United Staes

Departmn of

Agriculte

Forest

Servic

Pacific 

Southwest 

R5-MB-235 

Region 5 

Final Environmental 

Impact Statement for 

Fish Camp Project 

Sierra National Forest, Bass Lake Ranger District 

Madera/Mariposa Counties, CA 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 

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Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 

FISH CAMP PROJECT 

Final Environmental Impact Statement 

Madera & Mariposa Counties, California; Sierra National Forest; Bass Lake Ranger District 

Lead Agency: USDA Forest Service 

Cooperating Agencies: N/A 

Responsible Official: Scott Armentrout, Forest Supervisor 

 1600 Tollhouse Road, Clovis, CA 93611 

For Information Contact: Mark Lemon, District Fuels Officer 

 57003 Road 225, North Fork, CA 93643 

 (559) 877-2218 ext. 3110 

Abstract: This document examines the environmental effects of a proposal to move towards 

meeting management goals and objectives set forth in the SNF-LRMP, as amended. The purpose 

of the proposal is multi-faceted and has two primary purposes (1) the placement of treatment 

areas on the landscape to reduce the intensity and spread of wildfires across the landscape and 

near communities and (2) to reduce inter-tree competition to improve tree vigor increasing stand 

resistance to drought conditions, and insect and disease attack. Alternatives considered in detail 

are: Alternative 1 (No Action), which would leave the area in its present condition; Alternative 2 

(Proposed Action), which proposes to thin conifer stands to reduce stand densities and ladder 

fuels; masticate ladder fuels and brush/shrub patches; utilize prescribed burning; manually treat 

and/or prescribed burn noxious weed infestations; and site prepare and plant failed conifer 

plantations; Alternative 3, contains similar types of treatments as Alternative 2, but proposes to 

limit the degree of treatment to that needed to achieve fire and fuels objectives only in all 

treatment areas.
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 

This page deliberately left blank. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest iv Table of Contents

Table of Contents 

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

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

Document Structure ............................................................................................................. 1

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

Purpose and Need for Action ................................................................................................ 2

Proposed Action .................................................................................................................. 4

Decision Framework ............................................................................................................ 5

Forest Plan Direction ........................................................................................................... 5

Public Involvement .............................................................................................................. 6

Significant Issues ................................................................................................................. 7

Changes between the DEIS and the FEIS ............................................................................... 9

Chapter 2 Alternatives, Including the Proposed Action ........................................................ 10

Introduction ...................................................................................................................... 10

Design Criteria .................................................................................................................. 13

Comparison of Alternatives ................................................................................................ 26

Chapter 3 Affected Environment and Environmental Consequences ....................................... 30

Past, Present and Reasonably Foreseeable Actions ................................................................ 30

Cultural Resources ............................................................................................................. 35

Botany: Rare plants and Noxious Weeds .............................................................................. 40

Geology/Soils.................................................................................................................... 47

Lands/Special Uses ............................................................................................................ 59

Terrestrial Wildlife ............................................................................................................ 62

Aquatic Wildlife and Management Indicator Species ............................................................ 90

Terrestrial Management Indicator Species .......................................................................... 113

Hydrology/Water Quality ................................................................................................. 128

Alternative 1 – No Action................................................................................................. 130

Forest Vegetation/Silviculture ........................................................................................... 137

Fire/Fuels........................................................................................................................ 150

Air Quality ...................................................................................................................... 175

Environmental Consequences ........................................................................................... 182

Engineering / Transportation............................................................................................. 193

Economics ...................................................................................................................... 194

Chapter 4. Consultation and Coordination .......................................................................... 205

Preparers and Contributors ............................................................................................... 205

Distribution of the Environmental Impact Statement ........................................................... 206

Glossary ......................................................................................................................... 207

Literature Cited ............................................................................................................... 217

Index .............................................................................................................................. 233

Appendices ..................................................................................................................... 234

Appendix A – Map Package for Fish Camp Project ............................................................. 234

Appendix B – Best Management Practices - Stream Crossing Design Measures .................... 235

Appendix C – Response to Comments ............................................................................... 247

Appendix D – Data Tables Fish Camp Project .................................................................... 299

Appendix E - Sugar Pine California Wildlife Habitat Relationship Mapping and Acres .......... 304
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest v Table of Contents

Table of Tables 

Table 1: Riparian Area Management Zones ................................................................................ 19

Table 2 Relationship Feature Types, RCA, Stream Classes, SMZ, RMA, and Stream Orders . 20

Table 3: Comparison of Alternatives .......................................................................................... 26

Table 4: Past, Present and Reasonably Foreseeable Actions ....................................................... 32

Table 5: Forest Service Sensitive Plants ..................................................................................... 41

Table 6: Summary of Soil Map Units in the Fish Camp Area .................................................... 50

Table 7: Description of Soil Taxonomic Units ............................................................................ 52

Table 8: Soil Disturbance ............................................................................................................ 53

Table 9: Special Status species on the Sierra NF. ....................................................................... 64

Table 10: Action Alternatives Summary of changes to CWHR Forest Type ................................ 68

Table 11: Fish Camp Treatment Units within California spotted owl PACs or HRCAs .............. 71

Table 12: Analysis of Effects to female fisher habitat 4 mile radius around Fish Camp Project .. 79

Table 13: Summary of subwatershed conditions (millimeters ...................................................... 90

Table 14: Perennial streams; resident trout occupancy ................................................................. 91

Table 15: Amount and value of MYLF habitat in the analysis area based on CW HR. ................ 94

Table 16: Amount and value of occupied YThabitat in the analysis area based on CWHR. ........ 97

Table 17: Summary of potential habitat within Project area subwatersheds. ................................ 97

Table 18: Activities proposed under Alternative 1 ...................................................................... 100

Table 19: Potential effects to habitat from Alternative 1 (acres are approximate) ...................... 101

Table 20: Acres of habitat cumulatively affected under Alternative 1. ...................................... 102

Table 21: Alternative 2 activities (acreages approximations generated by GIS).. ...................... 102

Table 22: Overlap of Proposed Treatment Areas and Potential Habitat for species. ................. 103

Table 23: Acres of habitat cumulatively affected under Alternative 2. ...................................... 109

Table 24: Effects from Alt. 1 on aquatic threatened, endangered, and sensitive species. ........... 111

Table 25: Effects from Alt. 2 and 3 on aquatic threatened, endangered, and sensitive species. . 112

Table 26: Selection of MIS for Project-Level Habitat Analysis for the Fish Camp Project. ...... 115

Table 27: Summary of Treatments with pre- and post-treatment CWHR type acres ................. 119

Table 28: Subdrainage Summaries. ............................................................................................. 128

Table 29: Existing (Baseline) CWE Conditions. ......................................................................... 131

Table 30: Activities proposed within Project area subdrainages under Alternative 2 ................ 131

Table 31: Alternatives 2 and 3 CWE Conditions. ....................................................................... 135

Table 32: Principles of Fire Resistant Forests. ............................................................................ 151

Table 33: Adapted from How to Predict the Spread and Intensity of Forest and Range Fires. ... 157

Table 34: Rocky Mountain Research Station Fuel Models, S ..................................................... 158

Table 35: Fire History within the Project boundary .................................................................... 160

Table 36: Fire History Outside of the Project boundary ............................................................. 160

Table 37: Indicator for Fuel Models in Shrub/Brush Areas. ....................................................... 162

Table 38: Indicators for Fuel Models in Timbered Covered Areas. ............................................ 162

Table 39: Shows the predicted results of fuel model conversions anticipated with this Alt. ...... 167

Table 40: Sensitive receptors identified within 10 miles of the Fish Camp Project .................... 176

Table 41: Tons of Estimated Pollutants per Individual Project. .................................................. 177

Table 42: Federal de minimus Threshold Levels . ....................................................................... 179

Table 43: Class I airsheds near the Fish Camp Project area. ....................................................... 181
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest vi Table of Contents

Table 44: Statewide Emission Inventory for Natural Sources-Wildfire ...................................... 185

Table 45: Potential emissions of wildfire Fish Camp Project boundary. .................................... 186

Table 46: Total Emissions from All Prescribed Fire Treatments Proposed in this Action ......... 187

Table 47: Total tons of emissions for mechanical treatments and road maintenance Alt. 2. ...... 188

Table 48: Emissions conformity to General Conformity Rule for Criteria Pollutants ................ 188

Table 49: Fish Camp economic analysis for alternative 2 ........................................................... 196

Table 50: Fish Camp economic analysis for alternative 3 ........................................................... 197

Table 51: Full time Job relationship to specific project tasks ..................................................... 198

Table of Figures 

Figure 1: Associated Bounds and Treatments within Old Forest Linkages ................................. 20

Figure 2: Locations of invasive weeds in the Fish Camp Project area ......................................... 43

Figure 3: Terrestrial Wildlife Management Areas ........................................................................ 62

Figure 4: FIA Plot data Log Decomposition Classes ................................................................... 66

Figure 5: FIA Plot data Snag Decay Classes ................................................................................ 66

Figure 6: Mean daily water temperatures through the summer of 2008. .................................... 90

Figure 7: Expected summer temperature range ............................................................................ 92

Figure 8: Potential habitat for MYLF in the analysis area (yellow are lands in Yosemite NP). .. 94

Figure 9: YT occupied habitat, potential habitat, and dispersal ................................................... 96

Figure 10:Fish Camp Project area with subdrainages, perennial streams, and meadows. T ....... 130
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest – vii Summary

Summary

The Sierra National Forest (SNF), Bass Lake Ranger District (BLRD) proposes to create a 

network of landscape area treatments and defensible fuels profiles near key transportation 

corridors to reduce the intensity and spread of wildfire across the landscape and near 

communities. As part of the proposal, treatments to improve forest health are planned to reduce 

inter-tree competition and improve tree vigor providing increased stand resistance to drought 

conditions, and insect and disease attack. 

The area affected by the proposal includes 5,440 total Project boundary acres within the Big 

Creek watershed, in the Southern Sierra Nevada. The project is immediately east of the 

community of Fish Camp (designated as Wildland Urban Intermix [WUI]) and State Highway 41. 

Vegetation types include ponderosa pine plantations, and wild stands made up of mixed conifer, 

true fir, and hardwood species, as well as areas dominated by brush, rock and steep slopes. 

This action is needed, because under the amended SNF-LRMP (Sierra Nevada Forest Plan 

Amendment [SNFPA], Record of Decision [ROD], USDA-FS 2004), an ecosystem approach to 

project development and planning is recommended. Where there are significant departures from 

the desired condition or potential for a loss in key ecosystem functions management actions to 

address these departures were developed. An emphasis on the inter-relationship of the major 

functional program goals was placed on these actions. Of particular concern was the State 

Highway 41 Corridor with its high concentration of human habitation and the declining health of 

forest stands within and surrounding these areas. 

The community of Fish Camp is one of the communities of interest within the State Highway 41 

Corridor and is considered highly vulnerable to and at risk from wildland fire. Current forest 

conditions, due to past management activities (including harvesting operations, fire 

exclusion/suppression, housing development, etc.) have changed from one where fires were of 

frequent, low intensity to current conditions where fires are infrequent, and of moderate to high 

intensity. Forest structure and composition has developed, through the lack of fire in a fire 

dependent ecosystem, into overabundant shade-tolerate conifer species in the lower and mid-level 

canopies of the forested stands. This overstocking of conifers has led to a decline in forest health 

and high susceptibility of loss from insects, disease, drought conditions and wildland fire. 

A variety of wildlife species are highly dependent on conditions provided by functioning 

ecosystems (Pacific fisher, California spotted owl and Northern goshawk, to name a few) and are 

susceptible to possible loss of viability if the degree of change in their habitat and the ecosystem 

in which they are dependent is improperly balanced. There is uncertainty (due to gaps in 

information) surrounding the proper degree of change that can occur in these species habitat, 

where forest functionality and resilience can be improved and where human habitation’s 

susceptibility to wildland fire can be reduced. 

These issues led the agency to develop alternatives to the Proposed Action including: 

 Alternative 1 – No Action. Under the No Action alternative, current management 

plans would continue to guide management of the Project area. No thinning, either 

commercial, pre-commercial and/or biomass operations, of mixed conifer and pine 

stands, mastication of brush/shrub patches, prescribed burning to reduce natural fuel 

accumulations and/or treatment of infestations of noxious weeds and replanting of 

conifers in failed conifer plantations would be implemented to accomplish the purpose 

and need. 

 Alternative 2 – Proposed Action. Treatment areas within the Project area boundary 

were delineated to include those areas where some form of treatment was necessary to 

meet the purpose and need. First treatment areas were designed to reduce the intensity 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest viii Summary

and spread of wildfires in and around WUI. Fire and fuels treatments reduce the ladder 

and surface fuels within the lower and limited mid-level canopy as per the Fire and Fuels 

Objectives. Treatment areas near key transportation corridors and within the defense zone 

of the WUI were designed next. Treatment areas were designed to not only focus on 

those treatments needed to meet Fire and Fuel Objectives, but also meet Forest Health 

Objectives. Areas where the stands were considered overstocked with conifers and are in 

higher levels than can be sustained with changing environmental conditions are 

vulnerable to loss from insect, disease and wildfire. Forest health treatments are designed 

to reduce basal area and stocking to such a level that the stands are resilient to changing 

environmental conditions, increasing growth and vigor with reduced stand susceptibility 

to insect and disease attack and wildfire. These treatments occur within the lower and 

mid-level canopy. 

 Alternative 3 – Lower and Limited Mid-level Canopy Treatments, All 

Treatment Areas. In Alternative 3, treatment areas would remain the same as in 

Alternative 2. Treatments within these areas would include only those needed to reduce 

surface and ladder fuels (within the lower and limited mid-level canopy levels) to achieve 

Fire and Fuels Objectives only. Under Alternative 3 there would be no additional 

treatments (i.e. additional thinning in the mid-level canopy) to address stand density and 

Forest Health Objectives. 

Major conclusions are displayed in the following table: 

Major Conclusions 

Resource 

Area 

Indicator Alt 1 Alt 2 Alt 3 

Cultural 

Resources 

(page 9)

The degree to 

which historic 

property values 

are diminished. 

53 sites have the 

potential to be 

adversely affected if 

a uncharacteristically 

severe wildfire was 

to occur from 

untreated fuel 

accumulations. 

Artifact looting could 

occur from increased 

access and visibility 

of sites resulting 

from a 

uncharacteristically 

severe wildfire. 

Cumuluative effects 

are unlikely. 

By implementing the 

Standard Protection 

Measures outlined in the 

Regional PA, Attachment 

B, the historic property 

values of 53 sites would 

not be diminished as a 

result of implementing this 

alternative. 

No cumulative effects are 

anticipated. 

Similar Effects to Alternative 

2. 

Botanical 

TES (page 33) 

*Other plant 

species do not 

have habitat 

Determinations for TES species 

No effect 1 Threatened species 

Calyptridium 

pulchellum 

1 Threatened species 

Calyptridium pulchellum 

1 Threatened species 

Calyptridium pulchellum 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest ix Summary

Resource 

Area 

Indicator Alt 1 Alt 2 Alt 3 

within the 

Project area, 

therefore 

would not be 

impacted by 

any of the 

alternatives. 

May affect but is 

not likely to 

adversely affect 

N/A N/A N/A 

 May affect 

individuals, but is 

not likely to result 

in a trend toward 

Federal listing or 

loss of viability 

4 Sensitive species 

Epilobium howellii 

Peltigera hydrothyria 

Hulsea brevifolia 

Cypripedium 

montanum 

4 Sensitive species 

Epilobium howellii 

Peltigera hydrothyria 

Hulsea brevifolia 

Cypripedium montanum

4 Sensitive species 

Epilobium howellii 

Peltigera hydrothyria 

Hulsea brevifolia 

Cypripedium montanum 

Noxious 

Weeds (page 

39) 

Potential for 

Noxious Weed 

Spread 

Increased risk of 

spread if wildfire was 

to occur in the area 

and fireline 

equipment does not 

follow Noxious 

Weed Prevention 

Practices (e.g. under 

extreme emergency 

no time for 

equipment cleaning) 

Low risk of spread through 

use of design criteria for 

prevention of spread. 

Similar Effects to Alternative 

2. 

Soils/Geology 

(page 45) 

Potential for 

reduction in Soil 

porosity due to 

compaction 

Compacted soils (in 

4.55% of the Project 

area) would continue 

to recover over time 

with no additional 

disturbance. 

Design criteria would 

minimize detrimental 

compaction of soils. 

Similar Effects to Alternative 

2. 

Soil Cover 

Remaining (Large 

Woody Debris) 

Meets and/or exceeds 

current Regional 

Standards 

Reduction, but would 

continue to meet and/or 

exceed Regional Standards 

Similar Effects to Alternative 

2. 

Lands/Special 

Uses (page 57) 

Effects to Special 

Uses Permitted in 

Project area. 

No Effect With implementation of 

Design criteria minimal to 

No effect 

Similar Effects to Alternative 

2. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest x Summary

Resource 

Area 

Indicator Alt 1 Alt 2 Alt 3 

Terrestrial 

Wildlife 

(page 60) 

*Listed below 

are species 

that do not 

have habitat 

within or 

adacent to the 

Project area, 

nor are 

directly, 

indirectly or 

cumulatively 

effected by 

this Project 

therefore the 

Project would 

have no effect 

on them: 

Valley 

Elderberry 

Longhorn 

Beetle

Desmocerus 

californicus 

dimorphus (T)

Bald Eagle 

Haliaeetus 

leucocephalus 

(FSS)

Wolverine

Gulo 

gulo(FSS, C)

Willow 

Flycatcher

Empidonax 

trailli (FSS) 

No effect 

California Spotted 

Owl Strix 

occidentalis 

occidentalis (FSS) 

Great Gray Owl

Strix nebulosa (FSS) 

Northern goshawk

Accipiter gentilis

(FSS) 

Pallid bat Antrozous 

pallidus (FSS) 

Townsend’s bigeared bat 

Corynorhinus 

townsendii (FSS)

Western red bat

Lasiurus blossevillii

(FSS) 

Sierra Nevada red 

fox Vulpes vulpes 

necator (FSS) 

American marten

Martes americana

(FSS) 

Pacific fisher Martes 

pennanti pacifica

(FSS) 

Pallid bat Antrozous 

pallidus (FSS) 

Townsend’s big-eared 

bat Corynorhinus 

townsendii (FSS)

Pallid bat Antrozous 

pallidus (FSS) 

Townsend’s big-eared bat 

Corynorhinus townsendii

(FSS)
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest xi Summary

Resource 

Area 

Indicator Alt 1 Alt 2 Alt 3 

 (T)= 

Threatened 

(E)= 

Endangered 

(P)=Proposed 

(C)=Candidate 

(FSS)=Forest 

Service 

Sensitive 

May affect 

individuals, but 

is not likely to 

result in a trend 

toward Federal 

listing or loss of 

viability 

N/A

California Spotted Owl

Strix occidentalis 

occidentalis (FSS) 

Great Gray Owl Strix 

nebulosa (FSS) 

Northern goshawk

Accipiter gentilis (FSS) 

Pallid bat Antrozous 

pallidus (FSS) 

Townsend’s big-eared 

bat Corynorhinus 

townsendii (FSS)

Western red bat Lasiurus 

blossevillii (FSS) 

Sierra Nevada red fox

Vulpes vulpes necator

(FSS) 

American marten Martes 

americana (FSS) 

Pacific fisher Martes 

pennanti pacifica (FSS) 

California Spotted Owl

Strix occidentalis 

occidentalis (FSS) 

Great Gray Owl Strix 

nebulosa (FSS) 

Northern goshawk Accipiter 

gentilis (FSS) 

Pallid bat Antrozous 

pallidus (FSS) 

Townsend’s big-eared bat 

Corynorhinus townsendii

(FSS)

Western red bat Lasiurus 

blossevillii (FSS) 

Sierra Nevada red fox

Vulpes vulpes necator (FSS) 

American marten Martes 

americana (FSS) 

Pacific fisher Martes 

pennanti pacifica (FSS)
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest xii Summary

Resource 

Area 

Indicator Alt 1 Alt 2 Alt 3 

Aquatic 

Wildlife TES

(page 63) 

*Listed are 

species that do 

not have 

habitat 

withinor 

adacent to the 

Project area, 

nor are 

directly, 

indirectly or 

cumulatively 

effected by 

this Project 

therefore the 

Project would 

have no effect 

on them: 

Central Valley 

Steelhead (T) 

Delta smelt 

(T) 

Hardhead 

(FSS) 

California Red 

Legged Frog 

(T) 

Limestone 

Salamander 

(FSS) 

Relictual 

slender 

salamander 

(FSS) 

Foothill 

Yellow-Legged 

Frog (FSS) 

Western Pond 

Turtle(FSS)

No Effect 

Moutain Yellow 

Legged Frog (C/FSS) 

Yosemite Toad 

(C/FSS)

 

May affect 

individuals, but 

is not likely to 

result in a trend 

toward Federal 

listing or loss of 

viability 

N/A 

Moutain Yellow Legged 

Frog (C/FSS) 

Yosemite Toad (C/FSS)

Moutain Yellow Legged 

Frog (C/FSS) 

Yosemite Toad (C/FSS)

Aquatic 

Management 

Indicator 

Species (page 

63) 

Habitat conditions 

or alteration 

Macro-inverttebrates 

and Pacific Tree 

Frog= 

No expected direct, 

indirect or 

cumulative effects to 

habitat 

Macro-invertebrates and 

Pacific Tree Frog= 

Project Design Criteria 

expected to maintain 

habitat 

Macro-invertebrates and 

Pacific Tree Frog= 

Project Design Criteria 

expected to maintain habitat 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest xiii Summary

Resource 

Area 

Indicator Alt 1 Alt 2 Alt 3 

Terrestrial 

Management 

Indicator 

Species (page 

89) 

Habitat conditions 

or alteration and 

their effects on 

species 

Greatest effect on 

some species habitat 

would be loss or 

alteration due to 

uncharacteristically 

severe wildfire. 

Although there would be 

minor alterations to 

habitat, not any one 

particular habitat would be 

significantly affected or 

cause effects on species 

dependent on that habitat. 

Similar Effects to Alternative 

2. 

Hydrology 

(page 105) 

Cumulative 

Watershed Effects 

(CWE’s) 

Threshold Levels 

Reached 

The only watershed 

considered to be at or 

near CWE prior to 

field investigations is 

a segment of 

501.5005. 

Specifically, 

subdrainage 

501.5005 has a subbasin where CWE 

response is occurring, 

which includes Long 

Meadow. 

None of the subdrainages 

exceeded the Upper TOC 

of 14%. All of the 

subdrainages have been 

inspected for CWE 

response in the field by an 

IDT or surveyed using 

various methods (e.g., SCI, 

Pfankuch); Baseline and 

Project CWE data and IDT 

observations suggest that 

there is a low potential for 

CWE response from the 

Proposed Action 

throughout the greater 

subdrainage 501.5005, but 

a localized CWE response 

is occurring in the Long 

Meadow sub-basin. 

All of the subdrainages 

calculated above their Lower 

TOC% when adding in the 

Proposed Action, but none 

exceeded the Upper TOC of 

14%. Since the treatment 

acreages would not change 

under Alternative 3, the 

%ERA calculation would be 

the same as in Alternative 2 

resulting in the same 

conclusion, that is, none of 

the subdrainages exceeded 

the Upper TOC of 14%. 

Baseline and Project CWE 

data and IDT observations 

suggest that there is a low 

potential for CWE response 

from Alternative 3 

throughout the greater 

subdrainage 501.5005, but a 

localized CWE response is 

occurring in the Long 

Meadow sub-basin. 

Air Quality 

(page 166) 

Degree of 

degradation of Air 

Quality from 

Smoke 

High degree of long 

lasting unhealthy to 

severe graded air 

quality from potential 

uncontrolled 

wildfire(s). 

If an uncontrolled 

wildfire was to occur 

within the area, 

smoke would 

produce unhealthy, 

widespread, 

prolonged and sever 

periods of air quality 

degradation. 

Depending on upper 

level atmosphere 

Class 1 air sheds 

could be impacted. 

With prescribed burning 

occuring on Air District 

designated affirmative 

Burn Days, only short-term 

impacts to air quality 

would occur in isolated 

areas. 

Potential air quality 

impacts from wildfires 

would be reduced with less 

ground fuels available. 

Similar Effects to Alternative 

2. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest xiv Summary

Resource 

Area 

Indicator Alt 1 Alt 2 Alt 3 

Transportation 

System (page 

184) 

Effects of 

Transportation 

System 

With minimal 

maintenance there is 

a continued potential 

for loss of 

infrastructure 

investment from 

erosion, wet weather 

use, and brush 

encroachment 

Roads not meeting 

acceptable standards would 

be required to have 

maintenance, or 

reconstruction done for 

Project implementation. 

This has the potential to 

reduce erosion problems 

caused by transportation 

cooridors. 

Implementation of BMP 

and erosion control 

measures would reduce the 

impacts of such 

construction. 

Similar Effects to Alternative 

2. 

For a summary of Forest Vegetation/Silviculture and Fire/Fuels major conclusions please refer to 

Table 2, Comparison of Alternatives on page 19. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 1 Chapter 1 - Purpose and Need

Chapter 1 Purpose of and Need for Action

Document Structure ______________________________ 

The Forest Service has prepared this Environmental Impact Statement in compliance with the 

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

regulations. This Environmental Impact Statement discloses the direct, indirect, and cumulative 

environmental impacts that would result from the Proposed Action and alternatives. The 

document is organized into four chapters: 

Chapter 1 Purpose and Need for Action: This chapter briefly describes the Proposed Action, 

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

also details how the Forest Service informed the public of the Proposed Action and how 

the public responded. 

Chapter 2 Alternatives, including the Proposed Action: This chapter provides a detailed 

description of the agency Proposed Action as well as alternative actions that were 

developed in response to comments raised by the public during scoping. The end of the 

chapter includes a summary table comparing the Proposed Action and alternatives with 

respect to their environmental impacts. 

Chapter 3 Affected Environment and Environmental Consequences: This chapter describes 

the environmental impacts of the Proposed Action and alternatives. 

Chapter 4 Consultation and Coordination: This chapter provides a list of preparers and 

agencies consulted during the development of the environmental impact statement. 

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

presented in the environmental impact statement. 

Index: The index provides page numbers by document topic. 

Additional documentation, including more detailed analyses of Project area resources, may be 

found in the Project planning record located at Bass Lake Ranger District (BLRD) office in North 

Fork, California. 

Background _____________________________________ 

The SNF-LRMP was amended in 2001 by the Sierra Nevada Forest Plan Amendment (SNFPA) 

Record of Decision (ROD) (USDA-FS 1992, 2001b). Standards and Guidelines for project 

planning were to focus on the modification of fire behavior through fuels treatments. These 

treatments were to have the highest priority in areas described as Wildland Urban 

Interface/Intermix (WUI), (see map package; map2). In 2004, a Supplemental Environmental 

Impact Statement (USDA-2004a) was written to the SNFPA and a ROD was signed (USDA-FS 

2004b). This ROD replaced the 2001 decision in its entirety. This decision recommended an 

ecosystem approach whereby the development and planning of projects would be based not only 

on fuels reduction treatments, but would create an overall approach by looking at all key elements 

within an ecosystem. WUI continued to be the highest priority area for treatments. 

In July 2005, the BLRD completed the Fresno River Landscape Analysis. In the Fresno River 

Landscape Analysis, the State Highway 41 Corridor was determined as an area with greatest 

departure from desired conditions set-forth in the SNFPA ROD (USDA-FS 2004b) and where 

opportunity existed to move it closer to that desired condition. Although the Fish Camp Project is 

not located in the Fresno River Watershed it is still part of the area of concern along the Highway 

41 corridor. This area includes high concentrations of recreational activity and human habitation. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 2 Chapter 1 - Purpose and Need

Adjacent forests suffer with declining health from overcrowding and include habitat for speciesat-risk (such as California Spotted Owl, goshawk and Pacific fisher). 

Following management goals and direction from the SNFPA 2004 ROD (USDA-FS 2004b), 

treatment areas for the Fish Camp Project were developed. These treatment areas were based on 

the basic fire and fuels strategy which remained in the SNFPA 2004 ROD (USDA-FS 2004b); 

reducing the risk of wildland fire to WUI and to effectively modify wildland fire behavior by 

strategically placing a pattern of area treatments (known in the SNFPA 2004 ROD (USDA-FS 

2004b) as SPLATs, see map3) across broad landscapes. In addition, this strategy was broadened 

to include the need to consider and provide for other important objectives to improve forest health 

by restoring and maintaining ecosystem structure and composition. A network of land 

allocations, designated as part of the SNFPA 2004 ROD (USDA-FS 2004b), have an associated 

set of desired conditions, management intents, and management objectives. From standards and 

guidelines management direction is provided for project planning and implementation. The 

vegetation and fuels treatment standards and guidelines are intended to (1) act as sideboards for 

local managers as they design projects to meet fuels and vegetation management objectives and 

respond to site-specific conditions, and (2) retain important components of habitat that are 

believed to be important to species associated with old forests, including large trees, structural 

diversity and complexity, and moderate to high canopy cover. At the project level, these 

standards and guidelines are used in conjunction with desired conditions, management intents, 

and management objectives for the relevant land allocation to determine appropriate treatment 

prescriptions (SNFPA 2004 ROD; USDA-FS 2004b). 

As part of the SNFPA 2004 ROD (USDA-FS 2004b), an adaptive management and monitoring 

strategy designed to address high priority, key questions that relate to the uncertainties associated 

with management activities was to be initiated. In 2006, Region 5 (Pacific Southwest Region) of 

the Forest Service, as well as other Federal and State Agencies, entered into an agreement with 

the University of California whereby the university would act as a neutral third party to studying 

the effects of management actions associated with implementation of the SNFPA 2004 ROD 

(USDA-FS 2004) management direction. Focus was on the four key areas where the highest 

priority management questions exist (detailed and incorporated from SNFPA 2001 FEIS, 

Appendix E [USDA-FS 2001] and SNFPA 2004 FSEIS [USDA-FS 2004a]). These key areas 

include wildlife (specifically Pacific fisher/California spotted owl), fire and forest health, water 

quality and quantity, and public participation. This adaptive management study is known as 

Sierra Nevada Adaptive Management Study (SNAMP) and is focused on an area directly south of 

the Fish Camp Project. One of the key issues with the Fish Camp Project is it falls within the 

Pacific fisher habitat zone. Knowledge gained by the SNAMP project has been utilized in the 

design of the Fish Camp Project including; current movement patterns and 2008/2009/2010 

denning sites (both birthing and maternal) of Pacific fisher that have been radio collared and 

intensively monitored within and outside of the Project area, and information about what type of 

habitat conditions are preferred by denning females. 

