

relationships in two Arizona ponderosa pine forests. Journal of Range Management 43(1): 25-

28.

Johnson, C.G & S.A, Simon, 1987. Plant associations of the Wallowa-Snake province. USDA-Forest 

Service, Wallowa-Whitman National Forest, Baker City, Or.

Moore, M.M., C.A. Casey, J.D. Bakker, J.D. Springer, P.Z. Fule, W.W. Covington, and D.C. Laughlin. 

2006. Herbaceous vegetation responses (1992-2004) to restoration treatments in a ponderosa 

pine forest. Rangeland Ecology and Management 59(2):135-144.

Riegel, G.M., R.F. Miller, and W.C. Krueger. 1992. Competition for resources between understory 

vegetation and overstory Pinus ponderosa in Northeastern Oregon. Ecological Applications 

2(1):71-85.
Chapter 5 Snow Basin Vegetation Management Project FEIS

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USDA. 1990. Wallowa-Whitman Land and Resource Management Plan Record of Decision. USDAForest Service, Wallowa-Whitman National Forest, Baker City, Or.

Scenic Resources

Sciarrino, J. 2003. Fire Regime Condition Class.

USDA (1974). National Forest Landscape Management Volume 2, Chapter 2, The Visual Management 

System. Agricultural Handbook Number 462, USDA Forest Service.

USDA. 1995. Landscape Aesthetics, A Handbook for Scenery Management (Agriculture Handbook 

#701, Forest Service, 1995).

Recreation Resource

Farnum. J., Hall,T., Kruger.L.E. 2005. Sense of Place In Natural Resource Recreation and Tourism: An 

Evaluation and Assessment of Research Findings. PNW-GTR-660. 

http://www.fs.fed.us/pnw/pubs/pnw_gtr660.pdf

USDA Forest Service (USDA-FS). 1995. Landscape Aesthetics- A handbook for Scenery Management. 

Agricultural Handbook No. 701 

http://www.fs.fed.us/cdt/carrying_capacity/landscape_aesthetics_handbook_701_no_append.pdf

Wallowa-Whitman National Forest (WWNF). USDA Forest Service. 1993. Eagle Creek Wild and 

Scenic River Management Plan. 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5308705.pdf

Wallowa-Whitman National Forest (WWNF), USDA Forest Service. 1990. Wallowa-Whitman National 

Forest Land and Resource Management Plan.

Wild and Scenic River Resource

The same list of references cited in the Recreation section was used in this WSR section.

Heritage and Paleontological Resources

Blackburn, David H. Structural Analysis of an Exotic Terrane Wallowa Mountains, Northeastern 

Oregon. http://keckgeology.org/files/pdf/symvol/4th/Oregon/blackburn.pdf 4th Keck 

Symposium.

Elder, Don. May 2010. Potential Fossil Yield Classification (PFYC) Fore Washington, Oregon and 

California: Initial Determination Process Description. USDA Forest Service.

Orr, William N., Kurt T. Katsura. July 1985. Oregon’s Oldest Vertebrates [Icthyosauria (Reptilia)]. 

Oregon Geology vol. 47 number 7. pgs. 75-77.

Stanley, George D. Jr., McRoberts, Christopher A., Whalen, Michael T. 2008. Stratigraphy of the 

Triassic Martin Bridge Formation, Wallowa terrane: Stratigraphy and depositional setting. 

Geological Society of America Special Paper 442. pgs 227-250.

Social and Economics

U.S. Census Bureau, Census 2000

U.S. Census Bureau Quick Facts, 2008
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Acronyms

APE Area of Potential Effect (term used in heritage analysis)

ATP Area to Protect

ATV All-terrain Vehicle

AUM Animal Unit Month (a term used in grazing management)

BA Biological Assessment (document disclosing effects on FWS Listed Species)

BE Biological Evaluation (document disclosing impacts on FS Sensitive Species)

BLM Bureau of Land Management

BMP Best Management Practice

BpE Bio-physical Environment

BpS Bio-physical Setting

CAA Clean Air Act of 1955

CE Council on Environmental Quality

CFR Code of Federal Regulations

CVS Current Vegetation Survey

CWPP Community Wildfire Protection Plan (provided for in the Healthy Forests Restoration Act of 2003 

[HFRA])

CY Calendar year (January 1 to December 31 of same year)

DBH. Diameter (of a tree) at Breast Height (measurement at 4.5 feet from uphill base of a tree)

DecAID Decayed Wood Advisor Tool (model for wildlife snag analysis)

DEIS Draft Environmental Impact Statement

DF Douglas-fir

DFC Desired Future Condition

DFIR1 Douglas-fir Interior Pacific Northwest (vegetation type category)

DFTM Douglas-Fir Tussock Moth (silvicultural term/abbreviation)

DIB Diameter Inside Bark

DMR Dwarf Mistletoe Ranking (silvicultural term/abbreviation)

DMT Dwarf Mistletoe (silvicultural term/abbreviation)

DSC Detrimental Soil Conditions (soils analysis term)

EA Environmental Assessment (document)

ECA Equivalent Clearcut Acres (watershed analysis term)

EIS Environmental Impact Statement

EO Executive Order

EPA Environmental Protection Agency

ESA Endangered Species Act of 1973, as amended

EVG Existing Vegetation Group

FA Functioning Appropriately (fisheries and watershed term)

FAR Functioning At Risk (fisheries and watershed term)

FAUR Functioning at Unacceptable Risk (fisheries and watershed term)

FEIS Final Environmental Impact Statement

FLPMA Federal Land Policy Management Act

FM Fuel Model

FP Forest Plan (see also LRMP)

FR Forest Road

FRCC Fire Regime Condition Class (fuels and fire term)

FRI Fire Return Interval (fuels and fire term)

FS Forest Service (see USFS)

FSH Forest Service Handbook

FSM Forest Service Manual

FSR Forest System Road

FWS Fish and Wildlife Service (in the Department of the Interior)

GF Grand fir

GFDF Grand fir / Douglas-fir (vegetation type category)

GHG Greenhouse Gases (term used in air quality and climate change analysis)

GIS Geographic Information System
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GTR General Technical Report (USFS research publications abbreviation)

GTR Green Tree Replacement

HEI Habitat Effectiveness Index (computer model for wildlife analysis of elk habitat)

HOR Harvest Overstory (silviculture term)

HPR Harvest Partial Removal (silviculture term)

HRV Historical Range of Variability (silvicultural term)

HTH Harvest Thinning (silviculture term)

HUC Hydrologic Unit Code (pertains to watersheds)

IDT Interdisciplinary Team (for NEPA analysis process)

INFISH Inland Native Fish Strategy 1995

INT Intermediate Commercial Thinning (silvicultural term)

INSP Invasive Species

INWMP Integrated Noxious Weed Management Plan

IPCC Intergovernmental Panel on Climate Change

IRA Inventoried Roadless Area

KV Knutson Vandenberg Act of 1930

LAU Lynx Analysis Unit (wildlife analysis term)

LMZ Lower Management Zone (silviculture term)

LOS Late and Old Structure (silviculture term)

LRMP Land and Resource Management Plan (management plan for National Forests)

LTA Land Type Association (analysis term used in many resource areas)

LTA Leave Top Attached (refers to a logging yarding system)

LWD Large Woody Debris (wood material) similar to CWD

MA Management Area (in a Forest Plan)

MBF Thousand Board Feet (used for timber volume)

MBTA Migratory Bird Treaty Act of 1918

MFI Mean Fire Interval (fuels and fire term)

MIIH May Impact Individuals or Habitat (determination statement for FS Sensitive species)

MIS Management Indicator Species (usually in a FS land management plan)

ML Maintenance Level

MMBF Million Board Feet (of timber volume)

MOU Memorandum of Understanding (usually between the FS and other Agencies)

MPP Maximum Population Potential

MSLT Multi-Storied Large Trees Common Stands (silviculture term)

NAAQS National Ambient Air Quality Standards

NCT Non-Commercial Thin (silviculture term)

NE No Effect

NEPA National Environmental Policy Act of 1969

NF National Forest

NFFL Northern Forest Fire Laboratory

NFMA National Forest Management Act of 1976

NFS National Forest System

NFSR National Forest System Road (see also FSR)

NI No Impact (a determination statement for FS Sensitive Species)

NOI Notice of Intent (for an EIS, issued in the Federal Register)

NRMDPS Northern Rocky Mountain Distinct Population Segment

NS Non-system (transportation term = non-system road)

NTMB Neotropical Migratory Birds (wildlife analysis abbreviation)

ODA Oregon Department of Agriculture

ODEQ Oregon Department of Environmental Quality

ODFW Oregon Department of Fish and Wildlife

OHV Off-highway Vehicle

ORV Off-road Vehicle

ORV Outstanding Remarkable Value (pertains to Wild and Scenic Rivers)

PA Proposed Action

PA Programmatic Agreement
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PACFISH Interim Strategies for Managing Anadromous Fish in Northwest

PCE Primary Cavity Excavators (birds)

PCE Primary Constituent Elements (of critical habitat for listed fish species)

PDF Project Design Feature

PETS Proposed, Endangered, Threatened and Sensitive Species

PFA Post-fledging Area (term used for wildlife goshawk analysis)

PFYC Potential Fossil Yield Classification

PHOR Partial Overstory Removal

PI Protection Investment

PIF Partners in Flight

PNV Present Net Value (used in economic analysis)

PNVG Potential Natural Vegetation Group

PNW Pacific Northwest (refers to USFS regional office or region of the USA)

POO Plan of Operation

PP Ponderosa Pine (simple abbreviation, sometimes also seen as PIPO)

PPDF1 Ponderosa Pine-Douglas Fir (Inland Northwest) (veg category term)

PPIN1 Ponderosa Pine PNW/Great Basin (veg category term)

PSI Pounds Per Square Inch (refers to logging yarding equipment impacts)

PWA Potential Wilderness Area

RAWS Remote Automated Weather Station

RD Ranger District (in the Forest Service)

REG Regeneration Harvest (silviculture term)

RHCA Riparian Habitat Conservation Area

RMO Riparian Management Objective

RNA Research Natural Area

ROD Record of Decision (for an FEIS)

ROS Recreation Opportunity Spectrum (visuals analysis term)

RSR Road Surface Replacement (term used in FS transportation)

Rx Prescription (silviculture term)

RXF Prescribed Fire Treatment

S&G Standard and Guideline (in Forest Plans)

SB Snow Basin (project name for this DEIS)

SCN Site Preparation Non-commercial Whip Felling (silviculture term)

SCREENS Region 6 USDA-FS direction for projects in R6 (Oregon and Washington)

SDI Stand Density Index (silviculture term)

SHPO State Historic Preservation Office

SI Stand Initiation (silviculture term)

SMS Scenery Management System

SMU Stand Management Unit (silviculture term)

SOPA Schedule of Proposed Actions (Forest Service notification of projects))

SPBW Spruce Budworm

SPDI5 Interior West Lower Subalpine Forest #2 (silviculture term)

SSLT Single Story Large Trees Common Stands (silviculture term)

SWS Subwatersheds

TEP Threatened/Endangered/Proposed (species status for FWS)

TES Threatened, Endangered, and Sensitive (species)

TEU Terrestrial Ecological Unit (a wildlife and silviculture analysis term)

TMDL Total Maximum Daily Load (used in sediment analysis)

TPA Trees per acre (silviculture term)

USDA United States Department of Agriculture

USDI United States Department of Interior

US-EPA US Environmental Protection Agency

USFS United States Forest Service (also see FS)

USFWS U.S. Fish & Wildlife Service ( also see FWS)

VQO Visual Quality Objective

WEPP Water Erosion Prediction Program (computer model used in hydrology analysis)
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WO Washington Office (refers to the USDA-FS main office in Wash D.C.)

WQL Water Quality Limited (watershed analysis term)

WQMP Water Quality Management Plan (watershed analysis term)

WQRP Water Quality Restoration Plan (watershed analysis term)

WSA Wilderness Study Area

WTY Whole Tree Yarding (silviculture term)

WUI Wildland-Urban Interface (fuels and fire analysis term)

WWNF Wallowa-Whitman National Forest
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Glossary

Activity fuels ~ Fuels generated or altered by a management activity.

Advisory Council on Historic Preservation (ACHP) ~ An independent Federal agency that provides a

forum for influencing Federal activities, programs, and policies as they affect historic resources.

Affected environment ~ Natural environment that exists at the present time in the area being analyzed.

Age class ~ A group of trees that started growing (regenerated) within the same timeframe, usually 20 

years. A single age class would have trees that are within 20 years of the same age, such as 1−20 years or

21−40 years.

Air quality ~ The composition of air with respect to quantities of pollution therein; used most frequently

in connection with “standards” of maximum acceptable pollutant concentrations.

Airshed ~ A geographic area that, because of topography, meteorology, and climate, shares the same air.

Allotment (range allotment) ~ Area designated for use by a prescribed number of livestock for a 

prescribed time period.

Alternative ~ In an EIS, one of a number of possible options for responding to the purpose and need for

action.

Anadromousfish ~ Fish that hatch in fresh water, migrate to the ocean, mature there, and return to fresh

water to reproduce; for example, salmon and steelhead.

Analysis area ~ A delineated area of land subject to analysis of (1) responses to proposed management

practices in the production, enhancement, or maintenance of forest and rangeland outputs and

environmental quality objectives; and (2) economic and social impacts.

Aspect ~ The direction a surface faces. A hillside facing east has an eastern aspect.

Bankfull width ~ The width of a stream channel measured between the tops of the most prominent banks

on either side of the stream. Also refers to the width of the stream at the normal flood flow.

Basal area ~ The area of the cross-section of a tree trunk near its base, usually 4.5 feet above the ground.

Basal area is a way to measure how much of a site is occupied by trees. The term basal area is often used

to describe the collective basal area of trees per acre.

Benchmark ~ The analytical basis from which the alternatives were developed; the use of assessed land

capability as a basis from which to estimate the effects of alternative patterns of management on the land.

Beneficial uses ~ Any of the various uses which may be made of water including, but not limited to, 

domestic water supplies, industrial water supplies, agricultural water supplies, navigation, recreation in

and on the water, wildlife habitat, and aesthetics. The beneficial use is dependent upon actual use, the

ability of the water to support a non-existing use either now or in the future, and its likelihood of being

used in a given manner. The use of water for the purpose of wastewater dilution or as a receiving water for

a waste treatment facility effluent is not a beneficial use.

Best management practices (BMPs) ~ A practice or combination of practices that is the most effective

and practical means (including technological, economic, and institutional considerations) of preventing or

reducing negative environmental impacts to water pollution that may result from resource management

activities.

Big game ~ Large mammals, such as deer and elk, which are hunted for sport.

Big game summer range ~ A range usually at higher elevations, used by deer and elk during the summer.

Summer ranges are usually much more extensive than winter ranges.
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Big game winter range ~ A range usually at lower elevation used by migratory deer and elk during the

winter months; usually more clearly defined and smaller than summer range.

Biological assessment (BA) ~ A document prepared by a Federal agency for the purpose of identifying

any endangered or threatened species likely to be affected by an agency action.

Biological diversity ~ The number and abundance of species found within a common environment. This

includes the variety of genes, species, ecosystems, and ecological processes that connect everything in a

common environment.

Biological evaluation (BE) ~ A document prepared by the Forest Service to disclose impacts toForest

Service Regional Foresters Sensitive Species.

Biophysical ~ The combination of biological and physical components in an ecosystem.

Browse ~ Twigs, leaves, and young shoots of trees and shrubs that animals (such as deer and elk) eat.

Buffer ~ A land area designated to block or absorb impacts to the area beyond the buffer. For example, a

streamside buffer is often retained to reduce impacts of a harvest unit.

Canopy ~ In a forest, the branches of the uppermost layer of foliage. It can also be used to describe lower

layers in a multistoried forest.

Canopy closure ~ The amount of ground surface shaded by tree canopies as seen from above. Used to

describe how open or dense a stand of trees is, often expressed in 10 percent increments.

Capability ~ The potential of an area or land/or water to produce resources, supply goods andservice, and

allow resource uses under a specified set of management practices and at a given level of management

intensity.

Catastrophic wildfire ~ An especially intense and widespread fire that usually, but not always, occurs in

forests that are outside the historical range of variability in terms of forest structure and forest fuels due to

fire suppression.

Cavity ~ A hole in a tree often used by wildlife species, usually birds, for nesting, roosting, and 

reproduction.

CCF ~ One hundred cubic feet (see CF).

Channel (stream) ~ The deepest part of a stream or riverbed through which the main current of water 

flows.

Climax ~ The stage of plant development in which vegetation is thought to be stable, self-sustaining, and

self-replicating.

Closure ~ A road management term indicating the road cannot be used by motorized traffic. This 

limitation can be accomplished by regulation, barricade, or blockage devices. The road can be available for

emergency use or permitted use, such as firewood cutting, during dry periods.

Coarse woody debris (CWD) ~ Pieces of woody material derived from tree limbs, boles, and roots in

various stages of decay, generally having a diameter of at least 3 inches and a length greater than 3 feet.

Code of Federal Regulations (CFR) ~ A codification of the general and permanent rules published in the

Federal Register by the Executive departments and agencies of the Federal government.

Commercial thinning ~ Any type of tree thinning that produces merchantable material at least equal in

value to the direct costs of harvesting.

Community ~ A group of species of plants or animals living and interacting at a particular time and place;

a group of people residing in the same place under the same government.
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Compaction ~ Making soil hard and dense, and decreases its ability to support vegetation because the soil

can hold less water and air and because roots have trouble penetrating the soil.

Conifer ~ A tree that produces cones, such as a pine, spruce, or fir tree.

Connectivity (of habitats) ~ The arrangement of habitats that allows organisms and ecological processes

to move across the landscape; patches of similar habitats are either close together or linked by corridors of

appropriate vegetation. The opposite of fragmentation.

Consultation ~ A process required by section 7 of the Endangered Species Act whereby Federal agencies

proposing activities in a listed species habitat confer with governing agencies about the impacts of the

activity on the species. Consultation may be informal, and thus advisory, or formal, and thus binding.

Corridor ~ Elements of the landscape that connect similar areas. Streamside vegetation may create a 

corridor of willows and hardwoods between meadows where wildlife feed.

Cover ~ Any feature that conceals wildlife or fish, sometimes referred to as hiding cover. Cover may be

dead or live vegetation, boulders, or undercut stream banks. Animals use cover to escape from predators,

rest, or feed.

Critical habitat ~ Areas designated for the survival and recovery of federally listed threatened or 

endangered species.

Crown ~ The part of a tree containing life foliage; treetops.

Crown fire ~ A forest fire that advances through the crown fuel layer normally in direct conjunction with

a surface fire.

Cultural resource ~ The remains of sites, structures, or objects used by people in the past (at least 50 

years old); this can be prehistoric or historical.

Cumulative effects ~ Effects on the environment that result from the incremental impacts of an action

when added to other past, present, and reasonably foreseeable actions. Cumulative effects can result from

individually minor but collectively significant actions taking place over a period of time.

Danger tree ~ Danger trees are a standing tree that presents a hazard to people due to conditions such as,

but not limited to, deterioration or physical damage to the root system, trunk, stem, or limbs and the 

direction or lean of the tree (FSH 6709.11 Glossary). Danger trees have an imminent or likely potential to

fail and are within reach of roads utilized by forest workers, areas where people congregate, or frequently

traveled roads (Toupin and Barger, Field Guide for Danger Tree Identification and Response, USDA FS 

[2005]).

DecAID ~ An advisory tool that provides guidance to land managers evaluating effects of forest 

conditions and existing or proposed management activities on organisms that use snags, downwood, and

other wood decay elements. DecAID is a statistical summary of empirical data from published research on

wildlife and deadwood. Data provided in DecAID allows the user to relate the abundance of deadwood

habitat for both snags and logs to the frequency of occurrence of selected wildlife species that require dead

wood habitat for some part of their life cycle.

Decommission ~ Activity that results in the stabilization and restoration of unneeded roads to a more 

natural state. Removes the road segment from the Forest road inventory system. Decommissioning can

involve closing entrances; scarifying road surfaces, or decompacting (sub-soiling) to establish vegetation

and reduce run-off; seeding to control erosion; partial to full restoration of stream channel by removing

culverts and fills; and removing unstable portions of embankments.

Density (stand) ~ The number of trees growing in a given area; usually expressed in terms of trees per

acre.
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Desired future condition (DFC) ~ A vision of the long-term conditions of the land.

Diameter at breast height (dbh) ~ The diameter of a tree 4.5 feet above the ground measured on the 

uphill side of the tree.

Distinct population segment (DPS) ~ A subgroup of a vertebrate species that is treated as a species for

purposes of listing under the Endangered Species Act. It is required that the subgroup be separable from

the remainder of and significant to the species to which it belongs.

Diversity ~ The distribution and abundance of different plant and animal communities and species within

the area covered by a land and resource management plan.

Downed wood ~ A tree or part of a tree that is dead and laying on the ground.

Duff ~ Organic matter in various stages of decomposition on the floor of the forest.

Eastside SCREENS ~ Regional Forester’s Forest Plan Amendment (June 1995) designed to maintain 

options for old growth related and other species.

Endangered species ~ A plant or animal that is in danger of extinction throughout all or a significant 

portion of its range. Endangered species are identified by the Secretary of the Interior in accordance with

the Endangered Species Act of 1973.

Environmental analysis ~ An analysis of alternative actions and their predictable long- and short- term

environmental effects. Environmental analyses include physical, biological, social, and economic factors.

Environmental impact statement (EIS) ~ A statement of environmental effects of a proposed action and

alternatives. The draft EIS is released to other agencies and the public for comment and review. A final

EIS is issued after consideration of public and agency comments. A record of decision (ROD) is based on

the information and analysis in the final EIS.

Erosion ~ The wearing away of the land surface by wind, water, ice, gravity, or other geological activities.

Erosion can be intensified by human activities (such as road building) that may reduce the stability of soils

or slopes.

Fauna ~ The vertebrate and invertebrate animals of an area or region.

Fire behavior ~ How fire reacts to the influences of fuel, weather, and topography.

Fire cycle (mean fire interval) ~ The average time between fires in a given area.

Fire regime ~ The ecological effects of frequency, intensity, extent, season, and synergistic interactions

with other disturbances, such as insects and disease, classified into generalized levels of fire severity.

Fire severity (or burn severity) ~ Severity describes the fire-caused damage to the vegetation. The 

severity ratings (high, moderate, and low) are based on standards in Forest Service Handbook 2509.13.

Flame length ~ The visible measurable indicator of fireline intensity. It is the length of a flame at the 

flaming front of a fire.

Floodplain ~ The portion of a river valley or level lowland next to streams which is covered with water

when the river or stream overflows its bank at flood stage.

Forage area ~ All areas that do not meet the definition of either satisfactory cover or marginal cover.

Forb ~ A broadleaf plant that has little or no woody material in it, including plants commonly called 

wildflowers and weeds.

Foreground ~ The part of a scene or landscape that is nearest the viewer.
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Forest health ~ The condition in which forest ecosystems sustain their complexity, diversity, resiliency,

and productivity while providing for human needs and values. It is a useful way to communicate about the

current condition of the forest, especially with regard to resiliency, a part of forest health that describes the

ability of the ecosystem to respond to disturbances. Forest health and resiliency can be described, in part,

by species composition, density, and structure.

Forest plan (land and resource management plan [LRMP]) ~ A document that guides natural resource

management and establishes standards and guidelines for a National Forest; required by the National

Forest Management Act.

Forest road or trail ~ As defined in Subpart A-Administration of the Forest Transportation SystemAuthority: 16 U.S.C. 551, 23 U.S.C. 205. § 212.1 Definitions. A road or trail wholly or partly within or

adjacent to and serving the National Forest System that the Forest Service determines is necessary for the

protection, administration, and utilization of the National Forest System and the use and development of its

resources.

Fragmentation ~ The breakup of a large land area (such as a forest) into smaller patches that are isolated

from the original area. Fragmentation can occur naturally (as by stand-replacing wildfire) or from human

activities (such as road building).

Fuel(s) ~ Combustible material that includes vegetation such as grass, leaves, ground litter, plants, shrubs,

and trees. Includes both living plants; dead, woody vegetative materials; and other vegetative materials

which are capable of burning.

Fuel break ~ A zone in which fuel quantity has been reduced or altered to provide a position for 

suppression forces to make a stand against a wildfire. Fuel breaks are designated or constructed before the

outbreak of a fire. Fuel breaks may consist of one or a combination of the following: natural barriers,

constructed fuel breaks, man-made barriers.

Fuel ladder ~ Shrubs, small trees, and low growing branches that allow fire to move from the ground to

the tree crowns.

Fuel load ~ The dry weight of combustible materials per unit area; usually expressed as tons per acre.

Fuel model ~ The combination of live and dead fuel loadings and arrangement that is used in conjunction

with weather and topography inputs to model the fire behavior of a surface fire.

Geographic information system (GIS) ~ Computer software that provides database and spatial analytic

capabilities.

Groundwater ~ Water that sinks into the soil and is stored in slowly flowing and slowly renewed 

underground reservoirs called aquifers.

Habitat capability ~ The ability of a habitat to support a given species of wildlife.

Habitat diversity ~ The variety of different types of wildlife habitat within a given area.

Habitat type ~ A way of defining land areas potentially capable of producing similar plantcommunities at

climax. In forestry, habitat types are named for the predominant climax tree species. For example, the

Pinus Ponderosa Habitat Type series is habitat that typically supports climax ponderosa pine. A number of

other habitat features can be identified using habitat types, such as aspect, elevation, climate, and use by 

wildlife species.

Harvest ~ (1) Felling and removal of trees from the forest; (2) removal of game animals or fish from a

population, typically by hunting or fishing.

Headwaters ~ Beginning of a watershed; unbranched tributaries of a stream.
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Historic site ~ A type of cultural resource associated with the historic-era that may possess archaeological

values; or may be valued in light of its ability to convey its association with important historic events,

people, or architectural/engineering techniques. Historic sites usually must be 50 years of age or more.

Historical range of variability (HRV) ~ The natural fluctuation of components of healthy ecosystems

over time. In this EIS, it refers to the range of conditions and processes that are likely to have occurred

prior to settlement of the project area by people of European descent (approximately the mid 1800s),

which would have varied within certain limits over time.

Hydrologic unit code (HUC) ~ An area of land upstream from a specific point on a stream (designated as

the mouth) that defines a hydrologic boundary and includes all of the source areas that could contribute

surface water runoff directly and indirectly to the designated outlet point.

Hydrology ~ The study of water on the surface of the land, in the soil and underlying rocks, and in the

atmosphere.

Indicator species ~ A plant or animal species that is presumed to be sensitive to habitat change. Its 

presence indicates specific habitat conditions are also present. Population changes in an indicator species

can indicate the effects of land management activities.

Indirect effects ~ Impacts on the environment that are caused by the action and are later in time or farther

removed in distance, but are still reasonably foreseeable.

INFISH ~ Interim Inland Native Fish Strategy for the Intermountain, Northern, and Pacific

Northwest Regions (Forest Service) 1995.

Intensity (fire intensity) ~ The rate of heat release for an entire fire at a specific time.

Interdisciplinary team (IDT) ~ A team of individuals with skills from different disciplines that focuses

on the same task or project, referred to as ID team.

Intermittent stream ~ A stream that flows only at certain times of the year when it receives water from

streams or some surface source, such as melting snow.

Invasive plant species ~ A non-native plant species whose introduction does or is likely to cause 

economic or environmental harm or harm to human health (Executive Order 13122, 2/3/99). Invasive 

plants are distinguished from other non-native plants by their ability to spread (invade) into native 

ecosystems.

Inventoried roadless area (IRA) ~ formerly referred to an area usually of at least 5,000 acres, without

developed and maintained roads, and substantially natural conditions that was inventoried as part of the

land and resource management planning process (LRMP 46 CFR 219.27 (c)).

Irretrievable ~ A category of impacts that applies to losses of production or commitment of renewable

natural resources.

Irreversible ~ A category of impacts that applies to non-renewable resources, such as minerals and 

archaeological sites. Losses of these resources cannot be reversed. Irreversible effects can also refer to

effects of actions on resources that can be renewed only after a very long period of time, such as the loss of

soil productivity.

Issue ~ A matter of controversy, dispute, or general concern over resource management activities or land

uses. To be considered a “significant” EIS issue, it must be well defined, relevant to the proposed action,

and within the ability of the agency to address through alternative management strategies.

Ladder fuels ~ Fuels which provide vertical continuity between strata. Fire is able to carry from the 

surface fuels by convection into the crowns with relative ease.
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Landing ~ Any place where cut timber is collected before further transport from the timber sale area.

Landscape ~ All the natural features such as grasslands, hills, forest, and water, which distinguish one

part of the Earth's surface from another; usually that portion of land which the eye can comprehend in a

single view, including all its natural characteristics.

Large downed wood ~ Logs on the forest floor with a large end diameter of at least 21 inches.

Large woody debris (LWD) ~ Pieces of wood that are of a large enough size to affect stream channel

morphology.

Late forest succession ~ The stage of forest succession in which most of the trees are mature or overmature.

Lethal fire (stand replacement) ~ Fire that kills upwards of 70 percent of overstory trees.

Litter (forest litter) ~ The freshly fallen or only slightly decomposed plant material on the forest floor.

This layer includes foliage, bark fragments, twigs, flowers, and fruit.

Management action ~ Any activity undertaken as part of the administration of a national forest.

Management area ~ An aggregation of capability areas that have a common management direction, and

may be dispersed over the Forest.

Management indicator species (MIS) ~ A wildlife species selected by a land management agency to 

indicate the health of the ecosystem in which it lives and, consequently, the effects of management 

activities on that ecosystem (see indicator species).

Marginal cover ~ A stand of coniferous trees 10 or more feet tall with an average canopy closure equal to

or more than 40 percent but less than 70 percent and generally capable of obscuring at least

90 percent of a standing elk from the view of humans at a distance of 200 feet.

Matrix of pathways and indicators (MPI) ~ (Fish topic) NMFS uses a matrix of pathways and indicators

which identifies pathways for determining the effects of an action. Eighteen habitat condition indicators

(e.g., temperature, width/depth ratio) are associated with three levels of environmental baseline condition:

properly functioning, at risk, and not properly functioning. The effects of the action upon each indicator

are classified by whether it will restore, maintain, or degrade the indicator.

MBF ~ Thousand board feet (see board foot).

Middleground ~ A term used in visual management to describe the portions of a view extending from the

foreground zone out to 3 to 5 miles from the observer.

Mitigation ~ Measures designed to counteract environmental impacts or make impacts less severe.

Mixed stand ~ A stand consisting of two or more tree species.

MMBF ~ Million board feet (see board foot).

Monitoring ~ A process of collecting information to evaluate whether or not objectives of a project and its

mitigation activities are being realized.

Mortality ~ The loss of a population due to all lethal causes, often referring to the rate of death of a 

species in a given population or community.

Mosaic ~ A pattern of vegetation in which two or more kinds of plant communities are interspersed in

patches, such as a meadow between stands of old growth.

National Environmental Policy Act (NEPA) ~ An act of Congress passed in 1969 declaring a national

policy to encourage productive and enjoyable harmony between people and their environment. Section 102
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of the NEPA requires a statement of possible environmental effects be released to the public and other

agencies for review and comment.

National Forest Management Act (NFMA) ~ A law passed in 1976 requiring the preparation of regional

guides and forest plans and regulations to guide that development.

National Forest System road ~ A classified forest road under the jurisdiction of the Forest Service. The

term “National Forest System roads” is synonymous with the term “forest development roads” as used in

23 U.S.C. 205

National Register of Historic Places (NRHP) ~ A list of significant cultural resources maintained by the

National Park Service. A “significant” site is a site that has been evaluated as eligible for inclusion to the

NRHP, or its eligibility status is undetermined.

Natural regeneration ~ Reforestation of a site by natural seeding from surrounding trees. Natural 

regeneration may or may not be preceded by site preparation.

Natural resource ~ Water, soil, wild plants and animals, air, minerals, nutrients, and other resources 

produced by the earth's natural processes.

No action alternative ~ The most likely condition expected to exist in the future if management practices

continue unchanged.

Non-point source pollution ~ Pollution whose source is not specific in location. The sources of the 

discharge are dispersed, not well defined, or constant. Examples include sediments from logging activity

and runoff with chemicals from agricultural lands.

Non-system road/unclassified road ~ Any continuous set of wheel tracks that exist for more than one

season, and do not belong to the transportation system.

Noxious weed ~ “Any living stage (including but not limited to, seeds and reproductive parts) of any 

parasitic or other plant of a kind, or subdivision of a kind, which is of foreign origin, is new to or not 

widely prevalent in the United States, and can directly or indirectly injure crops, other useful plants, 

livestock, or poultry or other interests of agriculture, including irrigation, or navigation or the fish and 

wildlife resources of the United States or the public health” (Public Law 93-629, January 3, 1975, Federal

Noxious Weed Act of 1974). Noxious weed is also an important legal designation that can be assigned at

both the state and/or Federal level. Noxious weed lists vary by state and often focus on species that have a

negative impact on commercial agriculture or rangelands. States have developed laws that require the

control or elimination of noxious weeds by landowners. Not all invasive plants are designated as a state or

Federal noxious weed.

Old growth ~ Old forests often containing several canopy layers, variety in tree sizes and species, 

decadent old trees, and standing and dead woody material. For all national forests in the Pacific Northwest

Region, an old growth stand is defined as any stand of trees 10 acres or greater generally containing the

following characteristics:

a. Stands contain mature and over-mature trees in the overstory and are well into the mature growth

stage (see Handbook of Terminology, Society of American Foresters).

b. Stands would usually contain a multi-layered canopy and trees of several age classes. c. Standing

dead trees and down material are present.

c. Evidence of human activities may be present but may not significantly alter the other 

characteristics and would be a subordinate factor in a description of such a stand.

Ongoing actions ~ Actions that have been implemented, or have contracts awarded or permits issued.

Overstory ~ The upper canopy layer; the plants below comprise the understory.
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PACFISH ~ Interim strategies for managing Pacific anadromous fish-producing watersheds in eastern

Oregon and Washington, Idaho, and portions of California.

Park-like structure ~ Stands with large scattered trees, few or no understory trees, and open growing 

conditions, usually maintained by frequent ground fires.

Patch ~ An area of uniform vegetation that differs in structure and composition from what surrounds it.

Perennial stream ~ A stream that flows throughout the year from its source to mouth.

Potential wilderness area (PWA) ~ Areas of potential wilderness identified through the identification of

potential wilderness process as outlined in FS Handbook 10-909.12, Chapter 71. This inventory of

potential wilderness is not a land designation, nor does it imply any particular level of management

direction or protection in association with the evaluation of these potential wilderness areas. It is

completed with the express purpose of identifying all lands that meet the criteria for being evaluated for

wilderness suitability and possible recommendation to Congress for wilderness study or designation.

Precommercial thinning ~ Removing some of the trees from a stand that are too small to be sold for 

lumber or house logs so the remaining trees will grow faster.

Predator ~ An animal that captures and feeds on parts or all of an organism of another species.

Preferred alternative ~ The alternative identified in a draft environmental impact statement which has

been initially identifed by the agency as the most acceptable resolution to the problems identified in the

purpose and need.

Prescribed fire ~ The intentional use of fire under specified conditions to achieve specific management

objectives.

Prescription ~ Measurable criteria that define conditions under which a prescribed fire may be ignited,

guide selection of appropriate management responses, and indicate other required actions. Prescription

criteria may include safety, economic, public health, and environmental, geographic, administrative,

social, or legal considerations.

Present net value (PNV) ~ The measure of the economic value of a project when costs and revenues 

occur at different times. Future revenues and costs are "discounted " to the present by an interest rate that

reflects the changing value of a dollar over time. The assumption is that dollars today are more valuable

than dollars in the future. PNV is used to compare project alternatives that have different cost and revenue

flows.

Proposed action ~ A proposal by a Federal agency to authorize, recommend, or implement an action.

Public involvement ~ The use of appropriate procedures to inform the public, obtain early and continuing

public participation, and consider the views of interested parties in planning and decision making.

Rangeland (range) ~ Land on which the principle natural plant cover is composed of native grasses, 

forbs, and shrubs that are valuable as forage for livestock and big game.

Recreation opportunity spectrum (ROS) ~ The Forest Service developed the ROS system to help 

identify, quantify, and describe the variety of recreational settings available in national forests. The ROS

system provides a framework for planning and managing recreation resources. The ROS settings are

classified on a scale ranging from primitive to urban.

Redd ~ Spawning nest made by salmon or steelhead in the gravel bed of a river.

Reforestation ~ The restocking of an area with forest trees by either natural or artificial means such as

planting.
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Regeneration ~ The process of establishing a new tree crop on previously harvested land. The term also

refers to the young crop itself.

Regeneration harvest ~ A silvicultural treatment intended to regenerate a stand of trees. Shelterwood and

seed tree harvests are forms of regeneration treatments.

Resident fish ~ Fish that spend their entire life in freshwater: examples include bull trout and westslope

cutthroat trout.

Resilient, resiliency ~ The ability of a social or ecological system to absorb disturbance while retaining 

the same basic structure and ways of functioning, the capacity for self-organization, and the capacity to 

adapt to stress and change.

Restoration (of ecosystems) ~ The process of assisting the recovery of an ecosystem that has been 

degraded, damaged, or destroyed. Ecological restoration focuses on establishing the composition, 

structure, pattern, and ecological processes necessary to facilitate terrestrial and aquatic ecosystem 

sustainability, resilience, and health under current and future conditions.

Revegetation ~ Establishing or re-establishing desirable plants on a site where they are absent or in few

numbers. Revegetation can be accomplished through natural or artificial reseeding or transplanting.

Riparian area ~ The area along a watercourse or around a lake or pond. Area with distinctive soil and

vegetation between a stream and other body of water and the adjacent upland; includes wetlands and those

portions of floodplains and valley bottoms that support riparian vegetation.

Riparian ecosystem ~ The ecosystems around or next to water areas that support unique vegetation and

animal communities as a result of the influence of water.

Riparian habitat conservation area (RHCA) ~ Portions of watershed where riparian-dependent 

resources receive primary emphasis, and management activities are subject to specific standards and 

guidelines. RHCAs include traditional riparian corridors, wetlands, intermittent headwater streams, and

other areas where proper ecological functioning is crucial to maintenance of the stream’s water, sediment,

woody debris and nutrient delivery systems.

Riparian management objectives (RMO) ~ Quantifiable measures of stream and stream-side conditions

that define good anadromous fish habitat, and serve as indicators against which attainment, or progress

toward attainment, of the goals will be measured.

Road density ~ The measure of the degree to which the length of road miles occupies a given land area.

Road ~ A motor vehicle travelway over 50 inches wide, unless designated and managed as a trail. A road

may be classified, unclassified, or temporary (36 CFR 212.1). See also definition for “Forest Road.”

Roaded natural ~ A natural-appearing environment with moderate evidence of the sights and sounds of

humans. Such evidence usually harmonizes with the natural environment. Interaction between

users may be moderate to high, with evidence of other users prevalent. Motorized use is allowed.

Runoff ~ The portion of precipitation that flows over the land surface or in open channels.

Satisfactory cover ~ A stand of coniferous trees 40 or more feet tall with an average canopy closure equal

to or more than 70 percent. The Malheur Forest Plan defines it as cover used by animals to ameliorate the

effect of weather.

Scenery management system (SMS) ~ Management guidelines based on the premise that land 

management activities (including construction of facilities) should not contrast with the existing natural

appearing landscape. Within a framework of regional landscape, character types, form, line, color, and

texture should be used to make activities and structures “fit” within landscapes.
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Scenic integrity objective (SIO) ~ The degree of direct human-caused deviations in the landscape, such

as road construction, timber harvesting, or activity debris. Indirect deviations, such as landscape created by 

human suppression of the natural role of fire, are not included. The level to which an area meets its SIOs is

indicated by the ratings very high, high, moderate, low, very low, or unacceptably low.

Scoping ~ The early stages of preparation of an environmental analysis to determine public opinion, 

receive comments and suggestions, and determine issues during the environmental analysis process. It may

involve public meetings, telephone conversations, or letters.

Sediment ~ Solid materials, both mineral and organic, in suspension or transported by water, gravity, ice,

or air; may be moved and deposited away from their original position and eventually will settle to the

bottom.

Semi-primitive motorized ~ A natural or natural-appearing environment of moderate to large size. 

Interaction between users is low, but there is often evidence of other users. The opportunity exists to use

motorized equipment.

Semi-primitive non-motorized ~ A natural or natural-appearing environment of moderate to large size.

Concentration of users is low, but there is often evidence of other users. Use of local roads for recreational

purposes is not allowed.

Sensitive species ~ A sensitive species is one that has been designated by the Regional Forester because of

concern for population viability. Indications for concern include significant current or predicted downward

trends in population numbers or density or in habitat capability that would reduce an existing species

distribution.

Seral ~ Refers to the sequence of transitional plant communities during succession. Early seral refers to

plants that are present soon after a disturbance or at the beginning of a new successional process (such as

seedling or sapling growth stages in a forest); mid-seral in a forest would refer to pole or medium saw

timber growth stages; late or old seral refers to plants present during a later stage of plant community

succession (such as mature or old forest stages).

Shade-tolerantspecies ~ Species of plants that grow well in the shade of others. Douglas-fir is a 

relatively shade-tolerant tree.

Shelterwood harvest ~ A regeneration cut designed to establish a new crop of trees under the protection

of the old. This type of harvest typically occurs in stages with a second entry following the first after

regeneration has occurred.

Silviculturalsystem ~ The cultivation of forests; the result is a forest of a distinct form. Silvicultural 

systems are classified according to harvest and regeneration methods and the type of forest that results.

Silviculture ~ The practice of manipulating the establishment, composition, structure, growth, and rate of

succession of forests to accomplish specific objectives.

Site potential ~ A measure of resource availability based on interactions among soils, climate, hydrology,

and vegetation.

Site preparation ~ The general term for removing unwanted vegetation, slash, roots, and stones from a

site before reforestation. Naturally-occurring wildfire as well as prescribed fire can prepare a site for 

natural regeneration.

Slash ~ The residue left on the ground after timber cutting or after a storm, fire, or other event. Slash 

includes unused logs, uprooted stumps, broken or uprooted stems, branches, bark, etc.

Snag ~ A standing dead tree, usually larger than 5-feet tall and larger than 6 inches dbh. Snags are 

important as habitat for a variety of wildlife species and their prey.
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Soil compaction ~ The reduction of soil volume. For instance, the weight of heavy equipment on soils can

compact the soil and thereby change it in some ways, such as in its ability to absorb water.

Soil productivity ~ The capacity of a soil to produce a specific crop. Productivity depends on adequate

moisture and soil nutrients as well as favorable climate.

Soil resource inventory (SRI) ~ An inventory of the soil resource based on landform, vegetative 

characteristics,soil characteristics, and management potentials.

Stability ~ Ability of a living system to withstand or recover from externally imposed changes or stresses.

Stand ~ A group of trees in a specific area that are sufficiently alike in composition, age, arrangement, and

condition so as to be distinguishable from the forest in adjoining areas.

Stand composition ~ The vegetative species that make up the stand.

Stand density ~ Refers to the number of trees growing in a given area, usually expressed in trees per acre.

Stand structure ~ The mix and distribution of tree sizes, layers, and ages in a forest. Some stands are all

one size (single-story),some are two-story, and some are a mix of trees of different ages and sizes (multistory).

Standards and guidelines (S&Gs) ~ Requirements found in a Forest Plan which impose limits on natural

resource management activities, generally for environmental protection.

State Historic Preservation Office (SHPO) ~ The agency that represents the interests of the state in 

historic preservation and cultural resources. Federal land managers are required by the National Historic

Preservation Act of 1966, to consult with the SHPO during land management planning.

Stream morphology ~ The study of the form and structure of streams.

Strongholds(fish) ~ Watersheds that have the following characteristics: (1) presence of all major lifehistory forms (for example, resident, fluvial, and adfluvial) that historically occurred within the watershed;

(2) numbers are stable or increasing, and the local population is likely to be at half or more of its historical

size or density; (3) the population or metapopulation within the watershed, or within a larger region of

which the watershed is a part, probably contains at least 5,000 individuals or 500 adults.

Structural stage ~ A stage of development of a vegetation community that is classified on the dominant

processes of growth, development, competition, and mortality. See stand structure.

Subwatershed ~ A drainage area of approximately 20,000 acres, equivalent to a 6th-field Hydrologic Unit

Code (HUC). Hierarchically, subwatersheds(6th-field HUC) are contained within a watershed (5th

-field

HUC), which in turn is contained within a sub-basin (4th-field HUC).

Succession ~ The predictable, natural replacement of one plant community with another over time. The

different stages in succession are often referred to as seral stages (see seral).

Successional stage ~ A stage of development of a plant community as it moves from bare ground to 

climax. The grass-forb stage of succession precedes the woody shrub stage (see seral).

Suitability ~ The appropriateness of certain resource management practices for an area of land. Suitability

can be determined by environmental and economic analysis of management practices.

Sustainability ~ Meeting the needs of the present generaton without compromising the ability of future 

generations to meet their needs. Sustainability is composed of desirable social, economic, and ecological 

conditions or trends interacting at varying and temporal scales, embodying the principles of multiple-use 

and sustained-yield (FSM 1905).

Thermal cover ~ Cover used by animals against weather. For example, thermal cover for elk can be found

in a stand of coniferous trees at least 40 feet tall with a crown closure of at least 70 percent.
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Thinning ~ A cutting made in an immature stand of trees to accelerate growth of the remaining trees or to

improve the form of the remaining trees.

Threatened species ~ Those plant or animal species likely to become endangered throughout all or a 

specific portion of their range within the foreseeable future as designated by the U.S. Fish and Wildlife

Service under the Endangered Species Act of 1973.

Tractor logging ~ A logging method that uses tractors to carry or drag logs from the stump to a landing.

Unclassified roads ~ Roads on National Forest System lands that are not managed as part of the forest

transportation system, such as unplanned roads, abandoned travelways, and off-road vehicle tracks that

have not been designated and managed as a trail; and those roads that were once under permit or other

authorization and were not decommissioned upon the termination of the authorization (36 CFR 212.1).

Underburn ~ A burn by a surface fire that can consume ground vegetation and ladder fuels.

Understory ~ The trees and woody shrubs growing beneath the overstory.

Uneven-aged management ~ Method of forest management in which trees of different species in a given

stand are maintained at many ages and sizes to permit continuous natural regeneration. Selective cutting is

one example of an uneven-aged management method.

Uneven-aged stand ~ Stand of trees in which there are considerable differences in the ages of individual

trees.

Unroaded area ~ Portion of the National Forest System that does not contain classified roads (see Road)

that is of sufficient size and configuration that the inherent values associated with an unroaded condition

can be protected. Unroaded areas do not overlap with inventoried roadless areas.

Unsuitable lands ~ Forest land that is not managed for timber production. Reasons may be matters of 

policy, ecology, technology, silviculture, or economics.

Vegetation management ~ Activities designed primarily to promote the health of forest vegetation for

multiple-use purposes.

Viable population ~ A population that has the estimated numbers and distribution of reproductive 

individuals to ensure the continued existence of the species throughout its existing range (or range required

to meet recovery for listed species) within the planning area.

Visual quality objective (VQO) ~ A set of measurable goals for the management of forest visual 

resources. A desired level of management based on physical and sociological characteristics of an area.

Refers to the degree of acceptable alteration of the characteristic landscape.

Water yield ~ The runoff from a watershed including groundwater outflow.

Weed ~ A human-oriented term generally applied to any plant that is growing where someone does not

want it. Which plants are wanted and unwanted depends on the setting or on individual prejudices and

taste (Randall, 1997).

Watershed ~ (1) The region draining into a river, river system, or body of water. (2) A watershed also

refers specifically to a drainage area of approximately 50,000 to 100,000 acres, which is equivalent to a

5th-field HUC. Hierarchically, subwatersheds(6th-field HUC) are contained within a watershed (5th-field

HUC), which in turn is contained within a sub-basin (4th-field HUC).

Wetlands ~ Areas that are permanently wet or intermittently covered with water. Wetlands generally 

include swamps, bogs, seeps, wet meadows, and natural ponds.

Wildland urban interface (WUI) ~ Includes those areas of resident human population at imminent risk

from wildfire, and human developments having special significance. These areas may include critical
Chapter 5 Snow Basin Vegetation Management Project FEIS

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communication sites, municipal watershed, high voltage transmission lines, observatories, church camps,

scout camps, research facilities, and other structures that if destroyed by fire, would result in hardships to

communities. These areas encompass not only the sites themselves, but also the continuous slopes and

fuels that lead directly to the sites, regardless of the distance involved.

Wildfire ~ A human or naturally caused wildland fire that does not meet land management objectives.

Windthrow ~ Trees blown over by the wind.

Winter range ~ That portion of big game’s range where animals congregate for the winter.

Yarding ~ Hauling timber from the stump to a collection point.
Chapter 5 Snow Basin Vegetation Management Project FEIS

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Index

American marten, pine marten, marten

ix, x, xi, 1, 2, 12, 13, 29, 30, 31, 36, 37, 38, 42, 47, 70, 201, 202, 203, 204, 207, 208, 209, 

210, 211, 212, 213, 219, 245, 254, 423, 525, 529, 535, 545, 563, 564, 565, 566, 567, 568, 

570, 607, 615

aspen, quaking aspen

viii, ix, 4, 5, 6, 8, 14, 18, 20, 25, 28, 29, 30, 31, 34, 37, 38, 40, 45, 51, 59, 62, 71, 73, 74, 80, 

81, 92, 112, 114, 135, 155, 172, 185, 187, 217, 223, 233, 235, 243, 244, 246, 247, 248, 251, 

259, 260, 277, 285, 286, 295, 296, 297, 298, 300, 301, 302, 436, 453, 464, 470, 472, 473, 

475, 477, 490, 545, 547, 597, 620, 634, 636, 642, 644, 645, 646

bull trout critical habitat

105, 149, 150, 152, 155, 172, 173, 552, 556

climate change

93, 142, 143, 144, 145, 148, 263, 282, 288, 393, 394, 513, 538, 549, 550, 551, 579, 589, 590, 

594, 603, 610, 620, 621, 622, 640, 645

Eagle Creek Wild and Scenic River

3, 10, 22, 30, 39, 49, 50, 52, 63, 86, 87, 92, 105, 111, 119, 120, 124, 125, 126, 128, 132, 139, 

149, 150, 152, 153, 154, 156, 157, 159, 161, 163, 167, 171, 172, 182, 183, 194, 195, 197, 

206, 252, 265, 266, 282, 289, 290, 291, 292, 293, 296, 297, 298, 299, 304, 305, 307, 308, 

309, 311, 313, 323, 324, 325, 329, 330, 331, 338, 348, 349, 356, 357, 360, 367, 368, 373, 

454, 470, 477, 531, 552, 556, 563, 574, 575, 576, 617, 628, 644, 646, 648

forest plan amendment(s)

ix, 1, 2, 8, 9, 10, 12, 14, 15, 17, 18, 26, 27, 28, 30, 35, 36, 40, 47, 61, 65, 66, 74, 80, 105, 

106, 109, 115, 130, 132, 136, 165, 167, 175, 201, 204, 207, 214, 218, 231, 232, 253, 254, 

269, 274, 282, 289, 360, 469, 471, 525, 544, 545, 546, 547, 565, 571, 573, 591, 592, 598, 

603, 611, 614, 615, 634, 636, 637, 639, 643, 645, 647

historic range of variability (HRV)

viii, 2, 3, 4, 5, 6, 7, 8, 10, 18, 26, 27, 30, 35, 37, 42, 44, 56, 57, 58, 59, 60, 61, 65, 66, 69, 70, 

71, 73, 74, 75, 76, 77, 78, 79, 80, 84, 143, 150, 201, 221, 231, 282, 290, 292, 394, 400, 446, 

448, 467, 468, 469, 470, 471, 527, 528, 534, 536, 545, 547, 558, 559, 560, 561, 562, 568, 

572, 573, 576, 579, 583, 589, 590, 591, 592, 593, 594, 595, 596, 599, 600, 601, 603, 604, 

605, 607, 608, 609, 610, 612, 613, 614, 616, 618, 619, 623, 626, 634, 635, 639, 640, 641, 

642, 643, 644, 645, 647

late and old structure (LOS)

viii, ix, x, xi, 1, 2, 4, 5, 6, 7, 10, 12, 13, 17, 18, 22, 26, 27, 29, 30, 32, 35, 36, 37, 38, 42, 44, 

47, 53, 56, 57, 59, 61, 63, 65, 66, 67, 68, 70, 72, 74, 80, 81, 86, 91, 184, 186, 191, 201, 202, 

203, 204, 206, 213, 218, 222, 248, 249, 294, 306, 307, 뫰394, 448, 449, 

524, 525, 526, 528, 534, 536, 541, 544, 546, 548, 551, 565, 567, 568, 573, 576, 579, 582, 

590, 592, 593, 594, 596, 598, 602, 603, 607, 610, 612, 614, 616, 617, 620, 634, 636, 637, 

639, 641, 644, 645, 646, 647, 649
Chapter 5 Snow Basin Vegetation Management Project FEIS

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Little Eagle Meadows IRA

3, 361, 363, 364, 365, 366, 368, 497, 499

management indicator species (MIS)

105, 136, 149, 155, 164, 166, 167, 173, 175, 176, 201, 207, 214, 215, 220, 221, 225, 226, 

243, 253, 394, 402, 531, 541, 546, 548, 553, 557, 563, 564, 566, 567, 568, 569, 570, 571

multi-story large trees (MSLT)

4, 12, 44, 47, 57, 58, 59, 60, 65, 72, 74, 78, 79, 183, 184, 186, 191, 192, 193, 201, 202, 218, 

248, 394, 448, 469, 471, 525, 536, 545, 563, 570, 590, 591, 592, 596, 607, 612, 616, 639, 

641

old growth

1, 5, 9, 18, 20, 29, 35, 36, 37, 57, 62, 63, 65, 66, 69, 85, 175, 203, 220, 296, 313, 316, 319, 

325, 326, 332, 359, 399, 402, 403, 469, 471, 524, 525, 526, 527, 528, 530, 532, 536, 537, 

543, 544, 547, 553, 555, 561, 565, 566, 567, 571, 573, 577, 580, 581, 583, 585, 586, 590, 

591, 592, 593, 594, 595, 596, 598, 600, 602, 603, 605, 611, 612, 614, 617, 620, 621, 635, 

636, 638, 640, 642, 645, 647, 649

pileated woodpecker(s), pileated(s)

201, 202, 220, 221, 222, 223, 224, 225, 229, 230, 248, 255, 440, 545, 546, 563, 564, 565, 

566, 567, 568, 570

potential wilderness area (PWA)

48, 361, 362, 363, 364, 365, 366, 367, 368, 369, 395, 403, 495, 496, 497, 498, 499, 502, 572, 

573, 574, 575, 576, 649

riparian habitat conservation areas (RHCAs)

17, 18, 21, 22, 25, 29, 32, 34, 36, 39, 40, 44, 62, 99, 105, 107, 109, 114, 115, 116, 117, 118, 

121, 122, 123, 125, 128, 129, 133, 134, 135, 136, 137, 139, 145, 146, 147, 148, 152, 153, 

154, 157, 159, 161, 163, 164, 166, 169, 170, 171, 172, 173, 195, 197, 198, 206, 217, 233, 

251, 252, 259, 264, 267, 395, 405, 440, 441, 442, 444, 447, 454, 467, 543, 545, 553, 554, 

555, 556, 557, 572, 603, 604, 607, 615, 628, 629, 630, 631, 632, 642

single story large trees (SSLT)

4, 6, 12, 44, 47, 57, 58, 59, 65, 66, 69, 70, 72, 74, 78, 79, 80, 183, 185, 186, 187, 193, 201, 

202, 218, 246, 248, 294, 395, 448, 469, 471, 545, 546, 563, 570, 579, 591, 592, 596, 607, 

612, 623, 639, 641
Appendix A Snow Basin Vegetation Management Project FEIS

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APPENDIX A – PROJECT MAPS

Table of Contents

Map A-1. Project Vicinity Map ................................................................................................................429

Map A-2a. Alternative 2 Vegetation Treatments......................................................................................430

Map A-2b. Alternative 2 Transportation System......................................................................................431

Map A-3a. Alternative 3 Vegetation Treatments......................................................................................432

Map A-3b. Alternative 3 Transportation System......................................................................................433

Map A-4a. Alternative 4 Vegetation Treatments......................................................................................434

Map A-4b. Alternative 4 Transportation System......................................................................................435

Map A-5. Subwatersheds and Wild & Scenic River Map ........................................................................436

Map A-6. Fish Distribution Map...............................................................................................................437

Map A-7. LOS/Old-Growth Stands and Connectivity Corridors..............................................................438

Map A-8. LOS and Old-Growth Stands with Alternative 2 Units............................................................439

Map A-9. Marten Habitat with Alternative 2 Units..................................................................................440

Map A-10. Management Areas and WUI Boundaries..............................................................................441

Map A-11. Cool/moist stands in project area ...........................................................................................442
Appendix A Snow Basin Vegetation Management Project FEIS

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Project Maps

Map A-1. Project Vicinity Map
Appendix A Snow Basin Vegetation Management Project FEIS

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Map A-2a. Alternative 2 Vegetation Treatments
Appendix A Snow Basin Vegetation Management Project FEIS

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Map A-2b. Alternative 2 Transportation System
Appendix A Snow Basin Vegetation Management Project FEIS

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Map A-3a. Alternative 3 Vegetation Treatments
Appendix A Snow Basin Vegetation Management Project FEIS

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Map A-3b. Alternative 3 Transportation System
Appendix A Snow Basin Vegetation Management Project FEIS

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Map A-4a. Alternative 4 Vegetation Treatments
Appendix A Snow Basin Vegetation Management Project FEIS

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Map A-4b. Alternative 4 Transportation System
Appendix A Snow Basin Vegetation Management Project FEIS

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Map A-5. Subwatersheds and Wild & Scenic River Map
Appendix A Snow Basin Vegetation Management Project FEIS

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Map A-6. Fish Distribution Map
Appendix A Snow Basin Vegetation Management Project FEIS

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Map A-7. LOS/Old-Growth Stands and Connectivity Corridors
Appendix A Snow Basin Vegetation Management Project FEIS

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Map A-8. LOS and Old-Growth Stands with Alternative 2 Units
Appendix A Snow Basin Vegetation Management Project FEIS

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Map A-9. Marten Habitat with Alternative 2 Units
Appendix A Snow Basin Vegetation Management Project FEIS

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Map A-10. Management Areas and WUI Boundaries
Appendix A Snow Basin Vegetation Management Project FEIS

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Map A-11. Cool/moist stands in project area
Appendix B Snow Basin Vegetation Management Project FEIS

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APPENDIX B

Appendix B-1 – Project Design Features/Best Management Practices / Mitigation Measures Applicable to all 

Alternatives.........................................................................................................................................................445

Table B-1a. Project Design Features/BMPs/Mitigation Measures.................................................................445

Table B-1b. Monitoring Activities .................................................................................................................462

Appendix B-2 – Late and Old Structure Forest (LOS) – landscape Assessment................................................465

Map B-2a. LOS Stands and Past Harvest on La Grande Ranger District.......................................................466

Map B-2b. LOS Stands and Past Harvest on Pine (Whitman) Ranger District..............................................467

Appendix B-3 –Snags and Large Down Logs ....................................................................................................468

Figure B3-1. Wind damage Sparta Area, Whitman Ranger District, 2007. Snapped off trees are ponderosa 

pine that average 24” DBH.............................................................................................................................469

Appendix B-4 – Landscape Treated Comparison...............................................................................................470

Table B-4a. All Ownerships Landscape Project Area - Treatments by Alternative .......................................470

Table B-4b. NFS Ownership only Landscape Project Area - Treatments by Alternative..............................470

Appendix B-5 – Connectivity/Top 1/3 of Site Potential/UMZ-LMZ .................................................................471

Appendix B-6 – Estimate Difference in Time (yrs) to Achieve LOS with and without Stand Management.....472

Table B-6. Estimated time needed to reach 21 inch DBH with and without management ............................472

Appendix B-7 – Plant Association Crosswalk....................................................................................................473

Table B-7. Plant Association Cross Walk to Biophysical Group...................................................................473

Appendix B-8 – Unit Treatments/Logging Systems...........................................................................................474

Table B-8a. Commercial Treatments/Logging Systems Table by Alternative...............................................474

Key: ................................................................................................................................................................481

Table B-8b. Aspen Treatment Units...............................................................................................................481

Approximately 15 acres are located with harvest units, and approximately 14 acres are outside of harvest 

units. Specialist reports will reflect the total acres of Aspen treatments. .......................................................481

Key: ................................................................................................................................................................482

Table B-8c. Non-commercial Harvest Units..................................................................................................482

Table B-8d. Prescribed fire Units...................................................................................................................482

Key: ................................................................................................................................................................483

Appendix B-9 – Management Area Direct Comparison.....................................................................................484

Table B-9a. Management Area 1, 1W, and 3 .................................................................................................484

Table B-9b. Management Area 7 - Wild and Scenic- Recreational Section (Eagle Creek Wild and Scenic 

River Management Plan)................................................................................................................................487

Table B-9c. Forest Plan Management Direction - Aspen Restoration............................................................489

Table B-9d. Comparison of Management Area Treated by Alternative.........................................................490

Appendix B-10 – Potential Cumulative Activities List ......................................................................................491

Table B-10a. Ongoing misc activities for the Snow Basin Project Area........................................................491

Table B-10b. Ongoing Range Management Activities for the Snow Basin Project Area..............................491

Table B-10c. Prescribed Fire Activities for the Snow Basin project area ......................................................492

Table B-10d. Past Vegetation Management Activities...................................................................................492

Table B-10e. Planned Prescribed Fire Activities Adjacent to the Snow Basin Project Area .........................494

Appendix B-11 – Transportation System-Road Maintenance and Reconstruction Segments............................497

Table B-11. Road System Maintenance and Reconstruction Segments - Condition and Inventory ..............497

Appendix B-12 – Transportation System: Road Closure and Decommissioning Definitions and Strategies.....504

Table B-12. Decommissioning road segments...............................................................................................507

Appendix B-13 – List of Harvest Unit Activities Operations within RHCAs....................................................508

Table B-13 Harvesting operations within RHCAs.........................................................................................508

Appendix B-14 Scoping Process ........................................................................................................................511
Appendix B Snow Basin Vegetation Management Project FEIS

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Table B-14a. List of letters and emails comments on the proposed received during scoping period.............511

Table B-14b. Newspaper Media Articles about Snow Basin Project.............................................................511

Appendix B-15 – Potential Wilderness Areas – Undeveloped Areas Inventory Methodology..........................512

Table B-15a. Summary of acres evaluated in the inventory process..............................................................513

Table B-15b. Other undeveloped lands. .........................................................................................................517

Table B-15c. Final Inventory of Potential Wilderness Areas.........................................................................519

Map 1. Existing IRAs.....................................................................................................................................521

Map 2. Past Activities.....................................................................................................................................522

Map 3. Road Buffers ......................................................................................................................................523

Map 4. Acres Not Containing Roads..............................................................................................................524

Map 5. Potential Wilderness/Undeveloped Lands..........................................................................................525

Map 6. Alternative 2 Potential Wilderness/Undeveloped Lands....................................................................526

Map 7. Alternative. 3 Potential Wilderness/Undeveloped Lands...................................................................527

Map 8. Alternative 4 Potential Wilderness/Undeveloped Lands....................................................................528

Appendix B-16 – Climate Change Synopsis for the Blue Mountain region of NE Oregon ...............................530

Appendix B-17 – DEIS Commenters..................................................................................................................532

Table B-17. List of DEIS Commenters ..........................................................................................................532
Appendix B Snow Basin Vegetation Management Project FEIS

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Appendix B-1 – Project Design Features/Best Management Practices / Mitigation 

Measures Applicable to all Alternatives

The Project Design Features (PDFs), Best Management Practices (BMPs) and Mitigation items noted below in 

Table B-1a are an integral part of the proposed action and alternatives and would be implemented as part of any 

project treatments. These items were developed to reduce or eliminate impacts on analysis issues, affected 

resource areas and are incorporated as an integrated part of the proposed action and any action alternative as 

applicable. Project design features are based upon standard practices and operating procedures that have been 

employed and proven effective in similar circumstances and conditions. In addition, Table B-1b notes 

monitoring activities that are planned.

Table B-1a. Project Design Features/BMPs/Mitigation Measures

PDF / BMP Item 

(By Resource 

Area or Activity)

Description of PDF / BMP / Mitigation Measures Applicable Units or 

Activities Reference

Botany TES Plants

BO-1 Protection of TES plants, regardless of when they are located, is 

provided contractually under BT6.25 Protection of Threatened, 

Endangered and Sensitive species. Any TES plant populations 

found during the survey periods (prior to project implementation) 

would need to be designated as an Area to Protect (ATP).

Known TES plant populations (Carex cordillerana) ATP’s are 

marked on the ground and on project area maps. Any known or 

newly discovered populations would be protected (through 

avoidance) from post activity burning, site preparation, road 

closures, etc. The District Botany Specialist would make 

locations known to sale administrators if TES plants are 

discovered during any phase of project implementation.

Units 11, 13, 18A, 

39, 40, 41, 44, 45, 

57, 100, 101, 107, 

109, 142, 321

Prescribed fire 

units 1, 12, 13A, 

19, 20, 30

BO-2 Use INFISH/site specific riparian buffers to protect riparian 

habitat and vegetation. No prescribed fire would be started or 

introduced in these areas, but prescribed fire would be allowed to 

back-burn down into riparian habitat under low fire intensity 

conditions.

All units

BO-3 Avoid locating temp road construction, skidding, landing piles, 

slash piling on previously undisturbed non-forest openings. 

These sites contain shallow soils and provide habitat for diverse 

plant species. 

All units

Noxious Weeds

NX-1 Project personnel would inform District weed specialists of 

upcoming project activities (i.e. temporary road openings, 

harvest, etc.), so reprioritization of treatment (if deemed 

necessary) and inventory can begin prior to the start of project 

activities.

All units Specialist 

Report

NX-2 New infestations would be inventoried and managed as rapidly 

as possible under early detection rapid response (EDRR) 

guidelines.

Project Area WW Invasive 

Plant EIS

NX-3 To reduce the potential spread from known invasive plant sites, 

these occurrences would be identified as Areas-To-Avoid for 

All units Specialist 

Report
Appendix B Snow Basin Vegetation Management Project FEIS

446

PDF / BMP Item 

(By Resource 

Area or Activity)

Description of PDF / BMP / Mitigation Measures Applicable Units or 

Activities Reference

moderate to high-risk ground disturbance activities. Coordination 

will occur with District weed specialists for exceptions.

NX-4 All landing piles, created as part of a whole tree yarding system, 

would be rehabilitated and seeded with an approved native seed 

mix. Skid trails would also be reseeded following project 

activities.

All units Specialist 

Report

NX-5 Actions conducted or authorized by written permit by the Forest 

Service that operate outside the limits of the roads prism, require 

cleaning of all heavy equipment prior to entering NFS lands.

Project Area R6 Invasive 

Plant EIS

NX-6 Use weed-free straw and mulch for all projects, conducted or 

authorized on NFS lands.

Project Area R6 Invasive 

Plant EIS

NX-7 Use only gravel, fill, sand, and rock that are judged weed free by 

District weed specialists.

All sources R6 Invasive 

Plant EIS

Range/Livestock 

RG-1 All range improvements must be protected during project 

activities. If fences are damaged, repairs must be made 

immediately to prevent livestock from entering areas outside of 

established allotments.

All units Specialist 

Report

RG-2 No trees used as anchor trees along a fence line shall be marked 

for harvest.

All harvest units Specialist 

Report

RG-3 All gates must be closed while livestock are within the allotment 

adjacent to the harvest units

All units Specialist 

Report

RG-4 Treatments located within Grazing Allotments will be coordinated 

with the District Range Management Specialist prior to treatment 

to adapt the administration of the allotment (if needed).

All units Specialist 

Report

RG-5 The allotments will be administered to standard following 

treatment to ensure the Forest Plan Standards and Guidelines 

set for allowable use are met.

Allotments within 

the project area

Specialist 

Report, 

Forest Plan

RG-6 All burning activities will be coordinated with the District Range 

Management Specialist to identify needed adjustment to grazing 

activity based on the specifics of each burn block.

All prescribed fire 

units

Specialist 

Report

Fire/Fuels

FIRE/FUELS-1 Burns which consume more than 10 tons of fuel must follow 

requirements in the State of Oregon Smoke Management Plan.

All Units that apply

FIRE/FUELS-2 Smoke Management forecasts will be obtained through Oregon 

Department of Forestry, the morning of ignition, and each 

subsequent day of ignition. Forecast must be favorable or 

reviewed with forecaster for the burn to proceed.

All Units that apply

FIRE/FUELS-3 Fire lines will have appropriate waterbars in steep sections to 

reduce erosion and sedimentation.

All Units that apply

FIRE/FUELS-4 Selected Overstory Protection: FDR - Pullback of fuel 

accumulation as needed from designated trees prior to 

All Units that apply RMRS-GTR238
Appendix B Snow Basin Vegetation Management Project FEIS

447

PDF / BMP Item 

(By Resource 

Area or Activity)

Description of PDF / BMP / Mitigation Measures Applicable Units or 

Activities Reference

prescribed burning to limit overstory mortality from prescribed 

fire. Follow recommendations in RMRS-GTR-238.

FIRE/FUELS-5 Where mechanical fuel reduction is necessary, use low ground 

pressure equipment such as grapple mounted excavator to 

reduce the impacts on the soil resource.

All Units that apply

FIRE/FUELS-6 Rehab firelines that have the potential to increase public off-road 

motor vehicle travel as necessary to ensure created firelines are 

near natural appearing, and do not pose potential for increase 

public off-motor vehicle and/or forest resource long-term adverse 

impact.

All Units that apply

Heritage/ Paleontology

HR-1 Activities are excluded from any known archaeological sites, 

except on established (open) roads; or allowed with coordination 

with the archaeologist and consulted upon with the Oregon State

Historic Preservation Office (SHPO).

All Units

HR-2 No driving or staging of vehicles or other equipment or supplies, 

no mechanical logging or skidding, no piling, and no pile-burning, 

in known archaeological sites.

All Units

HR-3 For pre-commercial thinning activities, hand-cut vegetation in 

sites may be hand-carried from archaeological sites to aid in 

reducing hazardous fuels build-up in sites. This will be approved 

on a case-by-case basis and monitored by the District 

Archaeologist.

All Units

HR-4 Historic sites that could potentially be damaged by fire or 

associated, preparatory activities will be avoided and/or 

protected. During the layout and development of prescribed burn 

plans, district fuels specialists will work with the District 

Archaeologist to determine the location and appropriate 

protection measures for known heritage sites.

Wooden structures are at the greatest risk of damage or loss 

during burning activities. In order to eliminate the risk of damage 

from fire an appropriately sized buffer zone around structures will 

be excluded from areas to be burned. Depending upon the size 

of the buffer zone and the fire behavior anticipated and observed 

during burning operations, additional protection from embers 

may also be required. In some instances unit boundaries will be 

modified to provide the necessary buffer zone, in others fire 

control methods will be identified and applied prior to or during 

burn operations in order to prevent fire spread into buffer zones. 

Fire control methods include the construction of control lines, by 

hand or with machinery, around historic sites (generally done 

prior to burning) and the use of wetlines, hoselays, engines or 

handcrews to prevent fire spread into buffer zones. If previously 

unknown historic sites are identified during implementation of 

burning, protection actions will be developed and implemented, 

including if necessary the delay of burn activities.

All Units
Appendix B Snow Basin Vegetation Management Project FEIS

448

PDF / BMP Item 

(By Resource 

Area or Activity)

Description of PDF / BMP / Mitigation Measures Applicable Units or 

Activities Reference

Linear features and other historic evidence of human occupancy 

are at risk of some damage during burning activities, generally 

through the construction of control lines. Linear features will be 

identified in burn plans. Preburn fireline construction will be 

limited to the use of handlines and/or wetlines where potential 

exists to impact historic linear features. A dozer boss will be 

present to assist in identifying and avoiding historic sites when 

machinery is used in fireline construction.

HR-5 Water Transportation Ditches

1. No machinery within 50 feet from the center of the ditch in 

either direction.

2. No trees will be marked for harvest on the ditch; this includes 

dead or green trees.

3. No new crossings or landings on the ditch without the Zone 

Archaeologist review or agreement.

4. Trees adjacent to the ditch will be directionally felled away 

from the ditch. If trees cannot be felled away from the ditch, they 

will be left.

5. Any tree which falls on the ditch will be left, until the District 

Archaeologist can review the area.

6. Hand bucking and piling of slash will be the only method used

within the ditch corridor. Slash may be hand piled immediately 

adjacent to, but not within the ditch.

7. Prescribed burning will only be used if no wooden features are 

present. No fire line other than light hand line should be 

constructed within the ditch corridor.

8. Tree planting may occur up to within five feet of the sides of 

the ditch, but no closer, nor within the ditch itself.

All Units affected 

by Water 

Transportation 

Ditches

HR-6 Lithic Scatters - Intact Surface Sites 

These sites have high information content and are comparatively 

scarce. Therefore, project design criteria are limited to the 

following options:

Logging

a. Logging the site over snow when there are appropriate ground 

conditions to protect the site: at least 20 inches of snow and 

overnight temperatures of less than 25 degrees (F) and 

afternoon temperatures less than 35 degrees (F), using existing 

skid trails, and employing cultural resource monitors on the site.

b. Directional felling of designated trees that are inside the site 

boundaries to limit impact.

c. Directional felling (towards the sites outer boundaries) of 

designated trees that are located on the periphery of the site.

d. Aerial logging with full suspension of the logs.

e. Skyline logging with full suspension of the logs.

In all cases heavy equipment will be kept outside the site 

boundaries. Such logging techniques as ground yarding, cable 

yarding, skyline yarding with on end suspension, and directional 

felling with use of skid trails inside the boundaries of the site are 

All Units that apply
Appendix B Snow Basin Vegetation Management Project FEIS

449

PDF / BMP Item 

(By Resource 

Area or Activity)

Description of PDF / BMP / Mitigation Measures Applicable Units or 

Activities Reference

not appropriate for intact surface sites. 

Fuel Treatment

a. Hand piling of slash in off site locations.

b. Broadcast burning at low temperatures.

c. Lopping and scattering of slash rather than burning it.

In all case heavy equipment will be kept outside the site 

boundaries. Slash treatment and fire line construction will take 

place outside the site boundaries. Low temperature broadcast 

burning is not viewed as an adverse impact to the lithic resource 

composing these sites. 

Silviculture Treatment

a. Tree planting by hand, auger or mechanical equipment, 

mechanical site preparation, and rodent control will not be 

undertaken within the boundaries of intact surface sites. When 

silviculture treatment is necessary within site boundaries, 

mitigation will be under taken.

b. Commercial timber thinning over snow when there is 

appropriate snow depth and conditions (frozen ground) is an 

appropriate option.

c. Noncommercial thinning by hand and chainsaw is appropriate.

HR-7 Lithic Scatters - Disturbed Surface Sites

Sites that have been disturbed are less restrictive than intact 

surface sites, but still require sensitive treatment for most 

impacts.

Logging

a. Logging the site over snow when there are appropriate ground 

conditions to protect the site: at least 20 inches of snow and 

overnight temperatures of less than 25 degrees (F) and 

afternoon temperatures less than 35 degrees (F), using existing 

skid trails, and employing cultural resource monitors on the site.

b. Directional felling of designated trees that are inside the site 

boundaries.

c. Directional felling (towards the sites outer boundaries) of 

designated trees that are located on the periphery of the site.

Based on the degree of surface disturbance, the following 

logging systems may be employed following consultation with 

Oregon SHPO. System designs will consider the existing degree 

of disturbance.

d. Skyline yarding with one end suspension.

e. Ground yarding

f. Cable yarning.

g. Designated skid trails.

h. Constrained yarding based on soil moisture.

All Units that apply
Appendix B Snow Basin Vegetation Management Project FEIS

450

PDF / BMP Item 

(By Resource 

Area or Activity)

Description of PDF / BMP / Mitigation Measures Applicable Units or 

Activities Reference

i. Horse logging.

In all cases, heavy equipment will be kept outside the site 

boundaries.

Fuel Treatment

Hand piling, lopping and scattering of slash without burning, or 

low temperature broadcast burning are the only appropriate 

methods of fuels treatment for this class of site.

In all case, heavy equipment will be kept outside the site 

boundaries. Piling and burning of slash will also take place 

outside of the site boundaries.

Silviculture Treatment

a. Tree planting by hand or auger may take place within the 

boundaries of a disturbed surface site. Mechanical equipment 

will not be allowed. If more extensive silvicultural treatment is 

necessary, site specific mitigation measures will be developed.

b. Commercial timber thinning over snow when there is 

appropriate snow depth and conditions (frozen ground) is an 

appropriate option.

c. Precommercial thinning by hand and chainsaw is appropriate.

HR-8 Intact Buried Site

Logging

a. Logging the site over snow when there are appropriate ground 

conditions to protect the site: at least 20 inches of snow and 

overnight temperatures of less than 25 degrees (F) and 

afternoon temperatures less than 35 degrees (F), using existing 

skid trails, and employing cultural resource monitors on the site.

b. Directional felling of designated trees that are inside the site 

boundaries to limit impact.

c. Directional felling (towards the sites outer boundaries) of 

designated trees that are located on the periphery of the site.

d. Aerial logging with full suspension of the logs.

e. Skyline logging with full suspension of the logs.

Ground yarding, cable yarding, skyline yarding with one end 

suspension, directional felling, and use of designated skid trails

are appropriate when the logging system is designated to not 

affect the cultural deposit. This can occur when disturbance is 

limited to the non-cultural deposit above the buried cultural 

deposits. The type of logging system will depend on the depth of 

the sites buried cultural deposits.

Fuels Treatment

a. Hand piling of slash is the most appropriate method for 

treating slash inside site boundaries but wheeled and tracked 

All Units that apply
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Activities Reference

equipment can be used under the following conditions:

1. When the snow is of an appropriate depth and ground 

conditions are adequate to protect the site.

2. When the sites cultural deposits lie beneath the impact zone.

b. Broadcast burning at low temperatures and lop and scatter 

treatments are appropriate.

c. Piling and burning of slash will take place outside site 

boundaries.

Silvicultural Treatment

a. Tree planting by hand, auger, or mechanical equipment and 

site preparation using mechanical equipment will not be 

undertaken within site boundaries unless:

1. The excavation associated with planting and site preparation 

does not penetrate to the buried cultural deposits.

2. The excavation associated with planting and site preparation 

takes place in areas peripheral to the cultural deposits

3. Hand tree planting with bar or hoe at 12 ft by 12 ft or greater 

spacing is used.

b. Commercial thinning is appropriate within the site boundaries 

when snow is of appropriate depth and ground conditions are 

adequate to protect the site.

c. Precommerical thinning by hand and chainsaw appropriate.

HR-9 Disturbed Buried Sites

Logging

a. Logging over snow when there is appropriate snow and 

ground conditions to protect the site.

b. Directional felling of designated trees that are inside the site 

boundaries to limit impact.

c. Directional felling (towards the sites outer boundaries) of 

designated trees that are located on the periphery of the site.

Ground yarding, cable yarding, skyline yarding with one end 

suspension, directional felling, and use of designated skid trails 

are appropriate when the logging system is designated to not 

affect the cultural deposit. This can occur when disturbance is 

limited to the non-cultural deposit above the buried cultural 

deposits. The type of logging system will depend on the depth of 

the sites buried cultural deposits.

Fuels Treatment

a. Hand piling and burning slash is preferred within the site 

boundaries. Mechanical equipment can be used under the 

following conditions:

1. When snow atop the site is of appropriate depth and ground 

conditions are adequate to protect the site.

2. When the sites cultural deposits lie beneath the impact zone.

All Units that apply
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Activities Reference

Silvicultural Treatment

a. Tree planting by hand, auger, or mechanical equipment and 

site preparation using mechanical equipment will not be 

undertaken within site boundaries unless:

1. The excavation associated with planting and site preparation 

does not penetrate to the buried cultural deposits.

2. The excavation associated with planting and site preparation 

takes place in areas peripheral to the cultural deposits

3. Hand tree planting with bar or hoe at 12 ft by 12 ft or greater 

spacing is used.

b. Commercial thinning is appropriate within the site boundaries 

when snow is of appropriate depth and ground conditions are 

adequate to protect the site.

c. Precommerical thinning by hand and chainsaw is appropriate.

HR-10 It is recognized that even the most intensive field surveys may 

not locate all heritage sites therefore:

If cultural resources are located/relocated during implementation 

of any of the action alternatives, work will be halted and the 

District Archaeologist will be notified. The cultural resource will 

be evaluated and a mitigation plan developed in consultation with 

the Oregon SHPO if necessary.

All Units that apply

PALEO-1 If paleontological resources are located or relocated during 

implementation of any of the action alternatives, work will be 

halted and the Forest Geologist/Paleontology Staff will be 

notified.

All Units that apply

PALEO-2 Tractor units will have the most effect to potential paleontological 

resources if tractors were continually running over outcrops. 

Rubber tired or tracked tractors need to be used to prevent 

fracturing and crushing of the bedrock and therefore the 

vertebrate fossils inside. A paleontological trained person will be 

on site to observe all temporary road building in tractor units that 

are partially or entirely within the Martin Bridge Limestone.

During timber sale activities such as skidding and cross country 

travel, all limestone outcrops should be avoided and a 

paleontological trained person should be notified during work in 

the above units to do spot checking.

(Should further ground disturbing actions take place outside the 

proposed temporary roads and tractor units, or other activities 

come in contact and cut into bedrock, a Forest Service 

paleontologist will be contacted to determine if the resources on 

site will be impacted. If paleontological resources are found to be 

impacted during vegetation management activities, a survey will 

be required and further conservation strategies will be 

developed.)

Tractor units that 

are partially or 

entirely within the 

Martin Bridge 

Limestone are: 

119, 133, 135, 

213, 215, 202, 

203, 207, 208, and 

228

Visuals/Scenery

VIS-1 Screen landings from Forest roads 77, 7015, 7755, 7735, the

Martin Bridge Trail and the Main Eagle Trail.

All Units that apply
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VIS-2 Limit naturally shaped openings to be a maximum of 5 to 10 

acres in size with blended edges. In areas of Retention and 

Partial Retention in both Middle and Background from Forest

roads 77, 70, 7015, 7725, 7730, 7755 and 7735.

All Units that apply

VIS-3 New temporary roads and landings may be evident but must 

remain subordinate to the shape and pattern of the natural 

appearing forest canopy. In areas of Retention and Partial 

Retention foreground from Forest roads 77, 70, 7015, 7020, 

7725, 7730, 7755 and 7735.

All Units that apply

VIS-4 Foreground clearings (not to exceed 2 acres) should not be used 

frequently but can be used in specific circumstances to treat 

insect or disease infestations, or to open views to scenic 

attributes such as rock formations, large ponderosa pine or 

components, or views to distant mountain peaks. In areas of 

Retention and Partial Retention in both Middle and Background

from Forest roads 77, 70, 7015, 7020, 7725, 7730, 7755 and 

7735.

All Units that apply

VIS-5 Skid patterns, slash, soil exposure and stumps should be visually 

minor or unnoticed (4” maximum height of stumps). In areas of 

Retention foreground as seen from Forest roads 77, 70, 7015, 

7020, 7725, 7755 and 7735.

All Units that apply

VIS-6 Cut stumps at a height less than 4” that are within 100’ of Forest 

road 77 within the Wild and Scenic River Corridor.

All Units that apply

VIS-7 Slash piles shall not be located within the immediate Foreground, 

(100’) of Forest roads 77, 7015, 7020, 7755, 7735, the Martin 

Bridge Trail and the Main Eagle Trail.

All Units that apply

VIS-8 After burning piles within landings, scatter residue of burn piles 

and seed area within the areas of Foreground.

All Units that apply

Silviculture/Timber

SILVI-1 Operating restriction - Pine Engraver. Restricts the creation of 

pine engraver breeding habitat (ponderosa pine) slash from 

December 1 to June 30. Applies to harvesting and road 

construction/ reconstruction/maintenance to prevent outbreak of 

pine engraver beetles. In harvest units of greater than 2 MBF per 

acre gross harvest volume of ponderosa pine, avoid leaving the 

resulting green ponderosa pine slash in the woods from 

December 1 through June 30th. Applicable units would be based 

upon the cruise volume. Should green ponderosa pine slash be 

created during this period, Pine Engraver breeding habitat (green 

cambium) should be destroyed prior to July 1st. Log decks 

containing any ponderosa pine logs should be hauled prior to 

July 1st. 

Any unit where the 

harvested 

ponderosa pine 

volume per acre is 

2mbf or greater. 

SILVI-2 Operating restriction - quaking aspen units. Requires heavy 

machinery access within the aspen treatment units to be preapproved by the USFS, in order to protect the aspen root 

system. 

A1 – A29
Appendix B Snow Basin Vegetation Management Project FEIS

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Description of PDF / BMP / Mitigation Measures Applicable Units or 

Activities Reference

Transportation

TRANS-1 System roads planned for project use will be maintained to a 

standard needed for project use. Maintenance activities will be in 

accordance with the Wallowa-Whitman standard specifications 

for timber sales. Typical maintenance activities include; blading 

and shaping roadbeds, cleaning ditches and culverts, installing 

and replacing temporary culverts, removal or ramping over of 

small slumps and slides, road-side brushing of overhanging 

limbs and small diameter trees, logging out blow downs and 

felling danger trees. Haul activities may include; dust abatement 

on primary haul routes, and snow removal for winter haul. Posthaul maintenance includes; water barring and blocking closed 

roads; re-establishing and adding to crossditches on lower 

standard open and closed roads, and final blading and shaping 

of all roads, as necessary.

All NFS roads 

used for the project

TRANS-2 System roads needing work beyond the intent of the road 

maintenance specifications will be reconstructed to the minimum 

standard needed to support haul. Typical reconstruction work 

includes heavy clearing, drainage work (springs, culvert 

replacements), removal and stabilization of landslides, relocating 

road segments, placing rock subgrade reinforcement and 

surfacing. Non-typical reconstruction included removal and 

replacement of a bridge structure.

NFS roads used 

for the project and 

determined to 

need 

reconstruction to 

be suitable for use

TRANS-3 System roads that are closed will be opened for project use only 

and re-closed.

Closed (ML1) NFS 

roads used for the 

project

TRANS-4 Temporary roads will be constructed and then stabilized and 

blocked under the terms of the contract. Location, clearing width

and any special construction requirements (including post-haul 

treatment) will be agreed to in writing prior to construction.

New temporary 

roads

TRANS-5 Existing roads that are not system roads will be used for the 

project under the timber sale contract terms for temporary roads. 

Location, clearing width, and any special requirements (including 

post-haul treatment) will be agreed to in writing approval prior to 

construction and they will be closed and stabilized after use.

Existing nonsystem roads

TRANS-6 Open and closed (ML1 and 2) system roads not necessary for 

public access may be closed to the public and signed for project 

use only during project operations.

Roads shown in 

contract Road 

Maintenance 

Requirement 

tables for 

specifications T838 or T-839

TRANS-7 Bridges and culverts will be installed during instream work 

window. Culverts to be installed on Category 4 streams will occur 

during dry channel conditions.

TRANS-8 Prevention of Pine Engraver Beetle (IPS Pini) during road 

clearing and maintenance. Avoid leaving greater than or equal to 

4” diameter small end ponderosa pine slash in the woods from 

December 1 through June 30th. Avoid piling or decking during 
Appendix B Snow Basin Vegetation Management Project FEIS

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this period.

Wildlife

WL-1 Snags and Down Woody Material

All snags will be retained unless identified as posing a safety 

hazard.

Snags felled for safety reasons will be retained onsite to 

contribute to coarse wood where coarse wood amounts are 

deficient.

All Units Forest Plan

WL-2 Down Woody Material

Where material is available, all treatment units (harvest and 

prescribed burn) will exceed the minimum levels for down woody 

material described in the table below for each species:

SPECIES

PIECES 

PER 

AC

PIECE LENGTH 

AND SMALL END 

DIAMETER TOTAL 

LINEAL 

Diameter LENGTH

Min 

Length

Ponderosa Pine 3-6 12" 6 ft 20-40 ft

Mixed Conifer 15-20 12" 6 ft 100-140 ft

Lodgepole Pine 15-20 6" 8 ft 120-160 ft

All Units Forest Plan

WL-3 Green Tree Replacements (GTRs)

In addition to the guidelines for logs and snags, sufficient green 

trees of adequate size are to be retained in harvest units to 

provide replacements for snags and logs through time via natural 

mortality. Generally GTRs need to be retained at a rate of 16-74

trees per acre, depending on biophysical group. All harvest 

prescriptions in the project would retain GTRs within or above 

this range. See the WWNF Green Tree Snag Replacement 

Guidelines for details associated with managing for induced 

mortality.

All Units WallowaWhitman NF 

Green Tree 

Snag 

Replacement 

Guidelines

WL-4 Raptors

Any raptor sightings or active raptor nests observed during 

reconnaissance, layout, marking, or project activities will be 

reported to the District Wildlife Biologist for further assessment 

and potential mitigation associated with project activities.

All Units

WL-5 Big Game Winter Range

Logging operations within Big Game Winter Range will be 

conducted outside the period between December 15 through 

April 30. Waivers to operate during this time period may be 

requested of the District Ranger.