Purpose and Need for Action _______________________ 

The Fish Camp Project area lies within the Big Creek watershed, where during the period before 

significant Euro-American influence, natural fires occurred frequently and were low intensity 

with return intervals ranging from five to ten years. During the past century, wildland fires have 

played a significant role around the Fish Camp Project area and the Southern Yosemite National 

Park area. Between 1911 and 2008 there have been eight fires within three miles of Fish Camp 

Project area. The majority of fires occurred between 1911 and 1934 and ranged in size from 106 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 3 Chapter 1 - Purpose and Need

to 3930 acres. These fires were mostly to the south and west of the Project area. Although there 

is no documented history of large fire occurrence in the Project area, numerous residual trees and 

cut stumps show witness to fire. In 1990 a 26 acre fire started in or near two adjacent plantations, 

causing severe damage to both. In 1924 an 800 acre fire to the south west of Fish Camp was 

stopped within a tenth of a mile of the community. 

The areas east of the Fish Camp Project area received extensive logging between 1918 and 1925 

which resulted in slow natural regeneration of conifer species. Railroad and ground-based 

logging activities as well as stand replacing fires have resulted in little of the area with trees over 

100 years of age. The natural stands proposed for thinning generally consist of approximately 85 

to 100 year old shade tolerant trees. In the early 1950’s and 1960’s, a large number of the brush 

fields, that resulted for either past management actions or historic wildfires were prepared and 

planted with conifer species. Due to fire exclusion and areas not logged during the early 1920’s, 

conifer stands within the Fish Camp Project area have become densely populated with natural 

regeneration of fire intolerant species. 

Existing Condition 

Hundreds of small trees per acre are common beneath stands of white fir, sugar pine, incense 

cedar, and ponderosa/Jeffrey pine in the lower elevations and red fir in the higher elevations. 

These small understory trees consist of mostly shade tolerant incense cedar and white fir. 

Ponderosa pine and incense cedar have naturally reseeded into many areas where they are 

severely overstocked and create significant fuel ladders. Additionally this overstocking has 

created stands that can no longer successfully compete during natural disturbances such as 

drought conditions, insects/disease attacks and/or wildfire. 

The community of Fish Camp borders the west side of the Project area. This Project also affects 

three Forest Service campgrounds, a State Snow Play area and a county refuse transfer site. Also 

within the Project is a 244 room hotel situated on 35 acres with numerous out buildings and guest 

cottages. There is also a special use permit for a wilderness pack station and horseback riding. 

Many of the homes in the Fish Camp community do not have adequate clearance to protect them 

if a fast moving wildland fire were to move into the subdivision. Compounding this problem is 

poor access in the subdivision, with narrow winding roads and only one main road as access in 

the event of a wildfire. These conditions create additional hazards and risks to public and 

firefighter safety during wildfire evacuation situations. 

The Fish Camp Project area is located at the southern entrance to Yosemite National Park and as 

tourism increases recreational activities “spill” into the National Forest and the Project area. 

With high concentrations of recreation visitors during the height of the summer season, 

evacuations would be difficult if a fast moving fire started. Natural and/or human caused fires 

starting to the south of the Project or near the town of Fish Camp would have the greatest 

potential for threat. 

The last century was unusually wet compared to prior centuries.1 This wetter than normal period 

coupled with the exclusion of fire has set the stage for stands to become overcrowded with 

competing conifers, oaks and other vegetation. Changes in weather conditions over the past thirty 

years have placed stress on many of these stands. Inter-tree competition, drought, rising 

temperatures, and insect attacks are beginning to take a toll on both plantation and wild stands. 

White pine blister rust has also been killing a number of sugar pine over the past ten to fifteen 

years. Dead and down fuel loadings have been on the rise. 

 

1 Sierra Nevada Forest Plan Amendment, Record of Decision, 2004. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 4 Chapter 1 - Purpose and Need

Desired Conditions 

The underlying need(s) for this Project include: 

 Protecting human communities from moderate to high intensity wild fires as well as 

minimize the spread of wildfires that might originate in urban areas into the forested 

lands created by unnaturally high levels of fuel ladders and dead material. 

 Increasing the resiliency of overstocked stands to attack from insects, diseases, drought 

conditions, and/or wildfire. 

In meeting the aforementioned needs the action must also achieve the following purposes: 

 Reduction in the intensity and spread of wildfires across the landscape and near 

communities. The reason for this purpose is to provide a buffer between developed areas 

and wildlands where fire suppression capabilities are enhanced by modified fire behavior 

inside the WUI zones as well as provide a safe and effective area for fire suppression 

activities to occur (USDA-FS 2001, page 9). 

 Reduction in stand density within the lower and mid-canopy layers of conifer stands, to 

provide for increased stand resiliency, growth and vigor. The reason for this purpose is to 

increase the capability for forested stands to withstand drought conditions, attacks from 

insects and diseases, and the effects from wildfire. 

Additionally Alternative 3 of this document is analyzed as the noncommercial alternative as 

ordered by the Eastern District Court of California in [Sierra Forest Legacy, et. Al., v. Mark Rey, 

in his official capacity as Under Secretary of Agriculture, et. Al, Case No. 2:05-cv-00205-MCEGGH]. The District Court ordered the FS to “Include a detailed consideration of project 

alternatives, including a non‐commercial funding alternative, for all new fuel reduction projects 

not already evaluated and approved as of the date of this Memorandum and Order.” Subsequent 

Regional Forester guidance concerning Judge England’s decision indicates that the 

noncommercial funding alternative should be designed solely to meet the fuels reduction purpose 

and need. In a noncommercial funding alternative, it is not permissible to cut timber for the 

purpose of increasing economic returns beyond that needed to meet fuel reduction objectives. 

This court order could require development of an alternative to the Proposed Action should the 

Proposed Action include harvest of timber in excess of that needed to meet fuel reduction 

objectives 

Proposed Action _________________________________ 

The action proposed by the Forest Service to meet the purpose and need is: 

 Treat surface and ladder fuels (live and dead) to interrupt wildfire spread and fire 

intensity levels. This is proposed to be completed utilizing thinning and biomass thinning 

of pre-commercial and commercial conifers, mastication and/or dozer piling and burning 

in order to improve the ability of firefighters to suppress and control wildfires and 

provide a better measure of safety for the public and personnel. 

 Thin from below mixed conifer, white fir and pine stands, conifer plantations and small 

reproduction to reduce stand densities. 

 Masticate brush/shrub patches in strategic locations. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 5 Chapter 1 - Purpose and Need

 Utilize prescribed fire (Rx) as a tool to reduce natural and project-generated fuels through 

pile burning, understory and/or broadcast burning. 

 Use prescribed fire and/or manual methods to treat infestations of noxious weeds, with 

the goal of eradication and preventing their spread into areas treated. 

 Replant conifers within specific sites of failed conifer plantations. 

The Proposed Action is described in more detail in Chapter 2 under Alternative 2, page 9. 

Decision Framework ______________________________ 

Given the purpose and need, the deciding official will review the Proposed Action, other 

alternatives, and their environmental consequences, in order to determine whether to implement 

the Proposed Action as described, select a different alternative or take no action at this time. 

Forest Plan Direction _____________________________ 

The Proposed Action and alternatives are guided by the SNF-LRMP, as amended by the SNFPA 

2004 ROD [USDA-FS 2004b]. The SNF is subdivided into land allocations (management areas) 

with established desired conditions and associated management direction (Standards and 

Guidelines). Land allocations that are found within the Fish Camp Project boundary are shown 

on either individual maps for the specific land allocation or on the Land Allocations-Map 4. 

These maps are in the Map Package in Appendix A and include: 

Wildland Urban Interface/Intermix (both Defense and Threat Zones). This land 

allocation encompasses 1947 acres within the Fish Camp Project boundary and is set in 

closest proximity to communities, areas with higher densities of residences, commercial 

buildings, and/or administrative sites with facilities. Of this acreage; 578 acres are 

designated as Defense Zone and 1369 acres are designated as Threat Zone. There were no 

local site-specific adjustments made to these boundaries as allowed by SNFPA 2004 

ROD (USDA-FS 2004b) and are the zones mapped in the SNFPA 2004 FSEIS. As 

defined in the SNFPA 2004 ROD (USDA-FS 2004b), Defense Zones designated in the 

Project extend 1⁄4 mile from private property lines. Threat Zones designated in this 

Project extend 1 1⁄4 miles out from the Defense Zone boundary. There are Forest-wide 

standards and guidelines for this land allocation which have been incorporated into the 

Project design criteria. 

Southern Sierra Fisher Conservation Area (SSFCA). This land allocation encompasses 

the entire Fish Camp Project area (5,440 acres). The SNFPA 2004 ROD (USDA-FS 

2004b) has set forth standards and guidelines for this land allocation that address 

protection measures for fisher den sites as well as direction for projects proposed in 

SSFCA (USDA-FS 2004b, pgs. 61-62). In these standards and guidelines it is left to 

wildlife biologists to develop design criteria that protect important habitat structures 

within fisher habitat. Design criteria for the maintenance and protection of key habitat 

elements for Pacific fisher have been developed based on current scientific information, 

issues raised during public scoping and standards and guidelines in the SNFPA 2004 

ROD (USDA-FS 2004b). These are listed in Chapter 2, Design Criteria Common to All 

Alternatives starting on page 12. 

California Spotted Owl Protected Activity Centers (PACs) and Home Range Core Areas 

(HRCA). This land allocation encompasses 475 acres of the Project area as suitable 

nesting habitat and nearly the entire Fish Camp Project area is suitable foraging habitat. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 6 Chapter 1 - Purpose and Need

There are two PACs and associated HRCAs either entirely or partially within the Project 

boundaries. The 2004 SNFPA ROD (USDA-2004b) has set forth standards and 

guidelines for this land allocation that address mechanical treatments conducted to meet 

fuels management objectives in PACs located in the WUI defense zones and in threat 

zones where prescribed fire is not feasible and where avoiding PACs would significantly 

compromise the overall effectiveness of the landscape fire and fuels strategy (USDA-FS 

2004b, pgs. 59-61). These, as well as the remaining standards and guidelines for this land 

allocation are incorporated into design criteria and are listed in Chapter 2, Design Criteria 

Common to All Alternatives starting on page 12. 

Northern Goshawk Protected Activity Centers (PAC). This land allocation encompasses 

176 acres of suitable nesting habitat in one PAC and nearly the entire Fish Camp Project 

area is suitable foraging habitat. The SNFPA 2004 ROD (USDA-FS 2004b) has set forth 

standards and guidelines for this land allocation which are similar to those for California 

spotted owl PACs (USDA-FS 2004b, pgs. 59-61). The standards and guidelines for this 

allocation are incorporated into design criteria and are listed in Chapter 2, Design Criteria 

Common to All Alternatives starting on page 12. 

Old Forest Emphasis Areas. This land allocation is designated in approximately 1811 acres 

within the Fish Camp Project boundary. Mature forest habitat is described by California 

Wildlife Habitat Relationship (CWHR) types 4M, 4D, 5M, 5D, and 6 where outside of 

the WUI defense zones standards and guidelines are designed to maintain and enhance 

the structures associated with these forest types and the protection of the species habitat 

associated with these forest ecosystems (SNFPA ROD; USDA-FS, 2004b, pages 50-51). 

As such, standards and guidelines associated with wildlife species that prefer mature 

forest habitat are used as the standards and guidelines for this land allocation. These are 

incorporated into design criteria and are listed in Chapter 2, Design Criteria Common to 

All Alternatives starting on page 12. 

Riparian Conservation Areas (RCA): This land allocation encompasses the entire Fish 

Camp Project boundary because of the extensive stream network within the Project 

boundary. The standards and guidelines, specifically the Resources Conservation 

Objectives (RCO) from the SNFPA ROD (USDA-FS 2004b), associated with this land 

allocation are incorporated into design criteria and are listed in Chapter 2, Design Criteria 

Common to All Alternatives starting on page 12. 

Public Involvement _______________________________ 

A Notice of Intent (NOI) to prepare an Environmental Impact Statement for the Fish Camp 

Project was published in the Federal Register on August 12, 2010. The notice asked that scoping 

comments on the Proposed Action be received no later than 30 days after the publish date. In 

addition, as part of the public involvement process, the Forest Service sent scoping letters to 

residents within a 1.5 mile radius of the Project area, to members and groups in the Native 

American community and to publics expressing interest in the Project. The Project was also 

posted in the Sierra National Forest Schedule of Proposed Action (SOPA) by July 1, 2009. 

Scoping letters were sent on August 16, 2010 requesting the public’s input on the project. The 

scoping letter included an invitation to participate in a field trip and a news release announcing 

the public meeting which was also sent to the Sierra Star (local newspaper) on September 17, 

2010. On September 28, 2010, the Forest Service held the public field trip to the Project area. The 

public field trip was attended by approximately 25 individuals from the local community, local 

fire safe council, and environmental community. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 7 Chapter 1 - Purpose and Need

In conjunction with the written comments received during the scoping period and the issues 

associated with written comments (see below), the BLRD Interdisciplinary Team convened to 

discuss project planning, modifications to the Proposed Action, updates on base information 

collection, potential effects based on most recent information collected, review recommendations 

and items of concern that have been brought forward into this analysis. These recommendations 

led to the development of Alternative 3. 

Issues identified from scoping comments were used to determine the scope of the analysis for the 

Fish Camp Project. Central to the scoping comment issues was the proper balance between forest 

functionality and wildfire susceptibility. 

The DEIS Notice of Availability was published in the Federal Register on February 18, 2011 with 

the comment period ending April 4, 2011. The document was made available on the SNF website 

and hard copies of the document, compact disks or letters of notification were mailed to 53 

interested parties. 

Public Comments on the DEIS 

In response to the Forest’s request for comments during the DEIS comment period, Seven 

interested parties submitted responses. The SNF documented, analyzed, and summarized public 

comments. Although only substantive comments are required to be responded to in NEPA 

regulation, the forest chose to respond to all comments submitted. One hundred and forty seven 

(147) comments were responded to and these responses can be found in FEIS Appendix E. A 

decision was made to address all comments and/or statements received during the comment 

period. 

Tribal Government and Native American Interests 

Tribal Governments and Native American Interests representing constituents in the project area 

were sent all public correspondence and have consulted on aspects of the proposed projects. The 

following offices received mailing: 

American Indian Council of Mariposa County, California Indian Basketweavers Association, 

Chaushilha, North Fork Mono Tribe, North Fork Mono Rancheria, Sierra Mono Museum, 

Southern Sierra Miwok Nation, Picayune Rancheria and the Mono Nation, a non-profit 

organization. 

Significant Issues ________________________________ 

Comments from the public and other agencies were used to formulate issues concerning the 

Proposed Action. There were no comments received from members or groups from the Native 

American community. The Forest Service separated the issues into two groups: significant and 

non-significant. Significant issues were defined as those directly or indirectly caused by 

implementing the Proposed Action. Non-significant issues were identified as those: 1) outside the 

scope of the Proposed Action; 2) already decided by law, regulation, Forest Plan, or other higher 

level decision; 3) irrelevant to the decision to be made; or 4) conjectural and not supported by 

scientific or factual evidence. The Council on Environmental Quality (CEQ) NEPA regulations 

explain this delineation in Sec. 1501.7, “...identify and eliminate from detailed study the issues 

which are not significant or which have been covered by prior environmental review (Sec. 

1506.3)...” A list of non-significant issues and reasons why they were found non-significant may 

be found in the Project record located at BLRD Office in North Fork, CA. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 8 Chapter 1 - Purpose and Need

The Forest Service identified the following significant issue during scoping: 

Wildlife 

 Inappropriate size class snags in the future may impact snag dependent wildlife. 

 Removal of trees greater than 12 inches may impact wildlife species. 

 Reducing small patches of high intensity wildfire may impact wildlife. 

 Mastication may negatively impact wildlife. 

Forest Health 

 Removal of 10–30 inch trees may not improve forest health. 

 Forest heterogeneity may improve habitat for wildlife. 

 Forest homogeneity may adversely impact wildlife habitat. 

 Cutting trees grater then 20 inches may impeded ecosystem restoration/ old forest 

characteristic development. 

 Mechanical harvesting equipment may impact noxious weed spread. 

Economics 

 Project as proposed may have negative effects on profit to US Government.; Trees with 

too many knots, bio mass issues. 

 Mechanical thinning does not thin the forest as economically as prescribed burning. 

 Manufacturing biomass product on the forest is not economical. 

Wilderness 

 Using logging equipment may impact wilderness values. 

Community/Fire Suppression 

 Treatment of vegetation for fuels beyond 200 feet for homes and communities will not 

decrease their susceptibility to wildfire. 

 Mastication may negatively impact fire suppression. 

The Interdisciplinary Team utilized the following “Indicators” to determine to what degree these 

issues were documented and addressed. These “Indicators” are focused on maintaining high 

quality wildlife habitat. 

 The amount of Project area remaining in high canopy cover after treatment (measured by 

the average percent canopy cover in a stand remaining is not below 50% and a significant 

portion is at or greater 60%); 

 The canopy cover remaining consist of trees greater than 20” in diameter; 

 The changes in stand density would not create open stands; 

 Areas within the Project area would maintain a degree of understory diversity, such as 

brush, shrubs and small trees; 

 Large snags and downed woody material are available within the Project as well as an 

availability of enough “recruitment” material to maintain these levels into the future; 

 An availability of movement corridors to link suitable habitat outside of the Project area 

to provide for habitat connectivity. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 9 Chapter 1 - Purpose and Need

The Interdisciplinary Team for the Fish Camp Project developed Design Criteria Common to All 

Action Alternatives to address some of the significant issues that were focused on wildlife habitat 

quality and quantity. 

Changes between the DEIS and the FEIS 

Based on both public comment and Forest Service review, changes were made between DEIS and 

FEIS. The following types of changes and clarifications were applied to the FEIS: 

Data Omissions – In cases where omissions in data were identified by the FS or the public, those 

omissions were fixed in the FEIS. Where data pertinent to the analysis was identified between 

DEIS and FEIS it was include and analyzed. 

Corrections and Edits – Where typos or errors were identified they were correct. 

Clarifications – Public comment inspired the clarification of items in many sections of the FEIS. 

These clarifications ranged from adding a few words to help the reader more fully understand the 

content and rationale of a section to expansion of summary and comparison tables. The design 

criteria were streamlined and clarified in the FEIS as well. 

Additions – Alternatives suggested by the public were addressed. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 10 Chapter 2 – Proposed Action 

Chapter 2 Alternatives, Including the 

Proposed Action 

Introduction 

This chapter describes and compares the alternatives considered to meet the purpose and need of 

the Fish Camp Project. It describes both action alternatives considered in detail as well as those 

eliminated from detailed study. The end of this chapter presents the alternative’s fire and fuels 

and silviculture effects in tabular format so that the alternatives and their environmental impacts 

can be readily compared. Please see the table in the Summary titled Major Conclusions for the 

effects of other resources. 

Alternatives Considered in Detail 

The Forest Service is required to analyze a No Action alternative. The Proposed Action and one 

additional action alternative were considered in detail. The additional action alternative is the 

non-Commercial Funding Alternative, also referred to as the Lower and Limited Mid-Level 

Canopy Treatment alternative, which focused on limiting the quantity of material removed to just 

that needed to meet fire and fuels objectives in all treatment areas. This alternative was 

developed based, in part, using the “Indicators” for the significant issues where a higher degree of 

canopy cover would remain after treatment and stand densities would remain higher than in the 

Proposed Action. 

Alternative 1 – No Action 

Under the No Action alternative, current management plans would continue to guide management 

of the Project area. No thinning, either commercial, pre-commercial and/or biomass operations, of 

mixed conifer and pine stands, mastication of brush/shrub patches, prescribed burning to reduce 

natural fuel accumulations and/or treatment of infestations of noxious weeds and replanting of 

conifers in failed conifer plantations would be implemented. 

Alternative 2 – The Proposed Action 

Treatment areas within the Project area boundary were delineated to include those areas where 

some form of treatment was necessary to protect communities from wildfire and to improve forest 

health and resiliency. In developing the Proposed Action, first treatment areas were designed to 

create SPLATs to reduce the intensity and spread of wildfires in and around WUI. Treatment 

areas near key transportation corridors and within the defense zone of the WUI were designed 

next. Fire and fuels treatments are designed to reduce the ladder and surface fuels and occur 

within the lower and limited mid-level canopy [Fire and Fuels Objectives). Treatment areas were 

further designed to not only focus on those treatments needed to meet fire and fuel objectives, but 

areas where the stands were considered overstocked with conifers and are vulnerable to loss from 

insect, disease and wildfire (Forest Health Objectives) as well. 

Treatments defined for forest health are designed to reduce basal area and stocking to such a level 

that the stands are resilient to changing environmental conditions, increase growth and are 

vigorous with reduced susceptibility to insect and disease attack and wildfire. These treatments 

occur within the lower and mid-level canopy. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 11 Chapter 2 – Proposed Action 

Maintenance and/or reconstruction of forest roads that were determined to not meet Forest 

Service standards would be brought back up to standard prior to commercial thinning. 

Commercial thinning would be completed within the first two to five years of implementation. 

Areas where follow-up treatments are needed, such as slash piling/burning, prescribed understory 

burning and noxious weed treatments, would be prioritized based on proximity to WUI and 

completed as appropriated dollars became available. The Design Criteria Common to All Action 

Alternatives is incorporated as part of this alternative to address significant issues. A treatment 

area map (map 1) can be found in the Map Package in Appendix A. 

Of the 5,440 total acres within the Project boundary, approximately 1,200 acres were analyzed as 

areas where some form(s) of treatment are proposed (so named as treatment areas). The 

remaining 4,240 acres have no treatments proposed due to slopes greater than 35 percent, 

standard and guideline limitations on treatment and/or no treatment is needed to meet the purpose 

and need. 

In Alternative 2 (Proposed Action) the treatments would include: 

 commercially thin mixed conifer, pine, and white fir stands on approximately 562 acres; 

 commercially thin ponderosa and Jeffrey pine plantations on approximately 404 acres; 

 pre-commercially thin by masticating approximately 41 acres of plantations; 

 plant and hand release treated openings within commercial thin and mastication 

treatment areas on up to 10 acres; 

 treat slash concentrations within commercially thinned stands by a combination of tractor 

or hand piling and burning or mastication; 

 underburn on approximately up to 193 acres within 7 prescribed fire stands; 

 underburn within portions of T8, 9, 10, and 12 on approximately 208 acres; 

 perform maintenance on approximately 41.9 miles of forest system roads; 

 perform reconstruction on approximately 12.9 miles of forest system roads; 

 construct 0.5 miles of temporary road; and 

 manually pull and/or prescribed burn of noxious weed patches. 

Though a total of 1,200 acres are analyzed for the treatments listed above, design criteria 

common to all alternatives and standards and guidelines from SNFPA ROD (USDA-FS 2004b) 

dictate areas where treatments cannot occur to reduce and/or eliminate adverse effects on 

particular resources. It is estimated that excluding these sensitive areas, for example, cultural 

resource areas, botanical species areas, wildlife habitat areas, and aquatic species areas from the 

treatment areas where no treatment would occur, a total of 850 – 1,000 acres would remain for 

treatments as proposed. 

Alternative 3 – Lower and Limited Mid-Level Canopy Treatments, All 

Treatment Areas (Non-Commercial Funding Alternative) 

In Alternative 3, treatment areas would remain the same as in Alternative 2, treatments within 

these areas would include only those needed to reduce the surface and ladder fuels (within the 

lower and limited mid-level canopy levels) to achieve fire and fuels objectives. Under Alternative 

3 there would be no additional treatment (i.e. additional thinning in the mid-level canopy) to fully 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 12 Chapter 2 – Proposed Action 

address stand density and forest health objectives. This alternative was developed based, in part, 

using the “Indicators” for the significant issues where a higher degree of canopy cover would 

remain after treatment and stand densities would remain higher than in the Proposed Action. In 

treatment areas consider conifer plantations, fire/fuels objectives would be based on the need to 

break-up the continuity of crowns created by stands that are considered all one age (even-aged). 

This includes the need to remove some material that would be considered commercially sized. 

In treatment areas where wild stands occur (generally areas outside of plantations), the break-up 

of crown continuity would not be the main focus, but the ability to raise the height of the canopy 

base (the average height of the bottom layer of branches) where fire/fuels objectives are met. 

This includes the need to remove some material that is considered pre-commercially sized. 

Maintenance and/or reconstruction of forest roads that were determined to not meet Forest 

Service standards would be brought back up to standard. Mechanical thinning would be 

completed within the first two to five years of implementation. Areas where follow-up treatments 

are needed, such as slash piling/burning, prescribed understory burning and noxious weed 

treatments, would be prioritized based on proximity to WUI and completed as appropriated 

dollars became available. 

The Design Criteria Common to All Action Alternatives is incorporated as part of this alternative 

to address significant issues. A treatment area map (map 1) can be found in the Map Package in 

Appendix A. 

In Alternative 3, the treatments would include: 

 mechanically thin by mastication and/or hand-treatment, mixed conifer, pine, and white 

fir wild stands on approximately 562 acres; 

 commercially thin ponderosa and Jeffrey pine plantations on approximately 404 acres; 

 pre-commercially thin by masticating approximately 41 acres of plantations; 

 plant and hand release treated openings within commercial thin and mastication 

treatment areas on up to 10 acres; 

 treat slash concentrations and pre-commercial material within stands with a combination 

of hand cutting, tractor piling, and burning or mastication; 

 underburn on approximately up to 193 acres within 7 prescribed fire stands; 

 underburn within portions of T8, 9, 10, and 12 on approximately 208 acres; 

 perform maintenance on approximately 41.9 miles of forest system roads; 

 perform reconstruction on approximately 12.9 miles of forest system roads; 

 construct 0.5 miles of temporary road; and 

 manually pull and/or prescribed burn of noxious weed patches. 

Though a total of 1,200 acres are analyzed for the treatments listed above, design criteria 

common to all alternatives and standards and guidelines from SNFPA ROD (USDA-FS 2004b) 

dictate areas where treatments cannot occur to reduce and/or eliminate adverse effects on 

particular resources. It is estimated that excluding these sensitive areas, for example, cultural 

resource areas, botanical species areas, wildlife habitat areas, and aquatic species areas from the 

treatment areas where no treatment would occur, a total of 850 – 1,000 acres would remain for 

treatments as proposed. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 13 Chapter 2 – Proposed Action 

Design Criteria 

The design criteria listed by resource area below are direction to follow during implementation. 

As listed, they can be directly from the SNF-LRMP (USDA-FS 1992) and SNFPA ROD (USDAFS 2004b) Standard and Guidelines (S&G); Forest Service Manual/Handbook directions; Best 

Management Practices (BMP); based on past implementation experience; legal requirements; 

based on the best science available where they are used in addition to standards and guidelines 

and/or have been developed to address significant issues. 

Cultural Resources 

Cultural resources will be protected through implementation of Standard Protection Measures of 

the Regional Programmatic Agreement (PA), the primary protection measure being avoidance for 

all project activities, including resource design criteria. The appropriate specialist or 

representative will approve all landings and temporary roads prior to Project implementation as 

needed (Appendix B of the PA). 

Botany: Rare Plants and Noxious Weeds 

Project design criteria for protection of Forest Service Sensitive plants include:

a) All short-leafed hulsea populations will be flagged for avoidance (SNF 1992 LRMP S&G 

#s 67 and 68, SNFPA 2004 ROD S&G # 125).

b) Stream reaches containing populations of the veined water lichen will be flagged for 

avoidance and will not be used for drafting (SNF 1992 LRMP S&Gs# 67 and 68, SNFPA 

2004 ROD S&G # 125).

c) Open granitic and/or gravelly areas in or adjacent to units M08, T14a-b, T21a-d, T27, 

and T30 will not be driven through for Project implementation nor used for parking of 

vehicles, heavy equipment nor used as log landings. This is to ensure protection of 

suitable habitat for the following sensitive plant species that have not been discovered in 

the Project area but may exist: Mono Hot Springs evening primrose, Kelloggs’ lewisia, 

and Yosemite bitterroot. In the event that the granitic habitat occurs within a unit, the 

botanist will flag suitable habitat for avoidance in coordination with timber and/or fuels 

staff (SNF 1992 LRMP S&Gs # 67 and 68, SNFPA 2004 ROD S&G # 125).

Project design criteria for prevention of spread of noxious weeds:

a) All heavy equipment used for implementing the Project will be washed before arriving on 

site to remove soil and seeds of noxious weeds. This is to ensure that weed seeds or 

propagules are not inadvertently introduced into the Project area (SNFPA 2004 ROD 

S&Gs # 38 and 39; USDA Forest Service FSM 2081.3, Timber Sale Contract Clause 

B.6.35).

b) Infestations of noxious weeds occurring in treatment units or other areas such as landings 

where they are likely to be spread as a result of Project activities will be removed by 

Forest Service personnel prior to Project implementation. Because these areas will still 

have soil contaminated with seeds of the weeds, a buffer zone will be shown on the 

timber sale contract and flagged for avoidance to prevent heavy equipment from 

transporting seeds to other areas within the Project boundary and beyond. In some cases 

it may be necessary to wash equipment after working in an infested unit prior to 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 14 Chapter 2 – Proposed Action 

moving to a clean area elsewhere within the Project boundary and/or upon exiting the 

Project area altogether (SNFPA 2004 ROD S&Gs # 38, 40, 48; USDA Forest Service 

FSM 2081.3, Timber Sale Contract Clause B.6.35).

c) Any seeding, planting, or mulching for erosion control will be pre-approved by the Forest 

Botanist to minimize the likelihood of accidental introduction of noxious weeds and to 

ensure compliance with the FS Pacific Southwest Region Native Plant Policy (SNFPA 

2004 ROD S&Gs # 38, 40; USDA Forest Service FSM 2081.03; R5 Native Plant Policy, 

1994)

Geology/Soils 

a) Leave a 100-foot wide buffer of 100 percent soil cover below large rock outcrops 

especially in treatment units T-06, T-10a-d, T-14a-b, T-17a-d, T-18a-d, T-21a-d, and T28a-j. These areas have a high potential to generate run off that can cause accelerated 

erosion on soils down slope (FSM 2500 – Watershed and Air Management, Chapter 

2550 – Soil Management).

b) Limit mechanical operations, where sustained slopes exceed 35%, except where 

supported by on-the-ground interdisciplinary team evaluation (SNF-LRMP S&G 125).

c) Maintain 50% soil cover over all treatment areas. Where shrub species predominate, 

attempt crushing before piling to create small woody fragments left scattered over the 

site for soil cover and erosion protection (SNF-LRMP S&G #130).

d) Maintain at least five well-distributed logs per acre as large woody debris (LWD) 

representing the range of decomposition classes defined in the (SNFPA ROD S&G 10).

e) Provide for road surface stabilization (gravel) on roads over 5% grade that are located on 

sensitive soils, including Ultic Haploxeralf soils (SNF- LRMP S&G #129) and are 

affecting soil productivity and/or water quality. 

 Lands/Special Uses 

1. Forest Service project managers will notify permit holders and agencies, in person or in 

writing, Project activities including mastication, pre-commercial thinning and/or 

understory prescribed fire will be implemented in Forest areas that may affect their 

authorized special uses or agency jurisdictions. A list of permit holders is located in the 

Project record. Forest Service managers responsible for implementation will work with 

permit holders to ensure authorized improvements and/or right-of-ways are clearly 

identified on all contracts and visible during Project implementation. Appropriate 

protection measures will be put in place. 

Recreation and Recreation Special Uses 

A. A Limited Operating Period (LOP) (no harvest activity) will be established for T-6, T14a, T-14b, and T-21d adjacent to the Big Sandy Campground. The LOP is implemented 

from Memorial Day Weekend to Labor Day weekend during peak summer camping 

season. 

B. An LOP will be established for units T-8a, T-b, and T-9 adjacent to the Goat Meadow 

Snow Play Area. To avoid conflicts with permit holders and Forest visitors, Project 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 15 Chapter 2 – Proposed Action 

activities at or near the Goat Meadow Snow Play Area. No harvest activities will be 

permitted between Memorial Day and Labor Day. If Project activities occur at or in close 

proximity to the Goat Meadow Snow Play area the parking lot should be fully accessible 

to the public on weekends. 

C. The parking area at Goat Meadow Snow Play Area will not be used for a landing or 

staging area for Project related equipment. 

D. All activity fuels and slash will be pulled out of and at least five feet away from 

established Forest Service or permittee trails and any damage by Project activities will be 

repaired to pre-Project conditions. 

E. An LOP (no harvest activities) will be established for Project activities that occur in the 

vicinity of the Yosemite Trails Pack Station (YTPS) base facility or inside units T-7a, T10a, T-10b, T-18a and T-18b with YTPS trails during the peak user months from 

Memorial Day through Labor Day. 

Wildlife – Terrestrial 

Many standards and guidelines address wildlife and the Project includes compliance with them all 

however for brevity’s sake those that are particularly important for managing wildlife and 

wildlife habitat and/or have sparked public interest related to the Fish Camp Project area are 

listed here. 

Down Woody Material: “Determine down woody material retention levels on an individual 

project basis, based on desired conditions. Emphasize retention of wood in the largest size classes 

and in decay classes 1, 2, and 3. Consider the effects of follow-up prescribed fire in achieving 

desired down woody material retention levels.” This will be met by maintaining at least five welldistributed logs per acre as large woody debris (LWD) representing the range of decomposition 

classes from the Geology/Soils design criteria throughout the implementation of this project. 

(SNFPA ROD S&G#10) 

Snag Retention: “Design projects to implement and sustain a generally continuous supply of 

snags and live decadent trees suitable for cavity nesting wildlife across a landscape. Retain some 

mid- and large-diameter live trees that are currently in decline, have substantial wood defect, or 

that have desirable characteristics (teakettle branches, large diameter broken top, large cavities in 

the bole) to serve as future replacement snags and to provide nesting structure. When determining 

snag retention levels and locations, consider land allocation, desired condition, landscape 

position, potential prescribed burning and fire suppression line locations, and site conditions 

(such as riparian areas and ridge tops) avoiding uniformity across large areas. 

The general guidelines for large-snag retention are as follows: 

 Westside mixed conifer and ponderosa pine types – four of the largest snags per acre. 

 Use snags larger than 15 inches dbh to meet this guideline. Snags should be clumped and 

distributed irregularly across the treatment units. Consider leaving fewer snags 

strategically located in treatment areas within the WUI. When some snags are expected to 

be lost due to hazard removal or the effects of prescribed fire, consider these potential 

losses during project planning to achieve desired snag retention levels.” (SNFPA ROD 

S&G#11) 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 16 Chapter 2 – Proposed Action 

Old Forest Associated Species: Assess the potential impact of projects on the connectivity of 

habitat for old forest associated species. (SNFPA ROD S&G #28)

Forested Linkages: Consider retaining forested linkages (with canopy cover greater than 40 

percent) that are interconnected via riparian areas and ridgetop saddles during project-level 

analysis. (SNFPA ROD S&G #29)

Limited Operating Period for Spotted Owls and Northern Goshawks: Should surveys locate 

activity centers or active nests for California spotted owls or Northern goshawks, LOPs restricting 

vegetation treatments during the LOP period will be applied within a 1⁄4 mile radius of the activity 

center or nest. Should a great gray owl nest be located, the nesting location will be protected by 

an LOP. The district biologist will be notified when a nest or den of any Threatened (T), 

Endangered (E) Candidate (C), Proposed (P), or Forest Service Sensitive (FSS) species are 

discovered within or adjacent to a treatment area and an LOP would be established. All areas 

within the Project area have been surveyed to regional protocol for California spotted owl and 

Northern goshawk. (SNFPA ROD S&G #75&76) 

Limited Operating Period for Fisher Den Sites (SNFPA ROD S&G #85): Protect fisher den 

site buffers from disturbance with a limited operating period (LOP) from March 1 through June 

30 for vegetation treatments as long as habitat remains suitable or until another Regionallyapproved management strategy is implemented. The LOP may be waived for individual projects 

of limited scope and duration, when a biological evaluation documents that such projects are 

unlikely to result in breeding disturbance considering their intensity, duration, timing, and 

specific location. (SNFPA ROD S&G #85)

Fisher Den Site Management: Avoid fuel treatments in fisher den site buffers to the extent 

possible. If areas within den site buffers must be treated to achieve fuels objectives for the urban 

wildland intermix zone, limit treatments to mechanical clearing of fuels. Treat ladder and surface 

fuels to achieve fuels objectives. Use piling or mastication to treat surface fuels during initial 

treatment. Burning of pile debris is allowed. Prescribed fire may be used to treat fuels if no other 

reasonable alternative exists. (SNFPA ROD S&G #86) 

Management in Southern Sierra Fisher Conservation Area: Prior to vegetation treatments, 

design measures to protect important habitat structures as identified by the wildlife biologist, such 

as large diameter snags and oaks, patches of dense large trees typically 1⁄4 to 2 acres, large trees 

with cavities for nesting, clumps of small understory trees, and coarse woody material. For 

example, use firing patterns, place lines around snags and large logs, and implement other 

prescribed burning techniques to minimize effects to these attributes. Use mechanical treatments 

when appropriate to minimize effects on preferred fisher habitat elements. (SNFPA ROD S&G 

#90)

Pacific Fisher Den Site Buffers: The SNFPA ROD 2004 (USDA-FS 2004b) requires a 

minimum 700-acre buffer around fisher birthing and kit rearing dens, and this buffer consists of 

the best quality and most contiguous habitat. Standards and guidelines for management actions 

within these buffers are: #85 (creation of an LOP during breeding and rearing season); #86 

(mechanical treatment of surface and ladder fuels only, if den site within WUI); and #87 

(mitigation of disturbance by recreational users). 

Southern Sierra Fisher Conservation Area Desired Conditions: Within known or estimated 

female fisher home ranges outside the Wildfire Urban Interface Zone (WUI), a minimum of 50 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 17 Chapter 2 – Proposed Action 

percent of the forested area has at least 60 percent canopy cover. The entire Project area is within 

the Southern Sierra Fisher Conservation Area (SSFCA), and there are approximately 2230 acres 

of WUI within the Fish Camp Project boundary. (SNFPA ROD, pg. 41) 

The following management actions which expand upon the S&Gs in the LRMP will help 

maintain and/or enhance important Pacific fisher and American marten habitat. These measures 

include information from the 2008 Conservation Biology Institute Document “Baseline 

Evaluation of Fisher Habitat and Population Status and Effects of Fires and Fuels Management on 

Fishers In the Southern Sierra Nevada, Final Report to USDA Forest Service Pacific Southwest 

Region” (Spencer et al 2008); “An Ecosystem Management Strategy for Sierran Mixed-Conifer 

Forests” (North et al 2009); and Sierra Nevada Adaptive Management Study Integration Team 

discussions, fieldtrips to the Project area, as well as Forest Service Standards and Guidelines and 

Land Allocations stated previously. 

 Maintain 50-60% canopy cover immediately post-harvest. 

 Thinning will not remove any trees larger than 30-inch dbh (SNFPA ROD S&G # 6). 

 Protect all suitable fisher denning habitat with an LOP restricting vegetation treatments 

from March 1 through June 30. This LOP will protect reproductively active fisher and 

young that may be present in the Project area from treatment actions during their denning 

and early rearing periods. 

 Protect all suitable marten denning habitat with an LOP restricting vegetation treatments 

from May 1 through July 31. This LOP will protect reproductively active marten and 

young that may be present in the Project area from treatment actions during their denning 

and early rearing periods. 

 Snags will be felled only if they meet the definition of a danger tree (as described in the 

Engineering Design Criteria), have the potential to fall across prescribed fire control 

lines, and/or pose a threat to firefighter safety during prescribed fire implementation. 

Down logs created as a result of snag felling will remain in the stand where needed to 

meet down log requirements of SNFPA ROD S&G #10. Snags not meeting the criteria 

of a danger tree will remain as standing snags within the Project area. 

 Retain dense groups of larger trees (greater than 30-inch dbh) with touching crowns at the 

rate of approximately one group per 2.5 to 3.5 acres. Ideally these groups would contain 

“defect” trees, those that have cavity and platform creating defects (mistletoe, rot, fork 

topped, broken limbs and tops) for pacific fisher denning and resting sites. Within these 

large tree groups, all trees over 20” dbh will be retained. These large tree groups will 

generally have a residual basal area of 240 ft2

 or more for mixed conifer and 210 ft2 or 

more for pine and in many instances may reach 300 to 400 ft2

 per acre. Retention of 

these large tree groups with higher basal areas and the inclusion of defect trees are 

designed to maintain the integrity of suitable fisher denning and resting sites throughout 

the treatment units. Non-treated areas within proposed treatment units, such as riparian 

areas and steep slopes, will also provide extensive areas of tree group retention as no 

treatments will be occurring in these areas. Large conifer retention groups, combined 

with non-treatment areas outside of Project units will help maintain habitat heterogeneity 

throughout the treatment units and the Project area as a whole. 

 Within the Fish Camp Unit T-9, a 5 acre inclusion of decadent, high quality, dense 

fisher/spotted owl habitat was identified by the marking crew and field verified by the 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 18 Chapter 2 – Proposed Action 

wildlife biologist. A number of predominant trees were noted within this inclusion. 

Historic aerial photos showed that this inclusion was not previously cut during the 

extensive railroad logging that occurred in the Sugar Pine and Fish Camp areas 

throughout the turn of the century. Due to the high habitat value present in this stand, and 

in accordance with Standard and Guideline #90 from the SNFPA ROD, this unique 

habitat inclusion was removed from the treatment unit and will not be available for 

commercial entry. 

 To maintain decadent stand characteristics within the treatment units, conifers >16” dbh 

with structural decadence and/or the potential to become future snags will be identified 

for retention within the treatment areas. SNFPA ROD S&G #11 provides direction for 

retention of these structural elements. Within treatment units, conifers with the greatest 

existing or potential for structural decadence will be retained at an average of 1 every 100 

feet. Conifers will be selected using the following characteristics listed in order of 

priority: evidence of known or potential cavities; broken top; conks or other heart-rot 

indicators; mistletoe or other abnormal witches broom formation or other diseased or 

insect damaged trees; teakettle branches; forked top; or broken large branches. 

 Black oaks will be retained throughout the Project area. Within the treatment areas, 

conifers will be removed that overtop black oaks 10 inches dbh and larger, or that 

otherwise restrict sunlight from reaching them (e.g. from the south and west) now or 

within 15 years following treatment; the amount of conifer removal will be limited by the 

overall basal area thinning prescription thresholds. Conifer canopy gaps created through 

this process not only help promote and retain the vigor of black oaks, but also create 

habitat heterogeneity. Hiding cover around oaks, such as shrubs and small trees will be 

retained around 2-3 decadent oaks per acre. These oak retention areas will be protected 

with a buffer area 35 feet from the bole, or to the dripline, whichever is greater, where no 

thinning or fuels treatments will occur. 

 Promote diversity in pine plantation treatment areas larger than 5 acres by creating 1/10 

acre openings associated with young black oaks between 4” and 12” dbh, where present, 

on an average of 1 opening for every 5 acres to encourage diameter growth of the oak 

through increased sunlight, release the oak from competition, and encourage future stand 

heterogeneity. To achieve this, Ponderosa and Jeffrey pine trees within pine plantations 

will be removed from a 180° swath on the Southern aspect around crowded young black 

oaks for a 50’ radius. Species diversity will be increased by selecting vigorous conifer 

species other than ponderosa and Jeffrey pine for retention during thinning where present. 

Hardwoods are not planned for removal. (SNFPA ROD S&G #3; #26). 

 Shrub and understory diversity will be retained throughout the Project area. Understory 

vegetation will be maintained in Old Forest Linkages associated with riparian areas 

(cooler, moister sites--RMAs); black oak buffer zones; as well as areas where no 

treatment will be conducted such as heritage resource sites, botanical areas, slopes >35%, 

and rocky areas. Tree species associated with riparian areas, such as dogwoods, alders, 

and willows are not planned for removal. Post sale treatments will retain pockets of 

understory growth spread throughout the treatment units so that 15-20% of the total 

understory growth will be maintained in 1/10 acre pockets within plantation treatment 

units and 1⁄4 acre pockets within wild stand treatment units. This will preserve stand 

diversity while decreasing the threat posed by ladder fuels. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 19 Chapter 2 – Proposed Action 

 The district biologist will be notified immediately if a nest or den of any TESCP species 

is discovered within or adjacent to a treatment area so that proper protection measures 

can be identified and implemented. 

 Standards and Guidelines 28 and 29 provide guidance for developing and maintaining 

adequate habitat connectivity within riparian areas. Recent studies (Spencer 2008; North 

et al 2009) have also shown that fisher utilize riparian areas as travel corridors between 

high quality habitat. To provide for this habitat connectivity, design criteria have been 

developed to incorporate and expand upon established riparian area management zones; 

i.e. Streamside Management Zones (SMZ) and Riparian Management Areas (RMA) 

associated with perennial streams (Class I). The forest wildlife biologists have termed 

these zones Old Forest Linkages (OFL). They incorporate and expand upon the measures 

required for SMZs and RMAs. OFLs consist of buffers measuring 300 feet total on either 

side of perennial streams. Design criteria for these Old Forest Linkages are detailed in 

Table 1 and Figure 1. 

Table 1: Riparian Area Management Zones 

 *Distance from Stream for Activities is measured and applied to each side of the stream from bank-full left and bank-full 

right. 

 Distance from 

Stream* 

 Vegetation Management 

Activities Allowed within 

zone 

 Zone Designation 

 0-50 feet  No Activities Allowed  SMZ/RMA/OFL 

 50-100 feet 

 No ground disturbing 

equipment allowed into area 

(dozers, skidders, etc.) 

Activities allowed include 

hand-felling of trees smaller 

than 12”dbh, pile-burning, 

and equipment reach-in with 

boom arm. Canopy cover is 

to remain ≥60%. 

 SMZ/RMA/OFL 

 100-150 feet 

 Mechanical entry is allowed. 

Trees ≤12” dbh may be 

removed for fire and fuels 

reduction purposes by 

equipment. Canopy cover is 

to remain ≥60%. 

 OFL 

 150-300 feet 

 Mechanical entry is allowed. 

Thinning from below will 

occur. Canopy cover is to 

remain ≥60%. 

 OFL 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 20 Chapter 2 – Proposed Action 

Figure 1: Associated Bounds and Treatments within Old Forest Linkages 

Wildlife – Aquatics 

Applicable aquatic wildlife species and riparian habitat standards and guidelines are from the 

2004 Sierra Nevada Forest Plan Amendment, Final Supplemental Impact Statement and Record 

of Decision (USDA-FS 2004b) (S&Gs #91-124), the existing Sierra National Forest Land and 

Resource Management Plan direction (USDA-FS 1992) (S&Gs #66-79), Forest Service 

handbook (FSH) 2509.22 Sierra Supplement #1 for treatments within Streamside Management 

Zones (SMZ, USDA 1989), Best Management Practices and other applicable laws and 

regulations (USDA-FS 2000a). Generalized SMZ designation is outline in Table 2 and mapped in 

the Project Hydrology Report (Stone 2010). 

Table 2 Summary of Relationship between Feature Types, RCA Widths, Stream Classes, 

SMZ Widths, RMA Widths, and Stream Orders (and other GIS data) 

Feature Type RCA 

Width 

Stream 

Class 

SMZ Width RMA 

Width 

Corresponding 

GIS Layer 

Stream Order 

Perennial Streams 300 feet I At least 100 ft 100 feet 4+ 

Seasonally Flowing 

Streams 

150 feet II At least 75 ft N/A 3 

III At least 50 ft 2 

IV At least 25 ft 1 

V None required - 

Streams in Inner Gorge Top of 

inner 

gorge 

Varies 

Special Aquatic Features 

(fens, bogs, springs, 

seeps, lakes, ponds, 

wetlands, etc.) 

300 feet N/A N/A 100 feet Either identified on 

GIS layers 

(meadows, springs, 

lakes), or identified 

in the field 

Project specific design criteria implementing the above regulation and guidance include: 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 21 Chapter 2 – Proposed Action 

a) Class I SMZs are within or adjacent to treatment areas: M-09, RX-02, RX-03, RX-04, RX-05, 

RX-06, RX-09, T-05, T-06, T-08, T-07, T-10, T-14, T-15, T-16, T-17, T-18, T-20, T-22, T28, T-29, and T-4. Old Forest Linkage Prescriptions apply to these SMZs. 

b) Special Aquatic Features: Do not allow mechanical equipment within 100 feet of meadows or 

other special aquatic features. Includes treatment areas: M-13, M-14, RX-06, T-07, T-10, T12, T-13, T-14, T-15, T-16, T-17, T-18, T-19, T-20, T-21, T-22, T-27, T-28, T-30, and T-40. 

c) Applicable to all SMZs: 

i. Do not allow heavy mechanical equipment within SMZ. 

ii. To protect bank stability, do not cut streambank trees (trees with drip line 

extending to or over edge of streambank). 

iii. Do not cut any tree located within a channel. 

iv. When lighting piles, start burn from one end only to allow escape route for any 

species inhabiting piles. 

v. No lighting into SMZs, but fire can creep into zone. 

d) For water drafting, use a screened intake device and pumps with low entry velocity to 

minimize removal of aquatic species, including juvenile fish, amphibian egg masses and tadpoles, 

from aquatic habitats. A Hydrologist or Aquatic Biologist would approve water-drafting sites. See 

Best Management Practices (BMP) 2-21 in Appendix B for specific requirements. 

e) If newly listed or unknown occurrences of Federally listed threatened, endangered, proposed, 

candidate or Forest Service sensitive aquatic species are found within the affected Project area 

during sale preparation and implementation, additional species protection measures may need to 

be imposed by the district fisheries and aquatic biologist. 

Hydrology 

Use all applicable watershed standards and guidelines from the SNFPA ROD (S&Gs #95-124) 

(USDA-FS 2004b), the existing SNF- LRMP direction (S&Gs #120-131) (USDA-FS 1992), 

Forest Service handbook (FSH) 2509.22 Sierra Supplement #1 for treatments within Streamside 

Management Zones (SMZ, USDA 1989), and design measures to protect water quality and ensure 

watershed health that are detailed by Water Quality Management for Forest System Lands in 

California, Best Management Practices (USDA, 2000). 

Project specific implementation of the mentioned S&Gs and policy documents include: 

1. Stream Crossings: To minimize the potential for project-related effects on hydrologic 

connectivity, existing crossings would be used whenever possible. In the event that it is 

necessary to construct a temporary crossing, the methods used for construction would be 

selected to avoid or minimize detrimental soil and vegetation disturbance and to maintain 

hydrologic connectivity between upstream and downstream features (Appendix 2 of 

hydrology specialist report details a low impact crossing methodology). All temporary 

crossings would be removed following the completion of project-related activities and 

would be treated as necessary to restore to pre-Project conditions. Implementation of the 

activity-specific BMP’s would further ensure that hydrologic connectivity in streams and 

special aquatic features are not adversely affected. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 22 Chapter 2 – Proposed Action 

2. If treatment of wild/mixed stands or plantations does need to occur within the 100 foot 

meadow SMZ: 

a. If the slope gradient is less than or equal to 10%, and the soil has a low erosion 

hazard and low sensitivity, then light-on-the–land equipment can be used to precommercially thin within the SMZ provided that: 

i. the equipment minimizes the amount of turning within the SMZ. Where 

possible, the equipment should reach into the SMZ or roll straight into 

and out of the SMZ to minimize soil disturbance. 

b. If the slope gradient is greater than 10% and/or the soil has a moderate to high 

erosion hazard and/or a moderate to high sensitivity, then thinning should be 

done hand, i.e., trees should be felled by hand, bucked, and left in place or endlined out of the SMZ. 

c. All ground disturbance that could cause concentrated flow and/or accelerated 

erosion will be restored to pre-disturbance condition, with interim measures to 

protect the soil in order to allow at least 50% vegetative ground cover to return 

(protective measures could include placement of slash, mulch, weed-free straw, 

waddles, etc.). 

3. Treatment units T-16, T-17a-d, T-19a-b, T-22a-c, T-28a-j that are within subwatershed 

501.5005 (map 9) and the Long Meadow Creek drainage will require light-on-the-land 

mechanical treatment or deferral of treatment. Light-on-the land treatment includes: cutto-length harvest system or whole tree yarding system, grapple piling, or prescribed fire. 

Deferral of treatment areas includes spacing out disturbance over time to allow initial 

treated areas to recover (at least three years) before other areas are treated. 

a. Management prescription for Streamside Management Zones (SMZ). 

i. Do not treat vegetation within the SMZs of Class I or II streams in subwatersheds over the lower threshold of concern (TOC). 

ii. In the outer 50 feet of other SMZs, thin trees to reduce fuel loading by: 

1. Removing ladder fuels (intermediate and suppressed trees) 

2. Removing diseased trees that will fall away from riparian areas, 

and 

3. Hand-piling slash as necessary to reduce the effects of under 

burning 

4. maintaining trees with broken tops for source of large woody 

debris (LWD) recruitment 

b. The hydrologic connectivity of roads: 

i. Spot rocking of roads or out sloping road surfaces to quickly direct 

runoff from the road surface rather than concentrating flows in an 

inboard ditch and routing it to the stream channel; 

ii. Installing rolling dips and /or additional relief culverts to minimize the 

length of road drainage entering stream channels, with outlet treatments 

to minimize the risk of fill slope erosion; and 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 23 Chapter 2 – Proposed Action 

iii. Rocking of ditches to reduce flow velocity in the ditch, prevent ditch 

erosion, and encourage deposition, where other techniques are not 

feasible. 

Silviculture 

Based on SNFPA ROD (USDA-FS 2004b) S&Gs for mechanical treatments, as well as design 

criteria, silvicultural prescriptions will be written utilizing thinning from below techniques with 

basal area levels for stand species composition (SNF- LRMP S&G 17).

The planning and implementation of all activities shall use integrated pest management (SNFLRMP S&G #117): 

a) An LOP would be imposed in well stocked stands heavy to fir (over 50% fir) where 

operations could begin August 1st or later when the sap is not running (fir bark is much 

more easily dislodged when the sap is running than later in the year). The appropriate 

specialist or representative will determine which stands require an LOP during the 

thinning layout phase as needed. 

b) To minimize the threat of insect attack, all pine logs created as a part of harvest 

operations will be removed from the sale areas as either logs or biomass material within 6 

weeks of creation. Unutilized pine material will not be concentrated but spread to dry 

quickly or chipped and spread. Pine logs greater than 3 inches in diameter that are 

created between July 1st and October 15th and left in the stand will not exceed 8 feet in 

length. 

c) Commercial thinning operations taking place before July 1st or after October 15th in pine 

stands will require additional measures to minimize creation of pine slash concentrations. 

Additional bucking of slash may be needed to minimize creation of favorable insect 

breeding habitat. Any pine logs greater than 3 inches in diameter created after October 

15th or before July 1st left in the stand should not exceed 4 feet in length. Precommercial 

thinning of pine stands should not take place before July 1st or after October 30th each 

year.

d) Where whole tree yarding is utilized, careful consideration must be given to the 

protection of the residual trees from damage. Rub trees (previously designated for 

removal) and/or rub logs should be retained where needed to minimize damage. These 

will then be removed upon completion of yarding. Skid trails should be as straight as 

possible and approved prior to skidding. Landing size should be kept to a minimum 

especially in areas where additional trees must be felled to create landings. 

e) To minimize landing size, logs/biomass should be removed as quickly as feasible from 

landings during skidding operations and not allowed to accumulate. During post sale 

treatments, 15 to 20 percent of the understory growth would be retained within 

plantations and wildstands in pockets approximately 1/10 acre in size. (When 

determining understory pockets to be retained, understory pockets around oaks, 

groupings of larger diameter trees, steep slopes, draws, etc. within treatment units would 

be included.) Understory pockets would not be retained in locations where they would 

jeopardize the effectiveness of planned fuels treatments. (SNF- LRMP S&G #113, and 

114).

 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 24 Chapter 2 – Proposed Action 

Fuels 

SNFPA ROD (USDA-FS 2004b) S&G #3 addresses fuels treatments. Project specific S&G #3 

implementation criteria include: 

a) The utilization of prescribed fire to maintain appropriate levels of surface and ladder 

fuels to meet fire and fuels objectives will be conducted in prescribed fire treatment areas 

and portions of T-8b north of road 5S06, T-9, portion of T-10b north of road 5S06 and all 

except the very east portion of T-12. To reduce the potential impacts (fire effects) that 

may occur with the implementation of prescribed fire, the following criteria would need 

to be considered in the areas where prescribed fire would be used: 

b) Prescribed fire areas should be considered where there are larger residual trees (of size 

less susceptible to fire damage) with light fuel loadings, and/or areas where conifer 

reproduction is not being used for re-generation of openings. 

c) Prescribed fire will be conducted as outlined in a burn plan, to minimize effects to trees 

during active growing period and within Pacific fisher denning habitat areas. 

Engineering 

a) Maintain all National Forest Transportation System (NFTS) roads to standards 

established in the Forest Service Handbook 7709.58. Perform road maintenance, 

reconstruction and new road construction activities to support Project access needs. 

Insure drainage structures are functional and stable to prevent potential resource damage 

and degradation of water quality (SNF- LRMP S&G #78, #79, #124, #206 and BMPs). 

b) Perform a final field review of Project roads to determine reconstruction needs prior to 

Project activities. Where economically feasible, place aggregate on existing native 

surface roads located in areas with High and very High Soil Erosion Hazard ratings 

(SNF- LRMP S&G #129). 

c) Close temporary roads required for unit access upon completion of use; remove all 

culverts, rip and ditch landings, construct waterbars, block the entrance with a log and 

dirt berm, and disguise the entrance with brush to discourage additional traffic. (FS 

Handbook (FS Handbook 2409.15, Sec.51.8) 

Roadways will be managed for safe passage by road users. This will include the management of 

hazards associated with roadside vegetation, including the identification and mitigation of danger 

(hazard) trees. A danger tree, as defined in Forest Service Handbook (FSH) 7709.59, Chapter 40, 

is a standing tree (live or dead) 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 of lean of the tree (FSH 6709.11, Glossary). Selection criteria guidelines for the 

marking and removal of danger trees will be tiered to the BLRD Hazard Tree Environmental 

Assessment, (USDA-FS 2006a). 

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 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 25 Chapter 2 – Proposed Action 

achieving the purpose and need. Based on NEPA case law as described in NEPA Models 

and Case Lists, Third Edition, alternatives can be eliminated if the proposed alternative 

(1) does not achieve the purpose and need; (2) has substantially similar consequences as 

alternatives considered in detail; (3) is not significantly distinguishable from alternatives 

already being considered; (4) is infeasible; (5) is ineffective; (6) is inconsistent with basic 

policy objectives for the action; or (7) if the existing range of alternatives sets forth 

alternatives necessary to permit a reasoned choice (Schmidt 2009). 

Public comments and internal scoping that suggested alternatives or components of an 

alternative that were considered but subsequently eliminated from detailed study are 

described below. The explanation for the elimination of the alternative from further full 

analysis is also included. 

Alternative proposing to increase or create potential for large 

snags and down logs (>20” DBH) in units with little 

representation 

This alternative is the Proposed Action with the addition of increasing the numbers of 

large snags >20 inches dbh. Large standing or down fuels in fact contribute to additional 

fuel loading and, in larger numbers, may increase fire severity potential , especially in 

areas where the risk is already above the desired condition class. The snag inventory for 

the Fish Camp Project area shows that the Project meets or exceeds current standards for 

the area as a whole. It is not necessary to ensure snag sufficiency in every unit. 

Intentionally creating snags also has the potential to artificially induce higher than normal 

insect populations which could lead to mortality above that which would maintain or 

enhance tree vigor in the remaining stands. An additional mitigation measure leaving 

clumps of larger trees (generally larger than 20 inches dbh) maintains a stocking level 

higher than that needed to promote stand vigor in these clumps, likely leading to higher 

mortality and, thus greater numbers of larger snags and down logs. For these reasons, 

consideration of additional larger snags and down log does not create a significantly 

different alternative. 

Alternative limiting tree removal diameter to 10 inches or smaller 

The environmental effects of limiting treatments to only those necessary to meet 

fire/fuels objectives (generally, small diameter trees) were thoroughly analyzed for the 

non-plantation (wild) stands in Alternative 3. A separate alternative limiting tree removal 

diameter to 10 inches or less would have substantially similar consequences as 

Alternative 3. Limiting treatments in plantations to trees with less than 10” diameters 

would not fully meet the fire/fuels purpose and need. Most plantations have very few 

trees smaller than 10”. The fire risk in these areas comes from the dense stocking 

resulting in touching crowns. Removing 10” and smaller trees does little to address this 

fire/fuels concern and therefore does not meet the purpose and need for treatment in 

plantations. Additionally this alternative does not meet the need for stand density 

reduction. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 26 Chapter 2 – Proposed Action 

Alternative maximizing the use of fire as the agent for achieving 

the Project objectives. 

Over the last 30 years, wildfire in the Sierra Nevada Range has burned an average of 

about 43,000 acres per year. In the last ten years, that average has risen to about 63,000 

acres per year (FS, 2004). The lack of periodic fires within the Project area has resulted in 

a forest predisposed to stand replacing fire and insect attack. Considering the current 

condition of the forest, the reintroduction of fire as a sole management tool would be 

impractical and unmanageable in scope and very likely result in devastating and high 

severity stand replacing wildfires. Additionally, air quality restrictions could make 

implementation in a timely manner very difficult. Therefore this alternative is ineffective 

as a method of meeting the need for ecological restoration particularly in terms of fire 

resiliency of the forest. Additionally, It does not meet the purpose and need for public 

health and safety.

Alternative limiting treatments to 200 foot zones from structures. 

The purpose and need for this Project is not solely focused on the reduction of wildfire 

intensity and spread into and out of the WUI, but includes the need to reduce the threat of 

uncharacteristically severe wildfire in the general forest and maintain sustainable, 

resilient forested stands throughout the area by reducing stand density. Limiting 

treatments to this limited area does not meet the purpose and need for either the fire/fuels 

or forest health objectives. Additionally, treating only 200 feet adjacent to private 

property does not meet current policy (USDA-FS 2004, FSEIS) defining treatments in the 

Defense Zone WUI within a 1⁄4 mile zone where structures and other human development 

meet or intermingle with wildlands. 

Comparison of Alternatives ________________________ 

Table 3 provides a brief summary of the alternatives and their environmental impacts in 

comparative format. 