All Units that apply Forest Plan
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Activities Reference

WL-6 Landbirds and Neotropical Migratory Birds

To reduce the potential for loss of snags during prescribed

burning, employ passive lighting techniques near snags larger 

than 12 inches. Techniques include lighting at a slope position 

above snags, and avoid lighting directly adjacent to or at slope 

positions directly below snags. For larger snags (> 20 inches 

dbh) at higher risk due to heavy fuels accumulations at the base, 

pullback of fuels may be necessary prior to prescribed burning.

All Units

WL-7 Landbirds and Neotropical Migratory Birds

To reduce the potential for impacts to nesting landbirds, 

prescribed burning activities projected to occur on or after May 

20, and/or past the onset of vegetation leaf-out, will be reviewed 

by a district or forest wildlife biologist. The District Biologist will 

then provide recommendations concerning prescribed burning 

after May 20 and/or past the onset of vegetation leaf-out.

All Units

WL-8 Cavity-nester/Denning Habitat

All non-merchantable grand fir 35 inches dbh or larger will be 

retained within treatment units. 

All Units

WL-9 Connectivity 

All treatments within identified connectivity corridors will maintain 

canopy closure within the top 1/3 of site potential, where 

overstory canopy closure is maintained above 40% within Dry 

Forest PVGs and above 50% within Moist and Cold Forest 

PVGs.

All units that apply

WL-10 Sensitive Habitats

Plant communities adjacent to sensitive/unique wildlife habitats 

will be protected by maintaining vegetative structure 

characteristic of the edge inherent to these areas. These areas 

include cliffs and talus. If encountered, buffer these sensitive 

habitats by at least 100 feet, possibly more on some habitats. 

The degree of activity allowed within these buffers will vary 

depending on the type of sensitive habitat and the current 

conditions associated with the sites. Coordinate with district 

resource specialists. 

All Units

WL-11 White-headed Woodpecker Nest Site

Ensure that the known white-headed woodpecker nest tree is 

protected during implementation of prescribed fire-only 

treatments in Unit F-10. Also, conduct prescribe fire treatments 

within Unit F-10 outside the nesting season (after July 31), 

unless the nest tree is known to be unoccupied.

Prescribed fire unit 

F-10

WL-12 Goshawk Nest Stand

No harvest or disturbing activities will take place within the 30 

acres established as the nest stand.

The 30-acre 

goshawk nest 

stand

WL-13 Goshawk Post-Fledging Area (PFA)

Underburning and prescribed fire-only treatments within the 

goshawk PFA will be implemented outside the nesting period 

(after July 31).

Goshawk PFA
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Description of PDF / BMP / Mitigation Measures Applicable Units or 

Activities Reference

WL-14 Goshawk PFA

Canopy closure in the portion of Unit 50 occurring within the 

delineated goshawk PFA will be maintained at a minimum of 60 

percent.

Unit 50

WL-15 Goshawk Surveys

Conduct goshawk surveys prior to implementing timber harvest 

or prescribed fire-only treatments. If goshawk nesting is 

confirmed, apply appropriate mitigation measures identified in 

the Eastside Screens.

Units 48, 50, 51, 

87, 420, 422, and 

423

WL-16 Pileated Woodpecker Nest Site

Protect the known pileated woodpecker nest tree during 

implementation of prescribed fire treatments. Also, conduct 

prescribed fire treatments outside the nesting season (after July 

31), unless the nest tree is known to be unoccupied.

Prescribed fire unit 

F-34

Watershed/Soils/Fish

WS-1 Riparian Habitat Conservation Areas (RHCAs)

INFISH RHCAs will be established on all streams as follows:

Category 1- Perennial Fish Bearing (300 ft each side of channel)

Category 2- Perennial Non-Fish Bearing (150 ft each side of 

channel)

Category 3- Ponds, lakes, reservoir, wetlands >1 acre (150 feet 

around perimeter of feature)

Category 4- Intermittent Non-Fish Bearing (100 ft each side of 

channel)

Category 4- Wetlands <1 acres, springs, seeps (100 ft around 

perimeter)

Category 4- Landslides (100 ft around perimeter of feature)

Exception: Roads will be used as boundaries when it is located 

at least 100 ft from Category 1 and 3, and at least 50 ft from 

Category 4. This allows for harvest within the RHCAs – About 50 

acres (Alt. 2)

All Units that apply

WS-2 Fire/Fuels RX in RHCAs

Prescribed fire will be allowed in RHCAs consistent with a goal of 

enhancing or maintaining Riparian Management Objectives 

(RMOs).

No active lighting will take place within default RHCAs buffers

except for pile burning. RX fire would be allowed to back into

RHCAs, unless direct ignition is needed to reduce the intensity of

fire within RHCA.

Avoid handpiling within 50 feet of Category 1, 2 and 4 stream 

channels.

Avoid machine piling within RHCAs (except at approved landings 

in RHCAs.)

All Prescribed fire 

units
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Activities Reference

WS-3 Channel Stability

Maintain natural LWD and trees needed for future recruitment to 

protect or enhance stream channel and bank structure, enhance 

water quality, and provide structural fish habitat within all stream 

systems.

All Units

WS-4 Stream Temperature

Prevent measurable (greater than 0.5oF change) temperature 

increases in Category I streams. Temperatures on other streams 

may be increased only to the extent that water quality standards 

on downstream, fish bearing streams will not be affected. 

Normally stream shade management on category III streams will 

differ little from treatment on Category I streams.

All units

WS-5 Roads

Avoid constructing temporary roads within RHCAs. Any planned 

reconstruction or construction of roads crossing riparian areas 

will not alter stream or groundwater flow characteristics to the 

extent that it will impact the riparian area. Design and maintain 

road drainage to prevent the influx of significant amounts of road 

sediment runoff into stream courses. When use of closed roads 

is complete, re-close as soon as possible. Seed as appropriate.

Road reconstruction within RHCAs

Limit vegetation modification to the road prism, road surface plus 

ditch lines, to what is needed to maintain a safe travelway and 

functional drainage system.

All Units/Project 

Roads

WS-6 Temporary Roads ManagementSediment Mitigation Strategy- provide low impact designs

Locate on benches where possible to reduce cut/fill construction, 

sedimentation risks

Provide adequate drainage

Adopt storm-proof designs- outsloping, water drainage features, 

location

Have post-harvest rehab plan for temp roads that include culvert 

removal, outsloped template, scarification, placement of slash 

materials, and seeding as appropriate

Utilize existing non-NFS road templates where possible

Temporary culverts will be located at stable sites to the extent 

possible.

All Temporary 

Roads and Units 

affected by 

Temporary roads

WS-7 Log landings

No new log landings or landing associated with slash pile burning 

within 100 feet of any channel. Any existing landings within 

RHCAs must be upslope of the road system at the base of a unit. 

Rehabilitat landings to minimize bare soil and promote 

vegetation growth.

All Units

WS-8 Skid Trail Rehabilitation

Rehabilitate skid trails using water bars (WS-10), slash 

placement, and seeding as appropriate.

All Units
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(By Resource 

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Activities Reference

WS-9 Ground-based operations

Ground-based harvest will not normally operate on slopes 

greater than 30%. Small inclusions of greater than 30% slope are 

included during layout if they can be operated on without causing 

excessive soil disturbance. Directional felling and winching of 

trees on slopes greater than 30% can be done on small 

inclusions of steep ground. Ground based equipment will not be 

operated within RHCAs on slopes greater than 30%.

All Units

WS-10 Water Bars

Construct water bars on skid trails and firelines where soil 

disturbance is evident (and at the direction of the sale 

administrator), using the spacing guide below:

Gradient Spacing

Under 20 % 80 ft.

20 - 39 % 40 ft.

Greater than 40 % 25 ft.

All Units

WS-11 Skidding and Skid Trails in RHCAs

Logging activities within RHCAs will be restricted to 

processor/forwarder operation. Skidding logs down 

streamcourses or ephemeral draws will not occur. Locate trails 

crossings at right angles to stream channels. Prior approval of 

crossing locations is required. Suitable crossings will be

mitigated to minimize impacts. Mitigation may include slash mats 

or rock amor. Damaged stream banks and crossings shall be

reshaped to stable conditions. Within RHCAs, where soil has 

been exposed, operate equipment on slash as much as possible. 

For roads within RHCAs, only allow skidding to road when the 

road is at least 100 ft away from perennial streams, and 50 ft 

away from intermittents. Existing landing within RHCA may be 

used for decking and loading of logs only. No wholetree 

operations within RHCAs.

All Units

WS-12 Soils

The mitigating measures listed below will be implemented to 

meet the standard in the Land and Resource Management Plan 

(LRMP) of the Wallowa-Whitman National Forest.

These standards state:

Minimize detrimental soil conditions with total acreage impacted 

(compaction, puddling, displacement, and severe burning) not to 

exceed 20 percent of the total acreage within the project area 

including landings and system roads.

The Plan requires use of "approved skid trails, logging over snow 

or frozen ground or dry soils, or some equivalent system for 

limiting the impact and aerial extent of skid trails and landings 

and to prevent cumulative increases from multiple entries in 

tractor logging areas.”

Skid trails and forwarder roads: Maintain a minimum of 100 feet

between main skid trails to the extent possible. Where 

All Units Forest Plan, 

Watershed 

Management 

Practices 

Guide for 

Achieving 

Soil and 

Water 

Objectives
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Activities Reference

Forwarding is required, to the extent practicable, slash will be left 

in forwarder roads from clearing and product manufacture to 

create ‘slash mats’. Forwarder roads will utilize existing skid trails 

to the extent practicable. Forwarder roads will maintain a 

minimum of 60 feet between roads to the extent possible.

Soil Moisture: Skidding, forwarding and mechanical felling 

operations shall not be allowed when soils are wet enough that 

ruts >6 inches deep 50 feet long or more would form. 

Existing skid trails will be used as much as possible, except 

where existing skid trails are inappropriately located, such as 

draw bottoms or too close together.

Winter Logging/Subsoiling: If pre-implementation or postimplementation field monitoring indicate the need, then landings 

and skid trails, or forwarder roads will be subsoiled or winter 

loggin will be required or both.

Cover the subsoiled area with slash. This shall be done in the 

same pass as the subsoiling, without creating new disturbance. 

Slash cover shall provide a minimum of 65% effective ground 

cover, but shall not exceed the fuels prescription for the area. 

Ideally subsoiling and grapple piling would occur at the same 

time in a single pass.

Subsoiling shall utilize a winged subsoiling attachment on an 

excavator.

Subsoiling shall occur when soils are at an optimum moisture for 

the soil type. Subsoiling shall not occur when soils are wet, or 

when moisture is high enough to cause clodding.

Subsoil to a depth of 20 – 24 inches.

Subsoiling passes shall be made close enough to cause 

complete subsurface fracturing between passes, and passes 

shall lift and fracture, not turn over the soil. To better facilitate 

water dispersion, subsoiling passes shall be accomplished in a 

herring bone or other pattern that does not create a furrowed 

pattern that follows the treated trail of road.

Discontinue subsoiling where large rocks are continually brought 

to the soil surface, or operate with the shoes at a shallower 

depther (15 inches).

Grapple piling shall be done with low ground pressure (< 8.5 psi) 

on dry, frozen or snow covered soil, and machinery would stay 

on existing skid trails where possible. On subsoiled units, ideally 

subsoiling and grapple piling will be accomplished in the same 
Appendix B Snow Basin Vegetation Management Project FEIS

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Activities Reference

operation.

WS-13 Additional soil mitigations are required for unit 121 to address 

existing DSCs %. Winter logging required over frozen ground (2-

feet of snow) or other measures which provide mitigation.

Unit 121

INFISH STANDARDS

WS-14 TM-1 INFISH: Prohibit timber harvest in RHCAs except to 

improve RHCA stand structure. Units identified overlap RHCAs 

and RHCA overlap areas will be treated with the rest of the unit 

to improve stand structure.

Units 1, 4, 33, 34, 

57. 213, 300, 301, 

303, 307, 311, 

314, 316, 342, 401

WS-15 RF-2b INFISH: For each planned road, meet the Riparian 

Management Objectives and avoid diverse effects on listed 

anadromous fish (PACFISH) / to inland native fish (INFISH) by: 

B. minimizing road and landing locations in RHCAs.

All Units

WS-16 RF-2d INFISH: For each planned road, meet the Riparian 

Management Objectives and avoid adverse effects on listed 

anadromous fish (PACFISH) / to inland native fish (INFISH) by: 

D. avoiding sediment delivery to streams from the road surface.

All Units

WS-17 RF-2e INFISH: For each planned road, meet the Riparian 

Management Objectives and avoid adverse effects on listed 

anadromous fish (PACFISH) / to inland native fish (INFISH) by: 

E. avoiding disruption of natural hydrologic flow paths.

All Units

WS-18 RF-2f INFISH: For each existing or planned road, meet the 

Riparian Management Objectives and avoid adverse effects to 

inland native fish by: F. avoiding sidecasting of soils. Sidecasting 

of road material is prohibited on road segments within or abutting 

RHCAs in priority watersheds.

All Units

WS-19 RF-5 INFISH: Provide and maintain fish passage at all new road 

crossings of existing and potential fish-bearing streams.

All Units

WS-20 FM-1 INFISH: Design fuel treatment so as not to prevent 

attainment of RMOs, and to minimize disturbance of riparian 

ground cover and vegetation. Strategies should recognize the 

role of fire in ecosystem function and identify those instances 

where fire suppression or fuel management actions could 

perpetuate or be damaging to long-term ecosystem function, or 

designated critical habitat / or inland native fish.

All Units

WS-21 RA-2 INFISH: Trees may be felled in RHCAs when they pose a 

safety risk. Keep felled trees on site when needed to meet woody 

debris objectives.

All Units
Appendix B Snow Basin Vegetation Management Project FEIS

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Table B-1b. Monitoring Activities

Monitoring 

(By Resource Area)

Description of Monitoring Activity 

Botany TES Plants

BO-m1 Monitor for five years to detect changes in population levels and plant community composition of 

Carex cordillerana.

Responsible Staff: Forest Botanist or District Botany Specialist

Noxious Weeds

NX-m1 Monitor for noxious weeds on a yearly basis for three years after the project activities are 

completed.

Responsible Staff: Forest or District Invasive Species Coordinator

NX-m2 Monitor gravel, fill, sand and rock source sites for noxious weeds.

Responsible Staff: Engineering personnel or District Invasive Species Coordinator

NX-m3 Re-seeding of landing piles, temporary roads, and skid trails.

Responsible Staff: Sale Administrator

Range/Livestock

RG-m1 Concurrent and post activity monitoring for damage to range improvements including fences, 

cattleguards and water developments.

Responsible Staff: Sale Administrator or Fuels AFMO

RG-m2 Monitor closure of gates while livestock are within the allotment adjacent to activities, when the 

activity requires opening of the gate.

Responsible Staff: Sale Administrator, Engineering personnel, or Fuels AFMO

Fire/Fuels

Fire/Fuels-m1 Monitor in accordance with ‘Monitoring Fuels Treatments on FS/BLM-Managed Lands in Oregon 

and Washington’

Responsible Staff: Rx Fire Manager or Burn Boss or Fuels AFMO

Fire/Fuels-m2 Smoke Dispersal Monitoring – Nephelometer site readings as well as visual observation.

Responsible Staff: Rx Fire Manager or Burn Boss

Heritage/Paleontology

HR-m1 Monitor any known heritage sites receiving protective treatments upon completion of the project 

to assure the preservation and protection of the heritage resources and determine the success of 

the proposed treatments.

Responsible Staff: Forest or District Archaeologist

PALEO-m1 Monitor temporary road construction in units that are partially or entirely within the Martin Bridge 

Limestone.

Responsible Staff: Forest Geologist/Paleontology Staff or paleontological trained person

PALEO-m2 Monitor utilizing spot checks in units that are partially or entirely with the Martin Bridge 

Limestone.

Responsible Staff: Forest Geologist/Paleontology Staff or paleontological trained person
Appendix B Snow Basin Vegetation Management Project FEIS

463

Monitoring 

(By Resource Area)

Description of Monitoring Activity 

Recreation

REC-m1 Monitor dispersed recreation sites to ensure no project activities occur within the site or the 25 ft 

buffer.

Responsible Staff: Sale Administrator or District Recreation Specialist 

REC-m2 Monitor timing of activities within the Semi-primitive motorized area which includes Unit 82 and 

Forest roads 7725-150 and 7725-094.

Responsible Staff: Sale Administrator, Fuels AFMO or District Recreation Specialist 

Visuals/Scenery

VIS-m1 Monitor stump and slash treatments within the immediate foreground of concern of level 1 and 2 

road segments.

Responsible Staff: District Landscape Architect or designee

Silviculture/Timber

Silvi-m1 Implementation monitoring to verify silviculture prescriptions, vegetation response, landscape 

change (HRV). Visual reconnaissance during sale preparation, harvesting, and implementation 

of thinning, burning, and reforestation activities. Harvest, thinning, and prescribed fire units would 

receive a field examination to assess implementation and to update the vegetation database.

Responsible Staff: District Silviculturist, Assistant Fire Management Officer-Fuels, GIS Specialist, 

Forestry Technicians.

Wildlife

WL-m1 Monitor effectiveness of the PDFs for species noted.

Responsible Staff: Forest or District Wildlife Biologist

Watershed/Soils/Fish

WS-m1 Pre-implementation monitoring will be done to ensure DSC levels remain below the Forest Plan 

Standard. Monitoring may result in requiring winter logging or other mitigation measures which 

limit DSC levels. This would be done in coordination with a hydrologist or soil scientist.

Post-implementation monitoring will be done to ensure that DSC levels remain within Forest Plan 

Standards. Monitoring may result in changes to the post-harvest activities.

Responsible Staff: Forest or District Soil Scientist or Hydrologist

WS-m2 Monitoring of sale layout and contract administration will be undertaken to ensure proper 

application of all identified constraints and mitigating measures.

Post-harvest activities will be monitored to ensure that guidelines to minimize soil disturbance 

are being followed. Site preparation activities such as area subsoiling/scarifying and burning will 

be monitored to ensure the purpose is achieved without causing additional soil damage.

Responsible Staff: Forest or District Soils Scientist or Hydrologist

WS-m3 Monitor the implementation of RHCA buffers on streams and wetland to determine the proper 

buffer widths were adhered to (WS-1).

Responsible Staff: Forest or District Soils Scientist or Hydrologist

WS-m4 Monitor the project to ensure that all Standards and Guidelines in the LRMP are met through 

implementation of protection measures as identified by the interdisciplinary team.

Responsible Staff: Forest or District Soils Scientist or Hydrologist
Appendix B Snow Basin Vegetation Management Project FEIS

464

Monitoring 

(By Resource Area)

Description of Monitoring Activity 

WS-m5 Implementation monitoring of the project and protection measures will take place throughout the 

life of the project by the TSA (Timber Sale Administrator) and Watershed Specialist. Action will 

be taken if an event arises that requires special attention. For example, if an intense 

thunderstorm caused overland flow and subsequent excessive soil displacement or sediment 

production, harvest operations would cease until the soil moisture decreased or protection 

measures were complete. Potential effects from log haul on roads which parallel RHCAs will be 

monitored throughout the life of the project by the TSA and Watershed Specialist. Timber harvest 

operations will be halted if adverse impacts are observed at any point during the operation.

Responsible Staff: Forest or District TSA Staff, Soils Scientist or Hydrologist

WS-m6 Post-project effectiveness monitoring includes implementation and effectiveness monitoring to 

determine if applicable Best Management Practices (BMPs) and mitigation measures were 

effective in meeting soil and water resource protection.

Responsible Staff: Forest or District Soils Scientist or Hydrologist
Appendix B Snow Basin Vegetation Management Project FEIS

465

Appendix B-2 – Late and Old Structure Forest (LOS) – landscape Assessment

Purpose 

The focus of this assessment is to determine the extent of treatments occurring within late/old structure (LOS) 

forest at a scale appropriate for determining cumulative effects resulting from the Snow Basin proposal.

Scope and Scale of the Assessment

Due to potential connectivity of LOS habitat the area of consideration for this assessment is the eastern portion 

of the La Grande Ranger District abutting the Eagle Cap Wilderness and the old Pine Ranger District, a land 

base of a little over 300,000 acres.

The Eagle Cap Wilderness was not included because it is not affected by active management activities. Also not 

included in this assessment is the Hells Canyon National Recreation Area (HCNRA). Although management 

activities can occur within this area, there have been very few within the last 15 years, which have affected LOS 

forests. The Puderbaugh project, currently in the development stages, may treat some LOS forest within the 

HCNRA but would amount to a negligible percentage of the total LOS in the area.

Also not included in this assessment is the remaining area of the Wallowa-Whitman National Forest or the Blue 

Mountains EcoRegion. Changes to LOS forest conditions at this scale are more appropriately addressed in a 

Forest Plan than a site-specific project. The three Blue Mountain Forest’s are currently in a plan revision 

process that will address changes in LOS forest as a result of natural or manmade disturbances.

The period of analysis is 1995 to present, the period in which the Regional Foresters Amendment to Eastside 

Forest Plans has been in effect.

Treatments considered in this assessment are all commercial harvesting activities including: commercial 

thinning, single tree selection, improvement cut, and salvage. These are operations that may have affected the 

structural composition of the LOS to the extent that multi-storied stands become single storied.

Assessment Process

All LOS stands within the analysis area were identified and mapped using the existing EVG database 

information (tables are located in project record files). The results, MSLT and SSLT Stand Acres, show that 

there are about 56,150 acres of LOS within this area. These results are comparable to those found during the 

Blue Mountain Forest Plan Revision process, which identified LOS occupying about 20 percent of the forested 

area across the Wallowa-Whitman NF (Countryman and Justice, June 2010, Analysis of Existing versus 

Historic Condition for Structural Stages and Potential Vegetation Groups within the Malheur, Umatilla, and 

Wallowa-Whitman National Forests Blue Mtn. HRV) and found in the project record files.

Harvest activities, derived from the FACTS database, were overlaid the LOS stands within this area. This 

identified about 2785 acres of LOS forest that have experienced some form of harvest activity in the past 15 

years. LOS Stand Overlap Past Harvest and the existing LOS with overlapping harvest areas are shown on maps 

1 and 2.

Conclusion 

Of the 56,150 acres of late/old structure located within this assessment area, approximately 2,785 acres (5

percent) have been treated in some fashion, between 1995 and 2010. Some of these treatments likely converted 

Multi-story structure (MSLT) forest to single-story structure (SSLT) forest. The predominant structural stage 

remains MSLT (93 percent), with a substantial deficit of SSLT-LOS (7 percent). 

Under the Proposed Action of the Snow Basin project approximately 1,250 acres of LOS forest would be 

treated. Most of these treatments would be to move MSLT forest to SSLT structural stage by removing the mid 

to lower canopy layers, thus creating a mostly single story canopy. When combined with the 2785 acres already 
Appendix B Snow Basin Vegetation Management Project FEIS

466

treated this would total about 7 percent of LOS within the assessment area treated over the past 15 years, a 

small percentage of the overall LOS within this area.

Map B-2a. LOS Stands and Past Harvest on La Grande Ranger District
Appendix B Snow Basin Vegetation Management Project FEIS

467

Map B-2b. LOS Stands and Past Harvest on Pine (Whitman) Ranger District
Appendix B Snow Basin Vegetation Management Project FEIS

468

Appendix B-3 –Snags and Large Down Logs

In all action alternatives, all existing snags and large down logs would be retained, except for snags that pose a 

safety hazard to the public or forest workers. Future snags would occur throughout the landscape by inter-tree 

competition, prescribed fire, insects and disease, and mechanical damage. Green tree replacements (GTRs) will 

be retained at a rate of 16-74 trees per acre, depending on biophysical group, harvest rotation, and average stand 

diameter (Schommer et al. 1993).

Inter-Tree Competition

Inter-tree competition would be immediately reduced in the areas treated under Snow Basin but would increase 

over time due to ingrowth and tree expansion into vacated areas. Existing inter-tree competition would 

continue, and in fact increase, in the forested untreated areas. The trees that normally die from inter-tree 

competition are those in the lower crown classes and shade intolerant tree species overcome by shade tolerant 

trees. Ponderosa pine and western larch readily lose live crown through self pruning when in direct competition 

with other trees. Thereby weakening their ability to compete and survive the effects of insects, disease, and fire.

Prescribed Fire

Prescribed fire is planned across the project area, both prescribed fire and post-harvest fire activities. While low 

intensity fire is planned, jackpots or fuel concentrations result in small areas of high fire intensity. Some trees 

die in any prescribed fire through root damage, root collar girdling, bole scorch, and torching. Dwarf mistletoe 

increases the risk of individual and clumps of trees torching. These trees would provide foraging, nesting, and 

roosting habitat for birds. When these trees fall they would provide foraging and denning habitat for various 

wildlife species.

Insects

Both bark beetles and defoliators, attack and kill trees providing snags and future down log habitat 

(Youngblood, 2002). Pine Engraver beetle, Fir Engraver, Western Pine Beetle, and Douglas-fir beetle are 

common to the Snow Basin landscape. Factors affecting beetle attack of trees includes; presence of host species, 

low tree vigor resulting from overstocking, disease, drought, wind and snow damage, defoliation, and fire.

Western Pine Beetle (WPB) host is large diameter ponderosa pine. Prior to fire exclusion WPB populations 

would rise in response to periods of drought (Miller & Keen, 1960). In most periods WPB would kill wind, ice, 

and lightning damaged trees, trees infected with disease, or those too old or weak to resist attack. WPB is 

currently responsible for increased mortality in the Forshey Meadows area directly adjacent to Snow Basin.

• Pine Engraver Beetle (IPS) host is ponderosa pine occurring in dense stands. Outbreaks were small as 

dense stands were scattered due to repeated underburning (Weaver, 1957) (Weaver, 1967). They are 

attracted to scorched trees or trees otherwise weakened. IPS commonly responds to weather damaged 

trees, trees weakened by drought, fire, disease, and poor harvesting practices. The Cup Springs/Forshey 

Meadows area experienced a large outbreak of IPS in 1989 in response to poor harvesting practices and 

winter breakage. IPS is currently responsible for increased mortality in the Forshey Meadows area 

directly adjacent to Snow Basin.

• Douglas-fir Beetle (DFB) favors large diameter Douglas-fir trees. DFB commonly responds to weather 

damaged trees, trees weakened by drought, fire, and disease. DFB is currently in outbreak stage in the 

East Eagle area directly north of Snow Basin. This outbreak has been ongoing for at least 10 years 

killing clumps of large diameter Douglas-fir throughout the drainage. DFB also reached outbreak stage 

in response to the 1996 Twin Lakes Fire in the Pine Watershed. Like East Eagle this resulted in high 

mortality in large diameter Douglas-fir throughout the drainage.
Appendix B Snow Basin Vegetation Management Project FEIS

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• Fir Engraver (FE) host tree species in Snow Basin is grand fir. It attacks trees from 5 inches dbh and 

larger that are damaged or weakened by competition, defoliation, root disease, or age (Berryman & 

Ferrell, 1988). Dry sites also increase fir’s susceptibility to FE.

• Western Spruce Budworm and Douglas-fir Tussock Moth’s host species are grand fir and Douglas-fir.

Outbreaks have been occurring through history (Swetnam & Lynch, 1989) but were likely of small 

extent due to the discontinuous nature of the hosts prior to fire exclusion (Gruell, Schmidt, Arno, & 

Reich, 1982). Direct mortality does result from outbreaks, as well as, secondary mortality from beetles 

attacking the weakened trees.

Weather Factors 

Weather factors such as wind and heavy wet snow create breakage and windthrow creating snags and future 

down log habitat. Commonly these involve single trees to small groups.

Figure B3-1. Wind damage Sparta Area, Whitman Ranger District, 2007. Snapped off trees are ponderosa pine 

that average 24” DBH

Diseases

Primarily Indian Paint fungus and dwarf mistletoe, create snags habitat and future down log habitat.

• Indian Paint Fungus will persist in the Snow Basin landscape in the untreated acres of grand fir type.

Indian Paint Fungus is the cause of the existing cull grand fir. All culls are retained in the action 

alternatives. Indian Paint will persist and spread over time in the untreated grand fir vegetation types.

• Dwarf mistletoe will create snags in western larch and Douglas-fir through direct mortality and in 

Douglas-fir and ponderosa pine by weakening trees and predisposing them to bark beetle attack. Dwarf 

mistletoe would persist in the treatments units as well as throughout the untreated areas.

Summary

The Snow Basin action alternatives, within the treated portion of the landscape, are designed to limit the 

severity and extent of insect and disease outbreaks to levels existing before the fire exclusion period. Disease, 

insect and weather events will create snags regardless of management type and extent. The widespread use of 

prescribed fire as part of the action alternatives would create snags. Snags in the untreated portion of the 

landscape would continue to increase due to above factors, as well as, competition mortality.
Appendix B Snow Basin Vegetation Management Project FEIS

470

Appendix B-4 – Landscape Treated Comparison

Tables below reflect total acreage (private, Baker County, and NFS) and NFS only ownership within the Snow 

Basin project area. The acres treated by alternative remains the same in both tables as only projects on NFS 

lands were proposed. Nor does it distinguish the non-forested sites across the landscape [(estimated at 

approximately 16 percent) Fire/Fuels Management Summary].

Table B-4a. All Ownerships Landscape Project Area - Treatments by Alternative

Snow Basin Project 

Area acres 28,545 

Alt. 2 Alt. 3 Alt. 4

Ac treated including

38 acres of Aspen

16,571 15,059 13,920

Percent of landscape 

treated

58% 53% 49%

The Snow Basin project area acres shown reflect private, Baker County and NFS land ownership.

Treatments include harvest, NCT, and prescribed fire activities.

Table B-4b. NFS Ownership only Landscape Project Area - Treatments by Alternative

NFS only Project 

Area acres 26,493

Alt. 2 Alt. 3 Alt. 4

Ac treated including 

38 acres of Aspen

16,571 15,059 13,920

Percent of landscape 

treated

63% 57% 53%

Treatments include harvest, NCT, and prescribed fire activities.
Appendix B Snow Basin Vegetation Management Project FEIS

471

Appendix B-5 – Connectivity/Top 1/3 of Site Potential/UMZ-LMZ

Current Forest Plan (Richmond) Standards/Guidelines for wildlife connectivity

FP Standard- Stands in connectivity shall retain the upper 1/3 of canopy closure site potential. The Upper Level 

Management Zone (UMZ) is the point where a suppressed class of trees begins to develop. This point (defined 

as 75 percent of SDI of a normally stocked stand) is most likely very close to maximum canopy closure on the 

site. The Lower Management Zone (LMZ) is defined as 67 percent (2/3) of the Upper Management zone. 

Therefore, if the UMZ = Max canopy closure, or site potential for canopy closure, then 2/3 of site potential = 

the LMZ.

The connectivity corridor network for Snow Basin was delineated to not only connect LOS and MA-15 areas 

(to the extent possible), but to also link to many of the refugia stands. The riparian habitat conservations area 

network and wild and scenic river corridor (Eagle Creek) will facilitate varying degrees of connectivity.
Appendix B Snow Basin Vegetation Management Project FEIS

472

Appendix B-6 – Estimate Difference in Time (yrs) to Achieve LOS with and without 

Stand Management

Table B-6. Estimated time needed to reach 21 inch DBH with and without management

Average Stand 

Diameter

Diameter growth 

needed to reach 21”

Diameter growth 

rate/decade

Years needed to 

reach 21” ASD

With management 14 7 2.5 28

No Action 12 9 1.5 60
Appendix B Snow Basin Vegetation Management Project FEIS

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Appendix B-7 – Plant Association Crosswalk

Table B-7. Plant Association Cross Walk to Biophysical Group

Plant 

Association

Description Biophysical 

Environment

Biophysical 

Environment 

Group

PAG PVG Biophysic

al Setting

CWS211 Grand fir/big huckleberry Cool/dry G-4 Cool/moist Moist upland forest GFDF

CWF421 Grand fir/queencup beadily Cool/moist G-4 Cool/moist Moist upland forest GFDF

CPG112 Ponderosa pine/Idaho fescue Hot/dry G-8 Hot/dry Dry upland forest PPIN1

CPS231 Ponderosa pine/bitterbrush-bluebunch wheatgrass Hot/dry G-8 Hot/dry Dry upland forest PPIN1

CPG111 Ponderosa pine/bluebunch wheatgrass Hot/moist G-8 Hot/dry Dry upland forest PPIN1

CDG121 Douglas-fir/pine grass Warm/dry G-7 Warm/dry Dry upland forest PPIN1

CDS622 Douglas-fir/common snowberry Warm/dry G-7 Warm/dry Dry upland forest PPIN1

CDS634 Douglas-fir/spiraea Warm/dry G-7 Warm/dry Dry upland forest PPIN1

CDS522 Ponderosa pine/common snowberry Warm/dry G-7 Warm/dry Dry upland forest PPIN1

CWG111 Grand fir/elk sedge Warm/dry G-5 Warm/dry Dry upland forest PPDF1

CWG112 Grand fir/pine grass Warm/dry G-5 Warm/dry Dry upland forest PPDF1

CWS321 Grand fir/spiraea Warm/dry G-5 Warm/dry Dry upland forest PPDF1

CDS625 Douglas-fir/mountain snowberry Warm/moist G-5 Warm/dry Dry upland forest GFDF

CDS711 Ponderosa pine-Douglas-fir/ninebark Warm/moist G-6 Warm/dry Dry upland forest GFDF

CDS722 Douglas-fir/Rocky Mountain maple/ninebark Warm/moist G-6 Warm/moist Moist upland forest GFDF

CWS412 Grand fir/Rocky Mountain maple/ninebark Warm/moist G-6 Warm/moist Moist upland forest GFDF

CWS912 Grand fir/Rocky Mountain maple Warm/moist G-6 Warm/very moist Moist upland forest GFDF

CWS221 Grand fir/big huckleberry Cool/dry G-4 Cool/moist Moist upland forest GFDF

CWS314 Grand fir/common snowberry Warm/dry G-5 Warm/dry Dry upland forest PPDF
Appendix B Snow Basin Vegetation Management Project FEIS

474

Appendix B-8 – Unit Treatments/Logging Systems

Table B-8a. Commercial Treatments/Logging Systems Table by Alternative

Unit 

#

Ac. 

Alt 2

Log 

System

Ac. 

Alt 3

Log 

System

Ac. 

Alt 4

Log 

System

Code

1 25 LF 25 LF 25 LF INT

2 3 S -- -- -- -- INT

3 42 T 42 T 42 T INT

4 16 T -- -- -- -- INT

5 35 T -- -- -- -- HOR

7 64 T 64 T 37 T INT

7A 23 T 23 T 21 T INT

8 19 S 19 S 19 S INT

9 19 S 19 S 19 S INT

10 22 T 21 T 21 T INT

11 57 T 57 T 57 T INT

12 53 T 53 T 53 T INT

13 18 S 18 S 18 S INT

14 9 S 9 S 9 S INT

15 7 S 7 S 7 S INT

15A 2 S 2 S 2 S INT

16 7 S 7 S 7 S INT

17 15 S 15 S -- -- INT

18 28 T 28 T 28 T INT

18A 5 T 5 T 5 T INT

19 41 T 41 T 41 T INT

20 15 S 15 S 15 S INT

20A 14 S 14 S 14 S INT

21 24 T 24 T 24 T INT

22 18 T 18 T 18 T INT

23 7 T 7 T 7 T INT

24 22 T 23 T 23 T INT

25 7 S 7 S 7 S INT

26 6 S 6 S 6 S INT

27 90 T 90 T 90 T INT

27A 67 T 67 T 67 LF INT

28 7 S 7 S 7 S INT

29 29 LF 29 LF 29 LF INT

30 21 S 21 S 21 S INT

31 69 T 69 T 69 T INT

31A 10 T 10 T 10 T INT

31B 4 T 4 T 4 T INT

32 11 S 11 S 11 S INT

33 157 T 157 T 157 T INT

33A 26 LF 26 LF 26 LF INT

34 55 LF 55 LF 55 LF INT
Appendix B Snow Basin Vegetation Management Project FEIS

475

Unit 

#

Ac. 

Alt 2

Log 

System

Ac. 

Alt 3

Log 

System

Ac. 

Alt 4

Log 

System

Code

35 39 S 39 S 39 S INT

36 10 T 10 T 10 T INT

37 19 S 19 S 19 S INT

38 27 T 27 T 27 T INT

39 106 T 106 T 106 T INT

40 29 T 29 T 29 T INT

41 14 T 14 T 14 T INT

43 6 T -- -- -- -- INT

44 31 T 31 T 31 T INT

45 14 S 14 S 14 S INT

45A 5 S 5 S 5 S INT

46 21 S 21 S 21 S INT

47 4 S -- -- -- -- INT

48 194 T 194 T 194 T INT

49 22 T 22 T 22 T HOR

49A 9 T 9 T 9 T HOR

50 87 T 87 T 87 T INT

50A 21 T 21 T 21 T INT

51 48 T 48 T 48 T INT

52 15 S 15 S -- -- INT

54 137 T 137 T 96 T INT

54A 6 T 6 T 6 T INT

54C -- -- -- -- 14 T INT

54D -- -- -- -- 9 T INT

55 30 T 30 T 30 T HOR

56 15 S 15 S 15 S INT

57 102 LF 102 LF -- -- INT

57A 5 S 5 S 16 LF INT

57B -- -- -- -- 18 LF INT

57C -- -- -- -- 7 LF INT

58 51 T 51 T -- -- INT

59 34 T 34 T -- -- INT

60 10 T 10 T -- -- HOR

61 11 T 11 T -- -- INT

62 8 S 8 S -- -- INT

63 43 S 43 S 43 S INT

64 23 T 23 T -- -- INT

65 34 T 34 T 34 T INT

66 39 S 39 S 39 S INT

67 11 S 11 S 11 S INT

68 51 T 51 T -- -- INT

68A -- -- -- -- 9 T INT

68B -- -- -- -- 16 T INT

69 2 S 2 S -- -- INT
Appendix B Snow Basin Vegetation Management Project FEIS

476

Unit 

#

Ac. 

Alt 2

Log 

System

Ac. 

Alt 3

Log 

System

Ac. 

Alt 4

Log 

System

Code

70 8 T 8 T 6 T INT

71 90 S 90 S 34 S INT

71A -- -- -- -- 14 S INT

72 20 S 20 S -- -- INT

73 7 S 7 S 7 S INT

74 10 T 10 T 10 T INT

82 88 S 88 S 70 S INT

83 30 T 30 T -- -- INT

84 44 S 44 S 44 S INT

86 26 T 26 T -- -- INT

87 177 T 177 T 153 T INT

88 8 T 8 T 8 T INT

100 14 S 14 S 14 S INT

101 16 T 16 T 16 T INT

103 378 T 378 T 378 T INT

105 48 T 48 T 48 T INT

106 46 T -- -- -- -- HOR

106A 45 T 45 T 45 T HOR

107 14 T 14 T 14 T INT

108 106 T 106 T 106 T INT

109 30 S 30 S 30 S INT

110 18 S 18 S -- -- INT

111 6 T 6 T -- -- INT

112 17 T 17 T 17 T HOR

112A 13 T 13 T 13 T HOR

113 28 T 28 T 28 LF INT

114 26 T 26 T -- -- HOR

115 458 T 458 T 251 T INT

115B -- -- -- -- 30 T INT

115C -- -- -- -- 66 T INT

116 46 S 46 S 46 S INT

117 14 T -- -- -- -- HOR

119 25 T 25 T -- -- HOR

120 48 T 48 T 48 T INT

121 68 T 68 T 68 T INT

121A 29 T 29 T 29 T INT

121B 33 T 33 T 33 T INT

122 5 S -- -- -- -- INT

123 9 S -- -- -- -- INT

127 20 S 20 S -- -- INT

128 16 T 16 T 16 T INT

128A 8 T 8 T 8 T INT

129 121 T 121 T -- -- INT

129A 4 T 4 T -- -- INT
Appendix B Snow Basin Vegetation Management Project FEIS

477

Unit 

#

Ac. 

Alt 2

Log 

System

Ac. 

Alt 3

Log 

System

Ac. 

Alt 4

Log 

System

Code

129B 4 T 4 T -- -- INT

130 31 T 31 T -- -- HOR

131 9 S 9 S -- -- INT

132 7 S 7 S 7 S INT

133 54 T 54 T 54 T INT

133A 60 T 60 T 60 T INT

134 26 S 26 S 26 S INT

134A 11 S -- -- -- -- INT

135 13 T 13 T 13 T INT

136 12 S 12 S 12 S INT

136A 7 S 7 S 7 S INT

137 31 S 31 S 31 S INT

140 21 T 21 T -- -- INT

141 44 S 44 S -- -- INT

142 15 S 15 S 15 S INT

143 7 S 7 S -- -- INT

200 48 S 48 S -- -- INT

201 20 S 20 S 20 S INT

202 88 T 88 T 88 T INT

203 33 T 32 T 33 T INT

204 108 S 108 S 108 S INT

205 6 S 6 S -- -- INT

205A 2 S 2 S 2 S INT

206 35 S 35 S 35 S INT

207 12 T 12 T 12 T INT

208 59 T 59 T 59 T INT

209 24 S 24 S -- -- INT

210 27 T 27 T -- -- INT

213 19 LF 11 S 11 S INT

214 12 S -- -- -- -- INT

215 13 T 12 T 13 T INT

216 15 S 15 S -- -- INT

216A 14 S 14 S -- -- INT

218 1 S 1 S -- -- INT

219 9 S 9 S 9 S INT

219A 9 S 9 S -- -- INT

220 11 T 11 T 11 T INT

222 14 S 14 S -- -- INT

223 16 S 16 S 16 S INT

223A 4 S 4 S 4 S INT

224 10 S 10 S 10 S INT

224A 3 S 3 S 3 S INT

225 60 T 60 T 60 LF INT

226 20 S 20 S -- -- INT
Appendix B Snow Basin Vegetation Management Project FEIS

478

Unit 

#

Ac. 

Alt 2

Log 

System

Ac. 

Alt 3

Log 

System

Ac. 

Alt 4

Log 

System

Code

227 7 S 7 S -- -- INT

228 40 T 40 T 40 T INT

229 6 S 6 S -- -- INT

230 9 S 9 S 9 S INT

231 13 S 13 S -- -- INT

232 4 S 4 S 4 S INT

234 22 T 22 T 18 T INT

235 7 S 7 S 7 S INT

236 33 T 33 T 33 T INT

238 18 S 18 S 18 S INT

239 10 S 10 S 10 S INT

242 7 T 7 T 7 T INT

244 75 T -- -- -- -- HOR

244A 22 T -- -- -- -- HOR

245 20 S 20 S -- -- HOR

245A 11 S 11 S -- -- HOR

248 10 T -- -- -- -- HOR

249 3 S -- -- -- -- HOR

249A 4 S -- -- -- -- HOR

253 20 S 20 S 20 S INT

253A 7 S 7 S -- -- INT

255 53 T 53 T 31 T INT

255A -- -- -- -- 17 T INT

256 2 S 2 S -- -- INT

257 6 S 6 S -- -- INT

258 17 S 17 S -- -- INT

259 31 S 31 S 31 S INT

259A 18 S 18 S 18 S INT

260 9 S 9 S 9 S INT

261 208 T 208 T 208 T INT

262 25 T 25 T 25 T HOR

263 22 T 22 T 22 T INT

264 43 S 43 S -- -- INT

265 19 S 20 S 19 S INT

265A 21 S 21 S 21 S INT

265B 3 S 3 S 3 S INT

266 42 T 42 T -- -- INT

267 8 T 8 T 8 T INT

268 19 S 19 S 19 S INT

269 73 T 73 T 73 T HOR

270 11 T 11 T 11 T INT

271 165 T 165 T 165 T INT

272 10 S 10 S 10 S INT

272A 9 S 9 S 9 S INT
Appendix B Snow Basin Vegetation Management Project FEIS

479

Unit 

#

Ac. 

Alt 2

Log 

System

Ac. 

Alt 3

Log 

System

Ac. 

Alt 4

Log 

System

Code

273 19 S 19 S 19 S HOR

274 44 T 44 T 44 T HOR

275 4 T 4 T 4 T HOR

275A 2 T 3 T 3 T HOR

276 19 T 19 T 19 T INT

277 15 S 15 S -- -- INT

278 6 S 6 S -- -- INT

279 17 S 17 S 17 S INT

280 22 S 22 S -- -- INT

281 6 S 6 S 6 S INT

300 187 T 187 T 187 T INT

301 352 LF 352 LF 352 LF INT

301A 102 T 102 T 102 T INT

302 7 T 7 T 7 T HOR

303 13 LF 13 LF 13 LF HOR

304 35 S 35 S 35 S INT

304A 15 S 15 S 15 S INT

305 7 T 7 T 7 T INT

306 18 T 18 T 18 T INT

307 78 T 78 T 78 T INT

307A 64 LF 64 LF 64 LF INT

308 29 S 29 S 29 S INT

309 40 S 40 S -- -- INT

310 7 S 7 S -- -- INT

311 181 T 181 T 158 T INT

311A 112 LF 112 LF 107 LF INT

312 67 T 67 T 67 T INT

313 128 T 128 T 128 T INT

314 108 T 108 T 108 T INT

314A 31 LF 31 LF 31 LF INT

315 131 T 131 T 131 T INT

316 105 T 105 T 105 T INT

316A 49 LF 49 LF 49 LF INT

317 21 T 21 T 21 T INT

318 6 T 6 T 6 T INT

319 26 T 26 T 26 T HOR

320 7 T 7 T 7 T INT

321 37 S 37 S 37 S INT

321A 13 S 13 S 13 S INT

322 17 S 17 S -- -- INT

323 18 S 18 S 18 S INT

324 11 S -- -- -- -- INT

325 17 S 17 S -- -- INT

326 25 S 25 S -- -- INT
Appendix B Snow Basin Vegetation Management Project FEIS

480

Unit 

#

Ac. 

Alt 2

Log 

System

Ac. 

Alt 3

Log 

System

Ac. 

Alt 4

Log 

System

Code

327 9 S -- -- -- -- INT

328 5 S -- -- -- -- INT

329 5 S 5 S 5 S INT

329A 7 S 7 S -- -- INT

340 20 S -- -- -- -- INT

341 6 S -- -- -- -- INT

342 11 LF 11 LF 11 LF INT

344 8 T 8 T 8 T INT

345 12 S 12 S 12 S INT

345 5 T 5 T 5 T INT

347 7 T 7 T 7 T INT

348 13 S -- -- -- -- INT

349 24 S 24 S 24 S INT

349A 6 S 6 S 6 S INT

350 31 T 31 T 31 T INT

350A 3 T 3 T 3 T INT

351 13 S 13 S 13 S INT

352 16 S -- -- -- -- INT

353 12 S 12 S 12 S INT

353A 7 S 7 S 7 S INT

400 96 T -- -- -- -- INT

401 67 LF 67 LF 67 LF HOR

402 24 T -- -- -- -- HOR

403 106 T 106 T 106 T INT

404 121 T 121 T 121 T INT

405 77 T 77 T 77 T INT

406 50 T 50 T -- -- HOR

407 30 T 30 T 30 T INT

408 132 T 132 T 132 T INT

409 96 T 96 T 96 T HOR

410 65 T 65 T 65 LF INT

411 435 T 435 T 435 T INT

412 5 T 5 T 5 T INT

413 36 T 36 T 36 T HOR

414 18 T 18 T 18 T INT

415 114 T 114 T 110 T INT

416 14 S 14 S -- -- INT

417 11 T 11 T -- -- INT

418 313 T 313 T 84 T INT

419 13 S 13 S -- -- INT

420 18 T 18 T 18 T INT

420A 78 T 78 T 78 T INT

421 4 S 4 S -- -- INT

422 16 S 16 S 16 S INT
Appendix B Snow Basin Vegetation Management Project FEIS

481

Unit 

#

Ac. 

Alt 2

Log 

System

Ac. 

Alt 3

Log 

System

Ac. 

Alt 4

Log 

System

Code

423 83 T 83 T 83 T INT

424 36 T 36 T 36 T INT

425 37 S 37 S 37 S INT

Due to rounding in GIS, minor differences in acres may occur between this table and reports.

Key:

HOR-commercial overstory removal S-skyline yarding (slopes greater than 30%)

INT- Intermediate commercial T-tractor yarding (slopes less than 30%)

-- - Not applicable to this alternative LF-log forwarder 

Table B-8b. Aspen Treatment Units 

Approximately 15 acres are located with harvest units, and approximately 14 acres are outside of harvest units. 

Specialist reports will reflect the total acres of Aspen treatments.

Unit # Ac. 

Alt 2 

Ac. Alt 

3

Ac. 

Alt 4

Log 

System

Code

A-1 <1 <1 <1 T HOR

A-2 5 5 5 T HOR

A-3 7 7 7 T HOR

A-4 <1 <1 <1 T HOR

A-5 1 1 1 T HOR

A-6 <1 <1 <1 T HOR

A-8 <1 <1 <1 T HOR

A-7 <1 <1 <1 T HOR

A-9 1 1 1 T HOR

A-10 <1 <1 <1 T HOR

A-11 5 5 5 T HOR

A-12 <1 <1 <1 T HOR

A-13 5 5 5 T HOR

A-14 1 1 1 T HOR

A-15 1 1 1 T HOR

A-16 1 1 1 T HOR

A-17 <1 <1 <1 T HOR

A-18 <1 <1 <1 T HOR

A-19 <1 <1 <1 T HOR

A-20 1 1 1 T HOR

A-21 1 1 1 T HOR

A-22 <1 <1 <1 T HOR

A-23 <1 <1 <1 T HOR

A-24 <1 <1 <1 T HOR

A-25 <1 <1 <1 T HOR

A-26 1 1 1 T HOR

A-27 <1 <1 <1 T HOR
Appendix B Snow Basin Vegetation Management Project FEIS

482

Unit # Ac. 

Alt 2 

Ac. Alt 

3

Ac. 

Alt 4

Log 

System

Code

A-28* 1 1 1 T HOR

A-29 <1 <1 <1 T HOR

*A-28 will not have commercial harvest.

Key:

HOR-commercial overstory removal T-tractor yarding (slopes less than 30%)

Table B-8c. Non-commercial Harvest Units

Unit # Ac. Alt 

2 

Ac. Alt 

3

Ac. Alt 

4

1 20 20 20

2 45 45 45

3 9 9 9

4 7 -- --

Key:

-- - Not applicable to this alternative

Table B-8d. Prescribed fire Units

Unit # Ac. Alt 

2 

Ac. Alt 

3

Ac. Alt 

4

F-1 196 196 196

F-2 104 104 104

F-3 218 218 218

F-4 32 32 32

F-4A 40 -- --

F-5 61 61 61

F-6 79 79 79

F-7 134 -- --

F-8 111 111 111

F-9 324 213 213

F-10 288 288 288

F-11 73 -- --

F-12 193 193 193

F-13 1074 1074 1074

F-13A 35 35 35

F-14 159 -- --

F-15 183 -- --

F-16 16 16 16

F-17 7 7 7

F-19 9 9 9

F-20 6 6 6

F-21 23 23 282

F-22 4 -- --
Appendix B Snow Basin Vegetation Management Project FEIS

483

Unit # Ac. Alt 

2 

Ac. Alt 

3

Ac. Alt 

4

F-23 74 74 74

F-24 394 331 331

F-25 29 29 29

F-26 258 258 287

F-27 42 42 42

F-28 34 -- --

F-29 23 24 24

F-30 44 44 44

F-31 3 3 3

F-32 11 11 11

F-33 6 6 6

F-34 693 433 433

F-35 15 15 15

F-37 -- -- 26

F-57 -- -- 61

F-68 -- -- 27

F-71 -- -- 10

F-71A -- -- 34

F-83 -- -- 30

F-115A -- -- 105

F-134A -- 11 11

F-200 -- -- 48

F-340 -- 20 20

F-341 -- 6 6

F-419 -- -- 13

F-421 -- -- 4

Key:

-- - Not applicable to this alternative
Appendix B Snow Basin Vegetation Management Project FEIS

484

Appendix B-9 – Management Area Direct Comparison

Table B-9a. Management Area 1, 1W, and 3

Management Direction Existing Condition Desired Condition Forested Vegetation 

Objective Methods Silviculture Prescriptions

Timber. Tree spacings 

permit optimum growth 

towards the production 

of wood, consistent with 

other resource 

objectives. (FP 4 - 56).

Many acres are 

overstocked with 

diameter growth less than 

potential.

The landscape 

outside of RHCAs, 

wildlife refugia, and 

MA15 consists of 

healthy stands of 

trees with radial 

growth at or near 

potential.

Stands are managed 

within the appropriate 

range of SDI.

Stocking control utilizing 

thinning from below both 

commercial and 

noncommercial.

-HTH- Commercial 

Thinning

-NCT- Non-commercial 

thinning.

-RXFire.

Silvicultural Systems.

Permit a stand structure 

and species composition 

that minimizes serious 

risk of damage by 

mammals, insects, 

disease, or wildfire, and 

will allow treatment of 

existing insect, disease, 

or fuel conditions. (FP 4 -

48).

Overstocked stands of 

low vigor with less 

resistance to bark 

beetles.

Multistory mixed conifer 

stands providing habitat 

for defoliating insects. 

Increased amounts of 

host trees species, as 

compared with the 

historical disturbance 

regime, for defoliating 

insects and root disease.

Dwarf mistletoe exceeds 

HRV.

Overstocked stands of 

fire susceptible sizes and 

species of trees favoring 

wildfire of 

uncharacteristic intensity 

and severity.

Tree stocking levels 

and species 

composition resist 

uncharacteristic 

insect outbreaks and 

disease above the 

HRV.

Tree stocking levels, 

sizes, and species 

composition resist 

uncharacteristic 

wildfire.

Stands are managed 

with the appropriate 

range of SDI.

Restore single story 

stand structure within 

HRV.

Tree species 

composition reflects the 

historical disturbance 

regime.

Stocking control utilizing 

thinning from below both 

commercial and 

noncommercial.

Restore single story structure 

on appropriate sites.

Favor existing seral tree 

species throughout the range 

of silviculture prescriptions.

Regenerate seral tree species.

-HTH- Commercial 

Thinning

-NCT- Non-commercial 

thinning

-HOR- Overstory 

Removal

-RXFire
Appendix B Snow Basin Vegetation Management Project FEIS

485

Insects and disease. 

Minimize serious risk of 

damage from insects 

and disease. (FP 4-48).

Overstocked stands of 

low vigor with less 

resistance to bark 

beetles.

Multistory mixed conifer 

stands providing habitat 

for defoliating insects. 

Increased amounts of 

host trees species, as 

compared with the 

historical disturbance 

regime, for defoliating 

insects and root disease.

Dwarf mistletoe exceeds 

HRV.

Tree stocking levels 

and species 

composition resist 

uncharacteristic 

insect outbreaks and 

disease above the 

HRV.

Stands are managed 

with the appropriate 

range of SDI.

Restore single story 

stand structure within 

HRV.

Tree species 

composition reflects the 

historical disturbance 

regime.

Stocking control utilizing 

thinning from below both 

commercial and 

noncommercial.

Restore single story structure 

on appropriate sites.

Favor existing seral tree 

species throughout the range 

of silvicultural prescriptions.

Regenerate seral tree species.

-HTH- Commercial 

Thinning 

-NCT- Non-commercial 

thinning.

-HOR- Overstory 

Removal.

-RXFire.

Fire. Minimize serious 

risk of damage from 

wildfire. (FP 4 - 48).

Overstocked stands of 

fire susceptible sizes and 

species of trees favoring 

wildfire of 

uncharacteristic intensity 

and severity.

Tree stocking levels, 

sizes, and species 

composition resist 

uncharacteristic 

wildfire.

Manage stands within 

the appropriate range of 

SDI.

Increase fire resistant 

tree species consistent 

with the historical 

disturbance regime.

Decrease multistory 

stand structure.

Increase fire resistant 

sized trees.

Stocking control utilizing 

thinning from below both 

commercial and 

noncommercial.

Restore single story structure 

on appropriate sites.

Favor fire resistant tree 

species throughout the range 

of silvicultural prescriptions.

Increase average stand 

diameter.

-HTH- Commercial 

Thinning 

-NCT- Non-commercial 

thinning.

-HOR- Overstory 

Removal.

-RXFire.
Appendix B Snow Basin Vegetation Management Project FEIS

486

Diversity. Provide and 

maintain an ecologically 

sound distribution and 

abundance of plant and 

animal communities and 

species (FP 4-30).

Single story structure as 

a whole and Single Story 

LOS below the range of 

HRV.

Multistory structure as a 

whole and Multistory LOS 

exceed the range of 

HRV.

There is a mosaic of 

structural stages 

across the 

landscape within the 

historic range of 

variability. Stands 

are of different sizes 

and ages, dispersed 

to provide a mixture 

of forage and 

security cover for big 

game and late seral 

stages for old growth 

dependent species.

LOS stages, MSLT 

and SSLT exceed 

the average HRV.

Manage the landscape 

towards HRV.

Restore single story structure, 

on appropriate sites, by 

converting multistory.

Increase average stand 

diameter.

Increase diameter growth.

-HTH- Commercial 

Thinning 

-NCT- Non-commercial 

thinning.

-HOR- Overstory 

Removal.

-RXFire.

Late and Old Structure. 

(FP Amendment 2).

Single story LOS below 

the range of HRV.

LOS stages, MSLT 

and SSLT exceed 

the average HRV.

Increase the amount of

Single Story LOS

Restore single story structure, 

on appropriate sites, by 

converting multistory.

Increase average stand 

diameter.

Increase diameter growth.

Create Single story LOS from 

surplus (above average HRV) 

Multistory LOS where 

appropriate.

-HTH- Commercial 

Thinning.

-NCT- Non-commercial 

thinning.

-RXFire.
Appendix B Snow Basin Vegetation Management Project FEIS

487

Table B-9b. Management Area 7 - Wild and Scenic- Recreational Section (Eagle Creek Wild and Scenic River Management Plan)

Management Direction Existing Condition Desired Condition Forested Vegetation 

Objective Methods Silviculture Prescriptions

Scenery. Retention. 

(WSRMP 79-2).

Overall undisturbed 

natural appearance.

LOS is exclusively 

multistoried.

Shade tolerant tree 

species are 

dominating in the 

corridor and 

adversely affecting 

the health and vigor 

of the desirable tree 

species.

Overall undisturbed 

natural appearance.

Emphasis on LOS, large 

diameter trees, and 

desirable tree species 

including western larch, 

ponderosa pine, and 

quaking aspen.

Restore seral tree 

species; ponderosa pine, 

western larch, and 

quaking aspen.

Restore Single story 

LOS.

Favor existing seral tree 

species.

-HTH- Commercial 

Thinning 

-NCT- Non-commercial 

thinning.

-RXFire.

Insects and disease. 

Minimize serious risk of 

damage from insects 

and disease. (FP 4-48).

Overstocked stands 

of low vigor with 

less resistance to 

bark beetles.

Multistory mixed 

conifer stands 

providing habitat for 

defoliating insects. 

Increased amounts 

of host trees 

species, as 

compared with the 

historical 

disturbance regime, 

for defoliating 

insects and root 

disease.

Dwarf mistletoe 

exceeds HRV.

Tree stocking levels and 

species composition 

resist uncharacteristic 

insect and disease 

outbreaks.

Stands are managed with 

the appropriate range of 

SDI.

Tree species composition 

reflects the historical 

disturbance regime.

Stocking control utilizing 

thinning from below both 

commercial and 

noncommercial.

Restore single story structure 

on appropriate sites.

Favor existing seral tree 

species by reducing 

competition from shade 

tolerant tree species.

-HTH- Commercial 

Thinning 

-NCT- Non-commercial 

thinning.

-RXFire.

Fire. Minimize serious Overstocked stands Tree stocking levels, Stands are managed with Stocking control utilizing -HTH- Commercial 
Appendix B Snow Basin Vegetation Management Project FEIS

488

Management Direction Existing Condition Desired Condition Forested Vegetation 

Objective Methods Silviculture Prescriptions

risk of damage from 

wildfire. (FP 4 - 48).

of fire susceptible 

sizes, species, and 

structure of trees 

favoring wildfire of 

uncharacteristic 

intensity and 

severity.

species composition, and 

landscape structure 

resist uncharacteristic 

wildfire.

the appropriate range of 

SDI.

Increase fire resistant 

tree species consistent 

with the historical 

disturbance regime.

Increase Single story 

stand structure.

Increase fire resistant 

sized trees.

thinning from below both 

commercial and 

noncommercial.

Restore single story structure 

on appropriate sites.

Favor fire resistant tree 

species throughout the range 

of silvicultural prescriptions.

Increase average stand 

diameter.

Thinning 

-NCT- Non-commercial 

thinning.

-RXFire.

Diversity. Provide and 

maintain an ecologically 

sound distribution and 

abundance of plant and 

animal communities and 

species (FP 4 30).

Single story 

structure as a whole 

and Single Story 

LOS below the 

range of HRV.

Multistory structure 

as a whole and 

Multistory LOS 

exceed the range of 

HRV.

There is a mosaic of 

structural stages across 

the landscape within the 

historic range of 

variability. Stands are of 

different sizes and ages, 

dispersed to provide a 

mixture of forage and 

security cover for big 

game and late seral 

stages for old growth 

dependent species.

LOS stages, MSLT and 

SSLT exceed the 

average HRV.

Manage the landscape 

towards HRV.

Restore single story structure, 

on appropriate sites, by 

converting multistory.

Increase average stand 

diameter by thinning from 

below.

Increase diameter growth 

through stocking control.

-HTH- Commercial 

Thinning 

-NCT- Non-commercial 

thinning.

-RXFire.

Late and Old Structure. 

(FP- Amendment 2).

Single story LOS 

below the range of 

HRV.

LOS stages, MSLT and 

SSLT exceed the 

average HRV.

Increase the amount of 

Single Story LOS

Restore single story structure, 

on appropriate sites, by 

converting multistory.

Increase average stand 

diameter.

Increase diameter growth.

-HTH- Commercial 

Thinning.

-NCT- Non-commercial 

thinning.

-RXFire.
Appendix B Snow Basin Vegetation Management Project FEIS

489

Table B-9c. Forest Plan Management Direction - Aspen Restoration

Management Direction Existing Condition Desired Condition Vegetation 

Objective(s) Methods Silviculture Prescriptions

Diversity. Maintain 

native.....or historic plant 

communities and animal 

species communities.

Provide for all seral 

stages of terrestrial 

...plant associations in a 

distribution and 

abundance to 

accomplish this goal. (FP 

4-30)

Quaking aspen, a 

historic species, is 

in decline primarily 

due to competition 

from conifers. This 

decline is evidenced 

by reduced live 

crowns, dead 

stems, shrinking 

lateral extent of the 

aspen stand, and 

lack of new 

seedlings and 

saplings.

Aspen stands provide 

habitat for a wide variety 

of plant and animal 

species. Pure stands of 

quaking aspen are free 

to grow. The lateral 

extent of individual 

stands in expanding. 

Aspen are healthy with 

high degree of live 

crowns. Root systems 

are able to effectively 

reproduce following a 

disturbance.

Improve aspen habitat 

for plant and animal 

species.

Improve the long term 

viability of aspen stands.

Improve the health of aspen 

stands (including live crown 

ratio and reproductive viability 

of their root systems).

Increase the number of aspen 

within a stand.

-Increase the acreage of aspen.

- HOR- Overstory 

Removal. Remove 

conifers meeting 

minimum 

merchantability using 

Whole Tree Yarding via 

ground based yarding.

- SCN- Weed and 

Clean. Fall noncommercial sized 

conifers.

-Hand pile slash 

exceeding 4 tons per 

acre of less than 12" 

diameter small end.

- Fence to exclude 

livestock and big game 

as needed until aspen 

regeneration is at least 

feet in height.

- Restrict heavy

equipment from the 

aspen stand to prevent 

root damage from 

compaction.

Wildlife. To provide 

habitat for viable 

populations of all existing 

native....species and to 

maintain the overall 

quality of wildlife habitat 

across the Forest. (FP 4-

44)

Quaking aspen, a 

historic species, is 

in decline primarily 

due to competition 

from conifers. This 

decline is evidenced 

by reduced live 

crowns, dead 

stems, shrinking 

lateral extent of the 

Aspen stands provide

habitat for a wide variety 

of plant and animal 

species. Pure stands of 

quaking aspen are free 

to grow. The lateral 

extent of individual 

stands in expanding. 

Aspen are healthy with 

high degree of live 

Improve aspen habitat 

for plant and animal 

species.

Improve the long term 

viability of aspen stands.

Improve the health of aspen 

stands (including live crown 

ratio and reproductive viability 

of their root systems).

Increase the number of aspen 

within a stand.

Increase the acreage of aspen.

- Ensure that 2.5 snags 

>= 21" d.b.h exist post 

activity.

- Leave down logs >= 

12" diameter small end.
Appendix B Snow Basin Vegetation Management Project FEIS

490

Management Direction Existing Condition Desired Condition Vegetation 

Objective(s) Methods Silviculture Prescriptions

aspen stand, and 

lack of new 

seedlings and 

saplings.

crowns. Root systems 

are able to effectively 

reproduce following a 

disturbance.

Timber Management.

To provide for production 

of wood fiber consistent 

with various resource 

objective, environmental 

requirements, and 

economic efficiency. (FP 

4-48)

Quaking aspen, a 

historic species, is 

in decline primarily 

due to competition 

from conifers. 

Removal of conifers 

to free aspen from 

competition would 

present an 

opportunity to 

provide wood 

products (saw 

timber) to local 

economy.

Offer marketable product 

(saw logs) via the sale of 

timber.

Harvest of competing 

conifers of commercial 

size.

Timber Sale using Ground 

based yarding 

HOR- Overstory 

Removal. Harvest 

conifers meeting 

minimum 

merchantability.

Table B-9d. Comparison of Management Area Treated by Alternative

Management Area Existing Alt. 1 ac Alt. 2 ac Alt. 3 ac Alt. 4 ac

Acres treated by alternative

MA 1 16,388 0 8498 8099 6805

MA 1W 1,157 0 368 368 312

MA 3 5,567 0 2303 2278 1946

MA 7 2,702 0 1396 754 705

MA 15 10 0 1 1 1

MA 15-7 592 0 332 72 72

MA 16 77 0 0 0 0

One acre of aspen restoration with no commercial harvest in MA 15
Appendix B Snow Basin Vegetation Management Project FEIS

491

Appendix B-10 – Potential Cumulative Activities List

Table B-10a. Ongoing misc activities for the Snow Basin Project Area.

Activity Note Schedule/Quantified

Routine Road 

Maintenance Actions by 

the FS and County

Most commonly would be blading 

aggregate roads and roadside brushing. 

Can also include cleaning ditches and 

culverts, slough and slide removal.

Ongoing each year. Not 

quantified.

Firewood Gathering Personal use firewood gathering in entire 

project area as allowed.

Ongoing each year. Not 

quantified.

Recreational uses 

(camping hunting, fishing)

Ongoing normal recreational uses as 

allowed.

Ongoing each year. Not 

quantified.

Summer hiking, 

horseback and ATV trail 

use and maintenance

Ongoing normal trail uses and 

maintenance as allowed.

Ongoing each year. Not 

quantified

Snowmobile Trails Ongoing snowmobile trail uses and 

grooming/maintenance as allowed.

Ongoing each year. Not 

quantified

Sled Dog Races Ongoing use over snow Ongoing each year. Not 

quantified

Brooks Ditch Dewatering (at least 80%) of Little Eagle Diversion period July-October 

each year.

Sources: Gayle Hammond, Greg Lind, (WWNF, Whitman RD/TEAMS)

Table B-10b. Ongoing Range Management Activities for the Snow Basin Project Area.

Allotment Name

National 

Forest Acres 

in project area 

Livestock 

Numbers

(Cow/Calf)

Dates of 

Use

Type of 

Permit

Grazing 

System

Boulder Creek* 72 150 7/1-9/30 Term

Defered 

rotation

Trouble Gulch 592 16 6/1-9/30 Term

Seasonlong

Eagle Valley* 19,654 485 6/1-10/31 Term

Defered 

rotation

Goose Creek 8,155 487 6/1-10/30 Term

Defered 

rotation

Sheep Rock 41 0 n/a none

Source: Lynn Smith, Whitman RD * Boulder-Eagle Grazing AMPs NEPA, ongoing, Decision expected 

2013.
Appendix B Snow Basin Vegetation Management Project FEIS

492

Table B-10c. Prescribed Fire Activities for the Snow Basin project area

Project Name Rx Underburn acres Rx Pile Burn acres FY 

Barnard 95 2011

Barnard 680 2009

Sanger 80 2010

East Eagle 50 2010

East Eagle 10 2009

East Eagle 246 2008

Goose 223 2010

Goose 200 2008

Goose 148 2007

Total Acres 348 1384

Source: Kat Naughton, Fuels Specialist; update – Steve Hawkins, Fuels Specialist

Table B-10d. Past Vegetation Management Activities

Timber Sale History 

SaleName Sale Type DateClosed Volume 

sold Acres Subwatershed

Sanger Stewardship 2009 1103 XXX East Fork Eagle

Eagle Salvage Salvage 2003 535 110 Eagle Paddy

Eagle Holcomb Green 2001 4225 820 Eagle Holcomb

Eagle Paddy Green 2000 3,750 586 Eagle Paddy

Little Eagle Green 2000 1700 600 Little Eagle

Basin Salvage Salvage 1998 14 Unknown* Eagle Holcomb

Eagle Forks Salvage Salvage 1995 16.6 Unknown* Little Eagle

Forshey Aspen Aspen 

Restoration 1994 52 10 Eagle Holcomb

Dark Red Green 1993 2900 641 Eagle Holcomb

Gold Eagle Green 1993 12700 3380 Eagle Paddy

Walnut Green 1993 2000 641 Little Eagle

Fizz Eagle Green 1993 6300 2190 Little Eagle

Biddy Beagle Green 1992 900 92 Little Eagle

Dempsey Green 1989 4000 1848 Eagle Holcomb

Bronze Green 1989 360 139 Eagle Paddy

Orchid Green 1988 280 105 Eagle Paddy

Connundrum 

Summit Green 1987 5100 1550 Little Eagle

Holcomb Green 1987 4900 1099 Eagle Holcomb

Little Eagle Basin Green 1987 5800 1267 Little Eagle

Sparta Salvage Salvage 1985 170 37 Eagle Holcomb

Seed orchard-Paddy Green 1985 Unknown* Eagle Paddy

Hung-Chow Salvage Salvage 1984 16 65 Eagle Holcomb
Appendix B Snow Basin Vegetation Management Project FEIS

493

Gello Green 1984 1300 163 Eagle Paddy

Paddy Cull Fiber Green 1982 2500 650 Eagle Paddy

Sparta Salvage 

1980 Salvage 1981 680 183 Eagle Holcomb

Blue Canyon Green 1979 8000 569 Eagle Paddy

Ethel Boulder Green 1977 10700 1112 Little Eagle

Twin Bridges Green 1977 10400 1386 Little Eagle

Lower Little Eagle Green 1969 23600 Unknown* Little Eagle

Paddy Creek Green 1966 9700 Unknown* Eagle Paddy

Gold Creek Green 1963 19400 Unknown* Eagle Paddy

Basin Creek Green 1959 6500 Unknown Eagle Holcomb

Little Eagle Green 1955 2400 Unknown* Little Eagle

Snow Fork Small sale 1954 200 Unknown* Little Eagle

Source: Joe Scarinio, WWNF, Whitman RD *Records are incomplete for these older sales.

Recent Past and Ongoing Vegetation Management on NFS Lands.

• Skookum Timber Sale – Green sale located outside of the Snow Basin project area. 

Harvest of 4.3 mmbf Will be completed in 2012. This sale is within the Bennet Creek 

Eagle Creek subwatershed.

• East Eagle Timber Sale – Green sale located outside of the Snow Basin project area.

Harvest of0.5 mmbf ,Was completed in 2011.This sale is within the East Fork Eagle 

Creek subwatershed.

Vegetation Management on Private forest lands

Private forest lands within and adjacent to the Snow Basin project area, with a couple of 

exceptions, have been recently heavily logged. The timing seems to have coincided with the 

reduction of harvest on NFS lands. These lands were tractor logged no matter the slope. They 

were harvested using a diameter limit apparently set at 10 inches DBH. All trees 10 inches DBH

and greater were harvested leaving these areas at least minimally stocked with seedling to pole 

sized trees. (Based on personal observations – Joe Sciarrino.)

Recent Past Road Projects on NFS Lands.

Road damage repairs associated with the June, 2010 flood event were performed in 2010 and 

2011. This work repaired two road washouts on an emergency basis in the early summer of 2010 

on NFSR 77 (MP 23.6) and NFSR 7745 (MP 1.4) as people and property were stranded behind 

these sites.

Road 77, MP 23.6: Site is located in the Eagle/ Paddy Creek (14G) subwatershed. Approximately 

100 cubic yards (yd3

) of riprap replaced the eroded fill, and the roadbed was reconstructed with 

60 yd3

of rock materials. The roadbed was resurfaced with crushed aggregate. 

Road 7745, MP 1.4: Site is located in the East Fork Eagle Creek (14H) subwatershed, north of the 

project area. Approximately 100 yd3

of riprap replaced the eroded fill, and the roadbed was 

reconstructed with 70 yd3 of rock materials. The roadbed was resurfaced with crushed aggregate 

surfacing. A new thalweg was constructed in the stream.
Appendix B Snow Basin Vegetation Management Project FEIS

494

Additionally, in the Fall of 2011, two bridge abutment repairs associated with the same 2010 

flood event were performed.

Road 7015, MP 4.6: Site is located in the Eagle/ Paddy Creek (14G) subwatershed. 

Approximately 150 yd3

of riprap replaced material that was lost in the front and behind the pilecap 

located on the northwest end of the bridge.

Road 7745, MP 4.4: Site is located in the East Fork Eagle Creek (14H) subwatershed. 

Approximately 160 yd3

of riprap replaced material that was lost in the front and behind the 

abutment, and upstream of the northwest corner of the bridge. Gabion baskets that were displaced 

during the flood event were removed from the streambed and hauled off National Forest Land.

Reasonably Foreseeable Actions

Tremble Aspen Restoration Project

Tremble Aspen Restoration Project (Decision Notice signed in 2010) has one unit located in the 

Snow Basin Project Area. Because it is located adjacent to a county road, there would be no effect 

on the transportation system by this project.

Table B-10e. Planned Prescribed Fire Activities Adjacent to the Snow Basin Project Area

Project Name Prescribed Fire Underburn Acres

Barnard 6000

East Eagle 409

Goose 6568

Skookum 3237

Total 16214

Bridge Abutment Repair

Bridge abutment repairs associated with the 2010 flood event, on FSR #7020 across Eagle Creek 

in Section 6, is anticipated to be accomplished during the next 5 years.

Forest Road 77 Flood Damage Repair

Remaining road damage from severe flooding in the Spring of 2010 will be repaired by Federal 

Highway Administration contract. Western Federal Lands Highway Administration (WFLHD) 

will be the primary agency in charge of completing the NEPA, survey, design, contract 

preparation and administration of the flood repairs. Work is estimated to begin in the summer of 

2012 and be completed by late fall of 2012. Repairs will be made at three road washout sites 

along NFSR 77 in the Eagle Creek/Bennett Creek (14I) subwatershed. All sites are within 

approximately 4 miles of the project area boundary at Eagle Creek, northwest and upstream of the 

project area.

Site Descriptions along Forest Road 77:

Milepost 25.7: Size of the washout is approximately 100' long by 42.5' high. To repair 

this site it will require an access road to be constructed down to the bottom of the site to 

begin work (estimate 520 yd3

excavation). Replacement of the embankment (estimate 

1588 yd3

) and the construction of a toe trench with keyed riprap and bank protection 

riprap (estimate 520 yd3

). The existing perforated pipe at the top of the slope will be 

removed and reinstalled. Roadway aggregate will be placed after embankment is 

complete.
Appendix B Snow Basin Vegetation Management Project FEIS

495

Milepost 26.3: Size of the washout is approximately 340' long by 22' high. Repairs 

include work to key in riprap below the stream bed strata and up the rebuilt slope at a 

height of 10' for bank protection (estimate 737 c yd3

y). The remainder of the fill slope and 

traveled way width will be constructed using smaller riprap and aggregate (estimate 844 

yd3

). Replacement of the damaged culvert in Bennett Creek will be required.

Milepost 28.1: Size of washout is approximately 200' by 41' high. Repairs include 

shifting the centerline of the road into the cutbank approximately 4'-10'; construction to 

stay within the existing road right-of-way and cuts will be left in a roughened, seminatural state. Estimated excavation to be approximately 800 yd3

. Roadway aggregate will 

be placed once subgrade construction is complete. No instream work will be required at 

this site.

Blue Mountains Forest Plan Revision 

This will result in revision of Land Management Plans (Forest Plans) for the Malheur, Umatilla, 

and Wallowa-Whitman Forests. Forest Plans provide strategic, program-level guidance for future 

management of forests and their natural resources for the next 10-15 years. Implementation of 

revised plans is expected in 2014.

Wallowa-Whitman NF Travel Management Plan 

The upcoming Wallowa-Whitman National Forest Travel Management Plan (TMP) which has 

been in progress since 2006 will limit motor-vehicle use to designated roads, trails and areas. It 

will also prohibit cross country travel and the use of closed roads by motor vehicles unless 

designated open for such uses (e.g. as OHV travel routes). Implementation of the travel plan is 

expected to begin in the summer of 2012 with publication of the Motor Vehicle Use Map 

(MVUM). With the implementation of the TMP, some roads that are open now but have had an 

objective to be closed when funding and opportunities allow, will be closed by promulgation 

(approximately 18 miles in the Snow Basin area). Some roads within the project area currently 

identified as closed (maintenance level 1), will be opened for motorized travel by full size 

vehicles and/or OHVs (approximately 6 miles in Snow Basin).

Use of undesignated roads will be allowed only by permit. The timber sale contract is the 

mechanism that will allow the contractor and his employees and subcontractors to travel on roads 

otherwise not designated. It will contain requirements for the contractor to restrict public use on 

these roads via signing or physical closures. Upon completion of the timber sale activities on a 

road, if the road is not a designated road on the MVUM, it will have drainage devices installed 

and be closed in a manner consistent with anticipated future use.

Roads that are designated on the MVUM will be maintained as open for joint use traffic unless 

otherwise stated in the timber sale contract (i.e., the road is determined to be unsafe during 

periods of haul for joint use). In this case, the road would be open to public traffic during times 

when the contractor is not working. If it is a designated road on the MVUM, it will have drainage 

devices installed appropriate to its maintenance level and will be left open to vehicular travel.

Summit Point Underground Power Line (Idaho Power)

Idaho Power has proposed an underground power line extending along Summit Ridge to provide 

service to Summit Point communications site. The proposed route is adjacent to the 77 road from 

the FS boundary toward the Summit Point site. Estimated length is 0.88 miles. Most is within the 

road prism (ditch against the full slope side of the road) with about the last 500 ft angling 
Appendix B Snow Basin Vegetation Management Project FEIS

496

northward to the site. All activity is within section 24. Construction is proposed during summer 

and fall of 2012. This project is outside the Snow Basin area.
Appendix B Snow Basin Vegetation Management Project FEIS

497

Appendix B-11 – Transportation System-Road Maintenance and 

Reconstruction Segments

Table B-11. Road System Maintenance and Reconstruction Segments - Condition and Inventory

Rte_No BEGIN 

TERMINI

END 

TERMINI

SEG 

MILES

OBJ 

ML

OPER 

ML

SURF 

TYPE TSL JUR REMARKS

7005000 FS Bdy 7010 2.4 2 2 NAT Co

in cooperation w/ 

County: clearing, 

surface cross 

drainage, rock 

base

7005150 mp 3.2 mp 3.45 0.25 2 2 NAT D FS

Springs, drain 

and rock 

reinforcement

7005182 7005000 7005160 0.2 2 2 NAT D FS

Surface cross 

drainage

7005200-1 mp 1.6 0 2 2 NAT D FS

Slide area, 

restore road 

Road dropped 

width

7005200-2 mp 2.55 0 2 2 NAT D FS

Repair gully in 

fill shoulder Road 

Dropped slope

7010000 7005000 7015000 5.4 2 2 NAT D FS

Clearing, surface 

drainage, spot 

rock, grid-roll 

existing spot rock

7010130 mp 0.12 mp 0.25 0.1 1 1 NAT D FS

Remove 2 

plugged culverts.

Replace with 

armored dips 

Reconstruct 

second crossing 

under watershed 

improvement 

project, not 

needed for SB. 

Class 4

7010135 7010130

second 

culvert 0.1 1 1 NAT D FS

replace rusted 

culvert Use temp 

culvert-class 4 

7010150 7010 7010175 0.8 1 2 NAT D FS

Relocate out of 

draw Will not 

relocate this road 

Class 4. 

Reconstruct .8 

miles as 

watershed 

improvement 

project by 

elevating road 

surface and 

improving 

drainage. 

7010151 mp 0.2 mp0.3 0.1 1 1 NAT D FS

Spring, drain and 

rock 
Appendix B Snow Basin Vegetation Management Project FEIS

498

Rte_No BEGIN 

TERMINI

END 

TERMINI

SEG 

MILES

OBJ 

ML

OPER 

ML

SURF 

TYPE TSL JUR REMARKS

reinforcement

7010153-1 7010150 MP 0.1 0.1 1 1 NAT D FS

reconstr. jct for 

50' radius curve

7010153-2 MP 0.5 7015 0.3 1 1 NAT D FS

Clearing, 

grading, remove 

boulders, restore 

prism

7010154 MP 0.5 END 0.5 1 1 NAT D FS

clearing, grading, 

remove boulders, 

restore prism

7010155 7010154 end 0.5 1 1 NAT D FS

Clearing, 

grading, remove 

boulders, restore 

prism

7010175 mp 1.0 7010150 0.2 1 2 NAT D FS

Will use existing 

and not relocate. 

Reconstruct .2 

miles as 

watershed 

improvement 

project by 

elevating road 

surface and 

improving 

drainage. 

7015030 7015

across 

Empire 

Gulch 0.02 1 1 NAT D FS

Install culvert in 

stream crossing, 

Empire Gulch, 

intermittent. –

temp culvert 

Class 4

7015075 mp 1.75 0.1 1 1 NAT D FS

Repair fill and 

armor shoulders 

at stream 

crossing

7015080 mp 0.9 7015150 0.9 1 1 NAT D FS

3 springs; failed 

cmp; clearing, 

grading (slides), 

strm crossing @ 

Torchlight-use 

temp culvert 

Class 3

7015082 mp 0.6 end 0.7 1 1 NAT D FS

Clearing, slides, 

grading

7020150 7015075 1.2 1 1 NAT D FS

Clearing and 

grading, 

Perennial stream 

crossing @ 

Torchlight-use 

temp culvert 

Class 3 Install 

Utah dips during 

operation and 

Waterbars for 

road closure. 
Appendix B Snow Basin Vegetation Management Project FEIS

499

Rte_No BEGIN 

TERMINI

END 

TERMINI

SEG 

MILES

OBJ 

ML

OPER 

ML

SURF 

TYPE TSL JUR REMARKS

7020000-1 mp 1.7 0.02 2 2 IMP D FS

repair or replace 

cmp-replace with 

permanent 

culvert Class 4

7020000-2 mp 3.5 0.02 2 2 IMP D FS

repair gully in fill 

shoulder

7020175

7020 mp 

.5 7020150 .25 1 1 NAT D FS

Repair washout, 

install drain dip to 

reduce surface 

erosion hazard

7015150 7015075 7015 1.75 1 1 NAT D FS

Clearing and 

grading, install 

culverts, (two 

temp culvertsclass 4) add 

drain dips to 

reduce surface 

erosion hazard

7020155 7020153 0.2 1 1 NAT D FS

Re-align 

switchback for 

50' radius curve, 

clearing, grading

7020157 7020 end 0.4 1 1 NAT D FS

Remove 

plantation fence, 

clearing, grading, 

drainage

7020162 0.05 0.02 1 1 NAT D FS

spring, drain and 

reinforce

7020175 FS Bdy 0.7 1 1 NAT D FS

Clearing and 

grading (slides) 

beyond scope of 

maintenance

7700000 7015 7030 3.3 3 2 AGG C FS

Repair fill 

failures, slump 

area, clearing, 

cleaning 

drainage 

structures, agg 

surface. Add 

Drain Dip to 

reduce surface 

erosion hazard

7700255 77 mp 0.8 0.8 1 1 NAT D FS

Repair slump 

(spring), repair 

gully, add 

drainage

7700268 7700255

across 

stream 0.02 1 1 NAT D FS

stream crossing, 

ex cmp plugged 

– temp culvertclass 3

7700274 MP 0.25

stream 

crossing 0.1 1 1 NAT D FS

land slide, no 

crossing in 

Conundrom Cr. –

temp culvertclass 1
Appendix B Snow Basin Vegetation Management Project FEIS

500

Rte_No BEGIN 

TERMINI

END 

TERMINI

SEG 

MILES

OBJ 

ML

OPER 

ML

SURF 

TYPE TSL JUR REMARKS

7700285 77 end 0.2 1 1 NAT D FS

Replace CMP, 

consider 

temporary 

installation– temp 

culvert-Class 1

7700310 mp 1.6 0 1 1 NAT D FS

Culvert removed 

from Ehtel Cr, 

perennial flow 

(dropped this 

culvert and 

section of road) 

7700310 mp 0.9 0.02 1 1 NAT D FS

Culvert removed 

from L. Eagle Cr, 

perennial– temp 

culvert-Class 1

7700314 mp 0.6 0 1 1 NAT D FS

Culvert has been 

removed from 

Ethel Cr, 

perennial 

(dropped this 

culvert and 

section of road)

7700314 mp 0.4 0.02 1 1 NAT D FS

No culvert in trib 

to Ethel Cr, 

perennial. – temp

culvert-class 4

7700345 77

across 

stream 

crossi 0.02 1 1 NAT D FS

Replace EX 18" 

culvert in 

intermittent. –

temp culvertclass 4

7700375-1 77 7700377 0.7 2 1 NAT D FS

Slough and slide 

removal, endhaul beyond the 

scope of 

maintenance

7700375-2 MP 0.75 0.05 2 1 NAT D FS Spring, drainage

7700377 7700375 SEC 10 1.1 1 1 NAT D FS

Slough and slide 

removal, 

clearing, endhaul beyond the 

scope of 

maintenance

7700379 77 mp 0.04 0.04 1 1 NAT D FS

Remove 14 loads 

of waste material 

to open road

7725046 77 1.2 2 2 NAT D FS drainage

7725065 7725 Ethel Cr 1 1 1 NAT D FS

Drain springs 

and reinforce 

roadbed, replace 

log culvert in 

Ethel Cr. . – temp 

culvert-class 3

7725090 7725 End 0.9 1 1 NAT D FS

Clearing and 

grading, culvert 
Appendix B Snow Basin Vegetation Management Project FEIS

501

Rte_No BEGIN 

TERMINI

END 

TERMINI

SEG 

MILES

OBJ 

ML

OPER 

ML

SURF 

TYPE TSL JUR REMARKS

in Ethel Cr. –

temp culvertclass 3

7725150 7725 Ethel Cr. 0.4 1 1 NAT D FS

Construct 

surface drainage, 

repair gullies

7730000-1 77 mp 0.4 0.4 2 2 IMP D FS

Clearing, surface 

drainage, Add 

Drain Dip to 

reduce surface 

erosion hazard

7730000-2 mp 1.18 0.04 2 2 NAT D FS

Clear CMP inlet, 

repair road prism

7730227 7730 SEC 10 0.6 1 1 NAT D FS

Clearing, 

grubbing, restore 

prism, remove 

boulders beyond 

scope of 

maintenance

7730260 7730

mp 0.3 

across Gold 

c 0.3 1 1 NAT D FS

Drainage in seg. 

adjacent to and 

across Gold Cr

7730261 7730260

across Gold 

Cr 0 1 1 NAT D FS

culvert has been 

removed -

Dropped from 

project crossing

7730300 mp 1.3 mp1.4 0.1 1 1 NAT D FS

Repair large 

landslide, near 

9/16 sec line

7730360 7730350

across 

perennial str 0.04 1 1 NAT D FS

perennial stream, 

no ex cmp. –

temp culvertclass 3

7732180 mp 0.8 0.02 1 1 NAT D FS

spring, drain and 

rock

7732220 mp 2.05 0.02 2 2 NAT D FS

Drainage and 

reconstr. fill at 

intermittent strm 

crossing

7732270 mp 0.2

across 

perennial str 0.1 1 1 NAT D FS

drainage and 

rock thru 2 

springs, 

perennial stream 

crossing, no ex 

culvert. – temp 

culvert-class 3

7735000-1 77 7720 5.9 2 2 IMP D FS

Clearing, 

drainage, bridge 

@ mp 5.8, Add 

Drain Dip to 

reduce surface 

erosion hazard 

from 7720 to 

7700300
Appendix B Snow Basin Vegetation Management Project FEIS

502

Rte_No BEGIN 

TERMINI

END 

TERMINI

SEG 

MILES

OBJ 

ML

OPER 

ML

SURF 

TYPE TSL JUR REMARKS

7735000-2 7720 FS Bdy 5.9 3 2 AGG C FS

remove rubber 

water diverters 

and replace 

w/drain dips –

Reconstruct as 

Watershed 

improvement 

7735075 mp 0.35 0.02 1 1 NAT D FS

Drainage and 

rock 

reinforcement 

thru spring 

(minor).