Table 3: Comparison of Alternatives 

Measure or Effect 

Alternative 1 – No 

Action 

Alternative 2 – Proposed 

Action Alternative 3 

Total Project area =5,440 acres; Total Acres Analyzed in Treatment Areas = 1,200 

Estimated Acres by Alternative to be Treated by Treatment Area Type: 

Thinninng 0 Acres Commercial Thin= 966 acres Commercially Thin 

Plantation= 404 acres 

Mastication 0 Acres 41 acres 604 acres 

Rx Fire 

(Rx in T units) 

0 Acres 193 acres 

208 

193 acres 

208 

Total miles of Road 42.2 42.2 42.2 

Maintenance 0 41.9 41.9 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 27 Chapter 2 – Proposed Action 

Measure or Effect 

Alternative 1 – No 

Action 

Alternative 2 – Proposed 

Action Alternative 3 

Reconstruction 0 12.9 12.9 

Temporary 0 0.5 0.5 

New Road 0 0 0 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 28 Chapter 2 – Proposed Action 

Fire/Fuels Objectives: Fire behavior spread and intensity is reduced as measured by crown fire potential is highly 

unlikely and non-sustainable; flame lengths < 4 feet; Rate of Spread 50% of pre-treatment; line construction rates are 

doubled from pre-treatment (SNFPA ROD (USDA-FS 2004b)) 

Measures: Forest 

Plantation – 

Further 

Future 

Conditions 

ForestMod. To 

Heavy 

Fuel level 

Areas 

ForestPlantation Forest 

areasthinned 

Heavy 

Fuels 

Forest 

areasthinned 

Fuels 

treated 

Forest 

plantation 

Fuels 

treated 

Forest 

areasthinned 

Heavy 

Fuels 

Forest 

areasunderstory 

thin 

Forest 

Plantation 

untreated 

Fuel Model 

(Resultant) 

SH5 TU5 SH2 TU5 TL8 TU1 TU5 TU5 SH2 

Predicted Rate of 

Spread (chains/hour) 

68 11 8.5 11 7.5 3.5 11 11 8.5 

Predicted Flame 

Length (feet) 

16 8.5 5 8.5 4 2 8.5 8.5 5 

Predicted Fireline 

Intensity (BTU/ft2) 

2259 606 217 606 117 27 606 606 217 

Predicted Crown Fire 

Potential (Yes/No; 

Type) 

YesCrown Yes 

Crown

Yes 

Crown 

Yes 

Crown 

No 

Surface 

No 

Surface 

Yes 

Crown 

YesCrownYes 

Crown

Resistance to Control 

(High, Moderate, 

Low) 

Extreme Mod/ 

High 

Mod Mod/ 

High 

Low / 

Mod 

Low Mod/

High 

Mod/ 

High 

Mod 

Forest Health Objectives: Reduce stand densities and improve tree vigor and overall forest health. Measured Desired 

Stocking levels by Species: Pine= 135 ft2/acre; White Fir= 240 ft2/acre; Mixed Conifer= 210 ft2/acre (SNFPA ROD 

(USDA-FS 2004b). 

Estimated Range of 

Basal Area Remaining 

(ft2/acre) for >10-inch 

dbh trees 

Plantations = 120 - 320ft2

Wild Stands = 120 - 480ft2

Plantations = 120 – 140ft2

Wild Stands = 120 – 240ft2

(pockets to 360ft2) 

Plant. = 120 – 200ft2

W/Stands = 120 – 480ft2

Estimated Range of 

Stems per Acre 

Remaining for >10-

inch dbh trees (# 

trees/acre) 

 Plantations = 103 – 220 trees 

Wild Stands = 75 to 190 trees 

Plantations = 55 – 93 trees 

Wild Stands = 45 to 85 trees 

Plant. = 58 to 96 trees.

W/Stands = 75 – 190 trees
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 29 Chapter 2 – Proposed Action 

Habitat Indicators (From Issue, page 7): 

Estimated Range of 

Canopy Cover 

Remaining (%) 

Plantations = 39 -100% 

(majority 50%+) 

Wild Stands = 39 – 100% 

(majority 75%+) 

Plantations = 39 – 85% 

 (majority 50%+) 

Wild Stands = 39 – 85% 

 (majority 60%+) 

Plantations = 39 – 86% 

 (majority 50%+) 

W/Stands = 39 – 85% 

 (majority 75%+) 

Estimated Range of 

Tree Diameter 

Remaining (> 10” dbh) 

Plantations = 10 - 29 

Wild Stands = 10 - 48 

Plantations = 10 - 29 

Wild Stands = 10 – 48 

Avg. dia. all stands would 

increase 

Plantations = 10 - 29 

Wild Stands = 10 – 48 

Avg. plantation dia. 

would increase 

Large Snag and Down 

Wood Standard for 

Treated Areas 

N/A Listed in Design Criteria 

Common to All Alternatives 

(pages 12) 

Listed in Design Criteria 

Common to All 

Alternatives (pages 12) 

Movement Corridors 

Addressed (Yes or No) 

Yes, with assumption 

corridors are present 

currently 

Yes, addressed as Old Forest 

Linkage Areas on page 20. 

Yes, addressed as Old 

Forest Linkage Areas on 

page 20. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 30 Chapter 3 – Affected Environment 

Chapter 3 Affected Environment and 

Environmental Consequences 

This chapter describes aspects of the environment likely to be affected by the Proposed Action 

and alternatives. Also described are the environmental effects (direct, indirect, and cumulative) 

that would result from undertaking the Proposed Action or other alternatives. Together, these 

descriptions form the scientific and analytical basis for the comparison of effects in Chapter 2. 

Past, Present and Reasonably Foreseeable Actions ______ 

According the CEQ NEPA regulations, “cumulative impact” is the impact on the environment 

which results from the incremental impact of the action when added to other past, present, and 

reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or 

person undertakes such actions (40 CFR 1508.7). 

In order to understand the contributions of past actions to the cumulative effects of the Proposed 

Action and alternatives, this analysis relies on current environmental conditions as a proxy for the 

impacts of past actions. This is because existing conditions reflect the aggregate impact of all 

prior human actions and natural events that have affected the environment and might contribute to 

cumulative effects. 

This cumulative effects analysis does not attempt to quantify the effects of past human actions by 

adding up all prior actions on an action-by-action basis. There are several reasons for not taking 

this approach. First, a catalog and analysis of all past actions would be impractical to compile and 

unduly costly to obtain. Current conditions have been impacted by innumerable actions over the 

last century (and beyond), and trying to isolate the individual actions that continue to have 

residual impacts would nearly be impossible. Second, providing the details of past actions on an 

individual basis would not predict the cumulative effects of the Proposed Action or alternatives. 

In fact, focusing on individual actions would be less accurate than looking at existing conditions, 

because there is limited information on the environmental impacts of individual past actions, and 

one cannot reasonably identify each and every action over the last century that has contributed to 

current conditions. Additionally, focusing on the impacts of past human actions risks ignoring the 

important residual effects of past natural events, which may contribute to cumulative effects just 

as much as human actions have. Third, public scoping for this Project did not identify any public 

interest or need for detailed information on individual past actions. Finally, the CEQ issued an 

interpretive memorandum on June 24, 2005 regarding analysis of past action, which states, 

“agencies can conduct an adequate cumulative effects analysis by focusing on the current 

aggregate effects of past actions without delving into the historical details of individual past 

actions.” 

The cumulative effects analysis in this EIS is also consistent with Forest Service NEPA 

Regulations (36 CFR 220.4(f)) (July 24, 2008), which states, in part: 

“CEQ regulations do not require the consideration of the individual effects of all past actions 

to determine the present effects of past actions. Once the agency has identified those present 

effects of past actions that warrant consideration, the agency assesses the extent that the 

effects of the proposal for agency action or its alternatives will add to, modify, or mitigate 

those effects. The final analysis documents an agency assessment of the cumulative effects of 

the actions considered (including past, present, and reasonably foreseeable future actions) on 

the affected environment. With respect to past actions, during the scoping process and 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 31 Chapter 3 – Affected Environment 

subsequent preparation of the analysis, the agency must determine what information 

regarding past actions is useful and relevant to the required analysis of cumulative effects. 

Cataloging past actions and specific information about the direct and indirect effects of their 

design and implementation could in some contexts be useful to predict the cumulative effects 

of the proposal. The CEQ regulations, however, do not require agencies to catalogue or 

exhaustively list and analyze all individual past actions. Simply because information about 

past actions may be available or obtained with reasonable effort does not mean that it is 

relevant and necessary to inform decision-making. (40 CFR 1508.7)” 

In addressing the cumulative effects of the No Action Alternative the SNF considered the 

definition of cumulative effects from 40 CFR 1508.7: 

“the impact on the environment which results from the incremental impact of the action when 

added to other past, present, and reasonably foreseeable future actions regardless of what 

agency (Federal or non-Federal) or person undertakes such other actions.” (emphasis added) 

As according to this definition to have a cumulative effect an action must be taken. As no 

action is being taken by the SNF under the No Action Alternative by definition there would 

be no cumulative effects. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 32 Chapter 3 – AffeTable 4: Past, Present and Reasonably Foreseeable Actions Contributing to Cumulative Effects by Resources Act

Activity Type Description Year Unit Of Measure 

Air Quality 

Aquatics 

Botany 

Fuels/Fire 

Fuels 

Cultural Res. 

Vegetation 

Soil 

Roads/Trails USFS, County, State owned and maintained 

Includes the network of inventoried road/trail systems within Project subwatersheds 

On-going 86 miles X X X X X 

Campground and other USFS Owned Facilities 

Big Sandy Campground, Little Sandy Campground, Summerdale Campground, Goat Meadow Snow Area; 

Existing 4 sites X X X 

Past/Current USFS Timber Sales within Fish Camp subwatersheds 

Includes: 1) Green Timber Sales 2) Salvage Harvest 3) Thinning 

1) 1980s 2) 1990s 3) 2000-Current 

1) 2,640 acres 2) 1,532 acres 3) 189 acres 

X X X X X X X X 

Vegetation Management Plantation Maintenance 

Clearcutting, thinning, hand release, chemical release, and planting in plantations <30 yrs old. 

1980s 115 acres X X X X X X X X 

Fish Camp Railroad Yosemite Pack Station Infrastructure 

Special Use Permits which include buildings, amphitheater, RR track, corrals, and trails. 

Existing Approx. 25 acres 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 33 Chapter 3 – Affe

Activity Type Description Year Unit Of Measure 

Air Quality 

Aquatics 

Botany 

Fuels/Fire 

Fuels 

Cultural Res. 

Vegetation 

Soil 

Power Line Power Line Corridor Existing Approx.4.5 mi X Big Creek Ditch Diversion 

Madera Irrigation Historical Ditch System 1850s Approx. 3 miles X 

Roadside Hazard Tree Removal 

Removal of damaged, rotten, dead trees to abate roadside hazard using timber sale contracts. 

2003- present 41 miles X X X X X X X 

Fire/Fuels Management Activities 

Includes Fuelbreak Construction and Maintenance, Rx Burning, ladder fuel removal, mastication 

1980spresent Approx. 600 acres X X X X X X X X 

Private Land Infrastructure for communities of Fish Camp, Cedar Valley and Fish Camp 

New home construction, power, water, private roads 

Ongoing 378 acres X X X X X X X 

Private LandVegetation Management in communities and other private lands 

Timber harvesting, land type conversions Hazard fuels reduction 

Ongoing Individual 

Community Private Acres 

X X X X X X X 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 34 Chapter 3 – Affe

Activity Type Description Year Unit Of Measure 

Air Quality 

Aquatics 

Botany 

Fuels/Fire 

Fuels 

Cultural Res. 

Vegetation 

Soil 

Special Use Permitted Activities 

Yosemite Trails Pack Station and trails; Camp Green Meadows; Allen Bee Company Apiary (2 sites), Madera Irrigation District, Mast Yower 

Ongoing Various 

MeasuresMapped Locations 

 

Motorized Recreation 

Pleasure driving; 4x4, OHV, and snowmobile uses of system and temporary roads 

Ongoing Approx. 160 

miles 

X X X X 

Livestock Grazing Soquel Allotment Ongoing Soquel Mdw 

Pasture 

 X X X X X 

Fish Camp Project Vegetation Mgmt Project Project 

proposal being developed 2009-2010 

2,000 to 3,000 acres 

 X X X X X X X 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 35 Chapter 3 – Affected Environment 

Cultural Resources ______________________ 

The direct, indirect and cumulative effects below are summarized from the Fish Camp Project 

Cultural Resources Report (Mogge, M. 12/16/2010). 

Affected Environment 

All throughout the SNF are the remnants of past cultures that illustrate the centuries-old 

relationships between people and the land. These cultural resources hold clues to past ecosystems 

and human adaptations to them, provide links between living communities and the Forest’s 

unique prehistoric and historic land uses, and help transform a visit to the woods into an 

encounter with history. These cultural resources comprise an irreplaceable and non-renewable 

resource record of past human life and land use. This record is contained in properties with 

archaeological and historical research value, and locations of cultural importance to local Native 

American groups. 

Archaeological and Historic Values 

Cultural resources are the buildings, sites, areas, architecture, and properties that bear evidence of 

human activity and use across the landscape, and have scientific, historic, and cultural 

importance. Cultural resources are not distributed equally across this landscape, but clustered 

according to the natural resources that were being used (e.g. acorn groves, timber stands, water, 

mineral locations). With new discovery upon almost every new survey effort, there continue to 

be many undiscovered cultural resources in the SNF. 

Physical remains of over 10,000 years of human history are found throughout the SNF. Except 

for the last century and a half of written history, the only record of this long human use is the 

remains left by the original native people and their descendants. At the time of contact with 

Euro-Americans, in the late 1700s and early 1800s, the Fresno River was the boundary between 

the southern Sierra Miwok to the north and west, and the Chukchansi Yokuts to the south and 

east. The Western Mono occupied the area around what is now Bass Lake. The boundaries 

between the groups were ambiguous, with a lot of overlap in the area between the Miwok, Yokuts 

and Mono. 

The processes of subsistence, the hunter-gatherer lifestyle, and the resulting indigenous land use 

are seen in the archaeological record with features common to the material culture of the native 

people of the Sierra Nevada (e.g. village sites, bedrock mortars, stone tool artifacts). Some of 

these sites have ethnographic documentation that indicates a fairly recent history of tribal use; in 

some cases, tribal use continues at sites that have an occupational history that spans thousands of 

years. 

Historic-era cultural resources reflect particularly the cultural and economic products of the rapid 

pace of technological achievement in the last 150 years imposed on the terrain of the Sierra 

Nevada. These resources often reflect environmental changes resulting from industrial and 

technological advances in resource extraction, landscape use, and management. Sites include 

remnants of exploration and settlement, Forest Service administration, grazing/range 

management, mining, transportation, travel, tourism and recreation, and the forest products 

industry. Each of these themes has an array of associated sites and features. For example, 

features associated with railroad logging operations may be work camps, refuse dumps, railroad 

grades, trestles, and discarded equipment. 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 36 Chapter 3 – Affected Environment 

Native American Cultural Values 

Federally Recognized tribal governments with interest in the SNF, as elsewhere in the United 

States, have a special political and legal relationship with the U.S. Government. Federally 

Recognized tribes are beneficiaries of a trust relationship with the Federal government. The 

Forest Service consults regularly with Federally Recognized and Non-Federally Recognized 

tribes and other interested parties and is responsible for considering tribal interests. 

There is a deep and abiding concern with many Native American people about what occurs in 

their aboriginal territory. The SNF honors the traditional ties that many tribal communities and 

Native American people have to this portion of the Sierra Nevada. Access to and use of the 

Forest and other public lands is critical for many Native American people, as community identity 

and cultural survival are dependent on continued access to ceremonial and sacred places, 

cemeteries, traditional gathering areas, traditional cultural properties, and resources at a variety of 

locations on forest land. Certain plants, animals, and locations provide for many needs, including 

food, medicine, utilitarian type materials, and ceremonial items. Specific resources insure that 

significant cultural traditions, such as basket weaving, survive and continue. These areas 

contribute to the tribal communities’ way of life, their identity, their traditional practices and 

cohesiveness. 

Consultation with tribes, the local Native American communities, and other interested parties to 

identify other cultural values, including contemporary Native American interests, was initiated 

with a Public Scoping Letter that was sent on August 16, 2010, to members and groups in the 

Native American community in accordance with the Regional PA, NHPA, and other laws and 

regulations. Consultation has consisted of meetings, letters, and presentations, and is documented 

in the project record. 

Cultural Resource Management: In the area of potential effect, the results of twenty seven years 

of cultural resource surveys and investigations have identified 53 archaeological properties that 

are associated with themes of SNF history. Most sites represent prehistoric life ways; other sites 

represent historic-era land uses. 

The SNF manages those cultural resources eligible for listing on the NRHP. The Forest does not 

manage or protect ineligible properties in project activities, unless there is local interest in 

preservation. NRHP eligibility has not been determined for every cultural resource in the Project 

area. Unevaluated sites are considered potentially eligible, and are managed as if eligible until 

such time as they are evaluated. 

Contemporary Native American interests can include traditional cultural properties (sites 

associated with cultural practices or beliefs that are rooted in history and important in maintaining 

cultural identity), and plant gathering sites for basket materials, medicines, and food resources. 

The SNF manages such known sites as cultural resources under the provisions of the NHPA, but 

where the interests of native people are considered to achieve a mutually beneficial outcome 

during project implementation. The location of these sites is also kept administratively 

confidential. The SNF would maintain appropriate access to sacred and ceremonial sites, and to 

tribal traditional use areas, and has consulted with affected tribes and tribal communities to 

address access to culturally important resources and areas in this project analysis. 

Methodology for Analysis 

Data Sources 

Existing information from cultural resource records, historic archives, maps, and Global 

Information System (GIS) spatial layers was reviewed to provide specific information about 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 37 Chapter 3 – Affected Environment 

cultural resources, or the likelihood that unidentified properties might exist in non-inventoried 

areas. 

The majority of the project had been adequately surveyed for prior projects between 1983 and 

2007. Between 2008 and 2010, additional surveys were completed in previously unsurveyed 

areas. For areas that had never been surveyed, new survey was conducted using a combination of 

intensive (0 – 30 meter transects) and cursory (50+ meter transects) coverage. Intensive survey 

was done in clear and/or non-steep terrain. Cursory survey was done where terrain was very 

steep or had dense brush cover. 

Cultural Resource compliance for this project is documented in Fish Camp Adaptive Management 

Project (Draft), ARR R2007051551043. This report, which describes the location and 

composition of the cultural resource sites within the Project boundary, is kept administratively 

confidential under the provisions of the Archaeological Resource Protection Act of 1979, 36 CFR 

296 and 36 CFR 800.11(c) Confidentiality. 

Spatial Analysis 

The location and extent of the cultural resource is the unit of spatial analysis when considering 

effects in action alternatives. For some cultural resources (e.g., Traditional Cultural Property), 

the setting beyond the cultural resource location must also be considered when determining 

whether an adverse effect would occur. 

Effects Timeframes 

 Short-term effects occur within one year. 

 Long-term effects occur up to 20 years. 

 Cumulative effects are analyzed at a 20-year interval. 

Measurement Indicator and Rationale 

When assessing direct, indirect, and cumulative effects, assessments are based on a historic 

property possessing at least one of the following NRHP values (36 CFR 60.4(a – d)) unless 

specific information already exists: 

 Prehistoric archaeological site: Criterion A, C and D 

 Historic archaeological sites: Criterion A, B and D 

 Historic structures: Criterion A, B, and C 

An undertaking can have no effect, no adverse effect, or an adverse effect on a historic property 

or cultural resource. An adverse effect to a cultural resource can occur when an undertaking 

directly or indirectly causes alterations in its character or use. An adverse effect on a cultural 

resource occurs when an undertaking alters its important characteristics and is measured by the 

degree to which it diminishes its location, design, setting, materials, workmanship, feeling or 

association (Integrity Measures) (36 CFR 800.5(a)(1)). These integrity measures can also be used 

to characterize the nature of any potential effects, whether they are direct, indirect or cumulative 

effects; and their severity. The degree to which cultural resource values are diminished will be 

used to measure the direct, indirect and cumulative effects of the proposed project. 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 38 Chapter 3 – Affected Environment 

When the nature and scope of a proposed project is such that its effects can be reasonably 

predicted and appropriate measures can be undertaken to ensure that the values of cultural 

resources are not affected in any way, then those cultural resources may be managed in a manner 

which ensures that their values are preserved. 

Alternative 1 – No Action 

Direct and Indirect Effects 

Direct effects under this alternative could happen should a uncharacteristically severe wildfire 

occur resulting from untreated fuel accumulations. The lack of fuels reduction management 

could result in higher intensity wildfires, thereby potentially adversely affecting 53 cultural 

resources within the Project boundary, especially those with wooden components. Should a 

wildfire occur, indirect effects could occur as a result of increased access to and visibility of 

cultural resources leading to increased likelihood of adverse effects from artifact looting. 

Cumulative Effects 

As no action is being taken by the SNF under the No Action Alternative by definition there would 

be no cumulative effects. See FEIS page 31 for more explanation. 

Alternative 2 – Proposed Action 

Direct and Indirect Effects 

There are a total of 53 cultural resource sites that have the potential to be affected by 

implementing this alternative. One of these sites is an historic railroad logging system that has 30 

separate features that have the potential to be affected. These features include: railroad grades. 

spur grades, log chutes that retain intact earthworks and features such as sheave posts, camps, 

trestle remains, non-residential work areas and trash dumps. All of these cultural resource sites 

and features will be protected through the application of Standard Resource Protection Measures 

(Regional PA, Attachment B). Therefore there would be no affect to cultural resources. 

Cumulative Effects 

According the Council on Environmental Quality (CEQ) NEPA regulations, “cumulative impact” 

is the impact on the environment which results from the incremental impact of the action when 

added to other past, present, and reasonably foreseeable future actions regardless of what agency 

(Federal or non-Federal) or person undertakes such actions (40 CFR 1508.7). As all cultural 

resource sites within the Project area would be protected through project design features it is 

anticipated there would be no affects from this action alternative. Since there would be no direct 

or indirect effects, there are no cumulative effects for Alternative 2. 

Alternative 3 

Direct and Indirect Effects 

There are a total of 53 cultural resource sites that have the potential to be affected by 

implementing this alternative. One of these sites is an historic railroad logging system that has 30 

separate features that have the potential to be affected. These features include: railroad grades. 

spur grades, log chutes that retain intact earthworks and features such as sheave posts, camps, 

trestle remains, non-residential work areas and trash dumps. All of these cultural resource sites 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 39 Chapter 3 – Affected Environment 

and features will be protected through the application of Standard Resource Protection Measures 

(Regional PA, Attachment B). Therefore there will be no affect to cultural resources. 

Cumulative Effects 

Since there would be no direct or indirect effects, there are no cumulative effects for Alternative 

2. 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 40 Chapter 3 – Affected Environment 

Botany: Rare plants and Noxious Weeds ____ 

The direct, indirect and cumulative effects to Threatened, Endangered and Sensitive botanical 

species and noxious weed analysis are summarized below from the Biological Assessment and 

Evaluation for the Fish Camp Project (Clines, J. 12/17/2010). 

Affected Environment 

Rare Plants 

General description of the vegetation with an emphasis on rare plant habitat: The 

Fish Camp Project area is on the west slope of the central Sierra Nevada, and ranges in elevation 

from 5,000 to 8,000 feet elevation. The Project area falls within the Sierra Nevada Ecological 

Section (M261E) in the USDA Forest Service National Hierarchical Framework of Ecological 

Units (Miles and Goudey, 1997). Vegetation varies from ponderosa pine and mixed conifer 

forest at lower elevations, to red fir and lodgepole forests at the higher elevations, with montane 

chaparral and montane meadows scattered throughout the area. The southeastern region of the 

Project area has some areas of rock outcrops, which though often considered “barren” sites, are 

characterized by a suite of diverse native species adapted to live in the desert-like conditions of 

these exposed areas. These outcrops are not generally included in areas proposed for treatment as 

they do not have trees but they provide habitat for rare plant species, thus are protected for this 

reason. This summary of the vegetation within the Fish Camp Project area sets the stage for 

analyzing effects of the alternatives on Forest Service Sensitive Plants by examining project 

effects on their habitat. 

Riparian vegetation is adapted to wet or moist conditions and is found along streams and in 

meadows, springs, and seeps. Riparian vegetation along streams varies considerably within the 

Project area, ranging from clearly defined bands of riparian forest dominated by white alder 

(Alnus rhombifolia), mountain alder (A. incana ssp. tenuifolia), willow (Salix spp.), and 

Oregon ash (Fraxinus latifolia) to simply a strip of herbaceous riparian plants with upland forest 

trees growing next to the stream. 

Meadows and fens: There are several meadows within the Project area: Long Meadow, Goat 

Meadow, Buffin Meadow, as well as several unnamed meadows. Meadows are defined as 

openings in forests which generally have high water tables dominated by herbaceous vegetation 

that is adapted to wet conditions. Meadows are typically heterogeneous, containing patches of 

different plant assemblages in response to variations in moisture, drainage, elevation within a 

given meadow. Overall, meadows can be classified as dry, moist, or wet; and montane, 

subalpine, or alpine (Ratliff, 1985). Some meadows contain areas of peat soils called fens. Fens 

are areas of perennial saturation where peat soils form because accumulation of organic matter 

exceeds decomposition (Cooper and Wolf, 2006). Fens are of significance because of their 

contribution to hydrologic function in meadows and because they provide habitat for several rare 

plant species. 

Forest Service Sensitive Plant Species in the Project area 

Sensitive species are those species that have been specifically designated by the Regional 

Forester as needing special management in order to prevent them from losing long-term viability 

or becoming federally listed as endangered or threatened; either because they are naturally rare or 

because their numbers have been reduced by human causes. In the SNF the former is generally 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 41 Chapter 3 – Affected Environment 

the case. Much has been written about endemism and rarity in the California flora (e.g. Fiedler, 

2001: http://www.cnps.org/cnps/rareplants/inventory/rarity.php; and Shevock 1996: 

http://ceres.ca.gov/snep/pubs/web/PDF/VII_C24.PDF). Based on a review of the scientific 

literature, historical collections available through the Consortium of California Herbaria (an 

online search tool which allows viewing of specimens housed at most major herbaria in the state 

since scientific collecting began), there is no reason to suspect that the species known or 

suspected to be present in the Fish Camp Project area were significantly more common in the 

past. 

Table 5 shows the Forest Service Sensitive Plants that are known to occur or that may occur 

within the Fish Camp Project area based on the fact that suitable habitat is present. Species 

known to occur within the overall Project boundary or along access roads to the Project area are 

shown in bold text: 

Table 5: Forest Service Sensitive Plants 

 OCCURRENCE IN FISH CAMP 

AREA 

HABITAT REQUIREMENTS 

SPECIES 

Bruchia bolanderi 

BOLANDER’S CANDLE MOSS 

None known to occur but suitable 

meadow / streambank habitat present. 

RIPARIAN/MEADOW. Vertical banks of 

streams, 5000-7500 feet. 

Camissonia sierrae ssp. sierrae 

MONO HOT SPRINGS 

EVENING PRIMROSE 

None known to occur but 

rocky/gravelly habitat present. 

ROCKY/GRAVELLY. Gravel and sand 

pans and ledges associated with outcrops in 

chaparral, ponderosa pine, mixed conifer 

and red fir/lodgepole forests, 4500 – 8500 

feet. 

Cypripedium montanum 

MOUNTAIN LADY’S SLIPPER ORCHID 

None known to occur, many 

populations occur within 5 miles of 

Fish Camp Project area, but none were 

found during surveys in 2009 and 2010 

FORESTED. Moist areas and dry slopes 

in late-successional conifer forest. Known 

from the vicinity of Fish Camp to the west 

of the project, Mariposa Grove, Wawona, 

Sugar Pine, and Nelder Grove; 4000-7200 

feet. 

Epilobium howellii 

SUBALPINE FIREWEED 

None known to occur. The nearest 

occurrence is about 3 miles away 

RIPARIAN/MEADOW. Meadow edges, 

moist ditches and streamsides in conifer 

forest, 5000-8800 feet. 

Fissidens aphelotaxifolius 

BROOK POCKET -MOSS 

None known to occur but habitat is 

present. 

RIPARIAN/MEADOW. Rocky substrate 

in streams, < 6300 feet. 

Helodium blandowii 

BLANDOW’S BOG-MOSS 

None known to occur but fen habitat is 

present in Long Meadow. 

RIPARIAN/MEADOW. Wet meadows, 

fens, and seeps in coniferous forests, 6500 

– 9500 feet. 

Hulsea brevifolia 

SHORT-LEAFED HULSEA 

Three occurrences known, in dry 

forested habitat. 

FORESTED. Granitic or volcanic soils 

in openings and under canopy in mixed 

conifer and red fir forest, 5000 – 9000 

feet. 

Lewisia disepala 

YOSEMITE LEWISIA 

None known to occur but rocky habitat 

present. 

ROCKY/GRAVELLY. Granitic sand and 

gravel in ponderosa pine, mixed conifer, 

and upper montane coniferous forest, 4000 

– 7500 feet. 

Lewisia kellogii ssp. kelloggii 

KELLOGG’S LEWISIA 

None known to occur but rocky habitat 

present. 

ROCKY/GRAVELY. Open, gravelly flats 

in mixed conifer and subalpine forest, 6000 

– 11,000 feet. 

Meesia triquetra 

THREE-RANKED 

HUMP-MOSS 

One large occurrence in Long 

Meadow. 

RIPARIAN/MEADOW. Fens in 

montane meadows within conifer forest, 

4500 – 8000. 

Meesia uliginosa 

ONE-NERVED HUMP MOSS

None known to occur but suitable fen 

habitat present. 

RIPARIAN/MEADOW. Fens in montane 

meadows within conifer forest, 7500 – 

9000 feet. 

Peltigera hydrothyria 

VEINED WATER LICHEN 

None known within Project boundary 

but occurs along a major access road 

to the project where hauling of logs 

will occur 

RIPARIAN/MEADOW 

(AQUATIC)/Cold, clear, unpolluted 

streams in conifer forests, 4000 – 8000 

feet. 

Trifolium bolanderi 

BOLANDER’S CLOVER 

None known, most likely absent due 

lack of detection during many surveys 

RIPARIAN/MEADOW. Montane 

meadows in mixed conifer forest, 6800-
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 42 Chapter 3 – Affected Environment 

over the past 20 years. 7300 feet. 

Noxious Weeds 

Invasive non-native plants (weeds) are species which, if allowed to spread, cause ecological and 

economic damage. Invasive weeds may be officially listed as “noxious” at the federal or state 

level. The California Invasive Plant Council (Cal-IPC, 2006) assigns ratings of high, moderate, 

or limited ecological impact statewide based on ecosystem impacts, potential for invasiveness, 

and ecological distribution. Weeds on the California Noxious Weed list with ratings of “A” or 

“B” are of highest priority for state and county weed managers (CDFA, 2010). New infestations 

of State A and B rated weeds are controlled promptly by county or California State Department of 

Food and Agriculture biologists or by Forest Service employees in cooperation with county 

agriculture department staff. 

Surveys conducted in 2005 (for permit reissuance for Yosemite Trails Pack Station) and in 2010 

for this project revealed that the primary invasive weed species in the Fish Camp Project area are 

bull thistle (Cirsium vulgare), and common mullein (Verbascum thapsus). There is one patch of 

an escaped invasive ornamental plant, rose campion (Lychnis coronaria). No California State 

Noxious Weed species are currently known from this area, although spotted knapweed was 

detected and eradicated in the Fish Camp area about 10 years ago by the California Department of 

Food and Agriculture. Figure 2 shows the locations of these species in relation to the treatment 

units and access roads within the Project area: 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 43 Chapter 3 – Affected Environment 

Figure 2 Locations of invasive weeds in the Fish Camp Project area: CIVU = bull thistle, VETH 

= common mullein, LYCO = rose campion

Bull thistle (Cirsium vulgare) - CIVU. There are infestations of bull thistle in or 

adjacent to units T8a, T9, T-16, RX-55, and along access roads to and within the 

Project area. Although not as highly invasive as other noxious thistles, bull thistle 

competes with and displaces native species and decreases forage values in meadows 

and uplands at elevations up to 7,000 feet (Randall, 2000). Cal-IPC rates bull thistle as 

having moderate ecological impact, but notes that this species can be very problematic 

regionally, and especially in riparian areas (Cal-IPC, 2006). Bull thistle has been 

found at elevations higher than 7,000 feet in the Sierra Nevada (e.g. up to 8795 feet at 

Sonora Pass on the Stanislaus National Forest (UC Berkeley, 2010). 

Common mullein (Verbascum thapsus) – VETH. There are infestations of common 

mullein in units T8a, T16, T8b, T9 (2), T18a, T28h, and along access roads to and 

within the Project area. Mullein is considered a Cal-IPC weed of limited ecological 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 44 Chapter 3 – Affected Environment 

impact at the State level, and generally is not considered one of the more damaging 

wildland weeds in the SNF. However, common mullein is a biennial plant with high 

seed production, often over 100,000 seeds per plant. Although most seeds at or near 

the soil surface germinate rapidly, buried seeds can remain viable for 35 to 100 years 

(Pitcairn, 2000). After soil disturbance, especially fire, high densities of mullein 

plants can prevent natural revegetation with native species (Pitcairn, 2000), thus it is 

considered important to control and prevent the spread of this weed as part of the Fish 

Camp Project’s objectives. 

Rose campion (Lychnis coronaria) – LYCO. There is a patch of rose campion near 

the Goat Meadow parking lot in Unit T-08a. Rose campion is native to southeastern 

Europe, and while it is not rated as a California noxious weed nor rated by Cal-IPC, it 

has been observed to spread into wildlands and when small infestations are 

encountered in the Forest, it is controlled as time and funds permit. This is a species 

commonly planted in gardens and often seen persisting and spreading from old 

homesteads on the Forest, although it does not appear to be as aggressive as many of 

the higher priority noxious weeds in the SNF. 

A coordinated program for inventorying, controlling and preventing the spread of noxious weeds 

and invasive non-native plants has been ongoing in the SNF since 1998. The SNF is a founding 

member of the Sierra-San Joaquin Noxious Weed Alliance (a Weed Management Area (WMA) 

for Mariposa, Madera, and Fresno counties). The WMA brings together landowners and 

managers (private, city, county, State, federal) for the purpose of controlling invasive weed 

species in a cooperative manner. The relatively “clean” or uninfested state of the Forest in the 

Fish Camp Project area can be directly attributed to the efforts of this group in treating weeds on 

lands leading up to the SNF, and to the strong weed management program in nearby Yosemite 

National Park. 

Alternative 1 – No Action 

Under the No Action alternative, known sites for botanical resources would continue to be 

managed to maintain present diversity of the species as specified in the SNF- LRMP (USDA-FS 

1992) and SNFPA ROD (USDA-FS 2004b). 

Direct Effects 

No direct effects would occur to Forest Service sensitive plants if the No Action alternative is 

chosen because project activities would not take place. 

Indirect and Cumulative Effects 

Indirect effects have the potential to occur to Forest Service Sensitive plants under the No Action 

alternative primarily from the potential of uncontrolled wildland fire. Uncontrolled wildfire has 

the potential to cause significant disturbance to soil, ground cover and canopy cover, placing 

Forest Service sensitive riparian species at risk, since these types of plants normally do not 

regenerate after unusually high-intensity fires. Through suppression actions, fires can also allow 

the opportunity for the spread of invasive weeds, which can affect Forest Service sensitive 

species through competition of resources. 

The invasive weeds currently in the Project area would continue to spread without manual 

control. 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 45 Chapter 3 – Affected Environment 

As no action is being taken by the SNF under the No Action alternative by definition there would 

be no cumulative effects. See FEIS page 31 for more explanation. 

Alternative 2 – Proposed Action 

Direct and Indirect Effects 

The following direct effects to sensitive plants are possible as a result of timber harvest or fuels 

reduction activities: Direct killing of plants when equipment runs over them or parks on them, 

when logs are skidded or dragged over them, when slash piles block their light, and when piles 

are burned directly over them and the heat intensity is too great to survive. Mastication could 

directly kill plants by running them over or by covering them with a dense layer of chipped wood 

and limbs. 

Plants of Riparian, Meadow, and Aquatic Habitats: For the known occurrence of veined 

water lichen (known to occur along Road 6S07, accessing the Project area), there should be no 

direct effects because the project is designed specifically to prevent the use of the area for 

drafting of water. There may be some additional dust that reaches this stream and briefly affects 

the lichen but this would be alleviated by standard dust abatement practices and should be of 

short duration. The population of three-ranked hump-moss in Long Meadow fen will be 

protected by the 100 foot buffer for Long Meadow. For all other riparian dependent Sensitive 

plant species that may occur in the Project area, the project is designed to protect their habitat and 

no direct or indirect effects are expected. 

Plants of Rocky/Gravelly Habitats: No plants of rocky habitats were found during surveys of 

the Project area, but these rocky areas were not specifically surveyed as no treatments were 

proposed within them. The project has been designed to prevent incidental effects to 

rocky/gravelly areas, thus no direct or indirect effects would occur to the three species that may 

be present: Mono Hot Springs evening primrose, Yosemite bitterroot, or Kellogg’s lewisa. 

Plants of Forested Habitats: The short-leafed hulsea populations in the treatment units and 

along access roads will all be flagged for avoidance, thus no direct effects would occur. Positive 

indirect effects may result from opening of the canopy near the populations as they respond 

positively to this type of disturbance as evidenced by observations of response to fire and 

thinning (Clines, personal observation). Any mountain lady’s slipper plants would be most likely 

to be within 150 feet of streams, thus are unlikely to experience severe effects. However, no 

plants were found during surveys or by the marking crew (who are well-trained to recognize these 

plants and cover the treatment units thoroughly). Thus no direct or indirect effects are expected 

for this species. 

NOXIOUS WEEDS AND INVASIVE NON-NATIVE PLANTS 

Ecosystem health is threatened by the spread of invasive non-native weeds in a variety of ways. 

Dense infestations can reduce native biodiversity, compete with threatened, endangered and 

sensitive (TES) plant species, reduce wildlife habitat quality and quantity, modify vegetative 

structure and species composition, change fire and nutrient cycles, hybridize with native species, 

and degrade soil structure (Bossard et al, 2000). 

Because the project is designed to improve the ecosystems of the Project area by removing 

known infestations of invasive weeds and to prevent the introduction and spread of new 

infestations or species of weeds, there will be beneficial direct and indirect effects. 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 46 Chapter 3 – Affected Environment 

Cumulative Effects 

No cumulative effects are expected for Botanical Resources as the project has been designed to 

eliminate direct and indirect effects to rare plants and to avoid the introduction and spread of 

noxious weeds. 

Positive cumulative effects for invasive weeds are expected in that the Project area will have a 

reduced number of infestations of invasive weed species over the long term beginning with the 

actions proposed in this project. 

Alternative 3 

Direct, Indirect and Cumulative Effects 

From the standpoint of effects to TES plants and the risk of introduction and spread of noxious 

weeds, the effects would be the same as for Alternative 2. The treatments cover the same number 

of acres in the same places as in Alternative 2, with no commercial logging. 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 47 Chapter 3 – Affected Environment 

Geology/Soils __________________________ 

The direct, indirect and cumulative effects to the geologic and soils resources are summarized 

from the Soils Resource Report for the Fish Camp project (Gallegos, A. 1/28/2011). 

Methodology for Analysis 

Data used to determine projected effects to the soil resource include: the Soil Survey of the SNF, 

(Giger, 1993), site specific data from soil transects collected in 2007, following the Region 5 

Protocol for Soil Monitoring (TenPas, 2005) and past monitoring of similar projects using BMP 

Monitoring Protocols (USDA, 2002) and the Region 5 Soil Monitoring Protocol. 

Soil resource management is achieved by maintaining soil productivity using Regional Soil 

Quality Standard and Guidelines and management direction provided in the Forest Land 

Management Plan – SNF, 1991. Soil productivity is evaluated within an Activity Area. An 

Activity Area is the area of land dedicated to growing vegetation which soil quality standards for 

soil productivity are applied. It is that area within a management area where soil disturbing 

activities take place and is of practical size for management, sampling, and evaluation. Activity 

areas include timber harvest units and fuels treatment units within the Fishcamp Project area. 

System roads and trails and other areas not dedicated to growing vegetation are not included as 

part of activity areas. 

The project proposal could affect soil productivity in the Fish Camp Project area by reducing 1) 

soil cover, 2) soil porosity, 3) large woody debris (LWD) and 4) disturbance of surface soils. 

1. The main soil physical property that can be affected by the Proposed Action is porosity, 

the space between individual soil particles. Soil hydrologic function is primarily 

dependent on the size and arrangement of soil pores, or pore geometry. Soil pore 

geometry also controls the transmission of air through soils, which is critical for plant 

growth. When porosity is decreased, the soil becomes denser, making it more difficult 

for roots to penetrate. Maintenance of natural soil porosity is important for maintaining 

healthy native plant communities and for maintaining the hydrologic function of the soil. 

Severe losses of porosity through soil compaction decrease the water and air available to 

plant roots, creating droughty and/or anaerobic conditions as well as physically inhibiting 

root growth. Soil hydrologic function is usually impaired as water storage capacity, 

infiltration, and permeability decrease, thus increasing runoff and the subsequent 

potential for erosion and cumulative watershed effects. Soil compaction diminishes soil 

porosity, and decreases the transmission of water, nutrients, and air to roots. Severe 

compaction can inhibit root growth when the soil becomes too dense for roots to 

penetrate easily. Finally, compaction decreases infiltration and hydraulic conductivity, 

the movement of water into and through soils, which in turn increases surface runoff and 

erosion potential. Severely compacted soils could take at least 50 years to recover. Bulk 

density (ratio of soil mass to soil volume) and soil strength (penetration resistance) are 

two widely accepted indirect means of measuring changes in porosity in the field. 

Qualitative indicators of compaction include platy soil structure, loss of soil structure 

(e.g. puddling), impressions or ruts in the mineral soil surface, and in some cases, 

redoximorphic features that indicate a recent change in soil aeration. Redoximorphic 

features are soil properties associated with wetness that results from reduction and 

oxidation of iron and manganese compounds after saturation and desaturation with water. 

Both quantitative and qualitative indicators will be used to describe compaction. Use of 

heavy equipment, especially rubber tired skidders, for logging and tractor piling could 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 48 Chapter 3 – Affected Environment 

compact soils, in the upper 12” of the soil profile. Soil compaction can have a 

detrimental effect on soil productivity on fine-textured soils that are moist or at optimal 

soil moisture conditions for soil compaction. Soil compaction is not a concern in coarse 

textured soils. In fact, soil compaction has been found to have an increase in soil 

productivity by increasing the available water holding capacity of the soil (Powers, et al 

2008). Soils have been classified into sensitive and non-sensitive soils types for the 

purpose of identifying soils that are susceptible to detrimental soil compaction. Soil 

porosity should be at least 90 percent of total porosity over 85% of an activity 

area (stand) found under natural conditions. A ten percent reduction in total soil 

porosity corresponds to a threshold for soil bulk density that indicates detrimental 

soil compaction. 

2. Soil productivity is dependent on the amount of soil organic matter available to prevent 

significant short or long-term nutrient cycle deficits, and to avoid detrimental physical 

and biological soil conditions. Soil organic matter should include fine organic matter and 

large woody debris. 

a. Fine organic matter provides soil nutrients and protects the soil by providing soil 

cover. Soil cover or the lack of soil cover can affect soil productivity by removal 

of surface soils from accelerated erosion. Accelerated erosion is erosion that 

occurs at a rate over and beyond normal, natural or geological erosion, primarily 

as a result of human activity. Soil loss should not exceed the rate of soil 

formation (approximately the long-term average of 1 ton/acre/year). Sufficient 

soil cover should be maintained to prevent accelerated soil erosion from 

exceeding the rate of soil formation. Ground cover will be at least 50% on 

ground slopes less then 35% and on slopes greater then 35%, ground cover will 

be determined by the ID team. Replenishment of fine organic matter to 

preexisting conditions could occur in less then 10 years as forests shed their 

needles and leaves and accumulate on the forest floor. 

b. Large organic matter or large woody debris, provides habitat for soil microorganisms including fungus, soil insects and soil bacteria. All of these organisms 

are critical for soil health and soil productivity. The loss or reduction of large 

woody debris in a forest could last anywhere from 10 to 50 years, depending on 

the number of decadent trees or snags that are left in the stand after treatment. At 

least 5 well distributed logs per acre, representing the range of decompositions 

classes, should be left on the forest floor after the Proposed Action is completed. 

3. Soil productivity can be reduced or impacted from displacement of surface soils. Surface 

soils include valuable amounts of organic matter and nutrients that are critical for 

productive soils. Surface soils can be disturbed by logging and mastication equipment 

operating in the forest, by tractors piling slash and by construction of roads and skid 

roads from excavation of the soil to construct a road or skid trail prism. The surface area 

of new roads will result in a loss of soil productivity for that area. Disturbance of surface 

soils by logging and mastication equipment could result in reduced soil productivity. The 

Sierra LRMP provides direction for avoiding tractor logging on sustained slopes that 

exceed 35%. There are no slope limitations for mastication equipment in the LRMP. 

Mastication equipment can operate on slopes up to 55% slopes. There has been no 

systematic monitoring of mastication work on slopes greater then 35% on the SNF. 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 49 Chapter 3 – Affected Environment 

Affected Environment 

The following information addresses the affected environment or existing pre-treatment soil 

condition, the environmental consequences of the Proposed Action to soil productivity; 

mitigations measures proposed to reduce the impacts of the Proposed Action and a monitoring 

plan to ensure that Forest Standard and guidelines are met to maintain soil productivity. 

Existing Condition 

Soils in the proposed Project area vary in their sensitivity to management. Soils with higher clay 

content and soil moisture have the highest potential to reduced soil porosity. Soil compaction can 

occur down to 12” deep. 

 There is a concern that areas proposed for ground based harvest have soils that are highly 

susceptible to reduction of soil porosity caused from compaction by heavy equipment 

operating when soils are moist or wet. 

 There a concern that prescribed fire and tractor piling will reduce soil cover and 

accelerated erosion could result in a loss of soil productivity. 

 There is a concern that ground based harvest systems on slopes that are too steep will 

displace surface soil horizons that could result in accelerated erosion and reduced soil 

productivity. 

The Project area as defined, borders the community of Fish Camp to the west and Yosemite 

National Park to the north. The soils developing in the area were formed from residual parent 

material. The parent material is mainly granitic rock with few localized areas of andesitic, 

basaltic, and metasedimentary rock formations. The Project area is being deeply dissected by 

localized dendritic stream systems. Some of the major factors affecting soil formation in the area 

are elevation and water regimes. Though not extreme, water regimes and elevation do have an 

accumulative effect on soil formation in the Project area. Elevation in the Project area ranges 

from approximately 5000 to 7200 ft and precipitation increases with rising elevation. 

 

The Fish Camp Project area is underlain with seven soil types and rock outcrop that combine into 

six soil map units (Giger, 1993). See Fish Camp Soils Map (Fish Camp soils report) showing 

location of treatment units and soil map units within the Fish Camp Project area. The major soil 

series located in the area are the Chaix, Chawanakee, Umpa, Ultic Haploxeralf, Entic 

Xerumbrepts, and Ledford families. The Chawanakee, Ledford and Entic Xerumbrept soils are 

shallow soils and are sensitive to disturbance from displacement of the A horizon. Soil map units 

with high amounts of impervious surfaces such as rock outcrop or shallow soil are most 

susceptible to runoff and subsequent surface erosion of soil adjacent to the rock outcrop. Soil map 

units with shallow soils and rock outcrop component include soil map units 123, and 143. These 

soil map units are distributed throughout the proposed Project areas and are a concern for 

increased runoff and potential accelerated erosion of soil below the rock outcrop and within the 

shallow soil. Rock outcrop is located in or adjacent to treatment units T-06, T-10, T-14, T-17, T18, T-21, and T-28. The Ultic Haploxeralf soils have a moderate compaction hazard and are 

located in treatment units T-9, T-7a, T-10a, T-8b, T-10d, T-12, T-8a, T-18a, T-5, T-7b, T-10b and 

T-10c. 

See Table 6 for a list of soils in the Project area and soil interpretations that are considered in the 

effects analysis and design of the project. See Table 7 for a list of physical properties of the soils 

that occur within the Project area. 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 50 Chapter 3 – Affected Environment 

Table 6: Summary of Soil Map Units in the Fish Camp Area 

Soil Map Unit Acres Map Unit name Max 

Erosion 

Hazard 

Runoff 

Potential 

Compaction 

Hazard

Treatment 

Units 

118 10 Chaix Family, 5 to 35 percent slopes Mod to

High Low Low 

T-14a, T-14b 

120 4 Chaix Family, deep, 5 to 45 percent

slopes

Mod to

High Low 

Low T-13 

123 194

Chaix‐Chawanakee Families‐Rock

Outcrop complex, 35 to 6 5 percent

slopes

High to

V High

Mod to 

High 

Low RX-05, RX03, T-18c, T18b, T-13, T18a, T-18d, 

T-16, T17b,T-17a, T19 

124 2 Chaix‐Holland Families complex, 15 to

35 percent slopes High Low 

Low T-7b, 

143 430

Ledford Family‐Entic Xerumbrepts‐

Rock Outcrop associati on, 10 to  45

percent slopes

Mod to 

High Mod Low

M-08, T‐16

T‐28e, T‐

20a

T‐22c, T‐

28b

T‐22b, T‐19

T‐21d, T‐13

T‐21c, UT‐

17a, T‐28a

T‐17a, T‐

28f

T‐28h, T‐

21a

T‐28c, T‐28i

T‐28j, UT‐

17b, T‐28d

T‐20b, T‐6

T‐28g, T‐

22a

T‐21b, T‐27

171 440 Ultic Haploxeralfs, deep, 15 to 50

percent slopes

Mod to

High Low Mod 

RX‐04, T‐9

T‐7a, T‐10a

T‐8b, T‐10d

T‐12, T‐8a

T‐18a, T‐5

T‐7b, T‐10b

T‐10c
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 51 Chapter 3 – Affected Environment 

176 33 Umpa family, deep, 20 to 60 percent

slopes Mod Low Low 

M-14, M-08 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 52 Chapter 3 – Affected Environment Table 7: Description of Soil Taxonomic Units 

Soil Family Taxonomy 

Name 

Temperature Regime 

Soil depth ( inches) 

Texture Hydro 

Grp 

Dr

Chaix 80% Mesic A: 0-6; 

B: 6-36 

A: Coarse Sandy Loam B: Coarse to Gravelly Sandy Loam 

B Som

excdra

Chaix, deep 75% Mesic A: 0-6; 

B: 6-36 

A: Coarse Sandy Loam B: Coarse to Gravelly Sandy Loam 

B We

Chawanakee 35% Mesic A: 0-4; 

B: 4-20 

A: Coarse Sandy Loam B: Coarse Sandy Loam 

C Som

excdra

Rock Outcrop 15% HigLedford 50% Frigid A: 0-8; 

AC: 8-18 

A: Coarse Sandy Loam AC: Coarse Sandy Loam 

B Som

excdra

Entic Xerumbrepts 

20% Frigid A: 0-8; 

B: 8-18 

A: Sandy Loam B: Gravelly Coarse Sandy Loam 

C Som

excdra

Ultic Haploxeralfs, deep 

75% Frigid A: 0-8; 

B: 8-50 

A: Cobbly Sandy Loam B: V Cobbly to Stony Loam 

B We

Umpa, deep 70% Frigid A: 0-6; 

B: 8-32 

A: Bouldery Sandy Loam B: V Stony Coarse Sandy Loam 

B We
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 53 Chapter 3 – Affected Environment 

Areas proposed for ground based harvest systems generally have slopes less than 35%. However, 

some areas exist where slopes exceed 35% and tractor logging could result in soil disturbance that 

mixes or removes soil below the A horizon. Tree removal on these steeper slopes would be “endlined” onto more gentle slopes to avoid mechanical disturbance on the steeper slopes. 

Soil Productivity 

Soil conditions have been reviewed in the Fish Camp Project area. Twenty two soil transects 

consisting of 20 points per transect were collected to characterize soil conditions using the 2005 

Framework Soil Monitoring Methods Protocol. Data for soil cover, soil disturbance, soil 

compaction and large woody debris were collected along transects and summarized and 

documented in a monitoring report by Stewart and Courter, 2007. This report will serve as 

baseline conditions from which to compare soil conditions in the future. The following is a 

summary of existing soil conditions for the Fish Camp Project area based on data collected from 

the soil transects for the Project area and from vegetative inventories. 

Table 7 summarizes existing soil conditions in the Project area. The Project area has an average 

soil cover of 95%, total D2/D3 disturbance is 1.82%, soil compaction is 4.55%, and there are 

19.77 pieces of LWD/ac. Data from the 22 soil transects indicate that the Project area is 

maintaining soil productivity and the criteria for soil productivity are being met for soil cover, 

disturbance, compaction, and large woody debris. Table 8 - Summary of Disturbance Levels from 

Soil Transect Inventory. 

Table 8: Soil Disturbance 

Desired Condition 

Soil physical, chemical, and biological properties that support the productive capacity of the land, 

its ecological processes, such as, hydrological function of watersheds, and the ecosystem services 

identified in land management plans. 

Soil Transect Data Average Over All 

Transects 

Slope Gradient 14.95 % 

Soil Cover 95.08% 

D1 (minimal 

disturbance) 

7.95% 

D2 (moderate 

disturbance) 

1.59% 

D3 (heavy 

disturbance) 

.23% 

Total Disturbance 

D1/D2/D3 

10.23% 

Total Disturbance 

D2/D3 

1.82% 

Compaction 4.55% 

LWD 

(points/transect) 

7.91 

LWD (logs /acre) 19.77 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 54 Chapter 3 – Affected Environment 

Regulatory Setting (Applicable Laws, Policies, and Regulations) 

Laws, regulation and policy direction on soil management relevant to the proposed project and 

affects on soil resources includes the following: 

National Forest Management Act of 1976: Renewable Resource Program. “(C) recognize the 

fundamental need to protect and where appropriate, improve the quality of soil, water, and air 

resources.” 

Forest Service Manual (FSM) 2500 – Watershed and Air Management, Chapter 2550 – Soil 

Management, 2010: FSM 2500 defines Forest Service policy on managing soil productivity and 

components of soil productivity. 

 

SNF- LRMP Soils Standards and Guidelines for General Forest 

The SNF- LRMP provides for soil management standards and guidelines to all management areas 

and analysis areas or aggregates of analysis areas (USDA, 1991). These S&Gs are as follows: 

1. Avoid tractor logging on highly erodible soils, where sustained slopes exceed 35%, 

except where supported by on-the-ground ID team review (see LMP S&G 125). 

2. Apply appropriate erosion prevention measures on all ground disturbing activities (FSH 

2409.23) prior to fall storms (October 1) and immediately upon completion of activity 

begun after November 1 (see LMP S&G 127). 

3. Apply appropriate erosion prevention measures on high erosion hazard soils under the 

following conditions: (see LMP S&G 128). 

a. When exposed soils from an average of several 500-foot linear transects: 

 

i. Exceed 150 feet on slopes of 15-35%, 

ii. Exceed 75 feet on slopes 35-65%, 

iii. Exceed 25 feet on slopes over 65%, 

b. On linear disturbances, such as skid trails and fire lines, cross-drain area at the 

following intervals: 

 Interval between Cross-Drain (feet) 

% Slope HEHR VHEHR 

0-15 150 125 

15-35 75 45 

35-65 35 20 

65+ 15 15 

4. Road construction on areas with High and Very High Erosion Hazard will follow 

standards on areas with High and Very High Erosion Hazard will follow standards in 

FSM 2521 Sierra Supplement No. 8, which gives direction concerning stabilization and 

road surface drainage (see LMP S&G 129 and LMP Letter of Correction, USDA, 2009). 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 55 Chapter 3 – Affected Environment 

5. Plan and execute activities such as timber harvesting, site preparation and fuels reduction 

on soils sensitive to loss of productivity by using the following standards. 

a. Avoid mixing or removing soils below the A horizon. Roads, skid trails, fire 

lines and log landings are exceptions. 

b. On completion of a ground disturbing project on less than 35% slope, maintain 

an average accumulation of 50% protective ground cove density in the 1 to 100-

hour fuels with some 1000-hr fuels up to 10” in diameter. Note: the 10” diameter 

logs conflicts with the Regional Soil Standard and Guideline recommendation for 

desired logs of at least 20 inches in diameter and 10 feet long. 

c. On slopes over 35% with very High and /or High Erosion Hazard soil, an ID 

team will evaluate ground cover needs and develop prescriptions. 

Alternative 1 – No Action 

Direct Effects and Indirect Effects 

Under Alternative 1, soil conditions would not change from the existing conditions. Soil transect 

data indicates that soil cover and large woody debris (LWD) are meeting Regional Soil Standard 

and Guideline thresholds. Soil cover will increase and LWD will increase. The average soil cover 

is 95% and the average number of LWD is approximately 20 logs/acre. This is well over the 

guideline of five logs per acre. The proposed Project area is meeting soil management indicators. 

Some areas have 10-12% detrimentally disturbed and compacted soils including Treatment Units 

10 and 19. The average throughout the Project area for detrimental disturbed and compacted soils 

is approximately 4.55%. Detrimentally disturbed and compacted soils will continue to recover 

over time. 

If vegetation is left in its current state of high fuels and high wildfire risk, it is inevitable that a 

wildfire will occur. Many areas within a potential wildfire area would not meet soil quality 

standards in terms of soil cover and surface erosion rates in a fire event. Soil cover would be less 

than 20% and some soils would develop hydrophobic conditions. Accelerated erosion will occur, 

especially during precipitation events. Soil Productivity will be reduced in some areas by at least 

one site class. Past monitoring of wildfire areas on the nearby Stanislaus National Forest has 

found that bare ground averaged about 70% by spring of the first year and by spring of the second 

year bare ground averaged 27% (Janicki, 2003). In a study conducted by Berg and Azuma (2002) 

bare ground and evidence of surface erosion recovered to pre-fire conditions within four to five 

years after a wildfire. Large woody debris would probably be consumed in a fire and long term 

soil productivity could be decreased. 

This alternative is in full compliance of the National Forest Management Act of 1976, the Forest 

Service Manual (FSM) 2500 – Watershed and Air Management, and the Sierra National Forest 

Plan and Amendments. 

Cumulative Effects 

As no action is being taken by the SNF under the No Action Alternative by definition there would 

be no cumulative effects. 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 56 Chapter 3 – Affected Environment 

Alternative 2 – Proposed Action 

Direct Effects and Indirect Effects 

The following is a discussion of the various kinds of treatments proposed and their potential 

direct and indirect effects to the soil resource. 

Commercial and Biomass Thinning activities (mechanical harvesters), Mastication operations, 

Pre-commercial Thin/Release operations, and Tractor Piling operations use equipment that 

includes steel tracked heavy equipment and rubber tired tractors. These activities have the 

potential to impact the soil resource by mechanically disturbing the soil and/or compacting soil. 

Planting and hand release operations do not affect the soil resource. 

Soil Disturbance and Soil Porosity or Soil Compaction 

Mechanical harvesters and rubber tired tractor skidders used for the proposed commercial and 

biomass thinning, tractor piling, and mastication would cause soil disturbance and their use poses 

increased risk of detrimental soil disturbance, detrimental soil compaction and accelerated soil 

erosion. Standard operating procedures such as cross ditching skid trails for erosion control would 

reduce the risk of erosion and promote surface soil stabilization and re-vegetation. Tractor 

logging is proposed for areas with slopes under 35%, which would reduce excessive soil 

displacement. Areas of slopes in excess of 35% are to be logged with a cut-to-length logging 

system or logs will be favorable skidded to prevent undue soil disturbance. The soils in this 

Project area are highly productive so rapid natural re-vegetation is expected. 

Ultic Haploxeral soils are moderately susceptible to soil porosity loss, due to compaction from 

heavy equipment, such as rubber tired skidders and mechanical harvesters operating when soils 

are moist or wet. Ultic Haploxeral soils occur in treatment areas T-5, T-7a, T-7b, T-8a, T-8b, T-9, 

T-10a, T-10b, T-10c, T-10d, T-12, and T-18a. In order to minimize detrimental soil compaction, 

soil moisture needs to be dry enough to reduce the susceptibility to compaction during thinning 

and biomass removal operational periods. The ideal moisture content varies between soils and 

should not be above 14% to prevent soil compaction. A design feature requiring a soil scientist or 

other earth scientist to be consulted prior to mechanical equipment operating on soils that have a 

moderate soil compaction hazard is a component of the project. The standard operating period 

from June 1 to October 15 and avoidance of operating mechanical equipment on soils with more 

than 12% soil moisture would minimize detrimentally compacted soils in an average rain year 

(See Soil Design Measures). Areas with detrimentally compacted soils would be less than 15% 

for most of the treatment areas. Some portions of the commercial thin or biomass treatment areas 

(Units T-10 or T-19) could have detrimentally compacted soils in excess of 15%. Subsoiling may 

be required in these units if soil compaction exceeds 15% of the treatment unit. Detrimentally 

compacted soils in excess of 15% could occur for at least 1 year, until after tractor piling of slash 

has occurred in the second year of project implementation. Subsoiling landings (BMP 1-16) and 

primary and secondary skid trails would result in less than 15% of the treatment areas with 

detrimentally compacted soils. Soil productivity would be reduced in areas with detrimentally 

compacted soils for 1 or 2 years. 

There are no potential indirect effects of Alternative 2 as soil compaction would be kept to less 

than 15% of an activity area and erosion control measures are implemented in a timely manner. 

There could be an occasional summer storm event that could cause accelerated erosion of bare 

exposed soils. In the event that this should occur soil erosion sites would be restored to pre-storm 

conditions. 