7735200 mp 0.25 7735205 0.1 1 1 NAT D FS

stream crossing 

@ 0.27 and 

surface drainage 

to jct 205

7735205 7735200

across

Holcomb 

Cr. 0.05 1 1 NAT D FS

stream crossing 

on Holcumb Cr.

No ex culvert. –

temp culvertclass 4

7735450 mp 0.01 bridge 0.04 2 2 IMP D FS

Repair sloughed 

off shoulders to 

restore 14’ width 

at bridge 

approach.

7735510 saddle end 0.3 1 1 NAT D FS

Clearing, 

grubbing, restore 

prism, remove 

boulders

7735516 7735510 End 0.1 1 1 NAT D FS

Clearing, 

grubbing, restore 

prism, remove 

boulders

7737190 mp 0.8 end 0.7 1 1 NAT D FS

Springs (3) will 

need drainage 

and rock 

reinforcement, fill 

slope washed, 

heavy clearing 

and grading

7739000-1 mp 2.5 0.1 2 2 IMP D FS

Spring in 

roadbed, drain 

and reinforce

7739000-2 mp 4.7 0.1 2 1 NAT D FS

spring, drain and 

reinforce

7739075-1 mp 0.3 0.04 1 1 NAT D FS

trees and brush 

block inlet, 

stream agraded.

Clear inlet and 

outlet area

7739075-2 mp 1.6 0.04 1 1 NAT D FS

trees and brush 

block inlet, 

stream agraded.

Clear inlet and 
Appendix B Snow Basin Vegetation Management Project FEIS

503

Rte_No BEGIN 

TERMINI

END 

TERMINI

SEG 

MILES

OBJ 

ML

OPER 

ML

SURF 

TYPE TSL JUR REMARKS

outlet area

7739205 mp 1.25 0.1 1 1 NAT D FS

Drain spring and 

reinforce 

roadbed

Total 42.21
Appendix B Snow Basin Vegetation Management Project FEIS

504

Appendix B-12 – Transportation System: Road Closure and Decommissioning 

Definitions and Strategies

Closed Road

A closed road is a maintenance level 1 road that is retained as a Forest Service system road, but closed to 

full-sized vehicle access by a variety of methods. 

These roads may be officially open to off highway vehicles (OHVs), or receive OHV use associated with 

cross-country travel. Closed roads receive periodic basic custodial maintenance primarily to maintain 

road drainage. With implementation of travel management, these roads will either be 1) not designated for 

motor vehicle use and will not appear on the Motor Vehicle Use Map (MVUM), or 2) designated for 

OHV use and appear on the MVUM as a motorized trail.

Watershed protection strategies

To prevent surface erosion, closed roads will be closed with a barrier suitable to prevent access by all 

motorized vehicles. If OHV use is approved, barriers will allow for OHV access. Roads that are closed to 

all motorized vehicles will usually have adequate barriers installed, and should be patrolled to prevent 

OHV use. During periodic maintenance, road drainage will be maintained by clearing stream and ditchrelief culverts of debris. Before closure, a hydrologist working with a road manager may recommend 

additional hydrologic stabilization measures such as waterbars, subsoiling, pulling culverts and re-shaping 

stream channels, or other treatments based on land type, terrain, and road characteristics.

Decommissioned Road

A decommissioned road is not needed for future management and is permanently removed from the 

Forest Service transportation system. 

Decommissioning treatments may vary from abandonment, to basic hydrologic stabilization, to total 

recontouring to match existing topography. In all cases, the route markers are removed and 

decommissioned roads are deleted from Forest Service Transportation Atlas.

Watershed protection strategies

The following watershed protection strategies define the level of treatment necessary to hydrologically 

stabilize a decommissioned road. The table at the end of this section displays road segments proposed for 

decommissioning as part of the Snow Basin project along with the treatment strategy (i.e. Types A 

through E, described below) that would likely be applied based upon site specific conditions.

Type A decommissioning

Some roads, such as ridge-top roads or roads in relatively flat areas are decommissioned administratively 

through sign removal, removal of the road from the map, and physical barriers to prevent access. This is 

referred to as abandonment. A road to be abandoned is already stable and is re-vegetating naturally. 

Roads to be abandoned are without stream crossings, are well vegetated and thus resistant to surface 

erosion, and are not prone to mass failure. Estimated costs for administrative decommissioning road 

treatments range from $50 to $500 per road.

Type B decommissioning

These roads have shallow culverts with up to five feet of average fill depth, with few road fills deeper 

than five feet, located in gentle terrain with relatively few stream crossings. Practices used to 

decommission these roads include:

1. decompacting road surface by subsoiling or scarification

2. removing stream crossing and ditch relief culverts and re-shaping banks
Appendix B Snow Basin Vegetation Management Project FEIS

505

3. minor outsloping or cross draining with waterbars

4. full recontouring or barrier at road approach to prevent motorized access

5. revegetating of disturbed soils using native seed and planting, and mulching.

Estimated costs for such road treatments range from $3,000 to $10,000 per mile.

Type C decommissioning

Roads have a mix of shallow and deeper culverts and larger fills (>5 ft avg. depth) on moderate terrain (0

to 30 percent slopes) with some stream crossings. They may occur within degraded riparian habitats 

within 300 feet of fish bearing streams. These roads may also have small bogs or seeps that may threaten 

fill-slope stability that would require special mitigations to provide drainage. Practices to decommission 

these roads typically include all practices described for type B decommissioning plus:

1. removing fills at risk of failure by end-hauling or re-contouring

2. obvious or frequent out-sloping and cross draining

Estimated costs for such road treatments range from $8000 to $15,000 per mile.

Type D decommissioning

Roads have numerous deep culverts and larger fills on steep terrain (30 to 40 percent slopes) with many 

stream crossings. They may occur within degraded riparian habitats within 300 feet of fish bearing 

streams. These roads often have small bogs or seeps that may threaten fill-slope stability. Practices to 

decommission these roads typically include all practices described for type B and C Decommissioning 

plus:

1. removing of all deep culverts and associated fills

2. removing fill and restoring slopes to as near original contours as possible on slopes at risk

Estimated costs for such road treatments range from $10,000 to $20,000 per mile.

Type E decommissioning

Full recontouring: Conditions along these roads vary widely. They may occur on extremely steep terrain 

(>45 percent slopes) with numerous, deep culverts. They may also occur within degraded riparian habitats 

within 300 feet of fish bearing streams. These roads represent direct and often chronic risk of degrading 

fish habitat and water quality. These roads are obliterated by completely removing the fill and restoring 

slopes to as near natural contours as feasible. Estimated costs for type E treatment range from $13,000 to 

$25,000 per mile.

Decommissioning roads to type B-E includes several standard approaches to treatment. Treatments along 

the road prism range from decompaction in areas with stable fill but reduced infiltration and productivity, 

to strong outslopes or complete recontouring in areas requiring fill stabilization. For every road, when 

stream crossing culverts and ditch relief culverts are pulled, the streambanks are re-shaped to match the 

adjacent slopes. Revegetation of treated areas combines seeding with a non-persistent grass mix, 

scattering duff excavated from natural ground above road cut-slope, and transplanting native forbs and 

shrubs which are growing on-site either adjacent to or on the road surface. Natural mulch consisting of 

onsite woody debris, logs, and stumps as well as imported weed-free straw mulch (used in areas where 

natural mulch is scarce) should be used to cover most disturbed ground. Treatments along stream 

crossings require a complete recontour of all fill material with stream channels restored to natural grade 
Appendix B Snow Basin Vegetation Management Project FEIS

506

and dimensions. Each stream crossing receives the same revegetation prescription as the roadbed with a 

special emphasis on transplants of riparian vegetation. At completion, the area will no longer convey 

vehicle traffic, and requires no maintenance.
Appendix B Snow Basin Vegetation Management Project FEIS

507

Table B-12. Decommissioning road segments

Rte_No Length 

GIS mi

BEGIN

TERMINI

END

TERMINI

OBJ 

ML

OPER

ML

TREAT. 

STRATEGY1 REMARKS

7005081 0.17 7005000 7005082 1 1 A Loc. bottom of swale, grown in, access covered by rd 082

7005218 0.22 7005215 SEC 3 1 1 B Loc. in bottom of ephemeral draw. Could use rehab work to remove berm, reshape.

7010197 0.53 7010000 7000040 1 1 B

Draw bottom/low slope loc, blocked, revegetating, Field check full length to 

determine level of recovery

7005013 0.39 7005000 7000045 1 1 A

Draw bottom loc, revegetated w/ trees and shrubs, not visible. Duplicates access of 

rd 012.

7000160* 0.40 7000000 7010000 1 1 B Rd bed has been covered with slash, mostly revegetated

7015010 0.07 7015000 SEC 19 1 1 A Can barely see, goes about 200 ft to aspen exclosure

7015150 0.80 7015000 7015150 1 1 C

Rd is non-existent in segments, draw bottom loc, steep slopes above road, need 

field check on total length. RHCA of Torchlight Cr.

7739025 0.59 7739000 SEC 30 1 1 C

Lower-slope loc, steep side slope, multiple landslides, springs, proximity to stream 

below

7739080 0.31 mp 0.2 SEC 19 1 1 C

Lower slope loc (intermittent below), steep side slope, land slide, not of use to 

logging system

7700323 0.39 7700000 7735275 1 1 B/A

Steep adverse grade (20%) off rd 77, segment is creek bottom but veg'd. Not 

suitable for haul or to reconstr in current loc.

7730510 0.73 7730000 mp 0.7 1 1 C

Draw bottom loc, multiple stream crossings, however popular ATV trail, rehab work, 

cmp's in place

7730271 0.32 7730000 7730300 1 1 C

Springs, proximity to stream (intermittent?), slump, slide, 40%+ SS, jct not graded to 

rd 300.

7732160* 0.35 mp 0.6 SEC 33 1 1 B

draw bottom loc (ephemeral, rehab work needed to remove berms and shape, use 

this entry

7005011 0.31 7005000 SEC 31 1 1 A rd not found on the ground--grown in

7700302 0.25 7700300 SEC 13 1 1 C grown in, landslides, in RHCA (L. Eagle), 50%+ SS, not of use to log sys

* These roads may be used for haul this entry
Appendix B Snow Basin Vegetation Management Project FEIS

508

Appendix B-13 – List of Harvest Unit Activities Operations within RHCAs

Table B-13 Harvesting operations within RHCAs

Alt # Unit

#

Proposed 

Activity

Forwarder 

Acres in 

RHCA

*Acres of 

Disturbanc

e in Trails

Harvest 

Acres

# 

Trails

** # 

Landing

s

# Stream 

Crossings

Stream 

Categor

y

Remarks

2,3,4 1 Forwarding

/ Harvest 2.4 0.1 2.4 3 1 0 1 Activity area is located above 7735 road and is in the outer 100' of the buffer on Little Eagle Creek.

2 4 Forwarding 6.8 0.5 0 2 0 0 4

Activity will occur within the RHCA of a category 4 

stream above road 7739050. No harvest will occur 

within the RHCA, but two forwarder trails will be 

needed to harvest the portions of the unit outside 

the RHCA.

2,3,4 33 Forwarding

/ Harvest 13.8 0.4 4.1 7 4 0 1, 2

All activity is above road 7735. The road will only 

be used as the unit boundary when at least 100' 

from Snow Creek.

2,3,4 34 Forwarding

/ Harvest 8.3 0.4 8.3 8 4 0 1

Activity area is located above 7720 road in the 

outer 100'-150' of the buffers on Little Eagle and 

Spring Creeks. Area with slopes >30% mid-unit will 

be dropped during layout.

2,3,4 57 Forwarding

/ Harvest 8.8 0.4 7.3 10 2 0 1, 4

Activity is located above roads 7700258 and 

7700268. The road will only be used as the unit 

boundary when at least 100' from Spring Creek.

2 213 Forwarding

/Harvest 7.4 0.5 7.4 4 2 0 1 Activity is located above 77 road and is within the outer 200" of the buffer on Eagle Creek.

3, 4 213 Forwarding

/ Harvest 0 0 0 0 0 0 0

Dropped portion of unit within RHCA in Alt 3 and 

Alt 4, changed rest of unit to skyline. No RHCA 

skidding or harvest within unit.

2,3,4 300 Forwarding 2.7 0.05 0 2 0 1 4

Activity will occur along road 700080. One 

crossing of a category 4 stream will need to be 

made at an existing crossing site. Forwarding will 

occur above road 700040 at one spot in the outer 

25' of the class 4 buffer. No harvest will occur 

within the buffer.
Appendix B Snow Basin Vegetation Management Project FEIS

509

Alt # Unit

#

Proposed 

Activity

Forwarder 

Acres in 

RHCA

*Acres of 

Disturbanc

e in Trails

Harvest 

Acres

# 

Trails

** # 

Landing

s

# Stream 

Crossings

Stream 

Categor

y

Remarks

2,3,4 301 Forwarding

/ Harvest

28.7 1.7 5.8 16 5 12 4

Activity will occur along roads 7010, 700060, and 

700040 adjacent to 3 category 4 streams. Roads 

will only be used as boundaries on category 4 

streams when they are at least 50' from stream.

This is only occurring on 5.8 acres of treatment.

2,3,4 303 Forwarding

/ Harvest

4.1 0.05 0.9 2 0 2 4

Activity will occur along road 7010. Two forwarder 

crossings will be required on category 4 stream.

Approximately 1 acre within the RHCA will be 

harvested on uphill side of the 7010 road.

2,3,4 307 Forwarding 13.6 0.2 0 5 1 2 2, 4

Activity will include 2 crossings on a category 4 

stream, and forwarding within a category 2 

buffer. No timber harvest will occur within RHCA's 

and only 1 landing will be needed within RHCA.

Landing will be above road in an existing opening.

2,3,4 311 Forwarding

/ Harvest

10.7 0.3 5.1 9 3 2 2,4

Activity will occur along the 7010 road adjacent to 

a category 4 stream that turns to a category 2 

stream. The road will be used as the boundary 

when at least 100' from the category 2 stream 

and at least 50' from the category 4 stream.

Where the stream is between the unit and the 

road, the full buffer will be applied to the stream.

Both stream crossings will use existing crossing 

sites.

2,3,4 314 Forwardin

g/Harvest 1.7 0.05 1.7 4 1 0 2,4

Activity will occur above the 7015 road 

adjacent to a category 4 stream that turns into 

a category 2 stream. The road will be used as 

the boundary when at least 100' from the 

category 2 stream and at least 50' from the 

category 4 stream.
Appendix B Snow Basin Vegetation Management Project FEIS

510

Alt # Unit

#

Proposed 

Activity

Forwarder 

Acres in 

RHCA

*Acres of 

Disturbanc

e in Trails

Harvest 

Acres

# 

Trails

** # 

Landing

s

# Stream 

Crossings

Stream 

Categor

y

Remarks

2,3,4 316 Forwardin

g/Harvest 2 0.1 1.4 5 2 0 2,4

Activity will occur above roads 7020055 and 

7020162 adjacent to two category 4 streams 

that turn into a category 2 stream. The road 

will be used as the boundary when at least 

100' from the category 2 stream and at least 

50' from the category 4 stream.

2,3,4 342 Forwardin

g/Harvest 5.3 0.25 5.3 3 1 0 1

Activity will occur above road 7015150 and is 

adjacent to a category 1 stream. The road will 

be used as the boundary when at least 100' 

from the category 1 stream.

2,3, 4 401 Forwardin

g/Harvest 1.5 0.1 0.5 5 1 0 4

Activity will occur above road 7000080 and is 

adjacent to a category 4 stream. The road will 

be used as the boundary when at least 50' 

from the category 4 stream.

TOTA

LS

Alt 2 -

117.8

Alts 3, 4 –

103.6

Alt 2 – 5.1

Alt 3,4 -4.1

Alt 2 –

50.2

Alt 3,5 –

42.8

Alt 2 –

85

Alt 3,4 

- 79

Alt 2 – 27

Alt 3,4 –

29

Alt 2 -19

Alt 3,4 -

19

* Acres of disturbance based on a forwarder trail width of 12' multiplied by the total estimated length of forwarder trails within the RHCA.

** Landings will be located on the uphill side of the road, use existing openings where possible, and will be made up of log decks only. No new landing construction 

will occur within RHCA's. Log forwarding is the required ground-based logging system for all ground-based units with RHCA's that must be entered.
Appendix B Snow Basin Vegetation Management Project FEIS

511

Appendix B-14 Scoping Process

Table B-14a. List of letters and emails comments on the proposed received during scoping period

Letter 

#

Agency, Organization, Business, or Individual 

Respondent Date

1. Richard Artley, Grangeville, ID Email comments 2008.12.11

2. B. Sachau, Florham Park, NJ Email comments 2008.12.12

3. Richard Artley, Grangeville, ID Email comments (second 

email) 2008.12.16

4. John Fullerton, LaGrande OR Email comments, 

representing Boise Cascade 2009.01.05

5. Jeff Young, Baker City, OR (Adjacent landowner and 

permittee) 2009.01.17

6. Powder Basin Watershed Council, Baker City, OR 2009.01.20

7. Andy Dennis, Baker City, OR 2009.01.23

8. Associated Oregon Loggers, Salem, OR 2009.01.26

9. American Forest Resource Council, Bend OR 2009.01.27

10. Hells Canyon Preservation Council, LaGrande, OR 2009.01.27

11. Oregon Wild, Eugene, OR 2009.01.29

12. Baker Economic Development, Baker City, OR 2009.01.30

13. US Environmental Protection Agency, Seattle WA 2009.01.30

14. Baker County, Baker City OR 2009.02.03

15. Prairie Wood Products, John Day, OR 2009.02.12

16. Lyle K. Huntington, Molalla, OR 2009.02.16

17. Dennis Cole, Baker City OR 2009.03.20

18. Arvid Andersen, Baker City OR 2009.03.18

Table B-14b. Newspaper Media Articles about Snow Basin Project

Media News Articles about Snow Basin EIS Date

Baker City Record Courier article 2008.12.18

Baker City Herald article 2008.12.24

Forest Policy Research www site, Snow Basin article 2008.12.25

Hells Canyon Journal article 2008.12.31

Baker City Herald - Editorial Board article 2009.01.01

Baker City Herald article 2009.02.05

Baker City Herald article 2009.03.10

Baker City Herald article 2009.05.29

Baker City Herald Editorial 2009.06.10
Appendix B Snow Basin Vegetation Management Project FEIS

512

Appendix B-15 – Potential Wilderness Areas – Undeveloped Areas Inventory 

Methodology

INVENTORY OF POTENTIAL WILDERNESS AREAS and IDENTIFICATION OF

UNDEVELOPED LANDS

For

Snow Basin Vegetation Management Project

Background

This document describes the process and rationale used to inventory for and identify potential wilderness 

areas and undeveloped lands within the Snow Basin planning area on the Whitman Ranger District, 

Wallowa Whitman National Forest. The inventory is based on and consistent with criteria found at 

Forest Service Handbook (FSH) 1909.12 Ch. 71.

Each step of the inventory process is visually documented as a map (see map discussion below). These 

maps can be found at the end of this appendix. The Forest Service used professional judgment and local 

knowledge regarding unique, site-specific conditions of each area being considered for placement in the 

inventory of potential wilderness areas. 

Potential Wilderness Areas (PWA): Areas of potential wilderness identified using inventory 

procedures found in Forest Service Handbook (FSH) 1909.12 Chapter 71 are called potential 

wilderness areas. The inventory is conducted with the express purpose of identifying all lands 

that meet the criteria for being evaluated for wilderness suitability. Potential wilderness area

inventories are not a land designation decision, they do not imply or impart any particular level of 

management direction or protection, they are not an evaluation of potential wilderness (Chapter 

72), and lastly they are not preliminary administrative recommendations for wilderness 

designation (Chapter 73). The inventory of Potential Wilderness does not change the 

administrative boundary of any Inventoried Roadless Areas (IRAs) nor any congressionally 

established Wilderness. 

Typically, PWAs substantially overlap, and/or are contiguous with inventoried roadless areas and 

PWAs may also be contiguous with, wilderness. Some newly inventoried PWAs may be stand 

alone areas that were not identified as ‘roadless areas’ in Appendix C of the Wallowa-Whitman 

Forest Plan and ‘inventoried roadless areas’ as identified in a set of maps in the 2001 Roadless 

Area Conservation Rule (RACR). PWAs overlap inventoried roadless areas only where those 

acres of land are consistent with the inventory criteria (FSH 1909.12 Chapter 71) and may extend 

beyond IRA and wilderness boundaries consistent with inventory criteria.

Methodology

The inventory process was conducted through a sequence of Geographical Information System (GIS) 

runs, using inventory criteria, and application of professional judgment. The judgment applied was 

situational and instance by instance. Each map documents the outcome of the application of specific 

inventory criteria. Inventory criteria were applied in a different order than appears in Chapter 71, but all 

criteria were considered and accounted for as described below under the map headings. Table 3 was used 

to account for and display all polygons greater than one acre in size, as displayed in the maps. 

Examples of typical situations that required applications of professional judgment included, but are not 

limited to:

1. Placement of PWA boundaries along permanent natural or semi-permanent human made features 

such as ridges, streams, topographic breaks, past harvest, or forest roads to facilitate easy on the 

ground identification;
Appendix B Snow Basin Vegetation Management Project FEIS

513

2. Whether to proceed through an isthmus (or pinch point) created between two roads or two harvest 

areas or place a PWA boundary across the isthmus; and

3. Whether to locate a PWA boundary around a peninsula or place the boundary through the 

peninsula.

The scope of this potential wilderness inventory included all acres contained within the project planning 

area boundary and lands outside the boundary sufficient to consider contiguous inventoried roadless 

areas, adjacent federal lands, and acres immediately adjacent to the boundary that do not contain forest 

roads and substantially recognizable stumps. Polygons that met this situation were examined as an entire 

unit (both portions that occur inside and outside of the project planning area) against the potential 

wilderness area criteria found at FSH 1909.12 Chapter 71.1. 

There are no adjacent lands managed by the Bureau of Land Management or any other federal land 

management agency that would need to be considered for their wilderness characteristics during the 

inventory being conducted for Snow Basin. 

The following inventory for the Snow Basin project planning area was created using the inventory criteria found in 

Forest Service Handbook (FSH) 1909.12 Chapter 71.1. Each polygon from Map 4 (described above) were examined 

against the following criteria from FSH 1909.12 Chapter 71.1:

(1) Area is more than 5,000 acres in size

(2) Area contains less than 5,000 acres, but can meet one or more of the following criteria:

2a. Area can be preserved due to physical terrain and natural conditions.

2b. Areas are self-contained ecosystems, such as an island, that can be effectively managed as a separate 

unit of the National Wilderness Preservation System.

2c. Areas are contiguous to existing wilderness, primitive areas, Administration-endorsed wilderness, or 

potential wilderness in other Federal ownership, regardless of their size.

The Forest Service relied on local knowledge and judgment regarding unique, site specific conditions of each area 

being considered for placement on the inventory of potential wilderness. Delineation of areas for potential 

wilderness inventory; locate boundaries at prominent natural or semi-permanent human-made features to facilitate 

easy on-the-ground identification.

Note 1: The following narrative is a comment that applies to all 101 polygons in Table B-15b except the IRA. ‘This 

individual polygon displayed on Map 4 is part of a larger ecosystem and is not a separate, self-contained ecosystem, 

such as found on an island surrounded by water. This polygon cannot be separately preserved due to a physical 

terrain or a natural condition because of the small size and shape of this polygon in relation to the setting of its 

physical terrain. While there are no roads or past timber harvest in this polygon, this condition alone is not a sole 

indication of a natural condition. For example, policies over the past 50 years have excluded fire disturbance from 

much of the area surrounding this polygon creating a context of uncharacteristic or un-natural conditions. In addition 

this polygon is part of a larger, overall continuous ecosystem condition distributed throughout and beyond the 

project area. This isolated, individual polygon cannot be effectively managed as a separate unit of the National 

Wilderness Preservation System.’

Map by map description

Table B-15a. Summary of acres evaluated in the inventory process

Chronology of Acres Reduced leaving the Potential Wilderness Area Acreage Summary

Map 1 – Total acres inventoried 34,492 Total Acres 

Snow Basin Planning Area (Federal 

Ownership): 26,484 
Appendix B Snow Basin Vegetation Management Project FEIS

514

IRA Eagle Meadows: 6,972

Area between IRA/Project: 267

Area E of 7745 Rd between IRA/Private: 769

Map 2 - acres removed from inventory - by past harvest 

activities since 1970. 

18,675 Total acres of past harvest activity since 

1970

(some activities slop over into the IRA, and will 

contribute to lowering the potential wilderness 

areas below)

Map 3 - acres removed from inventory - by roads and 

buffers

4,165 acres road buffer removed outside of past 

harvest since 1970

Map 4 - acres removed from inventory 11,645 acres

(These numbers include remaining areas after 

removing Activities/Rd Buffers. PLUS it includes 

the remaining IRA area after the activities and 

buffers within the IRA were removed.)

Map 5- acres of PWA that meet one or more inventory 

criteria.

797 acres of PWA outside IRAs that meet one 

or more criteria. 

Map 1 

Map 1 displays the Snow Basin analysis area, forest roads, Little Eagle Meadows inventoried roadless 

area (IRA), and Eagle Cap Wilderness. The inventory area is approximately 34,492 acres. The Boulder 

Park IRA is not included in the inventory area as it is geographically separated (by East Fork Eagle 

Creek) from the Snow Basin project planning.

Map 2

Map 2 displays this same area with areas harvested since about 1970. The entire planning area was 

overlain with the district's GIS/FACTS harvest layer which displays locations of timber harvest over the 

past 40 to 45 years. Timber harvest since 1970 likely results in features such as stumps and skid trails, 

which are evident; therefore, all acres depicted do not meet FSH 1909.12 Chapter 71.11(9) handbook 

inventory criteria and will be removed from the inventory in Map 3. It is important to note that evidence 

of past harvest, such as stumps and skid trails, may remain visible on the landscape much than the 40 to 

45 years represented by the FACTS database. As discussed in the vegetation section of Chapter 3, a large 

proportion of the project area has been harvested. Reliance on data from query of GIS/FACTS as a 

substitute for “evidence of past harvest” over estimates the acres within the Snow Basin project area that 

meet FSH 1909.12 Chapter 71.11(9) handbook inventory criteria for potential wilderness. This almost 

certainly results in more acres carried forward in this inventory than would have resulted from field 

verification of evidence of past harvest.

Map 3 

Map 3 displays this same area with past harvest areas since 1970 and roads with 300 foot buffers. The 

entire planning area was overlain with the district's GIS forest roads layer. Forest roads have associated 

permitted uses and maintenance. Road maintenance and many permitted uses have removed trees and 

created visible stumps in the corridor. These activities are expected to continue into the future. 

During initial road construction trees were felled within a clearing limit to provide for safe and efficient 

construction and future operational safety of road users. Clearing distances away from the edge of a road 
Appendix B Snow Basin Vegetation Management Project FEIS

515

varied by many factors including tree height, topographic slope, and other factors. Past clearing of trees 

along forest roads created stumps that are evident and recognizable. 

Road maintenance occurs to varying degrees along each road according to assigned maintenance level 

and available funding. Road maintenance includes the periodic clearing of brush and the falling of danger 

trees that present a hazard to forest visitors, employees and contractors as defined by the Region 6 Danger 

Tree Policy (2007). The distance of the hazard removal away from a road varies by tree height, 

topographic slope, and other factors. Past removal of danger trees along forest roads crated stumps that 

are evident and recognizable.

Harvest of trees for personal-use firewood is permitted, and travel management regulation allows the use 

of vehicles for access for a distance of up to 300 feet from the forest roads designated for motor vehicles.

Past firewood gathering along open forest roads created stumps that are evident and recognizable.

Stumps may not be present along every mile of forest road; for example roads adjacent to a meadow, 

talus, or a lake. The judgment applied in setting a PWA boundary is intended to balance inventory 

criteria regarding exclusion of part harvest with a straightforward approach to on-the-ground 

identification of where human activities were likely to occur. 

Based on local knowledge, and professional judgment regarding the evidence of recognizable stumps, 

skid trails, etc. which occur to varying degrees adjacent to forest roads (as described above) and to 

facilitate easy on-the-ground identification of a uniform, measurable boundary along a semi-permanent, 

human-made feature; the boundary was set at 300 feet each side of the forest road.

This boundary is fully consistent with and supported by the following inventory criteria.

• FSH 1909.12 at 71.1(3); potential wilderness areas do not contain forest roads therefore all acres 

that are a forest road, along with a 300 foot buffer will be removed from the inventory in Map3.

• FSH 1909.12 at 71.1(9); acres with evidence of past logging and roads will be removed from the 

inventory in Map 2.

• FSH 1909.12 at 71; locate potential wilderness area boundaries at semi-permanent, human-made 

features to facilitate easy on-the-ground identification of a boundary.

Therefore, highlighted acres along forest roads (approximately 4,165 acres) in Map 3 will be removed 

from the inventory.

Map 4

Map 4 displays those areas left after the roads, with buffers, and past harvest areas since 1970 have been 

removed from consideration. It is important to note that reliance on data from the query of GIS/FACTS as 

a substitute for “evidence of past harvest” over estimates the acres within the Snow Basin project area that 

meet FSH 1909.12 Chapter 71.11(9) handbook inventory criteria for potential wilderness. It is likely that 

on-the-ground observation of these acres (to identify evidence of past harvest, e.g. stumps and skid trails), 

or evaluation of aerial photographs (e.g. for noticeable interruptions of canopy closure resulting from 

harvest) would have resulted in fewer acres displayed on Map 4. 

Individual polygons less than 1 acre in size were eliminated from further study. The removal of these 

polygons resulted in one hundred and one (101) individual polygons, ranging in size from 1 acre to 

approximately 1,782 acres, covering about 5,004 acres total. 

Map 4 displays 101 polygons, each with its own unique, numeric identifier. These polygons do not have 

substantially recognizable stumps, do not contain forest roads, and each polygon boundary is greater than 

or equal to 300 feet from a forest road.
Appendix B Snow Basin Vegetation Management Project FEIS

516

Ninety six (96) polygons are not contiguous with the inventoried roadless area or wilderness due to the 

presence of forest roads and/or past timber harvest activity (Table B-13c and Map 4). All 101 individual 

polygons are part of a larger ecosystem and none are separate, self-contained ecosystems, such as found 

on an island surrounded by water. None of the 101 polygons can be separately preserved due to a physical 

terrain or a natural condition in part because of their small size and in part because they are each part of a 

larger, overall continuous ecosystem condition distributed throughout and beyond the project area. Based 

on the discussion above, local knowledge, and professional judgment none of these individual polygons 

met inventory criteria at 71.1, (2a), (2b), or (2c) and therefore will not be brought forward as potential 

wilderness areas. 

Five (5) polygons are contiguous with the Little Eagle Meadows IRA. These polygons (indentified as 3, 

4, 6, 8, and 97) generally met criteria 71.1 (2c) but no other criteria. These contiguous acres are retained 

in the inventory and will be displayed in Map 5.

The Little Eagle PWA was examined as a separate polygon from the 96 polygons discussed above. The 

IRA was examined with the same techniques as each of the individual polygons. The IRA was not 

assigned a numerical identifier because it has a commonly recognizable name that allows for easy 

identification. Approximately 6,641 acres of the Little Eagle IRA met wilderness potential criteria. 

Approximately 331 acres of the IRA did not meet potential wilderness area inventory criteria primarily 

because these acres had evidence of substantially recognizable stumps, contained forest roads, or were 

within 300 feet of a forest road. This inventory does not change the administrative boundary for the IRA 

which was established in the Roadless Area Conservation Rule (2001).

An outcome of the PWA inventory process was the identification of isolated polygons of other 

undeveloped lands. These polygons did not meet inventory criteria as potential wilderness areas and they 

are not inventoried roadless areas or a designated wilderness area. Each individual polygon of isolated 

land has no recent history of harvest activity and does not contain forest roads. They are stand-alone 

polygons of varying acreages all less than or equal to 1,782 acres within the project planning area. Other 

undeveloped lands will be brought forward and displayed on Map 5

Map 5

Map 5 displays the Forest Service’s completed inventory of potential wilderness areas in and adjacent to 

the Snow Basin project planning area. The potential wilderness area is Little Eagle Meadows includes 

7,438 acres, with 797 outside the IRA and approximately 145 acres are within the Snow Basin project 

planning area.

Map 5 also displays 96 polygons of other undeveloped lands within the Snow Basin project planning area. 

These 4,207 acres of land have not been harvested since 1970, do not contain forest roads4

, and are not 

designated as a wilderness area or inventoried as a potential wilderness area. As explained above, many 

of the acres identified as other undeveloped on Map 5 likely contain evidence of past harvest (See 

Chapter 3, Vegetation discussion).

 4 Forest road – A road wholly or partly within or adjacent to and serving the National Forest System that the Forest

Service determines is necessary for the protection, administration, and utilization of the National Forest System and 

the use and development of its resources. Road – A motor vehicle route over 50 inches wide, unless identified and

managed as a trail (36CFR §212.1)
Appendix B Snow Basin Vegetation Management Project FEIS

517

Table B-15b. Other undeveloped lands.

Polygon 

ID

Acres 

(Rounded 

to nearest 

acre)

FSH 

1909.12 

71.1(1)

FSH 

1909.12 

71.1 

(2a.)

FSH 

1909.12 

71.1 (2b.)

FSH 

1909.12

71.1 (2c.)

Comments

1 8 N N N N

2 1 N N N N

3 11 N N N Y Adjacent to IRA and FP 

PWA, added to 

inventory

4 59 N N N Y Adjacent to IRA and FP 

PWA, added to 

inventory

5 2 N N N N

6 7 N N N Y Adjacent to IRA and FP 

PWA, added to 

inventory

7 2 N N N N

8 229 N N N Y Adjacent to IRA and FP 

PWA, added to 

inventory

9 11 N N N N

10 1 N N N N

11 81 N N N N

12 1 N N N N

13 46 N N N N

14 97 N N N N

15 25 N N N N

16 74 N N N N

17 5 N N N N

18 12 N N N N

19 3 N N N N

20 268 N N N N

21 4 N N N N

22 1 N N N N

23 6 N N N N

24 13 N N N N

25 7 N N N N

26 18 N N N N

27 2 N N N N

28 11 N N N N

29 1 N N N N

30 5 N N N N

31 99 N N N N

32 2 N N N N

33 6 N N N N

34 6 N N N N

35 6 N N N N

36 70 N N N N

37 22 N N N N

38 1 N N N N

39 73 N N N N

40 110 N N N N
Appendix B Snow Basin Vegetation Management Project FEIS

518

Polygon 

ID

Acres 

(Rounded 

to nearest 

acre)

FSH 

1909.12 

71.1(1)

FSH 

1909.12 

71.1 

(2a.)

FSH 

1909.12 

71.1 (2b.)

FSH 

1909.12

71.1 (2c.)

Comments

41 4 N N N N

42 28 N N N N

43 50 N N N N

44 39 N N N N

45 5 N N N N

46 8 N N N N

47 3 N N N N

48 1 N N N N

49 1 N N N N

50 34 N N N N

51 10 N N N N

52 1782 N N N N

53 1 N N N N

54 8 N N N N

55 8 N N N N

56 1 N N N N

57 21 N N N N

58 9 N N N N

59 19 N N N N

60 1 N N N N

61 16 N N N N

62 1 N N N N

63 1 N N N N

64 4 N N N N

65 54 N N N N

66 6 N N N N

67 2 N N N N

68 6 N N N N

69 16 N N N N

70 2 N N N N

71 5 N N N N

72 2 N N N N

73 2 N N N N

74 40 N N N N

75 21 N N N N

76 26 N N N N

77 265 N N N N

78 72 N N N N

79 22 N N N N

80 45 N N N N

81 2 N N N N

82 10 N N N N

83 41 N N N N

84 47 N N N N

85 10 N N N N

86 23 N N N N

87 1 N N N N

88 7 N N N N

89 4 N N N N
Appendix B Snow Basin Vegetation Management Project FEIS

519

Polygon 

ID

Acres 

(Rounded 

to nearest 

acre)

FSH 

1909.12 

71.1(1)

FSH 

1909.12 

71.1 

(2a.)

FSH 

1909.12 

71.1 (2b.)

FSH 

1909.12

71.1 (2c.)

Comments

90 2 N N N N

91 3 N N N N

92 2 N N N N

93 2 N N N N

94 22 N N N N

95 2 N N N N

96 2 N N N N

97 491 N Y N Y Adjacent to IRA and FP 

PWA, added to 

inventory

98 224 N N N N

99 10 N N N N

100 2 N N N N

102 49 N N N N

101 .4 N N N N

103 .5 N N N N

104 .3 N N N N

105 .2 N N N N

106 .6 N N N N

107 .6 N N N N

111 .4 N N N N

112 .4 N N N N

113 .9 N N N N

114 .4 N N N N

115 .7 N N N N

116 .6 N N N N

117 .03 N N N N

118 .8 N N N N

119 .5 N N N N

120 .2 N N N N

Total 5004

INVENTORY RESULTS

In summary the following areas meet one of the inventory criteria as potential wilderness areas and are 

displayed in Map 5.

Table B-15c. Final Inventory of Potential Wilderness Areas 

Potential Wilderness Identifier (Polygon ID) Acreages Rounded

3 11

4 59

6 7

8 229

97 491
Appendix B Snow Basin Vegetation Management Project FEIS

520

Total 797 acres
Appendix B Snow Basin Vegetation Management Project FEIS

521

Map 1. Existing IRAs
Appendix B Snow Basin Vegetation Management Project FEIS

522

Map 2. Past Activities
Appendix B Snow Basin Vegetation Management Project FEIS

523

Map 3. Road Buffers
Appendix B Snow Basin Vegetation Management Project FEIS

524

Map 4. Acres Not Containing Roads
Appendix B Snow Basin Vegetation Management Project FEIS

525

Map 5. Potential Wilderness/Undeveloped Lands
Appendix B Snow Basin Vegetation Management Project FEIS

526

Map 6. Alternative 2 Potential Wilderness/Undeveloped Lands 
Appendix B Snow Basin Vegetation Management Project FEIS

527

Map 7. Alternative. 3 Potential Wilderness/Undeveloped Lands
Appendix B Snow Basin Vegetation Management Project FEIS

528

Map 8. Alternative 4 Potential Wilderness/Undeveloped Lands
Appendix B Snow Basin Vegetation Management Project FEIS

529

References

USDA Forest Service. 2007. Forest Service Handbook 1909.12, Chapter 70. Wilderness Evaluation. 

National Headquarters (WO). Washington, D.C. 
Appendix B Snow Basin Vegetation Management Project FEIS

530

Appendix B-16 – Climate Change Synopsis for the Blue Mountain region of NE 

Oregon

David W. Salo, Forest Hydrologist, WWNF

August 24, 2010

The following synopsis characterizes climate change trends for use in NEPA effects analysis. It is based 

on a white paper titled “Climate Change and Potential Climate Effects on National Forest System Lands 

in the Blue Mountains, Northeast Oregon and Southeast Washington, Part 1: Climate Baseline”, prepared 

by Bob Gecy. Bob is a Forest Plan revision member on the Blue Mountain revision team. Bob used local 

data from National Weather Service stations, Historical Climate Network sites, SNOTEL stations and 

stream gaging stations located throughout the Blue Mountains to develop trends for temperature, 

precipitation, and streamflow. The following trends and predictions are stated for both the Pacific 

Northwest region (PNW) and more specifically for the Blue Mountain region of NE OR.

Temperature: Temperature increases in the PNW since 1950 have been documented at 0.2 degrees C per 

decade. Projected temperature increases from the year 2000 for the PNW are 1.2 degrees C during the 

2020s, 2.0 degrees C by the 2040s, and 3.3 degrees C by the 2080s. Expected warming in the 21st century 

will be a substantially greater than in the 20th century. For NE OR, the rate of change mimics that 

observed for the PNW since 1970. Since 1993, Bob notes that average annual temperatures have been 

higher than the 30-year moving average for 14 consecutive years for NE OR. That trend was broken 

(likely momentarily) during 2008. Continuation of this trend for several more decades means that the 

coolest years will be warmer than the warm years of the past 30 years. Changes in temperature can also be 

noted monthly and seasonally. From 1970 until 2005, monthly average temperatures have increased for 

every month except during November and December where slight decreases were noted. Seasonally 

between 1970 and 2005, winters (Dec.-Feb.) have warmed slightly (+ 0.4  ̊C); spring temperatures (Mar.-

May) have warmed the most (+ 1.1 ̊ C); summers (Jun.-Aug) have warmed + 0.7 ̊ C; and fall 

temperatures have warmed the least (+ 0.1 ̊ C).

Precipitation: Annual precipitation for the PNW increased 13-38 percent during the 20th century. Climate 

models for the PNW predict increased winter precipitation and decreased summer precipitation, with 

higher overall (annual) precipitation. This means a continuation of trends observed during the past 

century. These trends do not reflect what is happening in NE OR. The overall decline in annual 

precipitation for NE OR is about 9 percent. Variability in precipitation trends in NE OR occurs both 

seasonally and geographically. Seasonal changes in precipitation for NE OR show that winter (Dec.-Feb) 

has changed the most (about 1 inch, or 16 percent). Wet season precipitation (Oct.-April) has declined 1.6 

inches or 9 percent in NE OR. Summer precipitation (Jun.-Aug.) has seen an average of 2.1 percent 

increase, with some stations experiencing a near doubling of summer precipitation. Spatially, it appears 

that precipitation has increased an average of 5 percent with stations located north and east of Interstate 

84, and decreased an average of 5 percent south and east of Interstate 84.

Considering the combined effects of Temperature and Precipitation changes and trends, the following

scenarios are possible or likely (see also IPCC Regional summaries and papers compiled by the Climate 

Impacts Group and Climate Change Resource Center websites):

• Increase in the percentage of winter precipitation that falls as rain, rather than snow

• Earlier snowmelt

• Increased potential for higher peak streamflows and extensive droughts

• Decline in late season streamflows

• Extended growing seasons
Appendix B Snow Basin Vegetation Management Project FEIS

531

• Lower soil moistures

• Increased late-season moisture stress on vegetation
Appendix B Snow Basin Vegetation Management Project FEIS

532

Appendix B-17 – DEIS Commenters

Table B-17. List of DEIS Commenters

Letter Number Name, City, State Date Letter Was Received

D08 Charles Burley

Bend, OR 97709 04/12/11

D09 Richard Harris

Baker City, OR 9781 04/09/11

D12 Steve Brooks

Culver, OR 97734 05/03/11

D13 John Fullerton

La Grande, OR 97850 05/05/11

D14 David Mildrexler

La Grande, OR 97850r 05/09/11

D15 Carmelita Holland

Richland, OR 97870 05/10/11

D17 Forest Schroeder

Baker City, OR 9781 05/11/11

D18 Jennifer Schemm 05/16/11

D20 Bill Whitaker

La Grande, OR 97850 05/20/11

D21 Barbara Tomleson 

Portland, OR 97219 05/20/11

D23 Steve Graven 05/20/11

D24 Lydia Garvey 

Clinton, OK 73601 05/23/11

D25 Pete Sandrock 

Portland, OR 97202 05/23/11

D26 James Carlson

Mitchell, OR 97750 05/23/11

D30 L. McCleary 05/20/11

D31 Dick Fleming

Baker City, OR 97814 05/24/11

D32 Jon & Julie Sallquist

Baker City, OR 97814 05/23/11

D33 Sonja and Larry Weems

Herinston, OR 05/24/11

D35 Dave Wiley

Sublimity, OR 97385 05/25/11

D36

Associated Oregon Loggers Inc 

(Rex Storm)

Salem, OR 97309

05/26/11

D37 Arvid Anderson

Baker City, OR 9781 5/26/11

D38 Baker County

Baker City, OR 97814 05/26/11

D39 Lyle Defrees

Baker City, OR 97814 05/27/11

D40 Bob Bastian

Klamath Falls, OR 97601 05/27
Appendix B Snow Basin Vegetation Management Project FEIS

533

D40

Jim James 

Oregon Small Woodlands Association

Salem, OR

05/27/11

D42 Robert Ellingson 05/27/11

D43 Ken Bothems

Richland, OR 97870 05/27/11

D43 Charles Hill

Baker City, OR 9781 05/27/11

D43 Gene & Elva Chetwood

Richland, OR 97870 05/27/11

D43 John E. Johnston

Richland, OR 97870 05/27/11

D43 Roseanne Riggs

Richland, OR 97870 05/27/11

D43 Bud Terry

Richland, OR 97870 05/27/11

D43 Lar Adeninker

Richland, OR 97870 05/27/11

D43 Mary Chanta

Richland, OR 97870 05/27/11

D43 Rick Bryan

Halfway, OR 97834 05/27/11

D43 Tamera J. Tyler

Halfway, OR 97834 05/27/11

D43 Stan M. Kaesennyn

Halfway, OR 97834 05/27/11

D43 Frank Holbriten

Halfway, OR 97834 05/27/11

D43 Marcia Lincoln

Richland, OR 97870 05/27/11

D43 Connie Forsea

Richland, OR 97870 05/27/11

D43 Amy Koskil

Oxbow, OR 97840 05/27/11

D43 Rose Darting

Halfway, OR 97834 05/27/11

D43 Jody Leasey

Halfway, OR 97834 05/27/11

D43 Jake Remey

Halfway, OR 97834 05/27/11

D43 Mitchell H. Weis

Halfway, OR 97834 05/27/11

D43

D63

Irene Jerome 

John Day, OR 97845

05/27/11

05/31/11

D43

D68

Don Glerup

Baker City, OR 97814

05/27/11

05/31/11

D43 Elizabeth Harmon

Richland, OR 97870 05/27/11

D43 Dave & D'Anna D. Yakel

Richland, OR 97870 05/27/11

D43 Lee Chaffer

Richland, OR 97870 05/27/11

D43 Brandon & Teresa Chaffee

Richland, OR 97870 05/27/11
Appendix B Snow Basin Vegetation Management Project FEIS

534

D43 Tonin Paul Dahan

Richland, OR 97870 05/27/11

D43 J.J. Sutherlin

Halfway, OR 97834 05/27/11

D43 Shawn Landers

Halfway, OR 97834 05/27/11

D43 Brad Plakil 

Adams, OR 97810 05/27/11

D43 Al Johnson 

Vancouver, WA 98685 05/27/11

D43 Darl S. Whies 

Forest Grove, OR 97116 05/27/11

D43 Dwight & Debbie Saunders

Richland, OR 97870 05/27/11

D43 Hill

Richland, OR 97870 05/27/11

D43 Gar Rovanq

Richland, OR 97870 05/27/11

D43 Harold Dietzen

Richland, OR 97870 05/27/11

D43 Angie Tucker

Richland, OR 97870 05/27/11

D43 Slany (Stanley) Beiutis 

Clatskanie, OR 97016 05/27/11

D43 Tom Cast

Richland, OR 97870 05/27/11

D43 Tom Sherwood

Richland, OR 97870 05/27/11

D43 Gary Haran 

Halfway OR 97870 05/27/11

D43 Alenepep Walfer 

Bend, OR 97702 05/27/11

D43 Milton Prowell

Baker City, OR 97814 05/27/11

D43 Lane Parry

Baker City, OR 97814 05/27/11

D43

D73

Larry McCalden

Baker City, OR 97814

05/27/11

05/31/11

D43

D52

BCPWA

Baker City, OR 97814

05/27/11

05/27/11

D43 Shyle Digs

Baker City, OR 97814 05/27/11

D43

D48

Vernan & Alice Knapp

Baker City, OR 97814

05/27/11

05/27/11

D43 John Saylor

Halfway, OR 97834 05/27/11

D43

D53

Robert Parker

Baker City, OR 9781

05/27/11

05/27/11

D43 Robert Wheeler

Baker City, OR 9781 05/27/11

D43 Janece Kennedy

Richland, OR 97870 05/27/11

D43 Ken Gard

Richland, OR 97870 05/27/11
Appendix B Snow Basin Vegetation Management Project FEIS

535

D43 Ray Spencer

Halfway, OR 97834 05/27/11

D43 Marvin T. & Beverly A. Lee

Richland, OR 97870 05/27/11

D43 Jana Terry

Richland, OR 97870 05/27/11

D43 Steve Passlor

Richland, OR 97870 05/27/11

D43 Luke Hearne

Richland, OR 97870 05/27/11

D43 Laura Bly

Halfway, OR 97834 05/27/11

D43 Donald R. Storm

Halfway, OR 97834 05/27/11

D43 Wayne C. & Lena E. Chetwood

Halfway, OR 97834 05/27/11

D43 Mike Lattim

Halfway, OR 97834 05/27/11

D43 Everett Devine

Richland, OR 97870 05/27/11

D43 Sharry Dawning

Halfway, OR 97834 05/27/11

D43 Pattie Barker

Portland, OR 97230 05/27/11

D43 Mack & Angela Chetwood

Halfway, OR 97834 05/27/11

D43 Brian D. Peniwick

New Bridge, OR 05/27/11

D43 Dal Thomas

Halfway, OR 97834 05/27/11

D43 Chay Rarm

Halfway, OR 97834 05/27/11

D43

D75

Cass Vanderwiele

Baker City, OR 97814

05/27/11

05/31/11

D43

D64

Doug Heiken 

Eugene, OR 97440

05/27/11

05/31/11

D43

D56

Robert Black

Baker City, OR 97814

05/27/11

05/27/11

D43 Brook A. Cruz

Richland, OR 97870 05/27/11

D43 Margaret Gristy

Richland, OR 97870 05/27/11

D43 Gary Holland

Richland, OR 97870 05/27/11

D43 James T. & Amanda Infor

Baker City, OR 97814 05/27/11

D43 Kyle Ransom

Richland, OR 97870 05/27/11

D43 John Randall

Richland, OR 97870 05/27/11

D43 Dan Elkey

Richland, OR 97870 05/27/11

D43 Alanas Lombank 

Adams, OR 97810 05/27/11
Appendix B Snow Basin Vegetation Management Project FEIS

536

D43 Robert L. Peickert 

The Dalles, OR 97058 05/27/11

D43 Baynl & Liz L. Landers

Richland, OR 97870 05/27/11

D43 Patricia L. Stichley

Richland, OR 97870 05/27/11

D43 Donnalee Moorcraft

Richland, OR 97870 05/27/11

D43 Alvin L.Simons 

Halfway, OR 97834 05/27/11

D43 David Paulson

Richland, OR 97870 05/27/11

D43 Brandon Langtz

Richland, OR 97870 05/27/11

D43 Dray Hammack 

Clatskanie, OR 97016 05/27/11

D43 Ryser Lrisn

Richland, OR 97870 05/27/11

D43 Alexandra Fry

Baker City, OR 97814 05/27/11

D43 John Thomas

Richland, OR 97870 05/27/11

D43 Mark Cliff

Halfway OR 97870 05/27/11

D43 Welms 

Lagrande, OR 97850 05/27/11

D43

D44

Ray Badger

Baker City, OR 97814

05/27/11

05/27/11

D43 Mike Higgens

Halfway OR 97870 05/27/11

D43

D69

Randell C. Guyer

Baker City, OR 97814

05/27/11

05/69/11

D43

D74

Walter Wood

Baker City, OR 97814

05/27/11

05/31/11

D43

D55

Blue Mt. Forest Coop.

Baker City, OR 97814

05/27/11

05/26/11

D43 Chris Cipis

Baker City, OR 97814 05/27/11

D43

D56

Mac Kerns 

Haines, OR 97833

05/27/11

05/27/11

D43 Robert Whitnah

Richland, OR 97870 05/27/11

D43 Jeremy Simpson

Baker City, OR 9781 05/27/11

D43 Jacob J

Richland, OR 97870 05/27/11

D43 Tony Sheld & Shirley Cochell

Richland, OR 97870 05/27/11

D43 Mary Edmondson

Richland, OR 97870 05/27/11

D43 Tom Thomason

Richland, OR 97870 05/27/11

D43 Ken & Pearl E. DaMars

Richland, OR 97870 05/27/11
Appendix B Snow Basin Vegetation Management Project FEIS

537

D43 Kurt Colnet

Richland, OR 97870 05/27/11

D43 Evelyn Fisher

Richland, OR 97870 05/27/11

D43 Tom Omann

Halfway, OR 97834 05/27/11

D43 Jory Hearne

Halfway, OR 97834 05/27/11

D43 Joseph E. Young

Halfway, OR 97834 05/27/11

D43 Derrick S. Jerssay

Halfway, OR 97834 05/27/11

D43 Jennifer Davis

Halfway, OR 97834 05/27/11

D43 Ralph Devine

Richland, OR 97870 05/27/11

D43 Cindy Thayer

Halfway, OR 97834 05/27/11

D43 Linda Miller

Halfway, OR 97834 05/27/11

D43 Gail Marteney

Halfway, OR 97834 05/27/11

D43 Alan Steele

Halfway, OR 97834 05/27/11

D43 Jim Chetwood

Halfway, OR 97834 05/27/11

D43 Todd Robertt

Halfway, OR 97834 05/27/11

D43 SOAR

Baker City, OR 9781 05/27/11

D43

D62

Lane Parry

Baker City, OR 97814

05/27/11

05/31/11

D43 Eagle Valley Grange #656

Richland, OR 97870 05/27/11

D43 Irene M. Mead

Richland, OR 97870 05/27/11

D43 Kim Wright

Richland, OR 97870 05/27/11

D43 Tim Dalt

Baker City, OR 97814 05/27/11

D43 Herbert L. & Barbara A. Jones

Newport, OR 97365 05/27/11

D43 Brian Marshall

Halfway, OR 97834 05/27/11

D43 Larry Flescher

Halfway, OR 97834 05/27/11

D43 Eric Carlos 

Pendleton, OR 97801 05/27/11

D43 Jeannette Peickert 

The Dalles, OR 97058 05/27/11

D43 Larry & Shawn Speelman

Richland, OR 97870 05/27/11

D43 Robert Starl

Richland, OR 97870 05/27/11
Appendix B Snow Basin Vegetation Management Project FEIS

538

D43 Mary Maerien

Richland, OR 97870 05/27/11

D43 Brian R. Holland

Richland, OR 97870 05/27/11

D43 Travis Cannon

Richland, OR 97870 05/27/11

D43 Angela Hyatt

Richland, OR 97870 05/27/11

D43 Lyn E. Akinam

Richland, OR 97870 05/27/11

D43 Nancy Nelson

Richland, OR 97870 05/27/11

D43 Betty L. Cook 

Halfway, OR 97834 05/27/11

D43 Lain Diren

Halfway, OR 97834 05/27/11

D43 Dick Artley 

Grangeville, ID 85530 05/27/11

D43 Nighthawk Ranch 

Mitchell, OR 97750 05/27/11

D43

D45

Michael O. Ragsdale

Baker City, OR 97814

05/27/11

05/27/11

D43

D77

Dan Warnock

Baker City, OR 97814

05/27/11

05/31/11

D43

D49

Valerie A. Omann

Baker City, OR 97814

05/27/11

05/27/11

D43 Gene & Cindy Cayser 

Richland, OR 05/27/11

D43 Glenn L. & Cindy Womack-Steele

Halfway, OR 97834 05/27/11

D43 Robert C. Duggan 05/27/11

D46 Department of Interior 05/27/11

D50 American Forest Resource Council 05/27/11

D54 Michele Edwards

Baker City, OR 97814 05/26/11

D58 Don Thatcher 05/27/11

D59 Hells Canyon Preservation Council

La Grande, OR 05/31/11

D60

Eagle Valley Soil and Water Conservation District

Gordon Summers

Baker City, OR 97814

05/31/11

D61 Tim and Jan Kerns 

Haines, OR 97883 05/31/11

D65 Baker Country Natural Resource Advisory Committee

Baker City, OR 97814 05/31/11

D66

Elkhorn Biomass

(Written by Lane Perry)

Baker City, OR 97814

05/31/11

D67 Environmental Protection Agency (EPA) 05/31/11

D70 Hideaway Hills Residents 05/31/11

D76 Pine Eagle Consensus Group 06/01/11

D79 Union County 06/02/11

D80 Department of Fish and Wildlife (ODFW) 06/08/11
Appendix B Snow Basin Vegetation Management Project FEIS

539

D81 Steve Pedery 

Portland, OR 97217 07/22/11

D81 Tom Insko

La Grande, OR 97850 07/22/11

D81 Andy Kerr

Ashland OR 07/22/11

D81 Mark Stern

Portland, OR 97214 07/22/11

D81 Rick Brown

Portland, OR 07/22/11
Appendix C Snow Basin Vegetation Management Project FEIS

540

APPENDIX C – RESPONSE TO COMMENTS 

Letters and emails received on the Snow Basin Draft EIS (DEIS) within the 45-day comment period contained approximately 

700 individual comments on the DEIS. Similar comments were combined, resulting in approximately 600 “unique” comments 

listed below. 

Comments on the Snow Basin DEIS were reviewed, analyzed and evaluated to determine if there was a need to: 

• Modify alternatives in the FEIS;

• Develop and evaluate alternatives not previously given serious consideration;

• Supplement, improve or modify analyses in the FEIS;

• Make factual corrections in the FEIS.

As a result of the comment analysis, alternatives were modified in the FEIS, analyses in the FEIS were supplemented, 

improved or modified, and factual corrections were made in the FEIS. No new alternatives were developed and evaluated. 

The start of each comment is indicated with a number or an asterisk. At the end of each comment, in parentheses, is the 

number assigned to the comment letter, and the page of the comment letter on which the comment can be found. In some 

cases, the same response applies to several comments. 

Comments used to modify alternatives in the FEIS

#1. As will be discussed in more detail, it is counter-productive and contradictory for managers to cut any 

ponderosa pine, western larch, or Douglas-fir over 21” dbh because of native diseases. The statements made 

above are heavily biased from the “timber output” point of view which historically framed the discussion 

regarding many native diseases in the United States. The statement that the “Screens” need to be amended 

is a subjective statement and already suggests the large bias the Agency has against Alternative 4. However, 

this statement is not supported by the comparison of key indicators presented in Tables 11 through 20 

where Alternative 4 is remarkably similar to the other alternatives in many key ecological comparisons. 

(D59 p. 5)

#2. Oregon Wild is very interested in working with the Forest Service to incorporate modifications to its 

preferred alternative that will result in a project we can fully support. Overall, we would support a decision 

closer to Alternative 4 than Alternative 2. There is still a severe shortage of large trees in this area and we 

believe the restoration objectives of this project can be met by focusing most management activities on small 

trees (<21” dbh). 

Removal of so many large trees will significantly detract from the restoration objectives that should be 

driving forest management in this area. The Forest Service should consider alternatives that would retain 

more large trees, while killing a strategic subset of the large shade-tolerant trees (that are in direct 

competition with larger shade-intolerant species) and retain them as snags. (D64A, pp. 2-3)

#3. There are also parts of the proposal that raise concerns and need further analysis, including: the 

removal of 43,000 large trees in an area where extensive high-grade logging has created a severe deficit of 

large green trees (and snags); the failure to recognize the self-correcting role of natural processes like 

insects, mistletoe, fire, and mortality in ecosystem restoration; and extensive areas of nearly continuous 

commercial treatment with too few untreated refugia. Oregon Wild recognizes there may be situations when 

it may be appropriate to remove some trees larger than 21” dbh, but this project area, having been 

extensively high-graded in the past, still has a shortage of large trees so it is not an appropriate place to 

remove a significant fraction of the few remaining large trees. (D64A, p. 2)

Response: The number of 21+ trees that would be harvested under alternatives 2 and 3, as well as the 

number of 21+ trees that would remain, was modified. See Chapter 1 of the FEIS for the revised purpose 
Appendix C Snow Basin Vegetation Management Project FEIS

541

and need. The removal scenarios for trees greater than 21”dbh can be found in Chapter 2 of the FEIS. In 

both the DEIS and FEIS Alternative 4 does not remove large trees. 

------------------------------------------------------------------------------------------------------------------------------------------

#4A. Table 16 in the DEIS compares the alternatives by resource areas and does not include any social 

value for old growth forests. This is a key social issue known by the Forest Service for decades. (D59 p. 24)

#4B. The Snow Basin DEIS completely overlooks the cultural heritage of old growth forests. By overlooking 

these values, there are very large omissions in this analysis. There is perhaps no single greater issue in the 

history of PNW public lands management that has been more controversial than management of our old 

growth forests. Snow Basin’s preferred alternative easily transcends into the extremely socially contentious 

world of old growth logging, whether the Forest Service likes it or not. (D59 p. 2)

Response: All alternatives have been modified in response to comments. See Ch. 2 Changes from DEIS 

to FEIS.

------------------------------------------------------------------------------------------------------------------------------------------

#5. Add provisions to protect old trees regardless of size. Old trees are ecologically important even if they 

are <21” dbh. Use the recommendation in the Eastside Scientific Societies Panel report that calls for not 

logging any tree over 150 years of age, regardless of diameter or species. See Henjum et al. 1994). Similarly, 

the Wyden legislation says: 

(2) SMALLER TREES.—Except as provided in paragraph (3)(B), the Secretary shall prohibit the cutting or 

removal of any live tree located in the covered area, the diameter of which is less than 21 inches measured 

at breast height, if the Secretary determines, after considering the recommendations of the advisory panel, 

that prohibiting the cutting or removal is required to meet the goals described in subsection (b). (D64A p. 9)

#6. Retain Old Trees Regardless of Size. The Wyden legislation contemplated circumstances when it may 

be appropriate to remove trees over 21” dbh, but it also called for retention of trees smaller than 21” dbh 

when necessary for ecological restoration. Trees smaller than 21” dbh can sometimes be older than 150 

years. New science indicates that slow-growing small old trees tend to be resilient and add to the diversity 

and resilience of forests. A recent study supports the retention of slow growing old trees because they are 

relatively more resilient. The study found that slower-growing older trees tend to channel their resources 

into structural support and defense compounds to “maximize durability while minimizing ... damage.” See 

Colbert & Pederson (2008), and see also Züst et al. (2011). 

We urge the Forest Service to protect trees with “old-growth morphology” regardless of size. The agencies 

often use morphological clues to identify and retain old-growth juniper trees, and similar methods can be 

used to identify and protect old growth ponderosa pine, western larch, Douglas fir and other species. See 

Van Pelt (2008). Old growth characteristics include thick bark, colored bark, flat top, asymmetric crown, 

broken top, forked top, relatively large branches, etc. These trees have important habitat value and human 

values regardless whether they are 21” dbh. Managers should allow natural processes of succession and 

mortality to turn some of these medium and large trees into ecologically valuable snags and down wood. 

(D64A p. 14, D59 p. 1) 

#7. Protect all trees with old growth characteristics regardless of diameter. (D22 p. 2, D24 p. 1)

#8. Mistletoe and old growth trees. How does Snow Basin achieve a balanced view regarding mistletoe? 

The DEIS on p. 28 states that all action alternatives would reduce dwarf mistletoe (DMT) occurrence and 

severity in LOS and non-LOS to differing degrees. Silvicultural prescriptions in all alternatives reduce 

DMT severity by removing moderately to severely infected trees. If all action alternatives reduce dwarf 

mistletoe occurrence and severity in LOS and non-LOS, then there is no justification for cutting down the 

old growth trees. Alternative 4 would protect old growth and reduce dwarf mistletoe. Obviously that is the 

balanced approach. 
Appendix C Snow Basin Vegetation Management Project FEIS

542

While the DEIS states at 28: “There is no known research suggesting a biological need to maintain high 

levels of mistletoe in LOS,” there is a lot of research suggesting we should protect old growth trees, and that 

old growth trees with mistletoe provide very valuable wildlife habitat. 

The 2003 Goodman letter States: 

3. Harvesting >21 inch d.b.h. mistletoe-infected trees when doing so best meets long-term LOS objectives 

and does not eliminate currently important wildlife habitat. 

How can removing rare old growth trees not eliminate important wildlife habitat? The DEIS states at 213 

for Lewis Woodpecker that Alternatives 2 and 3 have the potential to reduce or limit nesting structure some 

stands due to removal of larger mistletoe infected trees (DEIS at 313). For American Marten, “Treatments 

proposed until alternative 2 would cause the greatest loss of source habitat for marten by treating and 

removing 73 acres (30%) of existing MSLT in the G4 biophysical environment. An additional loss of 4 acres 

is expected due to prescribed fire application within MSLT in these BPEs” DEIS at 232. Snags are rare on 

the landscape and these severely diseased trees will soon create high quality snags. Removing trees over 21” 

is counter to the best available science, counter to the Goodman letter, and violates NEPA and NFMA. 

Table 34 of the DEIS shows the ponderosa pine, Douglas-fir, and western larch over 21” DBH that will be 

logged by Snow Basin. The Snow Basin DEIS fails to disclose the age of ponderosa pine, Douglas-fir and 

western larch 21+ inches that are proposed for cut because of mistletoe. How many centuries old are some 

of these old pines? This information needs to be disclosed. 

Furthermore the DEIS states at 86: “With the implementation of an action alternative, it would take several 

decades for mistletoe to reach its present level (Knutson and Tinnin, 1980).” Here the DEIS admits that in 

only a few decades dwarf mistletoe will be back to its present level. So why should be cut down century old 

trees, when in all likelihood, many of the trees that finally replace these old growth trees many decades in 

the future will be infected again! Protect the old growth resource. Mistletoe is part of the ecosystem. (D59 

pp. 81-82)

Response: All alternatives have been modified to avoid harvest trees 150 years of age or older. This 

would be based on visual characteristics and age/dbh sampling as described in Chapter 2 of the FEIS.

------------------------------------------------------------------------------------------------------------------------------------------

#9. The DEIS states at 75: “The alternatives vary in the effects, related to the treatment on trees greater 

than or equal to 21” d.b.h (21+) and stands of Late and Old Structure. Alternative 2 manages all tree sizes 

including those 21+ and addresses uncharacteristic conditions in some LOS stands. As a result some 21+ 

trees are removed and there is a net loss of LOS. Alternative 3 treats 21+ trees the same as alternative 2. 

Alternative 3 addresses uncharacteristic conditions in some LOS but does not result in a net loss of LOS. 

Alternative 4 does not remove 21+ trees, addresses uncharacteristic conditions in some LOS and does not 

result in a net loss of LOS.”

The DEIS states at 92: “The Regional Forester's letter of June, 11, 2003 letter emphasized the need for 

flexibility in applying the standards of the 1994 Regional Forester’s Amendment #2 (SCREENS). 

Alternatives 2 and 3 would harvest trees exceeding 21 inch diameter within the criteria established in this 

letter. It is assumed that one or more of these criteria would apply to each unit within the alternatives.” 

This statement indicates that the screens will be amended for every single unit in the Snow Basin project. 

In other words Snow Basin seeks to apply every exception due the eastside screens, at the same time, across 

the same landscape. Based on Table 53 of DEIS, 43,679 trees over 21in DBH will be logged by the preferred 

alternative (#2). This doesn’t include hazard trees and other incidental take for access, etc. As stated in my 

letter to the editor published on April 21st, 2011 in the La Grande Observer, “The preferred approach 

would log tens of thousands of old-growth trees in the southern Wallowas. That this massive loss of oldgrowth trees would have serious ecological consequences is unassailable.” The impacts that Snow Basin 
Appendix C Snow Basin Vegetation Management Project FEIS

543

threatens to old growth forests are at a vastly different scale than other projects that have amended the 

eastside screens. Snow Basin threatens old growth habitat and associated species at the sub-watershed scale. 

(D59 pp. 25-26)

Response: All alternatives have been modified in response to comments. See Chapter 2 for descriptions 

of changes from DEIS to FEIS. Modified the analysis for the number of >21" trees and acres affected by 

the removal of >21" trees. Refer to Section 3.1 Forest Vegetation in the FEIS. Also refer to Late and Old 

Structure Forest (LOS) - Landscape Assessment (DEIS Pg. 101).

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#10. The Snow Basin proposal oversteps the bounds of working with relevant stakeholders in a constructive 

way to figure out how and where to make exceptions to the Eastside Screens. As such the Forest Service is 

fast backing itself into a corner. This is frustrating to HCPC as we have worked with the Whitman on other 

timber sales and they have had every opportunity to realize that such a proposal is way outside of any 

reasonable approach. The analysis is heavily biased against the one alternative that leaves the Eastside 

Screens in place. In fact the Whitman Ranger District in the Snow Basin DEIS comes across as a special 

interest group, heavily advocating for its own approach. It will be interesting to see if the Forest Service 

makes any serious attempts to resolve this proposal. Clearly, very large changes are required for any such 

effort to be serious. (D59 p. 2)

Response: All the alternatives were modified based on public input. Reference DEIS Ch. 6 Public 

Involvement – Pg. 7. Also reference the FEIS Chapter 2 – Changes from DEIS.

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#11. As planned, the project would further harm the ecological integrity or the area by its planned removal 

of far too many of the area’s old and mature trees, including the scientifically insupportable logging in mid 

and high elevation mixed conifer forests, and the logging of inherently fire resistant mature and old growth 

trees. Such scientifically and ecologically unwarranted logging will seriously degrade wildlife habitat, 

jeopardizing the viability of forest-dependent species of concern throughout the greater project area. The 

planned logging violates the purpose and need for the project and the peer-reviewed science, expert advice, 

and reasonableness requirements of the NEPA. Project logging actions violate the qualified scientific 

objectives that comprise the foundation of the Eastside Screens. Project logging violates fire and fuels 

reduction scientific recommendations. Project logging of mature and old trees and degradation of forest 

habitat would likely extirpate or harm the habitat and populations of affected ESA listed species and 

imperiled forest dependent native species of concern in violation of the NFMA. (D59 p. 21)

Response: Modifications to the alternatives have been made based on comments received. The effects of 

the alternatives are discussed in the FEIS. 

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#12. The DEIS fails to analyze a full range of scientifically-sound alternatives or an adequate range of 

alternatives. The DEIS does not include a developed range of scientifically-based developed alternatives, 

even though it is “reasonable” to include a restoration alternative, and even though NEPA requires a full 

range of reasonable scientifically sound alternatives.

Analyzing alternatives is “the heart of the environmental impact statement.” 40 C.F.$. 1502.14. An agency 

is required under NEPA to “rigorously explore and objectively evaluate all reasonable alternatives.” 40 

C.F.R. 1502.14 (a) (emphasis added). An agency may not decline to evaluate an alternative simply on the 

grounds that it is not a “complete solution” to the agency’s goals. Citizens Against Toxic Sprays, Inc. v. 

Bergland, 428 F. Supp. 908, 933 (1977). Furthermore, an agency should use the NEPA process to “identify 

and assess the reasonable alternatives to proposed actions that will avoid or minimize adverse effects of 

these actions upon the quality of the human environment.” 50 C.F.R. 1500.2(e). 

The range of developed alternatives considered in the Snow Basin DEIS is inadequate, because the DEIS 

fails to develop and analyze a full range of scientifically supported action alternatives. As clearly described 
Appendix C Snow Basin Vegetation Management Project FEIS

544

in these comments, it is well established in the peer-reviewed literature that application of the appropriate 

disturbance regime to the landscape is critical to guiding projects that aim to restore historical vegetative 

characteristics. The Forest Service has not presented a single alternative that limits fuels reduction 

treatments to the appropriate plant association groups and recognizes the well-known fact that forests 

characterized by the mixed severity fire regime are within the range of natural variability. Applying fuels 

reduction treatments to the appropriate biophysical environments characterized by the low-severity fire 

regime is the cornerstone of projects that propose vegetation management actions that aim to restore forest 

structure toward a more historical and resilient stand composition and density and to return natural 

disturbance to the landscape such as the Snow Basin Vegetation Management Project. Without this 

sideboard, the Forest Service could propose fuels reduction treatments based on fire suppression impacts 

anywhere on the landscape with no accountability to the actual historic characteristics of the fire regime. 

That Snow Basin fails to include a single alternative based on this governing principle of fuels reduction 

treatments is a serious failure of the NEPA process. The public has no opportunity to advocate for an 

alternative based on the best-available science because that alternative does not exist. (D59 p. 19)

Response: Chapter 2 has a description of how Alternatives 3 and 4 were modified for the FEIS. 

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#13. The DEIS is biased against alternative 4. Despite all of the scientific issues presented above concerning 

Snow Basin’s preferred old growth logging approach, the DEIS is systematically biased against alternative 

4, the only alternative that protects old growth and some of the mature trees. For example, the DEIS states 

at 64-65, “Management of forested vegetation includes the need to harvest some live trees greater than or 

equal to 21" d.b.h.” This is a completely subjective statement. Many forest ecologists would tell you that 

there is no need to harvest live trees greater than 21”. Other examples of bias include: • Alternative 4 does 

not remove trees greater than 21 diameter, thus retaining excess overstory that impedes successful 

regeneration (29); • Alternative 4 does not manage uncharacteristic old growth or remove 21+ trees (44). 

(D59 p. 35-36)

Response: Alternatives 3 and 4 have been modified in the FEIS. 

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#14. Instream downed wood. The DEIS states at 145: “Large Woody Debris (LWD) – Large wood creates 

pools, stores sediment, and is an important component for stream structure. The INFISH RMO for large 

woody debris is greater than 20 pieces per mile greater than 12 inches diameter and greater than 35 feet in 

length. Existing levels of LWD in the streams surveyed within the project met the INFISH RMO for pieces 

of large woody debris per mile for all sampled streams. However, observations of Category IV intermittent 

streams show that intermittent streams in general do not have adequate quantities of large woody debris to 

support channel long-term stability and sediment retention.” Further removing trees over 21” DBH and 

other large, mature trees that are near to intermittent streams will perpetuate this for decades to centuries. 

Critical natural processes such as severe fire that trigger mass wasting and erosion events that transport 

large wood to intermittent streams are being managed against. (D59 pp. 66-67)

Response: A clarification/modification in the FEIS has been made for alt. 3 and 4, where a minimum 100 

foot buffer must exist between unit and category 4 streams. Exceptions exist only where roads provide a 

boundary at the bottom of a unit, and a minimum of 50 feet exists between road and category 4 streams. 

No effect to LWD recruitment expected because existing trees above the road don’t contribute wood to 

stream systems. When trees above the road fall onto the road prism, where they get bucked up to clear a 

path for vehicles (non-merchantable trees), or they get marked and retained as a merchantable product. 

LWD recruitment is not a function of mass wasting and erosion events within the project area.

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#15. I have seen no peer-reviewed science that recommends reducing stands to the lower management zone 

for basal area stocking. The Forest Service did not analyze a single alternative that offered a different 
Appendix C Snow Basin Vegetation Management Project FEIS

545

approach from heavy commercial thinning. The public requested a restoration alternative that was 

eliminated from detailed study. Seven suggestions are outlined in the DEIS at 28 and 29:

1. No harvesting of trees 21"+ diameter except where the grand fir is growing up underneath an old 

growth ponderosa pine or larch.

2. Maintain high levels of mistletoe infection in the Late Old Successional (LOS) pine and Douglasfir stands, especially the trees 21+ diameter, for biodiversity. Manage mistletoe with fire and cutting 

some mid canopy trees.

3. Manage mistletoe with fire and cutting some mid canopy trees.

4. Manage residual Basal Area above the Lower Management Zone (LMZ) of Stand Density Index 

(SDI) in all cases.

5. Girdle 21+diameter trees in overstory instead of removing from stands to both release understory 

and provide snags.

6. Do not cut units with regeneration prescriptions but leave as “refugia.”

7. Use an individual tree release prescription in grand fir type to release pine and larch by cutting 

grand fir less than 21" diameter around them but not harvesting entire stand to retain higher levels 

of hiding cover. (D59, pp. 19-20)

Response: 

(1.) FEIS Alternative 4 does not harvest 21+" trees.

(2.) DEIS Ch 3 Section 3.1 Pgs. 70-71 discuss dwarf mistletoe management. Dwarf mistletoe will remain 

throughout the landscape for the Snow Basin Planning Area including areas of high infection in the 

untreated portions.

(3.) Warm / Dry stands within the analysis area will have prescribed fire which will reduce mistletoe in 

lower canopy as a function of crown scorch. This however will not meet objectives in the upper canopy or 

larger trees.

(4.) All alternatives have been modified that stands will be managed within the Recommended 

Management Zone of SDI.

(5.) Snag creation and pruning is a highly expensive activity relegated to recreation settings. As described 

by Hallett et al., girdling trees provides foraging habitat but not cavity nesting habitat. 

Hallett, J. G., Lopez, T., Borysewicz, M. A., 2001. Decay dynamics and avian use of artificially created 

snag. Northwest Science. Vol. 75, no. 4, pp. 378-386.

(6.) Regeneration Harvests have been removed from all alternatives.

(7.) In Warm Dry Grand Fir types, individual tree prescription would not meet the purpose and need. In 

the Cool/moist/dry Grand Fir types, a prescription would be used that approximates the individual tree 

prescription mentioned but includes removal of 21+" Grand Fir in Alt. 2 and Alt 3.

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#16. The statement that Alternative 2 will “begin to create conditions for characteristic development” is 

opposite of ecological knowledge. These stands are obviously in a very ecologically valuable stage of 

characteristic stand development. Ecosystems in their potential state are rare globally, and the failure to 

recognize this is concerning. Lindenmayer et al. (2009) remind us that chainsaws cannot replace natural 

disturbance regimes. “However, we note that natural fire regimes cannot simply be replaced with regulated 

disturbance by logging (Hunter 2007). This is because, in part, many elements of forest flora and fauna 

depend on particular fire return intervals and associated habitat features (Saint-Germain et al. 2004). 

Logging operations also do not provide the diversity of habitats and micro site conditions found after 

wildfires (Haeussler & Kneeshaw 2003; Lindenmayer et al. 2008).” (D59 p. 14)

Response: See response to Comments #18, #118 and #412. See Chapter 3 Section 3.1 Forest Vegetation.

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#17. Treatments in forests with naturally mixed-severity fire regimes should be carefully scrutinized to 

ensure those areas (i) are in fact outside of the HRV, and (ii) treatment will not remove scarce habitat for 
Appendix C Snow Basin Vegetation Management Project FEIS

546

focal species that depend on dense forests, and (iii) treatments are in fact needed and (iv) proposed 

treatments will be effective. 

Treatments in mixed severity fire regimes should be more patchy and leave behind more structure, more 

snags and large dead wood. (D64A p. 19)

Response: All snags and large down logs would be retained unless a safety hazard to forest workers or the 

public. Prescribed fire would occur under conditions that would minimize the loss of large down log (See 

Mitigation Measures RX fire snags large woody debris. All cull grand fir would be retained. In Pine 

Marten habitat clumps of grand fir and those within 20 ft of a cull grand fir would be retained. See Section 

3.1 of the FEIS. 

All alternatives in the FEIS have been modified to include specific prescriptions in Pine Martin Habitat as 

identified within the Wildlife Section of Chapter 3 of the FEIS.

Additional analysis was done in response to comments about Cool Grand Fir stands - See Forest 

Vegetation effects section of the FEIS. 

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#18. Instead of striving for park-like single strata forests, the agency should consider working toward 

complex forests. Such an approach would retain all existing large and old trees, retain untreated patches at 

many scales, manipulate basal area as guided by PAGs, and generally tolerate more diversity in the stand. 

See reference below:

The Interforest Report defines structurally complex forests as follows: “These are forests which 

retain much of the pre-management forest structure, including: 1) a large-diameter tree component 

(including ponderosa pine when appropriate to the site); 2) a spatially-complex pattern of stand 

structural units (e.g., large tree groves and open areas of dense regeneration); 3) coarse wood 

habitats (snags and logs); 4) a well-developed understory communities of herbs and shrubs; and 5) 

moderate tree stocking levels (Interforest Report 2000, p. 21).” The goal of restoration of healthy, 

diverse, structurally complex forest ecosystems “calls for the return of ponderosa pine and mixedconifer forests of the Reservation to this structurally complex condition across the landscape. A 

complex ponderosa pine forest is illustrated in Figure 1 (from the Interforest Report). Individual 

patches can be relatively simple, i.e., all trees of similar size, but the mosaic of different sizes and 

ages creates the complexity. Thus the structural complexity is achieved though a fine-scale mosaic of 

relatively simple patches along with scattered large trees, snags, and down logs. (D64A p. 17-18)

Response: All alternatives have been modified to not harvest trees greater than 150 years old. 

See response to #186 for the untreated portion of the landscape. Reference Variable density Appendix 

Silviculture Report. Reference Seral Stages Fuels Report FRCC. The landscape would move towards the 

HRV for the landscape. HRV would include single and multistory stands. A landscape within HRV is a 

diverse landscape within inherent ability to withstand disturbance. Viable understory ponderosa pine and 

western larch, as well as, Douglas-fir would be retained and add to within stand diversity. Cull grand fir 

would be retained to further add to diversity. Specific prescriptions are designed for Pine Marten and 

Goshawk habitat. See Chapter 3 in the FEIS. Alternative 4 does not harvest trees >21". 

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#19. The Forest Service office implies that the impacts of temporary road building are minimal when 

located on ridgetops and away from water bodies. However the Snow Basin DEIS illustrates the variety of 

resources that are damaged by unnecessary temporary road building. HCPC strongly maintains that there 

are no vegetation management objectives worth the ecological cost of building temporary roads. The DEIS 

states at 309: “All action alternatives propose creating temporary roads, which is a significant ground 

disturbing activity. Even though the equipment is not supposed to go to a great soil depth, outcrops of the 

Martin Bridge Limestone would be affected by the blading of roads to get into locations. Temporary roads 
Appendix C Snow Basin Vegetation Management Project FEIS

547

constructed in areas outside the Martin Bridge Limestone formation would not affect potential 

paleontological resources. Table 142 shows the roads within the formation, the evaluation of the proposed 

area, and potential to find paleontological resources.” 

The Snow Basin DEIS paragraph quoted above raises the issue of failing to analyze a scientifically sound 

range of alternatives. If every action alternative proposes the same temporary road building, “a significant 

ground disturbing activity”, a full range of scientifically supported action alternatives has not been 

analyzed. Where is the action alternative that does not propose significant ground disturbing impacts from 

temporary road building? The scientific research recommends against continued temporary road 

construction. (D59 pp. 94-95)

#20. Despite the road densities presented in the DEIS in Table 83 and the information on page 141 that “the 

road network is extensive and multiple entries over many decades have occurred for timber harvest and 

other purposes,”10.6 more miles of temporary road construction are proposed (see DEIS Table 91). The 

DEIS states at 161 that “Temporary road construction is planned to access harvest units where NFS roads 

to not exist.” Where does this attitude ever end? The project area is already heavily roaded with a high 

level of access. When will forestry actions be required to work within the existing road system because the 

“gig is up,” just as it is for old growth logging. We simply can’t keep facilitating more mechanical treatment 

across these watersheds that supply ecosystem services such as water quality and quantity, and biodiversity 

and are of incredible value to everyone. The DEIS states at 166:

“For instance, the new construction temporary road segment proposed for unit 83 (see Table 91) has the 

highest risk of increasing and delivering sediment to streams of the proposed temporary roads. WEPP 

model runs for this road segment indicate very low sediment risk. However, protection for the crossing as 

described I the PDFs in DEIS Appendix B-1 is necessary to insure very low sediment risk as a result of the 

new construction. This segment would involve cut and fill road construction across an intermittent 

drainage. This temporary road segment will require additional measures (PDFs) be used at this location to 

reduce soil erosion potential (See DEIS Appendix B-1). A temporary culvert will be used at this crossing, 

and filter fence or slash windrows will be placed on the culvert fill to reduce sedimentation directly or 

indirectly reaching the stream.” These are excessive measures with high associated risks. All of these 

temporary roads should be dropped. (D59 pp. 65-66)

#21. Do not build any temporary roads (D22 p. 2, D24 p. 1)

#22. The DEIS states at 309: “All action alternatives propose creating temporary roads, which is a 

significant ground disturbing activity. Even though the equipment is not supposed to go to a great soil 

depth, outcrops of the Martin Bridge Limestone would be affected by the blading of roads to get into 

locations. Temporary roads constructed in areas outside the Martin Bridge Limestone formation would not 

affect potential paleontological resources. Table 142 shows the roads within the formation, the evaluation of 

the proposed area, and potential to find paleontological resources.” 

The Snow Basin DEIS paragraph quoted above raises the issue of failing to analyze a scientifically sound 

range of alternatives. If every action alternative proposed the same temporary road building, a “significant 

ground disturbing activity,” a full range of scientifically supported action alternatives has not been 

analyzed. (D59 pp. 94-95)

Response: Alternative 4 has been modified so it has no proposed temporary roads. 

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#23. To bring Snow Basin more in line with proposed Wyden Legislation, build fewer temporary roads and 

ensure complete decommissioning. (D64A pp. 8-9) 

#24. The proposed construction of 10+ miles of new roads is also a big concern driven by economics. 

Significant road construction undermines the ecological restoration goals of this project and should be 

avoided. We urge the Forest Service to carefully consider options for non-commercially treating those acres 

that require significant road construction. This would likely allow the Forest Service to accomplish the vast 
Appendix C Snow Basin Vegetation Management Project FEIS

548

majority of the work they desire to do, while accomplishing a more desirable mix of treated and untreated 

(or commercially treated vs. non-commercially treated) areas. (D64A, p. 7)

Response: Alternative 4 has been modified in the FEIS so it has no proposed temporary roads. Alternative 3 has 

been modified in the FEIS to eliminate all temporary roads in the Eagle Creek Wild & Scenic River Corridor. The 

specifications for decommissioning temporary roads can be found in the FEIS.

Comments Used to Supplement, Improve, or Modify Analyses In the FEIS

#25. DEIS p. 241 says timber harvest has the potential to impact snag availability but that impact is expected to be 

minor within the project area. This statement is likely inaccurate. The DEIS provides no quantitative analysis to 

support the assertion. In virtually every similar assessment, a significant effect of logging is to reduce the pool from 

which future snags are recruited, resulting in a long-term loss of snag recruitment that needs to be mitigated by 

providing more refugia and retaining higher basal area. (D64A p. 16).

Response: Implementation of the proposed activities in the Intermediate units would leave stands fully stocked with 

trees but at levels reducing mortality from inter-tree competition. However, inter-tree competition is only one way 

trees become snags. The Silviculture Report discusses how drought, weather events, and fire create snags. The 

silviculture response to comments displays the area in Snow Basin where no activities would occur. Snag levels in 

these areas are expected to increase over time. Although the “pool” of potential future snags is reduced, the stocking 

levels in intermediate treatment units reflect what is appropriate and sustainable for those sites. 

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#26. DEIS p. 239 states that “existing average snag densities in the Snow Basin project area fall primarily into the 30% 

tolerance level”. Based on quantitative analyses conducted to date, it is to be expected that logging will make this 

situation worse instead of better. Given this situation, proposed removal of 40-50% of the few remaining large trees in 

these stands in particularly troubling. (D64A p. 16).

Response: The FEIS characterizes snag levels and explains that snags are unevenly distributed on the 

landscape, with some areas where snag densities reach 50% and 80% tolerance levels. While reducing 

stand densities may decrease density and in-stand tree mortality due to inter-tree competition, non-density 

related mortality factors such as prescribed fire, wind and snow damage, drought, insects, and root disease 

will continue to create snags in treatment units. Treatments are expected to accelerate development of 

larger trees, and therefore, larger snags on the landscape. In addition, density-related tree mortality will 

continue in untreated areas (FEIS, MIS species - Primary Cavity Excavators). None of the alternatives 

propose removal of 40-50% of the remaining large trees. The Silviculture Specialist Report describes that 

on the average, approximately 1 tree per acre, >= 21” DBH would be removed to address the objective of 

reducing the spread of mistletoe to host understory trees. 

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#27. The wildfire and fuels reduction section is flawed in all mixed conifer systems. Enforcing low severity 

ground fires on the entire project area is completely uncharacteristic and requires drastic manipulation of 

the vegetated canopy that is not based on the natural disturbance regime, the primary method to ensure 

effectiveness of any of these treatments (D59 p. 48)

#28. The DEIS makes some very vague statements, cites the following research papers, and draws a blanket 

conclusion. (D59 p. 48). In some forest types this is not true. Fuels reduction treatments applied in the 

wrong forest types can increase fire risk. This is a good example of how the FS cites science but fails to 

acknowledge the huge body of literature in this area. That “heavy thinning” is necessary to effectively 

reduce potential fire behavior and crown fire hazard is not supported by the best available science, because 

numerous studies illustrate that over thinning can increase fire risk by making conditions hotter, drier and 

windier. In moister forest types that naturally harbor moist microclimate and sensitive plant communities, 

these treatments can be very damaging. First you have the direct impacts of all the equipment and logging, 

and then the increased influx of solar radiation desiccating moisture loving species. Heavy thinning has 

implications for soils, understory communities, and stand resiliency that should also be considered. In old 
Appendix C Snow Basin Vegetation Management Project FEIS

549

growth dry pine-Douglas-fir forests characterized by low severity fire regime, heavy thinning is often not 

recommended by the best available science. (D59 pp. 48-49)

#29. The DEIS on p. 124 assumes that reduced intensity fires are better. Severe disturbance plays an 

integral role in our landscape and is critical for maintenance of biodiversity. It is critical that we 

incorporate these processes into our management plans. The DEIS statement implies that mortality is bad 

and because a forest survives, or “withstands” the event, it’s therefore good. In reality imposing an 

uncharacteristic fire regime on a forest type is very destructive, even if you think you are “helping” the 

system by lowering fire intensity. (D59 p. 50)

Response: The following will be added to the fuels analysis description: Derivation of Fire 

Regime depends upon use of the Plant Association Groups (PVG’s) determined for the 

stands within the analysis area. A matrix approach was used in representing the ranking of 

temperature and moisture status of the PVG associated with the Plant Association Groups 

(PAG’s) (PNW-GTR-709, June 2007, Powell, Johnson, Crowe, Wells, and Swanson). Not 

considered in the determination of fire regime was the juxtaposition of PAG’s and related 

Potential Vegetation Type (PVT). 