Large Woody Debris (LWD) 

Commercial thinning, biomass removal and tractor piling would probably reduce existing fuel 

loads to levels where fire hazards and fuels achieve the desired conditions. After treatment, on the 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 57 Chapter 3 – Affected Environment 

ground fuel loads are expected to be no more then 5 – 10 tons/acre (see Fire/Fuel Section). This 

would probably reduce existing LWD to no less than 25% of existing levels (existing levels 

average 20 logs/acre), which will still be higher than the minimum five logs per acre that is 

needed to meet the LWD desired condition. 

Soil Cover 

In areas where tractor piling of slash is planned, leave at least 50 percent well distributed soil 

cover for erosion protection on slopes under 35%. If slopes are greater than 35%, soil cover 

should be at least 70%. Past observations on the SNF have found that this amount of soil cover 

generally prevents accelerated erosion. A buffer of 100 feet would be provided around rock 

outcrop to prevent accelerated erosion of the adjacent soils from rapid runoff from rock outcrops. 

Mastication Treatment Areas 

Areas planned for mastication pose little risk of reducing soil productivity. This includes 

treatment units M-8 and M-14. The masticator equipment reduces erosion potential by 

increasing soil cover and generally causes little soil disturbance and compaction. Soil masticating 

equipment generally does not result in compacted soils because the equipment has lower ground 

pressures then conventional logging equipment and because this treatment creates a bed of chips 

that the masticator travels over. Most mastication treatment will be on slopes less the 35%; 

however some areas with slopes in excess of 35% will be treated. This will probably occur in the 

north end of treatment unit M14. Some soil disturbance will probably occur where the 

masticator makes turns during the operations. Soil disturbance will be higher on steeper slopes. 

Prescribed Fire 

Areas planned for prescribed fire pose little risk of causing significant effects to soil productivity 

based on the past performance of the prescribed fire program on the SNF. Past prescribed fires on 

the forest has resulted in low burn intensity in most areas. Prescribed fire burns in a mosaic 

pattern leaving patches of unburned vegetation and patches of burned areas, where duff and litter 

is completely consumed. Most trees are left undamaged, except for a few small patches that have 

burned at moderate burn intensity with moderate burn severity. Soil quality standards have been 

met from past prescribed fires and are expected to be met from the Proposed Action. Soil cover of 

50% is expected to be met in the prescribed fire treatment areas. 

Cumulative Effects 

Cumulative soil effects have been addressed under the cumulative watershed effects (CWE) 

section under the Hydrology/Water Quality Section. Cumulative soil effects have been addressed 

under the cumulative watershed effects (CWE) section under the Hydrology/Water Quality 

Section. Analysis of cumulative soil effects use the Equivalent Roaded Acre (ERA) Model, which 

is used in the CWE analysis. The ERA model quantifies disturbance based on the degree of 

disturbance as compared to an acre of road and measured relative to disturbance in a given 

watershed. ERAs reflect changes to Soil Hydrologic Function, and are an indicator of rutting 

potential, erosion potential and loss of water control. See Fish Camp Project CWE Analysis 

(Gallegos, 2010) for a full description of assessment and assumptions including list of past, 

present and future foreseeable actions. The Forest Service Pacific Southwest Region (R5) 

methodology is used to determine the overall disturbed footprint. The disturbed footprint is a 

semi-quantitative measure of acres of detrimental soil disturbance and hence an approximation of 

change in Soil Quality as defined by the R5 Soil Quality Standards (USDA-FS 1995). 

The Fish Camp CWE Assessment modeled recovery from previous management actions over a 

30 year time span for 8 subdrainages for the existing condition and No Action Alternative. One of 

those subdrainages (501.5055) has evidence of cumulative watershed effects. If this alternative is 

selected, subdrainage 501.5055 would recover over time. Other planned actions that are not part 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 58 Chapter 3 – Affected Environment 

of this decision would still occur, but the total ERAs in the project sub-watersheds would be 

lower than if the project was implemented.. 

 Five of those subdrainages (501.5004, 501.5005, 501.5006, 501.5007 and 501.5053) will exceed 

their lower threshold of concern for cumulative watershed effects after the project is 

implemented, but not their upper Threshold of Concern of 14%. Subdrainages 501.5005 and 

501.5006 have a low potential of incurring CWE and the other subdrainages have an unlikely 

potential of incurring CWE. Evidence of existing CWE in the Long Meadow Creek portion of 

subwatershed 501.5005 and planned mechanical treatments in the SMZ of Long Meadow make 

this subwatershed vulnerable to CWE. Implementation of Soil and Water Conservation Best 

Management Practices and other design measures, including subsoiling of detrimentally 

compacted soils will minimize effects to the soil resource. No significant impacts to soil 

productivity are expected if soil cover is over 50%, detrimental soil disturbance and detrimental 

soil compaction is limited to no more than 15% of a treatment unit; and large woody debris is at 

least five logs per acre. 

Alternative 3 

This alternative would receive treatment only to achieve fire and fuels objectives and limit 

treatments to mechanical clearing of ladder and surface fuels. 

There is no difference between Alternative 2 and Alternative 3 to the soil resource (see effects 

analysis for Alternative 2). Fewer larger trees will be logged in the (T) treatment areas. The 

same or similar equipment will be used to implement either action Alternative. 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 59 Chapter 3 – Affected Environment 

Lands/Special Uses______________________ 

The direct, indirect and cumulative effects to Lands and Special Uses are summarized from the 

Lands and Specials Uses Report for the Fish Camp Project (Nooney, K. 1/28/2011). 

Affected Environment 

Most of the National Forest System (NFS) lands inside the Project area have Acquired Land 

status. Formerly owned by the Madera Sugar Pine Lumber Company, all of the lands inside the 

Project area were obtained by the Forest Service through land exchange in 1930, with the 

exception of 425 acres of Reserved Public Domain lands inside Sections 22, 23, 26 and 27, Range 

22 East, Township 6 South, Mount Diablo Baseline & Meridian. The only treatment scheduled in 

these 425 acres of the Project area is mastication planned in units M-08 and M-14. 

There are a few Land-type special-uses authorized under permit within the Project area including: 

one apiary site off road 5S43C; a Mariposa County-owned garbage transfer station at Goat 

Meadow off Road 5S06; approximately 4000 lineal feet of telephone line buried along the 

Jackson Road (Forest Road 6S07) leading east from Tenaya Lodge to the Yosemite Trails Pack 

Station (YTPS), and approximately 165 feet of overhead telephone line providing service to 

YTPS. 

The apiary site consists of a flat area surrounded by an electric fence where up to 100 hives of 

bees are located. The transfer station is the refuse collection site for all residents of Mariposa 

County living in the Fish Camp Area. The permit area consists of an access road, fee collection 

hut and fenced area. The phone line right-of-way begins at the gate on Road 6S07, buried a 

minimum of 30 inched below grade, and is staked and posted along the route with buried utility 

signs. The underground phone service comes to the service at a utility pole before the YTPS base 

facility and continues to YTPS overhead connected to trees. All of these uses have been 

authorized under permit for years and are easily recognizable features on the landscape. 

The Madera Irrigation District’s water conveyance Ditch built in the 1870’s is not authorized 

under permit or easement; the ditch predates the proclamation of the Forest and does not require 

an authorization. This feature is located adjacent to Road 6S07 and is located close to the 

southwest boundary of the Project area. A research mast tower located near Big Sandy 

Campground is authorized under agreement to support the Sierra Nevada Adaptive Management 

Project. 

The Forest Service holds a permanent, full public easement for Road 6S07 across private property 

located east of Highway 41 in the Fish Camp area. The Forest Service does not hold an easement 

for the portion of the Star Lakes Road on private property; this road turns into Forest road 5S43 at 

the private land-Forest Service boundary. The Forest does not hold an easement with the National 

Park Service for that portion of 5S06 located on NPS administered lands. This road intersects 

with Highway 41 south of the Park’s Wawona entrance station, providing access to the Goat 

Meadow Snow Play Area and the forest beyond. 

Land uses authorized under permit located adjacent to, but outside, the Project area include one 

apiary site, the YTPS base facility, and the Madera Irrigation District’s gauging station. The 

YTPS base facility is located adjacent to Road 6S07 and consists of an office, residence, 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 60 Chapter 3 – Affected Environment 

barracks, sales office, tack rooms, corrals, water tanks, water lines, septic tanks and other 

infrastructures. The Madera Irrigation Station consists of a parking area and facility located next 

to a stream gauging station adjacent to the MID Ditch to measure the flow of water flow in the 

Ditch. 

Alternative 1 – No Action 

Direct, Indirect and Cumulative Effects 

Under the No Action alternative, current management plans would continue to guide activities in 

the Project area. This includes all ongoing activities with existing decisions or permits that would 

not change if this alternative was selected. 

While special-use permittees would continue to perform hazardous fuels reduction around the 

facilities they operate, they would be limited to the standard 30 feet required by the Forest 

Service. Under consultation and in coordination with the Forest Service, permit holders may be 

able to extend fire clearances around their facilities to meet the 100 foot requirement of the State 

of California. There would be little protection from moderate to high intensity fires. 

The continuation of natural fuels build-up could pose a wild fire threat to permit holder 

improvements, and for commercial permit holders, a loss of revenue. Overstocked stands have the 

potential to be effected by epidemic infestations of bark beetles and, in combination with disease, 

and/or drought-induced mortality, the forested areas the commercial permit holders depend on for 

their livelihood are at risk. Commercial permit holders would likely experience loss of revenue 

because forest visitors they depend on may be hesitant to visit parts of the forest that have high 

tree mortality. As public safety concerns (mainly from snag densities and high fire danger) 

increase there would be the potential need for areas to be closed to public access. 

As no action is being taken by the SNF under the No Action Alternative by definition there would 

be no cumulative effects. See FEIS page 31 for more explanation. 

Alternative 2 – Proposed Action 

Direct Effects 

Implementation of Alternative 2, like the No Action alternative, would not change management 

or permitted activities within the Project area. The activities associated with the Proposed Action 

would include commercial, pre-commercial and biomass thinning of conifer stands and 

prescribed burning (understory and pile) with associated post-activity treatments. Implementation 

of this alternative may have direct effects to permitted operations and general recreation inside 

the Project area. Design criteria have been developed to minimize the impacts that could occur 

from the implementation of this alternative and are listed on page 13. 

The County Transfer Station and Goat Meadow Snow Play area are located within the T-8a Unit. 

Stand thinning activities, product hauling, use of the parking area for a landing, and other 

operations that occur during summer or winter months have the potential to interfere with access 

to and operations at the County Transfer Station, and Special-Use permitted activities including 

the Pioneer Wagon Train and Shadow of the Giants recreation events, the Camp Wawona and 

Tenaya Lodge outfitting and guiding operations. Dispersed camping that occurs in the area may 

be limited or restricted if operations occur during summer months. If project operations occur 

during winter months, snow play activities at the Snow Play area may be affected. 

Yosemite Trails Pack Station uses a network of Forest roads and permitted trails for their riding 

clientele in summer months. Trails permitted to YTPS are located in units T-7a, T-9, Rx55, T-12, 

T17a, T-17C, and T-18a. Project activities including chainsaw use, felling of trees over trails, 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 61 Chapter 3 – Affected Environment 

skidding, piling of logging slash and other operations have a high potential to affect the recreation 

experience of YTPS clients and other forest users. Hauling of equipment and forest products on 

Road 6S07 has the potential to interrupt activities authorized under permit to YTPS. 

Unit T6 is located near an authorized apiary site off road 5S43C. Noise and vibrations from 

project activities may cause honey bees to act more aggressively than normal. If worker safety 

becomes an issue during project activities, Forest Service project managers would work with the 

permit holder to minimize safety concerns. 

Unit T14e is located near a research Mast Tower that was installed to support the Sierra Nevada 

Adaptive Management Project. The tower is located in a clearing and is clearly visible. 

Units T-14b and T-5 are plantation units located near Big Sandy Campground. Project activities 

in from June-September could affect the experiences of people who are using the Campground. 

Transportation of project personnel, equipment and forest products would not occur on the Star 

Lakes Road (5S43) located on private property because the Forest Service does not hold an 

easement to use this road for project purposes. In addition, the road through private property is 

very narrow and goes through a congested residential area. 

The Forest used to hold a Special Use Permit for the portion of Road 5S06 located on National 

Park Service lands. That permit expired in the mid-1980’s and was not replaced by another road 

permit or easement. The Forest has does not have the authority to haul forest products on the NPS 

portion of this road. Transportation of project personnel, equipment and forest products would not 

occur on Road 5S06 until the Forest receives an authorization from the NPS to use the road for 

project purposes. 

Indirect and Cumulative Effects 

Indirect effects are predicted to be minimal, limited to aesthetic perceptions of changes noted by 

forest visitors. Due to unit layout and design there are no anticipated cumulative effects to Lands 

and Recreation Special Uses, or developed and dispersed recreation resulting from this action. 

Alternative 3 

Direct, Indirect and Cumulative Effects 

The effects of this alternative would be similar to that of Alternative 2. 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 62 Chapter 3 – Affected Environment 

Terrestrial Wildlife _______________________ 

The direct, indirect and cumulative effects to the terrestrial wildlife species are summarized from 

the Biological Evaluation/Biological Assessment (BE/BA) for the Fish Camp Project. (Otto, A., 

2010). 

Affected Environment 

The Fish Camp Project is located within both Madera and Mariposa counties on the BLRD of the 

SNF. The Project boundary encompasses 5,440 acres within the South Fork Merced River HUC 

5 watershed. (USDA USFS 2010). Most of the Northern boundary of the project abuts Yosemite 

National Park, while the eastern and western boundaries are bordered by private lands. The 

community of Fish Camp lies at the western edge of the Project area, and it is within a WUI 

forest designation. The proposed project ranges from 5,000 feet to 8,000 feet in elevation. 

Primary vegetation types include: Sierra mixed conifer (62% of the Project area), Jeffrey pine 

(16% of the Project area), red fir (9% of the Project area), and ponderosa pine (6% of the Project 

area). Montane chaparral habitat is present in 3% of the Project area. The remaining habitat types 

each represent less than 1% of the Project area and include mixed chaparral, white fir, wet 

meadow, rocky outcrop, lacustrine, and montane riparian areas. See figure 3. 

Figure 3: Terrestrial Wildlife Management Areas

As part of the effective environment monitoring of fisher and high quality fisher habitat within 

the Fish Camp Project area and the surrounding 4 key-subwatersheds will be conducted by Rick 

Sweitzer, UC Berkeley fisher team, as part of the Sierra Nevada Adaptive Management Project 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 63 Chapter 3 – Affected Environment 

(SNAMP). More information regarding SNAMP can be found on-line at 

http://snamp.cnr.berkeley.edu/). 

Management and Regulatory Framework 

Specific Forest Service requirements for managing Federally Listed and Forest Service Sensitive 

species and their habitats are defined in the following documents. 

 National Forest Management Act (NFMA) 

 Forest Service Manual and Handbooks (FSM/FSH-2670) 

 Endangered Species Act (ESA) 

 Sierra National Forest Land and Resources Management Plan (LRMP) 

 2004 Sierra Nevada Forest Plan Amendment (FSEIS and ROD) 

All Standards and Guidelines from the Record of Decision (ROD) for the 2004 Sierra Nevada 

Forest Plan Amendment for managing wildlife and wildlife habitats will be adhered to in this 

project. Additional Terrestrial Wildlife Project Design Criteria common to all alternatives can be 

found in Chapter 2 of this document and in Section IICiii of the project BE/BA (Otto , A., 2010). 

Methodology for Analysis 

A total of 13 terrestrial wildlife species were identified as Federally listed, or that are candidates 

for listing, or that are Forest Service Sensitive Species, and that also may inhabit the Project area 

or nearby areas. These species were determined by reviewing the USFWS on-line data base on 

October 5, 2010 (http://sacramento.fws.gov/es/spp_list.htm). Forest Service Sensitive Species 

were determined by reviewing the USFS Pacific Southwest Region’s Sensitive Species List on 

June 8, 1998, as amended on March 6, 2001, May 7, 2003, and October 15, 2007. 

The 13 species were evaluated to determine whether they or their habitats exist, or potentially 

exist, in or near the Project area. If the species or their habitats do exist in the area, then they 

were further assessed to determine whether there was potential for the species or its habitat to be 

directly, indirectly, or cumulatively affected by the project. 9 of the 13 species met these criteria, 

therefore they were analyzed in detail in the project BE/BA. Table 9 summarizes the species 

habitats, area of consideration, and the rationale for including them in detailed analysis within the 

project BE/BA. 

Four of the 13 species were not analyzed is the project BE/BA because they either do not occur in 

the Project area, or do not have habitat within or adjacent to the Project area, nor are affected 

directly, indirectly, or cumulatively by this project. Table 9 summarizes those species habitats, 

area of consideration, and the rationale for not including them in detailed analysis within the 

project BE/BA. The Fish Camp Project will have no effect on the following four species or their 

habitat, therefore they were not analyzed in detail in this BE/BA: 

 Valley Elderberry Beetle (Desmocerus californicus dimorphus) Federally Threatened 

 Bald Eagle (Haliaeetus leucocephalus) Forest Service Sensitive 

 Wolverine (Gulo gulo) Federal Candidate Species; Forest Service Sensitive 

 Willow flycatcher (Empidonax trailli) Forest Service Sensitive 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 64 Chapter 3 – Affected Environment 

Table 9: Special Status species on the Sierra NF and a summary of their habitats, 

area of consideration, and rationale for inclusion within the BE/BA detailed 

analysis. 

Species 

(Elevation 

Range in 

Feet) 

Habitat Analysis 

Boundary Rationale a

California 

wolverine 

(Elevation 

7,000’-

12,000’) 

Use a variety of habitats. Dens include 

snow-covered roots, standing or down logs 

with large cavities, holes under coarse 

woody debris, old beaver lodges, bear dens 

or rocky areas. 

Not known 

to occur in 

SNF 

There are no known 

locations and no suitable 

habitat for California 

Wolverine in or adjacent 

to the Fish Camp Project. 

This species will not be 

analyzed further in this 

document 

Bald eagle 

(< 10,000’) 

Winter habitat in the Sierra NF, day 

perches, roost sites and foraging sites 

along large open waters with abundant 

prey. Known nest sites are at Bass Lake 

and Shaver Lake. 

1⁄2 mile from 

large water 

bodies 

There are no known 

locations and no suitable 

habitat for Bald Eagle in 

or adjacent to the Fish 

Camp Project. This 

species will not be 

analyzed further in this 

document 

Valley 

Elderberry 

longhorn 

beetle 

(< 3,000’) 

Habitat consists of elderberry shrubs in 

Great Valley Oak Riparian Forests below 

3000 feet in elevation 

Within 1⁄4 

mile of 

Project area 

The Fish Camp Project 

ranges from 5,000’ to 

8,000’ in elevation which 

is well above the 

elevational range of 

VELB. This species will 

not be analyzed further in 

this document 

Willow 

flycatcher 

(2,000’-

8,000’) 

Western Sierra Nevada's 

Found in willow-dominated riparian areas, 

including moist meadows with perennial 

streams and smaller spring-fed or boggy 

areas 

Within wet 

meadows 

The Fish Camp Project 

does not propose any 

treatments within a 

minimum 100 foot radius 

of wet meadows. The 

nearest known sighting of 

Willow Flycatcher is over 

18 miles away from 

Project boundary. 

California 

spotted owl 

(>8,000’) 

Sierra Nevada province in CA. Need at 

least 40% canopy closure and an average 

dbh of 11 inches 

1⁄2 mile 

around 

Project 

boundary 

Potential impacts to the 

California spotted owl 

and/or its habitat will be 

analyzed in this document 

Northern 

goshawk 

(<10,000’) 

Dense mature conifer and deciduous 

forests interspersed with meadows, other 

openings and riparian areas. Found in 

Mixed Conifer to Lodge pole Pine 

1⁄2 mile 

around 

Project 

boundary 

Potential impacts to the 

Northern goshawk and/or 

its habitat will be 

analyzed in this document 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 65 Chapter 3 – Affected Environment 

Species 

(Elevation 

Range in 

Feet) 

Habitat Analysis 

Boundary Rationale a

Great 

gray owl 

(4,500’-

7,500’) 

Found in large moist montane meadows 

surrounded by dense forest of medium to 

large mixed conifer and red fir. 

1⁄2 mile 

around large 

meadows 

(15 acres +) 

or meadow 

complexes 

Potential impacts to the 

Great Gray Owl and/or its 

habitat will be analyzed in 

this document 

Pallid bat 

(<6,000’) 

Uses a variety of habitats. Depends on oak 

woodlands for foraging. Roosts in mines, 

snags, and in crevices in oaks 

1⁄4 mile 

around 

Project 

boundary 

Potential impacts to the 

pallid bat and/or its 

habitat will be analyzed in 

this document 

Townsend's 

big-eared 

bat 

(<10,000’) 

Found throughout the Sierra Nevada. 

Inhabits isolated areas with low human 

disturbance. 

1⁄4 mile 

around 

Project 

boundary 

Potential impacts to the 

Townsend’s big-eared bat 

and/or its habitat will be 

analyzed in this document 

Western 

Red Bat 

(<3,000’) 

Uses a variety of habitats. Prefers edges or 

habitat mosaics that have trees for roosting 

and open areas for foraging 

1⁄4 mile 

around 

Project 

boundary 

Potential impacts to the 

Western red bat and/or its 

habitat will be analyzed in 

this document 

American 

marten 

(>7,200’) 

Found in mesic, late successional 

coniferous forests. Dens are in trees, 

snags, downed logs and rocks in 

structurally complex old forests. 

3.1 mile 

radius 

around 

Project area 

Potential impacts to the 

American marten and/or 

its habitat will be 

analyzed in this document 

Pacific 

fisher 

(5,000’-

8,500’) 

Coniferous and mixed forests with high 

canopy closure and late successional oldgrowth forest structural elements. Den and 

rest sites associated with water or riparian 

habitats. Rest sites include large standing 

conifers or hardwoods (snags or live trees). 

Dens occur in cavities of standing large 

diameter conifers or hard-woods (snags or 

live trees) 

3.1 mile 

radius 

around 

Project area 

Potential impacts to the 

Pacific fisher and/or its 

habitat will be analyzed in 

this document. 

Sierra 

Nevada red 

fox 

(7,000’-

12,000’) 

Red fir and lodge pole pine in subalpine 

and alpine fell-fields of the Sierra Nevada. 

Dens seem to be in rock/talus slides or 

earthen excavations/holes. 

3.1 mile 

radius 

around 

Project area 

Potential impacts to the 

Sierra Nevada red fox 

and/or its habitat will be 

analyzed in this 

document. 

Mitigation and Monitoring 

This project integrates management design measures that help mitigate potential impacts to 

wildlife habitat. These measures include, but are not limited to, Limited Operating Periods to 

avoid breeding seasons, Riparian management areas, streamside management zones, and Old 

Forest Linkages for perennial streams. These design criteria were developed to maintain habitat 

connectivity, special habitat elements for terrestrial wildlife species, and limit the amount of 

behavioral disruption during project implementation and post-treatment. Project design criteria 

are outlined in Chapter 2 of this document. 

Key Wildlife Componants 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 66 Chapter 3 – Affected Environment 

Down Woody Material: (S&G#10) “Determine down woody material retention levels on an 

individual project basis, based on desired conditions. Emphasize retention of wood in the largest 

size classes and in decay classes 1, 2, and 3. Consider the effects of follow-up prescribed fire in 

achieving desired down woody material retention levels.” This will be met by maintaining at least 

five well-distributed logs per acre as large woody debris (LWD) representing the range of 

decomposition classes from the Geology/Soils design criteria throughout the implementation of 

this project. 

Figure 4: FIA Plot data Log Decomposition Classes 

Snag Retention: (S&G#11) “Design projects to implement and sustain a generally continuous 

supply of snags and live decadent trees suitable for cavity nesting wildlife across a landscape. 

Retain some mid- and large-diameter live trees that are currently in decline, have substantial 

wood defect, or that have desirable characteristics (teakettle branches, large diameter broken top, 

large cavities in the bole) to serve as future replacement snags and to provide nesting structure. 

When determining snag retention levels and locations, consider land allocation, desired condition, 

landscape position, potential prescribed burning and fire suppression line locations, and site 

conditions (such as riparian areas and ridge tops) avoiding uniformity across large areas. 

The general guidelines for large-snag retention are as follows: 

 Westside mixed conifer and ponderosa pine types – four of the largest snags per acre. 

 Use snags larger than 15 inches dbh to meet this guideline. Snags should be clumped and 

distributed irregularly across the treatment units. Consider leaving fewer snags 

strategically located in treatment areas within the WUI. When some snags are expected to 

be lost due to hazard removal or the effects of prescribed fire, consider these potential 

losses during project planning to achieve desired snag retention levels.” 

Figure 5: FIA Plot data Snag Decay Classes

Alternative 1 – No Action 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 67 Chapter 3 – Affected Environment 

Under the No Action alternative, current management plans would continue to guide management 

of the Project area. No thinning, either commercial, pre-commercial and/or biomass operations, of 

mixed conifer and pine stands, mastication of brush/shrub patches, prescribed burning to reduce 

natural fuel accumulations and/or treatment of infestations of noxious weeds and replanting of 

conifers in failed conifer plantations would be implemented to accomplish the purpose and need. 

Direct Effects 

There would be no direct effects to any terrestrial wildlife species under this alternative because 

there would be no new activities conducted that would change habitat conditions. 

Indirect Effects 

There may be indirect effects to terrestrial wildlife habitat if Alternative 1 is selected as no fuels 

treatments would occur and the continued immediate threat of uncharacteristically severe wildfire 

would remain unabated. Additionally, in failing to reduce stand density, drought stress and 

subsequent insect and disease mortality would exacerbate the threat of uncharacteristically severe 

wildfire. Furthermore, the high probability of a drying climate change in the Western United 

States would potentially further compound these effects. 

Cumulative Effects 

As no action is being taken by the SNF under the No Action Alternative by definition there would 

be no cumulative effects. See FEIS page 31 for more explanation. 

Alternative 2 – Proposed Action and 

Alternative 3-Lower and Limited Mid-Level Canopy Treatments, All 

Treatment Areas 

Direct Effects 

There are no expected direct effects to the great gray owl, Townsend’s big-eared bat, and western 

red bat, from the implementation of Alternative 2 or Alternative 3 due to a lack of suitable habitat 

for those species within the Project area. 

Direct effects from the implementation of Alternative 2 or Alternative 3 may occur to California 

spotted owl, northern goshawk, American marten, Pacific fisher, Sierra Nevada red fox, and 

pallid bat, although the potential effects would be limited to short-term noise disturbance of the 

project management, which potentially could lead to an energetic expense from avoidance 

reactions. No direct mortality from project activities is expected to occur to these species. 

Limited Operating Periods (LOP) will be implemented, for a variety of species, to protect nest 

and densites, as described in the BE/BA. In particular, a fisher LOP would be implemented for 

all suitable fisher habitat, throughout the Project area, regardless of whether a densite buffer is 

present. This would protect fisher den sites that may be occupied, but not identified through the 

SNAMP project. 

Indirect Effects 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 68 Chapter 3 – Affected Environment 

Habitats in the Project area are defined according to the “California Wildlife Habitat 

Relationship” (CWHR), as shown in Map 6 in the Map Package. Detailed CWHR assessment 

can be found in Appendix C and G of the Fish Camp Terrestrial Wildlife BE/BA (Otto 2010). 

Species specific habitat needs as well as the habitat availability within the Project area are listed 

within the following effects analysis. The effects analysis further describes the changes to this 

habitat for each alternative. Additional information on CWHR habitat types and canopy cover 

can be found in Appendices C of this document. 

Effects to Terrestrial Wildlife Habitat: The ExistingVegetation GIS feature class was refined 

for the Fish Camp Project using existing structure analysis from more than 90 stand examination 

plot data collected in 2009-2010 throughout the Project boundary, as well as forest aerial 

photography interpretation from the 2001 flight-line, and one meter resolution satellite imagery 

from the National Agricultural Imagery Program (NAIP). Plantation CWHR vegetation typing 

was refined through field verification as well as aerial photo interpretation by the district 

silviculturist. Based on past experience with similar situations and professional judgment, the 

district silviculturist was able to estimate the anticipated changes to CWHR habitat throughout 

the treatment units based on the various stand prescriptions and proposed alternatives. Summary 

Table 10 shows CWHR vegetation changes that are expected to occur through implementation of 

Alternatives 2. There will be no anticipated CWHR habitat changes through the implementation 

of Alternative 3, as this alternative proposes to treat for fire and fuels reduction purposes only 

there would not be any resulting change to the mid and upper level stand structure. 

Table 10: Action Alternatives Summary of changes to CWHR Forest Type within 

treatment units of the Fish Camp Project 

 Alternative 2 Alternative 3 

CWHR 

Habitat Type 

Pretreatment 

CWHR 

Habitat Type 

Posttreatment 

Number of 

Acres of 

Habitat Type 

Change 

Number of 

Acres of 

Habitat Type 

Change 

Sierra Mixed 

Conifer 

(SMC) 4D 

SMC4M 22 acres 0 acres 

Ponderosa 

Pine (PPN) 

4D 

PPN4M 9 acres 0 acres 

Total Acres CWHR Habitat Density 

Change

31 acres 0 acres 

Total planning area acreage for the Fish Camp project is 5,440 acres, and treatments units are 

planned for approximately 1200 of those acres. A total of 31 acres, or 3% of the total acreage of 

treatment units are anticipated to have changes in CWHR density under Alternative 2. These 

changes in CWHR habitat density are spread across 11 treatment units detailed in Appendix G of 

the Fish Camp Project Terrestrial Wildlife BE/BA (Otto 2010). There are no anticipated changes 

to CWHR habitat density or type with the implementation of Alternative 3. 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 69 Chapter 3 – Affected Environment 

The projected changes to CWHR habitat under the proposed Alternative 2 may result in short 

term effects in the way terrestrial wildlife species utilize the habitat. Individuals may leave 

treatment areas during project implementation, and would likely rely more heavily on other areas 

of their home range. The canopy cover in the Project area is expected to convert to higher quality 

habitat within 5-15 years after completion of the management actions as the remaining tree 

crowns grow and the understory develops. The resulting stand also would show increased health, 

growth rate, and resistance to large scale stand replacing wildfire. 

There are no expected indirect effects to the following species due to lack of suitable habitat 

within the Project area: Great gray owl, Townsend’s big-eared bat, and western red bat. 

Indirect Effects are summarized below for the following species: Pacific fisher, California spotted 

owl, Northern goshawk, Pallid bat, Sierra Nevada red fox, and American marten. 

Pacific Fisher: CWHR type changes are projected for 31 acres spread throughout 11 of the 55 

treatment units if Alternative 2 is implemented. Alternative 2 is the most aggressive management 

alternative and shows the greatest amount of change in CWHR 2.1 fisher habitat scores. These 

changes are relatively minor however, and the percentage of CWHR 2.1 habitat retained ranges 

from 98.57% to 99.75%. 

If Alternative 2 were implemented there would be an average of 47 large (greater than 20” dbh) 

live trees per acre remaining that may serve as fisher denning or resting sites post treatment. 

There are also currently 5 standing dead conifers per acre ≥18” dbh which may be used as fisher 

denning and resting sites throughout the Fish Camp treatment units. Snags will only be removed 

if they meet the definition of a danger tree. All currently marked danger trees (intended for 

removal) are immediately adjacent to roadways in the Project area and on average less than 1 

danger tree per acre is marked for removal. There are additional black oaks throughout the Project 

area that may serve as denning or resting sites that are not accounted for in these numbers of trees 

per acre. Considering 17 trees per acre as an estimate for the numbers of available resting and 

denning sites required by a fisher throughout their home range, the remaining numbers of live and 

dead trees per acre calculated for the Fish Camp Project area appears adequate for maintaining 

these important habitat structures throughout the treatment areas, exceeding this figure by 300%. 

As the majority of large trees >20”dbh would be retained through the implementation of 

Alternative 2, and all snags that do not meet the definition of a danger tree will be retained, the 

Fish Camp Project area will continue to provide adequate numbers of resting and denning 

structures for fisher. 

There may be a short-term reduction in prey availability within some areas of the treatment areas; 

however, long-term positive effects of treatment should promote the growth and re-growth of 

understory vegetation, which provides forage for prey species, as well as hiding and thermal 

cover. The horizontal and vertical diversity of forest vegetation structure and species also may be 

improved in some sites as a result of partially opening the forest overstory, particularly with 

Alternative 2. This in-turn would bring greater biodiversity into the stands, promoting greater 

prey species abundance and diversity. 

Habitat connectivity will be maintained throughout the implementation of this alternative by 

design criteria common to all Alternatives including Old Forest Linkages (OFLs), retention of 

shrub understory throughout treatment units, large tree groups, and areas between units where no 

treatments will occur. The inclusion of untreated areas along steep sloped regions and riparian 

corridors (primarily Big Creek, Rainier Creek, White Chief Creek, and several unnamed 

perennial tributaries) will maintain habitat connectivity and fisher dispersal routes. 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 70 Chapter 3 – Affected Environment 

The untreated areas, interconnected with OFLs will accommodate daily fisher movements as well 

as dispersal movements, providing habitat connectivity throughout the Fish Camp Project area 

and dispersal routes to the north and south. Fisher should also retain movement opportunities 

between adjacent high quality habitat areas such as Nelder Grove and Yosemite Mountain Ranch. 

These areas of no treatment are mapped in the project BE/BA and provide a visual representation 

of movement capabilities throughout the Project area during project implementation and posttreatment. Additionally, with Design Criteria Common to All Action Alternatives, the inclusion 

of large tree groups and the preservation of understory vegetation in cooler, moister sites within 

treatment units would maintain heterogeneity of the habitat post treatment and aid in fisher 

movements. 

Design criteria common to all action Alternatives includes a LOP from March 1 through June 30 

which will be applied to all potential fisher denning habitat and should limit potential disturbance 

to females during denning and kit rearing. Units with a fisher LOP are outlined in the project 

BE/BA. The Fish Camp project will adhere to Standard and Guideline 86 for fisher den sites 

within the Project area. 

Disturbance of habitat may result in short term effects in the way fisher utilize the habitat. Fisher 

may leave treatment units during project implementation, and will likely rely more heavily on 

other areas of their home range. Individual energetic expenses may be increased if fishers have to 

travel farther to forage, however with areas of adjacent suitable habitat outside treatment areas 

but within their home range, it is unlikely this would result in individual mortality. 

Habitat disturbance in the Project area may lead to increased predation of fisher by mountain lion, 

bobcat, or coyote. Predation potential could increase if an individual fisher were to move into 

unfamiliar habitat, although this would be unlikely as all male and female home ranges extend 

beyond the Fish Camp Project boundary. Habitat disturbance in the Project area may also 

exacerbate individual fisher mortality induced by disease. The degree of these potential effects 

are unknown, but may be illuminated through the SNAMP research. 

Alternative 3 would focus solely on treating surface and ladder fuels (within the lower and 

limited mid-level canopy levels) needed to achieve fire and fuels objectives. There would be no 

additional treatments to address stand density/forest health objectives. 

Without density management of the stands for forest health purposes, insect and disease induced 

mortality of trees throughout overstocked stands will remain a threat to fisher habitat. Minor 

outbreaks of disease or insect infection can be beneficial in creating decadent habitat 

characteristics; however extensive outbreaks which can occur during drought periods can 

drastically affect large contiguous blocks of land. Habitat effects could be similar to those that 

would occur with severe wildfire and could ultimately lead to habitat fragmentation or vegetation 

type conversions. 

Long-term positive effects of fuels treatments (due to the reduction of fire hazard) outweigh the 

short-term negative effects of fuel treatments (due to immediate loss of forest biomass) on fisher, 

especially when assuming a more severe fire regime in the future. Vegetation treatment has 

short-term impacts to habitat quality, particularly over the first year, however, new understory 

growth within the first two years by herbaceous, as well as woody vegetation, can also lead to 

habitat enhancement for a variety of wildlife, including fisher and fisher prey species, in the form 

of new forage and hiding/thermal cover. Habitat recovery following an uncharacteristically 

severe wildfire will take considerably longer—based on the silvicultural report prepared for this 

project an estimated 90-110 years if brought back to conditions similar to the historical logging 

that occurred around Fish Camp. 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 71 Chapter 3 – Affected Environment 

California Spotted Owl: Suitable spotted owl foraging habitat consists of mature conifer stands 

with a minimum average dbh of 11”, a minimum canopy cover of 40%, and high quantities of 

down logs and standing snags. Suitable nesting habitat has canopy cover of ≥60%, and large 

diameter trees with cavities, mistletoe brooms, and other structures suitable for nesting platforms. 

Within the Project boundary there are approximately 2,361 acres of suitable nesting habitat and 

3,933 acres of suitable foraging habitat. 

Three historic spotted owl activity centers are present within the Project area, with one of those 

activity centers overlapping proposed treatment units T21a-d. Additionally, there are several 

PACs and HRCAs within a 1.3 mile buffer of the Project area where no work is proposed but 

owls could experience some noise disturbance from project implementation. These include 

portions of the following PAC/HRCAs: MP070, MA079, MA083, MA069, MA001, MA003, 

MA078, and MA085. This noise disturbance will be minimized by geographic features such as 

ridgetops and canyons that will buffer mechanical noise. 

The Fish Camp Project proposes to maintain the highest canopy closure possible while still 

meeting fire and fuels objectives, and under Alternative 2 managing for forest health and stand 

density as well. The prescriptions aim for a canopy closure of not less than 50%, with a 

preference for 60% or greater immediately post treatment. All S&Gs from the SNFPA ROD 

(USDA 2004) will be followed in the implementation of this project. As this project proposes 

thinning from below, very few changes in CWHR habitat type are expected to occur throughout 

the entire Fish Camp Project area. No CWHR changes will occur in Spotted Owl PACs. 

Table 11 shows the proposed treatment areas of the Fish Camp Project in relation to the 

California spotted owl PACs and HRCAs present in the area. Appendix C in the Terrestrial 

Wildlife BE/BA (Otto, A. 2010) provides additional habitat information for CWHR changes 

expected to occur for each proposed project alternative while Appendix G displays detailed unit 

based CWHR changes. 

Table 11: Fish Camp Project Proposed Treatment Units within California spotted 

owl PACs or HRCAs 

SNF 

PAC/ 

HRCA 

ID 

Treatment 

Proposed 

for area 

NEPA Unit 

# of 

Treatment 

Acreage of 

PAC/ 

HRCA 

proposed for 

treatment 

CWHR 

Pretreatment 

CWHR 

Posttreatment Comments 

MA079 

PAC 

Commercial 

thin 

Unit T21a 

Plantation 9 JPN4M JPN4M 

No changes to CWHR 

type are expected. 

Canopy closure will be 

maintained at 60% or 

greater where 

currently available 

Unit T21b 

Plantation 1 SMC4M SMC4M 

Unit T21c 

Plantation 3 JPN4M JPN4M 

Unit T21d 

Wild stand 23 SMC4D SMC4D 

NOTE: JPN=Jeffrey Pine; SMC=Sierra Mixed Conifer 

 

California spotted owl protocol surveys were conducted throughout the Fish Camp Project area 

and did not locate any California spotted owl nests within the project. Spotted owl presence was 

noted adjacent to the Project area in Yosemite National Park. Proposed treatment units partially 

overlap one historic California spotted owl PAC (MA079). Treatment Units T-21a-d proposed to 

commercially thin 36 acres of plantation and second growth wild-stands within the northernmost 

portion of California spotted owl PAC MA079. Canopy cover will not be reduced below 60% 

where currently available to meet S&G 7. Additionally, a LOP from March 1 through August 15 

will be applied to Units T-21a-d to minimize disturbance to breeding owls. 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 72 Chapter 3 – Affected Environment 

The Fish Camp Project forest vegetation types are primarily Westside mixed conifer and 

Ponderosa/Jeffrey pine, which as part of S&Gs requires maintaining four of the largest snags per 

acre distributed irregularly across the landscape (USDA 2004b). The Fish Camp Project will 

retain an average of 9 snags ≥11” dbh and 5 large snags ≥18” dbh across the treatment units, 

exceeding the minimum requirement set forth in the SNFPA ROD. The Fish Camp Project will 

also retain an average of 47 large (≥20” dbh) live conifers per acre to serve as replacement snags 

in the future as some of these large trees receive environmental damage and decadence or 

succumb to disease and/or insect attacks (as set in the Design Criteria Common to All Action 

Alternatives section). 

Quantitative information on the ideal levels of coarse woody debris (CWD) retention levels are 

limited, however a synthesis of the available literature is available in RMRS-GTR-105 “Coarse 

Woody Debris: Managing Benefits and Fire Hazard in the Recovering Forest” (Brown et al. 

2003). This study examined available literature on the ecology of CWD, its importance to wildlife 

and soils, its contribution to potential fire behavior, historical stand structures and large fuel 

accumulations, and potential re-burn severity as a basis for identifying optimum quantities of 

CWD (Brown et al. 2003). CWD is typically defined as dead standing and downed pieces of 

wood larger than 3 inches in diameter (Harmon et al 1986, Brown et al 2003). For warm, dry 

ponderosa pine and Douglas-fir forest vegetation types, Brown et al. (2003) recommend retaining 

between 5-20 tons per acre of CWD ≥3” dbh. Larger logs (≥8” dbh) are used more frequently by 

a variety of wildlife species, while also posing a lower fuels loading threat for high severity fire 

since they are classified as >1,000 hour fuels. Prescribed burning proposed for the Fish Camp 

Project is of low intensity, and generally does not consume fuels >1,000 hours (≥8 dbh). 

Therefore nearly all logs ≥11 dbh should remain as CWD within the Fish Camp treatment units, 

leaving an average of 12 tons per acre, which is well within the range (5-20 tons/acre) suggested 

by Brown et al. 2003 for warm, dry ponderosa pine and Douglas-fir forests. 

This Project proposes to thin from below, mostly reducing understory vegetation. There is a 

potential for noise disturbance to spotted owls during project implementation from an increase in 

human presence, operating equipment, and transportation of materials. Owl activity centers or 

nests near unit operations will be protected by a 1⁄4 mile LOP during the breeding season from 

March 1-August 15. This LOP will minimize disturbance to breeding owls. California spotted 

owls in proximity to work crews and vehicles during project implementation may be disturbed 

sufficiently to leave the immediate area, resulting in a small energetic expense. Owls may also 

experience a missed feeding opportunity due to increased anthropogenic activity in the area. 

These potential effects are expected to be of short duration during the period of active vegetation 

removal. 

There are approximately 200 acres of proposed understory burning as a primary fuels treatment 

throughout the Fish Camp Project area. No prescribed burning is proposed in any California 

spotted owl activity centers as a primary treatment. Low intensity prescribed burning may occur 

throughout treatment units T-8, T-9, and T-12 as a secondary fuels maintenance treatment. 

Understory burning and commercial thinning activities may eliminate some woodrat nests within 

the Project area, which could lead to a decrease in available prey items and therefore an indirect 

effect to the California spotted owl. Since the scope of the primary proposed burning is limited 

within the Project area to 200 acres, and any burning occurring as a secondary fuels treatment 

will be of low intensity, this effect will be negligible. Although there may be a short term 

decrease in woodrat numbers, it is anticipated that woodrats would return to treated areas from 

adjacent areas within a few years. Additionally, availability of other prey items such as flying 

squirrels should remain constant as their nests/dens occur higher in the canopy and would not be 

affected by an understory burn. 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 73 Chapter 3 – Affected Environment 

Northern goshawk: Within the Fish Camp Project boundary there are approximately 2,456 acres 

of suitable nesting habitat, and 4,128 acres of suitable foraging habitat. Northern goshawk 

surveys were conducted in the Fish Camp Project area from July 26, 2010 through August 17, 

2010. Surveys located one northern goshawk nest, and a 200 acre PAC number SIEGH57 

consisting of the highest quality goshawk habitat was created around this nest tree. This is the 

only northern goshawk PAC present within the Fish Camp Project boundary, and no Fish Camp 

treatments overlap this PAC due to the fact that this lies within the hydrology study area for the 

Sugar Pine Adaptive Management Project (SPAMP). 

No direct effects to northern goshawks are anticipated from the proposed Fish Camp treatment 

units. This is due to the fact that surveys were conducted throughout the Project area and did not 

locate any goshawks within Fish Camp treatment units and no treatment units overlap northern 

goshawk PACs. One goshawk nest was located within the hydrology study area for the Sugar 

Pine Adaptive Management Project, and potential cumulative effects to goshawks will be 

discussed in the cumulative effects assessment. Goshawks in proximity to work crews and 

vehicles during project implementation may be disturbed sufficiently to leave the immediate area, 

resulting in a minor energetic expenditure. All northern goshawk nest sites located within the 

Project area will be protected by a 1⁄4 mile LOP during the breeding season from February 15 

through September 15. This will minimize disturbance to breeding goshawks. 

There may be a disturbance to northern goshawk prey base during project implementation. Birds, 

squirrels, and other small animals may leave treatment areas for the short term period when lower 

canopy fuels are being removed. However, these animals should return to the area shortly after 

work is completed. An LOP will be enforced in all goshawk PACs within the Project area so no 

work would occur during breeding season. It is expected that individual goshawks foraging in 

areas where vegetation removal work occurring would move to adjacent areas of the forest to 

forage. 

Pallid Bat: Suitable roosting and maternal cavity habitat may be affected in treatment areas 

where trees from 20” to 30” dbh may be harvested, since conifer trees in that size class may have 

suitable cavities for pallid bat roosts and maternal sites. As this project proposes to thin from 

below, a relatively small number of trees in that size class have been proposed for removal. 

Potential suitable habitat occurs across the majority of the Project area, so it is possible that some 

suitable roost or maternal trees may be removed. Post-treatment foraging opportunities should be 

enhanced or not significantly changed because understory vegetation will be cleared in some 

areas and retained in others which will provide a diversity of microhabitats for ground dwelling 

insect prey. 

Sierra Nevada red fox: There have been no verified detections of the Sierra Nevada red fox on 

the BLRD despite numerous Forest Service and research carnivore monitoring surveys. These 

include 3 years of intensive camera surveys conducted by the UC Berkeley SNAMP fisher crew, 

which are designed to detect small carnivores, as well as the ongoing SNFPA carnivore 

monitoring study (1996-2009) which has utilized track plates as well as cameras (Sweitzer 

personal communication, Truex 2008, Zielinski et al 2005). There have been 7 incidental 

sightings of Sierra Nevada red fox on the BLRD from 1964 through 1994, most of which have 

been reported by forest visitors with limited experience at mammal identification. These sightings 

are likely misidentifications of gray foxes, which usually have some degree of rusty/reddish 

color, and are common inhabitants of the SNF. All incidental sightings occurred below the 5,000 

foot elevation zone in areas heavily used by recreational visitors (ie: Bass Lake). There are no 

Sierra Nevada red fox sightings in the California Fish and Game CNDDB database from 1977-

present on the BLRD. 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 74 Chapter 3 – Affected Environment 

Sierra Nevada red foxes in proximity to work crews and vehicles during project implementation 

may be disturbed sufficiently to leave the immediate area or may miss a foraging opportunity, 

resulting in an energetic expense. However, this is unlikely as the majority of the Project area lies 

below the primary elevational range of the Sierra Nevada red fox, and the fact that red foxes have 

not been detected within the Project area, or anywhere else on the district despite numerous 

surveys. These include 3 years of intensive camera surveys conducted by the UC Berkeley 

SNAMP fisher crew which are designed to detect small carnivores, as well as the ongoing 

SNFPA carnivore monitoring study (1996-2009) which has utilized track plates as well as 

cameras. 

Habitat connectivity will be maintained throughout the implementation of all Action Alternatives 

by design criteria common to all alternatives including OFL, and no treatment areas. The 

inclusion of untreated areas along steep sloped regions and riparian corridors (primarily Big 

Creek, White Chief Creek and several unnamed perennial tributaries) will maintain habitat 

connectivity and SN red fox dispersal routes. 

Long-term positive effects of fuels treatments (due to the reduction of fire hazard) outweigh the 

short-term negative effects of fuel treatments (due to immediate loss of forest biomass) on Sierra 

Nevada red fox, especially when assuming a more severe fire regime in the future from potential 

changes in climate. Habitat within the Fish Camp treatment units is expected to recover within 5-

10 years post-treatment, and should reach current conditions within 15 years. Habitat recovery 

following a severe wildfire will take considerably longer, an estimated 90-110 years based on the 

Silviculture report prepared for this project. 

The Fish Camp Project proposes to maintain the highest canopy closure possible while still 

meeting fire and fuels objectives, and under Alternative 2 managing for forest health and stand 

density as well. The prescriptions aim for a canopy closure of >50%, with a preference of greater 

than 60% immediately post treatment. All S&Gs from the SNFPA ROD 2004 (USDA 2004b) 

will be followed in the implementation of this project. As this project proposes thinning from 

below, very few changes in CWHR habitat type are expected to occur throughout the entire Fish 

Camp Project area. Under the most aggressive Alternative (Alternative 2) 31 acres of CWHR 

habitat will experience a density type change spread across 11 treatment units. No changes to 

CWHR habitat type will occur in units above 7,000 feet in elevation. 

Habitat disturbance in the Project area may lead to increased predation of Sierra Nevada red fox 

by mountain lion, bobcat, or coyote. Habitat disturbance in the Project area may also exacerbate 

individual red fox mortality induced by disease. The degree of these potential effects is unknown. 

American Marten: The Fish Camp Project ranges from 5,000’ to 8,000’ in elevation, 

considerably limiting the potential impacts to martens which are most often found above 7,200’ 

in elevation. At the far eastern edge of the Fish Camp Project boundary there are approximately 

550 acres, (10% of the Fish Camp Project boundary) that are considered suitable marten habitat 

based on elevation and CWHR habitat typing. Mastication units M-14 and M-08 are adjacent to 

marten habitat and will have a LOP from May 1 through July 31. This LOP will protect 

reproductively active marten and young that may be present in the Project area from treatment 

actions during their denning and early rearing periods. 

Status and trend monitoring for fisher and American marten was initiated in 2002 by the SNFPA 

Carnivore Monitoring Program. The monitoring objective is to be able to detect a 20 percent 

decline in population abundance and habitat (USDA Forest Service 2006). From 2002 – 2008, 

439 sites were surveyed throughout the Sierra Nevada on 1,286 sampling occasions, with the bulk 

of the sampling effort occurring within the Southern Sierra fisher population monitoring study 

area (USDA Forest Service 2009). Sampling for this program occurs throughout late spring and 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 75 Chapter 3 – Affected Environment 

into fall, with no sampling occurring during the winter months. There are 10 sample stations 

located within a 3 mile radius of the Fish Camp Project boundary. Two of these stations are 

within the Fish Camp Project boundary and have not detected marten for five sample years. Of 

the remaining 8 sample stations: 6 have not detected marten to date during the SNFPA 

monitoring program, 2 did not detect marten for 1 sample year, 2 for 4 sample years, and 2 for 6 

sample years. The final 2 stations lie to the northeast of the Fish Camp Project boundary and have 

each detected marten, one station detected marten 1 of 2 years, the other detected marten for 3 

years out of 5. (USDA Forest Service 2009). The nearest marten detection from the SNFPA 

carnivore monitoring program is over 2.5 miles east from the Fish Camp Project boundary 

(USDA Forest Service 2009). 

More intensive camera sampling (concentrating primarily on locating Pacific fisher) has been 

conducted by the UC Berkeley fisher crew beginning fall 2007 throughout the Fish Camp and 

Sugar Pine Projects and the surrounding area. This sampling effort is active year-round. Cameras 

have detected marten in several 1km2

 grids in and around the Fish Camp Project, however all 

detections occurred at or above the 6,000’ elevation level mostly during the winter and early 

spring months when no management activities would occur due to snow. 

Much of the Project area receives heavy volumes of snow throughout the winter, and no proposed 

vegetation management activities would occur in the winter months, limiting potential 

disturbance to marten. Additionally, a marten LOP from May 1 through July 31 will be instituted 

for all treatment units at and above the 7,000’ foot level. 

The Existing Vegetation GIS feature class was refined for the Fish Camp Project using existing 

structure analysis from more than 90 stand examination plot data collected in 2009-2010 

throughout the Project boundary, as well as forest aerial photography interpretation from the 2001 

flight-line, and 1 meter resolution satellite imagery from the NAIP. Plantation CWHR vegetation 

typing was refined through field verification as well as aerial photo interpretation by the district 

silviculturist. Based on past experience with similar situations and professional judgment, the 

district silviculturist was able to estimate the anticipated changes to CWHR habitat throughout 

the treatment units based on the various stand prescriptions and proposed alternatives. Summary 

tables are shown below for the CWHR vegetation changes that are expected to occur through 

implementation of Alternatives 2. There will be no anticipated CWHR habitat changes through 

the implementation of Alternative 3, as this alternative proposes to treat for fire and fuels 

reduction purposes only. 

Treatment acres relative to existing vegetation were based on mapping and field visits conducted 

by the district silviculturist. These field visits refined the base vegetation layer and determined 

the net acres of treatment. As shown in Table 10 on page 68 there would be no anticipated 

CWHR habitat changes with the implementation of Alternative 3. None of the CWHR changes 

are expected to take place within marten habitat. 

Marten in proximity to work crews and vehicles during project implementation may be disturbed 

sufficiently to leave the immediate area or may miss a foraging opportunity, resulting in an 

energetic expense. However, this is unlikely as the majority of the Project area lies below the 

primary elevational range of marten, and marten activity within the Project area as detected by the 

SNAMP fisher crew appears to be confined predominantly to the winter months when no 

vegetation management activities would occur. 

Habitat connectivity would be maintained throughout the implementation of all action 

alternatives by design criteria common to all alternatives including OFL, and no treatment areas. 

The inclusion of untreated areas along steep sloped regions and riparian corridors (primarily Big 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 76 Chapter 3 – Affected Environment 

Creek, White Chief Creek, and unnamed perennial tributaries) will maintain habitat connectivity 

and marten dispersal routes. 

Marten habitat preferences and structure is similar to fisher habitat, though martens have a higher 

elevational range. Project design criteria, specifically for fisher habitat, will ensure that sufficient 

legacy structures (large trees with defects, large snags, and large downed logs) would remain after 

treatment and follow-up treatments to maintain habitat suitability for martens as well. An LOP 

from May 1 to July 31 would be applied to a 100-acre buffer around known marten den sites 

which would reduce potential disturbance to martens during the reproductive season. There are no 

currently known marten den sites within the Fish Camp Project area, therefore an LOP would be 

applied to all treatment units at and above the 7,000 foot elevation level. 

The Fish Camp Project proposes to maintain the highest canopy closure possible while still 

meeting fire and fuels objectives, and under Alternative 2 managing for forest health and stand 

density as well. The prescriptions aim for a canopy closure of >50%, with a preference of greater 

than 60% immediately post treatment. All S&Gs from the SNFPA ROD 2004 (USDA 2004b) 

would be followed in the implementation of this project. As this project proposes thinning from 

below, very few changes in CWHR habitat type are expected to occur throughout the entire Fish 

Camp Project area. Under the most aggressive Alternative (Alternative 2) 31 acres of CWHR 

habitat would experience a density type change spread across 11 treatment units. All changes to 

CWHR habitat would occur in units below 7,000 feet in elevation. No habitat that is currently 

suitable for denning would be reduced below suitable denning habitat. Habitat disturbance in the 

Project area may lead to increased predation of marten by mountain lion, bobcat, or coyote. 

Habitat disturbance in the Project area may also exacerbate individual marten mortality induced 

by disease. The degree of these potential effects are unknown, but may be illuminated through the 

SNAMP research. 

Long-term positive effects of fuels treatments (due to the reduction of fire hazard) outweigh the 

short-term negative effects of fuel treatments (due to immediate loss of forest biomass) on 

marten, especially when assuming a more severe fire regime in the future. Habitat within the Fish 

Camp treatment areas is expected to recover within 5-10 years post-treatment, and should reach 

current conditions within 15 years. Habitat recovery following a severe wildfire would take 

considerably longer—based on the silvicultural report prepared for this project an estimated 90-

110 years if brought back to conditions similar to the historical logging that occurred around Fish 

Camp. 

Cumulative Effects 

Potential Cumulative Effects by Species 

The following is a cumulative effects assessment for terrestrial wildlife species considering past, 

present, and reasonably foreseeable activities. Additional details of cumulative effects can be 

found in the Terrestrial Wildlife Biological Evaluation and Biological Assessment (BE/BA), as 

well as Chapter 3 of this EIS. The CEQ issued an interpretive memorandum on June 24, 2005 

regarding analysis of past actions, which states, “agencies can conduct an adequate cumulative 

effects analysis by focusing on the current aggregate effects of past actions without delving into 

the historical details of individual past actions.” Therefore, we use the existing conditions to 

reflect the aggregate impact of prior human actions and natural events that have affected the 

environment and might contribute to cumulative effects. 

Pacific Fisher 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 77 Chapter 3 – Affected Environment 

Assessment Area: For this cumulative effects analysis of past, present, and reasonably 

foreseeable activities on the fisher we will use three levels of analysis. The first assessment level 

is at the multiple home range scale. We chose to buffer the Fish Camp Project area by the size of 

an average female home range. We used 7,000 acres as the average home range size for a female 

fisher, which is based on the average female fisher 95% fixed kernel reported by SNAMP 

(28.4km2

 approximately 7,018 acres) for all female fishers tracked by the UC Berkeley SNAMP 

fisher crew in 2008-2009. This leaves us with an assessment area that consists of a 4-mile buffer 

surrounding the Fish Camp Project area. This buffered area measures 73,210 acres, and would 

incorporate any female fisher home ranges that would overlap or adjoin the Project area. This 

should show any potential cumulative effects to individual females surrounding the Project area. 

The second level of assessment for cumulative effects encompasses all suitable fisher habitat on 

the BLRD ranging from 4,500 to 8,000 feet in elevation. This boundary represents the portion of 

the SSFCA that is present on the Bass Lake RD and equates to approximately 323,500 acres, or 

approximately 46 adult female fisher home ranges. This boundary is consistent with the genetic 

data reported by (Tucker et al. 2009) which used the program “Geneland” to assign genetic 

subpopulations within the larger SSFCA encompassing the Sierra and Sequoia National Forests. 

Through analysis of genotypes 3 distinct “subpopulations” emerged: (1) the North population 

which encompasses most of the BLRD including the Chowchilla Mountains and Shuteye area, (2) 

the Central population which encompasses a small eastern portion of the BLRD, the entire High 

Sierra RD of the SNF, and the northern portion of the Sequoia NF, and (3) the South population 

which encompasses the Southern Sequoia NF and Kern Plateau (Tucker et al. 2009). Therefore, 

this second level boundary of assessment for cumulative effects for the Fish Camp Project 

encompasses 100% of the North subpopulation and around 10% of the Central subpopulation 

nearest to the San Joaquin River. This should show any potential cumulative effects to the North 

population. 

The third and final level of assessment is at the range of the entire SSFCA. The SSFCA 

encompasses the known occupied range of the Pacific fisher in the Sierra Nevada and measures 

1,018,000 acres. We will tie all three assessment levels together and show any potential 

cumulative effects to the Southern Sierra fisher population as a whole. 

Fish Camp Project: As discussed in the direct and indirect effects section, the most aggressive 

management action alternative (Alternative 2) of the Fish Camp Project will have minimal effects 

to fisher habitat (CWHR 2.1 habitat). Specifically, all action alternatives will retain a high degree 

of overstory forest canopy cover (>50% with a preference of greater than 60%, when conditions 

allow); all trees >30 inches dbh, and all snags, will be retained during mechanized treatments, 

except where they pose an immediate safety hazard. Trees >20 inches dbh will be retained, in 

adequate quantity, to help assure availability of resting and denning structures now and into the 

future. Black oaks also will be retained, as well as large tree groups. The project will not impede 

movement or dispersal to other currently connected suitable habitat areas because habitat 

connectivity will be maintained within and adjoining the Project area. And no treatments will 

occur throughout suitable fisher habitat during their breeding season (refer to the effects analysis 

of the Fish Camp Terrestrial Wildlife BE/BA (Otto, A. 2010). There are currently no hazard tree 

removal timber sales within the Fish Camp Project area. The nearest road hazard sale is the 

Oliver/Silver Hazard Reoffer, which is a current sale located southwest of the community of Fish 

Camp, along Forest Road 5S66 which will occur during summer 2011. The last Hazard tree 

timber sale within the Fish Camp Project area was the White Hazard Timber Sale that terminated 

in 2002. This sale was located along Forest Road 5S06 in the eastern edge of the Project area. 

This project is analyzed as part of the current conditions within the Fish Camp Project area. 

All action alternatives also may result in long-term positive effects to the fisher by: 1) reducing 

the potential for Un-characteristically severe, stand eliminating wildfires; and 2) promoting the 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 78 Chapter 3 – Affected Environment 

growth and re-growth of understory vegetation, which provides forage for prey species, as well as 

hiding and thermal cover. The horizontal and vertical diversity of forest vegetation structure and 

species also may be improved in some sites as a result of partially opening the forest overstory, 

particularly with Alternative 2. This in-turn would bring greater biodiversity into the stands, 

promoting greater prey species abundance and diversity, including promoting the establishment 

and improved growing conditions of black oaks, which are important components of fisher 

habitat. All of these factors combined outweigh the short-term negative effects of treatments (due 

to immediate partial loss of forest biomass and disturbance), especially considering that a more 

severe fire regime is predicted for the future, and without fuels reduction, large scale, stand 

replacing wildfires would most likely cause serious and significant impacts to the population. 

Other Current and Future Land Management Projects on the Bass Lake RD: Currently 

there are four land management projects on the Bass Lake District that are of the size that could 

influence the cumulative effects on fisher habitat. Thinning treatments have been completed for 

three of the four projects, including: Sonny Meadows North (with 955 acres of treatments), Sonny 

Meadows South (with 1,400 or more acres of commercial thinning), and Rush Creek 

(approximately 500 acres of commercial thinning). Post-harvest follow-up treatments are still in 

the implementation phase for these three projects. It was determined that treatments for Sonny 

Meadows North, South, Graham Mountain, and Rush Creek would not result in loss of suitable 

habitat, although temporary, activity-related disturbances were expected within proximity of 

management activities. Overall habitat suitability will increase over the long term as a result of 

the completed treatments, and these projects will not increase habitat fragmentation since postharvest habitat will remain suitable. 