Throughout the project area there are a number of instances where moist stands are 

surrounded by dry site vegetation. These stands represent the dry end of the classification 

for cool/warm moist vegetation as they occur on this landscape. This mosaic of cool 

moist/warm moist vegetation, surrounded by dry vegetation, poses a challenge when 

modeling fire regime departure. These stands fit within the drier end of a mixed fire regime 

spectrum. The adjacency and location on slope of many of the moist stands proposed for 

treatment are such that fire frequency would have been expected to be similar if not 

identical to that found on adjacent dry plant associations. 

Agee in the PSW GTR 181 states: Mixed-severity fire regimes had larger patch sizes and 

considerable edge (fig.1). These fires maintained both a naturally fragmented forest 

structure and fuel structure. Patch size in the mixed-severity fire regimes is typically larger 

than for the low-severity fire regimes. Patch size for mixed-severity forests (including some 

drier westside Cascade forests) ranges from 2.5 to 250 ha (Agee 1998b). 

Patch edge is typically much higher for mixed-severity fire regimes than for high-severity 

fire regimes (although the methods for defining a patch will significantly influence any edge 

metric). The result, both from fire and other disturbances, was considerable local-scale 

patchiness on the landscape (Taylor and Halpern 1991). Patches burned with light fires had 

surface fuels removed and only understory trees killed. Patches burned with higher 

intensity fires had some overstory removed (similar to the first entry on a shelterwood) and 

resulted in a favorable environment for regeneration of a new age class of trees (generally 

shade-tolerant species: white fir [Abies concolor {Gord. and Glend.} Hildebr.] or grand fir 

[Abies grandis {Dougl. ex D. Don} Lindl.], Douglas-fir [on dry sites], red fir [Abies 

magnifica A. Murr.], and/or sugar pine [Pinus lambertiana Dougl.]). Patches burned with 

very high intensity within the mixed-severity fire regime had all the overstory killed and 

created an environment for shrubfields or new shade-intolerant tree species (typically 

western larch (Larix occidentalis Nutt.) or lodgepole pine (Pinus contorta Dougl.) (Antos 

and Habeck 1981, Cobb 1988). Landscape position in part explains differential severity: 

lower slope positions had the least amount of severe fire, while upper slopes, particularly of 

west or south aspect, and ridgetops experienced more severe fire (Taylor and Skinner 1998).

Most of the mixed severity regimes in the analysis area show presence of large ponderosa 

pine older than 150 years and smaller to large diameter grand fir less than 100 years in age. 
Appendix C Snow Basin Vegetation Management Project FEIS

550

The area has not had fire within the last 100 years except some prescribed fire. Species 

composition currently would support a history of higher severity fire which resulted in the 

older ponderosa pine. Area is currently lacking in the open mid-seral structures. Areas 

generally burned at the same interval as surrounding warm/dry stands based on stand size 

and edge effect which again would support a more open structure. 

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#30. Canopy retention can help reduce fire hazard by maintaining a cool, moist, and less windy microclimate, and by 

retaining the larger trees with thicker bark and higher crowns that are less susceptible to fire. Conversely, canopy fuel 

treatments move large amounts of fuel from the crown to the ground where it is more of a hazard. It also makes stands 

hotter, drier, and windier, and stimulates the growth of future ladder fuels. When all the factors are considered 

together, it is clear that fire hazard is not a good justification for canopy removal, and there are far more ecological 

benefits to maintaining canopy than reducing canopy. (Waltz et al. 2003; Kaufmann et al. 2008).

To be clear we are not opposed to any and all effects on the canopy, but we object to the prevalent and often 

inappropriate use of crown fire and canopy fuels as an excuse to remove medium and large trees over large areas. The 

FS should consider alternative canopy treatments that are small and patchy, instead of extensive and continuous. 

Pruning lower branches should also be considered as a viable canopy treatment. 

“Thinning is most effective when it removes understory trees, because larger overstory trees are more resistant to heat 

injury (Agee & Skinner 2005). IN addition, shade and competition from larger trees slows the recruitment of younger 

trees in the understory.” (Keeley et al. 2009). Models show that maintaining canopy cover is a useful way to reduce 

fire hazard, while removing canopy increases fire hazard. 

Compared with the original conditions, a closed canopy would result in a 10 percent reduction in the area of 

high or extreme fireline intensity. In contrast, an open canopy has the opposite effect, increasing the area 

exposed to high or extreme fireline intensity by 36 percent. Though it may appear counterintuitive, when all 

else is equal open canopies lead to reduced fuel moisture and increased midflame windspeed, which increase 

potential fireline intensity. (Platt et al. 2006). 

Modeling shows that canopy fuel reduction is accomplished at the expense of increasing surface fire intensity. 

Modifying canopy fuels as prescribed in this method may lead to increased surface intensity and spread rate 

under the same environmental conditions, even if surface fuels are the same before and after canopy 

treatment. Reducing CBD to preclude crown fire leads to increases in the wind adjustment factor (the 

proportion of 20-ft windspeed that reaches midflame height). Also a more open canopy may lead to lower fine 

dead fuel moisture content. These factors increase surface fire intensity and spread rate. Therefore, canopy 

fuel treatments reduce the potential for crown fire at the expense of slightly increased surface fire spread rate 

and intensity. (Scott 2003). 

(D64A pp. 24-26)

#31. Canopy removal will significantly increase surface temperature. The relationship between forest canopy cover 

and the regulation of surface temperature is well documented and the key mechanism responsible for this is 

transpiration (Nemani et al, 1993; Waring 2002). The influence of vegetation on the expression of Land Surface 

Temperature (LST) has been observed in disturbed and undisturbed areas across a range of spatial scales (Lambin 

and Ehrlich 1996; Nemani et al. 1996; Mildrexler et al. 2006; Running 2008). Forests, with their deep root systems, can 

access groundwater even during dry conditions and continue transpiring. Forests partition a larger proportion of 

incoming solar radiation to latent heat flux compared with other land cover types, and thereby maintain maximum 

LSTs close to air temperature. This is a clear indication of the hydrologic cycle and the continuous interaction between 

a climate that is wet enough to support vegetation, and the transpiration from forests reducing maximum temperature. 

Exposure of bare ground to direct solar radiation results in dramatic increases in the land surface temperature 

(Mildrexler et al. 2009, Running 2008) and opens the stand for more wind penetration. Both of these factors result in 

hotter and drier conditions. Less canopy cover will encourage the growth of understory vegetation, which will 

contribute more fine fuels that burn quicker and hotter than the leaves or needles shed slowly from dying trees (Veblen 

et al. 2000). These larger trees keep temperature cooler in the summer especially in semi-arid regions. Even partial 

canopy removal has dramatic impacts on the surface temperature. The Forest Service’s plan threatens to dry out 

many parts of the forest by reducing canopy cover and exposing the soil to direct solar radiation. (D59 p. 34)

#32. All action alternatives are built around the general concept that heavy commercial logging in the 15-20.9” DBH 

range is the only approach to reducing fuels and restoring dry forests. However, this heavy logging of mature trees has 

been shown to increase fire risk (Brown et al 2004; Carey and Schumann 2003; Noss et al 2006; Rhodes 2007; Hanson 

and Odion 2006; Raymond and Peterson 2005; Baker et al 2006) and numerous studies recommend removing the 

smaller trees only. (D59 p. 19)
Appendix C Snow Basin Vegetation Management Project FEIS

551

Response: The fuels analysis has been supplemented to add information on how thinning and prescribed fire is 

expected to modify the understory microclimate on treated stands. Expected results include increased solar radiation, 

increased surface temperatures, decreased fine fuel moistures, and reduced sheltering from wind. An increase in fine 

fuels, primarily grass and forbs, is also anticipated. Combined, these changes are expected to result in a change in 

fire behavior, from fire burning in heavier fuels under a more sheltered condition with ladder fuels, a continuous 

canopy, and with potential for crown fire, to fire burning in light fuels in a more exposed or unsheltered situation 

where the predominant fire spread mechanism will be surface fire. 

Fires in light fuels can be expected to exhibit high intensity where fuel, weather, and topographical conditions align. 

These high intensities are short lived, as fire in light fuels spread relatively rapidly and burnout quickly, pose less 

resistance to control efforts, and are reactive to changes in fine dead fuel moistures. Reduced ladder fuels and open 

canopies reduce potential for crown fire initiation and spread. Fire in light fuels is less “severe” than those in heavy 

fuels as measured by consumption of surface fuels, soil heating, etc. In general, shifting a fire’s behavior from a 

crown to surface fire produces less severe effects and fewer impacts on resource values (Fitzgerald 2002). 

Modification of understory conditions toward a higher proportion of light fuels with reduced surface fuel loading 

reduces the difficulty in application of prescribed fire, extending the time available when burning objectives can be 

met (prescription window), and reducing the need to burn when the relative risk of ignition is otherwise high (mid 

season). Treatment and maintenance of thinned stands will be critical to maintaining surface fuel conditions and 

managing development of ladder fuels over time so as to manage future crown fire risk.

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#33. The following is a brief outline representative of the range of current scientific information that should 

be incorporated in revising the proposed decision and management actions of the Snow Basin Project: 

Management recommendations based on scientific forest and fire ecology research:

Exclude treatments from rare LOS areas greater than 1,000 acres, and from smaller ecologically significant 

areas. These areas are scarce, biologically important, and serve as important controls for monitoring 

effectiveness of any fuel treatments. (D59 p. 37)

Response: See FEIS Chapter 3 Section 3.1 Vegetation for new analysis of HRV discussions for tree 

density, structure, species composition. Also see FEIS Ch.1 Purpose and Need for need to treat within LOS 

within the project area. 

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#34. The following is a brief outline representative of the range of current scientific information that should 

be incorporated in revising the proposed decision and management actions of the Snow Basin Project: 

(D59 p. 37)

Management recommendations based on scientific forest and fire ecology research:

Retain all mature trees, including those that pre-date settlement (Baker et al. 2007) 

 

#35. The following is a brief outline representative of the range of current scientific information that should 

be incorporated in revising the proposed decision and management actions of the Snow Basin Project: 

(D59 p. 37)

Logging-thinning diameter limits of 21 inches are excessive, allowing far too many mature, old trees to be 

removed unnecessarily. Additionally, logging in excess of such limits lacks scientific support and ecological 

merit. 

Response: The intent is not to harvest or remove trees over 150 years of age. This would include trees 

that pre-date settlement. All alternatives have been modified to define old trees as 150 years of age or 

older. Reference Ch. 3 Section 3.1 – Vegetation. Also see FEIS Ch. 2 Changes from DEIS to FEIS. 

Alternative 4 does not harvest or remove any trees >21". 

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#36. Indian Paint Fungus. The DEIS states at 51: “Indian Paint Fungus (Echinodontium tinctorium) was 

observed in all stands of mature grand fir. Where it occurs, Indian Paint fungus can produce extensive stem 

decay (Aho, 1982). This can result in loss of sawlog volume, wind throw or structural failure leading to 

localized public safety concerns, and habitat for cavity nesting wildlife species (see Figure 5 below).”
Appendix C Snow Basin Vegetation Management Project FEIS

552

These few sentences underlie that the Snow Basin DEIS is using Indian Paint Fungus as an excuse to log 

mature grand fir. It is apparent that the Snow Basin DEIS still very much takes the commercial timber 

viewpoint with regard to native diseases. Indian Paint Fungus is common in mature grand fir stands 

because it is an important part of the ecology of these stands that provides vital wildlife habitat for many 

avian and other species. It is hard to believe that the Forest Service highlights “loss of sawlog volume” at the 

top of the list for the results of Indian Paint Fungus, and includes habitat for cavity nesting wildlife species 

as an afterthought. I cannot find any scientific references in the Snow Basin DEIS documenting the wildlife 

usage of cavities created by Indian Paint Fungus.

However, in our very region, Bull et al. (2005) studied “Habitat selection by the American Marten in 

Northeastern Oregon.” This study found that “Most of the large-diameter hollow trees used by martens as 

den and rest sites were in grand fir as Indian paint fungus (Echinodontium tinctorium), a heart-rot fungi, 

was prevalent in this tree species.” Despite this very important and local finding, the Snow Basin DEIS 

Environmental Consequences-Direct and Indirect Effects to American marten (pg 232-233) does not analyze 

the effects of logging grand fir with Indian Paint Fungus.

In another study of northeastern Oregon forests, Bull (2003) studied declines in the breeding population of 

Vaux’s Swifts. This study states: “Vaux's Swifts nest and roost primarily in hollow trees in forests, less 

commonly in chimneys. Hollow trees of large diameter with decayed heartwood provide the structural 

components necessary for nesting in forests. In northeastern Oregon, these swifts typically nest and roost in 

forests with tall and dense canopies. The hollow chambers formed in Grand Firs (Abies grandis) by the 

Indian Paint fungus (Echinodontium tinctoriurn) are most commonly used as nest sites, although the 

Western Larch (Larix occidentalis) and Western Redcedar (Thuja plicata) are also used (Bull 2003).

Bull (2003) states that one of the factors affecting the Vaux’s Swifts population includes tree harvesting.

“The loss of nesting habitat over the last decade may be partially responsible for the observed declines in 

Vaux's Swift (Bull 2003). In the 1990s insect outbreaks in northeastern Oregon have killed many Grand 

Firs, including the large-diameter trees used by swifts for nesting (Bull and Collins 1993). The old 

multilayered stands that typically contain hollow trees where swifts can nest currently constitute less than 

3% of the forested landscapes in the interior Columbia River basin (Hann et al. 1997), and there are few or 

no alternative stands maturing to replace those which have been lost.”

Page 88 of the Snow Basin DEIS states: “Alternatives 2, 3, and 4 directly reduce Indian Paint Fungus by

removing its host tree species, grand fir.” The Snow Basin DEIS completely fails to consider how. (D59 pp. 

82-83).

Response: Immature large grand fir trees on the Dry Upland Forest types would be removed. Cull grand 

fir (those already well affected with Indian Paint fungus or any other root/stem disease) would not be 

removed from any portion of Snow Basin. In addition, in the cool/moist type (grand fir/big huckleberry) 

large grand fir would only be removed when they are in direct competition with a suitable ponderosa pine 

or western larch. Ponderosa pine and western larch have been reduced in these types by past removal and 

fire exclusion. All grand fir within 6 feet of a cull would be retained. This was a result of public comment 

and a reassessment by the wildlife biologist. See Chapter 3 of the FEIS.

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#37. The project is premised in part on an assumption that native insects and disease need to be drastically 

reduced, and that logging is the answer to achieving such protection. The DEIS does not present verifiable 

compelling evidence that the area’s forests are outside of the range of natural variability for insect, disease, 

and other natural pathogens and disturbances. Forest wildlife and ecologically systems are well-adapted to 

inherent pathogenic and disturbance events and endemic fluctuating levels. Wildlife habitat is often 

improved by the diversity of structural conditions created by mistletoe (brooms for nesting) or Indian paint 

fungus (cavities in large trees). When bark beetle insect populations rise and peak cyclically, populations of 
Appendix C Snow Basin Vegetation Management Project FEIS

553

predator species from woodpeckers to small mammals to invertebrates such as arthropods and 

hymenoptera benefit, with an abundance of high protein forage and new habitat opportunities in the 

making. The analysis fails to account for the natural abundance of mistletoe and Indian paint fungus in old 

growth trees and seeks to remove these trees because of impacts to the understory. However, a very real 

possibility is that the future trees that reach old growth size will again have mistletoe. With such an openly 

recognized shortage of old growth Ponderosa Pine, removal of old growth Pine to benefit the understory is 

very contradictory. (D59 p. 8)

Response: Reference Ch. 3 Section 3.1 for discussion on defoliating insects, bark beetles and mistletoe 

removal protocol. Also all alternatives will leave all cull grand fir trees infected with Indian Paint Fungus. 

Reference DEIS Ch. 3 Section 3.1 for mistletoe protocols.

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#38. Density reduction is often warranted in dry forest types that have experienced long-term fire exclusion, 

but there is not a scientific consensus about the need for density reduction in more moist forests, with mixed 

species, and mixed fire regimes. 

It appears there is some potentially unwarranted activities proposed in cool/moist and warm/very moist 

grand fir sites, but it is difficult to tell from the DEIS whether each treatment unit is characterized by dry, 

moist, or intermediate plant association groups (PAGs). It is hard to find in the DEIS a clear description of 

how much commercial logging is planned within the different forest types, but there are a few revelations 

scattered in the DEIS, like ... "Within G4, an estimated average 5 larger trees per acre would be removed 

over 973 acres ...." DEIS p 234.

This project proposes to reduce multi-storied large-tree old growth (MSLT LOS) in cool/moist fir PAGs 

that are already below HRV. This project also reduces both multistoried and single-storied LOS in 

warm/dry fir and warm/moist Douglas-fir and warm/dry Douglas-fir and ponderosa-pine. We urge the FS 

not to trade one rare forest type for another. Please focus on treating non- LOS forests to restore rare singlestoried LOS, while retaining multi-storied LOS to meet the continuing deficient in this habitat type caused 

by past (and ongoing) logging. (D64A p. 19)

Response: The acres treated by Biophysical Environment is shown in the FEIS in Chapter 3 Section 3.1 

Forest Vegetation; Effects Analysis . Reference Table 11. Estimate of the number of large trees that 

would be removed by bio-environment and remaining large trees remaining after harvest in the treatment 

units. The alternatives do treat not LOS to restore LOS single story. Multi-story LOS is retained within 

HRV except for Cool / Moist which is currently below HRV. Management within multistoried stands is to 

restore historic species composition improving landscape resiliency. All alternatives treat non-LOS forests 

to restore single storied LOS.

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#39. Purpose and Need is Inherently Limited to the Warm/Dry Forests and Threatens Widespread Forest 

Degradation to Moist Forest Types. The Purpose and Need states (DEIS at 2):

“This project is needed to help restore a full complement of vegetative patterns within the natural range of 

variability across the landscape. These vegetative patterns will be described in terms of the major forest 

elements: 1) structural stages (vertical and horizontal arrangement), 2) vegetation type (relative composition 

of different tree species), and 3) tree sizes (large diameter vs. small diameter trees). Specifically, the purpose 

of the project is to restore more natural and sustainable forest structure, composition and densities based on 

the fire ecology of low and mid elevation warm dry forests. The project would have other resource benefits 

including the reduction of wildfire risk in urban interfaces and restoring important wildlife habitat.”

Here the Purpose and Need professes that the specific purpose of the project is to restore a forest structure, 

composition, and density based on the fire ecology of low and mid elevation warm dry forests. Therefore, if 

the project area includes forest types that are outside of the low and mid elevation warm dry forest type, 

these forests are being subjected to a management approach that does not mimic the characteristic natural 
Appendix C Snow Basin Vegetation Management Project FEIS

554

disturbance regime. It is scientifically well documented that active forest restoration treatments must be 

consistent with the natural disturbance regime of a forested landscape (Brown et al. 2004; Noss et al. 2006; 

Crist et al. 2009) or significant degradation of the forest, such as loss of resiliency and biodiveristy, 

homogenization of forest structure, reduced canopy cover and increased fire risk, increased risk of insect 

epidemics, degraded wildlife value, and degraded soil and watershed values can occur (Rieman and Clayton 

1997; Lindenmayer et al, 2009). (D59 pp. 3-4)

Response: See Ch. 3 – Section 3.2 Fuels for discussion on FRCC. The treatments in Cool/Moist forest 

are targeting tree species composition. Through the past removal of large ponderosa pine and decades of 

fire exclusion stands in this type are converting the pure grand fir. Ponderosa pine and western larch, 

shade intolerant species, are succumbing to grand fir. The principle of forest succession is that, without 

disturbance, stand will convert to their most shade tolerant species. In the cool/moist type this is grand fir. 

This is evidenced on the ground, by reduced crowns, lack of regeneration, and mortality in the ponderosa 

pine and larch.

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#40. In addition to the scientifically insupportable logging of 43,679 old growth trees greater than 21” 

across the planning area, the Snow Basin proposal also provides for the removal of unspecified numbers of 

more old growth trees greater than 21” dbh throughout the project to provide for the movement of 

machinery, and fails to disclose the number of 21” dbh and above trees that are likely to be felled for skid 

trails, roads, landings, safety rationales, and other reasons. (D59 p. 21) 

Response: Danger trees (some 21+) would be removed or felled to protect the public and forest workers. 

Danger trees could be alive or dead and be of any size capable of creating a hazard. They would occur 

along haul roads and near harvest operations (landings, skid trails, felling areas). They would be identified 

by a qualified person using the Field Guide for Danger Tree Identification and Response. (Toupin, Filip, 

Erkert, & Barger, 2008). Recent experience on Barnard, Pine Valley, Moonshine, East Eagle, and 

Skookum timber sales is that, on average, 0.25 operational trees are removed per landing.

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#41. Table 53 on Page 97 of the DEIS calculated out shows that the estimated number of large trees to be 

cut in preferred Alternative 2 is 43,679 large trees to be killed, which would then leave 53,533 that would not 

be cut. This estimate indicates there are only 97,212 large trees. They propose to kill 44.9% of all the large 

old trees on the project area. Remember, the large trees are supposed to be protected. (D22 pp. 1-2)

Response: Reference Ch. 3 Section 3.1 – Table Estimation of Large Number of Trees being removed by 

Bio-Environment. Alternative 4 does not remove trees >21". All alternatives have been modified to not 

remove Old Trees. Reference Ch. 3 Section 3.1. 

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#42. Reported trees being harvested >21” on all acres (average) and in Biophysical Environments should be clarified 

that they are only estimates and are currently estimated to be for 0-3.5 TPA. It should also be clarified that the 

majority of the trees are Grand Fir in non-natural environments across the landscape. As I found out P 97 of the DEIS 

has estimates of these trees being removed that are arbitrarily high especially in the DF BPE. I also believe that these 

numbers should also be represented at a project level and a forest level to put the impact of the harvest of the 21” trees 

into context. I think breaking it out into a unit basis would help as many units have no trees of this size in inventory so 

the “average” label will misinform the public. Once again this project treats very little of the overall landscape. (D29 

pp. 1-2)

Response: Reference Ch. 3 Section 3.1 – Table Estimation of Large Number of Trees being removed by BioEnvironment.

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#43. In the absence of recommendations from a scientific panel as contemplated under the proposed Wyden 

Legislation, we urge the Forest Service to retain all trees over 21” dbh with the following limited exceptions: 

(see D64A, p. 10). These criteria for management of large trees are adapted from the Burnt Willow project 

on the Fremont-Winema NF and are explained in more detail on D64A pp. 10-14. (D64A pp. 10)
Appendix C Snow Basin Vegetation Management Project FEIS

555

Response: In the FEIS, the alternatives have been modified to use age to identify large old trees defined as greater 

than 150 years. The Snow Basin project was started before the Wyden legislation was initiated. In review of the 

Wyden bill, this project meets the intent of the Wyden Bill. 

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#44. The following is a brief outline representative of the range of current scientific information that should 

be incorporated in revising the proposed decision and management actions of the Snow Basin Project: 

(D59 p. 37)

Management recommendations based on scientific forest and fire ecology research:

Restrict fuel treatments only to areas where multiple lines of empirical evidence clearly indicate that the fire 

regimes have been altered; there are currently more high-severity fires than there were prior to fire 

suppression; and significant prior management has previously logged, roaded and degraded the forest 

ecosystem. In such areas, limit thinning to small-diameter trees beneath the forest canopy. Ensure that 

treatments do not occur in systems where fire regimes have not been altered.

Response: See the FRCC analysis in the FEIS. Analysis indicates a current FRCC departure of 64% with 

an expected improvement to 34-37%, depending upon alternative. 

The area has seen widespread management over the past 100 years, including mining, timber harvest, fire 

suppression, and has an extensive road system in place. Relative to thinning of small diameter trees only, 

see explanation in DEIS, page 117-118 regarding the effective methods of accomplishing fuels treatment. 

 

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#45. The ecological reality of imposing an artificial fire regime onto a mixed severity system through heavy 

industrial logging and prescribed fire is forest degradation. The Snow Basin proposal would senselessly 

degrade the mixed conifer stands it treats. There is no peer-reviewed science that states we should be 

converting the mixed or high severity fire regime to one characterized by low intensity surface fires because 

of climate change. (D59 p. 49)

Response: See response #27. Large, continuous areas represented by cool moist and cold dry sites which 

would be expected to have less frequent occurrence of fire, are not proposed for treatment and overall 

exhibit a history of fire frequency that is within the range of what would have been expected historically 

(See FRCC analysis). No proposed action is included on any stands categorized as high severity fire 

regimes

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#46. Preventing fire from reaching the canopy to allow direct fire suppression in mixed conifer forests has 

nothing to do with the natural fire regime or the historical condition. This is not an ecologically appropriate 

goal. This is a fire fighting goal that has nothing to do with the historical conditions of these forests or the 

characteristic fire regimes. If the Forest Service’s goal is to improve direct fire suppression tactics in mixed 

conifer systems, then just be honest about it and quit masking the real goals as “restoring historical

conditions.” (D59 pp. 49-50)

Response: See response #27. Large, continuous areas represented by cool moist and cold dry sites which 

would be expected to have less frequent occurrence of fire, are not proposed for treatment and overall 

exhibit a history of fire frequency that is within the range of what would have been expected historically 

(See FRCC analysis). The purpose and need (FEIS Chapter 1) does not list fire suppression as a project 

goal.

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#47. The DEIS on p. 121 states that silvicultural treatments that target canopy closure have the potential to 

reduce the development of all types of crown fires if surface fuels are concurrently treated. These 

treatments also have the potential increase fire risk in moist stands, while degrading wildlife habitat and 

overreducing closed canopy forests in the area. (D59 p. 49)
Appendix C Snow Basin Vegetation Management Project FEIS

556

Response: See responses #27 and #30. Large, continuous areas represented by cool moist and cold dry 

sites which would be expected to have less frequent occurrence of fire, are not proposed for treatment and 

overall exhibit a history of fire frequency that is within the range of what would have been expected 

historically (See FRCC analysis).

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#48. The DEIS purports that because of 100 years of fire suppression these forests are now in need of these 

“treatments.” However, the focus of these “treatments” is to improve the ability to do more fire suppression. The 

analysis in the DEIS gives no recognition to the fact that these flame lengths are natural in some areas and 

artificially changing the fire regime combined with more fire suppression is not restorative and will actually 

degrade ecosystem function. (D59 p. 50)

Response: See response #27. Analysis also states that low to moderate fire severities will be expected to 

be reintroduced.

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#49. See literature (paper) attached to D78. (D78 pp. 5-10)

Response: Literature is in reference to treatment in Moist Forest. Examples are relative to “very moist”, 

tropical conditions for instance, however responses #27 and #30 address the comment.

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#50. Fire/fuels analysis runs counter to best available science for mixed severity systems. (D59 pp. 46-47)

Response: An error was discovered in the FRCC analysis relative to expected mortality levels, 

particularly following summer wildfire, primarily in the moist stand types. This error has been corrected 

along with a modification done to incorporate elimination of several burn only units along the Eagle Creek 

Drainage. See response #27 regarding concerns for treatment of cool moist stands. 

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#51. Analysis does not limit impacts of fire suppression to scientifically documented plant association 

groups and the relevant fire regimes. There are many places in the DEIS that describe the large range of 

elevation, hydrological, topographical, and biotic characteristics of the project area. (see DEIS p. 42, 139, 

107). (D59 pp. 11-12)

Response: See response #27. The moist vegetation types identified for treatment are intermixed with warm dry 

sites (the majority of the sites in the analysis area) and as such would have been historically impacted with natural 

disturbance (frequent periodic fire). See DEIS, Pages 124-127 for discussion of FRCC. 

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#52. Fuels reduction thinning should be applied only in ecologically appropriate dry ponderosa pine and 

limited pine intermixed with Douglas-fir plant association group forests. This is the only fire regime where 

we can honestly say that fire suppression has outlasted the range of the fire return interval and therefore 

stand structure is outside of a historical condition. These projects should be ecologically constrained by 

elevation and by site-based evidence of non-lethal surface fire on a short return interval. (D59 p.1)

Response: See application of FRCC modeling data including change to stand structure, fire regime 

descriptions, and PNVG’s in analysis, pages 124-127 in DEIS. See response #27 for additional 

clarification added to the fire/fuels analysis regarding moist sites. In the reference to Fire Return Intervals, 

Cool Moist Forests have missed more than one fire return intervals as well as Warm / Dry. 

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#53. The subalpine fir/lodgepole pine high elevation forest is characterized by stand replacement fire 

regime. The moist mixed conifer stands that compose the ecological transition between the high elevation 

cold forest types and the low elevation dry forest types are characterized by a variable intensity fire regime. 

Even in the dry forest types, fire regimes had much more variability than the DEIS description 

acknowledges, including high severity fire that needs to be recognized and areas of dense regeneration. The 

dominant fire regime of the inland Pacific Northwest is the mixed severity fire regime. (D59 p. 5)
Appendix C Snow Basin Vegetation Management Project FEIS

557

Response: The FEIS was corrected to show low to moderate severity in Warm / Dry and Moist Forest 

Types. See response to #27 for additional clarification added to the fire/fuels analysis regarding moist 

sites

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#54. It is completely scientifically indefensible to suggest that fuels reduction treatments are ecologically 

appropriate for these moist forest types (cool/moist grand fir and warm/very moist grand fir types). It is 

alarming that the Forest Service is so focused on restoring pine and larch that it would recognize natural 

succession in a moist mixed conifer forest. Natural succession has washed away the impacts from the 

historic selective removals like the ocean washing away a sand castle. Nothing needs fixed in this forest type. 

The effects of logging on fire regimes in moist conifer forest types run counter to the goals of Snow Basin. 

(D59 p. 7)

Response: See response to #27 for section added to Fire/Fuels analysis relative to cool/moist sites. 

Succession in the absence of natural disturbance on these forest types, combined with historic selective 

harvest of ponderosa pine, western larch, and Douglas-fir has resulted in stands dominated by grand fir 

addressed in the comment. Treatments are designed to return stands to conditions that would have been 

typical under natural succession with disturbance, and over time without selective harvest of early seral 

species. 

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#55. The DEIS discloses that the purpose of these “treatments” are to reduce flame lengths to promote 

direct attack fire suppression tactics with no acknowledgement that in some forest types, flame lengths are 

naturally greater than what is required to support direct attack. (D59 p. 8)

Response: DEIS described expected changes in flame length as well as overall fire type (crown vs. 

surface) associated with general overall changes in fuel model following fuels and vegetation treatment, 

DEIS pg 122. The role of high intensity, stand replacement fire, particularly in cold dry stand types was 

not fully addressed as treatments in those stand types was not proposed. Fire behavior modeled for 

cool/moist sites was done for treatment units identified in which the cool/moist sites are surrounded by 

warm dry vegetations and given proximity would have been expected to support similar vegetation (and 

fire behavior) under historic disturbance. 

Treatment of cool/warm moist sites is further clarified in the FEIS, see response to #27. 

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#56. The DEIS fails to take a “hard look” at effects of alternatives on soil productivity. Snow Basin 

Alternatives 2 and 3 would remove over 40,000 trees over 21” dbh, whereas alternative 4 would keep all of 

these same trees. Surely, on this key different in future nutrients being on site, vs. being sent to the mill, the 

Snow Basin DEIS should espouse the superiority of Alternative 4 over Alternatives 2 and 3. The one 

sentence analysis on p. 157 of the DEIS provides no effort to significantly understand this issue and is a 

violation of the NEPA core tenet to take a “requisite hard look” at such a key issue of long term 

productivity. The LRMP states that maintenance of soil productivity and stability is to be given priority 

over uses described in all other management direction, standards or guidelines (LRMP at 4-21). The 

priority needs to be given to soil health, not other needs. The LRMP intends a general improvement in soils 

conditions across the WWNF. (D59 pp. 61-63)

Response: As stated in FP-1, “...no standard exists for CWD either in the W-W Forest Plan or Region 6 

Soil Quality standards.” In terms of the LRMP at 4-21, this applies to situations where conflicts with other 

uses do exist, with exceptions given to campgrounds and transportation facilities. “Conflicts” with 

management actions such as timber harvest are addressed in the LRMP through Soils Standards and 

Guidelines #2, which disallow detrimental soil conditions over 20% of an activity area. The FEIS discloses 

that nitrogen levels probably are currently higher than they were before fire suppression, that the nitrogen 

removed during a thinning would be replaced in about 35 years or less, and that on most sites productivity 

is more limited by water than by nitrogen.

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Appendix C Snow Basin Vegetation Management Project FEIS

558

#57. Large, mature, shade tolerant trees are future old-growth, snags and downed logs. Snags are 

“currently uncommon” in eastern Oregon (only 1 per acre presently) and management may be necessary to 

produce a greater density of large snags (Donnegan et al. 2009 [pp. 47-48]). Mature, early-successional trees 

are priceless in this regard; they can be likened to an investment in future forest health, regardless of 

disturbance (disturbance doesn’t remove the biological legacies). The Snow Basin proposal will drastically 

change these old-growth stands by removing mature trees that are currently showing old-growth 

characteristics. (D59 pp. 34)

Response: As a result of public comment the project would avoid harvest trees 150 years of age or older. 

This would be based on visual characteristics and age/dbh sampling as described in Chapter 3 of the FEIS.

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#58. Failure to take a hard look at impacts on OHV access and motorized recreation. DEIS Table 89 shows 

an increase in OHV use in the last 5-10 years. The DEIS on p. 304. The Snow Basin DEIS has not evaluated 

how opening up the forest so dramatically with heavy logging, tractor and skid trails will affect OHV use in 

the area. (D59 p. 97)

#59. More information on ATV use in riparian areas is needed. The statement in the DEIS is too general. 

(D59 p. 77)

Response: Cumulative effects related to travel management are covered in Appendix B-10, Potential 

Cumulative Effects Activity List; the Transportation section in Chapter 3; and in route-specific tables in 

the project record.

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#60. The Snow Basin Project Area landscape is seriously low in snags. The DEIS confirms this on p. 239.

All alternatives will drastically reduce future snags for snag dependent wildlife, while alternatives 2 and 3 

will erase the progress toward restoring large trees across the landscape made since the Eastside Screens 

were initiated. (D59 p. 80)

Response: The commenter incorrectly states that the proposed activities in Alternatives 2 and 3 would 

“erase the progress toward restoring large trees ...” While these alternatives would temporarily reduce the 

number of 21+ trees, it will set the stage for large areas of the project area to develop into characteristic 

LOS. One of the main objectives is to increase tree size at a faster rate and to protect existing large 

ponderosa pine and western larch. Although the “pool” of potential future snags is reduced, the stocking 

levels in intermediate treatment units reflect what is appropriate and sustainable for those sites. (See 

vegetation summary in chapter 3 of the FEIS). 

In addition, no existing snags would be removed with the proposed activities, except those that pose a 

hazard to forest workers or the public. While reducing stand densities may decrease density and in-stand 

tree mortality due to inter-tree competition, non-density related mortality factors such as prescribed fire, 

wind and snow damage, drought, insects, and root disease will continue to create snags in treatment units. 

Treatments are expected to accelerate development of larger trees, and therefore, larger snags on the 

landscape. In addition, density-related tree mortality will continue in untreated areas (FEIS, MIS species -

Primary Cavity Excavators). Also, see FEIS appendix B for the total acres of areas in Snow Basin where 

no activities would occur. Snag levels in these areas are expected to increase over time. For additional 

information see response to comments #25 and #26, and also FEIS appendix B: Factors Affecting the 

Occurrence of Snags and Large Down Logs.

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#61. To bring Snow Basin more in line with proposed Wyden Legislation, retain an adequate population of 

all sizes of trees within treated areas to provide for recruitment of ecologically valuable future large trees 

and snags. This does not mean that all small and medium sized trees need to be retained, but it means 

conducting careful analysis to ensure that future recruitment is assured through retention of adequate 
Appendix C Snow Basin Vegetation Management Project FEIS

559

numbers of smaller trees, most likely in patches within and between stands. (D64A pp. 18-19, D64A p. 9, 

D64A p. 14, D59 p. 1, D64A pp. 26-27)

Response: The FEIS discloses that the Overstory Removal prescriptions would reduce GTRs to a level 

that may require induced mortality to maintain snags until the young sapling stands grow into large size.

See Chapter 3 of the FEIS and the Vegetation Report. Implementation of the proposed activities in the 

Intermediate units would leave stands fully stocked with trees but at levels reducing mortality from intertree competition. However, inter-tree competition is only one way trees become snags. Appendix B of the 

Silviculture Report discusses how drought, weather events, and fire create snags and also displays the 

acres in Snow Basin where no activities would occur. Snag levels in these areas are expected to increase 

over time. See also response to comment #60.

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#62. This project will remove 42 mmbf of logs from smaller size classes than 21”, which means that large 

numbers of trees 12-21” dbh will be removed. An unavoidable impact of a project like this is to put a 

significant dent in the recruitment pool for future large trees and snags. The DEIS does not fully disclose 

the long-term effects of commercial logging. These effects need to be quantified with a stand simulation 

model, and the FS needs to show that sufficient medium sized trees are retained for future recruitment of 

desired levels of large trees (both live and snags). The DEIS analysis of effects on snag habitat are not 

adequate. The effects analysis focuses on existing snags while ignoring the more significant effect of logging 

in terms of “capturing mortality” and reducing the pool from which future snags and logs are recruited.

This is by far the most significant and meaningful effect of logging and must be disclosed quantitatively.

(D64A pp 26-27)

Response: See response to Comments #60 and #61. 

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#63. The DEIS says that the Eastside Screens 21” dbh limit is getting in the way of restoration, however 

Table 53 (DEIS p. 97) shows that most of the large trees will be removed from acres that currently have an 

average of less than 10 large live trees per acre, and commercial logging will remove an average of 40-50% 

of those trees. In order to restore historic populations of large trees, and large snags, the Forest Service 

needs to maintain an adequate population of medium and large trees for recruitment. To account for future 

mortality, the current population of medium and large trees must be far larger than the target level of large 

live trees. Based on the management history in this project area, the shortage of large snags on these acres is 

likely or equal or greater concern. This highlights that these stands suffer from a severe shortage of large 

tree structure, and this project will exacerbate that problem. When the landscape has this few large trees, it 

is important to keep the few that exist. If the species composition really needs to be addressed, then at least 

the valuable physical structure of these large trees should be retained as snags. The Regional Forester’s 

letter also urged careful consideration of the need to recruit ecologically adequate levels of snags, which the 

local Forest Service has not done here. The enclosure to the Regional Forester’s memo says “it is critical 

that silvicultural prescriptions provide for large snags in adequate numbers (as indicated by DecAID and 

other tools) through time to provide habitat for these species.” The Wallowa-Whitman National Forest 

Land and Resource Management Plan snags standards are scientifically outdated, and have not been 

updated. DecAID provides information but not standards or threshold to guide management. The DEIS 

lacks any stand simulation analysis or disclosure of the long-term effects of logging on future recruitment of 

snags. For all these reason, the Forest Service lacks any credible basis for concluding that snag needs are 

being met, or that removal of 40-50% of the few remaining large trees in treated stands will not adversely 

affect diverse wildlife associated with snags. (D64A, pp. 11-12, 29-31)

Response: See response to Comments #60, #178, #61, #26 and #413.

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#64. The removal of 43,000 large trees in an area where extensive high-grade logging has created a severe 

deficit of large green trees (and snags) raises concerns and needs further analysis (D64A, p. 2)
Appendix C Snow Basin Vegetation Management Project FEIS

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Response: The Direct, Indirect, and Cumulative effects of large tree reduction are disclosed in the vegetation report 

in Chapter 3 of the FEIS. 

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#65. The Forest Service fails to recognize that it was the large, valuable trees that were logged historically, 

and now it is the large valuable trees that are proposed for logging again. With regards to large trees, Snow 

Basin is more of the same of what happened going back decades. Even if all of the 43,679 trees over 21” 

DBH that would be cut are dropped from the project, Snow Basin would go from a 62 MMBF timber sale to 

a 42 MMBF timber sale. To produce this kind of volume without cutting any trees over 21” indicates that 

Snow Basin would cut heavily in the 15-20.9” DBH range; the replacement old growth. (D59 p. 4)

Response: See response to Comments #61, #63, and #64.

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#66. Dynamic ecosystems historically included a variety of mortality events, both large-scale and smallscale, both pulsed and continuous. Mortality and biomass accumulation are natural and desirable ecological 

processes that forest management has been working for decades to suppress, capture, and avoid. Large 

snags are severely underrepresented in our forests and commercial logging virtually always reduces and 

delays recruitment of future large snags. (see references, D64A pp. 27-28) One of the most significant effects 

of logging is its effect on dead wood, but this is not an issue the agencies have given serious consideration to.

DEIS p. 42 and 241 say that a large fraction of the project area has experienced timber harvest, mostly highgrade removal of large pine and larch – 94% of the planning area has had previous partial cutting, with 

approximately another 6 percent having been regenerated. That means that an entire cohort of the best 

large trees has been removed from the forest before they could ever fulfill their full lifecycle as snags and 

dead wood. The continuing long-term effects of past management do not appear to be fully appreciated by 

the FS in the design of this proposal. Further logging in this already heavily logged watershed, while 

intended to correct the shifting species composition, will also cause further cumulative loss of snag 

recruitment and exacerbate the existing cumulative loss of snags across the project area. Once quantified, 

the FS will find that the effect on future recruitment of dead wood is likely to be both significant and longlasting, affecting snags both small and large. (D64A pp. 27-29)

Response: See response to Comments #60, #61, #63 and #64.

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#67. Two of the best ways to mitigate for the loss of dead wood include: retaining more untreated “skips” 

and to retain higher basal area within treated areas. (D64A p. 29) 

Response: Snow Basin’s approach to attaining or maintain a variable density landscape can be found in 

the FEIS vegetation report. See appendix B of the FEIS for total acres not treated within the project area. 

In addition to wildlife refugia, RHCAs, and Wild and Scenic River corridors that will not be treated, this 

project also designated wildlife corridors where basal area would remain higher. Also see FEIS Appendix 

B for a discussion of how snags occur. 

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#68. We are concerned that the adverse effects of extensive commercial logging without adequate skips 

could be long lasting. The graph below (see D64A p. 16) shows that thinning can delay attainment of large 

snag objectives by more than 60 years. This result is primarily a result of the significant reduction in the 

recruitment pool from which future snags are derived. The Snow Basin DEIS did not conduct any 

quantitative analysis that would reveal the true effects on habitat recruitment. The Snow Basin FEIS must 

include a stand simulation analysis as a way to show the temporal effects of logging and to help identify the 

scale of refugia needed to meet habitat objectives for wildlife that depend on dense forests and dead wood.

(D64A p. 15)

#69. Proposed treatments threaten to remove what would eventually become high quality snags and large 

downed logs in an already snag deprived landscape and favor commercial characteristics such as crown 

ratios that homogenize the landscape at the expense of verified old growth characteristics. (D59 pp. 89-90)
Appendix C Snow Basin Vegetation Management Project FEIS

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Response: See response to Comments #60, #65, and #67.

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#70. Large, mature, shade tolerant trees are future old-growth, snags and downed logs. There is currently 

a significant deficit of large snags (dead trees) in Oregon’s forests relative to the minimum habitat needs of 

many native cavity-nesting wildlife species, especially in eastern Oregon (Donnegan et al. 2008). This Forest 

Service report, based upon thousands of field plots, concluded that large (over 20 inches in diameter) snags 

are “currently uncommon” in eastern Oregon (at only 1 per acre presently), and determined that 

“management may be necessary to produce a greater density of large snags” (Donnegan et al. 2008 [pp. 47-

48]).

While we cannot change the snag deficit due to past logging, it is imperative that we recognize that the 

mature trees in the Snow Basin Project area are the future old-growth trees, large snags, and large downed 

wood. The mature, early-successional trees are priceless in this regard; they can be likened to an investment 

in future forest health, regardless of disturbance (disturbance doesn’t remove the biological legacies). The 

Snow Basin proposal will drastically change these old-growth stands by removing mature trees that are 

currently showing old-growth characteristics. (D59 p. 34)

Response: See response to Comments #60, #178, #65, #67, #26, and #134. 

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#71. OFMS to OFSS Conversion Artificially Imposes a Low Severity Fire Regime on a Mixed Severity 

System. As has been discussed, numerous studies have now conclusively shown that variable fire severity 

was the dominant fire regime and that mixed conifer forests were the dominant forest type in the Blue 

Mountains (Noss et al. 2006, Hessburg et al. 2007; Baker et al. 2007). The Wallowa Mountains, with its 

fantastic biological, topographical, and hydrological complexity fits this description very well. The Snow 

Basin project encompasses a large diversity of forest types. That low severity fire was the primary influence 

in this area is not supported by the best available science. The purpose in summary for the Snow Basin 

project states; “Restore and maintain resilient sustainable-forested ecosystems, specifically by creating open 

grown ponderosa pine, larch, and Douglas fir stands dominated by the largest trees on the site.” This 

summary runs counter to the best available science for all mixed conifer and moist forest sites and threatens 

logging to forests based on inappropriate application of the disturbance regime. (D59 p. 33)

Response: Revised analysis to differentiate Cool / Moist from Dry Forests. Discussions fire Regimes have been 

modified to include both low and moderate severity fires. See FEIS Ch. 3 Section 3.2. 

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#72. To analyze the cumulative effects of repeatedly waiving the Eastside Screens old-growth protections, 

each of these effects should be considered. The time crowding is especially relevant given the extreme loss of 

the old-growth resource that has already taken place across the WWNF, resulting in the small fraction of 

old-growth remaining. The Eastside Screens were specifically developed to address the extreme depletion of 

old-growth throughout the greater eastside region. Numerous site-specific amendments to allow commercial 

logging within the last few remaining old-growth pockets, a trend that has accelerated greatly in recent 

years, have resulted in “frequent and repetitive effects” to this forest-wide resource. Nevertheless, the Forest 

Service has yet to critically examine these “frequent and repetitive effects” at a forest-wide scale.

Response: Reference DEIS Pg. 101 Late and Old Structure Forest (LOS) - Landscape Assessment. 

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#73. The Forest Service is well aware of the fact that the old-growth resource is already highly fragmented 

across the WWNF, and unfortunately throughout the region. Again, this is another fact that led to the 

development of the Eastside Screens in the first place. The WWNF may be perpetuating old growth habitat 

fragmentation through its series of site-specific amendments, yet it has never asked this critical question. 

Certainly converting one type of old-growth forest type to another forest type, with mechanical logging 

methods that create a whole slew of potential impacts, repeatedly, and on a piecemeal basis throughout the 
Appendix C Snow Basin Vegetation Management Project FEIS

562

forest, will result in “landscape pattern” changes. Moreover, the Forest Service has yet to assess what this 

further loss of an already deficient forest type (OFMS) means in terms of impacts to old-growth dependent 

species that are already declining and becoming rarer due to habitat fragmentation--particularly those that 

rely upon or prefer this forest type, such as American Marten, Pileated Woodpecker, and Northern 

Goshawk. (D59 p. 44)

Response: Increased accuracy in mapping has resulted in acreage recalculation in the FEIS. As a result, 

connectivity network and RHCAs have been increased.

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#74. HCPC is very concerned that the Forest Service is foreclosing future options for preserving old-growth 

through its increasing use of site-specific amendments to allow logging in older (LOS) stands that are within, 

or below HRV. With Snow Basin the Forest Service greatly ups the ante from many previous proposals 

where hundreds of trees greater than 21” DBH would be removed, to tens of thousands of trees across the 

sub-watershed scale. As discussed in detail below, these kinds of decisions are being proposed with 

increasing frequency without any regional or forest-wide analysis on the ecological consequences and 

cumulative impacts of this piecemeal approach.

HCPC has actively engaged with the Forest Service on numerous occasions regarding the agency’s frequent 

waivers of old-growth protections. We have repeatedly expressed that our organization generally supports 

restoration efforts aimed at increasing the development of old-growth single-story structure by thinning 

stands in the stem exclusion closed canopy and understory reinitiation structural stages, but that we want 

old growth forests protected.

When it comes to old-growth, our concerns pertain directly to the Forest Service’s decision to repeatedly 

allow commercial logging within, and the removal of intermediate and mature trees from, these old growth 

stands. Both the law and the best available science demonstrate that commercial logging in our last few 

remaining old-growth stands is unacceptable.

The Forest Service’s current approach to old-growth management is fixated on the number of acres

classified as Multi-Stratum Large Tree (“MSLT”) and Single-Stratum Large Tree (“SSLT”) and the need to 

increase SSLT. This fixation is well captured by Snow Basin’s preferred approach that would treat MSLT 

that is below HRV (see table 26 of the DEIS). This approach threatens the same degradation to MSLT that 

has already occurred in SSLT. 

This discrete old-growth classification approach also has many weaknesses because both MSLT and SSLT 

forest structures historically existed in very close proximity to one another, in a complex mosaic with no 

fixed boundaries. Changes in aspect and topography, for example, historically altered the fire regime at fine 

scales, resulting in a patchy mosaic of forest structures across the landscape. In reality a gradient of oldgrowth forest structure existed between the driest old-growth single story Ponderosa Pine forest and moist 

mixed conifer old-growth forest. The mixed severity fire regime that defines the Blue Mountains creates a 

great diversity of habitat conditions that are excellent for a broad array of organisms.

The Wallowa-Whitman National Forest (WWNF) has proposed numerous timber sale projects that call for 

commercial logging in MSLT old-growth stands to convert those stands to SSLT over the past several years. 

Note that the Tremble Aspen Project has reached The agency points to the need to increase SSLT acreage in 

its documentation, with no science to support that a functional change actually results due to the mechanical 

treatment, and despite a vast amount of science warning about furthering the spread of mechanical 

treatment into our last unlogged forests. The Forest Service lacks any information regarding monitoring in 

previously converted areas. A basic tenet of ecological restoration is that the creation of form without 

function does not constitute ecological restoration (Kauffman et al. 1997).
Appendix C Snow Basin Vegetation Management Project FEIS

563

The rate of these conversion treatments has dramatically increased in recent years. All told, the Snow Basin 

project, when added to past site-specific amendments, will affect over 5% of the WWNF’s remaining oldgrowth. The significance of this figure must be viewed in light of the fact that only 2% of the entire 2.3 

million-acre WWNF is representative of old-growth forest conditions.

The Forest Service is not following the best-available science with regard to treating old-growth forest 

habitat. The literature urges a precautionary approach--remove only the smaller trees so that fire can be 

reintroduced. That is all that is needed to reduce competition for moisture and nutrients and reduce fire 

risk, both main goals put forth in the Snow Basin DEIS. Overtime this treatment plan will move stands 

toward a more open canopy structure because subsequent under-burning will continue to remove the new 

regeneration (not that it should all be removed), and natural competition combined with disturbance agents 

will result in canopy mortality. Instead the Forest Service insists on aggressive treatments that risk invasive 

weed spread, soil disturbance, increased fire risk, drier conditions, and loss of overall carbon storage; all so 

the amount of SSLT will be increased on paper. It seems that the Forest Service does not have the patience 

to treat these stands appropriately and is trying to do too much too fast. Regarding the moist forests 

proposed for treatments, there is no ecological justification for the proposed treatments period. (D59 p. 27-

28)

Response: In moist forest stands, activity slash may be treated with prescribed fire post harvest. Maintenance 

burning will not be reintroduced into these stands outside the historic fire return interval. See FEIS Ch. 2 –

Description of the Alternatives. DEIS Pg. 101 Late and Old Structure Forest (LOS) - Landscape Assessment. 

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#75. The Forest Service’s justification of such a massive removal of trees over 21” is not supported by the 

2003 Goodman letter itself which states with regards to wildlife habitat and snags:

“For example, the U.S. Fish and Wildlife Service (2002) documented birds of conservation concern. Those 

for eastern Oregon and Washington include a number of species associated with LOS. Work with the 

DecAID advisory tool (Mellen et al. 2003) indicates 70 percent of populations of the following bird species 

(some cited as concerns in U.S. Fish and Wildlife Service 2002) use snags as follows:

Pygmy nuthatch: 18-34 inches or larger

White-headed woodpecker: 18-36 inches or larger

Pileated woodpecker (an MIS): 20-35 inches or larger

Flammulated owl: 6-53 inches or larger

The fisher is a Regional Forester’s Sensitive Species found in moist eastside forests. The Fish and Wildlife 

Service has recently been petitioned to list the fisher under the Endangered Species Act. Data from DecAID 

indicate that 70 percent of fishers use snags between 27 and 47 inches DBH. Radio telemetry studies indicate 

that snag densities in telemetry locations of fishers are significantly greater than those of random sites.

These findings reinforce the importance of retaining and recruiting large, old trees in the eastside landscape, 

particularly (but not only) in Forests historically dominated by single-story LOS. It is critical that 

silvicultural prescriptions provide for large snags in adequate numbers (as indicated by DecAID and other 

tools) through time to provide habitat for these species.”

In stark contradiction to the guidance given above regarding snag recruitment, Snow Basin would eliminate 

the progress that we have to get more large trees and future snags on the landscape for these imperiled 

species made since the Screens were enacted. As already stated in these comments, not only would the 

preferred approach cut over 43,000 trees greater than 21” DBH, all alternatives would log heavily in the 

mature (15” to 20.9” DBH) range, drastically reducing future snag recruitment. The Snow Basin proposal is 

not balanced. (D59 pp. 26-27)

Response: Snag recruitment is discussed in the Wildlife section in Chapter 3. 

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Appendix C Snow Basin Vegetation Management Project FEIS

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#76. Exceptions to the 21” diameter limit must have very tight constraints, not as broad as those proposed 

for the Snow Basin Project. In the Wyden legislation, trees over 21” could only be cut if determined to meet 

the land management goals of the legislation. In the absence of a scientific panel’s recommendations as 

under the legislation, we urge the Wallowa-Whitman National Forest to use an example like the Burnt 

Willow Project on the Fremont-Winema National Forest.

A plan amendment for the Burnt Willow Project was signed in May 2007. There are many similarities 

between the Snow Basin and Burnt Willow Projects in terms of forest types, departure from HRV, and 

project purpose and need. The final decision on the Burnt Willow project, which was endorsed by the 

conservation community, approved a “site-specific Forest Plan amendment to remove white fir trees greater 

than 21 inches diameter breast height (dbh), where it would benefit even larger trees, especially old growth 

ponderosa and western white pine” with defined criteria for application in the field. 

In contrast, the Snow Basin Project criteria for the cutting of trees over 21” are very broad with large 

loopholes:

O Moving multi-layered ponderosa pine stands towards LOS of a single layer where the pine are competing 

with grand fir or other shade-tolerant species historically held in check by wildfire

O Maintaining shade-intolerant desirable trees <21 inch d.b.h. where their recruitment into >21 inch class is 

reasonably foreseeable in the near future, and when giving preference better meets LOS objectives

O Harvesting >21 inch d.b.h. mistletoe-infected trees when doing so best meets long-term LOS objectives and 

does not eliminate currently important wildlife habitat

O Fuel reduction when in Scenario A to protect older trees (e.g. removal of smaller "ladder" fuels)

O Overstory removal of shade tolerant species to protect rare or declining understory elements, such as aspen 

or rare herbaceous plants 

Important missing elements from these criteria include specification of:

• a clear logical connection relating the physical proximity of each large tree to be removed and the 

ecological benefits that are expected from such removal, and 

• some mechanism for site-specific application in the field, to ensure that the appropriate trees get killed 

and the appropriate trees get retained. 

In the absence of the scientific determination called for in the Wyden legislation, constraints like those in the 

Burnt Willow Project applied to the Snow Basin Project would help ensure the ecologically appropriate 

nature of large tree removal and limit controversy. (D64A, pp. 12-14)

Response: Marking guides provide site specific guidance in selection of greater that 21" trees to be 

harvested. These are in the analysis files. Large tree removal is based on the removal scenarios. See 

Chapter 3 Section 3.1 Forest Vegetation. In the FEIS, the alternatives have been modified to use age to 

identify large old trees defined as greater than 150 years. The Snow Basin project was started before the 

Wyden legislation was initiated. In review of the Wyden bill, this project meets the intent of the Wyden 

Bill. 

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#77. The local Forest Service is not faithfully following the Regional Forester’s 2003 direction about using 

flexibility to amend the 21” dbh limit. That letter explicitly said that the exceptions would be “site-specific,” 

not applied to virtually every acre of a 12,000 acre project. The DEIS analysis seems to imply that because 

there are instances within the project area that match the examples in the Regional Foresters’ 2003 memo, 
Appendix C Snow Basin Vegetation Management Project FEIS

565

therefore all 43,000 large trees are suitable for removal. To support the removal of thousands of large trees, 

there needs to be much more explicit and site-specific documentation, analysis, and criteria that can be 

applied in the field. 

The Regional Forester's letter urged retention of existing habitat values associated with large mistletoe 

infected trees. Yet, this is not being done in this project. (See the subsection and citations below regarding 

the ecological view of mistletoe.)

The Regional Forester 's letter also urged careful consideration of the need to recruit ecologically adequate 

levels of snags, which the local Forest Service has not done here. The enclosure to the Regional Forester’s 

memo says "It is critical that silvicultural prescriptions provide for large snags in adequate numbers (as 

indicated by DecAID and other tools) through time to provide habitat for these species.” The WallowaWhitman National Forest Land and Resource Management Plan snags standards are scientifically outdated, 

and have not been updated. DecAID provides information but not standards or thresholds to guide 

management. The DEIS lacks any stand simulation analysis or disclosure of the long-term effects of logging 

on future recruitment of snags. For all these reasons, the Forest Service lacks any credible basis for 

concluding that snag needs are being met, or that removal of 40-50% of the few remaining large trees in 

treated stands will not adversely diverse wildlife associated with snags. (D64A, p. 12)

Response: The Regional Forester’s letter of 2003 allows the consideration of the removal of live trees 

greater than or equal to 21 inches d.b.h. under ecological scenarios. See DEIS Chapter 3 – Section 3.1 

Forest Vegetation Pg. 92. This letter states that "Harvesting >21 inch d.b.h. mistletoe-infected trees when 

doing so best meets long-term LOS objectives and does not eliminate currently important wildlife habitat". 

Also see See DEIS Chapter 3 – Section 3.1 Forest Vegetation for the discussion on removal of large trees. 

Mistletoe will remain throughout the planning area including large trees in the untreated portion of the 

landscape. Alternative 2 and alternative 3 do harvest some large mistletoe infected trees. Alternative 4 

does not harvest any large trees. The silviculture prescription is designed to meet those scenarios and 

would be applied to each acre making the application site specific. The FEIS characterizes snag levels and 

explains that snags are unevenly distributed on the landscape, with some areas where snag densities reach 

50% and 80% tolerance levels. While reducing stand densities may decrease density and in-stand tree 

mortality due to inter-tree competition, non-density related mortality factors such as prescribed fire, wind 

and snow damage, drought, insects, and root disease will continue to create snags in treatment units. 

Treatments are expected to accelerate development of larger trees, and therefore, larger snags on the

landscape. In addition, density-related tree mortality will continue in untreated areas (FEIS, MIS species -

Primary Cavity Excavators). None of the alternatives propose removal of 40-50% of the remaining large 

trees. The Silviculture Specialist Report describes that on the average, approximately 1 tree per acre, >= 

21” DBH would be removed to address the objective of reducing the spread of mistletoe to host understory 

trees. 

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#78. When forest health is the objective, the Forest Service really needs to address the role of livestock. 

Grazing reduces the density and vigor of grasses and forbs which usually outcompete tree seedlings, often 

leading to establishment of shade-tolerant trees in areas where the FS would prefer open grown pine. 

Livestock also decrease the abundance of fine fuels which are necessary to carry periodic, low intensity 

surface fires. This reduces the frequency of fires, but increases their severity. See Belsky et al 1997 and 

Wuerthner 2003. (D64A p. 33)

#79. The NEPA document describes the effects “on” range resources (e.g., transitory forage) but fails to 

disclose or analyze the effects “of” livestock on forest health and the desired future condition of vegetation 

composition. A court decision (see D64A pp. 33-34) makes clear that the agency has a duty to take a hard 

look at the effects of grazing in the context of making timber sale decisions. The agency must disclose 

cumulative impacts and cannot compartmentalize. 
Appendix C Snow Basin Vegetation Management Project FEIS

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#80. The agency often erroneously concludes that livestock grazing will not affect upland vegetation or fuel 

profiles because fire suppressed stands are too dense to allow livestock access, but this is a gross 

oversimplification. The agency is conducting so-called “restoration” projects to reduce fuels and vegetation 

density which has and will allow livestock use. The NEPA document must disclose how livestock grazing 

interacts with the so-called forest restoration projects. The goal of restoration is a more open stand, and the 

agency wants more grass and forbs and fewer conifers, but grazing in those “restored” stands will cause the 

opposite effect - more conifers and less grass and forbs – thereby conflicting with the restoration objectives. 

(D64A p. 34)

Response: A discussion of the relationship between forest health and grazing in the Snow Basin project 

area has been added to the FEIS. 

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#81. The Snow Basin DEIS fails to present an evidence-based science driven analysis to mistletoe. Rather 

pages 86-88 are subjective and based on the personal experience of the silviculturist whose viewpoints on 

mistletoe are heavily influenced by the commercial timber production model (see section 21). This results in 

a heavily skewed analysis that is in violation of NEPA and alternatives that violate NFMA. (D59 p. 19)

Response: The vegetation and mistletoe analysis have been rewritten for the FEIS. See Chapter 3. 

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#82. Snow Basin DEIS has numerous discrepancies with NEPA’s accuracy requirement, failure to consider 

best available and contending science. Specific examples are the application of inappropriate disturbance 

regimes, discussions on severe fire and severely burned soils, discussions on mechanical fuels treatment 

effects on erosion and sediment delivery to aquatic systems, and the subjective mistletoe analysis. (D59 pp. 

16-19)

Response: These topics have all been revised in Chapter 3 of the FEIS and in the project analysis file. 

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#83. Climate change analysis takes large-scale generalized projected climate change impacts from GCMs to 

justify “preparing” diverse, local plant communities for these projections while not considering the climate 

mitigation benefits of forests. 

Forests are active participants in the manifestation of local to regional scale climate. Forests can create 

microsite-conditions that promote a more optimal growing environment for their own persistence. For 

managers to actively force a drier condition on the forest, especially within moist PAGs that are currently 

resilient, is akin to drawing the water out of streams because predictions show future streamflows will be 

lower. How these forests will respond to climate change is a huge question and using generalized large-scale 

climatic predictions to change entire plant community types with chainsaws, tractors and reforestation 

could be the worst approach to preserving resiliency in local ecosystems. 

The Snow Basin DEIS cites at 72 to a few large-scale climatic change papers and then states: 

Taken together, these reports suggest the following key trends for the project area: 

Extended growing seasons – more soil moisture demand by vegetation

Lower soil moistures – less available to vegetation

Increased late-season moisture stress on vegetation – increased susceptibility to disturbance. 

There can be no question that all of the proposed alternatives would respond to the stated trends in a 

positive way. However, in order to develop an understanding of which alternatives are better than others, 

the papers cited in the DEIS give little guidance because for the most part they focus on large-scale modeled 

future climatic changes, and do not make recommendations regarding specific forestry practices such as 

proposed in Snow Basin. Each alternative has to be evaluated in context of the holistic impacts on all 

critical aspects of the project area’s ecology, such as impacts to aquatic systems and soils, and wildlife 

habitat. For example, Snow Basin makes the sweeping assumption that forest density should be reduced 
Appendix C Snow Basin Vegetation Management Project FEIS

567

which may be warranted in some cases but not in others. Any effort to increase climate resilience by 

reducing the density of trees must consider several factors:

Dense forests provide rare habitat values;

Dense forest canopy actually helps reduce fire hazard and increase stand resilience by maintaining a coolmoist microclimate with lower wind speeds under the canopy, shading and suppressing the growth of ladder 

fuels;

In forests with intermediate or longer fire return intervals there is a chance that fuel treatments will 

backfire and increase the risk of fire;

Logging to reduce density will transfer carbon to the atmosphere thus exacerbating climate change, and 

Logging will add to the cumulative stress of climatic change (such as watershed impacts). 

The Snow Basin DEIS does not appropriately balance these factors. (D59 p. 83)

Response: See the revised vegetation and fuels analyses. 

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#84. The Peterson and Peterson (2001) paper cited in the DEIS does not seem to be in the bibliography. A 

paper found through google search is on mountain hemlock growth responses to climatic variability. The 

abstract states the following: “Increasing atmospheric CO2 concentrations could produce warmer 

temperatures and reduced snowpack depths in the next century. Such changes would likely increase 

mountain hemlock growth and productivity throughout much of its range in Washington and northern 

Oregon. Increased summer drought stress and reduced productivity would be likely, however, in mountain 

hemlock forests of southern Oregon and near the species lower elevation limit at some sites.” 

This is the type of nuanced analysis that is lacking in the Snow Basin DEIS. It is possible that local 

productivity will increase in some forest types, especially higher elevations where less temperature restraints 

on physiological activity coupled with heavy snowfall accumulation could improve site growing conditions. 

All of this is very complex and considers a comprehensive evaluation of the specific physiology of each 

individual tree species (Coops and Waring 2011). Coops and Waring (2011) show that the modeled 

distribution of ponderosa pine is not projected to change much in the Wallowas (see Fig. 3). This is because 

the more coastal regions of the PNW are hydrologically buffered compared to the interior forests of the 

Rockies where range contractions for ponderosa pine are projected (Figure 3, Waring and Coops (2011) and 

personal communication with Dr. Richard Waring, April 2011). What this also indicates is that moist forest 

types should not be considered eminently threatened by climate change as hydrological buffering in our 

region may allow these moist forest communities to persist. However, the Snow Basin approach can be 

boiled down to sharply reducing stand density and shifting/favoring early seral species composition across 

as much of the landscape as possible. While it makes sense in the previously logged dry forests to reduce 

competition and favor early seral species, this approach in the moist mixed conifer sites is not recommended 

by science, and none of the proposed removals of trees over 21” DBH are generally recommended by 

science. The Snow Basin analysis overlooks the entire body of literature that is specific to forests and their 

biophysical interactions with local and regional weather and climate patterns and recommendations to 

manage forests for climate benefits (Jackson et al. 2008, Chapin et al. 2008, Ryan et al. 2010). Snow Basin 

takes the approach that forests on a very local scale need to be “made to fit” the projections of large-scale 

climate change models, and the systemic problems associated with failure to distinguish the drastically 

different disturbance regimes in moist and dry forests continues to plague the Snow Basin DEIS analysis. 

The vegetated fraction of the Earth’s surface influences climate through physical, chemical, and biological 

processes [Bonan, 2008; Nemani et al. 1996]. Because plants are the primary site for the exchange of water, 

energy, and momentum between the land and atmosphere, vegetation has an important role in the climate 

system [Hoffman and Jackson, 2000]. Plants leaves actively exchange absorbed solar radiation through 

evaporation and thereby maintain daytime canopy temperature close to the air temperature [Gates 1965; 

Nemani et al. 1993; Waring 2002]. An increase in green biomass is often associated with a reduction in 

surface resistance to evapotranspiration, greater transpiration, a larger latent heat flux, and decreasing 
Appendix C Snow Basin Vegetation Management Project FEIS

568

Bowen ratios [Goward et al. 1985; Nemani and Running 1989; Lambin and Ehrlich 1996]. Other qualities 

of vegetation, such as albedo and surface roughness also have very important impacts on surfaceatmosphere energetics [Bala et al. 2007; Betts et al. 2000; Marland et al., 2003]. Alterations of the land 

surface cover type initiate a series of interactions and feedbacks in the climate-biosphere system [Chapin et 

al. 2008]. Efforts to mitigate climate change with alterations to forestry and land-management practices 

must factor in these biophysical changes and interactions. 

Each land cover type has distinct interactions with the atmosphere that can result in different local 

meteorological conditions. This reciprocal influence of vegetation on the microclimate of the particular area 

results from vegetation properties such as aerodynamic roughness, leaf seasonality, leaf area index, and 

partitioning of sensible and latent heat fluxes at the vegetation or ground surface [Nemani et al. 1993]. The 

influence of vegetation on the expression of LST has been observed in disturbed and undisturbed areas 

across a range of spatial scales [Nemani et al. 1996; Mildrexler et al. 2006, 2009; Running 2008]. (D59 pp. 

83-84)

Response: See the revised vegetation analysis. 

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#85. DEIS says that CO2 enriched atmosphere may “fertilize” the forest, but maybe more significantly, 

CO2 enrichment may lead to increased water use efficiency in trees. This may not completely offset the 

increased demand for water in a warmer climate, but it may significantly mitigate the predicted drought 

stress caused by warming, and should be considered in the NEPA analysis. (D64A p. 26)

Response: This statement has been removed from the FEIS. That process would need to be analyzed on a 

much larger scale than the Snow Basin project area. 

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#86. The DEIS fails to sufficiently and accurately demonstrate the “best available science” standard was 

objectively considered and employed with regard to this analysis and decision. The DEIS neither 

objectively, nor accurately identifies what the “best available science” fully represents or recommends with 

respect to the Forest Service’s decision to log extensively in rare LOS forest habitat. The EIS fails to 

demonstrate that the “best available science” supports the agency’s plans to log century and older mature 

trees, and to extensively degrade important ground vegetative cover needed by associated old forest species 

and prey species. The DEIS fails to objectively disclose the contending “best available science” that 

recommends strongly against the project’s plans for extensive logging within LOS forests and the removal 

of mature trees. 

The DEIS fails to sufficiently and accurately demonstrate how the “best available science” standard was 

objectively considered and employed with regard to this analysis and decision. Numerous courts, including 

the Ninth Circuit have held Forest Service decisions to be arbitrary and capricious where there was nothing 

in the record that objectively and accurately explained what “best available science” entails or how it was 

considered in developing aspects of the challenged timber sales. Bark, 2007 U.S. Dist. LEXIS 21272 at *19-

20; Forest Watch v. U.S. Forest Serv., 410 F.3d 115, 117 (2nd Cir. 2005); Ecology Ctr; Inc. v. U.S. Forest Serv.; 

451 F.3d 1153, 1191, 1195 (10th Cir. 2006). (D59 p. 35)

Response: The use of best available science is explained for each topic in the specialist reports for each 

topic. Uncertainty and controversy are also dealt with for each topic in the specialist reports. 

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#87. Commercial logging appears to be proposed within the Wild and Scenic River corridor. The DEIS 

analysis on p. 336 is not adequate to determine compliance with the WSRA requirement to protect and 

restore the outstandingly remarkable values (ORVs). (D64A p. 34)

#88. The FEIS needs to disclose the outstandingly remarkable values and how they have been degraded by 

past management. (D64A p. 34)
Appendix C Snow Basin Vegetation Management Project FEIS

569

#89. The FEIS needs to disclose the relevant elements of the LRMP and Eagle Creek WSR plan (LRMP 4-

75). (D64A p. 34)

#90. The FEIS needs to disclose the site-specific proposed activities within the corridor, as well as activities 

outside the corridor that may affect the ORVs (LRMP p. 4-71) (D64A p. 34)

#91. The FEIS needs to disclose the site-specific effects of management on each ORV. (D64A p. 34)

Response: The Wild and Scenic River analysis has been re-written to clearly identify the proposed 

treatments within the Eagle Creek Wild and Scenic River Corridor. It is summarized in Chapter 3 and the 

complete Wild and Scenic River Specialist Report, and Section 7(a) Review and Determination can be 

found in the Project Record. The analysis discloses the effects of the proposed treatments on the 

Outstandingly Remarkable Values in the wild and scenic river corridor, and evaluates if the proposed 

treatments will unreasonably diminish the scenic, recreational, and fish and wildlife values present in the 

area.

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#92. The FEIS needs to consider alternative means of avoiding and mitigating adverse impacts. (D64A p. 

34)

#93. Based on LRMP requirements to provide quality snag habitat and the previous comments with respect 

to the effects of logging on snags, the FEIS needs to be much more thorough in addressing the issue. (D64A 

p. 34)

Response: The Wild and Scenic River analysis has been re-written to clearly identify the proposed 

treatments within the Eagle Creek Wild and Scenic River Corridor. It is summarized in Chapter 3 and the 

associated Specialist Reports for Wild and Scenic Rivers, Scenery, Vegetation, and Fire can be found in 

the Project Record. 

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#94. The DEIS includes a section titled “Bull trout – Designated Critical Habitat) that begins on DEIS p. 

181. The resilience of the aquatic community is a key element to consider when determining impacts on bull 

trout. Studies show that while open systems are considered resilient to disturbances such as drought and 

flooding, reservoir fish communities may be more confined and potentially less resilient to environmental 

disturbance. Drastic or ill-timed changes in water levels of reservoirs can lead to reduced growth and 

survival of fishes as well as other detrimental impacts. While, based on the information in the DEIS, there 

are currently no bull trout known without the project or analysis area, the Eagle Creek Drainage is 

designated critical habitat for bull trout; therefore the DOI recommends that the FEIS include a discussion 

of the resilience of the aquatic community and offer mitigation options to reduce or avoid any adverse 

impacts to the aquatic community in the area. DOI suggests this reference: (see D46 p. 2).

Response: We agree with the Commenter on the importance of resilient aquatic communities with regard 

to potential impacts to bull trout and their habitat. In response to your comment the analysis of effects to 

bull trout and their habitat has been updated and is summarized in the FEIS (See Watershed/Aquatics 

Section, Chapter 3). The complete cumulative effects analysis can be found in the Watershed/Aquatics 

Specialist Report located in the project file. In summary, bull trout are not present in the analysis area and 

there are significant challenges (e.g. stream temperatures, stream flows, reduced prey base, passage 

barriers) to reestablishing a bull trout population in the Eagle Creek system. 

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#95. The following is a brief outline representative of the range of current scientific information that should 

be incorporated in revising the proposed decision and management actions of the Snow Basin Project: 

High-severity fires also provide a bonanza of downed wood which benefits aquatic systems (Beschta et al. 

2004; Karr et al. 2004; Swanson et al. 2010). (D59 p. 36)
Appendix C Snow Basin Vegetation Management Project FEIS

570

Response: In response to your comment we have updated the analyses of effects to aquatic habitat and 

species in the FEIS (See Watershed/Aquatics Section, Chapter 3) to include potential short-term and longterm effects of wildfire on riparian and aquatic habitats. We reviewed the references you provided 

concerning potential effects of wildfire on riparian and aquatic habitats and incorporated the information in 

the effects analysis. 

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#96. DEIS p. 274 and Table 130 offer another compelling reason to avoid new road construction. The EIS 

should disclose the proximity of all proposed new roads and landings to existing weed infestations. (D64A 

pp. 22-23)

Response: A descriptive location (and general proximity to project activities) of known infestations is 

located in Table 2 of the Invasive Species Resource Report and Summary. This table will be included in 

the FEIS. Further, the standards 7 and 8 (Invasive Resource Report pg. 1) and mitigations 1, 2, & 3 

(Invasive Resource Report pg. 13) should help reduce the risk of new site establishment or current site 

spread. These standards and mitigations are also included in the FEIS. 

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#97. The Snow Basin DEIS fails to consider that widespread soil disturbance from logging equipment, 

followed by prescribed fire, is a perfect recipe for invasive species spread (D59 pp. 17-18). 

Response: The Invasive Species Resource Report and Summary (see Table 3 Invasive Species Resource 

Report) identifies the risk to invasive non-native plants from activities such as commercial harvest and 

prescribed fire. Standards (1, 2, 3, 7, 8, & 13 Invasive Species Report and Summary pg. 1), mitigations (1, 

2, 3, & 4 Invasive Species Report pg. 13), and monitoring (Table 7 Invasive Species Report pg. 15) will 

reduce the threat of invasive species spread or establishment. 

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#98. Recreation does not consider loss of old growth forests. Old growth forests provide important social 

and cultural values to many people and are an irreplaceable part of the recreational experience to many 

people. Snow Basin DEIS completely fails to acknowledge the effects on recreation from logging trees > 21”. 

People like to recreate in old growth forests and they are valuable for wildlife viewing due to the wildlife 

habitat that they provide. The public has been calling on the FS to protect our old growth forests for 

decades. The massive widespread effects and loss of recreation opportunities that Snow Basin threatens to 

those that love old growth forests is not considered, but trivial impacts on motorized recreation are 

considered in the DEIS (p. 307). It is absurd that the FS could give this level of detail to motorized 

recreation and not even consider the loss of old growth forests, one of the defining natural resource issues of 

our time. (D59 p. 94)

Response: The recreation analysis has been updated in the FEIS. It is summarized in Chapter 3 and the 

complete Recreation Specialist Report can be found in the Project Record. The analysis recognizes that a 

change in natural features or landscape characteristics such as harvesting large trees or creating more open 

canopy may elicit different responses in visitors. In some cases the changing landscape will displace or 

discourage certain types of dispersed recreational activities; however in other areas it may encourage new 

dispersed recreational activities.

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#99. The DEIS on p. 172 lists critical habitat and sensitive aquatic species, and aquatic MIS. See also Table 

96 and Table 101. There are numerous RMO problems in the project area. The FS is not able to attribute 

much of these deficiencies to the condition of the RHCAs. It would be prudent to question the condition of 

the entire watershed and the historic impacts that may have created long-term deficiencies in proper 

ecosystem functioning. However the DEIS does not do this. It basically claims that the degraded state will 

be maintained. This is a questionable claim considering the DEIS discloses that the reasons for temperature 

deficiencies are unknown, and no reasoning is given for the pool frequency deficiency. What is causing the 

very poor condition of streams regarding pool frequency within the project area? If the FS has no idea 
Appendix C Snow Basin Vegetation Management Project FEIS

571

what is causing these deficiencies in RMOs, how can it assume that Snow Basin will not worsen this 

degraded condition? (D59 pp. 72-74)

Response: In response to your comment the analysis of the existing condition of aquatic habitat and 

effects to INFISH Riparian Management Objectives (RMOs) have been updated and is summarized in the 

FEIS (see Watershed/Aquatic Section, Chapter 3). The complete analysis can be found in the 

Watershed/Aquatics Specialist Report located in the project file. 

To summarize, Alternative 4 would likely have the least impacts to aquatic habitat because it has the least 

amount of ground disturbing activities. Alternative 3 would have fewer impacts to aquatic habitat than 

Alternative 2 due to the lesser amounts of ground disturbing activities. All action alternatives would have 

short-term impacts as a result of proposed activities. The impacts to aquatic habitat would include: 1) 

short-term immeasurable increase in fine sediment as a result of timber harvest and prescribed burning 

activities, and 2) short-term measureable increases in fine sediment as result of replacing 1 bridge and 

installing four temporary culverts on Category 1 streams. All action alternatives would result in a longterm improvement in aquatic habitat as a result of road improvements that will decrease overall erosion 

rates in the action area.

Effects to aquatic habitat from water temperature increases are unlikely as a result of thinning and 

prescribed burning activities. Thinning activities will occur in about 50 acres in Riparian Habitat 

Conservation Areas (RHCAs). However, these activities will occur in the outer portions of RHCAs 

(greater than 100 feet from Category 1 and 2 streams) therefore stream shading is unlikely to be affected. 

Burning in RHCAs will occur under conditions that limit the severity and intensity of burning. Mortality 

of trees in RHCAs that provide shading will likely be rare and will be limited to understory trees. 

Therefore, prescribed burning in RHCAs is unlikely to result in a measureable increase in water 

temperatures. 

Measurable effects to the aquatic habitat RMOs (Large Woody Debris {LWD}, Pools, Bank Stability, 

Lower Bank Angle, and Width-to-Depth Ratio) are unlikely as a result of thinning and prescribed burning 

activities. Thinning activities will occur in about 50 acres in RHCAs. However, these activities will occur 

in the outer portions of RHCAs (greater than 100 feet from Category 1 and 2 streams) therefore future 

levels of LWD is unlikely to be affected. LWD does not appear to be the primary component for creation 

of pools in the analysis area. Therefore the proposed thinning of about 50 acres in Category 1 and 2 

RHCAs is unlikely to result in a future decline of pools. Use of heavy equipment will be restricted to 

designated areas in RHCAs and crossings will be hardened. Therefore, decreases in bank stability, lower 

bank angle and width-to-depth ratios are unlikely.

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#100. On DEIS p. 188 the DEIS discloses that there may be more negative effects to a system that is already 

Functioning at Unacceptable Risk for large pools. Based on the science supplied in the above section 

“Inadequacy of PACFISH RHCAs”, the negative effects are likely much worse than are predicted by the 

DEIS. (D59 pp. 73-74)

Response: In response to your comment the analysis of the existing condition of aquatic habitat and 

effects to the INFISH Riparian Management Objective (RMO) for pools has been updated and is 

summarized in the FEIS (See Watershed/Aquatics Section, Chapter 3). The complete analysis can be 

found in the Watershed/Aquatics Specialist Report located in the project file. We reviewed the references 

you provided concerning the inadequacy of PACFISH RHCAs and incorporated the information in the 

effects analysis. 

To summarize, impacts to INFISH Riparian Management Objectives (RMOs) for large woody debris 

(LWD) and pool frequencies are unlikely. About 50 acres in RHCAs will be included in commercial 

thinning units under Alternative 2 and about 43 acres under Alternatives 3 and 4. In general, thinning 
Appendix C Snow Basin Vegetation Management Project FEIS

572

activities will not occur within 200 feet of Category 1 stream channels and 100 feet of Category 2 stream 

channels. Given that an average site potential tree in the project area is 80 to 100 ft in height (J. Gilsdorf, 

Silviculturist, Whitman RD, pers. comm.) INFISH RHCAs should be sufficient to eliminate impacts to 

future LWD that originates from the streamside zone for Category1 and 2 streams. Majority of the 

proposed harvesting activities in Category 1 and 2 RHCAs will occur above roads; areas that are unlikely 

to provide LWD to stream channels.

Channel sinuosity and large roughness elements (e.g. boulders, tree roots, LWD, bedrock) create flow 

obstructions which result in the formation of pools. In general, pool habitat increases as LWD increases 

(Dollof and Warren, 2003; Montgomery et al., 1995). However, there does not appear to be a relationship 

between LWD and pool habitat in steeper streams (Montgomery et al., 1995) or in streams with low stream 

power (Jackson and Sturm, 2002). As noted earlier, the majority of streams in the analysis area are high 

gradient streams, including fish-bearing streams which have been surveyed (see Table 7 in 

Watershed/Aquatics Specialist Report), which may reduce the pool forming function of LWD in the 

project area. 

Thinning units, skid trails, and landings will not be located adjacent to stream channels under the action 

alternatives. Restricting commercial thinning activities to at least 200 feet (twice the height if a site 

potential tree) for Category 1 streams are sufficient to prevent removal of trees that have the potential to 

fall into stream channels as LWD and potentially create pool habitat. 

Small tributaries, such as Category 4 streams, can also transport LWD to streams especially where debris 

flows occur (Naiman et al., 2000). However, debris flows do not appear to be a major process in the 

analysis area. The primary delivery area for LWD reaching Category 4 streams in the project area appears 

to be the streamside zone. 

Harvesting in Category 4 RHCAs has the potential to remove some trees that would provide future LWD 

to Category 4 stream channels. A limited amount of thinning will occur in Category 4 RHCAs; less than

15 acres total. Thinning will be restricted to the outer 50’ of Category 4 RHCAs where this occurs. These 

areas are located above roads therefore any trees that were to fall towards the stream channels would be cut 

up and removed from the road prism. Given that the majority of trees to be thinned are likely smaller than 

a site potential tree (100 feet tall) and the average road prism for a 7-digit Forest Service Road is 14 feet 

wide, a small reduction in future LWD levels in Category 4 streams may occur where proposed thinning 

occurs in Category 4 RHCAs.

Danger trees will be removed from haul road corridors for public and forest worker safety. Dangers trees 

in RHCAs will be felled and left on site in accordance with INFISH S&G TM-1.

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#101. The DEIS on p. 187 discloses the deficiencies in large woody materials in the RHCAs in many places 

of the DEIS and attributes it to preInfish logging of riparian areas, it does not analyze the impacts of logging 

so much old growth across the landscape on future RHCA large woody material. Some of the logging units 

that directly abut against RHCAs and are also on steep slopes. It is very likely that over time some of the 

large wood that will be removed by this proposal, especially under Alternatives 3 and 4, would end up in the 

RHCAs. This needs to be analyzed in the EIS. The deficiency of large wood within the RHCAs makes the 

contribution from outside sources even more important. (D59 p. 74)

Response: In response to your comment the analysis of the effects to the INFISH Riparian Management 

Objective (RMO) for Large Woody Debris (LWD) has been updated and is summarized in the FEIS (see 

Watershed/Aquatics Section, Chapter 3). The complete analysis can be found in the Watershed/Aquatics 

Specialist Report located in the project file. 

To summarize, fish habitat in the analysis area generally meets the Riparian Management Objectives 

(RMOs) for large woody debris (LWD) but does not meet INFISH RMO for pool habitat (see Table 7 in 

the Watershed/Aquatics Specialist Report). LWD in stream channels originate from both upslope and 
Appendix C Snow Basin Vegetation Management Project FEIS

573

streamside zones (Naiman et al., 2000). Large-scale episodic events such as stand replacement fires 

(Harmon et al., 1986; Romme et al., 2011), landslides (Reeves et al., 2003), and the combination of the 

two events (Burton 2005) can supply large amounts of LWD that persists in stream channels for decades to 

centuries (Naiman et al., 2002). Since landslides are generally rare in the analysis area, the majority LWD 

reaching stream channels likely results from the streamside zone (see Table 18 in the Watershed/Aquatics 

Specialist Report). 

Impacts to INFISH RMOs for LWD and pool frequencies are unlikely. About 50 acres in RHCAs will be 

included in commercial thinning units under Alternative 2 and about 43 acres under Alternatives 3 and 4. 

In general, thinning activities will not occur within 200 feet of Category 1 stream channels and 100 feet of 

Category 2 stream channels. Given that an average site potential tree in the project area is 80 to 100 ft in 

height (J. Gilsdorf, Silviculturist, Whitman RD) INFISH RHCAs should be sufficient to eliminate impacts 

to future LWD that originates from the streamside zone for Category 1 and 2 streams. Majority of the 

proposed harvesting activities in Category 1 and 2 RHCAs will occur above roads; areas that are unlikely 

to provide LWD to stream channels.

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#102. Bull Trout: The DEIS on p. 184: Despite this finding, the Snow Basin DEIS does not adequately evaluate the 

potential feedbacks between the proposed widespread canopy removal across the subwatersheds, the commensurate 

increase in surface temperatures and stream temperatures. On p. 191 the DEIS fails to take a “hard look” at the 

impacts of these factors on Bull Trout. On p. 193 of the DEIS, the conclusion that the impacts of Snow Basin will be 

small in magnitude and duration is unfounded and not supported by the DEIS. On p. 193 of the DEIS (and 196), the 

short-term negative impacts are disclosed. The DEIS makes a very subjective conclusion that the “sum total” of 

project related short-term and long-term negative effects, and long term positive effects, will remain well below a level 

of significance due to RHCA buffers and BMPs. But the RHCA buffers are devoid of large wood due to previous 

logging, stream temperatures are too high for Redband in Little Eagle Creek and too high for Bull Trout everywhere, 

and pool frequency and pool size/quality are deficient across the project area. These issues are already significant 

because RMOs are not being met. On p. 193 of the DEIS it is hard to believe that lack of data on the relevant topic for 

many streams in the project area is not critical (D59 pp. 74-75). 

Response: In response to your comment the analysis of the effects to bull trout and bull trout critical 

habitat has been updated and is summarized in the FEIS (see Watershed/Aquatics Section, Chapter 3). The 

complete analysis can be found in the Watershed/Aquatics Specialist Report located in the project file. In 

summary, the Snow Basin Project (all alternatives) will have no effect to bull trout because they are not 

present in the analysis area. 

We updated the analysis of effects to water temperature as a result of your comments which is summarized 

in the FEIS (See Watershed/Aquatics Section, Chapter 3). The complete analysis can be found in the 

Watershed/Aquatics Specialist Report located in the project file. In summary, where groundwater is close 

to the surface, removal of the forest canopy may increase groundwater temperatures. However, since 

timber harvest activities proposed under the action alternatives are primarily commercial thinning it is 

unlikely that an increase in soil temperature will occur. Thus, it is unlikely that an increase in stream 

temperatures will occur as a result of thinning in areas outside of RHCAs. See response to Comment #99 

for a discussion of INFISH RMOs.

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#103. Redband Trout: DEIS p. 194 and 197: This is not consistent with the information presented in the section above 

“Inadequacy of PACFISH RHCAs”. Moreover, the DEIS on p. 176. Please disclose how stream characteristics will 

not be significantly impacted for redband trout when the science shows the RHCA buffers are already questionable 

and these buffers will be further reduced for skidding trees through them, especially in intermittent and ephemeral 

draws where riparian vegetation is reduced or absent. (D59 pp. 75-76)

Response: See response to Comment AS-2 with regard to Riparian Habitat Conservation Areas (RHCAs) 

and proposed activities. In response to your comment we have updated the analysis of effects to redband 

trout which is summarized in the FEIS (see Watershed/Aquatics Section, Chapter 3). The complete 

analysis can be found in the Watershed/Aquatics Specialist Report located in the project file. In summary, 

Alternatives 2, 3, and 4 of the Snow Basin Project may impact individual redband trout, and their habitat, 

but will not likely contribute toward federal listing or loss of viability to the population or species. 
Appendix C Snow Basin Vegetation Management Project FEIS

574

Impacts may occur as a result of 1) short-term immeasurable increases in fine sediment from timber sale 

activities in general; and 2) short-term measurable increases in fine sediment as a result of bridge and 

culvert replacement activities. Long-term beneficial impacts may occur as a result of proposed road 

reconstruction activities that will result in a decrease in erosion rates over the long-term.

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#104. Shortface lanx and Columbia pebblesnail: These MIS species are both highly sensitive to sedimentation (DEIS 

on pp. 199-200). As discussed for redband trout, potential sedimentation from this project could be much higher than 

the DEIS suggests due to inadequacy of RHCA buffers and the detrimental impacts of the proposed action, especially 

in intermittent and ephemeral draws. (D59 p. 77)

Response: We agree with the Commenter that these species are sensitive to increases in fine sediment. 

See response to Comment #100 regarding the effectiveness of INFISH RHCA widths with regard to fine 

sediment. In response to your comment the analyses of effects to shortfaced lanx and Columbia 

pebblesnail have been updated and are summarized in the FEIS (See Watershed/Aquatics Section, Chapter 

3). The complete analyses are contained in the Watershed/Aquatics Specialist Report located in the project 

file. In summary, Alternatives 2, 3, and 4 of the Snow Basin Project may impact individual Shortfaced 

lanx, Columbia pebblesnail, and their habitat, but will not likely contribute toward federal listing or loss of 

viability to the population or species. Impacts may occur as a result of 1) short-term immeasurable 

increases in fine sediment from timber sale activities in general; and 2) short-term measurable increases in 

fine sediment as a result of bridge and culvert replacement activities. Long-term beneficial impacts may 

occur as a result of proposed road reconstruction activities that will result in a decrease in erosion rates 

over the long-term.

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#105. Cumulative Effects, DEIS p. 202. Please disclose in the EIS what proportion of RHCAs are currently open to 

cattle grazing. DEIS p. 201 states: As this suggests, it is well known that grazing can have very serious impacts to 

riparian vegetation and overall riparian function and that cattle can graze on very steep slopes. Can you really 

overlook the importance of this factor on ESA and MIS species because of the “steep slopes of the project area?” (D59 

p. 77)

Response: Currently the majority of riparian areas in the project area are open to grazing. In response to 

your comment the analysis of cumulative effects to aquatic habitat and species has been updated and is 

summarized in the FEIS (See Watershed/Aquatics Section, Chapter 3). The complete cumulative effects 

analysis can be found in the watershed/Aquatics Specialist Report located in the project file. 

To summarize, past and current management activities have had and are having impacts to aquatic habitat 

and aquatic species in the Snow Basin aquatic analysis area. These impacts have likely resulted in a 

decline in aquatic and riparian habitats in the analysis area compared to the period prior to intensive 

management activities. Water temperatures, erosion rates and fine sediment levels in the project area are 

likely higher today then prior to European settlement. Current activities (including livestock grazing and 

road maintenance activities) on Forest Service lands are managed under the standards and guidelines of 

INFISH which were developed to speed the recovery of riparian and aquatic habitats.

Livestock grazing and road maintenance activities in the project area are rated as a moderate risk for 

negative cumulative effects with the activities proposed under the action alternatives for the Snow Basin 

Project on aquatic species or their habitat. This risk rating is based on the likelihood that immeasurable 

increases in fine sediment are likely to occur from the two activities that would be additive to potential 

immeasurable increases in fine sediment resulting from proposed activities for the Snow Basin Project. 

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#106. The moist mixed-conifer forest type is fragile and vulnerable to the chronic negative impacts of industrial 

commercial logging. (D59 p. 9)

Response: The objective for Cool / Moist / Dry is to return to Historical Species Composition. See 

Silviculture Prescriptions for Cool / moist / dry treatments

Fuels treatments will reduce the scope of crown fire in all forest types to insure a resilient landscape. Agee 

et all discusses methods for fuels reduction which include reduction of surface, ladder, crown fuels and 

selecting species tolerant to fire. See fuels report figure 1 and 

Silvicultural treatments that target reduce canopy closure have the potential to reduce the development of 

all types of crown fires (Cruz et al. 2002, Rothermel 1991, Scott and Reinhart 2001, van Wagner 1977) if 
Appendix C Snow Basin Vegetation Management Project FEIS

575

surface fuels are concurrently treated. Canopy and ladder fuels will be reduced by forest thinning 

operations that target crown classes, stand basal area and canopy bulk density. Treatments would also 

maximize managing towards large trees that are resistant to insects, disease, and fire.

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#107. Forest types that are outside of the low and mid elevation warm dry forest types are therefore being subjected to 

a management approach that does not mimic the characteristic natural disturbance regime. Active forest restoration 

treatments must be consistent with the natural disturbance regime of a forested landscape or significant degradation of 

the forest, such as loss of resiliency and biodiversity, homogenization of forest structure, reduced canopy cover and 

increased fire risk, increased risk of insect epidemics, degraded wildlife value, and degraded soil and watershed values 

can occur. (see references D59 pp. 3-4)

Response: Additional analysis was done in response to comments about Cool / Moist / Dry Grand Fir stands - See 

Forest Vegetation effects section of the FEIS. Silviculture prescriptions in Cool / Moist / Dry Grand Fir stands have 

been modified Alternative 3 and Alternative 4. (See Silviculture Report in the analysis file for the FEIS.)

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#108. These northern aspects and high elevation ridges supporting mixed conifer forests are structurally very complex. 

Douglas-fir patches can be centuries in the making, standing weathered by time in incredible forms. These forests have 

interacted with multiple disturbances (insects, windstorms, lightning, fire, drought, etc.) further increasing their 

ecological value and beauty. These systems are beyond the capabilities of forest management to improve upon. These 

are biologically important areas, harboring important genetics no doubt important to adapting to changing climate 

conditions. (D59, p. 48)

Response: See the DEIS, Pg 56 Definition of Wildlife Refugia. 

Areas that have been excluded are defined on DEIS Pg 71

There are no High Elevation Stands within the Snow Basin planning area. Additional refugia areas have been 

excluded in the FEIS in Alternative 3 and Alternative 4. 

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#109. Plans for restoring HRV and reducing fire, insect, and disease risk in old-growth do not use the Best Available 

Science and are scientifically controversial. The FS erroneously concludes that commercial logging of mature and old 

trees is necessary to reduce the risk of fire and insects in the planning area. 

The DEIS fails to adequately and objectively “disclose the extent to which the impact of the proposed action is 

scientifically controversial,” regarding the FS decision to achieve HRV objectives and reduce fire risk by commercially 

thinning intact, mature stands of mixed-conifer forest. 40 C.F.R. 1507.27(b)(4). 

Cutting maturing and mature and old-growth trees not only degrades wildlife habitat, but also exacerbates wildfire 

severity (Brown et al. 2004; Carey and Schumann, 2003; Noss et al. 2006; Rhodes, 2007; Morrison and Smith, 2005). 

(D59, p. 35)

Response: The effects of the proposed activities on fire risk and insect populations, wildlife habitat are disclosed in 

the FEIS. See Chapter 3 of the FEIS. The scientific basis for reducing stand density is referenced with the vegetation 

analysis. 

Removal of old trees is covered in the Silviculture Report in Chapter 3 Section 3.2. All alternatives have been 

modified not to remove "old trees" as defined within the Silviculture Report. Goals of effective fuels treatments are 

the retention of fire resistant species. 

As discussed in Brown et al. 2004; Opening up stands would increase fire rate of spread and fire behavior. They do 

discuss that thinning without follow up fuels treatment will increase fire behavior. Snow Basin Analysis does treat 

activity slash. Brown also discusses leaving large fire-resistant species trees in prescriptions for canopy thinning, 

and that leaving fire intolerant species will lead to hire mortality.

This is discussed in the DEIS Chapter 3.2.4.2 (Pgs. 121-122)

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#110. A scientifically founded ecological restoration alternative would not remove irreplaceable mature and oldgrowth trees; nor further fragment area forests with logging, roads, skid trails, landings, openings, and impacts. 

One of the most critical steps in undertaking effective ecological restoration is to forgo those activities and land uses 

that either cause additional damage or prevent the recovery of degraded systems (Kauffman et al. 1997). 

Undisturbed mature forests require little or no restoration (Baker et al. 2007). 

Passive restoration is the best way to return forests back to the condition first perceived by the European settlers 

(McIver and Starr, 2001). (D59 p. 35)

Response: Removal of old trees is covered in the Vegetation Report in Chapter 3 Section 3.2. All alternatives have 

been modified not to remove "old trees" as defined within the Silviculture Report. Goals of effective fuels treatments 

are the retention of fire resistant species. 
Appendix C Snow Basin Vegetation Management Project FEIS

576

There are no "undisturbed Forests" within the Snow Basin project area as discussed in the vegetation report FEIS Ch 

3 Section 3.2

Fragmentation is addressed in the Wildlife Report in the FEIS. 

Kauffman et. A. 1997 discusses treatments within riparian areas. Treatments proposed in all alternatives exclude 

activities within RHCA. In this citation, passive restoration is defined as "the cessation of those anthropogenic 

activities that are causing degradation or preventing recovery", referring to livestock grazing, which is not within the 

scope of this analysis. 

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#111. Table 53 on Page 97 of the DEIS calculated out shows that the estimated number of large trees to be cut in 

preferred Alternative 2 is 43,679 large trees to be killed, which would then leave 53,533 that would not be cut. This 

estimate indicates there are only 97,212 large trees. They propose to kill 44.9% of all the large old trees on the project 

area. Remember, the large trees are supposed to be protected. In addition to this, (Page 18 of DEIS) Danger trees 

would be removed from the “haul road” system and would include some commercial removal of biomass. The 

definition of “danger” or “hazard” trees has been abused in the past, and this indicates that there are 228 miles of 

“haul road.” Many danger or hazard trees turn out to be large old trees. (D22 pp. 1-2)

Response: See Ch 3 section 3.1 Vegetation Effects for revised large tree data. 

Danger trees would be identified by a qualified person using the Field Guide for Danger Tree Identification and 

Response, Pacific Northwest Region, USDA Forest Service (Toupin et. Al 2008). The guide aids in assessing the 

safety risk of individual trees. 

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#112. The Snow Basin DEIS fails to consider the important role of severe fire in creating heterogeneous soil conditions 

that then feedback to create biodiverse vegetated communities. (D59 p. 17)

Response: See response to comment #27 for further discussion. 

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#113. The term overstocked appears in the DEIS 56 times in reference to all biophysical environments. However mid 

and high elevation mixed fire severity forests are naturally more structurally varied and dense. On p. 29 of the DEIS it 

states that Alternative 2 and 3 manage to or below the LMZ. This indicates that alternative 2 and 3 consistently apply 

the approach of cutting down to the LMZ, the opposite of what was requested by the public. (D59 p. 21)

Response: See FEIS Ch 3 Section 3.1 for discussion of HRV of tree density. 

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#114. Tom Spies made some useful observations in the Northwest Forest Plan Monitoring Synthesis Report: 

“Certainly, the growth of trees into larger diameter classes will increase as stand density declines (Tappeiner and 

others 1997). At some point, however, the effect of thinning on tree diameter growth levels off and, if thinning is too 

heavy, the density of large trees later in succession may eventually be lower than what is observed in current oldgrowth stands. In some cases, opening the stand up too much can also create a dense layer of regeneration that could 

become a relatively homogeneous and dominating stratum in the stand. Furthermore, if residual densities are too low, 

the production of dead trees may be reduced (Garman and others 2003). Thinning should allow for future mortality in 

the canopy trees.” 

Where natural conditions plainly evidence higher densities and greater structural stand complexity than formulas may 

recommend, it is not the forests that are to be re-made to fit contrived human formulas, but rather the formulas 

themselves that must be revised to better match natural forest conditions, ecological patterns, and structural 

complexity. Instead, the Forest Service is failing to recognize what the ecosystem is plainly demonstrating; that 

century old trees can co-exist in denser patterns than the combination of biophysical environment, stand density index, 

and upper management zone information suggest. (D59 p. 22)

Response: Reference modifications discussed in FEIS Chapter 3 Section 3.1 Forest Vegetation. 

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#115. Also, DEIS p. 4: Best available science does not fit this description for the area. The Forest Service is 

threatening to drastically overreduce stand densities to create “open grown forests” that never existed at this scale. 

This fundamental flaw in the analysis results in compounding errors that permeate through the DEIS and contradict 

the biophysical environments, plant association groups, elevational and aspect driven differences in plant communities, 

precipitation gradients, etc. (D59 p. 9)

Response: See FEIS Chapter 3 Section 3.1 Vegetation for new analysis of HRV discussions for tree density, 

structure, species composition. 

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Appendix C Snow Basin Vegetation Management Project FEIS

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#116. The scene described by the specific desired landscape condition in the Snow Basin DEIS is a picture derived 

from the ponderosa pine forests of the southwest U.S. and applies only to limited geographical areas in the interior 

PNW (D59 pp. 9-10)

Response: See FEIS Chapter 3 Section 3.1 Vegetation for new analysis of HRV discussions for tree density, 

structure, species composition. 

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#117. Numerous studies have now conclusively shown that variable fire severity was the dominant fire regime and that 

mixed conifer forests were the dominant forest type in the Blue Mountains. Hessburg et al. (2007) used forest structure 

to predict pre-management era fire severity across three biogeoclimatic zones in eastern Washington State and offered 

the following conclusion: Mixed severity fires were most prevalent, regardless of forest type. The structure of mixed 

conifer patches, in particular, was formed by a mix of disturbance severities. In moist mixed conifer, stand

replacement effects were more widespread in patches than surface fire effects, while in dry mixed conifer, surface fire 

effects were more widespread by nearly 2:1. However, evidence for low severity fires as the primary influence, or of 

abundant old park-like patches, was lacking in both the dry and moist mixed conifer forests. The relatively low 

abundance of old, parklike or similar forest patches, high abundance of young and intermediate-aged patches, and 

widespread evidence of partial stand and stand-replacing fire suggested that variable fire severity and nonequilibrium

patch dynamics were primarily at work.

Hessburg et al. (2007) adds this very relevant statement: Our results suggest that low, mixed, and high severity fires 

each occurred in dry (and moist) mixed conifer forests of eastern Washington. The scope of management and 

restoration activities could be broadened to not only accept many such wildfire effects, but to manage for them. This 

should be good news for forest managers because it suggests that some contemporary wildfire effects will meet 

management objectives, and a broader suite of forest structural conditions and a broader range of patch sizes 

supported native fire regimes of mixed conifer forest.

Mounting evidence for variable fire severity. Schoennagel et al. (2004) reviews an extensive literature concerning premanagement era fire regimes of Rocky Mountains forests from Montana to New Mexico, including mixed conifer 

forests. They show strong evidence of variable fire severity in those types, and indicate that mixed conifer systems were 

probably dominated by mixed severity fires. Similarly, Baker and Ehle (2001), Ehle and Baker (2003), and Baker et al. 

(2007) show evidence for variable fire severity in ponderosa pine and Douglas-fir forest types.

Baker et al. (2007) in a study of ponderosa pine-Douglas fir forests in the Rocky Mountains, found the

following: Historical sources and tree-ring reconstructions document that, near or before ad 1900, the low-severity 

model may apply in dry, low-elevation settings, but that fires naturally varied in severity in most of these forests. Lowseverity fires were common, but high-severity fires also burned thousands of hectares. Tree regeneration increased 

after these high-severity fires, and often attained densities much greater than those reconstructed for Southwestern 

ponderosa pine forests. Exclusion of fire has not clearly and uniformly increased fuels or shifted the fire type from lowto high-severity fires. However, logging and livestock grazing have increased tree densities and risk of high-severity 

fires in some areas. Restoration is likely to be most effective which seeks to (1) restore variability of fire, (2) reverse 

changes brought about by livestock grazing and logging, and (3) modify these land uses so that degradation is not 

repeated.

The Snow Basin DEIS makes it clear that the post-treatment goal of Snow Basin for fire behavior for every 

alternative in every stand type is surface fire (DEIS Table 69). This is an incredibly inappropriate desired 

future condition for this diverse project area. In forests characterized by the mixed intensity fire regime, 

Snow Basin will remove areas from historic conditions and openly states it as a goal. That the DEIS 

recognizes moist forests characterized by mixed-intensity fire, and proposes through logging to convert 

these forests to surface fire demonstrates a pre-meditated plan that removes forests from the historic range 

of variability which is counter to the Purpose and Need of the project and lacks scientific integrity. (D59, 

pp. 10-11)

Response: See FEIS Chapter 3 Section 3.2 Fire/Fuels and Air Quality for FRCC descriptions and effects summary. 

Also see response to Comment #27. 

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#118. DEIS p. 48. Best available science does not support the purported impacts of fire suppression on moist grand fir 

types, nor the proposed treatments. For example, the DEIS states at page 48: “Fire suppression has allowed the 

establishment and dominance of grand fir in the warm/dry grand fir and warm/very moist grand fir types, where 
Appendix C Snow Basin Vegetation Management Project FEIS

578

ponderosa pine was historically maintained as the dominant species by frequent low-severity fires.” As already 

described above based on the variable severity fire model that characterizes these sites, it is incorrect to state that fire 

suppression has allowed the dominance of grand fir in mixed conifer types, especially the warm/very moist and 

cold/moist types. Rather this is called natural succession and it is a sign of a healthy functioning vegetative community. 

Natural succession occurs continuously. With regards to fire suppression, those claims are unfounded because the 

mean fire return interval is longer than the period of historical fire suppression in the moist grand fir types. Even the 

DEIS at 57 states that the historic wildfire, of mixed intensity, frequented this Cool/moist grand fir and warm/very 

moist grand fir area about every 26 - 150 years (Hann, 2001). Only long-term variability in the mean fire interval 

(MFI), estimated from a relatively large landscape, should be considered for setting management targets under the 

natural variability approach (Cyr et al. 2009). To state that “ponderosa pine was historically maintained as the 

dominant species by frequent low-severity fires” is inaccurate in all moist types.

Even if the historical selective thinning of ponderosa pine and western larch had not occurred in the very moist 

biophysical environment, these stands would be in the same successional stage with little to no regeneration of pine and 

larch. Natural forests are extremely competitive environments and the dynamics of succession whereby shade 

intolerant trees cannot reproduce and are eventually lost to competition is completely natural. These stands are 

naturally succeeding to old growth grand fir. (D59, pp. 12-13).

Response: In the FEIS in Ch 3 Section 3.2 Fire/Fuels and Air Quality, FRCC discussion of biophysical 

environments. FRCC uses mean fire return interval at a landscape level (by PVG), (Interagency Fire Regime 

Condition Class (FRCC) Guidebook, Version 1.3.0, 2008). See comment responses #54 & #27. 

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#119. Don’t focus too much of tree health, but think instead about forest ecosystem health. (D64A, p. 4)

Response: See analysis for HRV for tree density, structural stage, and species composition. See FEIS Ch 3 Section 

3.1 Vegetation Report Effects Section. 

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#120. Regeneration harvest and overstory removal are not restoration. Removing and replacing a stand with new 

trees is inconsistent with the full cycle of stand dynamics in natural forest ecosystems. The FS needs to embrace 

management objectives that include forests will a full range of natural conditions, including some with numerous trees 

that are stressed, infected with mistletoe, or already dead. Stands like this may not seem “healthy” from the standpoint 

of a “regulated forest” or tree farm, but they are part of the natural forest continuum, and they are important for some 

species that utilize dead and dying trees and mistletoe infected trees for important life functions. Some species require 

that these types of stand conditions be retained on the landscape. (D64A p. 26)

Response: Regeneration prescriptions have been removed from the FEIS. New analysis for HRV for tree 

density species composition See FEIS Ch 3 Section 3.1 Vegetation Report Effects Section. 

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#121. In this landscape, removal of small trees may be restorative, but where there is such a shortage of 

large trees, removal of large trees is not restorative (D64A p. 20). 

Response: The removal of large trees is discussed in the FEIS in Chapter 3 Section 3.1 Forest Vegetation in the 

Effects Analysis of the 4 alternatives. 

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#122. It is hard to find in the DEIS a clear description of how much commercial logging is planned within 

the different forest types, but there are a few revelations scattered in the DEIS, like ...”Within G4, an 

estimated average 5 larger trees per acre would be removed over 973 acres...” (DEIS p. 234) (D64A p. 19)

Response: The acres treated by Biophysical Environment is shown in the FEIS in Chapter 3 Section 3.1 Forest 

Vegetation; Effects Analysis . Reference Table 11. Estimate of the number of large trees that would be removed by 

bio-environment and remaining large trees remaining after harvest in the treatment units.

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#123. Science overwhelmingly concludes that logging mature and large, fire resistant trees do not reduce the risk of 

fire and actually can contribute to more intense fires (Brown et al. 2004; Carey and Schumann 2003; Noss et al. 2006; 

Rhodes 2007; Hanson and Odion 2006; Raymond and Peterson 2005; Baker et al. 2006). The Snow Basin prescription 

calls for heavy logging of mature and old growth trees across the project area. These conditions can result in hotter, 

drier, and windier conditions that promote more ignitions and rapid fire spread. Even where low severity fires were 
Appendix C Snow Basin Vegetation Management Project FEIS

579

historically common, active thinning of small stems and retention of old live trees is recommended (Noss et al. 2006). 

Brown et al. (2004) recommend using passive approaches and active approaches to remove the “larger understory 

trees that are less likely to be safely thinned with fire”. Variable density thinning is also recommended in the lowseverity fire regime as well as care taken to retain some patches of young pine trees in an approximation of historic 

patterns (Brown et al. 2004 citing Allen et al. 2002). Allen et al. (2002) states that restoration should be aimed at 

resetting ecosystem trends toward an envelope of “natural variability”. They caution that “impatience, overreaction to 

crown fire risks, extractive economics, or hubris could lead to widespread application of highly intrusive treatments 

that may further damage forest ecosystems.” The DEIS does not discuss any of this. I have also personally seen the 

prescriptions of the Whitman district that aim to lower stand densities to the lower management zone (Sundry 

Rooster) disregard all of the above mentioned science. (D59 pp. 8-9, 15)

Response: Table 67 in the DEIS (p. 117) illustrates the principles in reducing fire behavior potential in large fires. 

Retention of larger trees is one of those principles where the larger trees have thicker bark and greater height to the 

base of the live crown. The proposed removal of 21”+ dbh trees for the Snow Basin project is targeted in part on 

grand fir, which tends to have thinner bark. Prior harvest and lack of disturbance have resulted in an uncharacteristic 

distribution of large grand fir that, if not removed, will continue to support future propagation of high levels of fastgrowing understory trees that will develop into ladder fuels, perpetuating the fuels issue that currently exists. 

The fuels analysis has been supplemented to add information on how thinning and prescribed fire is expected to 

modify the understory microclimate on treated stands. Expected results include increased solar radiation, increased 

surface temperatures, decreased fine fuel moistures, and reduced sheltering from wind. An increase in fine fuels, 

primarily grass and forbs, is also anticipated. Combined, these changes are expected to result in a change in fire 

behavior, from fire burning in heavier fuels under a more sheltered condition with ladder fuels, a continuous canopy, 

and with potential for crown fire, to fire burning in light fuels in a more exposed or unsheltered situation where the 

predominant fire spread mechanism will be surface fire. 

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#124. The following is a brief outline representative of the range of current scientific information that should be 

incorporated in revising the proposed decision and management actions of the Snow Basin Project: 

In the eastern Cascades, high-severity fire occurrence is very low, with a current (since 1985) rotation interval of 889 

years, i.e., at current rates, high-severity fire will only affect a given stand every 889 years – well beyond the normal 

lifespan of the conifer species (Hanson et al. 2009, Hanson et al. 2010). Fires are not getting more intense in eastside 

forests (Hanson et al 2009, Hanson et al. 2010), and overall fire occurrence is far below its historic extent (Medler 

2006). It is also apparent that recent levels of fire occurrence make it highly unlikely that fuel treatments could affect 

fire behavior even in the forest types that tend to burn most frequently (Rhodes and Baker 2008). There is no good 

evidence that current high-severity fire in eastern Oregon exceeds the natural range of variability. (D59 p. 36, 55) 

Response: The fuels analysis (current condition section) has been revised in the FEIS. What appears to be different 

about recent fires is that fewer ignitions are contributing to larger burn areas. In 1910, 3.1 million acres in the 

Northern Rockies were burned, ignited by more than 1,700 fire starts. In 2000, 380,000 acres around Bitterroot 

valley burned due to 78 starts. In 2002, the 450,000 Rodeo-Chedeski fire burned as the result of two ignitions, and 

the 138,000 Hayman fire burned as the result of one. These recent and large wildfires all seem to exhibit 

uncharacteristically intense wildfire behavior and increased fire severity (Graham et al. 2004, p. 6). All of these 

recent fires are occurring in an age of fully mechanized and organized fire suppression response.

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#125. The DEIS fails to adequately analyze the adverse impacts of further reducing wildland fire, especially highintensity wildland fire on wildlife species dependent in whole or in part upon post-fire habitat. Patches of highintensity fire are very important ecologically, and provide some of the best wildlife habitat. Despite the fact that 

considerable extent of the project area forests are the result of naturally occurring past mixed and high-intensity fires, 

the DEIS nevertheless arbitrarily treats high-intensity fire as if it is unnatural – i.e., as if it is not part of the historic 

range of variability (or natural range of variability). The DEIS states at 85: 

“Alternatives 2, 3, and 4 would improve stand and landscape resilience to fire. Resilience to fire is the ability to 

maintain desirable characteristics. Desirable characteristics can be maintained by use of low intensity fire and 

exclusion of high intensity fire. Stand resistant or resilience to fire varies with tree species composition, stand structure 

and density.” (D59 p. 51)

Response: The FEIS has been revised and no longer contains the statement about exclusion of high intensity fire. 

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#126. This description given of Cumulative Effects for Watershed Resources is given on page 170 of the DEIS: “These 

are the areas where reduction in forest canopy reduced evapo-transpirative (ET) loss of incoming precipitation, which 

can lead to cumulative watershed effects including changes in peak flows or water yield. Increased peak flows can lead 

to widening and de-stabilizing of channels, and destruction of riparian vegetation. Opening of canopy can change how 
Appendix C Snow Basin Vegetation Management Project FEIS

580

much snowpack is stored, and the rate and timing of snowmelt. In addition, some activities have an influence that may 

extend downstream in the subwatersheds within the project area boundary through the lower Eagle Creek drainage 

systems as far as the Powder River.” These are very important issues to analyze. However, the cumulative effects 

analysis does not seem to analyze the cumulative effects to these biophysical processes. Please disclose what science 

supports the Forest Service’s use of the ECA as a tool to assess watershed changes in ET and then to subsequently 

assess impacts on peak water flow and channel morphology. (D59 p. 71) 

Response: Chapter 3 of the FEIS discloses science that supports use of ECA in the Water Yield and Streamflow 

section.

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#127. The importance of the project area to Rocky Mountain Elk was severely understated. A large portion of the 

project area falls within ODFW defined elk winter range and portions of the area provide important spring and 

summer habitat for elk. The project area also contains part of the Conundrum Critical Elk Habitat Area identified in 

the proposed WWNF Travel Management Plan. (D80 p. 1).

Response: The importance of the project area for elk was explained in the DEIS on page 241. Additional 

information concerning seasonal elk use within the project area has been incorporated into the FEIS (Wildlife 

Specialist Report, MIS Species – Rocky Mountain Elk).

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#128. Recent wolverine activity has been documented in the Wallowa Mountains and just north of the project area 

near the wilderness boundary. (D80 p. 2).

Response: Information concerning recent wolverine sightings on the WWNF has been incorporated into the FEIS 

(Wildlife Specialist Report, PETS Species - Wolverine)

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#129. ODFW is aware of martens in the project area. ODFW recommends that the Forest Service implement a 

systematic survey prior to project implementation with survey methods in PSW-GTR-157. (D80 p. 2).

Response: The FEIS discusses recent documented marten occurrence records and ongoing survey efforts in the 

project area (page 59, Wildlife Specialist Report, MIS species – American Marten).

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#130. Since the preferred alternative removes 40% of suitable goshawk nesting habitat, ODFW recommends a 

systematic survey be implemented prior to project implementation using methods in WO-GTR-71. (D80 p. 2).

Response: Goshawk surveys were conducted by the Forest Service within portions of the project area in 2011. 

Additional surveys in areas where goshawks were observed during 2011 would also occur prior to implementation of 

project activities (page 79, Wildlife Specialist Report, MIS Species - Northern Goshawk).

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#131. ODFW has observed pileated woodpeckers in the project area. ODFW recommends a systematic survey be 

implemented prior to project implementation using methods in PNW-GTR-269. (D80 p. 2).

Response: Pileated woodpecker surveys were conducted by the Forest Service within portions of the project area in 

2011 (page 88, Wildlife Specialist Report, MIS Species - Pileated Woodpecker).

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#132. DEIS p. 223 – Analysis of effects on marten discloses that conversion of MSLT to SSLT will have an adverse 

effect on marten but DEIS does not accurately disclose that the removal of commercial sized trees from marten habitat 

will reduce habitat complexity over the long-term, because it removed trees that would enhance future recruitment of 

snags and dead wood. This is true whether the stand is converted from MSLT or not. The DEIS also needs to disclose 

the effect of logging, not only on existing suitable habitat, but also on slowing the rate of recruitment of future marten 

habitat because of the reduced rate of recruitment of large dead wood. This is another missed opportunity to explore 

the optimal mix of treated and untreated areas within and between stands. (see reference, D64A. p. 15).

Response: Analysis of marten habitats has been updated to include stands outside MSLT as modeled and described 

by Penninger and Keown (2011). The importance of the Snow Basin project area to martens is further developed in 

the Wildlife Specialist Report (page 61). The impacts to recruitment of future down wood are also discussed for 

marten (page 57, Wildlife Specialist Report, MIS Species - American marten).

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#133. DEIS 233-234 discloses adverse effects on 700+ acres of pileated woodpecker habitat and 1,442 acres of goshawk 

habitat, but the DEIS did not disclose how long-lasting those effects might be, or what the effects are in terms of 

slowing the rate of habitat recruitment. Nor does the DEIS explain how adverse effects might be mitigated by 

providing more refugia, or retaining higher basal area in suitable habitat and recruitment habitat (D64A, p. 15).
Appendix C Snow Basin Vegetation Management Project FEIS

581

Response: Duration of effects of proposed treatments on pileated woodpecker habitat is addressed in the FEIS (MIS 

species - pileated woodpecker). Duration of effects of proposed treatments on goshawk habitat is addressed in the 

FEIS (MIS species – northern goshawk).

Some forested stands originally proposed for silviculture or prescribed fire-only treatment have been identified as 

wildlife refugia with no treatment proposed. Additionally, regeneration prescriptions originally proposed in 

alternative 2 are deferred in alternatives 3 and 4. 

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#134. DEIS p. 241 states that “current availability of snags in the project area is estimated to exceed LRMP standards 

on average,...”. This statement gives false assurances to the public and the decision-maker because the forest plan 

standards are based on outdated science, and it is now understood that wildlife need more snags than prescribed in the 

LRMP. (D64A p. 16)

Response: The FEIS acknowledges the variation in distribution of snag densities within the project area. The FEIS 

also discusses more recent science related to snag requirements for various wildlife species (FEIS, MIS species -

Primary Cavity Excavators section). None of the alternatives propose to remove existing snags, except for those 

presenting hazards, and those would be left for down woody material (multiple locations within the Wildlife 

Specialist Report). 

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#135. DEIS Appendix B-1 and DEIS p. 250 and 254. The DEIS description of effects to landbirds and neotropical 

migrants, many of which depend on snags and dead wood, is incomplete. The description of indirect effects fails to say 

anything about the long-term loss of recruitment of snags and dead wood resulting from commercial logging under 

alternative 2. Nowhere are the relative effects of Alternative 4 compared to no action or the preferred alternative. The 

indirect effects of the preferred alternative on snag recruitment are significant and need to be quantified. (D64A p. 

17).

Response: See response to #25. This topic is also addressed in the Wildlife Specialist Report (Primary Cavity 

Excavators section, beginning on page 107). The relative effects of Alternative 4 compared to the other alternatives 

are also discussed in the primary cavity excavator section. Effects to neotropical migratory birds are discussed in the 

FEIS, Landbirds, Including Neotropical Migratory Birds section, and beginning on page 121 of the Wildlife 

Specialist Report. 

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#136. DEIS Table 123 and page 253. The projected impacts and benefits to landbirds likely need to be reconsidered in 

light of the effects of logging on snags and dead wood, and the effects described in that table need to include 

information on the magnitude and duration of effects, so that short-term minor effects are not confused with long-term 

significant effects, and vice versa. (D64A p. 17).

Response: Duration of effects to proposed activities has been added to the analysis (10-30 years). Also, potential 

impacts to snag and down log components would be reduced by implementing project design features (PDFs) (FEIS, 

Landbirds Including Neotropical Migrant Birds section).

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#137. The ecological benefits of mistletoe should not be under-estimated. It has been suggested that mistletoe is a 

“keystone species” in many vegetation communities. The abundance and diversity of birds is correlated with the 

degree of mistletoe occurrence, and avian vectors seem to prefer infected hosts. (see references D64A p. 21).

Response: The FEIS wildlife analysis discusses mistletoe importance and implications of proposed treatments on 

mistletoe availability for a number of PETS and MIS species. See the American Marten, MIS section, Northern 

Goshawk, MIS section, and the Johnson’s Hairstreak section of the Wildlife Specialist Report. 

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#138. It has also been reported that mistletoe brooms provide important habitat for relatively high densities of flying 

squirrels (important prey for many carnivores). This function of mistletoe brooms is quite valuable in typical stands 

that are deficient in large snags. (see references D64A pp. 21-22).

Response: The FEIS describes the importance of mistletoe to northern goshawk and American marten prey species 

(FEIS, MIS species - American marten and northern goshawk sections).

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#139. Project logging of mature and old trees and degradation of forest habitat would likely extirpate or harm the 

habitat and populations of affected ESA listed species and imperiled forest dependent native species of concern in 

violation of NFMA. (D59 P. 21).

Response: The FEIS discusses effects of proposed treatments to applicable PETS, MIS, and neotropical species 

habitats. There is no evidence that any terrestrial ESA listed species inhabit the project area, nor does habitat exist 

for them. The only exception is the presence of a minor amount of habitat for Canada lynx, which is listed as 
Appendix C Snow Basin Vegetation Management Project FEIS

582

Threatened under ESA. This species is discussed beginning on page 25 of the Wildlife Specialist Report. There is 

also no evidence that there are any “imperiled” forest dependent native species in the Snow Basin project area. 

Species of conservation concern like the white-headed woodpecker and Lewis’ woodpecker are addressed in the 

FEIS, and Wildlife Specialist Report (beginning on pages 17 and 21).

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#140. I am less concerned about the taxpayer than the wildlife. What is the impact there? I can tell you that it will 

cause the bigger animals to leave the area until the next generation of trees grows back – 20 to 40 years. They need 

cover to stay in an area and that will be removed. (D23 p. 1).

Response: The FEIS discusses implications of cover reduction to elk as well as a number of other species (FEIS, 

Rocky Mountain Elk MIS section, and beginning on page 112 of the Wildlife Specialist Report). Areas of low 

disturbance that will result from implementation of the Forest’s Travel Management Plan will also mitigate a 

reduction in cover for some wildlife species. This is covered in multiple locations in the FEIS. 

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#141. The impact to bees, birds, and bugs – that is totally unknown. It seems the only honey bees left in Oregon are 

the European variety. (D23 p. 1).

Response: The FEIS discusses impacts to birds and insects included in the R6 Sensitive Species list, as well as MIS 

and applicable neotropical bird species. True “honey bees” are an introduced species from Europe and outside the 

scope of this FEIS. 

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#142. Snow Basin threatens old growth habitat and associated species at the sub-watershed scale. (D59 pp. 25-26).

Response: The FEIS discusses effects to old-growth associated PETS, MIS, and neotropical bird species. No net 

loss of late and old forest structure would occur under any alternative proposed. As discussed at multiple locations in 

the FEIS, this project focuses on restoring the appropriate old growth structure on sites that have been altered by fire 

exclusion. 

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#143. All “Site-Specific” amendments to the eastside screens’ old-growth protections affect the quality and quantity of 

old-growth habitat available for dependent wildlife species throughout the WWNF. The appropriate analysis scale is 

the entire forest, not the project subwatershed. The FS has never assessed what all these past, present, and reasonably 

foreseeable old-growth amendments mean in terms of forest-wide viability for old-growth dependent species, especially 

those that prefer OFMS, and thus cannot be reasonably certain that NFMAs substantive mandate to ensure species 

diversity and viability is being met. 

There is no indication in the Snow Basin DEIS that the Forest Service considered other past, as well as proposed, 

Eastside Screens amendments in determining the cumulative impacts to old-growth dependent species such as Pileated 

Woodpeckers, American Marten, and Northern Goshawks, which all rely heavily on OFMS. Additionally, the 

Flammulated Owl is another species closely associated with old growth forest. 

Some of the specific cumulative effects that the CEQ highlights in its guidance report are: “time crowding” 

characterized by “frequent and repetitive effects on an environmental system”; “fragmentation,” which is 

characterized by a “change in landscape pattern’; “compounding effects,” which are characterized by “effects arising 

from multiple sources or pathways,” and “triggers and thresholds” characterized by “fundamental changes in system 

behavior or structure.” To analyze the cumulative effects of repeatedly waiving the Eastside Screens old-growth 

protections, each of these effects should be considered. The time crowding is especially relevant given the extreme loss 

of the old-growth resource that has already taken place across the WWNF, resulting in the small fraction of old-growth 

remaining. The Eastside Screens were specifically developed to address the extreme depletion of old-growth 

throughout the greater eastside region. Numerous site-specific amendments to allow commercial logging within the 

last few remaining old-growth pockets, a trend that has accelerated greatly in recent years, have resulted in “frequent 

and repetitive effects” to this forest-wide resource. The Forest Service has yet to critically examine these “frequent and 

repetitive effects” at a forest-wide scale. 

Converting one type of old-growth forest to another type, with mechanical logging methods that create a whole slew of 

potential impacts, repeatedly, and on a piecemeal basis throughout the forest, will result in “landscape pattern” 

changes. The Forest Service has yet to assess what this further loss of an already deficient forest type (OFMS) means 

in terms of impacts to old-growth dependent species that are already declining and becoming rarer due to habitat 

fragmentation – particularly those that rely upon or prefer this forest type, such as American Marten, Pileated 

Woodpecker, and Northern Goshawk. 

Numerous site-specific amendments to the Eastside Screens will also have a compounding effect in that multiple sales 

have resulted, and will result, in potentially significant tree removal that is otherwise prohibited by the Eastside 

Screens. The Forest Service has yet to address what this compounding effect means to the ability of the old-growth 

resource to maintain itself within the WWFN, and the viability of old-growth dependent species. In turn, the potential 
Appendix C Snow Basin Vegetation Management Project FEIS

583

for a “compounding effect” from the continued loss and manipulation of the remaining old-growth stands gives rise to 

the potential for the old-growth resource, and especially for the OFMS forest type, to reach “threshold” (characterized 

by the “fundamental changes” to the forest “structure”)where it can no longer sustain itself on the forest. 

Given the small fraction of current old-growth, each site-specific amendment to commercially log within old-growth 

stands or remove trees greater than 20” threatens to significantly impact and/or reduce this resource – making it the 

type of resource “especially vulnerable to incremental effect.” The Forest Service fails to determine whether related 

impacts “have been historically significant for this resource” or whether a “cumulative effects concern” exists for the 

old-growth resource at the forest-wide scale. (D59 pp. 42-46).

Response: The FEIS assesses old growth habitat for various management indicator species including American 

marten, pileated woodpecker, and northern goshawk. Each of these respective sections contain assessments of habitat 

for these species at multiple scales, including the Wallowa-Whitman NF scale (FEIS, American Marten MIS section, 

Pileated Woodpecker MIS section, Northern Goshawk MIS section, and Old-Growth Associated Species section). 

Existing conditions described for each MIS and landbirds that are associated with old-growth habitat inherently 

consider past management activities that have altered or decreased available old-growth habitat. The comment 

implies that past Forest Plan amendments that have allowed timber harvest in old-growth have resulted in 

fragmentation and a decrease in available old-growth. Actually, these past Forest Plan amendments have resulting in 

no net decrease in old-growth habitat, but have restored the appropriate types of old-growth on sites that have been 

altered from fire exclusion over the past 100 years. 

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#144. The DEIS makes the scientifically unsound and inaccurate assumption that a loss of wildlife habitat and 

ecosystem value is caused by wildland fires, at least where moderate-intensity or high-intensity patches occur, and that 

the forest ecosystems are somehow diminished because such fires occur. (D59 p. 52).

Response: The FEIS considers effects to habitats for applicable PETS, MIS, and neotropical bird species associated 

with post-burn conditions. Enhanced habitat conditions from wildfire for species like black-backed woodpecker are 

described in the Wildlife Specialist Report (page 93, Primary Cavity Excavators section). Uncharacteristically large 

or intense wildfires can lead to long-term degradation of habitat for many wildlife species. 

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#145. The DEIS does not adequately analyze the adverse impacts to wildlife species from eliminating high-intensity 

fire. Areas of high intensity fire resulting from large, intense wildland fires create some of the best, most biodiverse, 

and most ecologically rich wildlife habitat according to the current science. Ecologically vital snag forest habitat, 

which is rich with large snags, large downed logs, dense pockets of natural conifer regeneration, patches of native

shrub habitat, or “montane chaparral” and large live trees, is a result of high-intensity, or stand-transforming fire. 

Countless species of flying insects are attracted to the wealth of flowering shrubs which propagate after standtransforming fire. Many species of birds nest and forage in snag forest habitat to feed upon the flying insects. Some 

native wildlife species are largely restricted to snag forest habitat for nesting and foraging. Without a continuous 

supply of this ephemeral habitat, they won’t survive. This habitat is possibly the most rare, endangered, and 

ecologically important forest habitat in western U.S. forests. (D59 pp. 52-53).

Response: The effects of reduced risks from stand-replacement fire are analyzed for applicable PETS, MIS, and 

landbird species associated with post-burn conditions. The Snow Basin FEIS does not purport to “eliminate” high 

intensity fire. 

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#146. NFMA and its implementing regulations require the FS to manage forests for viable populations of native 

vertebrate and desired non-native species. Snow Basin DEIS does not identify the amount and quality of habitat 

necessary to maintain viable populations of the affected MIS on the WWNF and how much of the requisite quality of 

habitat will remain post-Snow Basin. Furthermore, the DEIS on p. 209 evaluates impacts to old growth dependent 

species at the following geographic scale. This scale of analysis is inappropriate. These species should be evaluated at 

the forest-wide level. (D59 pp. 77-78).

Response: Analysis of effects to MIS species and habitats in the FEIS includes effects at the Forest-level (FEIS, 

American Marten MIS section, Pileated Woodpecker MIS section, Northern Goshawk MIS section, and Old-Growth 

Associated Species section).

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#147. Lewis woodpecker: DEIS p. 212: If removal of larger trees had a negative effect on Lewis woodpecker, how will 

removing another 40,000+ not negatively impact them for many, many decades? (D59 p. 78).

Response: The effects of large tree removal on Lewis’ woodpecker are discussed in the FEIS and the Wildlife 

Specialist Report beginning on pages 17 and 95.

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Appendix C Snow Basin Vegetation Management Project FEIS

584

#148. Old-growth associated species. DEIS p. 228 and Figure 24 illustrate the severe fragmentation of LOS in the 

project area. (D59 pp. 78-79).

Response: The FEIS acknowledges existing levels of LOS fragmentation (FEIS, American Marten MIS section, 

Pileated Woodpecker MIS section, Northern Goshawk MIS section, and Old-Growth Associated Species section, and 

Connectivity of LOS Habitat section). The intermediate type treatments, prescriptions that address connectivity 

corridors, and retention if refugia areas combine to improve the distribution and connectedness of LOS habitat. 

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#149. DEIS p. 252. Primary cavity nesters: drop the logging of trees greater than 21” dbh and restrict logging to an 

upper limit of 15” dbh to retain adequate levels of future large snags and nest trees. Do not log to eliminate Indian 

Paint fungus. (D78 p. 3).

Response: The FEIS contains a range of alternatives, including Alternative 4 under which no removal of trees 

greater than 21” is proposed. In addition to untreated areas, retention of all cull grand fir in treatment units ensures 

that Indian Paint fungus persists within the project area. The value to wildlife from grand fir infected with Indian 

paint fungus is addressed at multiple locations in the Wildlife Specialist Report. 

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#150. Pileated woodpecker. DEIS p. 233. (D59 p. 79)

Response: Effects to pileated woodpeckers and their habitat are described in the FEIS, and in the Pileated 

Woodpecker MIS section and Primary Cavity Excavator section of the Wildlife Specialist Report.

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#151. Other negatively impacted MIS species include northern goshawk and elk. The EIS needs to analyze how the 

implementation of Alternative 2 or 3 will affect other habitat components such as hollow logs (usually grand fir), 

important habitat for black bear, pileated woodpeckers, flying squirrels, bush-tailed wood rats, bats, American 

martens, northern flickers, and Vaux’s swifts. Are there enough downed logs and hollow logs currently in the project 

area to maintain viable populations of pine martin, and other MIS and desired species now, let alone after all of the 

impacts associated with Alternative 2 or 3? At a bare minimum, the FS must explain how they are going to protect this 

important habitat. Lack of monitoring for individual species and downed logs providing habitat in the project area 

makes it impossible for the FS to claim that only minor effects on wildlife will occur with the proposed action. (D59 p. 

80).

Response: Retention of down log densities would follow direction provided in the Eastside Screens (Wildlife 

Specialist Report - Appendix A – Wildlife Project Design Features). The values to wildlife from hollow trees, snags, 

and down logs are addressed at multiple locations in the Wildlife Specialist Report (American Marten MIS section, 

Pileated Woodpecker MIS section, Northern Goshawk MIS section, and Old-Growth Associated Species section). 

Some species such as bats and black bear may not be specifically mentioned, but the concept behind using 

Management Indicator Species is that a select number of species will represent habitat for a much larger wildlife 

community. 

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#152. Primary cavity excavators. DEIS p. 237. Snow Basin would remove existing and future habitat for primary 

cavity excavators. The FS needs to conduct surveys for primary cavity excavators in the project area. How can the FS 

assess the cumulative effects when no information is available regarding even the presence of PCEs in the project area? 

(D59 p. 80).

Response: Surveys for pileated woodpecker and white-headed woodpecker were conducted by The Forest Service 

within portions of the project area in 2011. Snag habitat was also sampled in 23 stands in 2010, and these results are 

described beginning on page 103 of the Wildlife Specialist Report. These surveys are also discussed in the FEIS 

under the Primary Cavity Excavators section.

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#153. As the Snow Basin discloses at page 85: These 21” grand fir have bark thick enough to survive low intensity 

fire.” The Forest Service should be leaving these fire resistant old growth grand fir trees for the critical habitat they 

provide and focus on understory treatments. (D59 p. 24).

Response: The FEIS contains a range of alternatives, including Alternative 4 under which no removal of trees 

greater than 21” is proposed. Retention of cull grand fir in all alternatives also recognizes the value to wildlife from 

these trees (multiple locations in the Wildlife Specialist Report). To retain all larger grand fir would compromise part 

of the project’s objectives to transition some stands toward a tree species composition that reflects historic conditions

and that would be sustainable under a natural disturbance regime. 

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#154. Snags and Dead Wood. Current plan direction for protecting and providing snags and down wood tends to be 

focused on a small subset of the full spectrum of values provided by dead wood and does not ensure the continued 
Appendix C Snow Basin Vegetation Management Project FEIS

585

operation of these ecosystem functions or meet the complete lifecycle needs of the many species associated with this 

unique and valuable habitat component. Please consider all the many values of snags and down wood presented in the 

scientific literature (see references D59 pp. 87-88) An important and under-appreciated ecological process is the cycle 

of biomass accumulation. The dead wood portion of this cycle needs to be re-established to enhance biodiversity, 

hydrology, soil productivity, and carbon storage. The Snow Basin project area is already snag deprived, as confirmed 

by the DEIS on p. 239. (D59 pp. 87-89).

Response: References described in this comment were reviewed, with pertinent information to species analyzed 

included in the Wildlife Specialist Report (FEIS, MIS sections).

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#155. Protect high value wildlife habitat and connectivity throughout the project area. (D22 p. 2, D24 p. 1, D30 p. 1).

Response: The FEIS discusses retention of connectivity consistent with Eastside Screens direction. The discussion 

of connectivity between LOS habitat was further developed between the DEIS and the FEIS. Prescriptions were 

modified for treatment units within connective corridors in alternatives 3 and 4 to respond to this issue. This 

information can be found in the Wildlife Specialist Report beginning on page 51.

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#156. There is no good evidence that current high-severity fire in eastern Oregon exceeds the natural range of 

variability. The consequences of the Forest Service’s stated goals of further reducing or eliminating high-intensity fire 

areas, and, therefore, black-backed woodpecker habitat, and further reducing overall fire occurrence, must be fully 

analyzed in light of this information. Similarly, actions that would reduce the levels of insect occurrence and impacts 

must be addressed in objective and accurate relation to their impacts on this and other regional species of concern. 

(D59 p. 55).

Response: The effects of reduction of large-scale tree mortality risk are discussed for black-backed woodpecker 

(FEIS, Primary Cavity Excavator section). Also see response to comment W24. 

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#157. Big game management did not seem to play much of a role in the DEIS. Any harvests that open canopies and 

allow more forage to grow will have favorable impacts on big game. Combine with the high quality cover this should 

be a success for big game management and should be outlined as such. (D29 p. 1, D35 p. 1).

Response: Additional clarification of enhancement of elk foraging habitat is included in the FEIS (beginning on 

page 112, Wildlife Specialist Report, MIS Species – Rocky Mountain Elk).

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#158. The elk section doesn’t pass muster. It used the HEI model from 1986, but didn’t qualify with more recent 

research (D35 p. 1).

Response: The FEIS discusses more recent research concerning the effects from roads and displays habitat effects 

analysis using distance-banding (FEIS, Rocky Mountain Elk section). In addition, science concerning the importance 

of estimating forage quality on elk ranges (Cook et al. 1996) was reviewed and incorporated into the discussion of 

HEI parameters (FEIS, Rocky Mountain Elk section).

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#159. Didn’t discuss details on disturbance from roads (elk disturbance from roads) (D35 p. 1).

Response: The FEIS discusses the effects from roads and displays habitat effects analysis using road densities and 

distance-banding (FEIS, Rocky Mountain Elk section).

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#160. No mention of John Cook’s recent research on big game forage (D35 p. 1).

Response: Science concerning the importance of estimating forage quality on elk ranges (Cook et al. 1996) was 

reviewed and incorporated into the discussion of HEI parameters (FEIS, Rocky Mountain Elk section). 

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#161. To conserve habitat for species like goshawk, fisher, marten, pileated woodpecker, and other cavity associated 

species, the Forest Service may need to retain existing patches of dense forest and large trees because there is still a 

severe shortage of that habitat across the landscape. (D64A, pp. 4-5).

Response: Existing and post-treatment amounts of denser forest are discussed in the FEIS for the range of species 

listed. Specifically, the FEIS addresses the retention of “refugia” for its value to wildlife. 

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#162. The project is in the ODFW Keating Wildlife Management Unit. The mule deer population of this unit is half of 

ODFW’s management objective; the Rocky Mountain Elk population is at or near management objective. Due to the 

landscape scale of this project, it will have a very favorable impact on big game forage enhancement, and adequate 

forage is essential if increasing the wildlife population carrying capacity of any site. The DEIS did not indicate there 

was any collaboration with ODFW during the development of the DEIS. We suggest that before the FEIS is prepared, 
Appendix C Snow Basin Vegetation Management Project FEIS

586

the FS should obtain comments on the project from the DOFW District Biologist in Baker City who is responsible for 

wildlife management in the Keating Unit and incorporate them into the FEIS. (D40 pp. 1-2, D35 p. 1).

Response: The FS received comments on the DEIS from ODFW concerning species and habitats that may be 

affected by proposed treatments. ODFW was further consulted between DEIS and FEIS on technical matters related 

to wildlife in the Keating WMU. This is referenced as personal communication with ODFW within the Wildlife 

Specialist Report. 

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#163. The DEIS does not give sufficient address to the wildlife benefits this project will provide, and would be better 

served if it did so. Far more species are obligates of the more open forest types the project seeks to provide than are 

obligates of the closed canopy forest currently present, thus species diversity will be enhanced (D40 pp. 1-2).

Response: The FEIS discusses post-treatment habitat improvement to species relying on open-canopy forests. The 

Wildlife Specialist Report describes the positive and negative effects from this project.

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#164. The Gray Wolf is no longer federally listed species in the area of the project and thus should not be discussed in 

the EIS. (D40 p. 2).

Response: That correction has been made in the FEIS (Wildlife Specialist Report, Table 5).

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#165. The Rocky Mountain Elk is a management indicator species and was therefore given attention in the DEIS. The 

would suggest the 1986 Elk Habitat model has been called into question by more recent science, particularly as it 

pertains to cover requirements and thus reliance upon it is questionable. The HEI model’s forage index of the model 

was not used and yet one of the most outstanding benefits of the Snow Basin project is its capacity to increase big game 

forage production. We suggest the Rocky Mountain Elk discussion be revised in the final EIS after consulting the most 

recent elk research regarding summer forage requirements, cover, and disturbance response available from the USFS 

PNW Starkey Forest and Range Experiment Station (D40 p. 2).

Response: LRMP direction requires that elk habitats be analyzed in the context of the HEI model. Discussion 

concerning limitation of the HEI model has been added to the FEIS (Rocky Mountain Elk section).

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#166. The DEIS contains many statement of fact and surveys references that lack literature citation. The DOI 

recommends that the FEIS provide scientific references for factual statements and surveys, and include them in the 

bibliography section. Specific statement for which references should be provided include (see D46 pp. 1): DEIS p. 195, 

213. (D46 p. 1).

Response: Literature citations that support statements describing relevant science are included throughout the 

Wildlife Specialist Report. Not every statement of fact has to be based on published literature, but may be based on 

professional experience, observations, and judgment. 

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#167. DEIs p. 252. There should be no spring burning during the reproductive season for Neotropical songbirds. (D78 

p. 3).

Response: Effects to neotropical migrant birds from spring burning are discussed in the FEIS (page 121, Wildlife 

Specialist Report, Land Birds Including Neotropical Migrant Birds section).

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#168. DEIS p. 252. We are especially concerned about protecting overstory canopy closure and structurally diverse 

multilayered forest habitat for species like Townsend’s warbler and varied thrush. (D78 p. 3).

Response: The FEIS describes potential impacts to neotropical migrant birds under the range of alternatives (page 

212, Wildlife Specialist Report, Land Birds Including Neotropical Migrant Birds section). Changes in canopy 

closure is also addressed in more detail in the Rocky Mountain Elk section of the Wildlife Specialist Report (page 

112), which can be related to the importance of canopy closure for other species. 

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#169. DEIS p. 252. Elk: eliminate any planned reduction of satisfactory cover and any conversion of marginal or 

satisfactory cover to forage. Drop the partial overstory and “regeneration” virtual clearcutting. (D78 p. 3).

Response: The effects of cover reduction and forage creation are discussed in the FEIS (page 112, Wildlife 

Specialist Report, Rocky Mountain Elk section). Some partial overstory removal prescriptions occur in all action 

alternatives, but regeneration prescriptions have been dropped from alternatives 3 and 4 in the FEIS. 

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#170. The black-backed woodpecker is the MIS species representing post-fire habitat, where high-intensity fire has 

occurred, or areas where most of all trees are killed by beetles. The Forest Service has not addressed how the viability 

of the black-backed woodpecker will be maintained in the project area when the stated goal of the Snow Basin DEIS is 
Appendix C Snow Basin Vegetation Management Project FEIS

587

to eliminate the high intensity fire process which creates its habitat, and degrade future habitat through thinning 

designed to prevent high-intensity fire. Past and recent post-fire salvage logging in the Wallowa Whitman, combined 

with ongoing logging-thinning in green forests intended to minimize fire impacts – cumulatively has influenced the 

landscape, diminishing and degrading habitat availability for fire dependent forest species such as black-backed 

woodpeckers and others. (D59 p. 55).

Response: The purpose of the Snow Basin project is not to “eliminate” high intensity wildfire, but to modify fire 

behavior and frequency to reflect historic disturbance regimes. It would be inappropriate to focus a discussion on the 

viability of black-backed woodpecker at a scale as small as this project area. The Impacts to black-backed 

woodpecker habitats have been added in the FEIS (Primary Cavity Excavators section, and Landbirds Including 

Neotropical Migratory Birds section). The existence of burned habitat adjacent to the project area is discussed in the 

FEIS. 

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#171. The Forest Service fails to identify how many black-backed woodpeckers, and how much black-backed 

woodpecker habitat, is needed in order to maintain viable populations of this species in the planning area, or how 

many black-backed woodpeckers and how much suitable black-backed woodpecker habitat there currently is in the 

project area. Without this information, any analysis of impacts to the black-backed woodpecker is inadequate, and the 

FS is failing to ensure the viability of black-backed woodpecker populations. (D59 p. 55).

Response: Impacts to black-backed woodpecker suitable habitats have been added in the FEIS (Primary Cavity 

Excavators section). It is not necessary to know the number of black-backed woodpeckers in order to assess potential 

effects to its habitat. 

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#172. Due to the lack of current population status and viability threshold data for northern goshawk, pine marten and 

pileated woodpecker, their suitable habitat should be protected from logging and burning degradation as they are all 

MIS species. Drop the 73 acres of MSLT in G4 for marten, the 279 acres of MSLT G4-6 for pileated woodpecker, and 

the 1,523 acres of goshawk suitable habitat. (see DEIS p. 234) (D78 p. 1).

Response: Project effects on Forest-level viability of these MIS species are discussed in the FEIS.

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#173. DEIS p. 234. Pileated woodpecker and American marten habitat should not be burned. (D78 p. 1).

Response: The effects of underburning on these species’ habitats are discussed in the FEIS (Pileated Woodpecker 

and American marten sections).

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#174. DEIS p. 234. Drop all logging of trees over 21” dbh to benefit goshawk, pileated and marten. (D78 p. 1).

Response: The effects of large tree removal on these species’ habitats are discussed in the FEIS (MIS section). 

Removal of trees over 21” DBH was removed from alternative 4 between the DEIS and FEIS to respond to this issue. 

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#175. DEIS p. 234/Table 112. This table shows losses of suitable habitat that should be avoided. (D78 p. 1).

Response: The table referenced describes pre- and post-treatment amounts of MSLT in the project area. 

Implications to species habitats are discussed in the FEIS (MIS section). Restoration of SSLT structure in dry forest 

types that have experienced in-growth of shade tolerant trees does not represent “losses” of suitable habitat. The 

reduced habitat quality from some proposed treatments is also discussed throughout the Wildlife Specialist Report. 

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#176. DEIS p. 235 fails to consider the effects of likely future “large scale vegetation management” predicted for the 

area in only 10-20 years elsewhere in the DEIS. This is a large impact to wildlife connectivity that should be avoided 

(D78 pp. 1-2).

Response: Reasonably-foreseeable cumulative effects are listed in the FEIS (Appendix B) and analyzed in the 

Wildlife Specialist Report.

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#177. American Marten: DEIS p. 232. The FS does not have adequate information on populations to ensure viability 

of marten. The DEIS p. 232 supports HCPC’s argument that the Snow Basin DEIS does not analyze the impacts to 

MIS at the appropriate scale. DEIS p. 233. (D59 p. 79).

Response: Current knowledge of marten populations as well as potential implications of proposed treatments on 

marten viability at the Forest-scale are provided in the FEIS (American Marten MIS section).

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#178. The DEIS admits that LRMP standards for snag retention are outdated and that more snags are needed than 

previously thought. By logical extension, this means that standards for green tree retention (GTR) must also be 

updated. Unfortunately, the DEIS relies on outdated GTR standards (DEIS p. 240) It is widely understood that past 
Appendix C Snow Basin Vegetation Management Project FEIS

588

standards (for snags and dead wood) did not provide adequate levels of snag and green tree retention. The FS has not 

taken action to amend its LRMP standards to incorporate current science and meet ecological objectives and other 

values provided by dead wood, including carbon storage. The FS needs to prepare an EIS to consider a replacement 

methodology for maintaining species and other values associated with dead wood. This is especially critical because 

adequate dead wood is recognized as an essential feature of healthy forests and the Forest Service has identified 

numerous “management indicator species” associated with dead wood habitat. An agency must re-examine its decision 

when the EIS “rests on stale scientific evidence and false assumptions.” (D64A p. 26,28-31)

Response: Changes in Forest-level direction are outside the scope of this analysis. The FEIS also discusses more

recent science related to snag requirements for various wildlife species (FEIS, MIS species - Primary Cavity 

Excavators section). None of the alternatives propose to remove existing snags, except for those presenting hazards, 

and those would be left for down woody material (multiple locations within the Wildlife Specialist Report). 

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#179. HEI values will substantially change when the WWNF Travel Management Plan is implemented. ODFW 

recommends that HEI values for the area be calculated using the open roads in the proposed WWNF Travel 

Management Plan (D80 p. 1).

Response: Because the WWNF Travel Management Plan was not finalized during the FEIS analysis, HEI analysis 

of a selected alternative is not possible. However, additional analysis that discusses HEI outputs in relation to the 

Travel Management Plan preferred alternative has been included in the FEIS (Wildlife Specialist Report, MIS 

Species – Rocky Mountain Elk)

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#180. The Pine Eagle Consensus Group framework was never officially adopted in the form of a forest plan 

amendment, but it became the unofficial guideline for forest management on the Pine Ranger District. It worked very 

well for almost 20 years, providing a sustainable flow of forest products while enhancing wildlife habitat, clean water, 

and reductions in road density. In the last 10 years or so, efforts have been made to circumvent the vision and goals in 

Management Alternatives 20-21, the official name of the Consensus Groups' management plan. Ultimately, those 

attempts have been scrapped in favor of the overall, long range vision of MA 20-21. Reinforced by the screens, the core 

and corridor system in MA 20-21 has proven to be the most effective means of attaining a balanced ecosystem.

After studying the EIS for the Snow Basin project, we’re wondering what happened to the model that so many of us 

volunteered so many hours to create. The basic design of that model was core areas of old growth connected by

corridors, with very-low-impact management activities. Surrounding the cores and corridors were the areas of more 

intense management. The mosaic that resulted was made up of primo wildlife habitat (the cores) connected by travel 

routes (the corridors) and surrounded by the more intensely managed blocks of timberland. In the alternatives 

outlined in the Snow Basin project, it appears that the whole concept framed by MA 20-21 is being rejected in favor of 

a wipe-the-slate-clean-and-start-over approach to forest management. The sale units are right in the middle of our 

Cores and Corridors, and if implemented, would result in total fragmentation of the MA 20-21 landscape plan. If 

either alternative 2 or 3 is selected, the core/corridor system would be essentially destroyed. (D76 pp. 1-2)

#181. Surely the sacrifices and hard work the consensus Group invested to create MA 20-21 deserve more respect and 

attention than this EIS would indicate (D76 p. 2)

#182. The FS needs to clearly demonstrate how they are following the tenets outlined in the MA20-21 document with 

the Snow Basin project. (D59 pp. 96-97)

Response: The Wildlife Specialist Report discusses how the Pine Eagle Consensus Group’s earlier work was 

considered in the planning of this project (page 53). Their work relates directly to how the Forest Service addressed 

the network of refugia, allocated old-growth stands, and other old-growth stands, and how these features are 

connected on the landscape. Principles of biogeography as they relate to conservation of forest dwelling species were 

woven throughout the Pine Eagle Group’s proposal. An approach very similar to the Pine Eagle Group’s proposal 

ended up in the Regional Forester’s Forest Plan Amendment #2 (Eastside Screens). The Snow Basin project

incorporates the standards and guidelines from this Amendment in the design and management of an old-growth and 

connectivity network. 

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#183. Inland Tailed Frog: DEIS on p. 194 indicates that Little Eagle Creek is above the standard for inland tailed 

frog. The Snow Basin project does not account for the impacts of the project on overland dispersal. Forest 

management policies that rely on riparian buffer strips and structure-based management – practices meant to preserve 

habitat – address only some of these habitat needs. The DEIS findings on p. 194 are not supported by the Forest 

Service science cited here. (D59 p. 76)

Response: More detail on the effects of management on overland dispersal of tailed-frogs was incorporated in the 

FEIS (page 39, Wildlife Specialist Report, Inland Tailed Frog section). The likelihood of tailed frogs occurring in 
Appendix C Snow Basin Vegetation Management Project FEIS

589

this project area is low given the lack of high gradient, cold streams. The presence of potential tailed frog habitat is 

also described in Wildlife Specialist Report (page 39). 

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#184. Columbia Spotted Frog: The DEIS states at 195: “Spotted frogs are found in areas where permanent water is 

present such as marshes, ponds, or riparian areas. They may move considerable distances from water following the 

breeding season.” Where are you planning for or assessing the effects of the proposed action on these amphibian 

movements? 

“Although Columbia spotted frogs have a wide distribution in eastern Oregon, recent surveys and preliminary data 

from long-term monitoring suggest that declines have occurred, and that low elevation populations are isolated, small, 

and particularly vulnerable. There are no known surveys for Columbia spotted frogs in the project area.” (DEIS at 

195) (D59 pp. 76-77)

Response: More detail on the effects of management on overland dispersal of spotted frogs was incorporated in the 

FEIS (page 35, Wildlife Specialist Report, Spotted Frog section). Further research into published literature indicates 

that the “Northern clade” of spotted frogs that occurs near the Snow Basin project area is experiencing population 

expansion (Funk et al. 2008). 

Funk, C.W., Pearl, C.A., Draheim, H.M., Adams, M.J, Mullins, T.D., and Haig, S.M. 2008. Range-wide 

phylogeographic analysis of the spotted frog complex (Rana luteiventris and R. pretiosa) in Northwestern North 

America. Manuscript. U.S. Geological Survey Forest and Rangeland Ecosystem Science Center, 3200 SW Jefferson 

Way, Corvallis, OR 97331 

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#185. The following is a brief outline representative of the range of current scientific information that 

should be incorporated in revising the proposed decision and management actions of the Snow Basin 

Project: Fire and insect mortality are probably the most effective natural processes for providing the snags 

and large wood that are currently in deficit in these forests. (D59 p. 36)

Response: The Forest Service agrees that fire and insects are probably the most effective processes for recruiting 

snags, and this is acknowledged in several locations in the Wildlife Specialist Report (page 93, Primary Cavity 

Excavator section, and sections in the Biological Evaluation that address sensitive woodpeckers species). 

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#186. The DEIS maps of proposed treatments show that very little of the Snow Basin project area will be left untreated 

and that large, nearly contiguous, areas will be commercially treated. The DEIS needs to address the important issue 

of scale and make a conscious effort to find the optimal mix and scale of treated and untreated areas (or commercially 

treated vs. non-commercially treated areas). The DEIS says “Areas not proposed for treatment reside in RHCAs 

[Riparian Habitat Conservation Areas], wildlife refugia, and inaccessible areas.” Thus, virtually all acres that could be 

treated are slated for treatment, without any particular effort made to identify ecological values associated with 

untreated areas, without establishing goals for untreated areas, and without seeking an optimal mix of treated and 

untreated areas. We believe there must be more of an effort to address this issue (D64A, P. 5)

Response: Tables have been added to Appendix B to display proposed treated and untreated acres for the Snow

Basin Project area. Untreated areas are distributed throughout the landscape and each plays valuable ecological roles 

as described in Chapter 3 of the FEIS. Rx fire only is a treatment used to mimic natural processes to maintain acres 

that have evolved with periodic low to moderate intensity fire. These prescribed burn acres are included in the 

treatment acres within the Appendix B tables. Wildlife Areas, Refugia and MA 15 have been excluded from 

treatment to manage the landscape within the HRV for tree density species composition and structural stage. 

#187. Contiguous roadless extent and the irreplaceable environmental importance of roadless areas. Snow 

Basin would conduct activities in undeveloped and unroaded areas that currently provide ecologically 

important habitat and refugia. Uninventoried roadless areas are included among the project units, and the 

DEIS fails to accurately disclose and address the ecological importance and actual contiguous roadless 

extent of these areas, fails to correctly disclose where they are located and accurately describe their 

ecological site-specific conditions, and fails to adequately address the proposed project’s logging, skid trails, 

mechanized thinning, and other management action impacts upon these areas. The DEIS on p. 330 

illustrates the inadequacy of the PWA approach to evaluate impacts to uninventoried roadless areas. It also 

indicates that the FS is subjectively “writing off” the impacts of the proposed action on these irreplaceable 

roadless forests. Even in uninventoried roadless areas, NEPA requires the FS to consider the environmental 

impacts of a proposed project because logging, road building, and/or other intrusive management actions in 

roadless areas are so environmentally irreparable that their impacts are far beyond the threshold for 
Appendix C Snow Basin Vegetation Management Project FEIS

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significant. First, the FS is required to analyze the attributes of roadless areas. Second the FS is required to 

discuss a project’s impacts on areas of “sufficient size” for future wilderness designation. The NEPA 

analysis should discuss whether the project will push the landscape toward or away from the natural range 

of variability for unroaded habitat. (D59 pp. 93-94)

Response: We are unaware of any “natural range of variability for unroaded habitat.” The Potential 

Wilderness/Unroaded Areas analysis has been supplemented with additional maps and information. This information 

is located in Chapter 3 and Appendix B. 

Comments used to make factual corrections in the FEIS

#188. Errata? DEIS p. 21: Where stands are being converted to non-LOS, do not meet EASTSIDE 

SCREENS Direction and would require a FP Amendment. In the Proposed Action Alternative, this applies 

to 116 treatment areas proposed in G4 (26 acres), G5 (13 acres), and G7/8 (77 acres). Applies to Alternative 

2 only. BUT on p. 91 it says: Any timber harvest activity that results in a net loss of LOS, where stands are 

being converted to non-LOS, does not meet SCREENS Direction and would require a FP Amendment. This 

will be referred to as Snow Basin Amendment 2 (SB2). In Alternative 2, this applies to 874 treatment acres. 

In Cool/moist grand fir (22 acres), warm dry grand fir (358 acres), warm/moist Douglas-fir (86 acres) and 

warm/dry Douglas-fir (408 acres). Notice the difference in acres: 116 in the first reference and 874 in the 

second. Unless one talks only of commercial harvest and the other of all treatments, you have a big 

discrepancy and you may want to errata it. (D08 p. 1)

Response: This has been corrected in the FEIS. 

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#189. The DEIS states about these forests “Due to fire exclusion, shade tolerant species, grand fir and 

Douglas fir have expanded into areas that were once pure ponderosa pine or ponderosa pine/western larch 

mixture. Regeneration and growth of these species, over time, has created dense multiple canopy layered 

stands.” This is unacceptable. The Forest Service is proposing a solution that is clearly designed for low 

elevation dry forests and applying it to these mid/high elevations and ridges that should not be logged at all. 

All north facing and mid to high elevation units should be dropped. (D59 p. 48)

Response: The Fire Fuels report in Chapter 3 of the FIES was corrected to say "Due to fire exclusion, 

shade tolerant species, grand fir and Douglas fir have expanded into areas that were dominated by 

ponderosa pine or ponderosa pine/western larch mixtures." See response to #108. For discussion on north 

facing and high elevation stands: See the DEIS, Pg 56 Definition of Wildlife Refugia. Areas that have 

been excluded are defined on DEIS Pg 71. There are no High Elevation Stands within the Snow Basin 

planning area. Additional refugia areas have been excluded in the FEIS in Alternative 3 and Alternative 4.

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#190. The Snow Basin DEIS uses conjecture to support its actions in old growth grand fir forests. What 

science is the Forest Service relying on to make the following claim that “The characteristic mixed fire 

regime in cool/moist grand fir (DEIS p. 93) has been replaced by one of high intensity?” (DEIS at 93). It 

lacks scientific integrity to make unfounded claims about changes in the fire regime simply in order to 

support the Agency’s agenda. Please see the Scientific Integrity requirements of NEPA, and the attached 

memo regarding the directives of President Obama’s Memorandum of March 9, 2009. (D59 p. 14) 

Response: The FEIS has been corrected. The term "characteristic mixed fire regime" has been replaced by the term 

"characteristic expected fire behavior" in the FEIS. The intent was not to change the fire regime. Refer to discussion 

of Fire Regime/Condition Class and effective fuels modification in Chapter 3 Section 3.2 of the FEIS – Table 1; 

Figure 1. 
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Other Comments – Response Provided

While these comments did not generate changes in the FEIS, we would like to acknowledge the time and effort from 

the individuals and groups who submitted these comments. Where a response is appropriate, it is included. 

Comments that did not raise a specific issue or concern, and comments that spoke in favor or in opposition to specific 

alternatives, or to the Snow Basin project in general, do not have responses. 

#191. Best available science on roadless forests. Scientific research clearly enumerates the many reasons 

why remaining roadless areas should be protected. The FS has a legal obligation pursuant to NEPA to 

disclose all pertinent science, including ongoing scientific research and controversy. NEPA also requires the 

agency to develop scientifically sound environmentally protective action alternatives in its DEIS. The 

analysis for this project all proposes the exact same thing in uninventoried roadless areas (DEIS p. 330). 

Based on the best available science presented here, Snow Basin fails the requirements of NEPA to consider 

and disclose the best available scientific research on roadless forests and to develop scientifically sound 

environmentally protective action alternatives. (D59 pp. 91-93) 

Response: The Potential Wilderness/Unroaded Analysis conducted for the Snow Basin project can be 

found in Appendix B. Several of the larger uninventoried roadless areas in the project area overlap the 

Eagle Creek Wild and Scenic River Corridor. The Management Plan for the Eagle Creek Corridor 

recognizes the importance of many of the values listed in the comment. Other values of uninventoried 

roadless areas are discussed in various places in Chapter 3. In addition, Alternatives 3 and 4 have been 

extensively revised in the FEIS. 

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#192. NEPA analysis failures concerning uninventoried roadless and ecologically significant areas. 

Roadless “potential wilderness inventory” criteria and “analysis”. The agency fails to disclose the scientific 

research recommendations relevant to the importance of all roadless areas, inventoried or not. Instead, the 

FS uses the criteria it developed for PWA to avoid meaningfully addressing the harmful impacts of logging 

extensive heavy machinery use within environmentally significant de-facto roadless areas. The reasons 

scientists call for excluding treatment from roadless areas greater than 1,000 acres is not considered in the 

PWA analysis and therefore the PWA analysis criteria the FS uses to evaluate the significance of unroaded 

areas is not appropriate for assessing the ecological value of uninventoried roadless forests. The DEIS at p. 

337: This “systematic process of elimination” was not designed to evaluate and/or consider roadless areas 

greater than 1,000 acres and threatens degradation to these valuable roadless forests. The DEIS on p. 330. 

The PWA method breaks contiguous roadless forest into polygons, with each being assessed separately. 

This approach fails to analyze the imperative role all of these ecologically important unroaded areas play 

combined as a large expanse of contiguous roadless forest habitat and/or connective habitat, where 

disturbance is minimal. The types of limited disturbance evident in parts of Snow Basin do not significantly 

detract from these areas’ importance as unroaded, ecologically intact wildlife habitat and refugia. The 

importance of uninventoried roadless forests is not appreciably diminished by the vanishing presence of the 

long past evidence of limited levels of prior management. Though these may be considered by the FS as not 

meeting their “potential wilderness area” criteria – do not significantly detract from the ecological 

importance of the now largely undisturbed roadless forest habitat such areas provide. (D59 pp. 90-91)

Response: The Potential Wilderness/Unroaded Areas analysis can be found in Appendix B and is 

summarized in Chapter 3 of the FEIS. Effects of the proposed Snow Basin treatments on wildlife habitat 

and connective habitat are summarized in the Wildlife section of Chapter 3 and in the Wildlife Specialist 

Report. 

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#193. The 11-24-04 memo from Lisa Freedman of the PNW Regional Office wisely instructs the Forest 

Service to give consideration to “special” features of undeveloped areas regardless of size. However, this 

memo also has some troubling instructions that deserve mention. First, it instructs forests not to “establish 

a permanent identity or inventory for these areas” which not only interferes with efficient management on 

information and natural resources but also violates the NFMA mandate to maintain an accurate and up-todate inventory of the renewable resources. Second, forests are instructed to focus their analysis on the 
Appendix C Snow Basin Vegetation Management Project FEIS

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“effects of the proposed activity where the effects occur rather than on identification or inventory of the 

undeveloped area.” How can the effects of management be adequately disclosed “where they occur” or 

anywhere else for that matter, UNLESS the qualities of the area are fully understood through identification 

and inventory. This memo essentially instructs the Forest Service to (i) routinely destroy factual 

information about resources under its management, and (ii) provide uninformed disclosure of the effects of 

proposed management action without collecting and considering contextual information about 

roadless/undeveloped areas that could be affected. If the Forest Service follows these instructions they will 

be violating NEPA, so don’t do it. (D64A pp. 31-32)

Response: The Potential Wilderness/Unroaded Analysis conducted for the Snow Basin project can be 

found in Appendix B. Several of the larger uninventoried roadless areas in the project area overlap the 

Eagle Creek Wild and Scenic River Corridor. The Management Plan for the Eagle Creek Corridor 

recognizes the importance of many of the values listed in the comment. 

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#194. Separate from its duties under the Wilderness Act and the National Forest Roadless Rule, the FS has 

a duty under NEPA to disclose the impact of its management proposals on ecologically relevant resources. 

The Forest Service adopted new guidance concerning ecological restoration and resilience which urges 

managers to “identify opportunities to sustain ecological refugia that may serve as vital sources of ecological 

diversity.” This is an opportunity to look at uninventoried roadless areas in a fresh new light. (see 

reference D64A pp. 31-32)

Response: See response below. Several of the larger uninventoried roadless areas in the project area 

overlap the Eagle Creek Wild and Scenic River Corridor. 

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#195. Unroaded areas greater than about 1,000 acres, whether they have been inventoried or not, provide 

valuable natural resource attributes that must be analyzed under NEPA, and hopefully protected. These 

include: water quality; healthy soils; fish and wildlife refugia; centers for dispersal, recolonization, and 

restoration of adjacent disturbed sites; reference sites for research; non-motorized low-impact recreation; 

carbon sequestration; refugia that are relatively less at-risk from noxious weeds and other invasive nonnative species, and many other significant values. Management activities like road building and logging can 

have disproportionately significant adverse effects on these unroaded resource values. A growing number 

of scientific studies indicate the significant value of roadless areas smaller than 5,000 acres and larger than 

1,000 acres. Recent scientific literature emphasizes the importance of unroaded areas greater than 1,000 

acres as strongholds for the production of fish and other aquatic and terrestrial species, as well as sources of 

high quality water (see references D64A pp. 32-33) (D64A pp. 31-33)

#196. Low impact restoration activities including but not limited to prescribed burning and precommercial 

thinning may be appropriate in roadless/unroaded areas as long as they will be substantially unnoticeable to 

the casual observer and leave the area suitable for future wilderness designation. The NEPA document 

must accurately describe the roadless/unroaded area, the roadless/unroaded values represented, and the 

need for, and impacts of, the proposed restoration activities. (D59 pp. 91-93)

Response: There is one “other undeveloped” polygon greater than 1,000 acres identified in the Potential 

Wilderness Analysis in the FEIS. More than half of that polygon is in the Eagle Creek Wild and Scenic 

River Corridor. The Management Plan for the Eagle Creek Corridor recognizes the importance of many of 

the values listed in the comment. The proposed harvest units that overlap this >1,000 acre polygon and 

their effects are identified in Chapter 3 and Appendix B.

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#197. We have some concerns about the roadless analysis in the DEIS. The wilderness inventory conducted 

for the Blue Mountains Plan Revision process is not accurately capturing the full suite of unroaded values 

that are relevant to an accurate “hard look” NEPA analysis. The wilderness inventory criteria excludes 

certain features that clearly add value to the unroaded resources such as areas within 300 feet of roads and
Appendix C Snow Basin Vegetation Management Project FEIS

593

areas previously subject to less intensive forms of timber management. We urge the FS to conduct a 

credible inventory of unroaded areas >1,000 acres and apply only non-commercial restoration methods in 

unroaded areas >1,000 acres. We urge the FS to avoid commercial logging in unroaded areas because 

commercial removal requires roads, has adverse impacts on soil and water, and will remove important 

structural building blocks. Unroaded areas are rare and under-represented. Roadless areas also harbor 

natural processes like mortality recruitment and carbon accumulation that are not well-represented across 

the managed landscape. (D64A p. 31)

Response: The potential wilderness inventory for the Snow Basin project was conducted independently of 

the wilderness inventory completed for the Blue Mountains Plan Revision. (see DEIS p. 330 and DEIS 

Appendix B). 

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#198. This project appears to mostly steer clear of roadless areas, but we are not certain, based on the maps 

in the DEIS, whether any commercial logging treatments are proposed in unroaded areas included in 

Oregon Wild’s inventory. Unit 304 in the Eagle Creek Wild and Scenic River corridor appears to be in an 

unroaded area. (D64A p. 31)

Response: Unit 304 is located in an unroaded area included in Oregon Wild’s inventory. 

------------------------------------------------------------------------------------------------------------------------------------------#199. 

Some stands in the Snow Basin project area where part of previous proposals such as Eagle Paddy and Eagle Holcomb 

that would have logged trees >21” dbh. The public protested these actions and was able to resolve the differences by 

allowing the Forest Service to remove trees less than 21” dbh, while saving those larger. The Forest Service planted 

trees in these areas, and now claims that the trees greater than 21” dbh must be cut down for the seedlings. The irony 

of cutting down large century old trees that are rare on the landscape to protect a seedling that could be killed by any 

number of reasons...is astounding. How many times must the public save the same trees? (D59 p.24)

Response: Large trees (>21” DBH) were considered and discussed in many sections of the DEIS and 

FEIS. Changes were made during development of the FEIS. As a result of public comment and analysis 

of number of 21” trees that would be harvested under alternatives 2 and 3, and the number of 21” trees that 

would remain, were modified. See Chapter 1 of the FEIS for purpose and need. The removal scenarios for 

21+ trees can be found in Chapter 2 of the FEIS. In both the DEIS and FEIS, under Alternative 4, no trees 

>21” DBH would be removed. 

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#200. The following is a brief outline representative of the range of current scientific information that 

should be incorporated in revising the proposed decision and management actions of the Snow Basin 

Project: (D59 p. 37)

Remaining LOS areas are critical to biodiversity and larger LOS and/or roadless areas typically have the 

lowest potential for altered fire regimes, especially due to their location at higher elevations (Henjum et al. 

1994). Such areas should be protected from intrusive management alterations including logging, road 

building, and other scientifically unfounded actions. 

 

Response: Large roadless areas of LOS are not currently proposed for treatments within the project area. 

Multi-story LOS is currently within the HRV for all biophysical environments in the HRV analysis area. It 

would remain within HRV under all action alternatives. The effects to LOS are discussed in Chapter 3 

Section 3.1 of the FEIS. Reference Appendix B.

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#201. Failure to involve the Pine Eagle Consensus Group as interested stakeholders in the development of 

this project highlights the lack of a true collaborative effort. Instead of bringing together all interested 

parties to discuss the range of possibilities first so that decisions could reflect our environmental values and 

to head off potential conflicts, a developed plan was established prior to meeting with interested parties. 

(D59 pp. 96-97)
Appendix C Snow Basin Vegetation Management Project FEIS

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Response: The Forest was not aware that the Pine Eagle Consensus Group was still operating as a group; 

however, we made efforts to ensure that all interested individuals, including members of the group, were 

included in the public comment process for the Snow Basin project. Pages 7-8 of the DEIS and Appendix 

B-11 of the DEIS describe the public involvement process for the Snow Basin project. Letters, newspaper 

articles, public meetings and field trips were used to involve interested parties in the process leading to 

development of the alternatives and issues. 

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#202. The Snow Basin project proposes logging in moist mixed conifer forests. Scientific research has 

repeatedly concluded that thinning is not needed, effective, nor ecologically beneficial in moist mixed conifer 

forest to prevent fire, does not mimic the complex natural fire regime (Noss et al, 2006; Rhodes, 2007) and 

threatens to increase fire risk (Lindenmayer et al. 2009). This forest type is fragile and vulnerable to the 

chronic negative impacts of industrial commercial logging. Mature and old-growth moist mixed conifer 

stands have dense, moist interiors and little wind, which inhibit the spread of wildfire (Lindenmayer et al. 

2009; Morrison and Smith, 2005; Rhodes, 2007). Large fires are climatically driven and fuels reduction 

treatments can be insignificant to prevent fire spread under these conditions. However, the post-fire habitat 

is significantly degraded by the logging that happens in the name of fuels reduction prior to the fire. (D59 p. 

9)

Response: Reference Purpose and Need DEIS Ch. 1 Treatments are intended to return cool moist to 

historical species composition. There is no intent to prevent fire in moist forests. Current conditions will 

support high severity fire which is outside the predominant regime for this stand type. 

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#203. The DEIS states at 44: “Alternative 4 would not prepare the treated portions of the cool/moist, 

warm/very moist, and warm dry grand fir landscape for development into characteristic conditions or 

maintenance through low intensity fire. In fact, conditions will immediately begin to revert back to the 

existing condition due to the retention of a well distributed grand fir seed source.” It is scientifically 

indefensible to suggest that the cool/moist Grand fir type is outside of HRV based on fire suppression. It is 

scientifically inaccurate to group very moist sites with dry sites and suggest that they should be managed by 

low intensity fire. Regarding the claim that these sites will immediately begin to revert back to the existing 

condition due to maintenance of the old growth grand fir, please see Emeritus Professor Dr. Richard 

Waring’s different opinion below.

Dr. Richard Waring stated in his Declaration on the “Wildcat Fuels Reduction and Vegetation Management 

Project,” “Grand fir, which establishes under the shade of the other species, has notably thinner bark, and 

because of this feature is easily damaged by fire. With the burning of slash, grand fir will become 

progressively less abundant in this type, even if large diameter trees were to be left standing. Less shadetolerant trees with thicker bark will become relative more dominant, even with some selective removal.”

This indicates that the conditions are sustainable and that the objectives of reducing fuels, increasing early 

successional species, and maintaining the larger Grand fir can all be achieved simultaneously. This would 

allow the larger Grand fir to help fill the gap defined by the deficit of large trees across the landscape as the 

Eastside Screens intended. (D59 p. 4, 5 & 17)

Response: Cool moist forests within the analysis area have an average 59 year fire return interval. The 

last large fire within the analysis area occurred in 1910. Stands have missed at least one if not more fire 

return intervals, missed fire return intervals is a measure of departure of FRCC. The prescription in cool 

moist includes selective removal of some large grand fir in favor of Ponderosa Pine and western larch, but 

would retain most of the large grand fir. 

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#204. Critically Important Comprehensive Science Review on Moist Forest Logging Not Considered. A 

review paper recently published in Conservation Letters entitled: Effects of logging on fire regimes in moist 

forests (Lindenmayer et al. 2009) focuses primarily on logging in relatively moist forests where fires 
Appendix C Snow Basin Vegetation Management Project FEIS

595

naturally occur at a lower frequency relative to dry forests, such as within the moist forests with mixed 

severity regimes within the Snow Basin Project Area (manuscript attached here). This manuscript

represents a thorough a review of over 650 articles and cites to many articles that we have submitted with 

these DEIS comments. 

Lindenmayer et al. (2009) state:

“Our focus is on relationships between industrial logging practices in native forests (i.e., not plantations) 

and alterations to natural fire regimes (sensu Gill 1975) that might include (among others) changed 

susceptibility to ignition, altered fire severity, altered fuel loads and fuel condition, and changed fire 

frequency. Altered fire regimes can have significant negative effects on biodiversity in moist forests 

(Holdsworth & Uhl 1997; Brown et al. 2004; Noss et al. 2006b; Lindenmayer et al. 2008), especially those 

forest types where wildfires are extremely rare or even a novel kind of major natural disturbance (e.g., some 

kinds of tropical rainforest, Uhl & Kauffman 1990; Cochrane & Barber 2009).” 

Lindenmayer et al. (2009) identifies at least five interrelated ways that logging could influence wildfire 

frequency, extent and/or severity, each being extremely relevant to the Snow Basin Project.

1. Changes in Microclimate: The removal of trees by logging creates canopy openings and this in turn 

alters microclimatic conditions, especially increased drying of understory vegetation and the forest floor 

(Ray et al. 2005; Miller et al. 2007). As with the influence of forest edges (Harper et al. 2005), microclimate 

effects (including fuel drying) associated with forest harvesting can be expected to be greatest where the 

unmodified forest is moist.

2. Changes in stand structure and plant species composition: [Logging] changes not only alter 

microclimatic conditions as described above, but also can change stocking densities and patterns of trees, 

inter crown spacing, and other forest attributes such as plant species composition. Research in western 

North America indicates that logging related alterations in stand structure can increase both the risk of 

occurrence and severity of subsequent wildfires through changes in fuel types and conditions (Thompson et 

al. 2007).

3. Changes in fuel characteristics: Logging can alter fire regimes by changing the amount, type, and 

moisture content of fuels (Perry 1994; Weatherspoon & Skinner 1995; Thompson et al. 2007; Krawchuk & 

Cumming 2009). Large quantities of logging slash created by harvesting operations can sustain fires for 

longer than fuels in unlogged forest and also harbor fires when conditions are not suitable to facilitate 

flaming combustion or the spread of fire (Cochrane & Schulze 1999). 

4. Change in ignition points: The road networks required for logging operations create an increased 

number of ignition points for wildfires. A substantial increase in ignitions and fire frequency in Russian 

boreal forests (Achard et al. 2006) has been attributed, in part, to roads built for logging and mining (Dienes 

2004; Bradshaw et al. 2009). In Canadian mixedwood boreal forests, fire initiation following lightning 

strikes is more likely to occur in harvested areas because of increased fine fuels resulting from logging slash 

and this effect can remain for 10–30 years following logging (Krawchuk & Cumming 2009).

5. Change in the spatial pattern of stands: Logging operations change natural patterns of spatial 

juxtaposition of different kinds of forests stands (i.e., patterns of landscape heterogeneity) (Franklin & 

Forman 1987). This, in turn, can change spatial contagion in the spread of wildfire through landscapes 

(Whelan 1995; Bradshaw et al. 2009) with some areas traditionally characterized by an absence of fire 

becoming more susceptible to being burned by fires that spread from adjacent, more flammable, logged 

areas (Holdsworth & Uhl 1997; Perry 1998; Nepstad et al. 1999; Malhi et al. 2009). Similarly, forest edges 

created by logging and by logging roads can become sites for fire incursions into adjacent forests (Cochrane 

& Laurance 2002).
Appendix C Snow Basin Vegetation Management Project FEIS

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Lindenmayer et al. (2009) offer the following conclusions: 

“Contrary to claims by some commentators (e.g., National Association of Forest Industries 2009a,b,c), 

industrial logging is likely to make some kinds of forests more, not less, prone to an increased probability of 

ignition (Krawchuk & Cumming 2009) and increased fire severity and/or fire frequency (Uhl & Kauffman 

1990; Thompson et al. 2007; Bradshaw et al. 2009; Malhi et al. 2009). Such places include tropical 

rainforests where fire was previously extremely rare or absent (Uhl & Kauffman 1990; Barlow & Peres

2004; Malhi et al. 2009), and other moist forests where natural fire regimes tend toward low frequency, 

stand replacing events (Whelan 1995; Odion et al. 2004; Bradshaw et al. 2009). These altered fire regimes 

can, in turn, have significant negative effects on a range of elements of forest biodiversity (Uhl & Kauffman 

1990; Lindenmayer & Franklin 2002; Barlow & Peres 2004; Cochrane & Barber 2009). 

“If industrial logging changes fire proneness, then interactions between logging and climate change could 

lead to cumulative negative impacts, including those on biodiversity. Conversely, recent work in Amazonia 

suggests that some kinds of forest may have some inherent resilience to climate change through maintaining 

mesic microclimate conditions if other agents such as logging are left undisturbed (Malhi et al. 2009). Third, 

a better understanding of relationships between logging and wildfire will improve policy making and forest 

management. For example, in moist forests there may be a case to create buffer areas adjacent to human 

settlements. In addition, there may be a strong case to exclude logging from those areas where past human 

disturbances (like timber harvesting) have been limited (Cochrane & Barber 2009). This is because logging 

induced alterations in landscape cover patterns can take prolonged periods to reverse and hence associated 

changes in fire susceptibility also may be long lived (Perry 1998).” 

“Calls to log forests to save them (Tuckey 2001) are overly simplistic. In this case, fire and forest 

management recipes suitable in one situation (e.g., for restoring the natural fire regime of a dry forest) 

might be inappropriate (and even counter productive) in another (e.g., a relatively moist forest) (Brown et 

al. 2004).”

All moist forest types should be dropped from the Snow Basin project proposal. (D59 pp. 14-16)

Response: The major cited literature, Lindenmayer et al., and the supporting literature are concerned with 

boreal forests. Lindenmayer includes “other moist forests where fire regimes tend toward low frequency, 

stand replacing events”. In the Wallowa Mountains, this would be analogous to high elevation cold 

upland forests. The moist forest in Snow Basin experienced a mixed fire regime historically. This has 

changed to a high severity regime today. See the Fire and Fuels report and the Silviculture report. Within 

the Wallowa Mountains moist forest includes a range of moisture and temperature regimes. The areas 

classified as moist forest in Snow Basin are the grand fir /big huckleberry plant association (VAME). This 

type is at the driest end of the moist forest moisture regime. Little differentiates VAME from the adjacent 

dry grand fir forest types other then the presence of big huckleberry. In the fuels report there is a 

discussion of how the VAME areas would respond to fire. In short, due to their position on the landscape, 

the surrounding dry forest, being the driest moist forest type, and south aspects, fire in the VAME areas 

would behave similar to the adjacent dry forest. Also see the Fire/fuels Report. 

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#205. Objective 1 is to manage forest structure towards landscape historic range of variability (HRV) by 

creating more single story LOS and shifting tree species composition toward early seral species.

Response: This objective is fine at the right scales in the right PAGs (Plant Association Groups), but there 

is evidence to indicate that some of the more moist forest types in this project do not fit the SSLT template. 

(D64A, p. 5). See responses to #39 and #295.

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#206. The Snow Basin claims that Grand Fir over 21” DBH are “immature.” The DEIS states at 53: “Over 

several decades the shade tolerant tree species have thrived with many immature trees reaching large size 
Appendix C Snow Basin Vegetation Management Project FEIS

597

(greater than or equal to 21" dbh). An informal sample of 50 grand fir greater than or equal to 21” resulted 

in an average d.b.h. of 24” and age of 93 years.” There is a general scientific consensus that the approximate 

age for protecting old growth trees in eastern Oregon is about 150 years. In fact the DEIS recognizes this at 

66: “Current old growth tree definitions for ponderosa pine, grand fir, Douglas-fir, and western larch 

include a minimum age of 150 years diameter breast height (USDA-FS Region 6 Interim Old growth 

Definition, 1993). “ If these Grand fir trees are two/thirds the age of old growth, why does the Forest Service 

fail to recognize them as mature? Moreover, the DEIS states at 85: “These 21+ grand fir have bark thick 

enough to survive low intensity fire.” This is clearly the sign of a mature tree. These mature Grand fir trees 

constitute our future old growth and Snow Basin aims to cut them down based on the erroneous claim that 

they “immature.” (D59 p. 21)

Response: The need to remove some 21+ trees is disclosed in Chapter 2 of the FEIS. The effects of their 

removal under Alternatives 2 and 3 are disclosed in Chapter 3 of the FEIS. Alternative 4 responds to this 

issue by not including the removal of 21+ trees. 

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#207. Similarly the issue of removing trees over 21” dbh will draw a lot of attention (it already has). It 

appears to us that you have done a commendable job in documenting the reason for these trees being 

removed. Unfortunately some have focused on the trees per acre (TPA) you propose to remove over the 

12,400 acres being treated (Table 53, DEIS page 97). 

Here too you must highlight the fact that you are LEAVING a weighted average of 4.3 TPA over 21” dbh 

(Table 13, DEIS page 32). Again, these remaining trees are only in the 12,400 acres being treated. You must 

quantify the amount of trees over 21” dbh to the extent practical in the remaining portion of the 26,493 

acres not being treated. (D50 p. 2)

Response: Reference Ch. 3 Section 3.1 – Table Estimation of Large Number of Trees being removed by 

Bio-Environment.

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#208. There is much to recommend the Snow Basin Project, especially its goal to protect old-growth 

ponderosa and reduce the risk of catastrophic fire. The fatal flaw, however, is the removal of trees > 21” 

dbh. Much could be achieved by removing smaller trees, especially the smaller firs. But from a habitat and 

soil protection standpoint, removal of the largest trees is a huge mistake. (D25 p. 1)

Response: The objectives in regards to stand management and 21+ trees can be found in Chapter 2 of the 

FEIS. Alternative 4 would not harvest 21+ trees. 

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#209. Mistletoe Analysis is Subjective and relies on personal experience that is highly questionable. E. The 

DEIS makes quantitative statements regarding mistletoe infection levels and reduction that would result 

from alternatives that are not based on any analysis or science, rather they are subjective opinions of the 

Forest Service and are most likely incorrect and biased. For example, pg 86 of the DEIS presents estimates 

for DMT infection over 23,608 acres based on a citation to the Whitman silviculturist. There is absolutely no 

indication of how this “assumed” quantitative value that applies to over 20,000 acres was determined. The 

DEIS states at 86: “In stands treated under Alternatives 2 and 3, timber harvest would reduce DMT as 

much as 70% by direct removal of moderately and severely infected trees.” This statement is cited again to 

the silviculturist and this time to “personal experience.” Please disclose what specific experience these 

quantitative figures are based on, especially considering this project proposes to log over 40,000 trees 

greater than 21” DBH, a level of old growth that has not been proposed since before the Eastside Screens. 

When has the silviculturist had experience in large-scale quantitative mistletoe assessments and the 

reductions based on the proposed treatments? What level of extrapolation does the Forest Service think is 

appropriate given the diverse forested landscape and the diverse ecology of mistletoe? On page 87 of the 

DEIS, prescribed fire is deemed insufficient to reduce DMT based on “personal experience.” 
Appendix C Snow Basin Vegetation Management Project FEIS

598

The Snow Basin DEIS fails to present an evidence-based science driven analysis to mistletoe. Rather pages 

86- 88 are subjective and based on the personal experience of the silviculturist whose viewpoints on mistletoe 

are heavily influenced by the commercial timber production model (see section 21). This results in a heavily 

skewed analysis that is in violation of NEPA and alternatives that violate NFMA. (D. 59 pp. 18-19) 

Response: For analysis of Dwarf mistletoe, see the Silviculture report in the Analysis File. The analysis 

conducted for the Snow Basin project was conducted by journey level resource specialists, working as an 

interdisciplinary team, using the most up to date information and the best applicable scientific information 

available. This work is documented in interdisciplinary team meeting notes in the project file and in the 

specialists’ reports.

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#210. The Regional Forester’s letter urged retention of existing habitat values associated with large 

mistletoe infected trees. Yet, this is not being done in this project. (See the subsection and citations below 

regarding the ecological view of mistletoe.) (D64A, p. 12)

Response: Reference the removal Large Tree Removal Scenarios in Ch. 2 of the FEIS.

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#211. An unprecedented level of negotiation and compromise led to an agreement between the conservation 

community and the timber industry resulting in proposed legislation by Senators Wyden and Merkley. Here 

are some specific suggestions for bringing the Snow Basin Project more in line the proposed Oregon 

Eastside Forests Restoration, Old Growth Protection and Jobs Act (S.220,IS, 112th Congress). 

Large trees with mistletoe should not be removed. Mistletoe is a native species that results in more diverse 

canopy structure that provides many benefits to wildlife. The goals of the legislation include allowance for 

characteristic natural disturbances. Killing some large mistletoe infected trees might be acceptable, but they 

should be retained onsite as snags.

(e) PROHIBITIONS ON REMOVAL OF CERTAIN TREES.—

(1) LARGER TREES.—Except as provided in paragraph (3), the Secretary shall prohibit the cutting or 

removal of any live tree located in the covered area, the diameter of which is 21 inches or greater measured at 

breast height....

(3) EXCEPTIONS.— (A) ECOLOGICAL EXCEPTION.—The prohibitions described in paragraph (1) shall 

not apply if the Secretary, after considering the recommendations of the advisory panel and consulting with 

each relevant collaborative group, determines that the cutting or removal of the tree would be consistent with 

the goals described in subsection (b)(1) [cited below]

In the Wyden legislation, trees over 21” could only be cut if determined to meet the land management goals 

of the legislation, which are:

(b) LAND MANAGEMENT GOALS.—

(1) IN GENERAL.—In the covered area, the Secretary shall, considering the

best available science, seek—

(A) to conserve and restore forest health, watershed health, and other

ecosystems;

(B) to reduce the risk of, and increase the resistance and resiliency of the land

to, uncharacteristic disturbances;

(C) to allow for characteristic natural disturbances; and 

(D) to harvest wood to maintain adequate levels of industry infrastructure to accomplish the goals described in 

subparagraphs (A), (B), and (C). 

Exceptions to the 21” diameter limit must limited and clearly constrained by ecological objectives, not as 

broad as those proposed for the Snow Basin Project. 
Appendix C Snow Basin Vegetation Management Project FEIS

599

(D64A p. 8-10) 

Response: Many of the features of the Wyden legislation are in line with Snow Basin. See the analysis of 

the removal of 21+ trees in Chapter 2 of the FEIS. 

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#212. Only high-severity fire can effectively eliminate mistletoe. It is important to remember these public 

lands must be managed for a wide variety of values. Managing for peak growth rates of commercial tree 

species should be a think of the past. Science tells us that mistletoe is a persistent part of infected stands and 

effective mistletoe control is nearly impossible. Selective harvest is an ineffective treatment because many 

trees are infected but do not exhibit clear evidence of infection. 

The DEIS makes misleading assertions about the effectiveness of mistletoe treatments” “Under Alternatives 

2 and 3, ponderosa pine regeneration in Partial Overstory Removals and Regenerations prescriptions would 

be protected from infection by removing DMT including 21+ infected trees.” (DEIS p 87). In reality, the 

only way to effectively treat mistletoe is to kill infected and host trees hosts over large areas so that the 

regeneration grows up faster than the mistletoe can invade from the edges. Mother Nature kept mistletoe in 

check through occasional large stand replacing fires. The only way for the agency to control mistletoe would 

be to prescribe large stand-replacing fires or do large clearcuts, which are either ecologically or socially 

unacceptable. Small clearings won’t be effective, and any form of partial cutting won’t be effective, because 

residual trees, even if they are not visibly infected, are usually in fact infected, and they will spread infection 

to the regenerating stand.

Since mistletoe does not kill trees directly and since it has many ecological benefits, the best course is to set

our expectations a little lower in terms of tree growth and just to learn to live with mistletoe in this infected 

area and focus management on restoring natural fire regimes. In the long-term mistletoe will be 

“controlled” the next time this area is subject to a stand replacing fire. Reference: Pollock & Suckling 

(1995), Conklin (n.d.), Penning & Callaway (2002), Geils et al. (2002), Bennetts et al. (1996), Maloney & 

Rizzo (2002), Hawksworth (1985), and Johnson et al. (1976). (D64A p. 6, D64A pp. 20-21, references pp. 21-

22)

Response: Fire can “eliminate” DMT from areas experiencing high intensity fire. Historically, fire has 

reduced mistletoe in lower crowns through periodic low to moderate severity fire. The treatments would 

reduce severity. DMT will remain well distributed across the landscape. Moderated to severe DMT 

infections can reduce tree vigor and increase susceptibility to bark beetles. DMT does kill severely 

infected Douglas-fir. In western larch, DMT brooms directly cause a loss of crown due to the weight of 

the brooms. Eventually the crown is unable to sustain the tree. See Chapter 3 of the FEIS and the 

Silviculture Report. 

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#213. We urge the Forest Service to develop an alternative in the FEIS which focuses commercial 

treatments on: non-LOS forests, in unambiguously dry forest types, using non-regeneration prescriptions. 

The Forest Service should also consider more options to retain large trees, such as killing and retaining 

some large trees as snags, or pruning selected branches of large trees that pose particular risks, which can 

reduce fuel hazard and/or reduce mistletoe, while retaining structural values associated with large trees.

Failure to consider such alternatives highlights the ongoing problem of ecological restoration objectives 

being undermined by economic objectives, which is a primary source of the conflict, controversy, and 

ecological degradation that everyone hopes to put behind us. The Forest Service needs to work toward 

balanced approaches to restoration that recognize the value of both active and passive restoration, in order 

to find the optimal mix of both of these approaches. The good news is that numerous successful project 

across Oregon demonstrate that restoration-based initiatives can still produce significant economic benefits. 
Appendix C Snow Basin Vegetation Management Project FEIS

600

Objective 3 is to provide a supply of forest products to the public. We recognize the interest in producing an 

economically viable project, but we strongly urge that the objective of wood production not trump ecological 

goals. The preferred alternative will remove approximately 43,000 trees larger than 21" dbh. While some of 

these might need to be killed in order to help save an adjacent even larger early seral species like ponderosa 

pine, there is still a severe shortage of large snags and dead wood, so we urge the Forest Service to retain as 

many of these large trees as possible to help mitigate the landscape level deficit of large trees and snags. 

Killing and retaining some of these large trees will better mimic natural disturbance processes and move 

toward the HRV for large snags. (D64A, p. 3 & p. 7)

#214. The FEIS should consider a wider range of possible management approaches, including strategically

identifying large shade-tolerant trees that are in direct competition with even large shade-intolerant trees, 

and killing but leaving the large trees that need to die, to help mitigate the regional deficit of large snags. 

Another option, not considered by the Forest Service, would be to prune the lower branches of the large 

trees to reduce ladder fuels by increasing the gap between the ground and the crown. These efforts may be 

expensive, but it is widely recognized that not all restoration activities will generate income. These are 

among the important investments that are needed to effectively restore eastside forests. (D64A, p. 12)

Response: In the FEIS in all alternatives, regeneration harvest treatments have been dropped. Ch 2. Of 

the FEIS discusses alternatives as proposed by the public during scoping in which girdling was evaluated 

but eliminated from detailed study. As a result of public comment and analysis of number of 21+ trees that 

would be harvested under alternatives 2 and 3, as well as, the number of 21+ trees that would remain was 

modified. See Chapter 1 of the FEIS for purpose and need . The removal scenarios for 21+ trees can be 

found in Chapter 2 of the FEIS. In both the DEIS and FEIS Alternative 4 does not remove large trees. 

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#215. A paper that suggests ten guiding principles to help maintain biodiversity, ecosystem function, and 

resilience in production landscapes (Fischer et al. 2006) states the following: Strategy 7: Apply appropriate 

disturbance regimes. Landscape change often results in a change to historical disturbance regimes. Such 

changes can substantially alter vegetation structure and species composition (Hobbs and Huenneke 1992) 

and may trigger cascades that cause fundamental and potentially irreversible changes to ecosystems. 

Pronounced ecological changes in production landscapes can result from changed fire regimes, changed 

grazing regimes, and logging. Understanding the impacts that particular disturbance regimes have on 

ecosystem functioning is therefore important for ecosystem management. Broadly speaking, disturbance 

regimes that attempt to mirror historical ones are probably a useful starting point for management. 

Managing disturbance regimes is especially important where it is known or suspected that many species 

depend on particular perturbations or successional stages. What is appropriate for one forest type is not 

appropriate for the other and peer reviewed science clearly states that the complexity created by variability 

in fire regimes defies a one-sized fits all management prescription. The DEIS argues that Snow Basin 

would allow for “natural disturbance” to return to the landscape, but natural disturbance regimes cannot 

be imposed on the wrong biophysical environment – this would not longer constitute a natural functioning 

disturbance regime. (D59 p. 6, 8)

#216. As a whole, Snow Basin fails to recognize the diverse forests across the project area, does not 

constrain fuels reduction treatments to low elevation dry forests, targets old growth and replacement old 

growth for removal, threatens degradation to all areas defined by the complex mixed severity fire regime, 

threatens roadless forests with commercial logging and industrial machinery, inappropriately uses HRV as 

a means to promote heavy logging, threatens area soils and watersheds with widespread chronic 

disturbance, and disregards the natural role of native disturbance agents such as wildfire and insects and 

disease. (D59 p.2)

Response: The prior harvest and lack of disturbance have resulted in an existing condition where 

treatments designed to retain existing early seral trees (ponderosa pine and western larch) and promote 
Appendix C Snow Basin Vegetation Management Project FEIS

601

conditions suitable for establishment of additional early seral trees is a high priority. This is discussed in 

the FEIS in Chapter 3 in the Fuels and Vegetation sections. 

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#217. That the DEIS tries to mask these objectives (DEIS Table 69) as “restorative” and use the fear of fire 

as a tool for heavy handed logging in inappropriate biophysical environments that are characterized by 

mixed and high severity fire regimes is arbitrary and capricious. Moreover it is a violation of the scientific 

integrity standards set out by President Obama. (D59 p. 49)

Response: The rationale for treating stands characterized by mixed fire regimes can be found in Chapter 3 

of the FEIS in the Fuels and Vegetation sections. There are no high severity fire regime areas proposed for 

treatment in any of the alternatives. 

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#218. The inherent variability of mixed-severity fire regimes precludes easy analysis of fire-exclusion 

effects, because high tree density or an abundance of shade-tolerant trees is not necessarily the result of fire 

exclusion. Past episodes of high-severity fires associated with droughts would have resulted in patchy stand 

ages across landscapes, and therefore, varying relative abundances of ponderosa pine and Douglas-fir. The 

mixed-conifer stands have developed with long-term cyclic fluctuations of low, mid, and high-severity fires; 

thus, there is little verifiable support to show that the stands’ fire regimes have been significantly altered. If 

the fire regime is not altered, then fuel “treatments” do not help to reduce the risk of severe fire or restore 

the stand to its natural fire behavior. (D59 pp. 33-34)

Response: Past management actions and impacts (including fire suppression) are documented in DEIS. 

The sequence of stand development in these stands is know and has been explained.

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#219. Beneficial fire use in this sense (DEIS p. 129) is ecological nonsense. As the Eagle Cap is at higher 

elevations than the project area, fire spreading from the Eagle Cap will first encounter the mixed conifer 

systems in the project area. This mixed conifer type is defined by the variable mixed severity fire regime. If 

the Forest Service wants to use wildland fire, it must accept the mixed-severity system. 

Response: See FRCC narrative in DEIS, pg 124-127 – discussion in DEIS under cumulative effects is 

much broader than addressed in this comment which appears to be focused on mixed conifer stand types. 

One effect of the proposed treatment would be an increased opportunity to allow future wildfire to play a

more natural role, assuming potential for higher intensity fire in the cold dry and cool moist sites, and 

lower intensity as you move down the slope onto the warm and hot dry sites. 

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#220. To suggest that fire suppression has been effective for 100 years is without merit considering that the 

technologies that really allowed modern direct attack, the road systems used to facilitate suppression, and 

the heavy machinery such as bulldozers, helicopters, engines, and airplanes that allowed widespread fire 

suppression tactics to be so effective have only been more recently available. While containing portions of 

wildland urban interfaces, much of the project area is remote and distant from residential communities, and 

likely did not experience effective fire suppression efforts until the mid 20th century. At most fire frequency 

patterns have been absent for 50-60 years. Fire suppression has not impacted the moist mixed conifer 

systems in any way that warrants fuels reduction. (D59 p. 47)

Response: See FRCC analysis relative to departure from desired, historic condition class, DEIS pages 

124-127. Comment is correct in that fire suppression has been the most effective since the 1940s when 

modern vehicles and equipment became available and road systems improved (RMRS GTR-120. 2004). 

Large, continuous areas represented by cool moist and cold dry sites which would be expected to have less 

frequent occurrence of fire, are not proposed for treatment and overall exhibit a history of fire frequency 

that is within the range of what would have been expected historically (See FRCC analysis).

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#221. Limit fuels reduction work to the low elevation dry forest type (D22 p. 2, D24 p. 1)
Appendix C Snow Basin Vegetation Management Project FEIS

602

Response: While a factor, elevation alone does not determine PNVG (PNW-GTR-709, Pg 6). Dry forest 

types in the analysis span a broad range of elevations, see DEIS mapping.

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#222. Restoration of remaining unlogged lower-elevation sites should focus on the reintroduction of fire and 

protection from activities that may cause degradation or loss of existing old growth: 1) Evaluate passive 

opportunities for introducing fire without any mechanical treatment. 2) Use the minimal amount of 

mechanical treatment needed to safely reintroduce fire. This will typically include trees mostly in the 3-8” 

DBH range and no larger than 12” dbh. Only hand crews should be permitted to enter existing old growth 

and previously unlogged forests. (D59 p. 23)

Response: See alternatives considered but dropped from consideration (burn only, DEIS page 27). As 

described, this alternative is viable, however due to the complexity and cost of implementation it is not 

economically or practically feasible. 

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#223. Calls to log forests to save them are overly simplistic. Fire and forest management recipes suitable in 

one situation might be inappropriate (and even counterproductive) in another. (D59 p. 16)

Response: See FRCC analysis (DEIS page 124-127)and vegetation report. Proposed actions are tailored 

to specific stand conditions.

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#224. Logging operations change natural patterns of spatial juxtaposition of different kinds of forest stands 

(i.e. patterns of landscape heterogeneity). This, in turn, can change spatial contagion in the spread of 

wildfire through landscapes with some areas traditionally characterized by an absence of fire becoming 

more susceptible to being burned by fires that spread from adjacent, more flammable, logged areas. 

Similarly, forest edges created by logging and by logging roads can become sites for fire incursions into 

adjacent forests. (D59 pp. 15-16)

Response: The area has a long history of harvest and fire suppression activities (see DEIS). Current stand 

conditions, including the juxtaposition of different kinds of forest stands, have been influenced by these 

past activities. Areas proposed for treatment are either dry sites or inclusions of cool moist sites in dry site 

landscapes, characterized by an absence of fire where fire would have been a frequent occurrence under 

historic conditions. Proposed treatments will re-introduce fire into these landscapes, reducing the expected 

fire intensities on these dry sites and reducing the potential for fire spread onto cool moist or cold dry sites 

that historically burned less frequently. Large, continuous areas represented by cold dry sites which would 

be expected to have less frequent occurrence of fire, are not proposed for treatment and overall exhibit a 

history of fire frequency that is within the range of what would have been expected historically (See FRCC 

analysis, DEIS Pg 124-127).

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#225. Industrial logging is likely to make some kinds of forests more, not less, prone to an increased 

probability of ignition and increased fire severity and/or fire frequency. Such places include...moist forests 

where natural fire regimes tend toward low frequency, stand replacing events. These altered fire regimes 

can, in turn, have significant negative effect s on a range of elements of forest biodiversity. (D59 p. 16)

Response: Large, continuous areas represented by cool moist and cold dry sites which would be expected 

to have less frequent occurrence of fire, are not proposed for treatment and overall exhibit a history of fire 

frequency that is within the range of what would have been expected historically (See FRCC analysis, 

DEIS page 124-127)

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#226. A better understanding of relationships between logging and wildfire will improve policy making and 

forest management. In moist forests there may be a case to create buffer areas adjacent to human 

settlements. In addition, there may be a strong case to exclude logging from those areas where past human 

disturbances (like timber harvesting) have been limited. This is because logging induced alternations in 
Appendix C Snow Basin Vegetation Management Project FEIS

603

landscape cover patterns can take prolonged period to reverse and hence associated changes in fire 

susceptibility also may be long lived. (D59 p. 16)

Response: See response to comment #224. 

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#227. Fuels reduction treatments are unwarranted in moist mixed conifer forests. (D59 p. 61)

Response: See response to comment #27. 

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#228. Snow Basin will increase fire risk by logging in moist mixed conifer forests. Scientific research has 

repeatedly concluded that thinning is not needed, effective, or ecologically beneficial in moist mixed-conifer 

forest to prevent fire, does not mimic the complex natural fire regime, and threatens to increase fire risk. 

Mature and old-growth moist mixed conifer stands have dense, moist interiors and little wind, which inhibit 

the spread of wildfire. (D59 p. 9)

Response: See response to comment #27 and #54. Prescriptions are designed to reduce the intensity of 

fire where it occurs but are not expected (or designed) to reduce fire occurrence.

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#229. I am writing to express my concern regarding the logging of old growth forests and old growth moist 

mixed conifer forests in eastern Oregon. The Forest Service’s plan to cut over 40,000 mature trees for fuel 

reduction is poorly considered policy. Fuel reduction measures are only justifiable when limited to low 

elevation dry forests. (D21 p. 1)

Response: Proposal to remove large trees is more specifically related to stand structure and species 

composition, not necessarily fuels reduction. In cases where grand fir is proposed for removal, reduction 

in proportion of species composition is designed to improve overall Fire Regime Condition Class Rating 

(see fuel FRCC discussion, DEIS pages 124-127), primarily where the lack of natural disturbance has 

enabled the spread of grand fir on dry sites. Relative to late-seral overstory vegetation; historic harvest and 

fire exclusion have resulted in an uncharacteristic distribution of large, overstory late-seral trees that if not 

removed will continue to support future propagation of high levels of fast growing, understory vegetation 

that will develop into ladder fuels, perpetuating the fuels issue that currently exists. Limiting historic 

disturbance events has resulted in the need for this treatment.

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#230. I have never read a scientific forestry paper or observed in my fieldwork where commercial forest 

harvest operations have caused as negative an impact as the wildfire that burned Dooley Mountain in July 

1989. The August 1994 fire in East Camp Creek, southeast of Unity, Oregon caused the same type of soil 

damage. The damage from the post-fire storms can still be seen in these creeks (King and East Camp 

Creek) today. (D37 p. 2) 

Response: Potential fire effects to soils and streams is discussed in the DEIS.

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#231. Previous soils damage is extensive and will be made more severe by Snow Basin. Due to all of the 

activities indicated in the DEIS on p. 141, soil compaction is the primary disturbance factor. DEIS 

statements on pages 152-153 underline the long-term widespread negative impacts in the project area 

resulting from previous logging/grazing/motorized use and the increased cumulative impacts that threaten 

even longer-term damage in the Snow Basin Proposal. These widespread long-term impacts are not well 

considered by the Forest Service’s approach of only raising a red flag concerning soil conditions once the 

20% detrimental soil condition is surpassed. The DEIS table 88 shows a consistent wide gap between 

existing and post-harvest detrimental soil conditions. This is widespread long-term soils and watershed 

degradation. There is an average 10% increase in detrimental soil conditions across the project area for 

Snow Basin. The effects of long-term widespread soil compaction on soil productivity, watershed function, 

and future forest health needs to be given a “hard-look” and the Snow Basin DEIS fails to do so. The 
Appendix C Snow Basin Vegetation Management Project FEIS

604

language of the DEIS clearly suggests that very real impacts that the soils are threatened with. Statements 

in the DEIS (p. 140, 143) indicate that the area is ecologically healing from the previous treatments. (D59 

pp. 63-65) 

Response: Forest Service policy that establishes the methodologies for assessing, monitoring and 

managing soil resources is given in FSM 2550, FSM R-6 Supplement No. 2500.98-1, and the Forest Plan. 

The process used for the Snow Basin DEIS follows this direction. Any disagreement or challenge to policy 

is beyond the scope of this project.

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#232. Industrial forestry practices harm natural forest soils. The less intensive the historical logging, the 

less damage done to the soils. Forests that were heavily logged, even decades ago, are still healing from this 

damage. Snow Basin has been logged for many decades. Science warns against exposing forest soils and 

hydrological ecosystems to extensive, widespread mechanical treatments. (D59 pp. 60-63) 

Response: The impacts to soils from use of ground based and cable logging systems have been 

recognized. This is why, in spite of not being considered a significant issue, the impacts were analyzed 

and weighed against Forest Plan Standards in DEIS in chapter 3. This analysis was improved and carried 

through into the FEIS. In the DEIS this analysis was included in the section containing Watershed 

(Section 3.3). In the FEIS it was separated out for clarity. 

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#233. The Snow Basin DEIS states that at least four of the project area soils naturally support moist mixed 

conifer forests. (DEIS p. 135). The approximate total % of treatment units that support moist forests is 

76%. However, these are very rough estimates as the percentages don’t add up (DEIS on p. 135 see Table 

76). Nonetheless it does illustrate that many soil types in the project area have good moisture holding 

capacity, a key factor of supporting moist forests as snow melt slowly recharges these soils through spring 

and early to late summer. (D59 p. 61) 

Response: The data presented in that table are misinterpreted by the commenter. That table was based on 

a Terrestrial Ecological Unit Inventory (TEUI) definition of "moist forest" instead of the Biophysical 

Environment definition used in the vegetation section of the EIS. The Snow Basin Vegetation 

Management Project area falls into 8 major Landtype Associations. Several of these are very common 

units on National Forest lands. For example, LTA 116 encompasses gentle mountain slopes and is the most 

abundant LTA in the Blue Mountains with over 800,000 acres. Many different vegetation types may occur 

on this LTA, but in general, on a landscape perspective, sites are occupied by Biophysical Environment 

"moist forest," although many sites are occupied by dry grand fir forest. Biophysical Environment "moist 

forest" is a classification that includes subalpine fir, moist grand fir and Engelmann spruce plant 

associations. The TEUI definition of "moist forest" includes in addition many sites that the Biophysical 

Environment definition classifies as "dry grand fir". For project scale work, we have more accurate 

information available in the form of stand exams, ecology inventory plots, and several modeled vegetation 

maps at various scales. While the LTA crosswalk implies that a large portion of the project area is covered 

by “moist forest”, our actual vegetation data do not support that conclusion. Refer to the Section on 

Forest Vegetation in the FEIS. In the FEIS that column was removed to avoid confusion caused by the 

two definitions.

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#234. Impacts of machinery are worse in moist soils. This is highlighted in the description on page 143 of 

the DEIS. All moist forest types should be dropped from the Snow Basin proposal. (D59 p. 65) 

Response: See Response to #233 on “moist forest types”. Timing of treatments and other mitigations can 

effectively deal with moist soils. Soil, even in moist forest types, dries out sufficiently that harvest and 

slash disposal activities during the normal operating season does not cause excessive detrimental soil 

conditions. This finding is supported by soil monitoring cited in the EIS. 

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Appendix C Snow Basin Vegetation Management Project FEIS

605

#235. The DEIS portends that the proposed treatments will protect the area resources such as soils from the 

negative impacts of “catastrophic” fire. (DEIS at 170, 154) These statements entirely place high severity fire 

in a negative light and suggest that soils need to be protected from severe burning. (D59 pp. 17-18)

Response: Even studies that have specifically focused on severely burned soils have shown that although 

the microorganism communities that make soil a fertile growing medium were greatly affected by severe 

burning, the red soil was not sterile. In severely burned soils, nutrients were limited enough to dampen the 

aggressive tendencies of nonnative plants. Some native species may be better adapted to regenerate in 

severely burned red soils because they are less dependent than nonnative, invasive plants on the flush of 

nutrients after a fire. Although burned soils in general promote growth of nonnative invasive plants, these 

species may be less competitive in severely burned sites where organic matter, soil nutrients, and microbes 

are reduced due to severe heating. It seems the patchiness of different burn severities may help enhance 

biodiversity across a postfire landscape. Nowhere does it state that proposed treatments will “protect” 

resources. It does state that Alternatives 2, 3 and 4 are likely to reduce impacts by “helping to prevent 

large catastrophic wildfires”. It’s an important distinction. Fuel treatments deal with risk management, not 

absolute outcomes. While there may be some instances where certain organisms benefit from high burn 

severity, the overall effects can typically be characterized as negative when considering the suite of 

ecosystem services that benefit from high soil productivity and function. The FEIS discloses that if a 

severe wildfire occurs, erosion would increase due to reduced ground cover and possibly due to 

hydrophobic soils. Soil may be lost in the smoke plume. Nutrients would be volatized. The purpose and 

need for this project does not seek to benefit a select organism or two at the expense of the greater 

ecosystem. Nor does the Forest Plan allow us to create biodiversity through a “scorched earth” 

management policy.

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#236. Compounding the soil impacts from road construction is over 4,500 acres of proposed grapple piling 

which has significant adverse effects on soil. It might be better to protect the soil and put more people to 

work by doing more hand piling. (D64A p. 24) 

Response: See response to #403. In addition to the monitoring results referred to in the response to #403, 

the mitigation measures in the watershed and soils section (WS-12) contain a requirement that Grapple 

piling utilize Low Ground Pressure machinery. Both the DEIS and FEIS disclose that the cumulative 

detrimental soil effects from grapple piling and other activities meet the Forest Plan standard for 

detrimental soil conditions. There is also an economic component as well, as hand piling can cost up to 3 

to 5 times what grapple piling costs. 

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#237. We appreciate the DEIS’s disclosure regarding recent publications that have provided information on 

appropriate levels of coarse wood required to protect long-term soil productivity (DEIS p. 157). However, 

we are unsure how the action alternatives address this information. We recommend the FEIS include a 

Project Design Feature/Best Management Practice/Mitigation Measure which addresses level of coarse 

wood required to protect long-term soil productivity (D67 p. 2) 

Response: While the function of Coarse Woody Debris (CWD) was recognized in the DEIS, no standard 

exists for CWD either in the W-W Forest Plan or Region 6 Soil Quality standards. The Eastside Screens 

which amended the Forest Plan does include a CWD standard, but that applies to wildlife. Any application 

to soils would be a side benefit. The science required in establishing a valid PDF/BMP/MM which 

addresses CWD for soils is beyond the scope of this project. PDF/BMP items WL-1 and WL-2 in the 

DEIS require retention of all snags unless a safety hazard and all existing down wood would be retained. 

In addition, coarse woody debris in this context is considered logging slash or fuels in another. The FEIS 

discloses that before fires were suppressed, little coarse woody debris existed because low severity fires 

burned it up. These high fire frequency ecosystems have persisted for thousands of years with low levels 

of coarse woody debris.

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Appendix C Snow Basin Vegetation Management Project FEIS

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#238. Please disclose where the Agee 1994 paper discloses information on appropriate levels of coarse wood 

required to protect long-term productivity, as I have searched the paper and cannot find any such 

information. Please also disclose these coarse wood figures from the other two papers (Harvey et al. 1994, 

Graham 1994) that the Snow Basin bibliography does not list. The EIS must clearly disclose the specific 

quantitative standards on coarse wood needed to protect long-term soil productivity from these papers, and 

compare these recommendations to the before and after effects for each alternative on coarse wood in the 

project area. (D59 pp. 62-63)

Response: Harvey et. al. 1994 and Graham 1994 are not in Bibliography. They will be added to the FEIS 

Bibliography. The Agee 1994 paper inclusion here in the DEIS appears to be a typographic error, and will 

be removed from the FEIS. For more information on soil methodologies and CWD, see responses to #237 

and #231.

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#239. Historical Range of Variability – Millar et al. (2007) states on the usage of historical baselines to guide 

current management: 

There is no doubt that historical data have immense value in improving our understanding of ecosystem 

processes to environmental changes and setting management goals (e.g. Swetman et al. 1999). However, 

many forest managers also use the range of historical ecosystem conditions as a management target, 

assuming that by restoring and maintaining historical conditions they are maximizing chances of 

maintaining ecosystem (their goods, services, amenity values, and biodiversity sustainably into the future. 

This approach is often taken even as ongoing climate changes push global and regional climates beyond the 

bounds of the last several centuries to millennia (Intergovernmental Panel on Climate Change, 2007). As 

importantly, novel anthropogenic stressors such as pollution, habitat fragmentation, land-use changes, 

invasive plants, animals, and pathogens, and altered fire regimes interact with climate change at local to 

global scales. The earth has entered an era of rapid environmental changes that has resulted in conditions 

without precedent in the past no matter how distantly we look. Attempts to maintain or restore past 

conditions require increasingly greater inputs of energy from managers and could create forests that are ill 

adapted to current conditions and more susceptible to undesirable changes. Accepting that the future will be 

different from both the past and the present forces us to manage forests in new ways. 

Mature and old forests are one example where historical baselines may not be particularly well suited for 

Snow Basin. Some stands may have more Grand fir and/or Douglas fir now than compared to historical 

conditions. However, because of the absence of mature and old forest in the overall project area due to 

historical logging, protecting these mature stands regardless of species could be very important for 

maintaining structural heterogeneity and providing habitat for wildlife right now. Another example where 

HRV may not be a good management target is for multi-storied mature forests. In an analysis of the upper 

Grande Ronde Basin, Wales (2007) states that “Because wildlife habitat of large-diameter trees takes a long 

time to develop, extra efforts to conserve existing large tree forests in the short term may be needed as 

continued loss may occur due to harvest on private lands, wildfire, and insect activity." 

Large wildfire activity is increasing across the western U.S. due to increased spring and summer 

temperatures and longer wildfire seasons (Westerling et al. 2006). The largest increases were found in midelevation forests in the Northern Rockies. This trend is expected to continue. Wales et al. (2007) cautions 

that active management approaches that reduce closed canopy forests could overshoot reductions in NRV 

levels.

"The NRV for this landscape apparently does not support high levels of closed-canopy medium and large 

tree forests. Management direction to maintain these habitats should take this into consideration; objectives 

may be established to manage for more of this forest type than could be easily sustained." 
Appendix C Snow Basin Vegetation Management Project FEIS

607

Contrary to the cautionary approach described by Wales et al. (2007), the Snow Basin preferred alternative 

employs every exception to the Eastside Screens in order to log old and large trees. (D59 p. 59-60)

Response: Reference FEIS Ch 1 Purpose and Need.

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#240. This project proposes to reduce multi-storied large-tree old growth (MSLT LOS) in cool/moist fir 

PAGs that are already below HRV. 

This project also reduces both multi-storied and single-storied LOS in warm/dry fir and warm/moist 

Douglas-fir and warm/dry Douglas-fir and ponderosa pine. We urge the FS not to trade one rare forest type 

for another. 

Please focus on treating non-LOS forests to restore rare single-storied LOS, while retaining multi-storied 

LOS to meet the continuing deficiency in this habitat type caused by past (and ongoing) logging. (D64A p. 

19)

Response: The alternatives do treat not LOS to restore LOS single story . Multi-story LOS is retained 

within HRV except for Cool / Moist which is currently below HRV. Management within multistoried 

stands is to restore historic species composition improving landscape resiliency. 

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#241. Old growth grand fir has a very important ecological role on the landscape and provides closed 

canopy forest habitat that is vital to many species. It is unacceptable for the Forest Service to degrade these 

critically important old growth forest moist environments. Another section of the DEIS describes these 

stands as follows: “The cool/moist grand fir stands selected for treatment are now nearly pure multi layered 

grand fir with a well developed big huckleberry shrub layer. Lack of a ponderosa pine or western larch 

seed source, dominance of the sites by the shade tolerant grand fir, vegetative competition from shrubs, and 

lack of exposed mineral soil sites for regeneration have changed these stands to or close to a climax (a pure 

grand fir) condition.” This sounds incredible! These forests are not in need of logging. (D59 pp. 13-14)

Response: See response to Comment #240. 

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#242. Old growth forests are not just incredible stores of carbon, key wildlife habitat, sensitive plant species 

refugia, biodiversity strongholds, etc., old growth forests are spiritual places for humans, they are ancient 

living beings, they are a defining and irreplaceable part of our natural heritage, they are very important for 

recreation and science, they bring mental peace and well being too many people, and our complex 

relationship with these forests might even represent the initiation of a modern form of traditional ecological 

knowledge. 

Certainly old growth forests give our region great cultural identity. Questions that arise from this cultural 

background could not even be considered by the Snow Basin’s approach of boiling this massive old growth 

logging proposal down to a 4-page letter from Linda Goodman. For example, if the average age of trees over 

21” that would be cut in the Snow Basin planning area is 200 years old, removing these 43,679 trees would 

remove 8,735,800 collective years of growth, productivity, photosynthesis, transpiration, habitat 

development, etc. What does it really mean to value such processes and understand the value to human 

society? If the Forest Service claims that 

Snow Basin considers climate change in its proposal, why doesn’t it consider the incredible carbon 

sequestration that has occurred in these large trees and protect them for climate mitigation impacts for our 

society? What tree has sequestered more carbon faster than grand fir in the past 100 years? (D59 p. 24)

#243. As trees greater than 21” dbh provide irreplaceable wildlife habitat, forest ecological structure, forest 

soil retention and nutrient replenishment in the long term, as well as scenic value, recreation value, cultural 

value and spiritual value, the public and the decision-maker should be fully and accurately informed as to 
Appendix C Snow Basin Vegetation Management Project FEIS

608

the value we stand to lose vs. the timber value gained by cutting these trees. It is wrong to log the old 

growth forests on Public Lands against the will of public. (D59 p. 21)

#244. There is perhaps no greater defining resource issue in the Pacific Northwest than management of old 

growth forests. Old growth forests are not just incredible stores of carbon, key wildlife habitat, sensitive 

plant species refugia, biodiversity strongholds, etc., old growth forests are spiritual places for humans, they 

are ancient living beings, they are a defining and irreplaceable part of our natural heritage, they are very 

important for recreation and science, they bring mental peace and well being too many people, and our 

complex relationship with these forests might even represent the initiation of a modern form of traditional 

ecological knowledge. 

Certainly old growth forests give our region great cultural identity. Questions that arise from this cultural 

background could not even be considered by the Snow Basin’s approach of boiling this massive old growth 

logging proposal down to a 4-page letter from Linda Goodman. For example, if the average age of trees over 

21” that would be cut in the Snow Basin planning area is 200 years old, removing these 43,679 trees would 

remove 8,735,800 collective years of growth, productivity, photosynthesis, transpiration, habitat 

development, etc. 

What does it really mean to value such processes and understand the value to human society? If the Forest 

Service claims that Snow Basin considers climate change in its proposal, why doesn’t it consider the 

incredible carbon sequestration that has occurred in these large trees and protect them for climate 

mitigation impacts for our society? What tree has sequestered more carbon faster than grand fir in the past 

100 years? (D59 p. 24)

Response: Refer to the Purpose and Need in the FEIS. Carbon sequestration and its relation to climate 

change are not covered in detail in the FEIS because of the scientific uncertainty of this issue. There are a 

number of different views on the topic and still no clear science as to the effect of forest thinning projects 

and carbon storage. Forest stands are being retained and thinned to maintain a vigorous forested condition 

that can contribute to support trees and sequester carbon long-term. Timber management projects can 

influence carbon dioxide sequestration in three main ways (1) – by increasing new forests (afforestation) 

(2) – by avoiding their damage or destruction (avoided deforestation) and (3) – by manipulating existing 

forest cover (managed Forest). Land-use changes, specifically deforestation and regrowth, are by far the 

biggest factors on a global scale in forests role as sources or sinks of carbon dioxide, respectively (IPCC, 

Intergovernmental Panel on Climate Change, 2000). Projects that create forest or improve forest 

conditions and capacity to grow trees are positive factors in carbon sequestration. The proposed action 

falls into this category.

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#245. The FS current approach to old-growth management is fixated on the number of acres classified as 

MSLT and SSLT and the need to increase SSLT. Snow Basin’s preferred approach would treat MSLT that 

is below HRV (DEIS p. 26). This approach threatens the same degradation to MSLT that has already 

occurred in SSLT. The WWNF has proposed numerous timber sale projects that call for commercial 

logging in MSLT old-growth stands to convert those stands to SSLT over the past several years. The agency 

points to the need to increase SSLT acreage in its documentation with no science to support that a functional 

change actually results due to the mechanical treatment, and despite a vast amount of science warning about 

furthering the spread of mechanical treatment into unlogged forests. 

The FS lacks any information regarding monitoring in previously converted areas. A basic tenet of 

ecological restoration is that they creation of form without function does not constitute ecological 

restoration. The rate of these conversion treatments has dramatically increased in recent years. Snow 

Basin, when added to past site-specific amendments, will affect over 5% of the WWNF’s remaining oldgrowth. The significance of this figure must be viewed in light of the fact that only 2% of the entire 2.3 

million-acre WWNF is representative of old-growth forest conditions. 
Appendix C Snow Basin Vegetation Management Project FEIS

609

The FS is not following the best-available science with regard to treating old-growth forest habitat. The 

literature urges a precautionary approach – remove only the smaller trees so that fire can be reintroduced. 

That is all that is needed to reduce competition for moisture and nutrients and reduce fire risk, both main 

goals put forth in the Snow Basin DEIS. 

Over time this treatment plan will move stands toward a more open canopy structure because subsequent 

under-burning will continue to remove the new regeneration (not that is should all be removed), and natural 

competition combined with disturbance agents will result in canopy mortality. Instead the FS insists on 

aggressive treatments that risk invasive weed spread, soil disturbance, increased fire risk, drier conditions, 

and loss of overall carbon storage; all so the amount of SSLT will be increased on paper. It seems that the 

FS does not have the patience to treat these stands appropriately and is trying to do too much too fast. 

There is no ecological justification for the proposed treatments in moist forest period. (D59 pp. 27-28)

Response: See response to Comment #246. Reference DEIS Pg. 101 Late and Old Structure Forest 

(LOS) - Landscape Assessment. See response to #250 for discussion of best available science. For 

monitoring requirements see Appendix B.

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#246. HCPC has actively engaged with the Forest Service on numerous occasions regarding the agency’s 

frequent waivers of old-growth protections. We have repeatedly expressed that our organization generally 

supports restoration efforts aimed at increasing the development of old-growth single-story structure by 

thinning stands in the stem exclusion closed canopy and understory reinitiation structural stages, but we 

want old growth forests protected. (D59 pp. 27-28)

Response: See DEIS Effects Analysis for No Action Alternative We assume “Protected” means no 

treatment. Snow Basin argues that managing Late and Old stands would improve their ability to resist 

uncharacteristic disturbance. 

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#247. When it comes to old-growth, our concerns pertain directly to the Forest Service’s decision to 

repeatedly allow commercial logging within, and the removal of intermediate and mature trees from, these 

old growth stands. Both the law and the best available science demonstrate that commercial logging in our 

last few remaining old-growth stands is unacceptable. (D59 pp. 27)

Response: See Chapter 3 of the FEIS for the objectives for managing LOS. Also, See comment #246.

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#248. The EIS Failed to Thoroughly Discuss the Scientific Uncertainties Associated with Logging in LOS 

Stands to Convert Multi-Storied Old Growth Forest to Single Storied Stands. The DEIS states on page 102 

“Under the Proposed Action of the Snow Basin project approximately 1,500 acres of LOS forest would be 

treated. Most of these treatments would be to move MSLT forest to SSLT structural stage by removing the 

mid to lower canopy layers, thus creating a mostly single story canopy.”

Our organizations have commented on numerous projects that reflect the Forest Service’s recent policy 

trend to log in Eastern Oregon’s old growth stands based on the purported need to convert multistory old 

growth to single-story old growth. The DEIS fails to sufficiently acknowledge and adequately discuss the 

high level of uncertainty with respect to the long-term ecological consequences of this management 

prescription for LOS stands, particularly given that most areas are also deficient in multistory old growth 

(as seen with many recent projects calling for amendments to the Eastside Screens to “treat” these areas) or 

are just barely within the HRV. This discussion is essential in order for the Forest Service to demonstrate 

that it took the requisite “hard look” at the environmental consequences of its proposed action under NEPA. 

The Ninth Circuit has held that the Forest Service’s failure to disclose the scientific uncertainty of its 

decisions to “treat” old growth forest violated NEPA. Ecology Ctr., Inc. v. Austin, 430 F.3d 1057, 1065 (9th 

Cir. 2005); Lands Council v. McNair, 2007 U.S. App. LEXIS 15749, *13 (9th Cir. July 7, 2007). In Ecology 

Center, the Forest Service sought to “correct uncharacteristic forest development resulting from years of 
Appendix C Snow Basin Vegetation Management Project FEIS

610

fire suppression.” Id. at 1063. This “treatment” was “designed to leave most of the desirable old-growth 

trees in place and to improve their health.” Id. 

Although treatment may be designed to restore old-growth to ‘historic conditions,’ . . . this can be a 

misleading concept: for example, information regarding historic conditions is incomplete; altering 

particular sections of forest in order to achieve "historic" conditions may not make sense when the forest as 

a whole has already been fundamentally changed; many variables can affect treatment outcomes; and the 

treatment process is qualitatively different from the ‘natural’ or ‘historic’ processes it is intended to mimic.

Id. (citing Plaintiffs’ arguments). The Ninth Circuit concluded that the Forest Service violated NEPA 

because it “treat[ed] the prediction that treatment will benefit old-growth dependent species as a fact 

instead of an untested and debated hypothesis” and it failed to “’address in any meaningful way the various 

uncertainties surrounding the scientific evidence’ upon which the decision to treat the old-growth rests.” Id. 

at 1065. Although, the Ninth Circuit recently overruled Ecology Center, to the extent it suggested that the 

Forest Service always violates NEPA every time it fails to address some scientific uncertainty in its analysis, 

it reaffirmed that the agency must at least acknowledge and respond to comments by outside parties that 

reasonably state such uncertainties exist. Lands Council v. McNair, 537 F.3d 981, 1001 (9th Cir. 2008). (D59 

p. 32)

Response: Resilience and species composition of forest stands dictates need to treat LOS. Resulting 

stand conditions will address long term sustainability of LOS. Multi-story LOS is currently within the 

HRV for all biophysical environments in the HRV analysis area. It would remain within HRV under all 

action alternatives. The effects to LOS are discussed in Chapter 3 Section 3.1 of the FEIS. Reference 

Appendix B.

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#249. We may or may not doubt the severe deficiency in single-storey old growth or the proposition that 

stands that were historically single-story may have shifted to more multi-storied conditions due to past 

management and fire suppression. Regardless, what is unconvincing remains whether logging in LOS 

stands that in this area are within or below HRV in order to convert multi-stored old growth forest to 

single-story stands is the appropriate solution, particularly when both forest types are rare at the landscape 

scale, fulfill distinct ecological roles and create distinct wildlife habitat. Further, given the agency’s clear 

misrepresentation of site specific HRV conditions of most of the project area, where these are instead multistrata mixed conifer and including moist mixed conifer, rather than single strata, such conclusions are 

highly suspect as to their veracity. 

Regardless of this, the FS should work within the vast reservoir of dry forest type in the stand initiation 

phase in order to increase development of single-story old growth and stop this “robbing Peter to pay Paul” 

approach to old growth management. The FS has been taking this management approach on a piecemeal, 

project-by-project basis, and this admittedly gives rise to significant uncertainties in terms of broad-scale, 

long-term ecological consequences. The NEPA process is intended to ensure “that important environmental 

consequences will not be overlooked or underestimated only to be discovered after resources have been 

committed or the die otherwise cast.” North Buckhead Civic Ass’n v Skinner, 903 F.2d 1533, 1539-40 (11th 

Cir. 1990). (D59 pp. 32-33)

Response: The surplus structural stage in the project area is in understory initiation. The alternatives 

would develop single story LOS from this stage. Refer to HRV discussion in Ch 3. Section 3.1 Vegetation 

in the FEIS. Refer to Table for acres of structural stages in the HRV analysis.

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#250. The National Forest Management Act’s (NFMA) implementing regulations require the consideration 

of the “best available science” for all site-specific projects. 36 C.F.R. § 219.11 (2008); 36 C.F.R. § 

219.35(d)(2000). Under the applicable NFMA regulations, this requires documenting “how the best available 

science was taken into account in the planning process within the context of the issues being considered;” 

and “that the science was appropriately interpreted and applied.” 36 C.F.R. § 219.11(a). 
Appendix C Snow Basin Vegetation Management Project FEIS

611

The DEIS fails to impartially identify what the “best available science” is or entails, with respect to the 

Forest Service’s decision to log multi-story old growth stands, which are within or below the HRV threshold 

for that forest type, in order to convert those stands to another more deficient forest type, and does not 

objectively present scientific research including contending research. Rather the Snow Basin proposal 

largely ignores the vast body of literature on old growth forests and justifies this extreme large tree logging 

proposal on the 2003 Goodman letter. 

The EIS must demonstrate how the “best available science” standard was objectively considered with 

regards to this proposal. Numerous courts, including the Ninth Circuit have held Forest Service decisions to 

be arbitrary and capricious where there was insufficient evidence in the record that objectively explained 

what “best available science” entails or how it was considered comparative to contending science in 

developing aspects of the challenged timber sales. Bark, 2007 U.S. Dist. LEXIS 21272 at *19-20; Forest 

Watch v. U.S. Forest Serv., 410 F.3d 115, 117 (2nd Cir. 2005); Ecology Ctr., Inc. v. U.S. Forest Serv., 451 

F.3d 1153, 1191, 1195 (10th Cir. 2006). (D59 p. 31)

Response: There is a significant body of up-to-date scientific literature cited in the FEIS and Forest 

Vegetation report that supports the purpose and need premise of the Snow Basin project. Specifically, 

moving forest structure, density, and composition towards the historical range of variability (HRV) to 

improve forest health and vigor is a scientifically supported concept, as evidenced by numerous citations 

within the FEIS. In formulating the analysis for the Snow Basin Forest Vegetation report, the Best 

Available Science was used. Multiple journals, textbooks, reports, and other sources were consulted to 

help inform the analysis and develop the alternatives. 

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#251. The argument put forth that fire suppression has increased multi-story old forest conditions beyond 

the historic range of variability is not supported by the data. Figure 3 illustrates that OFMS is right where it 

should be compared with historic conditions. It is imperative that the Forest Service does not take this for 

granted. Climate change threatens to reduce multi-story closed canopy forests more than any other forest 

type and when combined with logging projects, closed canopy forests could rapidly be reduced below the 

Natural Range of Variability (NRV) (Wales et al. 2007, report attached). Wales et al. (2007) cautions that 

active management approaches that reduce closed canopy forests could overshoot reductions in NRV levels. 

"The NRV for this landscape apparently does not support high levels of closed-canopy medium and large tree 

forests. Management direction to maintain these habitats should take this into consideration; objectives may be 

established to manage for more of this forest type than could be easily sustained." (D59 pp. 30)

Response: There is wide scientific research documenting the effects to forest stands from the exclusion of 

fire. Approximately 50% of the Snow Basin forested landscape would not be treated using harvest. 

Reference FEIS Appendix B-14 for acres untreated within the analysis area. Multistory LOS is and would 

remain within HRV with the implementation of any action alternative. See Chapter 3 of the FEIS. The 

cited study, Wales et al. (2007), reaches the following conclusions; 

“In such a system, late-successional and old forest elements would be continuously recruited, but would 

shift semi-predictably in landscape position across space and time.” 

We believe that the proposed Snow Basin activities would tend stands towards an LOS condition 

across the landscape. 

“Although we analyzed broad-scale changes in forest composition and structure, fine-scale habitat 

features also need to be considered to ensure high-quality, large-diameter trees as wildlife habitat through 

time.” 

We believe that the proposed Snow Basin activities would tend stands towards larger size by 

reducing density and increasing diameter growth rates across the landscape. 
Appendix C Snow Basin Vegetation Management Project FEIS

612

“Attention should be given to protecting existing large-diameter and old trees (especially fire resistant 

species) because they are difficult to replace” 

We believe that the proposed Snow Basin activities would protect the existing large diameter fire 

ponderosa pine and western larch across the landscape. 

“In addition, the long-term abundance and replacement of large snags and down logs should be 

considered in light of fall down and decomposition rates throughout the landscape “ 

We believe that the proposed Snow Basin activities would increase the amount of large trees 

across the landscape and by doing so would provide source of large snags and down logs.

“Prescribed fire can kill large trees that are intended to be retained and benefit from treatment (Agee, 

2003), so it may be necessary to remove slash and fuels surrounding individual trees or logs to protect 

them”.

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#252. Additionally “Old Forest Open Canopy” is within HRV for the moist potential vegetation group 

(Figure 4) and “Old Forest Closed Canopy” is within HRV for the dry potential vegetation group and at or 

below HRV for the moist potential vegetation group (Figure 5). These graphs indicate that the Forest 

Service should refrain from conversion of multi-story old growth to single-story old growth, and should 

leave all Old Forest’s in moist potential vegetation groups untreated, because these old growth forest types 

are only within the range of natural variability, not above. These conversions are not supported by the data 

shown here or the science and threaten to land OFMS and dependent wildlife species in the same condition 

as OFSS and dependent wildlife species. Applying highly experimental treatments to a forest structure that 

is already relatively rare and is serving a critical ecological role is unacceptable. (D59 pp. 30-31)

Response: The treatments in Cool / Moist stands address species composition. Species composition has 

changed from the historical condition going from mixed species to predominately grand fir. The treatments 

would protect the remaining ponderosa pine and western larch and begin to restore a mixed species 

composition. 

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#253. Where natural conditions plainly evidence higher densities and greater structural stand complexity 

than formulas may recommend, it is not the forests that are to be re-made to fit contrived human formulas, 

but rather the formulas themselves that must be revised to better match natural forest conditions, ecological 

patterns, and structural complexity. Instead, the Forest Service is failing to recognize what the ecosystem is 

plainly demonstrating; that century old trees can co-exist in denser patterns than the combination of 

biophysical environment, stand density index, and upper management zone information suggest. In these 

stands the Forest Service is removing the most fire-resistant, early seral species while paying lip service to 

protecting “old growth forests” (see Sugar Appeal Appendix attached). 

These treatments are removing what would eventually become high quality snags and large downed logs in 

an already snag deprived landscape and favoring commercial characteristics such as crown ratios at the 

expense of verified old growth characteristics. Removal of large trees is exposing the soil to increased solar 

radiation thereby drying out the stands, spreading weeds, and setting the forest back centuries when it 

comes to the recovery of these old growth stands. Nowhere does the peer-reviewed science state that mature 

century and older ponderosa pine and Douglas-fir trees should be cut down in the name of restoration. 

(D59 p. 22)
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613

Response: HRV analysis was done in accordance with Eastside Screens requirements. Removal of large 

trees is based on removal scenarios and not for density management . Reference DEIS Ch. 3 Section 3.1. 

Removal Scenarios in Regional Forest Letter 2003(Pg. 62). 

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#254. You must highlight the fact that the net loss of LOS is negligible over the treated acres. You should 

also quantify the amount of LOS within the 26,493 acres of NFS land within the project area that you are 

not treating. (D50 p. 2)

Response: Reference Ch 3. Section 3.1 Vegetation of the FEIS

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#255. Discrepancies with Snow Basin’s LOS data. The DEIS states at 101: “Due to potential connectivity of 

LOS habitat the area of consideration for this assessment is the eastern portion of the La Grande Ranger 

District abutting the Eagle Cap Wilderness and the old Pine Ranger District, a land base of a little over 

300,000 acres.” The EIS states at 101: “The results, displayed in DEIS Appendix B-14, Table 1: MSLT and 

SSLT Stand Acres, show that there are about 56,150 acres of LOS within this area. These results are 

comparable to those found during the Blue Mountain Forest Plan Revision process, which identified LOS 

occupying about 20% of the forested area across the Wallowa-Whitman NF.” 

HCPC is questioning the Snow Basin LOS numbers. In the Revised Sugar EA (La Grande Ranger District), 

the Forest Service stated there are 46,709 acres of LOS forestwide. See our Sugar Appeal, footnote 3: 3 See

Response to HCPC Comments on Sugar Project EA, February 6, 2009. Compare also to Revised Sugar EA, 

p. 162. In the Snow Basin analysis of LOS the Forest Service did not include the Eagle Cap Wilderness or 

the HCNRA, likely areas where a disproportionate amount of old growth exists. It would seem unreasonable 

that after ruling out these areas the proportion of LOS in the more heavily logged area would be the same as 

the Blue Mountain Forest Plan Revision analysis that included all Wilderness areas. We request 

clarification of this issue. (D59 pp. 28-29)

Response: The Snow Basin analysis is based upon the most current vegetation data. The vast majority of 

this data is field based. Much of the Eagle Cap Wilderness and HCNRA vegetation data is interpreted from 

aerial photos. Reference DEIS Pg. 101 Late and Old Structure Forest (LOS) - Landscape Assessment. 

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#256. The DEIS says that “The net loss of LOS under Alternative 2 would be short-term. The treatments 

would reduce the number of 21+ trees temporarily until remaining trees grow into large size. ... All species 

of trees will release and increase radial growth after thinning as more site resources become available to 

fewer trees.” (DEIS p 94). This statement conflates complex LOS with a simple stand of large trees. LOS is 

in fact a much more complicated ecosystem with numerous snags, accumulations of dead wood, diverse 

understory vegetation, and trees of all sizes. Commercial logging will adversely affect many of these LOS 

features. Some will bounce back relatively quickly, but snags and dead wood will be adversely affected for a 

very long time. This is why it is so important to mitigate for the adverse effects of commercial logging by 

retaining higher basal area in treated areas as well as generous untreated skips — where LOS features that 

are NOT enhanced by logging can flourish and add to the success of the overall restoration effort. (D64A p. 

15) 

Response: Old growth definitions used for this project come from the Region 6 Interim Old Growth 

Definitions June 1993 which discusses the numbers of large trees, structural diversity and dead wood 

components by vegetative series. Reference FEIS Ch. 3 Wildlife for snags and dead wood retention and 

effects to wildlife. 

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#257. Old growth is defined in the Interior Columbia Basin Ecosystem Management Project (ICBEMP) as:

1. Large trees for species and site.

2. Wide variation in tree sizes and spacing.

3. Accumulations of large-size dead standing and fallen trees that are high
Appendix C Snow Basin Vegetation Management Project FEIS

614

relative to earlier stages.

4. Decadence in the form of broken or deformed tops or bole and root decay.

5. Multiple canopy layers.

6. Canopy gaps and understory patchiness.

http://www.icbemp.gov/pdfs/sdeis/Volume2/Appendix17a.pdf (D64A p. 17). 

Response: The Region Six Old Growth Definitions provide a basic definition of old growth. The 

ICBEMP definition is a general visual description of what old growth should or did look like. The Snow 

Basin activities would set the stage for a return towards these conditions. 

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#258. It appears that there will be a considerable reduction in old growth as well as much needed fire 

suppression. I am well aware of the need to thin stands and reduce accumulated fuel. I do question whether 

this has to include larger trees, which are in short supply for wildlife in eastern Oregon due to a century of 

harvest, and if thinning needs to extend into moister higher elevation parts of the forest. (D26 p. 1)

Response: Removal scenarios are identified in the DEIS Ch. 3 Section 3.1 Forest Vegetation. Reference 

FEIS Ch. 3 Section 3.2 for descriptions of fuels treatments.

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#259. Good aspen prescriptions, supportive of taking ALL conifers out of aspen stands (D35 p. 1)

Response: Reference DEIS Ch. 2 Description of Alternatives. 

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#260. Aspen protection: These stands must be fenced and all stands should be fenced and burned prior to 

any proposal of logging trees greater than 21” dbh. (D59 p. 97)

Response: See response to Comment #261. Burning has proved to be unnecessary to restore aspen stands 

in the local area. However, it is assumed that these aspen sites will be burned in the future as part of a 

larger prescribed fire. 

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#261. If the Forest Service is serious about restoring aspen stands, removal of cows from the forest 

allotments will have a much more beneficial impact than “removing shade trees” will. Twenty-eight years 

of personal observation of aspen stands on our land is ample evidence of the benefits of removing cattle from 

those stands. As for aspen regeneration, the grazing and stomping of cattle is what has killed the aspen, not 

the shade of old growth trees. Control the cattle and leave the giants alone. (D22 p. 2, D76 p. 2)

Response: Cattle would be effectively excluded from the aspen restoration units by fencing. Aspen is the 

most shade intolerant tree in the Blue Mountains. The effect of conifer competition is well documented in 

the literature and local district experience. Immature large diameter trees are providing a portion of this 

competition. Some old large conifers would be retained for structural and species diversity that won’t 

interfere with aspen regeneration. See Chapter 2 of the FEIS for the proposed aspen restoration 

prescriptions. 

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#262. The Forest Service Must Assess the Cumulative Impacts of Amending the Eastside Screens on a 

Forest-Wide Level. The Forest Service needs to consider the Snow Basin proposal in the cumulative effects 

of multiple past decisions, when combined with present and reasonably foreseeable future decisions to 

amend the Wallowa Whitman LRMP (Forest Plan) by removing the Eastside Screens’ old-growth 

protections. Moreover, the Umatilla National Forest, directly adjacent to the WWNF, currently proposes 

logging trees over 21 inches DBH in the Wildcat Fuels Reduction Project, in the Mirage Fuels reduction 

project, in the Cobbler II project, and in the Tollgate WUI project.

NEPA “always requires that an environmental analysis for a single project consider the cumulative
Appendix C Snow Basin Vegetation Management Project FEIS

615

impacts of that project together with ‘past, present and reasonably foreseeable future actions.’” Northwest 

Ecosystems Council v. Dombeck, 304 F.3d at 895 (citing 40 C.F.R. §§ 1508.7, 1508.25, 1508.27(b)(7) (2001); 

Hall v. Norton, 266 F.3d 969, 978 (9th Cir. 2001); Kern v. United States Bureau of Land Management, 284 

F.3d 1062, 1075-76 (9th Cir. 2002)) Cumulative impacts are defined as the impact on the environment which 

results from the incremental impact of the action when added to other past, present, and reasonably 

foreseeable future actions. 40 C.F.R. § 1508.7. “CEQ regulations specifically admonish that cumulative 

impacts ‘can result from individually minor but collectively significant actions taking place over time.’” Id.

The importance of ensuring that EAs consider the additive effect of many incremental environmental 

encroachments is clear. “[I]n a typical year, 45,000 EAs are prepared compared to 450 EISs . . . . Given 

that so many more EAs are prepared than EISs, adequate consideration of cumulative effects requires 

that EAs address them fully.” Kern, 284 F.3d at 1076 (emphasis in original) (quoting Council on 

Environmental Quality, Considering Cumulative Effects Under the National Environmental Policy Act 

at 4, January 1997). As we have previously emphasized when considering the sufficiency of a timber sale 

EA, without a consideration of individually minor but cumulatively significant effects “it would be easy 

to underestimate the cumulative impacts of the timber sales . . ., and of other reasonably foreseeable 

future actions, on the [environment].” (D59 p. 40)

Response: Reference DEIS Pg. 101 Late and Old Structure Forest (LOS) - Landscape Assessment. 

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#263. I was one of the original appellants on the Eagle Creek-Paddy Timber sale in the early 1990’s. The 

big concern at that time was the huge timber sales, especially those that contained large trees being 

administered by the Forest Service. Estimates at that time were that 97% to 98% of the large old growth 

trees had already been harvested. It was in the monetary interests of the Forest Service to provide timber 

sales with higher value timber, as that is where the Forest Service obtains some of its income. The demand 

for Old Growth is what is what eventually brought on the “Screens” that stopped harvesting of trees over 21 

inches. My appeal on the Eagle Creek-Paddy sale was based on the findings of the Eastside Forest Scientific 

Society Panel, a copy of which I included in my appeal. These findings recommended cutting no trees larger 

than 20 inches in diameter until such time as a new Forest Plan was adopted. That has not happened yet! 

(D22 p. 1)

Response: The Regional forester has since allowed for the analysis of the removal of large trees for the 

ecological situations detailed in the letter. This letter was issued after Forest Plan Amendment 2 (Screens) 

and recognized the ecological need to analyze the removal of large trees under certain conditions. There is 

no reference for the 97-98% of the large old growth trees previously harvested. Certainly a large number 

of large trees were harvested since settlement. A large number of trees have grown into large size. 

Reference tree age/dbh data for Snow Basin. 

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#264. Numerous site-specific amendments to the Eastside Screens will also have a compounding effect in 

that multiple sales have resulted, and will result, in potentially significant tree removal that is otherwise 

prohibited by the Eastside Screens. The Forest Service has yet to address what this compounding effect 

means to the ability of the old-growth resource to maintain itself within the WWNF, and the viability of oldgrowth dependent species. In turn, the potential for a “compounding effect” from the continued loss and 

manipulation of the remaining old-growth stands gives rise to the potential for the old-growth resource, and 

especially for the OFMS forest type, to reach a “threshold” (characterized by the “fundamental changes” to 

the forest “structure”) where it can no longer sustain itself on the forest. (D59 pp. 44)

Response: A Landscape Assessment of LOS is located in the DEIS on pages 101 and 102. The 

assessment analyzed LOS on 300,000 acres in which Snow Basin resides.

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#265. The project proposes a significant plan amendment to allow removal of large numbers of ecologically 

valuable large trees in violation of the Eastside Screens. An average of 3.5 large trees per acre are estimated 
Appendix C Snow Basin Vegetation Management Project FEIS

616

to be removed across virtually all 12,000+ acres of commercially treated forest in the project area, or 43,000 

large trees that would fill 2,000 log trucks, that would stretch more than 20 miles if parked end to end. 

(D64A, pp 10-11)

Response: There is a forest plan amendment process. Alternatives 2 and 3 propose forest plan 

amendments. See Chapter 1- Purpose and Need of the FEIS.

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#266. The Eastside Screens called for retention of all large trees for very important ecological reasons that 

remain valid to this day. The flexibility to remove large trees (contemplated by the Regional Forester and 

the Wyden legislation) should be reserved for situations where there are abundant large trees that need to be 

protected from competition with smaller shade-tolerant trees that happen to be >21” dbh. This is not the 

case in the Snow Basin Project Area. (D64A, p. 11)

Response: The Regional Forester’s letter of 2003 “allows” the consideration of the removal of live trees 

greater than or equal to 21 inches d.b.h. under ecological scenarios. See DEIS Chapter 3 – Section 3.1 

Forest Vegetation Pg. 92. Alternative 4 in the FEIS does not harvest any trees >21" dbh. 

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#267. To bring Snow Basin more in line with proposed Wyden Legislation, the Purpose and Need and/or 

objectives should reflect goals of “forest health” and “watershed health” as defined in the Act (D64A p. 8) 

(5) FOREST HEALTH. – The term “forest health” means conditions that enable forested land –

(A) to be durable, resilient, and less prince to uncharacteristic wildfire, insect, or pathogen 

outbreaks, while –

(i) supporting ecosystem services and populations of native species; and 

(ii) allowing for natural disturbances;

(B) to maintain or develop species composition, ecosystem function and structure, hydrologic 

function, and sediment regimes that are within a acceptable range that considers –

(i) historic variability; and

(ii) anticipated future conditions; and

(C) to be resistant and resilient to uncharacteristic events. 

(15) WATERSHED HEALTH. – The term “watershed health” means landscape conditions that 

enable riparian and aquatic ecosystems –

(A) to capture, store, and release water, sediment, wood, and nutrients;

(B) to provide for water temperatures that are within the range of variability of the natural regimes 

for the the processes described in sub-paragraph (A); and

(C) to create and sustain functional riparian, aquatic, and wetland habitats that are capable of 

supporting diverse populations of native aquatic- and riparian-dependent species. 

Response: The Snow Basin purpose and need reflect the “Forest Health” definition given. There are 

Project Design Criteria, Best Management Practices, and Mitigations in Appendix B that are designed to 

maintain or enhance watershed health in the project area. 

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#268. A compelling ecological need that is clearly identifiable and warrants the proposed action is needed. 

Returning stands to the HRV should not be used as a justification for landscape-scale commercial thinning. 

This would clearly be counterproductive to true restoration. (D59 p. 1)

Response: The need for the project is represented by the difference, or ‘gap’, between the area’s existing 

condition and the desired condition, which is derived from direction contained in the amended WallowaWhitman Forest Land and Resource Management Plan (FEIS Chapter 1). 

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Appendix C Snow Basin Vegetation Management Project FEIS

617

#269. Purpose and Need Summary: “Restore and maintain resilient and sustainable-forested ecosystems, 

specifically by creating open grown ponderosa pine, larch and Douglas-fir stands dominated by the largest 

trees growing on the site” (DEIS at 2). 

Response: This purpose and need is inappropriate for every acre outside the dry ponderosa pine and pine 

intermixed with Douglas-fir plant association group forests. (D59 p. 3)

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#270. Purpose and Need is inherently limited to the warm/dry forests and threatens widespread 

degradation to moist forest types. The Purpose and Need states (DEIS at 2): 

“This project is needed to help restore a full complement of vegetative patterns within the natural range of 

variability across the landscape. These vegetative patterns will be described in terms of the major forest 

elements: 1) structural stages (vertical and horizontal arrangement), 2) vegetation type (relative 

composition of different tree species), and 3) tree sizes (large diameter vs. small diameter trees). 

Specifically, the purpose of the project is to restore more natural and sustainable forest structure, 

composition and densities based on the fire ecology of low and mid elevation warm dry forests. The project 

would have other resource benefits including the reduction of wildfire risk in urban interfaces and restoring 

important wildlife habitat.” 

Here the Purpose and Need professes that the specific purpose of the project is to restore a forest structure, 

composition, and density based on the fire ecology of low and mid elevation warm dry forests. Therefore, if 

the project area includes forest types that are outside of the low and mid elevation warm dry forest type, 

these forests are being subjected to a management approach that does not mimic the characteristic natural 

disturbance regime. It is scientifically well documented that active forest restoration treatments must be 

consistent with the natural disturbance regime of a forested landscape (Brown et al. 294; Noss et al. 2006; 

Crist et al. 2009) or significant degradation of the forest, such as loss of resiliency and biodiversity, 

homogenization of forest structure, reduced canopy cover and increased fire risk, increased risk of insect 

epidemics, degraded wildlife value, and degraded soil and watershed values can occur (Rieman and Clayton 

1997; Lindenmayer et al. 2009). (D59 pp. 3-4) 

#271. The Purpose and Need continues (DEIS at 2): “Historically, fires in the Snow Basin Project Area 

maintained natural live and dead fuels at low levels and killed most of the smaller tree seedlings, which had 

seeded into the area. The large thick-barked mature ponderosa pine, larch and Douglas-fir within the area 

survived these low intensity fires. This differentiation in tree survival caused by frequent low intensity fires 

led to the development of a “savannah” or a widely spaced forest or large old trees. Since the advent of fire 

suppression, tree seedlings have survived at rates which have led to the development of densely stocked 

multi-layered forest. Very little understory (forbs, grasses, shrubs) can survive under this dense forest 

canopy. When these types of forest stand burn in a wildfire situation, fire spreads vertically (gets into the 

crowns of the trees) through the forest canopy due to these ‘ladder fuels”. Douglas-fir, larch nor ponderosa 

pine typically survives crown fire events, and a substantial portion of the mature trees die. Although the 

forest eventually grows back, it may take several centuries to re-establish a mature or old growth forest.”

This is an inaccurate portrayal of the historical fire regime within the project area, it reduces natural 

complexity, and opens the door for overly homogenous treatment, and is not supported by the biophysical 

environments and plant association groups in the project area. Even for the ponderosa pine-Douglas-fir 

forests, the description above is heavily dependent upon the southwestern U.S. model and fails to recognize 

the more modern view of the low-severity model in the topographically complex regions of the interior 

western U.S. (Baker et al. 2007). The DEIS at 42 describes the project area vegetation as follows: “The 

project area vegetation is characterized by a mixture of forest and natural openings of various sizes. The 

forested stands range from high elevation subalpine fir/lodgepole pine to low elevation pure ponderosa 

pine.” It is a fact that the subalpine fir/lodgepole pine high elevation forest is characterized by stand 

replacement fire regime. It is also a fact that moist mixed conifer stands that compose the ecological 

transition between the high elevation cold forest types and the low elevation dry forest types are 
Appendix C Snow Basin Vegetation Management Project FEIS

618

characterized by a variable intensity fire regime. Moreover, it is well documented that even in the dry forest 

types, fire regimes had much more variability than your description acknowledges, including high severity 

fire that needs to be recognized and areas of dense regeneration. And lastly, it is well documented that the 

dominant fire regime of the inland Pacific Northwest is the mixed severity fire regime. (D59 p. 5)

#272. The project needs to be scaled back to the warm dry forest type. The Forest Service is focused on a 

“savannah of widely spaced old trees” maintained by low intensity fire regime which is uncharacteristic for 

mixed-severity fire regimes and therefore ecologically inappropriate for all parts of the project area 

characterized as such. The Purpose and Need is not suitable for portions of the project area characterized 

by a highly variable mixed fire regime. (D59 pp. 5)

#273. The DEIS states at 2 that “This project is needed to help restore a full complement of vegetative 

patterns within the natural range of variability across the landscape.” It follows that all forests that are 

within the natural range of variability should not be treated. However, this project extends well into the 

mixed conifer forest types including those characterized as “moist” where the fire regime is mixed-severity, 

and multi-layer canopy conditions are natural. All of these areas should be dropped because they are within 

the range of natural variability and therefore outside the scope of the Purpose and Need of the project. (D59 

p. 6)

#274. The DEIS’s purpose and need, “to help restore a full complement of vegetative patterns within the 

natural range of variability across the landscape” cannot be met with the proposed management actions and

threatens to remove the landscape further from the range of natural variability in numerous ways. As 

extensively discussed, Snow Basin should be limited to dry forest types only. The proposed actions in the 

moist forest types run counter to best available science and the stated goals and objectives of the project. 

(D59 p. 6, 20-22)

#275. The Purpose and Need and desired future conditions for Snow Basin are clearly oversimplistic, even 

for dry forest types. The DEIS states at 2 in reference to the entire Snow Basin Project area: “This 

differentiation in tree survival caused by frequent low intensity fires led to the development of a “savannah” 

or a widely spaced forest of large old trees.” Science shows little evidence for the widespread existence of

open park-like or savanna conditions in the interior Pacific Northwest (Hessburg et al. 2007) demonstrating 

the critical importance of constraining fuels reduction treatments to the right biophysical environment. 

Here is an excerpt from a leading fire ecology scientist in forests of western North America, Baker et al. 

2007: 

“Under the variable-severity model, the proportions of the historical landscape that contained patches of 

different age and tree density would have varied substantially over time due to relatively long periods with 

minimal fire occurrence followed by episodes of widespread and severe burning at landscape scales (Brown 

et al. 1999; Veblen et al. 2000). This is an important contrast with the low-severity model in which low 

severity fires are believed to have occurred often enough to maintain a relatively uniform uneven-aged, oldgrowth landscape (Covington & Moore 1994). For the variable-severity fire regime, more research is 

needed to characterize historical spatial variability in the proportions and configurations of particular 

categories of forest age, fuel loads and tree density across landscapes. However, any fixed restoration target 

(e.g. crown closure in ad 1900; Kaufmann et al. 2001) under the variable-severity model is inappropriate, as 

it may just be an instant when crown closure happened to be low due to preceding fires that were 

particularly high in severity. Instead a multi-century, landscape-scale restoration framework is needed. 

Although the variable-severity restoration model is incomplete at the landscape scale, it can still guide 

management response to severe fires. For example, the modern occurrence of extensive and severe fires in 

the Rocky Mountains should not be perceived as outside the historical range of variability for ponderosa 

pine-Douglas-fir forest forests, and should not trigger efforts to create forest structures that would 

exclusively support low-severity fires.”(D59 pp. 6-7).
Appendix C Snow Basin Vegetation Management Project FEIS

619

Response: Chapters 1, 2, and 3 have been revised to better reflect the fire regimes of the entire project 

area. 

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#276. We support a more comprehensive restoration program that not only reduces stand density by 

removing small trees where appropriate, but also improves: 

watershed integrity (by for instance removing more roads and reducing weeds and livestock), and 

habitat for a diverse community of species that require both open forest and dense forest, both live trees and 

snags and dead wood, and both low-severity and mixed-severity fire. 

To accomplish this comprehensive approach to ecological and hydrological restoration requires some 

analytic steps that the Forest Service has not yet taken, such as identifying and quantifying desired 

objectives for all these resources and creating a clear plan to create an optimal mix of treated and untreated 

areas (or commercially treated vs. non-commercially treated areas) that will meet diverse objectives in both 

the short- and long-term. (D64A, p. 4)

#277. All action alternatives are based upon the same controversial logging premises, although alternative 4 

drops the highly socially controversial and scientifically indefensible old growth logging. For many of the 

environmental impacts, the alternatives are analyzed together because they are so similar. For example, 

with regards to cumulative effects on flow regimes, the Snow Basin DEIS states: “Alternative 4 would result 

in the least among of overall disturbance in the project area, but only slightly less than Alternative 2 and 3.” 

Despite NEPA’s legal requirements the DEIS contains no action alternatives that are developed based upon 

the preponderance of credible peer reviewed ecological science. (D59 p. 20)

#278. All action alternatives are built around the general concept that heavy commercial logging in the 15” 

to 20.9” DBH range is the only approach to reducing fuels and restoring dry forests. However, this heavy 

logging of mature trees has been shown to increase fire risk (Brown et al 2004; Carey and Schumann 2003; 

Noss et al. 2006; Rhodes 2007; Hanson and Odion 2006; Raymond and Peterson, 2005; Baker et al. 2006) 

and numerous studies recommend removing the smaller trees only. I have seen no peer-reviewed science 

that recommends reducing stands to the lower management zone for basal area stocking. The Forest 

Service did not analyze a single alternative that offered a different approach from heavy commercial 

thinning. The public requested a restoration alternative that was eliminated from detailed study. Seven 

suggestions are outlined in the DEIS at 28 and 29: 

1. No harvesting of trees 21”+ diameter except where the grand fir is growing up underneath an old growth 

ponderosa pine or larch. 

2. Maintain high levels of mistletoe infection in the Late Old Successional (LOS) pine and Douglas-fir 

stands, especially the trees 21”+ diameter, for biodiversity. 

3. Manage mistletoe with fire and cutting some mid canopy trees. 

4. Manage residual Basal Area above the Lower Management Zone (LMZ) of Stand Density Index (SDI) in 

all cases. 

5. Girdle 21”+ diameter trees in overstory instead of removing from stands to both release understory and 

provide snags. 

6. Do not cut units with regeneration prescriptions but leave as “refugia”. 

7. Use an individual tree release prescription in grand fir type to release pine and larch by cutting grand fir 

less than 21” diameter around them but not harvesting entire stand to retain higher levels of hiding cover. 

In its dismissal of this alternative, the agency fails to disclose the existence of any scientific controversy. 

These serious analysis development deficiencies violate the requirements of NEPA. Moreover, the Forest 

Service relies heavily on alternative 4 to create an appearance of responding to the public’s concerns, and 

then the DEIS shows systematic bias against alternative 4. (D59 p. 20)

Response: Refer to Chapters 1 and 2 in the FEIS. 

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Appendix C Snow Basin Vegetation Management Project FEIS

620

#279. We urge the Forest Service to develop an alternative in the FEIS which focuses commercial 

treatments on: non-LOS forests, in unambiguously dry forest types, using non-regeneration prescriptions. 

(D64A, p. 3)

Response: Regeneration prescriptions were dropped from all alternatives in the FEIS. See Chapters 1 and 

2 of the FEIS for acres of non-LOS harvest is proposed in Alternatives 2, 3, and 4 respectively. The 

rationale for treating ambiguous dry forest types can be found in the FEIS. 

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#280. Lindenmayer et al. (2009) offers the following conclusion: “If industrial logging changes fire 

proneness, then interactions between logging and climate change could lead to cumulative negative impacts, 

including those on biodiversity. Conversely, recent work in Amazonia suggests that some kinds of forest 

may have some inherent resilience to climate change through maintaining mesic microclimate conditions if 

other agents such as logging are left undisturbed (Malhi et al. 2009). Third, a better understanding of 

relationships between logging and wildfire will improve policy making and forest management. For 

example, in moist forests there may be a case to create buffer areas adjacent to human settlements. In 

addition, there may be a strong case to exclude logging from those areas where past human disturbances 

(like timber harvesting) have been limited (Cochrane & Barber 2009). This is because logging induced 

alterations in landscape cover patterns can take prolonged periods to reverse and hence associated changes 

in fire susceptibility also may be long lived (Perry 1998).” (D59 p. 16) 

Response: The DEIS states that the entire Snow Basin project area has been logged. This selective 

logging of species such as ponderosa pine and western larch, and the lack of disturbance, has resulted in 

increased fire susceptibility. The purpose and need for the project is to manage forest structure, 

composition and density towards landscape HRV and improve sustainability and to maintain and increase 

landscape resilience to reduce the risk of uncharacteristic disturbance. 

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#281. It seems that the issues that precipitated Alternatives 3 and 4 were based on interpretation of terms. 

Specifically, the 21” dbh harvest limitation rule is an arbitrary limit and does not necessarily equate with 

“old trees.” Consequently the case could be made that alternative 2 may not result in a loss of LOS. If trees 

>21” dbh are removed from existing LOS areas potentially there would be a loss of structure but “large” 

and “old” are strictly a matter of definition. (D63 p. 1)

Response: Large trees are defined by the Region Six Old Growth Guidelines. For local tree species 

except lodgepole pine, this is and at least 150 years of age. Forest Plan Amendment 2 (SCREENS) defines 

Late and Old trees as greater than or equal to 21” dbh. Analysis indicates that many 21+ trees in Snow 

Basin are less than 150 years old. However, the Forest Plan direction must be followed unless amended. 

See Chapter 2 for the discussion of the Snow Basin forest plan amendments. 

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#282. Riparian areas should not be automatically off limits to treatment when riparian functions can be 

maintained or improved while accomplishing the broad goals of the project, which the forest plan and 

PACFISH will allow. In recent past, large buffer zones have been automatically designated around riparian 

areas excluding treatment. That has essentially placed the highest fire risk and fuel loads in arguably the 

most sensitive areas in the forest with the most potential for damage. This is not environmentally 

acceptable. (D29 p. 1)

Response: We are thinning 50 acres in RHCAs under Alternative 2. We are also Rx burning in 865 acres 

of RHCAs under Alternative 2 (about 16% of the total RHCA acreage in the project area). RHCAs are not 

"buffer" areas under INFISH/PACFISH, however, activities proposed in RHCAs must have the objective 

of improving riparian and aquatic habitat conditions. Granted the proposed activities are small in relation 

to the acreage of RHCAs in the project area. I haven't seen any data on fuel loads in RHCAs in the project 

area to respond to the comment that RHCAs are at the highest risk of fire in the project area. Maybe Noel 

can help you out there. Also, while there is a sentiment that by not treating vegetation and fuels in 
Appendix C Snow Basin Vegetation Management Project FEIS

621

RHCAs we are creating conditions that are outside of the HRV for riparian stands the science is pretty gray 

when it comes to this issue.

Regarding RX fire in Riparian, we are not intentionally igniting within RHCA's. We are allowing fire to 

back into RHCA's rather than construct firelines parallel to them. In other words the PDC's of allowing 

fire to back are based on achieving the least distrubance within the RHCA's. We do not have specific fuels 

info for the RHCA. Overall we can expect a somewhat higher vegetation load in the riparian (for obvious 

reasons) and so would expect a higher overall fuel loading, but overall little consuption due to expected 

moisture conditions under prescription parameters. There will not be activity fuels (other than the 50 

acres) so no difference between alts there.

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#283. This project design is being restricted by the ill advised and unscientific 21” rule and by wide stream 

buffers. With these restrictions on removing excessive fuel loads, the project will result in a token fuel 

reduction and leave the entire area subject to a catastrophic fire. There are many large and small trees 

being stressed by over crowded conditions and are dying. The rounded top and dead spire top trees are 

very numerous and standing dead trees are also numerous and provide sufficient fuel to cause any fire 

during dry conditions to become a devastating stand clearing fire, that burns up the carbon that has been 

sequestered in the soil and return it to the atmosphere. Such a fire will also wipe out fish and wildlife 

habitat and send wood ash into the streams. This highly alkaline ash will kill fish far downstream. (D31 p. 

1)

Response: We are thinning 50 acres in RHCAs under Alternative 2. We are also Rx burning in 865 acres 

of RHCAs under Alternative 2 (about 16% of the total RHCA acreage in the project area). RHCAs are not 

"buffer" areas under INFISH/PACFISH, however, activities proposed in RHCAs must have the objective 

of improving riparian and aquatic habitat conditions. Granted the proposed activities are small in relation 

to the acreage of RHCAs in the project area. Also, while there is a sentiment that by not treating 

vegetation and fuels in RHCAs we are creating conditions that are outside of the HRV for riparian stands 

the science is pretty gray when it comes to this issue.

What some regard as "fuel" can also be wildlife habitat and future components of aquatic habitat to others.

Also, the characterization that fire "wipes" out fish habitat is incorrect. Fire has both detrimental and 

beneficial effects to aquatic habitat. I discussed these effects in the Watershed/Aquatics Report under 

Alternative 1 for the water temperature, LWD, and fine sediment RMOs.

We have made riparian areas off limits relative to change in fire risk. Fire movement following drainages 

is a possibility as treatment units do not intersect riparian areas. Allowing fire to back into riparian areas is 

a mitigation to disturbance (from firelines), not a treatment designed to meet a fuels objective and so is not 

expected to change the situation much if at all. Treating the uplands to the scale we have identified, 

combined with the overall layout of the treatment units, will create barriers to fire movement across the 

landscape.

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#284. The DEIS states at 85: “Alternatives 2, 3, and 4 would improve stand and landscape resilience to fire. 

Resilience to fire is the ability to maintain desirable characteristics. Desirable characteristics can be 

maintained by the use of low intensity fire and exclusion of high intensity fire. Stand resistance or resilience 

to fire varies with tree species composition, stand structure and density. “

Where does the peer-reviewed science support the definition of resilience as the “ability to maintain 

desirable conditions and exclusion of high intensity fire? Who sets these desirable conditions? What if the 

desired conditions run counter to the best available science in many aspects of project design as in Snow 

Basin? (D59 p. 51)

Response: Chapters 1 and 2 of the DEIS have been revised in the FEIS. While the intent is to be able to 

use low intensity fire to maintain fuel loading at desirable levels and to control species composition by 

killing less fire-tolerant species such as grand fir, high intensity fire will still occur within the project area. 

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Appendix C Snow Basin Vegetation Management Project FEIS

622

#285. The following is a brief outline representative of the range of current scientific information that 

should be incorporated in revising the proposed decision and management actions of the Snow Basin 

Project: (D59 p. 37)

Management recommendations based on scientific forest and fire ecology research: 

Provide for the ongoing natural functioning, resilience, and biodiversity of ecologically foundational native 

vegetative and invertebrate species, and soil communities. 

Response: The purpose and need (FEIS Chapter 1) for the Snow Basin project is to manage forest 

structure, composition and density towards landscape HRV and improve sustainability and to maintain and 

increase landscape resilience to reduce the risk of uncharacteristic disturbance. Prior harvest and the lack 

of disturbance have resulted in an existing condition that is lacking in function, resilience, and biodiversity 

of ecologically foundational native vegetative species. 

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#286. Logging equipment requires road building, and cutting mature trees with old growth characteristics 

and trees with greater than 20” diameter is simply poor land management practices. Industrial logging in 

this manner completely destroys wildlife habitat and contiguous corridors, it ruins recreational areas, 

disrupts watersheds, impairs streams, and damages soils, let alone eliminating and decimating old growth 

forests. This plan is egregious and totally unacceptable. Please reconsider your plan in the Snow Basin area 

and stop this “preferred plan” of destructive logging practices. (D21 p. 1)

Response: The Snow Basin FEIS Alternatives show three different approaches to meet the purpose and 

need for the project. Effects on wildlife habitat, connectivity corridors, recreation, watersheds, streams, 

soils and old growth from each alternative are discussed in Chapter III of the FEIS. 

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#287. I am critical of careless prescribed burns that have burned off at ground level the largest and most 

majestic of our oldest ponderosa pine trees. The Forest Service sets fire to the accumulation of pine needles 

that over the years pile up deep around the tree trunk. The larger pines will simmer for a week to ten days 

or more before the tree is cut off and falls. I have photographs. I have documented instances where enough 

huge pine timber was killed, had the logs been taken to a sawmill, the lumber would have built a town. (D15 

p. 2)

Response: Project Design Features (PDFs) to prevent this from happening can be found in Appendix B-1 

of the DEIS. FUELS/AQ-6 would be used to protect overstory trees. 

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#288. Learning should be an objective of every restoration project. Use projects as an opportunity to 

conduct monitoring and research on the effects of thinning and other activities. There are many 

information gaps that need filling. Every project should generate useful information to inform future 

projects. (D64A p. 34)

Response: See the monitoring plan in Appendix B. 

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#289. So-called temporary roads are temporary only in their use by log trucks, but not so temporary in 

their effects on soil, water and wildlife. (D64A, p. 7)

Response: Discussed in DEIS on page 167. The Forest Service agrees and is well aware of this. The 

impact of temporary roads on soils, water quality and wildlife are taken into account and disclosed in those 

analyses in the FEIS in each of those sections. 

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#290. We have issues with the potential impacts from the action alternatives’ proposed road reconstruction. 

In particular, we are unclear about the potential impacts from the reconstruction of closed roads which 

“...are extensively grown in.” (DEIS p. 320). Reconstructing closed roads which have stabilized can have 

impacts similar to the construction of new roads, regardless of their administrative status. We also 
Appendix C Snow Basin Vegetation Management Project FEIS

623

understand, however, that reconstructing roads which are ongoing sources of adverse impacts to forest 

resources can have beneficial effects. We recommend the application of additional mitigation measures for 

the reconstruction of closed roads which have stabilized. Consider, for example, applying road 

rehabilitation contract requirements for temporary roads (i.e., BT6.63) to reconstructed closed roads. 

Additional mitigation seems particularly appropriate for road reconstruction near streams (i.e., 

Conundrum Creek). (D67 p. 2) 

Response: The Forest Service agrees with the commenter’s statement and has long been applying road 

rehabilitation measures that far exceed the requirements of Standard Provision BT6.63. The road 

rehabilitation requirements for temporary roads contained in Standard Provision BT6.63 are actually 

somewhat weak. This is why Temporary road rehabilitation requirements are extended by use of a Special 

Provision CT 5.1 Temporary Road and Landing Construction that go beyond the requirements of BT6.63. 

Permanent System roads closure and stabilization is covered in Special Provision, CT5.32 – Road 

Maintenance Requirements, and includes standard specifications for closing and stabilizing system roads 

that will be closed for long periods of times. These requirements are more stringent than what is required 

by BT 6.63, for Temporary Roads.

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#291. What is the minimum road system? Are we making good progress toward the minimum road 

system? (D64A p. 22) 

Response: The WW NF is currently working on the minimum road system plan. The product is not yet 

final.

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#292. Hydrological complexity and moist mixed conifer forests. A description of the sensitivity of the 

hydrological condition in mixed conifer stands from the DEIS at 150: “Wetlands, seeps and springs are 

abundant in the mixed conifer stands of the project area and consequently not all have been identified. 

They are important in sustaining late-season streamflows, maintaining cooler stream temperatures, and 

providing unique habitats. All wetlands, seeps and springs will be located and protected during all phases of 

project operation.” 

Note that these wet areas are abundant in the mixed conifer stands which are naturally more moist and have 

a mixed severity fire regime where fuels reduction treatments are not needed. These seasonal hydrology 

patterns have important implications for the carbon cycle in ponderosa pine forests (Thomas et al., 2009). 

The Snow Basin proposal does not recognize the hydroecological complexity of mixed conifer forests and 

instead fixates on fuels reduction at the expense of other important ecosystem attributes. (D59 p. 68) 

Response: The DEIS on page 150 does not state that these areas have a mixed severity fire regime where 

fuels reduction treatments are not needed. It merely points out that wetlands exist, and we will avoid them.

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#293. Species in moist mixed conifer are poorly adapted to frequent disturbance. It is imperative that the 

ground cover is protected from heavy machinery. The FS should drop all proposed treatments in the moist 

sites (D59 p. 97) 

Response: While moist mixed conifer forests historically did not experience frequent disturbance of low 

severity fires like dry ponderosa pine forests, they were historically shaped by the disturbance of mixed 

severity fire regimes. Mixed fire regimes are characterized by fires of intermediate severity and frequency 

(Arno et al. 2000). For the moist conifer forests of the Blue Mountains, the fire return interval is estimated 

at 45 - 100 years (mixed conifer, eastside mesic, Landfire Rapid Assessment 2007). These conditions 

produce highly diverse forest communities with seral species adapted to disturbance (Arno et al.2000). 

LANDFIRE Rapid Assessment. 2007. Rapid assessment reference condition models. In: LANDFIRE. U.S. Department of 

Agriculture, Forest Service, Rocky Mountain Research Station, Fire Sciences Lab; U.S. Geological Survey; The Nature 

Conservancy (Producers). Available: http://www.landfire.gov/models_EW.php [66533]
Appendix C Snow Basin Vegetation Management Project FEIS

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Arno, SF; Parsons, DJ and Keane, RE 2000. Mixed fire regimes in the northern Rocky Mountains: Consequences of fire 

exclusion and options for the future. In: Cole, David N.; McCool, Stephen F.; Borrie, William T.; O’Loughlin, Jennifer, 

comps. 2000. Wilderness science in a time of change conference—Volume 5: Wilderness ecosystems, threats, and 

management; 1999 May 23–27; Missoula, MT. Proceedings RMRS-P-15-VOL-5. Ogden, UT: U.S. Department of 

Agriculture, Forest Service, Rocky Mountain Research Station.

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#294. When I first reviewed the WWNF proposed action in 2009 in Snow Basin, tree harvest was to occur 

inside of the 300 foot buffer to restore forest health. I am very disappointed that this harvest was dropped 

in the DEIS. With properly designed tree harvest systems, no negative impact, if any, would occur in this 

300 foot buffer if the guidelines of the Oregon State Forest Practices Act were followed. (D37 p. 2)

Response: To keep the project on schedule, a decision was made prior to the DEIS to drop the harvest 

within RHCAs due to a lack of site-specific information for each RHCA. Any harvest activities within 

RHCAs require careful site-specific planning and analysis to ensure aquatic resource values (Riparian 

Management Objectives) are not compromised, but rather enhanced.

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#295. The objective to manage forest structure towards landscape historic range of variability by creating 

more single story LOS and shifting tree species composition toward early seral species is fine at the right 

scales in the right Plant Association Groups, but there is evidence to indicate that some of the more moist 

forest types in this project do not fit the SSLT template. (D64A, p. 5)

Response: The comment concerns moving cool/moist MSLT to SSLT. We agree that SSLT is not an 

appropriate structural stage in cool/moist portion of the Snow Basin landscape. Some SSLT would result 

order to manage tree species composition. The proposed activities would retain LOS, a fully stocked stand 

with gaps, and a mix of trees species. The change to SSLT would be short-term until these stands develop 

into MSLT. 

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#296. DEIS p. 44: “Alternative 4 would not prepare the treated portions of the cool/moist, warm/very 

moist, and warm dry grand fir landscape for development into characteristic conditions or maintenance 

through low intensity fire. In fact, conditions will immediately begin to revert back to the existing condition 

due to the retention of a well-distributed grand fir seed source.” See the different opinion on p. 4 of D59. 

(D59 p. 17)

Response: The reduction of grand fir including those 21+ is necessary to reduce competition to existing 

ponderosa pine and western larch and to create gaps for ponderosa pine and western larch regeneration. 

Large diameter grand fir would be retained in the cool/moist/dry area selected for treatment. Large 

diameter grand fir would be retained in the Pine Marten habitat selected for treatment. Cull grand fir, the 

vast majority of which are 21+, would all be retained. Large grand fir exists in all BPE 4 and 5 areas that 

would not be treated under any alternative including: Wildlife Refugia, RHCAs, no treatment areas.

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#297. Critically important comprehensive science review on moist forest logging was not considered. (D59 

pp. 14-16)

#298. There is no scientific consensus about the need for density reduction in more moist forests, with mixed 

species, and mixed fire regimes. It appears there are some potentially unwarranted activities proposed in 

cool/moist and warm/very moist grand fir sites, but it is difficult to tell from the DEIS whether each 

treatment unit is characterized by dry, moist, or intermediate plant association groups. (D64A p. 19) 

Response: There is a significant body of scientific evidence supporting logging in moist upland forests 

specifically for forest health. The proposed activities promote a species composition, density, and structure 

that more closely resembles historical conditions. The results of moving the Snow Basin project area closer 

to its historical range of variability (HRV) for these three measures will be a forest that is more resilient 
Appendix C Snow Basin Vegetation Management Project FEIS

625

and better able to handle future insect and disease related disturbances, and therefore will be, what we 

consider, a healthier forest.

For a comprehensive set of references related to treatments in mixed conifer forests for insect

and disease related disturbances, see the following:

Schmitt, C. L. 2010. Upland Moist Forests and Associated Disease Disturbances in the Blue

Mountains—Cases for Management Action. USDA Forest Service, Blue Mountains Pest

Management Service Center, La Grande, Oregon. 29p.

Scott, D. W. 2010. Upland Moist Forests and Associated Insect Disturbances in the Blue

Mountains: Supporting Science for Management Action. Report BMPMSC-10-01. USDA

Forest Service, Blue Mountains Pest Management Service Center, La Grande, OR. 101p.

Together, these two references contain literally hundreds of citations to studies showing clear,

supportable scientific evidence for treatment in mixed conifer forest stands for forest health

rationales.

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#299. Early SI stands are well under HRV also suggesting more regeneration Rx should be considered. 

(D29 p. 1)

Response: Stand Initiation is within HRV for all biophysical environments. Regeneration harvests were 

considered and analyzed in this project, but were not included in any of the alternatives in the FEIS. See 

Ch 3. Section 3.1.3.1 Existing Conditions – Table 27 Summary for Entire Landscape (Pg. 55)

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#300. Projects that propose vegetation management actions that aim to restore forest structure toward a 

more historical and resilient stand composition and density to return natural disturbance to the landscape 

should be limited to previously logged sites. Lower elevation forests that have not experienced the same 

logging and road-building regime as other federal lands are relatively rare and have a high value for 

conserving biodiversity. Restoration using fire alone is generally appropriate in unlogged stands (D50 p.1)

Response: See response to Comment V-8: “Wildlife Refugia”. Wildlife Refugia are areas of forested northerly aspects that 

have escaped one or more fire cycles. The wildlife model was based on research by Elizabeth Camp (Camp, A. E. (1995)). It 

is discussed in Chapter 3 of the FEIS section. Areas not proposed for treatment and the percent of the forested landscape are 

listed in response #186. 

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#301. Extensive areas of nearly continuous commercial treatment with too few untreated refugia raise 

concerns and need further analysis. (D64A, p. 2)

Response: See response to Comments #186 and #330. 

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#302. The failure to recognize the self-correcting role of natural processes like insects, mistletoe, fire, and 

mortality in ecosystem restoration raises concerns and needs further analysis. (D64A, p. 2)

Response: The existing condition’s departure from the desired condition is fully analyzed in Chapter 3 of 

the DEIS. Stands within the project area have moved outside of the HRV to the point where natural 

processes would not achieve management objectives for the area. The goals of this project include creating 

conditions that will allow natural processes such a fire to occur on the landscape.

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Appendix C Snow Basin Vegetation Management Project FEIS

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#303. BA targets should be set on a stand level. This should assure that targets are being met on a stand 

basis for the purpose and objective of the project. Historically this has happened occasionally, still leaving 

far too much stocking on site after treatment. (D29 p. 1)

Response: Residual stocking is set at the stand level based on its plant association. Marking guides are 

designed using plant association. Sale preparation supervision and the District Silviculturist monitor 

marking and correct as needed. 

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#304. I recommend the following standard for determining which trees to remove from the forest: 

“notwithstanding the size or proximity to water, any tree that is stagnating in its growth because of old age, 

disease or insufficient light, nutrients or water shall be removed to maintain forest health.” (D31 p. 1)

Response: The proposed activities are designed to improve forest health. This includes reducing, but not 

eliminating, the severity of insects, disease, and fire. An endemic level of tree mortality is necessary for 

overall forest health including wildlife, soil, and fish. 

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#305. This land needs a commercial thinning project that will reduce fuel loads. All large healthy thriving 

trees should remain, and small trees removed to limit the tree density to levels that will allow the trees to 

grow. All round top trees and dead spire top trees should be removed to prevent a stand clearing fire and 

the resulting loss of wildlife, wildlife habitat, fish bearing streams, watershed function, homes, human life, 

and economic values. (D31 p. 2)

Response: There are 3 action alternatives proposed in the FEIS that include commercial thinning and 

fuels reduction projects. Reference the DEIS Ch. 3 Section 3.1 Need to Manage All Tree Sizes for 

definition of removal criteria. DEIS Ch 3 Section 3.5.3.3 Primary Cavity Excavators – Snag Habitat

discusses snag retention. See the FEIS Fire and Fuels section for discussion of effective fuels treatments. 

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#306. The Forest Service also states in this section “Reliance upon natural disturbance to return the area to 

historic conditions could be expected to take several hundred years. The size and intensity of future natural 

disturbance is expected to be unacceptable on both federal and private land.” This statement does not 

recognize that all the forests within the project area characterized by mixed severity systems are already 

within the range of historical conditions. 

This is a fundamental flaw in the analysis. This statement also greatly underestimates the ability of natural 

disturbance to restore large tree conditions in dry forests. Wales et al. (2007) modeled various potential 

outcomes of fire and fuel management scenarios on the structure of forested habitats in northeast Oregon. 

Wales et al. (2007) found that the natural disturbance scenario resulted in the highest amounts of all types of 

medium and large tree forests combined and best emulated the Natural Range of Variability for medium 

and large tree forests by potential vegetation type after several decades. (D59 pp. 50)

Response: The Wales et al. (2007) paper is a modeling study conducted in a drainage on the La Grande 

Ranger District. The existing condition for that area is different than that found in Snow Basin so the 

modeling results from paper have limited applicability for the Snow Basin project. The final 

recommendations in that paper have been integrated into the Snow Basin project. 

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#307. The Forest Service should consider alternatives that would retain more large trees, while killing a 

strategic subset of the large shade-tolerant trees (that are in direct competition with larger shade-intolerant 

species) and retain them as snags. Or pruning selected branches of large trees that pose particular risks. 

(D64A, pp. 2-3)

Response: In both the DEIS and FEIS Alternative 4 does not remove large trees. The number of 21+ 

trees proposed for removal and those that would be retained is disclosed in Chapter 3 Section 3.1 

Vegetation of the FEIS. Snag creation and pruning is a highly expensive activity relegated to recreation 
Appendix C Snow Basin Vegetation Management Project FEIS

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settings. As described by Hallett, et, al, girdling trees provides foraging habitat but not cavity nesting 

habitat. 

Hallett, J. G., Lopez, T., Borysewicz, M. A., 2001. Decay dynamics and avian use of artificially created 

snag. Northwest Science. Vol. 75, no. 4, pp. 378-386.

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#308. The DEIS states at 69: “To restore characteristic tree species on appropriate sites. Planting occurs 

after Regeneration harvest and site preparation using fire. Seral trees would be planted at approximately 

400 trees per acre. These trees would be 1-0 containers of ponderosa pine and/or western larch from local 

seed sources.” There should be no planting of trees. National Forests are not tree farms. Natural 

disturbance and natural regeneration processes are fully capable. (D59 p. 97)

Response: In the FEIS in all alternatives, regeneration harvest treatments have been dropped.

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#309. At this point in management, it is critically important that we limit our subsequent treatments to the 

right places, the area’s dry ponderosa pine dominated forests. 

Response: The Purpose and Need, existing condition, desired condition for the cool/moist vegetation type 

is discussed in Chapter 3 Section 3.1 Vegetation of the DEIS.

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#310. The DEIS fails to objectively and accurately identify the ”Best Available Science” that supports the 

level and extent of planned commercial logging in old-growth forests. The DEIS neither objectively, nor 

accurately identifies what the “best available science” fully represents or recommends with respect to the 

Forest Service’s decision to log extensively in rare LOS forest habitat. 

The EIS fails to demonstrate that the “best available science” supports the agency’s plans to log century and 

older mature trees, and to extensively degrade important ground vegetative cover needed by associated old 

forest species and prey species. 

The DEIS fails to objectively disclose the contending “best available science” that recommends strongly 

against the project’s plans for extensive logging within LOS forests and the removal of mature trees.

The DEIS fails to sufficiently and accurately demonstrate how the “best available science” standard was 

objectively considered and employed with regard to this analysis and decision. 

Numerous courts, including the Ninth Circuit have held Forest Service decisions to be arbitrary and 

capricious where there was nothing in the record that objectively and accurately explained what “best 

available science” entails or how it was considered in developing aspects of the challenged timber sales. 

Bark, 2007 U.S. Dist. LEXIS 21272 at *19-20; Forest Watch v. U.S. Forest Serv., 410 F.3d 115, 117 (2nd Cir. 

2005); Ecology Ctr., Inc. v. U.S. Forest Serv., 451 F.3d 1153, 1191, 1195 (10th Cir. 2006). (D59 p. 35)

Response: There is a significant body of up-to-date scientific literature cited in the Snow Basin DEIS 

Forest Vegetation report that supports the purpose and need premise of the Snow Basin project. 

Specifically, moving forest structure, density, and composition towards the historical range of variability 

(HRV) to improve forest health and vigor is a scientifically supported concept, as evidenced by numerous 

citations within the EA. In formulating the analysis for the Snow Basin Vegetation report, the Best 

Available Science (BAS) was used. Multiple journals, textbooks, reports, and other sources were consulted 

to help inform the analysis and develop the alternatives. 

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#311. Also consider the natural range of variability, which is the historic range of variability as modified by 

future climate change and human tolerance of disturbances like fire. Harris etal. (2006). (D64A, pp. 6). 
Appendix C Snow Basin Vegetation Management Project FEIS

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Response: The effects of climate change are disclosed in Chapter 3 of the DEIS Section 3.1.6.1 

Consideration of potential effects due to climate change (pg. 72) . DEIS Ch. 3 Section 3.1.6.4 Cumulative 

Effects of Alternatives 2, 3, and 4; See Climate Change and Forested Vegetation. On Pgs 100-101. 

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#312. The WWNF may be perpetuating old-growth habitat fragmentation through its series of site-specific 

amendments, yet it has never asked this critical question. Certainly converting one type of old-growth forest 

type to another forest type, with mechanical logging methods that create a whole slew of potential impacts, 

repeatedly, and on a piecemeal basis throughout the forest, will result in “landscape pattern” changes. (D59 

p. 44)

Response: See DEIS Chapter 3 Section 3.5.3.2 for description and discussion on Connectivity.

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#313. All of the remaining old growth forests need to be protected and restoration efforts in dry forests 

should be firmly based on the best available science with no compromise. Restoration of the remaining old 

growth forests should not have to make money, or financially hold up other parts of a timber sale project. 

That’s absurd. If the Forest Service’s concern for old growth forests does not extend beyond the financial 

demands of the commercial logging program then old growth forests are best left unmanaged. Restoration 

of remaining unlogged lower-elevation sites should focus on the reintroduction of fire and protection from 

activities that may cause degradation or loss of existing old growth. 

1) Evaluate passive opportunities for introducing fire without any mechanical treatment. 

2) Use the minimal amount of mechanical treatment needed to safely reintroduce fire. This will typically 

include trees mostly in the 3-8” in DBH range and no larger than 12” DBH. Only hand crews should be 

permitted to enter existing old growth and previously unlogged forests. (D59 p. 23)

#314. All of the remaining old growth forests need to be protected and restoration efforts in dry forests 

should be firmly based on the best available science with no compromise. Restoration of the remaining old 

growth forests should not have to make money, or financially hold up other parts of a timber sale project. 

That’s absurd. If the Forest Service’s concern for old growth forests does not extend beyond the financial 

demands of the commercial logging program then old growth forests are best left unmanaged. (D59 p. 23)

Response: Reference Chapter 2 Section 2.3 Alternatives considered but Eliminated from Detailed Study -

2.3.1 Maximize Use of Prescribed Fire Only. Reference Purpose and Need DEIS Page 2. 

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#315. Grand fir, which establishes under the shade of the other species, has notably thinner bark, and 

because of this feature is easily damaged by fire. With the burning of slash (from minimal mechanical 

treatment), grand fir will become progressively less abundant in this type, even if large diameter trees were 

to be left standing. (From Dr. Waring’s declaration on the “Wildcat Fuels Reduction and Vegetation 

Management Project” EA). Once fire has been safely restored to these unlogged forests, it is the only tool 

needed in the future. 

As the Snow Basin DEIS discloses at 85: “These 21+ grand fir have bark thick enough to survive low 

intensity fire.” The Forest Service should be leaving these fire resistant old growth Grand fir trees for the 

critical habitat they provide and focus on understory treatments. (D59 pp. 23-24)

Response: One hundred years of fire exclusion has resulted in many grand fir having grown past the point 

where fire alone can meet the desired condition. Grand fir at modest diameters attains a bark thickness 

resistant to low intensity surface fire. The comment refers to “unlogged forests”. No such forests occur on 

the SB landscape.(DEIS Ch 2 Existing Condition) The proposed activities would move forest stands to a 

condition where future fire could be safely returned. 
Appendix C Snow Basin Vegetation Management Project FEIS

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#316. The DEIS on p. 107. The best available science openly recognizes the critical role of stand 

replacement fire in mixed conifer stands (Hessburg et al. 2007; Baker et al. 2007). Without question this 

variable role of fire, including the high severity component, is what has created the patchy forest structure 

that mixed conifer systems are defined by. 

Moreover, the best available science does not support the statement that mixed conifer stands have too 

many small diameter trees. In fact the science is clear that numerous small trees are within the range of 

natural variability in the mixed conifer type, which is no surprise given the mixed fire severity regime. (D59 

pp. 49)

Response: See FEIS Ch. 3, Sec 3.1 for discussion of HRV for species density, structure, and species 

composition. 

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#317. This section pertains to the report written by Bruce Countryman and Don Justice, updated Jan. 12th, 

2009. This report provides a landscape scale view of the SSLT and MSLT situation across the entire 

Wallowa-Whitman and neighboring national forests. Please note that the Countryman and Justice report 

refers to MSLT as old forest multi story (OFMS) and SSLT as old forest single story (OFSS). Page 6 of the 

Countryman and Justice report states; “Dry multi-story old forest (OFMS) is within HRV at the scale of the 

Blue Mountains, but varies from slightly above to within HRV when viewed at the scale of the individual 

national forest. 

Dry single-story old forest (OFSS) is below HRV, both at the scale of the Blue Mountains, and for each 

national forest” (see figure below entitled “Figure 3. Dry Forest Existing and Historic Structural Stage 

Percent”). The lack of OFSS in Figure 3 is nearly exactly matched by the excess of forest in the understory 

reinitiation (UR) phase. It is a historical fact that due to the accessibility of OFSS, this forest type was logged 

heavily across the Blue Mountains (Rainville et al. 2008). These previously logged OFSS areas are now in 

the UR phase based on general succession rates in the Blue Mountains. 

The definition of UR is: “a second tree layer is established under an older overstory. Overstory mortality 

has created growing space for new understory trees” (pg 3, Countryman and Justice). Areas in the UR 

structural stage contain the reservoir of lands suitable for restoration to OFSS. The FS should focus efforts 

to increase OFSS in the UR structural stage. (D59 pp. 29-30)

Response: Reference Ch 3 sec 3.1. OFSS or Single story Late and Old Structure is a single story 

structure and is deficit. UR, Understory Reinitiation is a multi-story non-LOS structure and is surplus. The 

proposed activities and all action alternatives would manage UR to develop into SSLT over time. See 

Chapter 3 of the FEIS. 

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#318. It is critical that the FS revisit the stand density science so that the fine line of accelerating singlestory old growth structure and helping imperiled species that need this habitat can be honestly aspired too. 

Considering the realities and temptations associates with commercial logging, this will be a very challenging 

task. See Lindenmayer et al. (2006) for a checklist of strategies that should guide these efforts. (D59 pp. 30)

Response: See response to Comment #317. In addition, tending the non-LOS stands involves setting the 

stage for these areas to grow into LOS. We estimate this to take 2 to 4 decades on average. SB would 

manage some stands of MSLT to SSLT. The change would be immediate as would be effects to wildlife 

species that utilize this habitat. 

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#319. The best available science does not support commercial logging in previously unlogged forests. 

Forests in their potential state are simply one of the most important ecosystems to preserve on earth. The 

peer-reviewed science repeatedly urges for a cautious approach to restoration of dry forests, especially in 

unlogged ponderosa pine/Douglas-fir forests(Keeling etal. 2006, Noss etal. 2006), and for excluding logging 
Appendix C Snow Basin Vegetation Management Project FEIS

630

from moist forest areas where past human disturbances (like timber harvesting) have been limited 

(Cochrane & Barber 2009; Lindenmayer etal. 2009). (D59 pp. 22-23)

Response: As stated in the DEIS all of the proposed treatment areas have been harvested in the past, DEIS 

page 3 and 158-159.

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#320. What peer-reviewed science states that mixed conifer stands are out of historical range with regards 

to small diameter trees? Likewise, what peer-reviewed science supports the claim that mixed conifer stands 

are at risk of uncharacteristic disturbance? (D59 p. 16)

Response: Reference the DEIS 3.1 Forest Vegetation Section for discussion of HRV and citations cited.

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#321. Reliance on non-peer reviewed 1994 GTR report for stand density treatments is outdated and 

creating scientific controversy. The Snow Basin DEIS fails to consider much of the best-available science 

but relies on an internal Agency non-peer reviewed report as the foundation for treatments across the 

project area. The Forest Service has no peer-reviewed science that supports the widespread reliance on the 

Cochran (1994) report from the grey literature. Not only is it out of date, the 1994 Cochran report should 

not be used as a guide for site specific projects. The methodology that the Cochran report is based upon is 

not capable of capturing even a snap-shot of the heterogeneity of the Blue Mountains Ecosystem and the 

complex vegetative communities such as are within the Snow Basin project area. Cochran et al. (1994) 

states for Proposed Method: “Values for SDIs at full stocking are not available for each species in each 

plant association for the Wallowa-Snake and Blue Mountain Provinces, but values for growth basal area 

(GBA) (Hall 1987, 1989) are given in plant association guides (Johnson and Clausnitzer 1992, Johnson and 

Simon 1987). We used some assumptions to relate GBA to SDI at full stocking and then created stocking 

level curves based on SDI values. Despite the generalizations and assumptions clearly stated in this report, 

the Forest Service is consistently applying treatments to a wide variety of forest types and conditions that 

systematically simplify stand structure, and consistently lower basal areas to the lower management zone, 

resulting in much heavier logging than any peer-reviewed science suggests. (D59 pp. 21-22)

Response: The 1994 GTR report is Research Note PNW-RN-513; Suggested stocking levels for forest 

stands in northeastern Oregon and southeastern Washington. 1994. Published by the USDA Forest 

Service, Pacific Northwest Research Station. This report provides guidelines for management of forest 

stands in the Wallowa-Snake Province, the area in which Snow Basin resides. The guidelines are plant 

association and tree species specific covering a wide variety of forest types. The report simply gives 

guidelines for stocking. It is used as just a just one part of the silviculture prescription. 

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#322. DEIS p. 4: The Desired Future Condition is inconsistent and fails to conform to the best available 

science. The statement on p. 4 clearly indicates that all forest types that are currently within the natural 

(historic) range of variability for these sites should not be within the scope of Snow Basin. (D59 p. 9)

Response: Reference the Desired Future Condition in Ch 1 in the DEIS.

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#323. The Forest Service only wishes to accept wildfire on its (Forest Service) own terms, and does 

not mention key science that clearly illustrates the great importance of high severity fire to wildlife 

(Hutto et al. 2008) and forest successional development (Swanson et al. 2010) with important 

implications for biodiversity conservation. (D59 p. 8)

Response: See Ch 3 Section 3.2 Fire Fuels – Figure 1. Purpose and Need of the project does not seek to 

eliminate moderate to high intensity fire from the project area, but to reduce the scale to which it could 

occur.

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Appendix C Snow Basin Vegetation Management Project FEIS

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#324. As a result of logging on non-federal land, and past practices on federal lands there are severe 

shortages of large trees, large snags, and high-quality forest habitat. (D64A, pp. 4-5) 

Response: Reference 3.1.3.1 Existing Condition in DEIS Pg 47-57. 

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#325. One can use HRV as a guide, but the Forest Service must not focus just on seral stage. Consider the 

historic abundance of ecological attributes like large trees, large snags, the scale and distribution of patches 

of dense forest, and roadless areas, all of which have been reduced from historic norms. D64A, pp. 4-5)

Response: See FEIS Ch. 3, Sec 3.1 for discussion of HRV for species density, structure, and species 

composition. Also see response to Comment #324. See DEIS Ch 3. Section 3.14 for discussion of 

unroaded areas.

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#326. Another example where HRV may not be a good management target is for multi-storied mature 

forests. (D59 pp. 59-60)

Response: An HRV analysis for structure is required by Forest Plan Amendment 2 (SCREENS). HRV is 

discussed in Chapter 3, Section 3.1 of the DEIS. Proposed activities would move the landscape towards 

the desired condition. The desired landscape is that found before settlement or HRV. Historic reference 

conditions are a useful tool to guide as forests were historically resilient to fire, drought, insects, and 

disease. See the following references:

Keane, R. E.; Hessburg, P. F.; Landres, P. B.; Swanson, F. J. 2009. The use of historical range and 

variability (HRV) in landscape management. Forest Ecology and Management. 258(7): 1025-1037.

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#327. There is no question that many of the stands in the current proposal are mixed conifer stands 

characterized by a variable fire severity model where old growth grand fir is characteristic. The Forest 

Service tries to argue in a very vague way that these large tree conditions are “unsustainable.” This must be 

viewed in context of a plan that disregards the irreplaceable role of natural disturbance regimes to recover 

historical conditions. Wales et al. (2007). (D59, pp. 4)

Response: covered in the DEIS Chapter 3. Large old grand fir is characteristic in cool/moist/dry grand fir 

vegetation types as well as in areas of Fire Refugia. The changes to ecological process from the historical 

condition to the present are discussed in Chapter 3 Section 3.1 Forest Vegetation and Section 3.2 

Fire/Fuels and Air Quality of the FEIS. 

The cited Wales paper analyzes the current and historical amount and types of large tree forests in the 

upper Grande Ronde River Basin. It highlights the importance of existing large trees. The paper reaches 

several conclusion that are listed below along with how we believe Snow Basin is compatible. 

Traditional reserve type networks may be susceptible to large-scale disturbances. The paper favors a 

system of old forest elements that would be continuously recruited and could shift across the landscape 

through time. 

The Snow Basin activities would move the landscape towards HRV for LOS. They create conditions for 

many stands to develop into LOS by creating fire resistant structure, reducing density, and favoring fire 

resistant tree species. Improving diameter growth rates would increase the amount of LOS at a faster rate 

than no action. This would be achieved across the landscape and is described in Chapter 3 of the FEIS. 

The future Snow Basin landscape resulting from an action alternative would be better able to resist 

disturbance and maintain large tree structure. 
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Fine-scale habitat features need to be considered to ensure high quality, large trees as habitat through 

time. Including protecting existing large-diameter and old trees (especially fire resistant species) because 

they are difficult to replace. 

The Snow Basin prescriptions are designed to maintain the vast majority of the existing fire resistant trees 

species and to increase the rate that trees reach large size. 

All cull grand fir would be retained to continue to provide habitat. Most of which are “large”.

The long-term abundance and replacement of large snags and down logs should be considered. 

The Snow Basin prescriptions would retain the vast majority of the existing large trees, large snags, and 

large down logs. Increasing diameter growth rates in the treated areas would increase the rate that trees 

reach large size and therefore a future source of large snags, and large down logs.

Protection of large trees should be given during prescribed fire. 

See Chapter 2 of the FEIS Project Design Feature for prescribed fire. 

Development of closed canopy medium and large trees forests in topographically or otherwise protected 

areas. This approach may be more effective than traditional reserve designs. 

Snow Basin incorporates a traditional reserve system as required by the Forest Plan (Forest Plan 

Amendment 2). See Chapter 3 of the FEIS.

This analysis area largely lies on warmer and dyer southerly aspects limiting “protected areas”. For this 

reason Snow Basin retains the vast majority of northerly aspects described by Camp as topographically 

protected areas. The vast majority of the INFISH RCHA buffers are also retained. Northerly aspects and 

RHCA buffers are retained (no harvest treatment) whether they are in the corridor system or not. 

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#328. Dr. Richard Waring stated in his Declaration on the “Wildcat Fuels Reduction and Vegetation 

Management Project,” “Grand fir, which establishes under the shade of the other species, has notably 

thinner bark, and because of this feature is easily damaged by fire. With the burning of slash, grand fir will 

become progressively less abundant in this type, even if large diameter trees were to be left standing. Less 

shade- tolerant trees with thicker bark will become relative more dominant, even with some selective 

removal.”

This indicates that the conditions are sustainable and that the objectives of reducing fuels, increasing early 

successional species, and maintaining the larger Grand fir can all be achieved simultaneously. This would 

allow the larger Grand fir to help fill the gap defined by the deficit of large trees across the landscape as the 

Eastside Screens intended.

Response: covered in the DEIS Chapter 3. The reduction of grand fir including those 21+ is 

necessary to reduce competition to existing ponderosa pine and western larch and to create gaps 

for ponderosa pine and western larch regeneration. Large diameter grand fir would be retained in 

the cool/moist/dry area selected for treatment. Large diameter grand fir would be retained in the 

Pine Marten habitat selected for treatment. Cull grand fir, the vast majority of which are 21+, 

would all be retained. Large grand fir exists in all BPE 4 and 5 areas that would not be treated 

under any alternative including: Wildlife Refugia, RHCAs, no treatment areas.

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#329. Recognize that tree mortality recruits valuable habitat structures and makes resources available 

which increase the vigor of surviving trees, thus accomplishing many of the objectives of mechanical density 

reduction projects. (D64A, p. 4)

Response: There is no doubt that a level of tree mortality provides many benefits. The proposed 

treatments seek to return snag creation processes to endemic levels across the landscape. 

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#330. The FS ran a GIS model which identified only about 5% of the project areas as “refugia.” Many 

areas were excluded for various (arguably arbitrary) reasons. It would go a long way to mitigate for the 
Appendix C Snow Basin Vegetation Management Project FEIS

633

high fraction of the landscape that is being treated to identify a larger (and more well-distributed) fraction 

of the landscape that is designated and protected as refugia and not treated, especially within the 

commercial logging units. Certain features of untreated areas are also ecologically important and must be 

retained, e.g. dense forest habitat, biomass accumulation, carbon storage, pyrodiversity, and mortality 

processes that recruit dead wood. Establishing explicit objectives based on this recognition, will help 

achieve a more optimal mix of ecological benefits from treated and untreated areas within and between 

stands. (D64A p. 18)

Response: “Wildlife Refugia”. Wildlife Refugia are areas of forested northerly aspects that have escaped 

one or more fire cycles. The wildlife model was based on research by Elizabeth Camp ( Camp, A. E. 

(1995)). It is discussed in Chapter 3 of the FEIS section. Areas not proposed for treatment and the percent 

of the forested landscape are listed in Comment #186. 

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#331. Prioritize treating dry forest types at low elevation and on south slopes. New evidence indicates that 

far more of the “dry” forests, rather than being typified low severity fire regimes, were in fact dominated by 

mixed severity fire regimes (including significant areas of stand replacing fire), so mixed severity fire is an 

important part of the historic range of variability that should be restored. (D64A p. 19)

Response: Discussion if FRCC is found in Ch 3 Section 3.2.2 Affected Environment / Existing 

Conditions in the DEIS on Pgs. 109-119. 

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#332. When managing for HRV, especially when significant trade-offs are being made between large fir 

versus large pine and MSLT versus LLST, the Forest Service needs to carefully consider the current 

degraded conditions across the landscape. (D64A, pp. 4-5)

Response: The Purpose and Need to manage LOS, the proposed activities, and the effects to 

LOS are discussed in the DEIS. Refer to DEIS Ch. 1 Purpose and Need, Section 1.3.3 

Objectives of the Project: Objective 1: Manage forest structure towards landscape HRV 

(DEIS pg. 5). 

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#333. The solution is finding the right scale and mix of treatments and the right prescriptions for the 

situation, while also utilizing natural processes to accomplish a lot of the important ecological restoration 

work. (D64A, p. 6)

Response: Natural processes are described in the response to #142. The mix of treatments proposed are 

specific to the vegetation type and stand conditions including Species Composition, Tree Density, and 

Forest Structure. This is discussed in the FEIS Chapter 3 Section 3.1 Forest Vegetation of the FEIS in 

Existing Conditions and in the Cumulative Effects analysis by Alternative. The Purpose and Need of the 

project identifies the objective to manage forest structure towards landscape HRV. Refer to DEIS Ch. 1 

Purpose and Need, Section 1.3.3 Objectives of the Project: Objective 1 (DEIS pg. 5).

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#334. The discussion on Columbia Spotted Frog on DEIS p. 195 ...The USGS recently published a survey 

on the Columbia spotted frog that was conducted just south of the project area. The DOI recommends that 

this report be reviewed and included as appropriate in the FEIS. (D46 p. 2)

Response: “Just south of the project area”, which describes the USGS study area, is actually over 100 

miles into the range of spotted frogs that are from a different clade than those that occur in the Snow Basin 

area. The USGS report was reviewed, and the finding was that more research was needed before any 

meaningful results would be available. 

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#335. The following is a brief outline representative of the range of current scientific information that 

should be incorporated in revising the proposed decision and management actions of the Snow Basin 

Project: (D59 p. 37)

Many imperiled species of concern depend on habitats that are affected by land use on public lands in 

Oregon (USFS and USBLM 1997). Many of these habitats are already widely degraded (Henjum et al. 

1994). Additional degradation from extensive management actions involving elevated use and/or 

construction of roads and landings is likely to further imperil these species and increase the likelihood of 

extirpation. 

Response: There is no evidence that any native species are “imperiled”, but some, like the white-headed 

woodpecker and Lewis’ woodpecker are species of conservation concern. “Extensive management” does 

not necessarily result in degradation of habitats. The management actions proposed with this project are 

geared toward the restoration of source habitat for many wildlife species, including the old-growth 

associated species addressed in the 1994 Henjum et al. publication. 

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#336. DEIS p. 252: “Because the objectives for treatment are centered on stand density reduction and removal of 

grand fir, treatments and alternatives are expected to have a more pronounced impact on focal habitats associated with 

mesic mixed conifer forest. Decreases in amounts or quality of overstory canopy closure and structurally diverse 

multi-layered canopies are expected under all action alternatives.” Greatly decrease planned reduction of mesic mixed 

conifer. (D78 p. 3).

Response: Forest Biophysical Environment (BPE) distribution would not be altered by proposed 

activities. The goal of prescribed treatments in mesic mixed conifer stands is to create or perpetuate the 

appropriate mixture of structural conditions that would have existed under the historic disturbance regime. 

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#337. DEIS Table 116 uses open road density (Her) in the calculation of HEI. ODFW recommends that road distance 

banding methods (Herd) be used when calculating HEI. (D80 p. 1).

Response: Results using the distance banding method are described in the DEIS (page 243-244).

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#338. The Forest Service needs to work toward balanced approaches to restoration that recognize the value of both 

active and passive restoration, in order to find the optimal mix of both of these approaches. (D64A, p. 3)

#339. Mechanical thinning should be considered first when economically possible, before the use of fire alone or 

combined with mechanical treatment. Utilizing fiber for local jobs should be a very high priority of these projects as 

opposed to simply burning the fiber. Proper sale layout (size, quality, saw/non-saw ratio) can economically address the 

high costs of treating non-commercial fiber and accomplish the goals of the project while being economically positive 

(D29 p. 1)

Response: While passive restoration is desirable for many reasons, the combined effects of past harvest 

and of lack of disturbance have resulted in an existing condition in the Snow Basin project area that is not 

amenable to passive restoration. In addition, the 1990 Wallowa-Whitman National Forest Land and 

Resource Management Plan allocated 87% of the Snow Basin Project Area to Management Areas 1 and 3. 

(DEIS Table 3, p. 6). These management areas have an emphasis on commercial harvest of wood that is 

coincident to other management objectives. This is reflected in the Purpose and Need for the project to 

“provide a supply of forest products to the public.” (DEIS p. 6)

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#340. I urge you to preserve the Snow Basin as a legacy for all Oregon grandchildren. Our grandchildren deserve the 

opportunity to enjoy old growth areas such as Snow Basin. (D20 p. 1)

Response: The desired condition for the Eagle Creek Wild and Scenic River Corridor (Management Area 

7) is “a predominance of late seral stands, abundant snags, and old growth groves”. Based on Historic 

Range of Variation for stand structural stage, the desired condition for the Snow Basin project area is to 

have up to 65% of the area in “late old structure”. (DEIS Table 31, p. 65)

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#341. Under section 2.3 Alternatives considered but eliminated from detailed study, you address the fact that some 

suggested you consider girdling trees over 21” dbh rather than harvest them. Your explanation for not fully 

developing this alternative is good but incomplete. You should add that this would be a waste of taxpayers’ assets. 
Appendix C Snow Basin Vegetation Management Project FEIS

635

You should also tie this to the fact that your statutory mandates and Forest Plan allow for the removal of forest 

products. You reference this on DEIS p. 59. (D50 p. 2)

Response: The 1990 Wallowa-Whitman National Forest Land and Resource Management Plan allocated 

87% of the Snow Basin Project Area to Management Areas 1 and 3. (DEIS Table 3, p. 6). These 

management areas have an emphasis on commercial harvest of wood that is coincident to other 

management objectives. “Other management objectives” include providing wildlife habitat and 

maintaining the long term productivity of the forest. Girdled trees are capable of contributing to these 

management objectives as well. 

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#342. The best available science clearly shows that severe disturbance is characteristic and is necessary to sustaining 

native biodiversity. One should not make the mistake of equating severe fires with “uncharacteristic” events. (D59 pp. 

51-52)

Response: Part of the purpose and need for the Snow Basin project is to reduce the risk of high severity 

and extent of disturbance. (DEIS p. 5). For the Snow Basin project, this risk reduction is directed at 

stands characterized by warm/dry biophysical environments, which have a fire regime characterized by 

frequent, low intensity fire. The warm/dry biophysical environment is found on approximately 73% of the 

Snow Basin project area. (DEIS Table 24 p. 52). 

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#343. Protect soils and watershed values from widespread industrial logging equipment (D22 p. 2, D24 p. 1)

Response: Appendix B-1 in the DEIS identifies the Project Design Features/Best Management 

Practices/Mitigation Measures applicable to all alternatives. The measures for Watershed/Soils/Fish start

on page 12 of Appendix B. 

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#344. Please preserve the forest and do not decimate it (D22 p. 2) 

Response: The combined effects of past harvest and of lack of disturbance have resulted in a situation that 

does not meet the desired condition for the Snow Basin project area. The proposed alternatives are 

designed to meet the purpose and need by: (1) managing forest structure towards landscape HRV; (2) 

moving the landscape toward a condition of reduced risk of high severity and extent of disturbance; and 

(3) providing a supply of forest products to the public. (DEIS pp. 5-6). 

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#345. I do enjoy seeing big trees and big animals. My property is just over the hill from the Snow Basin project so it is 

a common area to visit. All the property owners in the area I have talked to would prefer to let the trees die as trees do 

naturally. (D23 p. 1)

Response: The Snow Basin project area will still have big trees and big animals. The combined effects of 

past harvest and of lack of disturbance have resulted in a situation that does not meet the desired condition 

for the Snow Basin project area. In addition, the 1990 Wallowa-Whitman National Forest Land and 

Resource Management Plan allocated 87% of the Snow Basin Project Area to Management Areas 1 and 3. 

(DEIS Table 3, p. 6). These management areas have an emphasis on commercial harvest of wood that is 

coincident to other management objectives. This is reflected in the Purpose and Need for the project to 

“provide a supply of forest products to the public.” (DEIS p. 6)

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#346. These precious wild areas need to remain this way! Do your job – protect our public lands, waters, health, 

wildlife ... citizens, not industry! (D24 p. 1)

Response: The Snow Basin project area is managed under the amended Wallowa-Whitman Land and 

Resource Management Plan and a variety of laws and regulations. These form a framework designed to 

provide a wide variety of ecosystem services to benefit public lands, waters, health, wildlife, citizens, and 

more. 

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#347. This proposal is a good example of the type of management plan that inherently engenders lack of trust between

those advocating for true multiple use management and professional land managers. In this case, the plan’s stated goal 

(fire suppression) seems a cover for less explicit goals – more timber harvest of large trees and further extending a road 

network, even “temporary” into national forest lands. (D26 p. 1)
Appendix C Snow Basin Vegetation Management Project FEIS

636

Response: The combined effects of past harvest and of lack of disturbance have resulted in a situation that 

does not meet the desired condition for the Snow Basin project area. The proposed alternatives are 

designed to meet the purpose and need by: (1) managing forest structure towards landscape HRV; (2) 

moving the landscape toward a condition of reduced risk of high severity and extent of disturbance; and 

(3) providing a supply of forest products to the public. (DEIS pp. 5-6). The ability to suppress undesired 

fires could be enhanced by some of the proposed activities, but fire suppression is not a primary goal of the 

project. 

In addition, the 1990 Wallowa-Whitman National Forest Land and Resource Management Plan allocated 

87% of the Snow Basin Project Area to Management Areas 1 and 3. (DEIS Table 3, p. 6). These 

management areas have an emphasis on commercial harvest of wood that is coincident to other 

management objectives. This is reflected in the Purpose and Need for the project to “provide a supply of 

forest products to the public.” (DEIS p. 6)

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#348. Large wildfire activity is increasing across the western US due to increased spring and summer temperatures 

and longer wildfire seasons (Westerling et al. 2006). The largest increases were found in mid-elevation forests in the 

Northern Rockies. This trend is expected to continue. Wales et al. (2007) cautions that active management approaches 

that reduce closed canopy forests could overshoot reductions in NRV levels. “The NRV for this landscape apparently 

does not support high levels of closed-canopy medium and large tree forests. Management direction to maintain these 

habitats should take this into consideration; objectives may be established to manage for more of this forest type than could

be easily sustained.” Contrary to this cautionary approach described by Wales et al. (2007), the Snow Basin preferred 

alternative employs every exception to the Eastside screens in order to log old and large trees. (D59 p. 60)

Response: The Wales et al. (2007) quotation in the comment is cautionary, but it cautions about trying to 

maintain too much of the landscape in closed-canopy and medium and large tree forests and implies that a 

lower level of closed-canopy and medium and large tree forests may be more appropriate in the area 

modeled for that particular study. The purpose and need of the Snow Basin project is to manage forest 

structure, composition and density towards landscape HRV and improve sustainability and to maintain and 

increase landscape resilience to reduce the risk of uncharacteristic disturbance. (see FEIS Chapter 1) 

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#349. The consequences of inaction must be considered. Short term impacts can be mitigated and must be accepted to 

achieve long term goals. (D29 p. 1)

Response: The effects of the No Action alternative are analyzed in the Chapter 3 of the DEIS for each 

resource area. Project Design Features/Best Management Practices/Mitigations can be found in Appendix 

B-1 of the DEIS. 

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#350. I cannot find specific references to the 21” no cut rule or the 300 foot RHCA buffer in the National Forest 

Management Act of 1976, National Environmental Policy Act of 1969, and the Endangered Species Act of 1973. (D37 

p. 2, D48, p. 1)

Response: While the “21” no cut rule and 300 foot RHCA buffer” are not found in the laws mentioned, 

the Wallowa-Whitman National Forest is managed according to its amended Forest Land and Resource 

Management Plan, which incorporates direction from the three laws mentioned above and additional laws. 

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#351. We recommend that Objective 3 be amended to read “Provide a sustainable supply of forest products for the 

public.” It underscores the commitment to actively manage the forest to deliver a diverse array of forest products that 

are essential to promote economic vitality in the region as well as to foster a healthy forest ecosystem. (D52 p. 3)

Response: “A sustainable supply of forest products for the public” is a more appropriate objective for the 

entire Wallowa-Whitman National Forest than for an area the size of the Snow Basin project area. 

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#352. My view of forest management by the US Forest Service is baffling at best. I see privately managed forest 

properties for sustained timber production as one of all-sized trees and smaller competing vegetation loads. However, 

FS managed lands are overloaded with brush and old trees. My uneducated conclusion is that this reflects fire based 

management by the Forest Service. It’s time that our forests are managed for sustained yield, decreased fire potential 

and contribution to the local economy. This includes cutting all diameter classes of trees, including 21” + dbh (D56 p. 

1)
Appendix C Snow Basin Vegetation Management Project FEIS

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#353. The US Forest Service increasingly has become a very poor neighbor. Landowners adjacent to FS lands look 

across the boundary at lands owned by their federal neighbors and ask “why don’t they reduce their fuel loads? Why 

don’t they treat the dwarf mistletoe and the other insect and disease epidemics?” This has become an extremely 

complex issue. (D63 p. 1)

Response: The Wallowa-Whitman National Forest is managed according to the amended WallowaWhitman Land and Resource Management Plan and a variety of laws and regulations. These form a 

framework designed to provide a wide variety of ecosystem services to benefit public lands, waters, health, 

wildlife, citizens, and more. The amount of work that can be accomplished under that plan is constrained 

by the federal Forest Service budget. 

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#354. It would be helpful to have a concise summary in the front of the document that compares the alternatives and 

clearly articulates the differences between the respective alternatives and how completely those different alternatives 

meet the Purpose and Need for Action. (D63 p. 2)

Response: The “Summary of the DEIS” has been expanded for the FEIS to include the information noted 

in the comment. 

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#355. My experience with the 21” diameter rule is that 21 inches does not make old growth. On Lookout Mountain in 

southeastern Baker County many of the stands had trees more than 28” in diameter that were less than 90 years old. 

(D74 p. 1)

#356. The diameter of a tree is not always an indicator of health or the age of the tree. General Land Office notes of 

the Original Survey describe Bearing Trees scribed here in 1884. Some of the ten inch diameter trees scribed then, still 

on the ground now are over three feet in diameter and some show only a few inches growth with still visible scribing. 

(D15 p. 2)

Response: Similar observations about the relationship of tree size to tree age in the Snow Basin project 

area can be found in the DEIS on page 66. 

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#357. Projects that propose vegetation management actions that aim to restore forest structure toward a more 

historical and resilient stand composition and density and to return natural disturbance to the landscape should reflect 

holistic landscape management, with an awareness of the effect of restoration activities on wildlife species, non-native 

species, soil and soil processes, and insect and disease risks. (D59 p. 2)

Response: Effects of the proposed alternatives on wildlife species, non-native species, soil and soil 

processes, and insect and disease risks can be found in Chapter 3 of the FEIS. 

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#358. The peer-reviewed literature warns that efforts at restoration of fire-adapted forests are jeopardized from 

economic pressure to cut larger trees than can be ecologically justified (Brown et al. 2004). The repercussions of 

succumbing to this economic pressure are heightened in relatively rare unlogged old growth forests that have a high 

value for conserving biodiversity (Noss and Cooperrider 1994; Strittholt and DellaSala 2001; Crist et al. 2009) and 

serve as refugia for sensitive terrestrial and aquatic species, have lower rates of invasions of non-native species, and 

provide reference conditions for understanding natural ecosystem processes (Crist et al. 2009). In these rare and 

ecologically complex old growth forests, there is no room for economic interests to corrupt restoration efforts. (D59 p. 

23)

Response: There are no unlogged old growth forests in the Snow Basin project area. The DEIS on p. 47 

states that approximately 94% of the project area has had previous partial cutting and the remaining 6% 

has had regeneration harvest. The partial cutting of preferred species such as ponderosa pine and western 

larch, combined with lack of disturbance, has allowed other species, such as grand fir and Douglas-fir, to 

increase in dominance. 

Pages 92 and 93 of the DEIS explain the rationale for removing 21”+ diameter trees in selected stands in 

the Snow Basin project. These trees are proposed for removal to restore conditions associated with Late 

Old Structure (LOS) in the project area, to remove ladder fuels that reduce fire mortality risk for ponderosa 

pine and western larch, and to maintain and restore aspen stands. 

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#359. Vegetation management across such a large area and especially removal of 43,000 large trees will accelerate the 

transfer of carbon from the forest to the atmosphere and exacerbate climate change. Effective mitigation of climate 

change requires changes across all sectors, including not only absolute reductions in the use of fossil fuels, but also 
Appendix C Snow Basin Vegetation Management Project FEIS

638

changes in sectors (like forestry) that manipulate living systems that are part of the global carbon cycle. There is an 

urgent need to retain existing carbon in living ecosystems across the entire planet. This is an additional reason to take 

a cautious approach that focuses on clear restoration and removing small trees, while retaining habitat values and 

large stores of carbon associated with large trees. (D64A p. 26)

#360. If the Forest Service claims that Snow Basin DEIS considers climate change in its proposal, why doesn’t it 

consider the incredible carbon sequestration that has occurred in these large trees and protect them for climate 

mitigation impacts for our society? What tree has sequestered more carbon faster than grand fir in the past 100 years? 

(D59 p. 24)

#361. Snow Basin threatens last 100 years of carbon sequestration. It is particularly concerning that an analysis that 

claims to respond to climate change issues could be so completely devoid of an analysis of carbon storage. A new 

publication clearly illustrates the widespread impact of forest harvest on the carbon cycle of North America (Masek et 

al. 2011). Masek et al. (2011) states: 

“While fire and insect damage remain the dominant disturbance mechanisms in Canada (Wulder et al. 2011), stands 

growing in the United States have a similar chance of being cleared or harvested as being affected by a “natural” 

disturbance event.” Other recent science has clarified the critical role of U.S. forests in the carbon cycle (Ryan et al. 

2010). This key science omitted from the Snow Basin DEIS. 

It is critical for the Snow Basin EIS to include an analysis of the impacts of the alternatives on total carbon storage 

because Snow Basin impacts forests at the subwatershed scale, a scale that is commonly used to assess large scale 

national forest trends of resources. Furthermore, in contradiction to the last 20 years of National Forest management 

on the Wallowa Whitman, Snow Basin threatens to remove over 40,000 trees greater than 21inches d.b.h. As stated 

earlier, if the average age of trees over 21” that would be cut in the Snow Basin planning area is 200 years old, 

removing these 43,679 trees would cost us 8,735,800 individual years of carbon sequestration. The best available 

science shows that even the most restrained thinning will result in a net reduction in forest carbon storage (even after 

considering any beneficial effect on carbon emissions from fire). See Mitchell et al. (2009). However, Snow Basin 

doesn’t just propose commercial thinning; it proposes widespread old growth logging combined with heavy 

commercial thinning across 12,000 acres, jeopardizing landscape carbon storage that has been ongoing for a century. 

As the analysis continually points out, many of the grand fir trees are approximately 100 years old. It is possible that 

the grand fir trees in the 100 year age/21 inch size range have sequestered more carbon than any other species across 

the project area in the past 100 years. Now this entire ecosystem service of great importance to our society will be 

eliminated. 

It’s time for the agencies to walk the talk and do the things it claims to be doing. Recommended carbon storage 

strategies include:

• Letting forests grow more and logging them less, by protecting all mature and old growth forests 

and large trees, adopting much longer harvest rotations (i.e. letting forests grow larger and longer 

between harvests). 

• Retain more live and dead trees during harvest, so that stand level carbon stores are not depleted as 

dramatically during harvest. Thinning is much preferable to regeneration harvest. Oregon forests 

can grow for centuries without regen harvest. 

• Reduce demand for wood products by recycling, using wood sparingly, and making things to last, so 

they do not need to be replaced as often. 

• Avoid carbon losses from soil by reducing soil disturbance from roads, logging equipment, and 

grazing. 

• In an era of global climate change, when considering traditional development scenarios that involve 

forest degradation, energy consumption and resource use, the “no action’ alternative needs to be 

given more careful consideration. 

A respected conservation authority notes several related strategies -- 

Among the land-use and management practices likely to maintain forest biodiversity and ecological functions 

during climate change are (1) representing forest types across environmental gradients in reserves; (2) 

protecting climatic refugia at multiple scales; (3) protecting primary forests; (4) avoiding zones for adjustment 

of reserve boundaries; (6) practicing low-intensity forestry and preventing conversion of natural forests to 

plantation; (7) maintaining natural fire regimes; (8) maintaining diverse gene pools; and (9) identifying and 

protecting functional groups and keystone species. Good forest management in a time of rapidly changing 

climate differs little from good forest management under more static conditions, but there is increased 

emphasis on protecting climatic refugia and providing connectivity (Noss 2001). 
Appendix C Snow Basin Vegetation Management Project FEIS

639

How the National Forests are managed has a real and substantial impact on how much carbon is stored. Managementdriven deviations from business-as-usual can lead to significant increases or decreases in carbon storage. (Depro et al. 

2008: “Our analysis found that a ‘no timber harvest’ scenario eliminating harvests on public lands would result in an 

annual increase of 17-29 million metric tons of carbon (MMTC) per year between 2010 and 2050 – as much as a 43% 

increase over current sequentration levels on public timberlands and would offset up to 1.5% of total U.S. GHG 

emissions. In contrast, moving to a more intense harvesting policy similar to that which prevailed in the 1980s may 

result in annual carbon losses of 27-35 MMTC per year between 2010 and 2050.) See also Shanks (2008). 

We simply can’t solve the climate problem without including forests in the solution. Forestry activities still cause 20% 

of global emissions of greenhouse gases. According to Peter Curtis, professor and chair of evolution, ecology and 

organismal biology at Ohio State University. “Biological carbon storage, mostly in forests, is one of those little wedges 

along with other ones you might think of, such as increased energy efficiency, using fluorescent light bulbs and the like. 

There is not one silver bullet. (Ohio State University press release 2008). The technical and financial barriers involved 

in using forests to mitigate climate change are low compared to other wedges. “In forestry and agriculture, both costs 

and investments are relatively low. Here the implementation challenges are technical rather than economical, namely, 

designing effective policy and an effective way of measuring and monitoring the abatement.” (McKinsey & Company 

2009). (D59 pp. 85-87)

#362. There is no de minimus contribution to the climate problem. This fact is already acknowledged by the courts. 

Former D.C. Circuit Judge Wald wrote in a 1990 dissenting opinion, which was recently quoted with unanimous 

approval by the Ninth Circuit in Center for Biological Diversity v. NTSA: 

[W]e cannot afford to ignore even modest contributions to global warming. If global warming is the result of 

the cumulative contributions of myriad sources, any one modest in itself, is there not a danger of losing the 

forest by closing our eyes to the felling of the individual trees? 538 F.3d at 1217. 

Similarly, the U.S. Supreme Court in Massachusetts v. EPA, 127 S.Ct. 1438, 1455 (2007) noted that one cannot avoid 

responsibility to reduce and mitigate the climate problem by attempting to minimize the scale of one’s contribution to 

the problem. (“While it may be true that regulating motor-vehicle emissions will not by itself reverse global warming, 

it by no means follows that we lack jurisdiction to decide whether EPA has a duty to take steps to slow or reduce it. 

...In sum, ...[t]he risk of catastrophic harm, though remote, is nevertheless real. That risk would be reduced to some 

extent if petitioners received the relief they seek.”) (D59 p. 87)

#363. The Snow Basin proposal does not even evaluate the impacts of the proposed actions on carbon sequestration. 

(D59 p. 83)

Response: The Intergovernmental Panel on Climate Change has summarized the contributions to climate 

change of global human activity sectors in its Fourth Assessment Report (IPCC 2007). The top three 

anthropogenic (human-caused) contributors to greenhouse gas emissions (from 1970-2004) are: fossil fuel 

combustion (56.6% of global total), deforestation (17.3%), and agriculture/waste/energy (14.3%). IPCC 

subdivides the deforestation category into land use conversions, and large scale deforestation. 

Deforestation is defined as removal of all trees, most notably the conversion of forest and grassland into 

agricultural land or developed landscapes (IPCC 2000). 

The Snow Basin proposed project activities do not fall within any of these main contributors of greenhouse 

gas emissions. Forested land will not be converted into a developed or agricultural condition. Forest 

stands are being retained and thinned to maintain a vigorous forested condition that can continue to support 

trees and sequester carbon long-term.

This project is also consistent with IPCC recommendations for land use to help mitigate climate change. 

The 2007 IPCC report summarizes sector-specific key mitigation "technologies". For the forestry sector, 

the report recommends forest management including management to "improve tree species" and increase 

biomass. The proposed action is consistent with these recommendations because it will improve residual 

tree growth and will increase forest resilience to disturbances that result in an even greater loss of 

sequestered carbon. 

Timber management projects can influence carbon dioxide sequestration in three main ways: (1) by 

increasing new forests (afforestation), (2) by avoiding their damage or destruction (avoided deforestation), 

and (3) by manipulating existing forest cover (managed forests). Land-use changes, specifically 

deforestation and regrowth, are by far the biggest factors on a global scale in forests’ role as sources or 

sinks of carbon dioxide, respectively (IPCC, Intergovernmental Panel on Climate Change, 2000). Projects 
Appendix C Snow Basin Vegetation Management Project FEIS

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that create forests or improve forest conditions and capacity to grow trees are positive factors in carbon 

sequestration. The proposed action falls into this category.

References

IPCC. 2007. Intergovernmental Panel on Climate Change (IPCC), Fourth Assessment Report: Climate 

Change 2007, Synthesis Report, section 2, Causes of Change, 2007. IPCC, Geneva, Switzerland. 3 pp. 

http://www.ipcc.ch/publications_and_data/ar4/syr/en/spms2.html

IPCC. 2000. Intergovernmental Panel on Climate Change (IPCC), Special Report on Land Use, Land Use 

Change and Forestry, Summary for Policy Makers, 2000. IPCC, Geneva, Switzerland. 20 pp. 

http://www.ipcc.ch/ipccreports/sres/land_use/index.php?idp=0

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#364. DEIS: “Restore and maintain resilient and sustainable-forested ecosystems, specifically by creating open-grown 

ponderosa pine, western larch and Douglas-fir stands dominated by the largest trees growing on the site.” 

This purpose starts with vague ecological principles, then quickly narrows to creating open-grown forests, but open 

grown forest does not reflect a sufficiently nuanced view of the complex forest ecosystems this landscape can sustain. 

Also, the purpose of open grown forests does not apply to some of the more moist sites proposed for treatment by this 

project. (D64A, p. 4)

Response: The purpose in the FEIS no longer includes the creation of open-grown stands. 

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#365. A compelling ecological need that is clearly identifiable and warrants the proposed action is needed. Returning 

stands to the HRV should not be used as a justification for landscape-scale commercial thinning. This would clearly be 

counterproductive to true restoration. (D59 p. 1)

Response: The need for the project is represented by the difference, or ‘gap’, between the area’s existing 

condition and the desired condition, which is derived from direction contained in the amended WallowaWhitman Forest Land and Resource Management Plan (FEIS Chapter 1). 

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#366. Objective 2 is to move the landscape toward a condition of reduced risk of high severity and extent of 

disturbance, taking into account changes in climate, by reducing stocking, canopy closure, and fire-insect sensitive 

species, and reducing mistletoe infected and host trees. While managing to reduce disturbance sounds good on its face, 

disturbance is what creates and sustains forests in this part of the world. (D64A, p. 6) 

#367. Restoration requires a recognition that this landscape is suffering in part from a lack of natural disturbance, so 

it may not be in the best interests of the forest to reduce the extent of fire, or even the severity of fire. (D64A, p. 6) 

Response: The purpose and need has been clarified in the FEIS (Chapter 1). The part of the purpose and 

need that refers to disturbance states: “Maintain and increase landscape resilience to reduce the risk of 

uncharacteristic disturbance.” The proposed activities for the Snow Basin project area will increase the 

extent of disturbance through the application of prescribed fire. 

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#368. To bring Snow Basin more in line with proposed Wyden Legislation, prescribed fire should be applied with the 

objective of carefully reintroducing this natural disturbance, where fuels reduction is one of the benefits, rather than 

the primary goal. (D64A p. 9)

Response: The proposed prescribed fire treatments are designed to manage forest structure, composition 

and density towards landscape HRV and improve sustainability by thinning small diameter trees of all 

species, promoting mortality of less desirable species such as grand fir, and maintaining SSLT structure. 

They are also designed to maintain and increase landscape resilience to reduce the risk of uncharacteristic 

disturbance by reducing the development of ladder fuels to reduce the risk of a running crown fire and to 

reduce fuel levels to allow for safer and more effective fire suppression to limit the extent of 

uncharacteristic wildfire. 

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#369. Canopy fuels are not the most hazardous aspect of a forest fuel profile. Treating surface and ladder fuels are far 

higher priorities. (D64A p. 24)

Response: Reducing surface fuels, increasing the height to live crown, reducing canopy bulk density, and 

reducing forest canopy continuity comprise the most effective strategy for reducing crown fire occurrence 

and severity (Van Wagner 1977; Agee 1996; Graham et al. 1999; Scott and Reinhardt 2001; Cruz et al. 
Appendix C Snow Basin Vegetation Management Project FEIS

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2002; as cited in Graham et al. 2004). To address the need to maintain and increase landscape resilience to 

reduce the risk of uncharacteristic disturbance, all four types of fuel reduction are needed. Resilience will 

be increased by having conditions that promote surface fire. The expected change in fire behavior as a 

result of analyzed treatments is summarized in the Fuel Loading and Fire Potential section of the effects 

analysis and indicates a change from Passive Crown Fire to Surface fire in stands treated. 

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#370. Prescribed fires were introduced to reduce a wildfire risk but have become the source of some of the worst forest 

wildfires we have ever had. (D15 p. 2)

Response: Application of prescribed fire carries risk. Policies, procedures, training, and use of qualified 

personnel in planning and implementing prescribed burns can effectively reduce that risk to an acceptable 

level. Nationally, over 36,000 prescribed burns were conducted by the Forest Service between 2003 and 

2010, 78 of which escaped (0.2%). During that same period 903 burns were conducted on the WallowaWhitman National Forest, none of which resulted in an escaped fire.

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#371. The best-available science on fuels reduction repeatedly states that large trees should be protected (D59 p. 4)

Response: Table 67 in the DEIS (p. 117) illustrates the principles in reducing fire behavior potential in 

large fires. Retention of larger trees is one of those principles where the larger trees have thicker bark and 

greater height to the base of the live crown. The proposed removal of 21”+ dbh trees for the Snow Basin 

project is targeted in part on grand fir, which tends to have thinner bark. Prior harvest and lack of 

disturbance have resulted in an uncharacteristic distribution of large grand fir that, if not removed, will 

continue to support future propagation of high levels of fast-growing understory trees that will develop 

into ladder fuels, perpetuating the fuels issue that currently exists. 

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#372. Large fires are climatically driven and fuels reduction treatments can be insignificant to prevent fire spread 

under these conditions. However, the post-fire habitat is significantly degraded by the logging that happens in the 

name of fuels reduction prior to the fire. (D59 p. 9)

Response: Fuel reduction effectiveness is well documented and supported by local experience in NE 

Oregon. (See FRCC analysis & FMA Plus outputs on expected changes in fire behavior, DEIS pp. 117-

127.) Relative to post-fire habitat, silvicultural and fuels reduction treatments will leave the largest, most 

fire and decay (if dead) resistant trees.

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#373. Snow Basin aims to create more open conditions at the landscape level, build over 10 new miles of temporary 

road, open up 40 miles of closed roads, increasing access throughout the project area. There is a positive relationship 

between access and human caused fire starts. OHV use is cited in many places in the DEIS as being common in the 

project area. (D59 p. 9) The road networks required for logging operations create an increased number of ignition 

points for wildfires. A substantial increase in ignitions and fire frequency in Russian boreal forests (Achard et al. 

2006) has been attributed, in part, to roads built for logging and mining (Dienes 2004; Bradshaw et al. 2009). (D59 p. 

15)

Response: The fire occurrence analysis is on page 114 of the DEIS. Road density has not been found to 

impact fire occurrence on the Wallowa-Whitman NF, as the majority of fires are started by lightning. The 

human starts are primarily hunter ignited (warming fires) during the fall. In general, increased road access 

improves fire suppression response and as a result lowers overall fire risk on the Wallowa-Whitman.

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#374. It seems like fuels reduction should be limited to dry brushy stuff choking the forests, not the forests themselves. 

(D30 p. 1)

Response: Page 117 of the DEIS identifies important principles that can be applied to reduce fire 

behavior potential in large fires. Due to the existing condition in the Snow Basin project area, several fuel 

types are proposed for treatment. 

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#375. Recent levels of fire occurrence make it highly unlikely that fuel treatments could affect fire behavior even in the 

forest types that tend to burn most frequently (Rhodes and Baker 2008). (D59 p. 55) 

#376. The following is a brief outline representative of the range of current scientific information that should be 

incorporated in revising the proposed decision and management actions of the Snow Basin Project: (D59 pp. 36-37)
Appendix C Snow Basin Vegetation Management Project FEIS

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• Fuel treatments do not always reduce fire severity in the relatively rare cases when fire affects 

treated areas. 

• Fuel treatments in many widespread forest types are likely to be ineffective in restoring natural fire 

behavior (Veblen 2003; Schoennagel et al. 2004; Noss et al. 2006; Baker et al. 2007) 

Response: Fuel reduction effectiveness is well documented and supported by local experience in NE Oregon. 

(See FRCC analysis & FMA Plus outputs on expected changes in fire behavior, DEIS pp. 117-127.) 

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#377. The following is a brief outline representative of the range of current scientific information that should be 

incorporated in revising the proposed decision and management actions of the Snow Basin Project: 

Where snag densities are relatively higher, these areas do not tend to burn at higher severities (Bond et al. 2009). (D59 

p. 36)

Response: The contribution that snags make toward fire intensity depends upon the size, number, state of 

decay, proportion of fine fuels presents, and adjacent fuels within the stand. In the 1996 Tower and 

Summit fires for example, the high snag density due to spruce budworm defoliation contributed to the 

development of extreme fire intensity. This issue was not addressed in the FEIS as fire risk due to snags 

was not identified as a concern. 

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#378. The following is a brief outline representative of the range of current scientific information that 

should be incorporated in revising the proposed decision and management actions of the Snow Basin 

Project: (D59 p. 36)

Fuel treatments are not effective in maximizing carbon storage relative to fire alone (Mitchell et al. 2009). 

Response: While carbon storage is an important ecosystem service provided by forests, the lack of 

disturbance in the Snow Basin project area has allowed higher levels of biomass (carbon) accumulation 

than might have otherwise occurred. The 1990 Wallowa-Whitman National Forest Land and Resource 

Management Plan allocated 87% of the Snow Basin Project Area to Management Areas 1 and 3. (DEIS 

Table 3, p. 6). These management areas have an emphasis on commercial harvest of wood that is 

coincident to other management objectives. Other parts of the landscape, such as the Wild and Scenic 

River corridor (Management Area 15), are more suited to carbon storage. Once fuel loading is at desired 

levels and the stand structures are closer to the desired condition, prescriptions could be designed to 

optimize carbon storage while maintaining desired vegetation conditions. 

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#379. The following is a brief outline representative of the range of current scientific information that 

should be incorporated in revising the proposed decision and management actions of the Snow Basin 

Project: (D59 p. 37)

Management recommendations based on scientific forest and fire ecology research: 

Require sound scientific analysis and disclosure of the potential ecological costs and benefits of fuel 

treatments, prior to initiating treatments. 

Response: Effects of fuel treatments are analyzed in Chapter 3 of the FEIS. 

 

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#380. It may be appropriate to treat fuels in the wildland urban interface, but the WUI must not be defined too 

broadly, because fire hazard to communities can be effectively reduced by treating the area immediately adjacent to 

structures and this “structure ignition zone” is usually on non-federal lands. Fire is an important ecological process 

that needs to be restored on public lands, so the WUI fire problem should be framed as a structure-ignition problem 

rather than an ecological problem, and the solution generally lies with the private property owners. See Cohen (2008). 

Fuel treatments on federal land in the WUI should be coupled with efforts to make communities fire resilient, not just 

to facilitate fire suppression. (D64A, p. 6)

Response: Fuels treatments proposed adjacent to private land in WUI zones have been designed to meet 

the Purpose and Need (FEIS Chapter 1), with a side benefit of reducing the risk of undesirable wildfire 

effects on private lands and private structures. WUI areas within the Snow Basin project area have been 

analyzed and prioritized in the “Baker County Community Wildfire Protection Plan”. When work is 
Appendix C Snow Basin Vegetation Management Project FEIS

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approved on Forest Service land, the Oregon Department of Forestry works with adjacent private land 

owners to treat adjacent forest land. 

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#381. Logging changes not only microclimatic conditions as described above, but can also change stocking densities 

and patterns of trees, intercrown spacing, and other forest attributes such as plant species composition. Research in

western North America indicates that logging related alterations in stand structure can increase both the risk of 

occurrence and severity of subsequent wildfires through changes in fuel types and conditions (Thompson et al. 2007). 

(D59 p. 15)

Response: Thompson et al. (2007) analyzed conditions after two large, weather-driven wildfires in 

southwestern Oregon in 1988 and 2002 and looked at the effect of salvage logging and reforestation after 

the 1988 fire on the 2002 fire. To reduce the effect of logging-related alterations in stand structure on the 

occurrence and severity of subsequent wildfires in the Snow Basin project area, logging-generated slash 

would be reduced to desirable levels after the proposed harvest and only about half of the Snow Basin 

project area is proposed for treatment (burning only or logging and burning). In addition, the regeneration 

harvests have been dropped from the FEIS. 

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#382. Logging can alter fire regimes by changing the amount, type and moisture content of fuels (Perry 1994; 

Weatherspoon & Skinner 1995: Thompson et al. 2007; Krawchuk & Cumming 2009). Large quantities of logging slash 

created by harvesting operations can sustain fires for longer than fuels in unlogged forest and also harbor fires when 

conditions are not suitable to facilitate flaming combustion or the spread of fire (Cochrane & Schulze 1999). In 

Canadian mixedwood boreal forests, fire initiation following lightning strikes is more likely to occur in harvested areas 

because of increased fine fuels resulting from logging slash and this effect can remain for 10-30 years following logging 

(Krawchuk & Cumming 2009). D59 p. 15)

Response: Post treatment activities are designed and described in the analysis to eliminate the fuels added 

to the fuelbed following logging activity, thus eliminating increased fire risk due to logging slash. Slash is 

generally treated within one year of logging. The Wallowa-Whitman National Forest prioritizes treatment 

of created/activity slash over treatment of natural fuels. 

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#383. Prescriptions designed to reduce fire severity will have the unintended effect of prolonging the persistence of 

mistletoe in these stands, because under natural conditions, mistletoe is controlled by high-severity fire that kills host 

trees over large areas. If the HRV included only moderate amounts and distribution of mistletoe, then the HRV must 

also have included a large amount and distribution of high-severity fire. (D64A, p. 7)

Response: Historic moderate levels of mistletoe, particularly in ponderosa pine, do not necessarily 

provide a measure of historic fire intensity. However, it is well established that high intensity (not high 

severity) fire is effective at controlling mistletoe, particularly for late seral host mistletoe species such as 

grand fir. Increasing fire frequency is generally associated with reduced mistletoe occurrence (Fitzgerald 

2002). Underburning where some crown scorch is occurs has been found to limit levels of mistletoe 

infestation, both through the effects of crown scorch on mistletoe survival and the tendency for mistletoe 

infected host trees to be overall less resistant to crown scorch and thus experience high levels of mortality 

following surface fire (Conklin & Geil, 2007). Prescribed burning plans allow for crown scorch in 

mistletoe areas to reduce ladder fuels and to eliminate some mistletoe. 

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#384. Near concentrated human habitation, simple localized “fire-smart” management actions around residential 

facilities effectively can address fire threats without any need for widespread levels of excessive interior forest logging 

across the landscape. Our challenge, in the new and emerging paradigm, is to make certain that homes are protected 

so that we can allow wildland fire to do its vital and life-giving work in our forests. We need to stop our futile battle 

against wildland fire and learn to live well with fire, reminding ourselves that western U.S. conifer ecosystems evolved 

with fire and are adapted to it. (D59 pp. 53-55)

Response: Community/WUI protection will benefit from the proposed Snow Basin treatments, but it is 

not an objective of this project. About half of the Snow Basin project area will remain untreated, including 

areas characterized by a mixed or high severity fire regime. 

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#385. See Hanson (2010). (D78 pp. 12-13)
Appendix C Snow Basin Vegetation Management Project FEIS

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Response: Hanson (2010) focuses on several issues, including the idea that high intensity fire is missing 

from the ecosystem. Untreated areas with denser stand structure will continue to experience higher 

severity fire in the Snow Basin Project Area. 

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#386. HRV (even in sites dominated by early seral species like ponderosa pine) included a mix of less dense and more 

dense areas which exhibited a variety of fire intensities – not all low severity, but rather a mix that included moderate 

and high severity fire. Snow Basin seems to assume that the HRV was overwhelmingly dominated by low-density 

stands created by exclusively low-severity fire regimes (DEIS p. 58). To assume this is to under-appreciate the 

complexity of natural systems and the reality that a wide range of fire and vegetation conditions existed. The goal 

should not be a uniform low severity fire regime, but rather a wide mix of tree densities in patches of varying sizes. 

This can be done by allowing natural fire regimes to operate, or by leaving significant areas untreated when planning 

fuel reduction projects (Hessburg 2004, Baker et al. 2006). (D64A, p. 5, 19-20)

Response: The purpose and need of the Snow Basin project is to manage forest structure, composition 

and density towards landscape HRV and to maintain and increase landscape resilience to reduce the risk of 

uncharacteristic disturbance. Once the risk of uncharacteristic disturbance has been reduced, natural fire 

regimes will be allowed to operate over a greater portion of the landscape with the goal of producing a 

wide mix of tree densities and patch sizes. At least half of the Snow Basin project area will remain 

untreated. 

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#387. Unit 311 is an example of the previously heavily managed snag-deprived landscape that will now be 

mechanically thinned again. On the public field trip on 9/3/2009, I questioned that fire alone could be introduced into 

Unit 311. The fire ecologist was on the tour and agreed that fire alone could be used in this stand. (D59 p. 89)

Response: The 1990 Wallowa-Whitman National Forest Land and Resource Management Plan allocated 

87% of the Snow Basin Project Area to Management Areas 1 and 3. (DEIS Table 3, p. 6). These 

management areas have an emphasis on commercial harvest of wood that is coincident to other 

management objectives. This is reflected in the Purpose and Need for the project to “provide a supply of 

forest products to the public.” (DEIS p. 6)

Relative to the stand in question, the statement made by the fire representative was that fire could be used 

as a stand-alone tool, however doing so would be less effective and take multiple entries to reach the 

desired objective of fuels reduction than the proposed action, and would not meet the objective of density 

reduction. To reduce density to the prescribed level would require a moderate to high severity prescribed 

fire, which would be very difficult to implement. 

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#388. We are not opposed to any and all effects on the canopy, but we object to the prevalent and often inappropriate 

use of crown fire and canopy fuels as an excuse to remove medium and large trees over large areas. The FS should 

consider alternative canopy treatments that are small and patchy, instead of extensive and continuous. Pruning lower 

branches should also be considered as a viable canopy treatment. (D64A p. 25)

Response: The primary reason for removing medium and large trees is to protect medium and large fireresistant tree species (such as ponderosa pine and western larch) by removing medium and large grand fir. 

Increasing crown base height is one component of reducing crown fire risk and can be achieved in part by 

pruning. However pruning alone does not eliminate crown fire potential. Experience on the WallowaWhitman National Forest has shown that once stand structure, species composition and density are within 

the historical range of variation, the reintroduction of fire on a continuing basis results in patchier 

conditions of density and structure. 

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#389. The following is a brief outline representative of the range of current scientific information that 

should be incorporated in revising the proposed decision and management actions of the Snow Basin 

Project: (D59 p. 36)

The scientific data contradicts the assumptions that, prior to fire suppression, wildland fire in eastern 

Oregon’s forests burned only at low-intensity levels and patches of high-intensity fire are somehow 

“uncharacteristic” or unnatural. We now know that forests of the intermountain west, including ponderosa 

pine forest, have burned at various severities historically, and high-severity fire is a natural part of this mix 
Appendix C Snow Basin Vegetation Management Project FEIS

645

(Pierce et al. 2004; Sherriff and Veblen 2006; Baker et al. 2007; Hessburg et al. 2007; Sherriff and Veblen 

2007; Klenner et al. 2008; Whitlock et al. 2008; Baker 2009).

Response: We concur with the author’s comment that historic fires in eastern Oregon probably burned at 

a mix of intensities depending upon the vegetation types and conditions, time of season, location, weather, 

etc. in which they were burning. Eighty-four per cent of the Snow Basin project area is a warm dry type 

and the expected historical fire intensity, for the majority of the analysis area, would have been low 

frequency, low to moderate intensity fire. Untreated areas in the Snow Basin project area would continue 

to have higher fire severity, even within the warm dry types (DEIS Table 70, p. 122). 

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#390. Despite the DEIS’s rosy vision of the impacts of widespread logging and heavy log traffic on the project area 

roads, the reality is much different. The Snow Basin DEIS states at 196: “Sediment does not appear to be coming 

from unstable streambanks but instead roads in the Snow Basin project area. Surface erosion has been observed along 

roadways in some areas. Roads can provide a substantial source of sediment and a mechanism for delivering sediment 

to the stream systems.” If the Forest Service’s approach is so effective, why is sediment currently eroding into streams 

in the project area? The effectiveness of BMPs reduces with time. The Snow Basin DEIS uses the currently degraded 

condition described in the DEIS as a baseline to assess the “watershed improvements” from BMPs. (D59 p. 18)

Response: WEPP modeling was used in the FEIS to identify areas where BMPs could be applied to 

improve road drainage and reduce road-related sediment delivery from critical road segments. Critical road 

segments are proximal to stream channels without adequate existing BMPs. This modeling is summarized 

in the Aquatics/Hydrology section of the FEIS (under the sediment subheading). The complete 

analysis/modeling can be found in the Aquatics/Hydrology report in the Project Record. The need for road 

maintenance to maintain the effectiveness of BMPs is recognized in the DEIS on page 148, and accounted 

for in the DEIS effects analyses on pages 166-168. 

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#391. Stream Temperatures

“Most stream temperatures were below the applicable redband trout standard in the project area. 

However, monitoring at the mouth of Little Eagle Creek showed temperature standards were exceeded by 

over 1 degree F on average” DEIS at 149 and 169. While the DEIS states that the reasons for these elevated 

stream temperatures in Little Eagle Creek are uncertain, it does list the following possibility: 

“Stream temperatures may be elevated as a result of pre-INFISH past harvest that may have removed large 

trees in the RHCA that moderated stream temperature.” DEIS at 149. While RHCA’s are an important 

management designation, the overall watershed condition impacts water quality. How will removing over 

40,000 trees greater than 21” DBH and a large portion of the mature trees in the 15” 20.9” DBH range affect 

stream temperatures? Obviously this will reduce shading across the watershed. (D59 p. 68) 

Response: The DEIS on page 149 also notes another reason for higher stream temperatures - diversions 

by the Brooks Ditch. The Brooks Ditch reduces flow in Little Eagle Creek by approximately 75%. 

Watershed shading outside of RHCAs does not affect stream temperatures because shade does not reach 

the water surface. See the stream temperature section in the FEIS for additional information. 

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#392. Stream sedimentation. The DEIS states at 163: “Direct effects on sedimentation are possible from 

implementation of this project. For instance, sediment eroded from unpaved roads and delivered to stream channels at 

stream crossings or along road segments in close proximity to streams may impact water quality. Numerous studies 

have shown that forest roads can have a significant impact on the hydrology and sediment yield of forested watersheds. 

Wemple et al. (1996) found that nearly 60% of the road network in study watersheds in the western Cascades drained 

into streams and gullies. In turn, roads can serve as a link between sediment sources areas and stream channels.” (D59 

p. 68)

Response: The monitoring plan in the FEIS has been modified to include pebble count surveys to 

determine the fine sediment component of stream substrate on Eagle and Little Eagle Creeks. See 

Appendix B. 

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Appendix C Snow Basin Vegetation Management Project FEIS

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#393. The DEIS states at 145: “In addition to the 7 surveyed streams, there are 30 miles of perennial or intermittent 

fish bearing, 114 miles perennial and intermittent non-fish bearing and over 200 miles of ephemeral draws within the 

Snow Basin project area. Of the total miles of stream or ephemeral draws in the project area, 9% are perennial or 

intermittent fish bearing, 9% are perennial and intermittent non-fish bearing and 82% are ephemeral draws.” What 

measures are being used to protect the ephemeral draws which constitute the majority of the channel network? (D59 

pp. 68-69) 

Response: Ephemeral draws do not have an active channel system (evidence of scour and/or deposition) 

and typically experience only very rare if any occurrences of surface flow. The Wallowa-Whitman Forest 

Plan does not allow yarding down ephemeral draws (Watershed Standard 21).

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#394. With regards to these intermittent and ephemeral draws, the DEIS states at 176: “Riparian obligate 

vegetation such as willows, sedges, and alders provide bank stability, shade, and nutrient inputs for streams 

and upslope conifers typically provide shade and woody debris inputs to the channel and riparian area. 

Intermittent drainages have less well-developed riparian vegetation, often not supporting riparian obligate 

vegetation. Ephemeral draws often have no riparian vegetation associated with them.” This indicates that 

the majority of the channel network is either lacking well-developed riparian vegetation, or has none at all. 

These areas are not able to trap or filter sediment effectively. Additionally, the DEIS states at 180 that 

“observations of Category IV intermittent streams show that intermittent streams in general do not have 

adequate quantities of large woody debris to support channel long-term stability and sediment retention.”

Despite the lack of adequate riparian vegetation in intermittent and ephemeral draws, the DEIS proposes to 

reduce the size of the RHCA buffer from to just 50 feet from intermittent streams (DEIS at 184). This runs 

counter to the best available science. (D59 p. 68-69). 

Response: The statement on page 176 of DEIS characterizes expected vegetation in intermittent and 

ephemeral draws. It is not an assessment that rates condition of these systems in the Snow Basin project 

area. No harvest is planned within 100 feet of category 4 streams, with exceptions for units where a road is 

at least 50 feet from category 4 stream. In these situations, the boundary will be the road at the bottom of 

the unit (see Chapter 2 of FEIS). 

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#395. Moreover, the DEIS states at 164 “When it is not possible to exclude RHCAs from operations equipment would 

operate within guidelines provided in the project PDFs. Skid trails in RHCAs would be kept as few as possible and 

generally only be allowed where it is not possible to move logs to the landing without crossing an RHCA. Skidding 

across Category 4 streams and ephemeral channels/draws will be allowed, but would only be done at sites designated 

by the sale administrator or District Hydrologist and will be at right angles to channels. Suitable crossings would use 

corduroy log crossings or other crossings that will avoid impacts. Damaged stream banks and crossings would be 

reshaped to stable conditions. Within RHCAs, where soil has been exposed by equipment, equipment would be 

operated on slash. Table 92 shows units where skid trails may cross RHCAs.”

Table 92 lists the units where skidding may take place in RHCAs.

Despite stating that there is a low risk of sediment delivery to channels from this project, the DEIS identifies 

that the greatest potential to increase sediment delivery rates during timber harvest activities is to the 

intermittent tributaries of units 12, 14, 20, 27, 33, 39, 40, 54, 71, 103, 106, 112, 119, 121, 128, 129, 137, 141, 

207, 224, 244, 249, 251, 259, 261, 266, 301, 301, 302, 307, 311, 312, 350, 400, 401, 406, 407, 408, 410, 415 and 

423. These units may have intermittent channels within the unit that will require an RHCA and equipment 

exclusion buffer to ensure that sediment will not be delivered to the channel. Intermittent RHCAs will be 

applied to intermittent channels in project units identified on maps and then field verified during project 

layout.

Nonetheless, the DEIS states at 165: “With the application and monitoring of Best Management Practices 

(BMPs), project design features, including equipment and harvest exclusion zones in RHCAs no direct 
Appendix C Snow Basin Vegetation Management Project FEIS

647

effects on site hydrology and delivery of sediment generated by harvest activities is expected from the Snow

Basin Project.”

The PACFISH RHCA widths are inadequate to protect these types of streams (non-fish bearing perennial and 

intermittent streams) from increased sediment delivery from upslope sediment production, as noted in the aquatic 

assessment for the Interior Columbia Ecosystem management Project. Logged areas and roads within RHCAs act as 

sources of elevated erosion and sediment delivery; roads within RHCAs are a particularly acute source of channelized 

and non-channelized sediment delivery to streams. The outer 100 feet of an RHCA cannot trap sediment from a road 

constructed downslope in the inner 100 feet of an RHCA. (D59 pp. 69-70) 

#396. There are 19 units where logs will be skidded through RHCAs. What makes these treatment areas more 

important than protecting RHCAs? The FS should consider dropping units that cannot be accessed from existing 

roads, especially those that would require degrading riparian areas. This can help achieve a more optimal mix of 

treated and untreated (or commercially and non-commercially treated areas) that achieve a better mix of restoration 

benefits. (D64A p. 23)

Response: In all alternatives, to reduce the risk of sediment delivery from units within RHCAs, forwarder logging 

systems (with grapple piling and burning) are now proposed. This also eliminates the temporary roads needed for 

logging in RHCAs. The WEPP modeling in the FEIS reflects this logging system change. The FEIS analysis was 

improved by using WEPP to model erosion and sediment delivery on units perceived as highest risk. The highest risk 

units are those nearest to streams. Results show a very low risk of sediment delivery from these units. 

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#397. The PACFISH RHCAs on fish-bearing streams are not adequate to fully protect streams under all 

conditions. Quigley and Arbelbide (1997) noted that 300 foot wide RHCAs around streams may not be 

adequate to prevent increased sediment delivery to streams in some areas. There is a greater than 25% 

probability of sediment delivery to streams on a 30 percent slope with a 100 foot wide, fully functional, 

RHCA based on the analysis in Quigley and Arbelbide (1997). For slopes of 50% abutting intermittent 

stream channels, the aquatic assessment in Quigley and Arbelbide (1997) estimated buffer widths of more 

than 400 feet from each side of the stream would be needed to prevent sediment delivery in 95% of cases, 

although this, too, is undisclosed. The DEIS for the Interior Columbia Ecosystem Management Project 

(hereafter “ICBEMP”) included methods to expand RHCA widths based on slope steepness, in order to 

provide more protection from sediment delivery to smaller streams (USFS and USBLM, 1997b). These 

methods result in RHCAs with widths significantly greater than 100 feet on intermittent streams with slopes 

greater than about 15%.

Other applicable scientific literature has noted RHCAs wider than those of PACFISH are necessary to 

protect aquatic resources. Damage to headwater streams and riparian areas not only degrades habitats in 

headwater streams, but downstream habitats as well, because headwater streams provide most of the water 

and sediment for downstream reaches (Rhodes et al., 1994; Moyle et al., 1996; Erman et al., 1996). Due to 

their sensitivity, headwater streams need as much protection, or more, than larger downstream reaches if 

aquatic habitats and water quality at the watershed scale are to be protected (Rhodes et al., 1994; Moyle et 

al., 1996; Erman et al., 1996; Espinosa et al., 1997). Both Erman et al., (1996) and Rhodes et al., (1994) 

concluded, based on review of available information, that intermittent and non-fish-bearing streams should 

receive stream buffers significantly larger than those afforded by PACFISH.

Importantly, land management activities often significantly increase sediment loads to channelized sediment 

sources, which are not effectively arrested by RHCAs with a width of 300 feet (Quigley and Arbelbide, 

1997). In particular, increased road traffic elevates the delivery of sediment to channelized sediment 

sources, especially at stream crossings and road ditches that drain into streams. This undermines the touted 

effectiveness of the RHCAs under PACFISH. References: Espinosa et al. (1997), Moyle et al. (1996), 

Quigley & Arbelbide (1997), Rhodes et al. (1994), Rhodes (1995). (D59 pp. 70-71)

#398. The DEIS analysis of the effects of roads on streams and fish habitat does not adequately describe the sitespecific effects. Which roads are causing the most concern? Why? Where are the problem areas? How are they 

being addressed? What are the options to avoid or mitigate adverse impacts from roads? (D64A p. 22)
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#399. The re-opening of closed or unclassified roads for access, and then re-closure following treatment activities has 

very serious ecological impacts. Extensive and intensive road reconstruction greatly increase road impacts on 

watershed systems, as documented, very graphically, in Karr et al (2004). Reconstruction impacts are extremely 

significant because the elevated sedimentation they cause 66 is already ubiquitous water quality problem throughout 

the West and a major cause of the loss of aquatic biodiversity. (D59 pp. 65-66)

#400. Water quality and hydrological complexity. The Snow Basin project area is a hydrologically complex 

area and “many springs and seeps occur in project watersheds, and these support a broad range of riparian 

vegetation and play a key role as streamflow source areas” DEIS at 146.

The Forest Plan Water Goal is: - Manage National Forest resources to protect all existing beneficial uses of 

water and to meet or exceed all applicable State and Federal water quality standards. Within the Forest 

capability, maintain or enhance water quantity, quality, and timing of stream flows to meet needs of 

downstream users and resources. PACFISH goals and objectives for riparian areas apply here as well (p. 4-

22).

Numerous hydrological problems and obstacles to aquatic species exist in the project area: “There are 

approximately 128 road/stream crossings in Little Eagle subwatershed, and 383 in Paddy-Eagle Creek 

subwatershed. Many of these have been identified as barriers to fish on fishbearing streams.” DEIS at 148 

“The open road densities in the major subwatersheds in the analysis area range from 1.7 mi/mi2 to 2.6 

mi/mi2 and for the entire analysis area is 2.2 mi/mi2. The inventory of valley bottom roads within RHCA 

buffers in the analysis area found approximately 68 miles of existing roads (open, closed, FS and Non-FS). 

Roads within RHCA buffers can reduce the effectiveness of RHCAs to capture and store water and 

sediment from upslope sources, open up streams to temperature increases, may provide active sources of 

sedimentation, and decrease riparian habitat.” The total road density is much higher (See DEIS Table 83).

It is disclosed in the Snow Basin DEIS that the road system is degrading aquatic systems: “Sediment does 

not appear to be coming from unstable streambanks but instead roads in the Snow Basin project area. 

Surface erosion has been observed along roadways in some areas. Roads can provide a substantial source of 

sediment and a mechanism for delivering sediment to the stream systems.” DEIS at 196. However, site 

specific monitoring data on sedimentation from roads in the project area is not available DEIS at 148. (D59 

p. 67)

#401. Roads have a particularly negative influence on aquatic and riparian ecosystems and organisms. Roads interfere 

with movement of materials and organisms in three dimensions: upstream/downstream, channel/upland, and 

surface/subsurface (Doyle n.d.). Roads are also a conveyor belt for delivering chronic sediment to streams (Derrig 

n.d.). These effects cannot be adequately mitigated so it is best to just avoid building roads. 

Roads and Associated Activity

Roads contribute to the disruption of hydrologic function and increase sediment delivery to streams. Roads also 

provide access, and the activities that accompany access magnify their negative effects on aquatic habitats. 

...From an intensive review of the literature, we conclude that increases in sedimentation are unavoidable even using 

the most cautious reading methods. Roads combined with wildfires accentuate the risk from sedimentation. The 

amount of sediment or hydrologic alteration from roads that streams can tolerate before there is a negative response is 

not well known. 

...We conducted two analyses examining the correlation of roads to habitat and fish population status. Each of these 

analyses support the general conclusion that increasing road density correlates with declining aquatic habitat 

conditions and aquatic integrity. Our results clearly show that increasing road densities (combined with the activities 

associated with roads) and their attendant effects are associated with declines in the status of four nonanadromous 

salmonid species. Those species are less likely to use moderate to highly roaded areas for spawning and rearing, and if 

found are less likely to be at strong population levels. There is a consistent and unmistakable pattern based on 

empirical analysis of thousands of combinations of known species status and subwatershed conditions. The analysis is 

limited primarily to forested lands managed by the Forest Service and Bureau of Land Management. (Quigley & 

Arbelbide 1997). (D64A pp. 23-24)

Response: WEPP modeling was used in the FEIS to identify areas where Best Management Practices (BMPs) could 

be applied to improve road drainage and reduce road-related sediment delivery from critical road segments. Critical 
Appendix C Snow Basin Vegetation Management Project FEIS

649

road segments are proximal to stream channels without adequate existing BMPs. This modeling is summarized in the 

Aquatics/Hydrology section of the FEIS (under the sediment subheading). The complete analysis/modeling can be 

found in the Aquatics/Hydrology report in the Project Record.

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#402. The DEIS states at 168 with regard to the Cumulative Effects from Sediment: “Cumulatively, sediment 

produced from the proposed activities would combine with sediment produced from other activities such as roads, soil 

disturbing activities on private lands, etc. however, because the short-term increase associated with project 

implementation would last only a short time (2-5 years) and would be incremental, not occurring all at once, and 

because BMP practices and mitigation measures would be implemented effectively, the sediment impact would be 

limited as much as possible. The overall result is estimated to be beneficial (O’Laughlin 2005). A long-term decrease 

in sediment is expected as a result of timber stand fuel and fire risk reduction, and watershed-wide long-term sediment 

decreases that have occurred as a result of watershed improvements including application of mainly road related 

BMPS, and road decommissioning.” This statement fails to recognize the simple and well-known fact that in aquatic 

ecosystems, it is the chronic sources of sediment that are most degrading and unnatural (i.e. don’t mimic disturbance 

regimes), whereas aquatic systems have evolved with and respond to the large pulses of sediment and organic debris 

from natural disturbances in dynamic, restorative manners. (D59 p. 18)

Response: The FEIS analysis uses modeling (WEPP) to determine sediment effects from chronic sources, namely 

roads. This is summarized in the Aquatics/Hydrology section (under the sediment subheading) in the FEIS. The 

complete analysis/modeling can be found in the Aquatics/Hydrology report in the Project Record. 

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#403. Rhodes (2007) states: There is a high degree of certainty that Mechanical Fuel Treatments (MFT) will increase 

erosion and sediment delivery to stream systems with consequent negative impacts on water quality. This is due to the 

activities involved, their likely extent and frequency, and their likely placement within the watershed context. As 

concluded by Megahan et al. (1992) and USFS and USBLM (1997c) it is not possible to log areas without increasing 

erosion and sediment delivery, regardless of BMPs involved or care in implementation, especially when roads are 

involved. MFT involves the same suite of impacts as logging. There is ample evidence that MFT will almost always 

involve roads and landings.” Please see pages 23-30 from Rhodes (2007) for a review of peer-reviewed science that the 

Snow Basin DEIS fails to consider on this topic. (D59 p. 18)

Response: In all alternatives, to reduce the risk of sediment delivery from units within RHCAs, forwarder logging 

systems (with grapple piling and burning) are now proposed. This also reduces the temporary roads needed for 

logging. The WEPP modeling in the FEIS reflects this logging system change. The FEIS analysis was improved by 

using WEPP to model erosion and sediment delivery from units perceived as highest risk. The highest risk units are 

those nearest to streams. Results show a very low risk of sediment delivery from these units. Monitoring on the 

Wallowa-Whitman National Forest shows that grapple pile and burn activities can cause up to 3% additional 

Detrimental Soil Conditions (DSCs) when following commercial harvest, and 0% additional DSC if existing skid 

trails are utilized (Bliss, 2005). This indicates that the potential for erosion and sediment delivery to streams is very 

low, especially due to no-treatment sediment filter areas between treatment units and streams. Landings will be 

rehabilitated to minimize bare soil and promote vegetation growth. 

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#404. Decommission more roads overall to achieve net road reduction and comprehensive ecological restoration. 

(D64A p. 8)

#405. We support efforts to close and decommission unnecessary roads because roads contribute more 

sediment to streams than any other management activity and interrupt the subsurface flow of water, 

particularly where roads cut into steep slopes. In addition, roads and their use contribute to habitat 

fragmentation, wildlife disturbance, the introduction or exacerbation of noxious weeds, and increased fire 

danger from recreational activities. We believe that every project involving travel management decisions 

presents an opportunity to reduce continuing road related adverse impacts on forest resources. 

Decommissioning roads is particularly important in project areas, like this one, where existing road 

densities exceed thresholds identified in the Forest Plan and are deemed, from a watershed condition 

baseline perspective (DEIS Table 85) “unacceptable”. Further, decommissioning roads where stabilization 

would benefit water quality – which this proposal would do – is also important and consistent with the 

intent of the NEPA. (D67 pp. 1-2) DEIS p. 246 and Table 119 (DEIS p. 245) Removing only 6 miles of roads 

in a watershed with such high road density is inadequate. A sincere restoration effort would be more 

comprehensive in addressing the need to reduce road density necessary for watershed health and wildlife 

objectives. (D64A p. 22) 
Appendix C Snow Basin Vegetation Management Project FEIS

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Response: Each alternative proposes to decommission approximately 6 miles of unneeded roads. At the time of 

project design and up to this time, Travel Management Planning and Minimum Roads Analysis were both on the 

horizon. It was decided to not emphasize road decommissioning until these other, higher level planning processes 

were complete, and to instead focus on the vegetation and fuels aspects of the project area.

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#406. The DEIS further discloses the specific temporary roads that threaten the Martin Bridge Limestone Formation 

at 309 and 310 of the DEIS. HCPC strongly urges the Forest Service to drop all of these temporary roads. Moreover, 

forty one skyline and tractor units overlap the Martin Bridge Limestone formation. “The other activities related to 

vegetation management projects (i.e. skidding, under burning, etc.) would have less effect on the paleontological 

resources because of the lack of contact with the bedrock in the Martin Bridge Limestone formation. However, tractor 

units would have the most effect to potential paleontological resources if tractors were continually running over 

outcrops. The tractor units that are partially or entirely within the Martin Bridge Limestone are: 119, 133, 135, 213, 

215, 202, 203, 207, 208, and 228. Rubber tired or tracked tractors need to be used t prevent fracturing and crushing of 

the bedrock and therefore the vertebrate fossils inside. A geologist or paleontologist will be on site to observe both 

temporary road building and tractor unit activities to take care of a vertebrate specimen, should these activities expose 

one” (DEIS at 310). (D59 p. 95)

Response: In addition to the Project Design Features (PDFs) PALEO-1 and PALEO-2 (DEIS p. B-8), the FEIS has 

been modified to include monitoring of roads and units overlapping the Martin Bridge Limestone formation. 

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#407. The irreparable damage from the construction of temporary roads has been documented in considerable detail 

with empirical data (e.g., Espinosa et al. 1997). Federal land management practices that justify construction of 

temporary roads to carry out restoration projects are recipes for continued soil and watershed degradation. There is 

nothing temporary about the ecological impacts of these roads. It has been thoroughly documented that the impacts of 

temporary road construction are permanent, even with decommissioning (e.g., Beschta et al. 2004; Karr et al. 2004). 

Such long-term damage has been acknowledged by the USFS (Rhodes 2007). The use of temporary roads are far from 

a break-even provision concerning the achievement of ecological restoration objectives, with projects generally 

resulting in more environmental harm than benefit. Please see the section entitled “Prohibiting New Road 

Construction” on page 963 of Beschta et al. (2004). 

Additionally the re-opening of closed or unclassified roads for access, and then re-closure following treatment activities 

has very serious ecological impacts. Extensive and intensive road reconstruction greatly increases road impacts on 

watershed systems, as documented, very graphically, in Karr et al. (2004). Reconstruction impacts are extremely 

significant because the elevated sedimentation they cause is already ubiquitous water quality problems throughout the 

West and a major cause of the loss of biodiversity. (D59 pp. 65-66) 

#408. The following is a brief outline representative of the range of current scientific information that should be 

incorporated in revising the proposed decision and management actions of the Snow Basin Project: (D59 p. 37)

Landscape extensive fuels reduction activities, including logging and/or controlled burning, often involve road 

activities, including the construction of “temporary” roads and landings which have negative impacts on soil 

communities, hydrological functioning, and watershed ecosystems. The negative impacts of so-called “temporary” 

roads and landings are not temporary, but persistent (Beschta et al. 2004; Karr et al. 2004).

Response: Pages 166-167 of the DEIS discuss the effects of road reconstruction and temporary road construction 

effects on sediment delivery. 

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#409. NFMA and road densities. The LRMP requires FS decision makers to meet the specific open-road density 

guidelines for individual management areas unless the decision maker determines an exception is needed to satisfy 

management objectives through the NEPA process (LRMP 4-35). No such exception has been made for this project. 

Table 149 of the DEIS clearly indicates that open road densities are above Forest Plan standards. (D59 pp. 94-95)

Response: The intent of this project is not to change or alter the open road densities in the project area. There is a 

foreseeable future action called the implementation of the Wallowa-Whitman Travel Management Plan expected to 

take place in 2012, which will designate a system of roads open to motorized vehicular use, and it is expected that not 

all of the open roads in the area will have such designation. This will have the effect of reducing open road densities 

in the project area, thus meeting the intent of Forest Plan Standards and Guidelines for open road density.

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#410. The following is a brief outline representative of the range of current scientific information that 

should be incorporated in revising the proposed decision and management actions of the Snow Basin 

Project: (D59 p. 37)
Appendix C Snow Basin Vegetation Management Project FEIS

651

Management recommendations based on scientific forest and fire ecology research:

Prohibit construction of new landings and roads. Require significant levels of permanent road 

decommissioning and closure prior to any fuel treatments. 

Response: Alternative 4 in the FEIS has no temporary road construction. No landing construction is proposed for all 

alternatives. 

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#411. Real ecological restoration requires that the Forest Service embrace and work with natural 

disturbance processes. (D64A, p. 6)

Response: See response #418 and #412. For Historic Range of Variability, see DEIS Ch. 3 – 3.1 Forest 

Vegetation; Historic Range of Variability (Pg. 52) and Table 26 (Pg. 54); Table 25 (Pg. 55). Also refer to 

DEIS 3.2.2.2 Fire Environment; Snow Basin Fire Regime Condition Class (Pg. 111).

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#412. Use natural processes where it makes sense to do so. See Noss et al. (2006) and Crist et al. (2009). 

(D64A, p. 4)

Response: Snow Basin uses natural processes to reverse the unnatural anthropological activities and disturbances of 

the past; removal of large diameter old trees and the exclusion of fire for several decades. Snow Basin activities 

include wide use of prescribed fire to manage fuels and to return the dominant historic disturbance to a landscape that 

missed several fire cycles. The aspen treatments use aspen’s natural vegetative regeneration process to restore aspen 

across the landscape. Trees ability to increase radial growth after thinning would be used to increase diameters 

towards Late and Old Structure. 

For Historic Range of Variability, see DEIS Ch. 3 – 3.1 Forest Vegetation; Historic Range of Variability (Pg. 52) and 

Table 26 (Pg. 54); Table 25 (Pg. 55). 

Also refer to DEIS 3.2.2.2 Fire Environment; Snow Basin Fire Regime Condition Class (Pg. 111)

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#413. The Eastside Screens interim wildlife standard recognizes that maintaining healthy wildlife populations requires 

abundant dead wood and that past practices have depleted the dead wood resource (see D64A pp. 29-30). 

Unfortunately, the Eastside Screens still rely on the discredited “potential population” method. The Forest Service has 

numbers for meeting 100% potential population levels and strives to meet targets that are known to be inadequate. 

Even if the agency aims for a target above 100% potential population levels, the agency is still using an invalid 

reference point that does not belong in the NEPA analysis. The best available science has not been incorporated into 

the standards. The agency lacks the “documented procedures” for meeting snag habitat requirements called for in the 

Eastside Screens. (D64A pp. 29-31).

Response: Change in Forest-level direction is beyond the scope of this analysis. However, the discrepancy between 

Eastside Screens direction and current science regarding snag habitat is acknowledged on page 106 of the Wildlife 

Specialist Report. 

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#414. The 21 inch cut should be eliminated in regard to cutting down and dead timber for home heating. (D33 p. 1)

*If anyone cuts on one of these dead trees being guarded to burn on site they are arrested for a federal crime of theft 

imprisoned and fined. Federal Courts are flooded with wood theft crimes because desperation due to high gasoline 

prices, limited opportunity, financial hardships or health problems drives some people to take blocks off an “illegal 

tree.” The injustice of being refused wood because of its large diameter when the competition for legal size trees grows 

worse, added to the knowledge the forbidden wood will be consumed by a prescribed fire as soon as the feds can get to 

it fuels distrust and contempt for all government agencies. Court costs totaling millions of dollars must be paid by 

taxpayers. Being prosecuted for trying to save and utilize wasted trees leaves a bad taste. (D15 p. 2)

Response: While the Snow Basin FEIS proposes a project-specific forest plan amendment to allow the harvest of 

trees >21” in diameter in specific instances, the 21” diameter limit is still in place for all firewood cutting on the 

Wallowa-Whitman National Forest. 

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Appendix C Snow Basin Vegetation Management Project FEIS

652

#415. The following is a brief outline representative of the range of current scientific information that 

should be incorporated in revising the proposed decision and management actions of the Snow Basin 

Project: (D59 p. 37)

Management recommendations based on scientific forest and fire ecology research: 

Significantly curtail fire suppression in areas where human infrastructure is not at risk. 

Response: The Wallowa-Whitman National Forest Land and Resource Management Plan addresses the decision, 

rationale and options available for suppression of wildland fire on the Wallowa-Whitman National Forest. 

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#416. The Snow Basin project fails to recognize the broader suite of forest structural conditions and a 

broader range of patch sizes supported by native fire regimes. Even in the mid-elevation moist mixed 

conifer forests where the natural fire regime is longer than the historical period of fire suppression, logging 

is proposed because of fire suppression. Snow Basin is a recipe for homogenization of forests. (D59 p. 33)

Response: See FEIS Ch. 3, Sec 3.1 for discussion of HRV for species density, structure, and species 

composition. The proposed activities are described in Chapter 3 of the FEIS. They occur in a variety of 

plant associations in mixed species and structure stands. Several prescriptions are proposed that are 

specific to conditions at the stand level. HRV is a diverse landscape by definition. The proposed activities 

manage the landscape towards HRV. 

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#417. The Forest Service proposal is heavily dependent upon the goal of eliminating high severity fire from 

the project area, reducing native diseases to the point of cutting old growth ponderosa pine and Douglas-fir 

(the most drought tolerant trees on the forest) and removal of grand fir over 21 inches DBH because they 

are “unsustainable,” even within moist biophysical environments. With regards to large scale ecological 

disturbance, leading scientists have a different view. Lindenmayer et al. (2004): “To many ecologists, 

natural disturbances are key ecosystem processes rather than ecological disasters that require human 

repair. Recent ecological paradigms emphasize the dynamic, nonequilibrial nature of ecological systems in 

which disturbance is a normal feature...and how natural disturbance regimes and the maintenance of 

biodiversity and productivity are interrelated...” (D59 pp. 7-8)

Response: See Chapter 3 Section 3.2 Fire Fuels for description of Fire Regime 3 – Low-Mod severity 

covering 13% of the area. The removal of 21+ trees is discussed in Chapter 3 Section 3.1 Forest 

Vegetation of the FEIS. The FEIS Alternative 4 responses to this issue by not including the removal of 21+ 

trees. Lindenmayer et al. (2004) discusses post fire salvage operations which are not within the scope of 

the FEIS.

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#418. As mentioned in our scoping comments, the Forest Service should not expend too much effort simply 

restoring forest structure when doing so will require continuous expenditure of money and effort to 

maintain. We must use scarce resources efficiently by striving to restore ecological processes that can be selfsustaining. (D64A, p. 4) 

Response: The Snow Basin activities are designed to return vegetation to ecological processes similar to 

the historic or characteristic condition. Restoring the landscape to a more historic condition would lessen 

the risk of high intensity uncharacteristic disturbance such as large outbreaks of Spruce Budworm and 

large high intensity wildfire. A resilient landscape would also allow the use of low intensity fire to 

maintain these desirable conditions. 

Snow Basin activities produce a positive Cost / Benefit ration on Alternative 2 and Alternative. Both of 

these alternatives generate revenue that provides for restoration and maintenance of desired future 

conditions. See FEIS Social an Economic Report – Summary of Effects, Table 1 Estimated Cost of the 

Alternatives and Table 2 Economic Analysis Summary by Alternative.
Appendix C Snow Basin Vegetation Management Project FEIS

653

Other Comments – No Response Provided

* Unfortunately, old growth forests have been heavily targeted for logging in the Blue Mountains for over a 

century. Rainville et al. (2008) states:

“From its beginning, logging preferentially removed large, old-growth ponderosa pine trees (Langston 1995). 

Management of the national forests emphasized efficient and productive forests capable of meeting the Nation’s 

demands into the future. The emerging discipline of forestry at the time held that “inferior” diseased and decadent 

trees needed to be removed and replaced with young, healthy, rapidly growing trees.”

While usually more subtle, this mindset persists in National Forests management today. The Forest Service 

attempts to persuade the public and itself that old growth forests need mechanical treatment, and then once in these 

stands are quick to apply stand density metrics derived from the industrial crop style forestry mentality (see section 

on Stand Density Index). The Forest Service openly admits removing mature overstory Ponderosa Pine, Douglas 

fir, and Grand fir trees from designated old growth stands because they have a native disease such as dwarf

mistletoe and Indian Paint Fungus that create wonderful wildlife habitat, especially in old growth trees. It is the 

same mindset as expressed in the quote above, and overtime, this practice will progressively simplify stand 

structure and cause depletion of old growth characteristics such as snags and downed logs. Biodiversity will be 

systematically lost through this approach. Furthermore, the entire mentality implies subsequent entries when the 

next “crop” of trees are ready to be harvested. We simply cannot maintain ecologically complete old growth forests 

in this manner. (D59 p. 23)

* The magnitude and scope of the Snow Basin proposal has firmly passed into this cultural realm whether the 

Forest Service likes it or not. This is very frustrating for HCPC because we just successfully worked with the 

Whitman Ranger District on the Tremble Aspen Restoration project where we did make some exceptions to the 

Eastside Screens to help restore aspen stands. Tremble Aspen was limited in its scope and extent, and nonetheless 

was appealed and took a very serious effort by all parties involved to resolve. Now only a short time later the 

Forest Service drops this massive plan that is the exact opposite of Tremble Aspen; expansive in scope and extent. 

Does the Forest Service not notice how different these approaches are to this very complex social issue? HCPC 

does not have any level of comfort discussing exceptions to the Screens at the level Snow Basin proposes.

As Pesklevits et at. 2011 states in, Old-growth Forests: Anatomy of a Wicked Problem: “old-growth is 

simultaneously an ecological state, a value-laden social concept, and a polarizing political phenomenon, each facet 

of its identity influencing the others in complex ways. However, the public, scientific, and management discourse 

on old-growth has also suffered from simplifying tendencies which are at odds with old-growth’s inherently 

complex nature. Such complexity confounds simple or rationalistic management approaches, and the forest 

management arena has witnessed the collision of impassioned and contradictory opinions on the ‘right way’ to 

manage old-growth forests, ranging from strict preservationism to utilitarian indifference. What is clear is that 

management approaches that circumvent, trivialize, eliminate, or ignore old-growth’s inherent complexity may do 

so at the expense of the very characteristics from which old-growth derives its perceived value.” (D59 pp. 24-25)

* The Geographic Scope of the Forest Service’s Cumulative Impacts Analysis for the Old-Growth Resource is 

Inadequate Because the Eastside Screens is a Regional management Strategy that Sets Forth Forest-wide 

Standards. The Snow Basin Project analysis area for LOS is the eastern portion of the La Grande Ranger District 

not including the Eagle Cap Wilderness and the old Pine Ranger District. This is not the proper scale at which to 

analyze another Eastside Screens’ amendment to allow commercial logging within oldgrowth forest stands. This 

analysis scale is inadequate for measuring the cumulative impacts on the oldgrowth resource and old-growth 

dependent wildlife for several reasons: 1) there are several past timber sale projects on the WWNF involving sitespecific amendments to the Eastside Screens that allowed commercial logging within old-growth stands and/or the 

removal of trees greater than 21” DBH and more of these “site-specific” amendments are reasonably foreseeable; 

2) these amendments affect the distribution of old-growth habitat that is available for dependent wildlife that move 
Appendix C Snow Basin Vegetation Management Project FEIS

654

beyond the immediate project areas; 3) repeated waivers to the Eastside Screens’ old-growth protections should be 

considered at a scale similar to the area covered by the rule itself; and 4) the Forest Service has not previously 

considered the cumulative impacts of these repeated, piecemeal amendments.

The courts have held that “the choice of analysis scale must represent a reasoned decision and cannot be 

arbitrary.”Idaho Sporting Cong., Inc. v. Rittenhouse, 305 F.3d 957, 973 (9th Cir. 2002). Therefore, “[a]n agency 

must provide support for its choice of analysis area and must show that it considered the relevant factors.”Native 

Ecosystems Council v. Dombeck, 304 F.3d 886, 902 (9th Cir. 2002) (“Native Ecosystems Council”); see also 

Habitat Education Center, Inc. v. Bosworth, 363 F.Supp.2d, 1070, 1077 (E.D. Wis. 2005) (“HEC”) (“[T]he Forest 

Service did not consider all relevant factors.”). Relevant factors include “the scope of the project considered, the 

features of the land, and the types of species in the area.”Selkirk Conservation Alliance v. Forsgren, 336 F.3d 944, 

958 (9th Cir. 2003).

In this instance the Forest Service has neither considered all relevant factors (as discussed in further detail below), 

nor demonstrated reasoned and informed decision-making in determining the geographic scope of its cumulative 

effects analysis on the old-growth resource. This lack of supporting rationale for so narrowly defining the 

geographic scope of the cumulative impacts analysis with respect to this particular forest resource is especially 

problematic given the numerous past and reasonably foreseeable waivers of old-growth protections, and the 

scarcity of LOS forest-wide.

In NEC v. Dombeck, the EA for the timber sale at issue did contain a cumulative effects section discussing some 

reasonably foreseeable future actions to be taken in the area around the sale. However, similar to the Snow Basin 

DEIS, the Forest Service in that case did not “analyze what, if any, environmental impacts [the proposed] road 

density amendment might have in combination with the contemplated road density amendments in the 

other...sales.” Id. at 896. The plaintiffs alleged that the “Forest Service violated NEPA by failing to consider the 

cumulative effects of its multiple decisions to waive road density standards for [several timber sales within the 

same National Forest]. The Ninth Circuit held “[t]his omission violates NEPA,” further stating: 

The national forest was the geographic unit within which the Forest Service chose to set forth binding road density 

standards in the Forest Plan. All of these sales are proposed within the Gallatin National Forest and will necessarily 

have additive effects within that management unit. Unless the cumulative impacts of these amendments are subject 

to analysis even though distantly spaced throughout the Forest, the Forest Service will be free to amend road 

density standards throughout the forest piecemeal, without ever having to evaluate the amendments' cumulative 

environmental impacts. NEPA does not permit this, but rather requires the assessment of the cumulative impact of 

"individually minor but collectively significant actions taking place over a period of time." 40 C.F.R. § 

1508.7(2001). 

Id. at 897 (emphasis original). 

This Ninth Circuit precedent is directly on point. The Forest Service must assess the cumulative impacts of 

repeatedly waiving the Eastside Screens’ old-growth protections in the Snow Basin Project EIS, along with any 

reasonably foreseeable future amendments to the same affect, at least at a forest-wide scale. The Eastside Screens 

amended all forest plans for Oregon and Washington’s eastside forests and thus, as a Forest Plan standard, apply 

forest-wide like the Forest Plan road density standard at issue in NEC v. Dombeck. The Ninth Circuit further 

explained: A cumulative impacts analysis is required even absent a finding that the waivers are likely to have 

cumulatively significant effects; its purpose rather, is to determine whether this is so. Though we cannot say that 

the proposed waivers in this case will have cumulatively significant effects..., they are certainly reasonably 

foreseeable and implicate the possibility of cumulative impacts in the forest sufficiently to trigger [a cumulative 

effects analysis]. 

Id. at 896 n.2. 
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Because the Eastside Screens are a regional old-growth management strategy and set forth legally enforceable 

standards that apply forest-wide, the potential cumulative impacts of these numerous, so called “site-specific” 

amendments must be assessed, at a minimum, on a forest-wide basis. 

The analysis presented on page 101 and 102 is grossly inadequate and does not attempt to answer the important 

points raised above. (D59 pp. 40-42)

* The cultural issues alluded to above are so powerful and well-defined that it culminated in the passage of the 

Northwest Forest Plan in 1994. The passage of the Northwest Forest Plan is widely held as one of the key 

examples of how environmental values can significantly affect public lands management. All of this is 

scientifically documented in the peer-reviewed literature as follows. In the Pacific Northwest (PNW) of the United 

States, harvest of older forests constituted the majority of volume removed from federal land (Forest Service (FS) 

and Bureau of Land Management (BLM)) for decades. Harvest rates of older forest increased during the late 

1970’s through the late 1980’s (Stokstad, 2009). In the 1980’s, public controversy intensified over timber harvests 

of older forests because societal views of these forests were changing to include a broader set of values such as 

species dependent on older forests and the role of these forests in regional and local economies (Rapp, 2008). In 

1994, the Northwest Forest Plan (NWFP) was enacted partly because of growing concern that losses of older 

forests had put at risk the survival of species dependent on those forests (for example, the northern spotted owl, 

Strix occidentalis, USDI 1992).

The NWFP amended the management plans across 9.8 million hectares of federal lands (FS and BLM) in Oregon, 

Washington and California (Rapp, 2008). Following the enactment of the NWFP harvest of older forests on 

federal lands declined abruptly both in absolute terms and as a proportion of remaining older forests during the 

1990s (Healey et al. 2008). Federal stand-clearing harvest made up 32% (by area) of all stand-clearing harvests of 

older forests in western Oregon and Washington prior to the NWFP and less than 8% in 1992 and later (Healey et 

al. 2008). In just ten years (1992 to 2002) following the implementation of the NWFP, patterns in the loss of older 

forests and overall harvest rates on federal lands in the PNW changed dramatically. The magnitude and scope of 

the Snow Basin proposal has firmly passed into this cultural realm whether the Forest Service likes it or not. (D59 

pp. 24)

* Forests in their potential state are simply one of the most important ecosystems to preserve on Earth. The reasons for 

protecting old growth forests continue to accumulate, indicating the life-giving and supporting nature of these complex, 

interconnected ecosystems. Recent findings have shown the immense value of old growth forests for protecting carbon stores 

(Smithwick et al. 2002, Luyssaert et al. 2008, Hudiburg et al. 2009, Keith et al. 2009) and for continued accumulation of 

carbon in soils (Zhou et al. 2006). (D59 pp. 22-23)

* Unfortunately, old growth forests have been heavily targeted for logging in the Blue Mountains for over a 

century. Rainville et al. (2008) states: “From its beginning, logging preferentially removed large, old-growth 

ponderosa pine trees (Langston 1995). Management of the national forests emphasized efficient and productive 

forests capable of meeting the Nation’s demands into the future. The emerging discipline of forestry at the time 

held that “inferior” diseased and decadent trees needed to be removed and replaced with young, healthy, rapidly 

growing trees.”

While usually more subtle, this mindset persists in National Forests management today. The Forest Service 

attempts to persuade the public and itself that old growth forests need mechanical treatment, and then once in these 

stands are quick to apply stand density metrics derived from the industrial crop style forestry mentality (see section 

on Stand Density Index). The Forest Service openly admits removing mature overstory Ponderosa Pine, Douglas 

fir, and Grand fir trees from designated old growth stands because they have a native disease such as dwarf 

mistletoe and Indian Paint Fungus that create wonderful wildlife habitat, especially in old growth trees. It is the 

same mindset as expressed in the quote above, and overtime, this practice will progressively simplify stand 

structure and cause depletion of old growth characteristics such as snags and downed logs. Biodiversity will be 

systematically lost through this approach. Furthermore, the entire mentality implies subsequent entries when the 
Appendix C Snow Basin Vegetation Management Project FEIS

656

next “crop” of trees are ready to be harvested. We simply cannot maintain ecologically complete old growth forests 

in this manner.

The peer-reviewed literature warns that efforts at restoration of fire-adapted forests are jeopardized from economic 

pressure to cut larger trees than can be ecologically justified (Brown et al. 2004). The repercussions of succumbing 

to this economic pressure are heightened in relatively rare unlogged old growth forests that have a high value for 

conserving biodiversity (Noss and Cooperrider 1994; Strittholt and DellaSala 2001; Crist et al. 2009) and serve as 

refugia for sensitive terrestrial and aquatic species, have lower rates of invasions of non-native species, and provide 

reference conditions for understanding natural ecosystem processes (Crist et al. 2009). While the Forest Service 

wants more leeway to mechanically treat old growth forests, proposals such as Snow Basin indicate that less 

should be given. In these rare and ecologically complex old growth forests, there is no room for economic interests 

to corrupt restoration efforts. The peer-reviewed science repeatedly urges for a cautious approach to restoration of 

dry forests, especially in unlogged ponderosa pine/Douglas-fir forests (Keeling et al. 2006, Noss et al. 2006), and 

for excluding logging from moist forest areas where past human disturbances (like timber harvesting) have been 

limited (Cochrane & Barber 2009; Lindenmayer et al. 2009). (D59 pp. 23)

* It does not attempt to apply the 2003 Goodman letter in a precise and realistic manner and in context of the 

numerous ecological problems the Eastside Screens were put in place to help solve. Snow Basin is a single-minded 

logging proposal that throws out all the progress we have made in getting more large trees on the landscape.

Site Specific Amendments

To move the Snow Basin landscape toward HRV the proposed action (Alternative 2) would require three 

amendments to Screens direction contained in the Forest Plan (DEIS at 19).

1. Harvest activity within LOS stages that are BELOW HRV.

2. Harvest activity within LOS that results in a net loss of LOS.

3. Any timber harvest activity that removes live trees 21 inches in dbh and greater

1. Any timber harvest activity within multi-story late and old structure (MSLT) in cool/moist grand fir, and 

within single story late and old structure (SSLT) in warm/dry grand fir, warm/moist Douglas-fir, warm/dry 

Douglas-fir, and hot/dry ponderosa pine does not meet SCREENS Direction and would require a FP 

Amendment because harvest activities would occur in LOS stages that fall below HRV. This will be 

referred to as Snow Basin Amendment 1 (SB1).

In Alternative 2, this applies to 743 treatment acres. In MSLT for Cool/moist grand fir (66), and in SSLT 

for warm/dry grand fir (247 acres), warm/moist Douglas-fir (119 acres), and warm/dry Douglas-fir (311 

acres).

2. Any timber harvest activity that results in a net loss of LOS27, where stands are being converted to nonLOS, does not meet SCREENS Direction and would require a FP Amendment. This will be referred to as 

Snow Basin Amendment 2 (SB2). 

In Alternative 2, this applies to 874 treatment acres. In for Cool/moist grand fir (22 acres), warm/dry grand

3. Any timber harvest activity that removes live trees 21 inches in dbh and greater across any structural stage 

and in any biophysical group, does not meet SCREENS Direction and requires a FP Amendment. This will 

be referred to as Snow Basin Amendment 3 (SB3). (D59 pp. 26-27)

* I would also clearly state, as a management agency proposing heavy-handed commercial treatments that are highly 

controversial on our National Forest lands, you had better get the definition of the historic disturbance regime pretty close to 

right, or your whole analysis is wrong. And if you can’t even get the current disturbance regimes characterized right, you have 

no chance with future projections. Yet on page 3 the DEIS states “This project will address predicted changes in climate and 

the anticipated responses in the vegetative environment.” Outside of the well-documented approaches in the previously 
Appendix C Snow Basin Vegetation Management Project FEIS

657

logged, warm-dry forest types, I have a no confidence that the Forest Service can anticipate responses in the vegetative 

environment due to climate change. (D59 p. 6)

* Successful forest restoration strategies must take into account the specific ecology of forests as well as the history of land 

management activities in a particular place (Crist et al. 2009). Inappropriate application of restoration treatments on a 

landscape may lead to failed restoration efforts (DellaSalla et al. 2003). (D59 p. 2)

* Even then we should be saving the mature trees above 12” dbh. (D59 p.65)

* Some aspects of this project seem to treat some natural processes (such as fire, insects, and mistletoe) as enemies that need

to be defeated. (D64A, p. 6)

* Human disturbance offers, at best, only a rough approximation of natural disturbance. Unlike fire and insects, logging has 

many ecologically undesired effects such as roads, compacted soil, nutrient loss, weeds, and export of valuable structural 

building blocks. (D64A, p. 6) 

* It is important to remember these public lands must be managed for a wide variety of values. Managing for peak growth 

rates of commercial trees species should be a thing of the past. The agency should be managing for complex forests and a 

wide range of forest values. (D64A p. 20)

* HCPC’s mission is to protect and restore the inspiring wildlands, pure waters, unique habitats and biodiversity of the Hells 

Canyon-Wallowa and Blue Mountain Ecosystems through advocacy, education and collaboration, advancing science-based 

policy and protective land management. (D59 p. 1)

*AOL (Associated Oregon Loggers) member companies depend on a reliable timber supply, including federal forests, and we 

encourage federal regulations & plans that promote active management of federal forests in Oregon – especially the restoration 

of unhealthy forests. AOL members are directly impacted by the decisions that will be made as a result of national forest 

projects, such as the proposed Snow basin project (D36 p. 1)

* Efforts to establish a forest products industry in Baker County can only happen with a steady, predictable supply of product. 

Rebuilding this infrastructure will greatly improve the capability of land managers, both private and public, to manage the 

forests in the future. (D38 p. 1)

* The OSWA is interested in maintaining state and federal policies that will facilitate the ability of small woodland owners to 

keep their forests as forests and to contribute to the ecological, social, and economic benefits that forests provide. (D41 p. 1)

* Baker County historically had a strong custom and culture rooted in the forest products industry, but has had a drastic 

reduction in the infrastructure related to the forest industry over the past few decades, to the point that it has nearly become 

extinct. Forest products provided family wage jobs both in the manufacturing and harvesting of forest products. Currently 

there are efforts being made to reestablish the forest product related industry in Baker County and a steady, predictably supply 

of forest products would greatly improve the feasibility of these and other industries. Rebuilding this infrastructure will 

greatly improve the capability of land managers; both private and public, to better manage forests in the future. (D60 p. 2,

D62 p. 1, D65 p. 1)

* We need to remove trees to restore the forest to a healthy sustainable state. This would qualify as a real economic stimulus 

by creating jobs and revitalizing our mills (D48 p. 1)

* The mission of ARFC is to create a favorable operating environment for the forest products industry, ensure a reliable 

timber supply form public and private lands, and promote sustainable management of forests by improving federal laws, 

regulations, policies and decisions that determine or influence the management of all lands. (D50 p. 1)

* Baker County, like many of the rural communities in Oregon, is dependent upon revenue from timber receipts to fund 

schools and maintain roads. With the continuing decline in these receipts schools are struggling to keep their doors open and 

our county roads are in serious disrepair. (D60, D65 p. 2)

* Union County has experienced a tremendous increase in unemployment due to the loss of family wage jobs in the woods and 

local mills. We have experienced double digit unemployment constantly since the fall of 2008. This is impacting our 

communities in many ways. These factors demonstrate the importance of wood industry jobs in Union County. (D79 p. 1)

* The Snow Basin area has an advantage in that there are, for now, still essential mills in the area that can process the raw

material from the Snow Basin area. In the last several decades, the wood product industry’s infrastructure has diminished to 

the size that only a few eastside manufacturing facilities exist and the contractors and businesses needed to sustain a wood 

product industry are at the verge of collapse (D41 p. 1)

* While the Forest Service wants more leeway to mechanically treat old growth forests, proposals such as Snow Basin indicate 

that less should be given. (D59 p. 23)

* General Guidelines: 

• HRV concept despite its limitations is a reasonable approach because it entails less uncertainty.

• HRV concept is not one to take the forest back to pre Columbian condition or that human uses should not be 

part of the landscape.

• HRV manages for a range of conditions not a single condition over the landscape and should allow greater 

flexibility in management of increased tree densities.
Appendix C Snow Basin Vegetation Management Project FEIS

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• Disturbance is essential to species and ecosystems.

• Sustainability decisions are primarily social decisions.

• More and “better” science does not ensure better decisions.

• Science must be transparent and robust, should inform and not dictate decisions.

• Generally what is measured is what gets done.

• It is the FS job to consider the appropriate science, make a decision and manage the land, they have 

deference of the management. (D29 p. 2)

* Economic feasibility critical. Please remember that economic factors are critical to accomplish a viable forest management

project. Although low-value material must be removed, the sawtimber harvest of trees over 21” dbh is the economic means to 

help pay for the non-merchantable thinning necessary to accomplish these hazard reductions. (D36 p. 2)

* As a concerned citizen I urge you, the public servants, to make decisions benefitting the forests and not outside pressure 

groups. (D56 p. 1)

* The Snow Basin Vegetation management Project looks to me like one of the old timber sales proposed by the Timber Beasts 

of old. (D22 p. 1)

* I could say more of what I think of these “screens” but it would not contribute to your decision process. (D74 p. 1)

* Oregon Wild’s goal is to protect areas that remain ecologically intact while striving to restore areas that have been degraded. 

This can be accomplished by moving over-represented ecosystem elements (such as logged and roaded areas) toward 

characteristics that are currently under-represented (such as roadless areas and complex old forest). (D64A p. 1)

* As mentioned in our scoping comments, the Forest Service should not expend too much effort simply restoring 

forest structure when doing so will require continuous expenditure of money and effort to maintain. We must use 

scarce resources efficiently by striving to restore ecological processes that can be self-sustaining. Recognize that 

insects and disease are natural ecological processes that actually help improve landscape diversity. Recognize that 

tree mortality recruits valuable habitat structures and makes resources available which increase the vigor of 

surviving trees, thus accomplishing many of the objectives of mechanical density reduction projects. Don't focus 

too much on tree health, but think instead about forest ecosystem health. Use natural processes where it makes 

sense to do so. See Noss et al. (2006) and Crist et al. (2009). (D64A, p. 4)

* The potential for dispersal of insects and various diseases from the Snow Basin area to private woodlands is also a major 

concern. Many trees in the Snow Basin area are infected with dwarf mistletoe, other diseases and bark beetle infestations. The 

high density of trees increases the likelihood for insect/disease dispersal. Further, because trees within the area are densely 

crowded that are under greater stress and more susceptible to insect infestation and disease. For these reasons we strongly 

support the management actions proposed in Alternative 2. They will ensure healthier trees by ensuring access to the sun, 

water and minerals necessary to promote healthy growth; healthy trees will have greater resistance to insect infestations and

disease. (D52 p. 3)

* The excuse for killing these giant trees seems to be to save them from mistletoe. In the past, one of the recommendations for 

mistletoe management was 40 acre clear cuts. That did not stop the mistletoe. Mistletoe has been in our forests forever and

will never be removed, no matter how many giants you kill. This is just an excuse to kill the giants and satisfy the greedy. 

(D22 p. 2)

* Mistletoe is a native species that has affected these forests for millennia. It provides cover, nesting, and food for a wide

variety of birds and other wildlife. Removing only a few trees will not remove the species. In fact, prescriptions designed to 

reduce fire severity will have the unintended effect of prolonging the persistence of mistletoe in these stands, because under 

natural conditions, mistletoe is controlled by high-severity fire that kills host trees over large areas. (D64A p. 7) 

* Do not cut any trees over 21” diameter (D22 p. 2, D24 p. 1)

* This discrete old-growth classification approach also has many weaknesses because both MSLT and SSLT forest 

structures historically existed in very close proximity to one another, in a complex mosaic with no fixed 

boundaries. Changes in aspect and topography, for example, historically altered the fire regime at fine scales, 

resulting in a patchy mosaic of forest structures across the landscape. In reality a gradient of old-growth forest 

structure existed between the driest old-growth single story Ponderosa Pine forest and moist mixed conifer oldgrowth forest. The mixed severity fire regime that defines the Blue Mountains creates a great diversity of habitat 

conditions that are excellent for a broad array of organisms. (D59 pp. 28)

* The LOS treatment on this project is a very small percentage of the forest @2%. However it again is a positive step in 

moving the forest toward HRV. (D29 p. 1)
Appendix C Snow Basin Vegetation Management Project FEIS

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* The DEIS is premised upon erroneous and scientifically controversial management assumptions and actions, which 

are incapable of meeting the ecological goals and objectives of the project’s states purpose and need. 

The DEIS’s purpose and need, “to help restore a full complement of vegetative patterns within the natural range of variability 

across the landscape” cannot be met with the proposed management actions and threatens to remove the landscape further 

from the range of natural variability in numerous ways. As extensively discussed, Snow Basin should be limited to dry forest

types only. The proposed actions in moist forest types run counter to best available science and the stated goals and objectives 

of the project. 

As planned, the project would further harm the ecological integrity of the area by its planned removal of far too many of the

area’s old and mature trees, including the scientifically insupportable logging in mid and high elevation mixed conifer forests, 

and the logging of inherently fire resistant mature and old growth trees. Such scientifically and ecologically unwarranted 

logging will seriously degrade wildlife habitat, jeopardizing the viability of forest-dependent species of concern throughout the 

greater project area. The planned logging violates the peer-reviewed science, expert advice, and reasonable requirements of 

NEPA. Project logging actions violate the qualified scientific objectives that comprise the foundation of the Eastside Screens. 

Project logging violates fire and fuels reduction scientific recommendations. Project logging of mature and old trees and 

degradation of forest habitat would likely extirpate or harm the habitat and populations of affected ESA listed species and 

imperiled forest dependent native species of concern in violation of the NFMA. (D59 pp. 20-21)

* There are many things to like about this project, including the focus on previously managed stands in (mostly) dry forest 

types, the extensive use of prescribed fire, the effort to restore quaking aspen, and the effort to (mostly) stay out of roadless 

areas and Riparian Habitat Conservation Areas. (D64A p. 2)

* We support a decision closer to Alternative 4 than Alternative 2. (D64A, p. 2)

* We support the project objectives and believe the preferred alternative (Alternative 2) would best meet those objectives. 

(D67 p. 1)

* I am familiar with the Snow Basin Project DEIS Proposed Action and I believe it is definitely a strike in the right direction. 

What I have seen during the past ten years encourages me to believe that the Forest Service assessment of the environment in 

the Snow Basin Project is accurate, responsible, the objectives are reasonable and the outcome will have a definite benefit. I 

am satisfied the Forest Service evaluations and proposals deserve our support. (D15 p. 2 and D16 p. 2)

* I am totally opposed to Alternative 2 and Alternative 3 (D22 p. 2)

* The desired condition, purpose and need, and objectives are dead on. The area needs fuels reduction; it is the key to forest 

health. Regardless of what metric one uses to measure the health of this area the departure from healthy conditions is obvious. 

(D29 p. 1)

* I commend the FS for recognizing the economies of scale for this project. Completing NEPA has the same cost if it is 2600 

acres or 26,000 acres. This will provide for fewer entries to get the management completed and will bring the WW’s unit 

costs down. (D29 p. 1)

* The PA is the only real alternative, which should be implemented and treats the most acres on the landscape. This PA will 

treat the most area with massive departures of CC and fire regime. These areas are not IRA and virtually all have had past 

management (D29 p. 1)

* The best plan is to implement Alternative #2 with modifications allowing for the cutting of trees larger than 21” diameter –

those trees that are diseased or infested by insects or other parasites. It is imperative that the general health of the forest be 

improved so that a catastrophic fire can be avoided. The WW NF resources are crucial for the economic health of the region, 

and your efforts to secure the health of these resources are greatly appreciated. (D32 p. 1, D72 p. 1)

* The FS Proposed Action is the only alternative that presents a reasonable management plan for the snow Basin area. It 

speaks to the health of the forest, it will have a lasting benefit on the forest in the near future and a long range benefit. (D33 p. 

1)

* Our concern is for small animal habitat as well as big game habitat and stream access. The FS Proposed Action addresses 

these issues with firm background knowledge. (D33 p. 1)

* We applaud the FS for recognizing the extreme economic need of Baker County. The FS proposed action will do much to 

fill this need which is enormously important to the citizens and county as a whole. (D33 p. 1)

* We urge you to implement Alternative #2. We are generally in agreement with your decision, as well as the purpose and 

need and objectives. We urge you to proceed with project implementation as soon as possible – while keeping in focus the 

need for cost-effective contracting and operations (D36 p. 1)

* Size & scope of the project area is correct. This landscape scale approach provides for economy of scale, as well as the

ability to efficiently meet stated objectives. This large-scale project would improve forest health, recover important and 

valuable timber, and it is the best way to reduce excessive fuel loading and high wildfire hazards over the long term (D36 p. 1)

* I strongly support the proposed action to harvest trees above 21” DBH, to restore forest health by removing trees infected 

with pathogens, and reducing the fuel to lessen the chance for hot stand destroying crown fires. (D37 p. 1)
Appendix C Snow Basin Vegetation Management Project FEIS

660

* The proposed timber harvest operation will positively impact national forestlands, the local agricultural operations, the local 

wood product industries, and help protect the recreational opportunities that exist in the Eagle Caps by preserving the beautiful 

scenery from catastrophic wildfire within the boundaries of the Snow Basin DEIS study area. (D37 p. 2, D70 p. 2)

* We strongly support Alternative #2. It is most closely aligned with the goals and objectives of the Baker County Natural 

Resource Plan. It also has the highest probability of achieving the goals outlined in the desired conditions and project 

objectives. It has the highest positive effects on the economic, custom and cultural well being of the citizens of Baker County. 

(D38 p. 1, D65 p. 1)

* The project is a good step towards returning our forests to a healthy state that resembles historic ranges, reduce s the risk of 

insect infestation and disease and minimizes the risk of catastrophic fires, while providing jobs and economic security to the 

citizens of Eastern Oregon (D38 p. 1)

* The only rational decision for restoring the historical values of this area is Alternative 2. Appropriate management of this 

area would dictate that some of the trees that have a diameter than 21” must be cut. (D39 p. 1)

* The RMEF strongly supports Alternative 2. We concur with the purpose and need and we support the necessary 

amendments to implement the project (D40 p. 1)

* OSWA supports Alternative 2. It is clear that this alternative will provide the FS with the best opportunity to meet EIS 

objectives 1, 2, and 3. The ability to remove trees 21” dbh or larger is an essential element in meeting these important 

objectives. Implementing Alternative 2 is a great opportunity for the FS to do what is right. Please do not let external politics 

keep you from doing what is needed to meet the FS’s obligation to the forests you manage and to the communities you 

surround. Please implement this alternative before a catastrophic fire removes your ability to meet your objectives or the 

industry infrastructure is gone along with the tools needed to economically manage the area. (D41 pp. 1-2)

* Alternative 2 is the best method for proper treatment and management of the subject area. I would hope that the FS pursues

a strong defense of your plan. If you continue to compromise your plans, little or nothing of any consequence will be 

accomplished, and your organization will continue to decline and more resemble the National Park Service than the original 

vibrant entity that was created many years ago. (D42 p. 1)

* The best alternative is the Forest Service Proposed Action. Our main concern is our extreme low economy due to too few 

prospects for jobs. We have lost most of our infrastructure that provided many work opportunities. Without any industry 

providing work in this area, save a few ranch jobs there is a dim future. The proposed action is a glimmer of hope than can

lead to a beneficial change in our economy by providing jobs and we want to give it a chance. (D43 and D43A p. 1)

* Alternative 2 is an excellent and much needed way of addressing a current and increasing risk to those of us that live in close 

proximity to this area. (D44 p. 1)

* I endorse the need to restore the HRV as called for in Alternative 2. This alternative will reduce competition and stress of 

key tree species, increase economically important tree species in this area (larch, ponderosa pine and Douglas-fir), promote 

greater diversity of low story vegetation and promote rapid growth of young trees, reduce risk of regional fires of disastrous 

portions, and increase both the health and genetic diversity of all remaining trees. Key to many of these five points is the

selective removal of trees greater than 21” dbh in the Snow Basin area. (D45 p. 1, D47 p. 1, D52 pp. 1-2, D54 p. 1, D55 p. 1, 

D57 p. 1, D77 p. 1)

* As a steward of small private acreage all that I may accomplish to control disease, reduce fire risk, and enhance the overall 

viability of our land and woods can be destroyed if the public lands are not managed in a sustainable manner. Alternative 2 is 

necessary to provide for the public good and safety, and is consistent with local woodland owners land management 

principles. (D45 p. 1, D54 p. 1, D57 p. 1, D77 p. 1)

* I support alternative 2, which calls for cutting any tree for the health of the forest, including those over 21 inches. (D49 p. 1, 

D70 p. 1)

* In these hard economic times, this sale will be beneficial for all concerned: the forest, agriculture, water, fish, wildlife, and 

the jobs that it will create. Originally our National Forests were created to protect our timberlands for the benefit of the people 

of the United States. Let’s not forget this! (D49 p. 1)

* All parties involved with federal land management increasingly call for landscape-scale projects but it seems each time one 

gets started people shy away from the daunting task. We recognize the difficulties in doing NEPA and defending it for a 

project of this magnitude. But we also believe there are several reasons why you must stay the course. First is the simple 

reason it’s the right thing to do in today’s environment. People are calling for such projects and it’s incumbent upon the 

agency to make these types of projects work. Second, it costs a great deal of time and expense to compile NEPA documents 

today. One of the attractive features of landscape scale projects is the economy of scale when covering larger project areas. 

Last, another benefit of a project such as this is having NEPA-completed “shelf stock.” This can be metered out over quite a 

few years ensuring a predictable, albeit still insufficient, flow of volume much needed for local jobs both in the woods and in 

the mills. (D50 p. 1, D79 pp. 1-2)

* It appears you have covered all the bases in the DEIS. We strongly support Alternative #2. It best meets the purpose and 

need for action. It also presents the best PNV and benefit:cost to the public. (D50 p. 2)

* BCPWA endorses and supports alternative 2 to achieve the restoration of the HRV. 
Appendix C Snow Basin Vegetation Management Project FEIS

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* The proposed stewardship activities in the Snow Basin will enhance the capacity of the ecosystem to deliver an array of 

services that are essential for broader health of the forest, biodiversity, and humans in the region. The forest will be much 

more productive with the opening up on the canopy; the diversity of trees will increase, along with the associated biodiversity; 

water resources will be preserved; soils and associated minerals will be secured; carbon sequestration will increase with the

more rapid growth of the trees and other vegetation. (D52 pp. 3-4)

* We estimate that it costs $40 a green ton of marketable product to cover costs to manage forests. The local rate paid for logs 

is $26 per ton, and the seller has to cover the cost to deliver the logs. A sustained supply of timber and non-timber forest 

products from public and private woodlands will encourage greater diversity in wood-based commercial activities. With 

greater competition, higher prices will be paid (D52 p. 3, D55 pp. 1-2). Alternative 2 will contribute to meeting objective 3 by 

providing more supply of a diverse array of timber and non-timber forest products, giving private foresters opportunities for 

stewardship contracts, promoting employment by stewardship contractors to meeting their obligations. A continuous supply 

of forest products will better position public and private forest managers to respond to the shifting demands for a variety of 

forest-related products in addition to traditional harvests of logs of dimensional lumber and pulp. (D52 p. 3)

* We strongly support Alternative 2 as the actions revitalize the Snow Basin forest ecosystem; increase diversity of tree 

species and biodiversity; reduce risk to private woodlands from wildfire and insect infestations and disease; and foster 

economic opportunities that will have a positive impact on the local economy. (D55 p. 2)

* Eagle Valley SWCD is in strong support of alternative 2. It has the highest probability of achieving the goals outlined in the 

desired conditions and project objectives; it is believed that this alternative provides the maximum benefit to the overall 

watershed and to the communities. This alternative will also return the forest ecosystem towards HRV that has a higher and 

healthier level of LOS while generating forest products for the existing and potential forest industries and providing much 

needed family wage employment. (D60 p. 1, D62 p. 1, D65 p. 1)

* We are very concerned about the present forest health policies of the US Forest Service. We view Alternative 2 to be a 

positive step forward in restoring forest health while at the same time beginning to make a dent in flammable materials and the 

resulting conflagrations of a forest fire. Promoting diversity of vegetation will not only promote rapid growth of young trees, 

but will also provide fire retardation as well as big game habitat. We strongly encourage the harvesting of trees greater than

21” in Snow Basin. It not only makes forest health sense – it makes economic sense. (D61 p. 1)

* I fully support Alternative 2. (D63 p. 1)

* We support Alternative 2. As a new forest products industry (Elkhorn Biomass) in Baker County with strong emphasis on 

utilization of biomass that is a by-product of commercial harvest, thinning and fuels treatments, it is imperative that there be a 

strong and consistent supply of forest products from the local National Forest lands. (D66 p. 1)

* I support Alternative 2 to help forest health and restore aspen groves; for its positive impact on our depressed economy. 

(D68 p. 1)

* I support Alternative 2. The economy in Baker and Union counties has been impacted by the deep reduction in timber 

harvest during the past 20 years. This is mostly the result of extreme environmentalists and environmental groups that have 

pushed their no common sense forest management practices on the public who are generally closest to the forest land affected. 

(D69 p. 1)

* I support a balanced forest management program that utilizes our renewable resources to ensure that our forests remain 

healthy and vibrant so that generations can enjoy them in the future. Alternative 2 provides this balance. (D69 p. 1)

* I urge you to select Alternative 2. This provides the best opportunity to improve forest health and reduce hazardous fuels. 

(D73 p. 1)

* I agree that Alternative 2 is the best option. It is the most proactive to restore forest health and is most likely to insure the 

return of the HRV for this portion of the WWNF. (D74 p. 1)

* I strongly support the WWNF in addressing the forest health issues in Eagle Creek. I believe the forest health in the 

Holcomb Creek and surrounding areas has dramatically declines in the last thirty years and that is why I support the Snow 

Basin project. A healthy forest is good for every one of us. I ask the staff to identify trees that are appropriate for removal and 

get this area of the forest back to a healthy, sustainable state. (D75 p. 1)

* We support Alternative 2, as it would clearly meet the purpose and need that articulates a need for active management to 

restore and maintain a resilient and sustainable forest ecosystem. (D79 p. 1)

* One of the things we dread most is forest wildfires. The Forest proposed Action outlines a forest management plan that can

be followed to reduce wildfires that sometimes consumes not only wild animal habitat but burns alive all the animals in a 

boundless inferno. (D33 p. 1)

* I am pleased to see aspen recovery being addressed in all of the action alternatives. This should have a high priority in all 

future vegetation management projects on the forest. (D74 p. 1)

* To successfully manage these stands the board believes that it is necessary to remove large diameter trees. Many of the 

stands to be treated are dominated by species such as grand fir that are less resistant to fire, diseases and insects that the 

desired species such as ponderosa pine and western larch. To reintroduce and/or release these more desirable species it will be 

necessary to remove the older grand fir to reduce competition that impairs growth and regeneration of the desired species. In 
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stands that are predominantly comprised of desired species, but have stocking levels well above levels that allow for maximum

tree growth, it will be beneficial to thin both trees that are both large and small in size. This will better enable managers to 

retain the healthiest, faster growing trees, therefore obtaining the goals of LOS stands in shorter time duration. In stands that 

are dominated by diseased (dwarf-mistletoe) trees removing all heavily infected trees will improve stand health and increase 

growth rates while reducing the further propagation of the diseases. (D60 p. 1, D62 p. 1, D65 p. 1)

* Makes a good case for cutting >21” dbh trees to restore old growth conditions (D35 p. 1)

* Dense thickets of trees need to be thinned to preserve the health of the forest. (D31 p. 2)

* It is clear the SS component of the forest is well under HRV and MS is over, converting the MS to SS is the correct 

management for this landscape. (D29 p. 1)

* Achieving the goals of the project will require managing trees in all size classes. As stated in the DEIS, 63% of the LOS in 

certain forest types is there unnaturally because of the large GF component in them. These trees are only an average of 93 

years old. This project will move the landscape in the right direction and to increased resiliency. (D29 p. 1)

* It is necessary to have freedom concerning the 21 inch diameter-cut to thin trees enough to reduce situations that attract 

forest insect infestations. (D33 p. 1)

* The stems per acre and basal area that exist in the tree stands within the Snow Basin EIS study area are far in excess of what 

can be supported on a sustainable basis. The WWNF timber staff needs to identify trees that are appropriate for removal to 

restore the forest to a healthy sustainable state, either by removal of these trees for timber sale and commercial logging or by 

stewardship contracts, whatever is most cost effective and environmentally appropriate. This action would qualify as real 

economic stimulus, by creating real jobs for the local forestry, logging, and wood processing mills that need this raw material 

to continue operations. (D37 p. 1, D70 p. 2)

* We believe the project will have very significant benefits to forest health by making it more resistant to fire, insect and 

disease, more resilient to forecast climate change, and concurrently it will improve habitat and forage for mule deer, elk and 

many other wildlife species (D40 p. 1)

* We believe the Forest has appropriately interpreted the Regional Forester’s June 11, 2003 letter which provides examples 

where a forest plan amendment of the Screens is appropriate. This would result in, for example, more characteristic ponderosa 

pine and western larch single layer late/old structure and more restored stands of quaking aspen. (D67 p. 1)

* We endorse the selective removal of trees >21” to restore HRV in Alternative 2. Not permitting the selective removal of 

trees >21” in Snow Basin limits management options, such as the ability to remove diseased trees that represent a greater risk 

of burning, and will indirectly affect the capacity of the forest to provide the array of forest and non-timber forest products and 

ecosystem services which are needed. (D52 p. 2, D55 p. 1)

* The 3 Forest Plan Amendments are appropriate and the project will fail to address the conditions on the ground appropriately 

without them. (D29 p. 1) 

* Diameter limit rescission is essential. A proposed forest plan amendment is essential for the project to be feasible, as well as 

for accomplishing all the desired resource objectives. Harvesting trees over 21” dbh must be a necessary component to 

implement this project. We strongly support your efforts to restore the project area back to the historic range of variability; 

but this simply cannot be accomplished without harvesting over 21” trees. (D36 p. 1)

* Implement the Forest Plan Amendments and remove trees over 21” dbh to improve forest health. (D73 p. 1)

* I support the Forest Service proposal in the Snow Basin Vegetation Management Project that would remove the 21” 

diameter restriction. It is my opinion that since the 21” diameter rule has been in place, the foresters’ hands have been tied and 

they have not been able to manage the forests well. Removal of the 21” diameter restriction will allow the foresters and 

experts to once again manage and this will in the end lead to greater forest health. (D17 p. 1)

* We are strongly opposed to any further disruption of the natural cycles that are operating in the Eagle Creek drainage, cycles 

that have had nearly twenty years to restore the drainage to a balanced, healthy ecosystem. 

* I urge the Forest Service to take No Action on the Snow Basin DEIS. I believe the last thing this area needs is more 

disturbance to wildlife habitat and native vegetation. Improper management has contributed to the change in density and 

diversity of the trees, but this appears to me to be over management of the area at a significant cost and very little economic 

benefit. Please leave it alone and give the forest a chance to heal itself. (D12 p. 1)

* I have seen the health of our forests decline dramatically leaving unhealthy trees from disease and bug infestation, and 

dramatic fires that have left a virtual dead zone. This will continue because of the overcrowding of young and old, unhealthy 

trees. I very much support the WWNF preferred Alternative 2, which calls for cutting any tree for the health of the forest, 

including those over 21 inches. (D49 p. 1)

* The forest is overcrowded in the Snow Basin area and a high percentage of the trees are dead or dying. In a forest this 

crowded, the snow fall is held up in the branches and sublimates away, leaving less water to be shared among more trees. The

result is trees stressed for moisture in the late summer and fall. When stressed by a shortage of water, the trees are subject to 

attack by diseases and insects. Then there are even more dead and dying trees. The fuel load and the increased dryness of the 

trees create the conditions for a catastrophic fire. (D31 p. 2)
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* I would like to see the larger trees preserved if possible. (D30 p. 1)

* I would hope that the limit of 21 inches could, as it applies to the grand fir particularly, be exceeded without too much 

distress to those who claim to represent environmental interests. I understand the 21” rule has a rather arbitrary basis and does 

not reflect good silvicultural practice. Poorly conceived or self serving policies of the past have created the problems that 

currently face us and those policies and practices need to be amended to reflect current realities or else we face a very 

unpleasant or questionable future with the next good fire. (D44 p. 1)

* The forest resources described are currently being exposed to disease, insect invasion and fire. If a plan to use these 

resources is not implemented soon, the potential usage of said resources could be irretrievably lost and the remediation work

needed to restore the forest would require even more funds from taxpayer investment. (D32 p. 1, D72 p. 1)

* The negative effects of fire on the region would impact the hunting and recreational use of the area, as well as the air quality 

of the local residents. The resulting erosion and run-off would negatively impact fishing activities, especially in the Eagle 

Creek watershed. Tourism and its associated income to the area would be adversely affected. The expenditure of state and 

national funds to extinguish a large fire would certainly have a negative impact on both state and national resources at a time 

when the country is already dealing with the effects of many negative economic factors. (D32 p. 1, D72 p. 1)

* This area and its proximity to the Eagle Caps makes it a special place in the WWNF, deserving of you and your staff’s 

efforts to restore forest health and protect this watershed from the damages caused by catastrophic wildfires. (D37 p. 1)

* The federal forests play a role in any rural community where so much of the land is owned by the federal government. The 

Snow Basin area is in this category. The Organic Administration Act of 1897 states that the federal forests are to, among other 

things, “furnish a continuous supply of timber for the use and necessities of citizens...” in a way that supports the 

communities in which the Forest Service plays such a big role. (D41 p. 1, D52 p. 1)

* The demise of the wood product industry on the eastside of Oregon, brought on by a reduced USFS timber sale program, has 

removed markets for the timber from small woodland owners, and many of these owners are challenged to keep their forests as 

forests because of the economics of managing them. One could argue that private landowner values are not the responsibility 

of the Forest Service, but no one can question that the sole reason for these losses in value is the result of the Forest Service 

policy that is inconsistent with the mandates of the Organic Act and has been driven by politics and not the principles of good 

forest management. Adoption of Alternative 2 will be a step in the right direction to fix this unacceptable situation (D41 p. 2)

* The Organic Act of 1897 states that the National Forests were to be established to improve and protect the forest, for the 

purpose of securing favorable conditions of water, and to furnish a continuous supply of timber for the use and necessities of 

the citizens of the united States. (D48 p. 1)

* I would like to assert my hope that any alternative selected by the FS will be based on sound, science-based ecological 

principles offering the best likelihood of achieving the stated goals for project, rather than ideologically based opinions that 

may hinder, rather than promote, long-term success, particularly in the case of 21” + dbh grand fir. Historically this species 

had a much reduced presence in much of the Snow Basin area and its current status is only due to relatively recent human 

activities such as timber harvesting and fire exclusion. The expanded grand fir component is disruptive to other important 

ecosystem values such as quaking aspen viability, and places the entire project area at extreme risk due to the elevated risk of 

abnormal, destructive wildfire behavior. The eastside screens and other management guidelines have important value, but 

misusing subjective guidelines to manage forest components such as the grand fir will only perpetuate a misaligned system, 

leading to the unnecessary and unacceptable loss of ecosystem richness and resilience on a stand, watershed and regional scale 

(D53 p. 1)

* Eagle Valley SWCS has been dedicated to improving the overall health of the Eagle Creek watershed for the past decade. 

The board believes the goals will be accomplished by managing the forest ecosystem in a manner that will improve overall 

forest health and by reducing the danger of catastrophic fire. The area has steep slopes and erodible soils and this watershed 

supports numerous farmers and ranchers who are dependent upon water from Eagle Creek for irrigation. A catastrophic fire in 

this area would not only destroy the timber stand but has the potential of leaving the landscape vulnerable to erosion thus 

degrading water quality. Wildfires also create an environment for the propagation of invasive species and destroys wildlife 

habitat. (D60 p. 1, D65 p. 1)

* It is important to consider that changes in forests and ecosystems take place over decades and centuries. At this time the 

risks of losing LOS to wildfire, insects and disease are much greater and would have far more significant long term effects 

with regard to “large old structure” than would the short term impacts of Alternative 2. It is important to recognize that short 

term impacts and disturbance are often necessary to realize the long term desired future condition. (D63 p. 1)

* I would strongly encourage harvesting all sizes of timber to protect our declining healthy forests. (D68 p. 1)

* I would love to see the WWNF restore our forests to a healthy environment for our wildlife as well for the public to enjoy. 

This is a very beautiful area and should be managed to preserve it for all generations (D68 p. 1)

* I am for managed forests that are a balance between the long-range health of the forest and society. The US has a free 

market economy and is not a socialist country. It is important for the FS to keep that in mind and strive for a balance between 

the two forces. I believe the balance has shifted too far to the left during the past few decades. The FS could do a better job of 

maintaining a healthy forest and cut back on some of the rules to that effect. (D71 p. 1)
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*I have a strong desire to see the USFS implement more silviculturally sound practices. Your organization is still called the 

Forest Service. Some sound forestry would be appreciated. (D73 p. 1)

* There are currently millions of acres of NF lands that are not sustainable in their current condition including the area covered 

under the Snow Basin DEIS. (D63 p. 1)

* Since 1986 the WWNF has experienced a series of stand destroying wildfires that, in my opinion, are outside the normal 

range of historical fires for these forest types. These uncharacteristically large wildfires are causing damage to the resources 

we cherish: clean water, large diameter ponderosa pines and firs, abundant fish, and gorgeous scenery. (D70 p. 1)

* The Snow Basin area has severe forest health issues that have not had the opportunity to be managed adequately to reduce 

these forest health risks. (D41 p. 1)

* It is wrong to log the old growth forests on public lands against the will of the public. (D59 p. 21)

* For Snow Basin and future projects to become a success for both the ecosystem and the forest products industry it is 

imperative that the proposed changes be made to the Forest Plan. 1) allowing for the harvest of trees >21”; 2) reducing the 

current level of LOS structure forests; 3) allow for harvesting in areas below the HRV. Silviculturists and land managers have 

the scientific knowledge to manage these forests in a manner that will create the long-term desired conditions, but it is very 

difficult to reach these goals while being restricted by the existing forest plan. (D60 p. 2, D62 p. 2, D65 p. 2)

* The MS stands are 2x normal fuel loads and have increased disease presence. (D29 p. 1) 

* Round top and dead spire trees are large trees with economic value, but that value will soon turn into a detriment in a few

years. These trees are dying and will turn into a massive quantity of dry fuel. (D31 p. 2) 

* I oppose the cutting restriction of 21” dbh for this project because: a. this is an arbitrary restriction which has no meaning in 

professional forest management; b. it allows disease and insect infestation favorable habitat; c. it makes good, productive, 

healthy forest impossible. Please remove the 21” dbh cutting restriction from the Snow Basin harvest plan. (D58 p. 1)

* Neither the National Forest Management Act of 1976 nor the Endangered Species Act stipulates that trees >21” cannot be 

cut. We understand the value of this rule to preserve older trees, and attendant biodiversity where clear-cutting is the norm. 

But, in the high dry zones of eastern Oregon, trees grow much slower; selective harvest of trees is the norm. (D52 p. 2) 

* Even if Alternative 2 is not chosen, both amendments to the forest plan need to be done. The “Eastside Screens” as applied

have too often been a road block to forest health restoration, especially in areas where succession has reached the point where 

grand/white fir dominates areas that were once open stands of ponderosa pine. The selective removal of trees greater than 21” 

dbh, individually or in small groups, is necessary to provide open space for new healthy regeneration of more fire and insect 

resistant species. (D74 p. 1)

* I strongly support WWNF to cut all diameter class trees to restore forest health based on published scientific reports or past 

forestry activities proving to reduce fuels loads and minimize stand replacement crown fires. The intent of the eastside screens 

was admirable, but the outcome has been that they are a tripwire to pragmatic common sense forestry operations. This 

includes timely fire salvage and sanitation cuts to remove fire mortality and diseased trees. Since the adoption of the Eastside 

Screens, the wildfires in the WWNF have not become more manageable or less intense. Instead they seem to have gotten

hotter and burn more acreage. (D37 p. 2)

* I have always been amazed that this decision (the eastside screens) actually occurred and has progressed forward and 

remains a guideline for management today. In the scheme of things, from a silvicultural standpoint, it makes no sense. (D42 

p. 1)

* We object to the 21 inch (24 inch) diameter-cut of timber as it is causing a great many economic and environmental 

problems. We want to cut wood trees of any size. (D43 and D43A p. 1)

* Among the worst decisions to come from lawsuits settled by courts that had no experience or knowledge of forestry was the 

“diameter cut.” No tree over 21 inches breast height is to be cut. It was the understanding at the time the court decision would 

only be applied for a few years but has now continued over 17 years. The diameter cut decision has done more than anything 

else to cause us to lose our original, native Douglas-fir, ponderosa pine and western larch stands and changes the dominant 

species to the shade tolerant white fir which is a wildfire’s favorite, a take-over species. By its nature it crowds out the native 

species named which are much easier to protect from wildfire. Under the diameter cut a single white fir too often has been the 

only tree left to throw its seed in every direction. These ever more frequently materializing fire enticing fir thickets are eating 

up beautiful timber stands. (D15 p. 1)

* The diameter cut has had a very negative economic impact on our local economy. Wood cutters, those dealing in heating 

wood commercially and home owners who are a major group of consumers in rural areas have experienced the greatest 

psychological and financial negative impact of the diameter cut. For a century the Forest Service used the woodcutters to take 

dead wood of all sizes off the forests to reduce fuel on the forest floor. Since the diameter cut began to be enforced 

woodcutters have been denied any tree over 21 inches breast height. As a result, there are thousands of dead trees falling to 

the ground, some of them four to five feet in diameter that are being cleaned up by prescribed burning them where they fall. 

They must be destroyed to reduce the risk of wildfires. This burning is a cost to taxpayers. (D15 p. 2) *There is a deep-seated 

growing hatred for federal agencies where the 21 inch regulation is being enforced. The resource waste of these large dead 

logs ranges into billions of cords of wood that when set on fire sends dense clouds of choking black smoke into the 
Appendix C Snow Basin Vegetation Management Project FEIS

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atmosphere from early spring until late fall. The quantity of smoke in the sky does not easily dissipate and remains as a blue 

cast in the sky through all of the summer months. This is a senseless waste of natural resources. The cost to this economy in 

recreation is billions of dollars. We have an opportunity to develop methods of dealing with wood issues that will benefit our 

economies instead of polluting the environment. (D15 p. 2) 

* Even if none of the large trees end up on log trucks, this project can still provide a lot of jobs and produce substantial volume 

of logs to local mills – 40+ mmbf, or 8000+ log truck loads. (D64A, p. 7)

* We hope this project can recognize the historic low demand for wood products and the fact that the recovery of the wood 

products industry is likely to be long and slow. Many federal timber sales are going “no bid”. All these factors should allow 

the Forest Service to adopt something closer to Alternative 4. (D64A p. 7)

* The Forest Service seems to forget they are managing an ecosystem, not trees. The view that there is some correction that 

can be done to “fix” problems of the past by cutting over 21” trees seems ludicrous at best. Besides that the cost to the 

taxpayer is huge as the trees you are targeting are worthless. This is so obvious by the massive amount of such trees that have 

been lying by the roads in that very area for the last 40 years. The price of lumber is near rock bottom so what is to be gained? 

(D23 p. 1)

* Removal of so many large trees will significantly detract from the restoration objectives that should be driving forest 

management in this area. (D64A, pp. 2-3)

Alternative #2 has the highest protection against wild and catastrophic fires as it will treat the highest number of acres. This 

area has an extremely high fuel buildup and it is imperative that active management take place to minimize a large fire event 

which could spread to summer homes and other recreation areas (D38 p. 1)

Our highest concern is cataclysmic wildfire that could engage adjacent and nearby private woodlands. The risk is very high. 

Between 1986 and 2002 extensive wildfires occurred every three or four years in the WWNF (1986, 1989, 1994, 1997, 2000, 

and 2002) where there were high fuel loads. We are well overdue for another and the Snow Basin area is particularly 

vulnerable because of the excessive fuel loads that have built up. The dense stands of grand fir are especially vulnerable to 

fire. Older trees have rotting cores in which fire can get established and smolder unseen. Young grand firs provide ladders for 

flames to reach the crowns of the less flame resistant grand fir as well as more fire-resistant species: ponderosa pine and 

western larch and older Douglas-fir. In Snow Basin there is a much higher risk that an intense crown fire could get established 

that would get out of control very quickly. In addition to the immediate loss of timber and personal property, an intense 

wildfire would also negatively impact key ecosystem services on which both biodiversity and the humans in the region 

depend. It would require several decades for the ecosystem to recover the capacity to deliver these services through natural 

succession. It will take 50 plus years for the forests to recover sufficiently to permit selective harvesting. (D52 pp. 2-3)

I have witnessed the devastating result of catastrophic wild fires, the Dooley Mountain fire that nearly wiped out our parcel on 

Beaver Creek still lies a barren wasteland due to the sheer intensity of the heat. Still another example of this total sterilization 

of the soils there not to mention the huge settlement with property owners in the area. (D45 p. 1)

As an owner of private forestland on the north side of Dooley Mountain, I lost untold economic value that was part of my 

retirement funds and spent thousands of dollars replanting the trees that burned in that 1989 wildfire. I will never see income 

from that forest in my lifetime and it will be my grandkids that do. To prevent that from happening to others in the Snow 

Basin area, the WWNF needs to actively manage these forestlands to restore forest health and provide employment to the local 

economy. (D47 p. 1) 

Because of the current conditions in the Snow Basin area there is a much higher risk that an intense crown fire could get 

established that would get out of control very quickly. In addition to the immediate loss of timber and personal property, such 

a wildfire would require several decades for the ecosystem to recover through natural succession. (D55 p. 1)

Private landowners who own property near the Snow Basin area have expressed the gravest concerns about the poor forest 

health of the WWNF timberlands adjacent to their property. The negative impact a wildfire on WWNF land would have on 

their adjacent forest is a major concern to them. In the next EIS, one landowner has expressed that the FS include the East 

Eagle and Main Eagle Creek areas that contain considerable acres of private property to consider for timber sales and 

stewardship contracts to reduce the fuels loads and minimize the negative impact a wildfire would cause to these private 

properties. (D37 pp. 1-2)

The Organic Act of 1897 states with simple clarity that National Forests were to be established to improve and protect the 

forest, for the purpose of securing favorable conditions of water flows, and to furnish a continuous supply of timber for the use 

and necessities of the citizens of the United States. This is what the WWNF needs to address in the Snow Basin EIS project. 

The USFS must protect the water quality of Eagle Creek and secure a continuous flow of clean water that is beneficial to the 

trout fisheries of that watershed, and provide a good continuous flow of water to the agricultural operations that depend on that 

water for their living. These efforts must center on a commercial logging operation. (D37 p. 1, D70 p. 1) 

EPA supports efforts to close and decommission unnecessary roads because roads contribute more sediment to streams than 

any other management activity and interrupt the subsurface flow of water, particularly where roads cut into steep slopes. In 

addition, roads and their use contribute to habitat fragmentation, wildlife disturbance, the introduction or exacerbation of 

noxious weeds, and increased fire danger from recreational activities. We believe that every project involving travel 
Appendix C Snow Basin Vegetation Management Project FEIS

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management decisions presents an opportunity to reduce continuing road related adverse impacts on forest resources. 

Decommissioning roads is particularly important in project areas, like this one, where existing road densities exceed 

thresholds identified in the Forest Plan and are deemed, from a watershed condition baseline perspective (DEIS Table 85) 

“unacceptable”. Further, decommissioning roads where stabilization would benefit water quality – which this proposal would 

do – is also important and consistent with the intent of the NEPA. (D67 pp. 1-2) 

The collateral damage resulting from even more road-building would move these forests even farther from an acceptable road 

density. Road densities on the Whitman Forest are already 2-3 times higher than they should be; more roads would just 

exacerbate the problem. (D76 p. 2)

* There is perhaps no greater defining resource issue in the Pacific Northwest than management of old growth forests. (D59 p. 

24)

* All of the remaining old growth forests need to be protected (D59 p. 24)

* One of the motivations of this project is a perceived need to treat a mistletoe “problem.” From an ecological 

standpoint, mistletoe is not a problem; it’s just part of the forest ecosystem. None of the effects of mistletoe can be 

considered ecological problems. Mistletoe creates complex habitat structures such as brooms ands snags and 

suppresses the growth of competing trees.

This project appears to be trying to address uncharacteristic levels of mistletoe, by exacerbating the 

uncharacteristic shortage of large trees. The root problem is that infected stands will have a hard time reaching 

LOS goals whether they are treated or not. However, large mistletoe infected trees have high ecological value. 

Removing large infected trees is not an effective strategy to address mistletoe, and will remove high value 

structures that will be very difficult to replace.

The pronouncement that mistletoe is uncharacteristic does not give the FS a blank check to conduct logging. 

Treatments must be both effective and restorative. In this landscape, removal of small trees may be restorative, but 

where there is such a shortage of large trees, removal of large trees is not restorative. With clear objectives and 

careful planning, it may be appropriate to kill a few strategically identified large trees that are infected with 

mistletoe, but retain them as snags and down wood. Another management option that was overlooked would be to 

remove some of the more heavily infected branches from mistletoe-infected large trees. There are number of 

science sources on mistletoe that the FS should review: Pollock & Suckling (1995), Conklin (n.d.), Penning & 

Callaway (2002), Geils et al. (2002), Bennetts et al. (1996), Maloney & Rizzo (2002), Hawksworth (1985), and 

Johnson et al. (1976). (D64A p. 20, references pp. 21-22)

* DEIS p. 330. Drop all units that would degrade or change the character of undeveloped/unroaded land areas. 

(D78 p. 4)

* DEIS p. 330. Drop units abutting portions of the PWAs. (D78 p. 4)

* DEIS p. 330. Drop the 3 units where they overlap “polygon” 52. (D78 p. 4)