Two road hazard-tree sales have been completed on the district over the past 2 years in the 

Minarets area and surrounding Bass Lake. Several other road hazard sales are in the planning 

stages, with implementation expected in 2011-2012. No fisher den sites are located within any of 

the road hazard tree sale boundaries. Hazard tree removal may eliminate some potential fisher 

rest sites, but because hazard trees are identified in proximity to roads, campgrounds and other 

developed sites, the likelihood for use by fishers is minimal. 

Not all hazard trees are snags, in fact, many hazard trees are otherwise healthy, live trees that 

threaten the safety of roads and structures. Some examples of this include: 1. Trees that are 

“heavy leaners”. These types of trees are often without rot, cavities, or other type of habitat 

features. 2. Trees located on cut banks of roads. Many of these may be young, decently growing, 

defect-free trees that have some roots exposed--a potential for tree failure. 3. Trees that are a 

threat to power lines from growing below and into the lines, or leaning trees near power lines or 

other structures that may have grown too tall for the diameter that supports them. 

The Cedar Valley Project (approximately 915 acres of commercial thinning) is nearing the end of 

the implementation phase. It was determined that the Cedar Valley Project may result in a shortterm reduction of denning habitat quality on approximately 628 acres. However, this habitat will 

remain suitable as foraging habitat, and is expected to recover within 10-15 years to higher 

quality fisher habitat. The Cedar Valley Project will not impede movement or dispersal to other 

currently connected suitable habitat areas. 

There is also one reasonably foreseeable project; Grey’s Mountain, (with approximately 2,000 

acres of treatments). The proposed Grey’s Mountain ecological restoration project is in the initial 

planning stages, and would include provisions similar to those proposed for Fish Camp and Sugar 

Pine for fisher conservation. This project and all future projects will would be fully analyzed 

through the NEPA process to help ensure management effects are addressed. 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 79 Chapter 3 – Affected Environment 

Table 12: Analysis of Effects to female fisher habitat 4 mile radius around Fish 

Camp Project 

Female 

Fisher 

95% 

Use 

Kernal 

Home 

Range 

acreage 

Percentage 

of female 

home range 

in BLRD 

Past, 

Present, and 

Reasonably 

Foreseeable 

Vegetation 

Management 

treatment 

units 

Acres of 

female 

home range 

in project 

treatment 

units 

Post 

treatment 

percentage 

of total 

home 

range 

habitat 

retained at 

current 

CWHR 

F01 7026 16% 

Sugar Pine 

Project 516 

acres 

Cedar 

Valley 

Project 586 

acres 

91.85% 

F03 9217 17% 

Sugar Pine 

Project 911 

acres 

92.88% 

F04 7026 9% 

Fish Camp 

Project/8 

acres 

Sugar Pine 

Project /27 

acres 

Rush Creek 

Project/ 95 

acres 

Sonny 

Meadows 

North/ 460 

acres 

Oliver/Silver 

Road 

Hazard 

Project/ 48 

acre 

99.0% 

F05 5872 13% 

Rush Creek 

Project 

185/acres 

100% 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 80 Chapter 3 – Affected Environment 

Sonny 

Meadows 

North/ 597 

acres 

F08 7753 

Unknown 

10% 

Grey’s 

Mountain 

Project 

Graham 

Mountain 

Project/ 

346 acres 

Beasore 

Hazard tree 

Project/ 393 

acres 

 Unknown 

 96% 

F12 7439 7% 

Fish Camp 

Project/ 326 

acres 

Sugar Pine 

Project/ 180 

acres 

99.23% 

F13 6889 21% 

Sonny 

Meadows 

South/ 800 

acres 

Oliver/Silver 

Road 

Hazard 

project/ 670 

acres 

95% 

F14 6575 12% 

Sugar Pine 

Project 182/ 

acres 

Sonny 

Meadows 

North 60 

acres 

Oliver/Silver 

Road 

Hazard 

project/527 

96% 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 81 Chapter 3 – Affected Environment 

acres 

F15 6643 2% 

Fish Camp 

Project /56 

acres 

Cedar 

Valley 

Project 53 

acres 

99% 

F17 6159 16% 

Fish Camp 

Project /252 

acres 

Sugar Pine 

Project 723 

acres 

99.42% 

F18 5929 16% 

Fish Camp 

Project/ 118 

acres 

Sugar Pine 

Project 881 

acres 

99.36% 

F25 5171 18% 

Fish Camp 

Project/ 267 

acres 

Sugar Pine 

Project/ 577 

acres 

Oliver/Silver 

Road 

Hazard 

project/89 

acres 

98.66% 

F26 4804 17% 

Fish Camp 

Project 20 

acres 

Sugar Pine 

Project/ 637 

acres 

Oliver/Silver 

Road 

Hazard 

project/148 

acres 

97.68% 

 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 82 Chapter 3 – Affected Environment 

Of the 13 female fisher home ranges provided by SNAMP (December 2009; Sweitzer 

unpublished data) the percentage of female fisher home range kernel within vegetation 

management treatment units ranges from 2% to 16%. The percentage of CWHR habitat retained 

ranges from 91.85-100%. No more than 8% of any female fisher home range is projected to be 

reduced in habitat quality, and habitat that is effected will not be reduced below CWHR 4M. 

Table 12 shows the past, present, and reasonably foreseeable actions on the Bass Lake Ranger 

District. Approximately 14% of the fisher habitat within a 4 mile buffer of the Fish Camp Project 

is within a present vegetation management Project boundary. Since habitat within each female 

fisher home range is being retained close to current levels, and no more than 16% of any female 

fisher home range is being treated by current vegetation management projects, it is unlikely that 

an individual fisher would be cumulatively affected by vegetation management activities 

surrounding the Fish Camp Project. 

Timing of Vegetation Management Projects on the Bass Lake RD: It is expected that 

implementation of the Sugar Pine Project will be completed before any ground operations occur 

on the Fish Camp Project. This is due to the fact that the Sugar Pine project is part of the 

SNAMP, and is therefore restricted by the time limitations of research being conducted as a part 

of the on-going research for SNAMP. Treatments for the Sugar Pine Project are expected to 

commence in the summer of 2011 and will be completed under a service contract that will last 

approximately 2 years. A LOP from March 1 through June 30 is being implemented for all 

suitable Pacific fisher denning habitat within the Sugar Pine Project. 

Commercial thinning treatments in Graham Mountain, Sonny Meadows North and South, and 

Rush Creek have been completed. Some follow-up mastication and prescribed burning remains to 

be conducted over the next few years within these Project areas. Commercial thinning treatments 

in Cedar Valley are nearing completion, and are projected to be completed before Fish Camp 

implementation begins. Some follow up mastication and prescribed burning activities will occur 

over the next few years throughout the Cedar Valley units. The few remaining Cedar Valley 

commercial thinning treatment areas are likely to be conducted concurrently with the Sugar Pine 

treatments. Since treatment units occur throughout a total of 25-35% of the Project boundary area 

for all vegetation management projects on the BLRD, and few of these projects are occurring 

simultaneously, fishers should retain movement capabilities throughout all suitable habitat areas. 

The Fish Camp Terrestrial Wildlife BE/BA (Otto 2010) shows the past, present, and reasonably 

foreseeable actions on the BLRD. District-wide, less than 4% of fisher habitat is within a present 

vegetation management Project boundary. 

Provided the vegetation management projects on the BLRD have habitat management goals 

which include retention and promotion of large trees and oaks, as well as project design criteria 

promoting stand heterogeneity as well as retention of snags, large tree groups, decadent/cavitary 

trees, down woody debris, and understory trees/shrubs, it is unlikely that the cumulative effects of 

the vegetation management projects, considered with all past, present, ongoing, and reasonably 

foreseeable activities on the BLRD will have an effect on the North population of Pacific fishers 

within the Southern Sierra. 

Additional Vegetation Management Projects within the SSFCA 

High Sierra Ranger District, Sierra NF: The effects of implementing the Kings River 

Experimental Watersheds (KREW) Project on fisher were evaluated in the 2008 Kings River 

Project Biological Evaluation/Assessment for the Pacific Fisher (USDA Forest Service 2008b). 

The effects of the Dinkey North project on fisher were evaluated concurrently with the Dinkey 

South Project. The KREW Project – Providence unit is just northeast of the boundary of the 

Dinkey South Project area and is projected to result in no more than a 6% loss of fisher habitat 

within its boundaries immediately after project implementation. The KREW Project – Bull unit is 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 83 Chapter 3 – Affected Environment 

approximately 6 miles southeast of the Dinkey South Project area and is projected to result in less 

than a 1% loss in suitable fisher habitat within its boundaries immediately after that project is 

implemented. The Dinkey North Project borders the Dinkey South Project area to the north and is 

projected to result in a 1% loss in suitable fisher habitat within its boundaries immediately after 

project implementation. There are two additional projects on the High Sierra Ranger District 

which are part of the Dinkey Landscape Restoration Project Collaborative: Eastfork and 

Soaproot. These two projects are in the planning stages within the Kings River area. All of the 

previously mentioned projects are predicted to ultimately result in an increase of the quality and 

amount of fisher habitat within project boundaries over the long term. 

Stanislaus and Sequoia National Forests: Projects on the Stanislaus National Forest are not 

expected to result in a change in CWHR size class and cover type, though there would be a 15% 

reduction in canopy. The predicted habitat value for fisher would remain at 4M on these projects. 

Projects on the Sequoia National Forest are also not expected to result in a change in CWHR size 

class and cover type though would result in a loss of habitat. The current projections are that there 

would be a 10 to 20% reduction in suitable fisher habitat for these projects combined. Currently 

there is approximately 2,344 acres of suitable fisher habitat identified within in these Project 

areas, so the reductions would be between 234 and 469 acres. 

While present and reasonably foreseeable vegetation treatments occurring or proposed on the 

Sierra, Stanislaus, and Sequoia National Forests will result in temporary reductions to fisher 

habitat suitability, these effects are relatively small, with changes calculated to occur across 

approximately 3% of the SSFCA. 

Suitable fisher habitat on the SNF has increased slightly from 422,000 acres about ten years ago 

to 449,000 acres in recent years (USDA Forest Service 2006b). Rick Truex, a USDA Forest 

Service fisher scientist believes fishers may have increased their spatial distribution on the SNF 

since the mid-1990s, and that the annual occupancy rate within SNF seems to be consistent, 

though the spatial pattern of detections appears more variable among years than on the Sequoia 

National Forest (Truex pers. comm.). The combination of a stable or slightly increasing amount 

of suitable fisher habitat on the SNF over the last ten years and perhaps an increasing spatial 

distribution of fishers make it reasonable to conclude the cumulative effects of vegetation 

management activities on the SNF have not reduced overall habitat suitability for fishers on the 

Forest. 

Additionally, recent scientific information presented in 2011 at The Western Section of the 

Wildlife Society meeting indicates that the fisher population on the Sierra National Forest is 

stable to increasing. Values of lambda (λ) greater than 1 indicate that a population is increasing, 

while λ values less than 1 indicate that a population is decreasing. Calculated values for λ were 

presented for fisher populations within the SNAMP study area (λ 1.04) on the Bass Lake Ranger 

District, and the Kings River Fisher Project area (λ 1.2) on the High Sierra Ranger District 

(Sweitzer et al. 2011). Based on this data, fisher populations on both districts of the Sierra 

National forest are increasing, although the population growth rate is slightly lower within the 

SNAMP study area as compared to the Kings River area. This is likely due to the bisection of the 

SNAMP study area by Highway 41, a major travel corridor through Sierra National Forest and 

Yosemite National Park. Over 21% of the SNAMP recorded fisher mortalities are road kill events 

on Highway 41 (3 on SNF and 5 in YNP). The Kings River fisher study has only recorded 1 road 

related fisher fatality out of 27 total mortalities (4%). 

The information listed above is in alignment with the findings from the United States Fish and 

Wildlife Service (USFWS). Their annual review of native species that are candidates for listing 

as endangered or threatened (Federal Register: Vol. 72: 69034-69105), reemphasized that the 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 84 Chapter 3 – Affected Environment 

three remaining areas containing fisher populations, including the southern Sierra Nevada, 

“appear to be stable or not rapidly declining based on recent survey and monitoring efforts”. 

In addition, the California Department of Fish and Game (CDFG) in their Evaluation of Petition: 

Request of the Center for Biological Diversity to list the Pacific fisher (CDFG 2008) found that 

the information provided, and was evaluated by the CDFG did not indicate an immediate or 

substantial change in either population or distribution of fishers since the selected benchmark 

analysis period beginning with the assessment provided by Grinnell et al. (1937). Based on this 

information, the Department finds that the fisher has sustained itself since the Grinnell period, 

with no evidence of recent, immediate, or significant change in population or distribution, despite 

a decline in late successional forest. Available information suggests this may be the case for a 

number of reasons. Recent studies of fisher habitat use, occurrence, and movement patterns 

indicate fishers also use managed forest habitats of mixed tree age structure and canopy closure, 

which have essential attributes such as snag/large tree attributes remaining for resting/denning. 

Fishers are no longer subject to the significant mortality factors of trapping and poisoning of prey 

that were common in past decades. Forest management in California has been trending toward 

more retention of late successional stands and this change in management activity likely has been, 

and will be, beneficial to species such as the fisher in the future. 

Based on the above analysis of potential impacts within the Project area and in consideration of 

other past, present, ongoing and reasonably foreseeable actions from within the range of the 

Southern Sierra fisher population, it was determined that implementing either the Proposed 

Action (Alternative 2) or Alternative 3 of the Fish Camp Project would not contribute to 

significant cumulative effects to Pacific fisher or their habitat. This determination is supported by 

recent findings published by both the USFWS and the State of California with regard to fisher 

population viability and habitat sustainability. 

California Spotted Owl 

The California spotted owl has a continuous distribution throughout the Sierra Nevada with a 

network of 234 managed HRCAs (600 acres each) on the SNF. Given the scope and scale of the 

Fish Camp Project relative to the size of the SNF and the Sierra Nevada; the area considered in 

determining the cumulative effects of past, present, and reasonably foreseeable activities on the 

California spotted owl will focus on the SNF. A determination of viability for the California 

spotted owl will be made based on the following analysis. 

Since about the mid 1960s, past activities have included clearcutting and salvage logging (1960s 

to 1972), sanitation and salvage harvests (1972 through 1978), clearcutting, shelterwood cutting, 

and salvage harvests (1978 through 1992), and commercial thinning from below and salvage in 

recent times. The only fires to burn substantial amounts of timber were the Rock Fire in 1981, the 

Big Creek Fire in 1995 and the North Fork Fire in 2001, with each fire burning about 3000 acres 

of forest. Clearcuts or burned areas that took place prior to 1972 are typically successful 

plantations today, exhibiting size class 3 (pole sized, 6-10.9” dbh) and density class M (moderate 

cover, 40-59%) stands. Other, more recent disturbances, while they may be reforested have 

probably not yet reached size class 3. 

In its 12-month finding in which it decided to not list the California spotted owl as Threatened or 

Endangered, the USFWS concluded that the scale, magnitude, or intensity of effects on the 

California spotted owl resulting from fire, fuels treatments, timber harvest, and other activities did 

not rise above the threshold necessitating protection of the species under the Endangered Species 

Act (ESA) (USDI, 2006). The USFWS reached this conclusion after considering the impacts of 

the Forest Service’s implementation of the SNFPA ROD (USDA 2004). The USFWS’ (USDI, 

2006) conclusion is supported by: 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 85 Chapter 3 – Affected Environment 

 Data which indicate that California spotted owl populations in the Sierra Nevada are 

stable and comprise 81% of the species’ known territories 

 The anticipation that current and planned fuels-reduction activities throughout the range 

of the species will have a long-term benefit by reducing the risk of stand replacing 

wildfire; these activities embrace those described by the SNFPA ROD. 

 Protection measures are being implemented for the California spotted owl on private 

lands, including the largest private landholders within the range of the species. 

At a forest-wide scale, there currently are 344 designated HRCAs and 245 PACs which 

encompass 146,760 acres. Approximately 468,861 acres of suitable habitat currently exist on the 

Forest. Considering the proposed treatment activities of the Fish Camp Project, along with other 

ongoing actions, and reasonably foreseeable activities, less than one percent of suitable habitat on 

the SNF would be affected. 

Because the alternatives put forth in this project will increase forest stand structure and 

heterogeneity, and retain high canopy cover, along with the Project’s goal of increasing large 

diameter trees would result in long-term increases in California spotted owl suitable habitat over 

time; along with the relatively stable geographic distribution and population levels of spotted 

owls in the area, the cumulative effects of vegetation management activities in the Fish Camp and 

Sugar Pine treatment units taken together with all other past, present, and reasonably foreseeable 

activities on the Forest will not result in a loss of viability for the California spotted owl. 

All action alternatives also may result in long-term positive effects to the California spotted owl 

by: 1) reducing the potential for Un-characteristically severe,, stand eliminating wildfires; and 2) 

promoting the growth and re-growth of understory vegetation, which provides forage for prey 

species, as well as hiding and thermal cover. The horizontal and vertical diversity of forest 

vegetation structure and species also may be improved in some sites as a result of partially 

opening the forest overstory, particularly with Alternative 2. This in-turn would bring greater 

biodiversity into the stands, promoting greater prey species abundance and diversity, including 

promoting the establishment and improved growing conditions of black oaks, which are 

important components of California spotted owl habitat. These factors, combined with the 

project design criteria implemented to sustaining spotted owls, outweigh the short-term negative 

effects of treatments (due to immediate partial loss of forest biomass and disturbance), especially 

considering that a more severe fire regime is predicted for the future, and without fuels reduction, 

large scale, stand replacing wildfires would most likely cause serious and significant impacts to 

the population. 

Implementing the action alternatives (Alternatives 2 or 3), combined with other past, present, and 

foreseeable land management projects on the SNF, would not have significant, long-term, 

detrimental impacts to the California spotted owl population, and they are not likely to result in a 

trend toward Federal listing or loss of viability for the California spotted owl. 

Great Gray Owl 

While this species may move through the Project area during winter movements, as there is no 

suitable breeding habitat within the Project area, there are no expected direct or indirect negative 

effects to great gray owl from the project; therefore, there are no expected cumulative effects 

from the proposed project alternatives. 

Northern Goshawk 

The northern goshawk has a continuous distribution throughout the Sierra Nevada with a network 

of 57 managed territories on the SNF. Habitat for the northern goshawk has increased over the 

past decade from 382,000 acres in 1995 to 405,000 acres in 2005. Currently there are 405,000 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 86 Chapter 3 – Affected Environment 

acres of suitable northern goshawk habitat in the 4,000 to 8,000’ elevation range on the SNF, with 

less than 1% of the suitable habitat occurring in the Fish Camp Project boundary. Given the scope 

and scale of the Fish Camp Project relative to the size of the Sierra Nevada and the goshawk’s 

overall North American distribution, the area considered in determining the cumulative effects of 

past, present, and reasonably foreseeable activities on the northern goshawk will focus on the 

SNF. A determination of viability for the northern goshawk was made based on the following 

analysis. 

All goshawk nest sites within the Project area will be protected by an LOP. Outside of the LOP, 

portions of the three goshawk PACs will be thinned to the degree allowed under the SNFPA ROD 

(USDA 2004b). The PAC will not be reduced to less than 60% canopy cover, where available; 

therefore, will not be diminished to less than nesting habitat. All snags will be retained during 

project implementation except in those cases where they pose a hazard. 

BEs for many of the past projects in the SNF were reviewed to help inform the present analysis. 

Review of these documents revealed the following basic information about effects to northern 

goshawks from these activities: 

 Twenty-six (26) total project BEs were reviewed, dating back to 1993 on the SNF. 

 Determinations reached were: 

o No effect – 4 BEs 

o May affect individual goshawks, but not likely to lead to a trend toward 

federal listing or loss of viability – 20 BEs 

o May affect individual goshawks, and likely to lead to a trend toward federal 

listing or loss of viability – 0 BEs 

o Northern goshawk was not addressed in the document we reviewed due to 

lack of habitat or other reasons – 2 BEs 

 Types of Projects: Fuels reduction, harvest, hazard tree removal, thinning, and 

underburning were the proposed activities that were most often represented in the 

sample of BEs in which the northern goshawk was analyzed. 

 Relative to “May Affect” projects, the described impacts to northern goshawks most 

often fell in the following categories: 

o Noise disturbances 

o Loss of foraging area if underburn gets out of control 

o Loss of plucking trees 

o Habitat quality reduction 

As with other species, the SNFPA (USDA-FS 2001) provided our analysis of northern goshawks 

with useful historical and habitat information. Evidence suggests the number of goshawk 

breeding territories (ranging from 12 reported in the SNFPA (USDA-FS 2001) to the 57 such 

territories known to exist today) has increased since some of the earliest data was reported in 

Grinnell and Miller (1944 – as cited in USDA-FS (2001)). This is evidenced by the fact that 

there has been no apparent change in the geographic distribution of northern goshawks in the 

Sierra Nevada since then. Thus, goshawk numbers in the SNF remain fairly stable. Reasons for 

this, as put forth by the SNFPA (USDA-FS 2001), include (1) vegetation management practices, 

(2) the fact that the SNF is near the southernmost edge of the goshawk’s range, and (3) survey 

efforts for goshawks may be lower on the SNF. 

The major risk factors identified by the SNFPA (USDA 2004) for goshawks are the effects of 

vegetation management and wildfires on the amount and distribution of quality habitat. 

Implementation of Alternative 2 would result in 31 acres of CWHR 4D converted to 4M. This 

density type change is spread across 11 treatment units and comprises just over 0.5% of the total 
Final Environmental Impact Statement Fish Camp Project 

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goshawk habitat present in the Project boundary. This habitat is expected to recover with 10-15 

years to higher quality habitat. 

Because the alternatives put forth in this project will result in long-term increases in northern 

goshawk suitable habitat over time, along with the relatively stable geographic distribution and 

population levels of goshawks in the area, and the project’s goal of increasing large diameter 

trees, the cumulative effects of vegetation management activities in the Fish Camp treatment 

areas taken together with past, present, and reasonably foreseeable activities on the Forest will not 

result in a loss of viability for the northern goshawk. 

Pallid Bat 

BEs for many of the past projects in the SNF were reviewed to help inform the present analysis. 

Our review of these documents revealed the following basic information about effects to pallid 

bats from these activities: 

 Twenty-six (26) total project BEs were reviewed, dating back to 1993 on the 

SNF. The species was not listed as Forest Service Sensitive until the updated list 

from June 1998. 

 Determinations reached were: 

 No effect – 4 BEs 

 May affect individual bats, but not likely to lead to a trend toward federal 

listing or loss of viability – 10 BEs 

 May affect individual bats, and likely to lead to a trend toward federal 

listing or loss of viability – 0 BEs 

 Pallid bat was not addressed in the document we reviewed due to lack of 

habitat or other reasons – 12 BEs 

 Types of Projects: Fuels reduction, hazard tree removal, thinning, and 

underburning were the proposed activities that were most often represented in the 

sample of BEs in which the pallid bat was analyzed. 

 Relative to “May Affect” projects, the described impacts to pallid bats most often 

fell in the following categories: 

 Loss of roosting trees/snags 

 Displacement because of smoke from underburning 

 Noise disturbance 

Pallid bats occur most frequently below 6,000 feet and are especially sensitive to the removal of 

hardwoods (USDA-FS 2001). Except for 4D and 5D, CWHR rates all size classes and densities in 

blue oak woodlands as high for pallid bat, in terms of meeting its foraging needs. Montane 

hardwood conifer and montane hardwood habitats are rated low for pallid bat by CWHR 

(California Department of Fish and Game, 2005). Currently, there are 32,600 acres of blue oak 

woodlands and 251,000 acres of montane hardwoods and montane hardwood conifers below 

8,000 ft on the SNF in CWHR size classes 2 and higher. The protection, maintenance, and 

enhancement of such westside foothill oaks and montane oaks are expected to benefit pallid bats 

by ensuring the continued availability of roosting sites. Indeed, all of the alternatives proposed in 

the SNFPA FEIS were determined to lead to an increase in oak species (USDA-FS 2001). 

Cumulative effects discussed in the SNFPA FEIS stated that there have been no recent changes in 

the range or distribution of the pallid bat (USDA-FS 2001). For these reasons, and given the longterm objective for increasing the number of large trees across the landscape, the intention of 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 88 Chapter 3 – Affected Environment 

reducing fuels to reduce the potential for large stand replacing wildfire, and the foregoing 

discussion of effects, the cumulative effects of vegetation management activities in the Fish 

Camp Project treatment areas taken together with past, present, and reasonably foreseeable 

activities on the Forest will not result in a loss of viability for the pallid bat. 

Townsend’s Big-Eared Bat and Western Red Bat 

There are no expected direct or indirect negative effects to either of these species from the 

proposed project; therefore, there are no expected cumulative effects from the project. 

Sierra Nevada red fox 

The area considered in determining the cumulative effects of past, present, and reasonably 

foreseeable activities on Sierra Nevada red fox (SN red fox) encompasses the BLRD. This is an 

appropriate scale for cumulative effects for a wide-ranging species such as the Sierra Nevada red 

fox. Based on the following analysis, a determination of viability for the SN red fox will be 

made. 

No large vegetation management projects on BLRD have occurred above 7,000’ over the past 

decade as most recent projects are centered around the WUI areas of the district which generally 

occur below 6,000’ in elevation. Additionally, most SN red fox habitat on the forest occurs in 

wilderness areas where few management activities occur. 

Because the alternatives put forth in this project will result in long-term increases in suitable red 

fox habitat over time and the project’s goal of increasing large diameter trees, the cumulative 

effects of vegetation management activities in the Fish Camp treatment units taken together with 

past, present, and reasonably foreseeable activities on the Forest will not result in a loss of 

viability for the Sierra Nevada red fox. 

American Marten 

The area considered in determining the cumulative effects of past, present, and reasonably 

foreseeable activities on marten encompasses the BLRD. This is an appropriate scale for 

cumulative effects for a wide-ranging species (such as the marten) that has also been selected as a 

Management Indicator Species (MIS) for the SNF. Based on the following analysis, a 

determination of viability for the marten will be made. 

BEs for many of the past projects in the SNF were reviewed to help inform the present analysis. 

Our review of these documents revealed the following basic information about effects to marten 

from these activities: 

Twenty-six (26) total project BEs were reviewed, dating back to 1993 on the Sierra NF. 

Determinations reached were: 

 No effect – 7 Bes 

 May affect individual marten, but not likely to lead to a trend toward federal listing or 

loss of viability – 15 Bes 

 May affect individual marten, and likely to lead to a trend toward federal listing or loss of 

viability – 0 Bes 

 Marten were not addressed in the document we reviewed due to lack of habitat or other 

reasons – 4 BEs 

Types of Projects: Fuels reduction, harvest, hazard tree removal, and thinning were the proposed 

activities that were most often represented in the sample of BEs in which the marten was 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 89 Chapter 3 – Affected Environment 

analyzed. Relative to “May Affect” projects, the described impacts to marten most often fell in 

the following categories: 

 Temporary disturbances 

 Foraging area may be burned if underburning gets out of control 

 Removed hazard trees could serve as resting or denning sites 

 Habitat altered or removed 

 Reduction of habitat quality (e.g., reduction in canopy cover) 

 Habitat will be entered 

 Noise disturbance (SNFPA FEIS 2001) 

No large vegetation management projects on the BLRD have occurred above 7,000’ over the past 

decade as most recent projects are centered around the WUI areas of the district which generally 

occur below 6,000’ in elevation. Additionally, most marten habitat on the forest occurs in 

wilderness areas where few management activities occur. 

Because the alternatives put forth in this project will result in long-term increases in marten 

suitable habitat over time and the project’s goal of increasing large diameter trees, the cumulative 

effects of vegetation management activities in the Fish Camp treatment units taken together with 

past, present, and reasonably foreseeable activities on the Forest will not result in a loss of 

viability for the American marten. 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 90 Chapter 3 – Affected Environment 

Aquatic Wildlife and Management Indicator 

Species ________________________________ 

The direct, indirect and cumulative effects to the aquatic wildlife species and management 

indicator species habitat are summarized from the BE/BA (Strand, P. 2010) and the Aquatic 

Management Indicator Species Report (Strand, P. 2010a) for the Fish Camp Project. 

Affected Environment 

The Affected Environment describes existing condition based on data collected within the 

analysis area and any desired conditions that may have been established. 

Existing Condition 

Table 13 presents project SCI plots and stream channel surveys. The Project Hydrology Report 

(Stone 2010) indicates there is evidence that past activities have caused watershed degradation, 

but overall the channels and subdrainages in the Project area appear to be recovering and reaching 

a state of equilibrium. The current condition for most of the stream reaches is good or fair for 

channel stability using modified Pfankuch, after Rosgen (1996) and this has been corroborated 

with Stream Condition Inventory data. There are, however, several areas within the proposed 

Project boundary that are unstable and sensitive to disturbance. Specifically, Long Meadow in 

subwatershed 501.5005 has instabilities noted. 

Table 13: Summary of subwatershed conditions (ND= No SCI data). mi = miles; 

mm= millimeters 

Figure 6: Mean daily water temperatures through the summer of 2008. Table 4 displays 

miles of perennial streams, miles occuppied by resident trout, 2008 maximum (20-minute) 

summer water temperatures from the larger perennial streams, stream shading (% cover), 

and results from benthic macroinvertebrate sampling. Macroinvertebrate indices were 

calculated by the U.S. Department of the Interior Bureau of Land Management Aquatic 

Monitoring Center (Vinson 2008; Miller 2010) who report slight to moderate organic 

enrichment, with a community dominated by generally intolerant taxa. 

Subwatershed Acres 

Channel 

Typing 

(mi) 

Pfankuch 

stability 

(Rosgen 

modified) 

 Rosgen Sensitivity (mi) 

Poor 

Stability 

(mi) 

D50 

(mm) 

Low Moderate High 

501.5002 587 0 ND ND ND ND ND ND 

501.5004 2436 5 ND ND 2.45 0.1 2.45 0.1 

501.5005 2229 4.94 51.8 Good 3.1 0.62 1.22 0.5 

501.5006 638 2.67 92.9 Fair 0.84 1.48 0.35 1.5 

501.5007 668 7.24 ND ND 4.15 0.17 2.92 0.2 

501.5008 2261 3.6 ND ND 1.24 0.36 2 0.2 

501.5053 lower 1817 4.8 45 Good 2.8 0.46 1.54 0 

501.5053 upper 75.3 Fair 

501.5054 1480 4.71 ND ND 4.54 0 0.17 0 

501.7052 2891 0 85.4 Poor ND ND ND ND 
Final Environmental Impact Statement Fish Camp Project 

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Table 14: Perennial streams; resident trout occupancy, maximum water temperatures, % stream 

shading, and benthic macroinvertebrate index (Hilsenhoff Biotic Index (HBI)). HBI ratings 

between 0.0 – 3.5 considered Excellent; between 3.51 – 4.50 considered Very Good (Hilsenhoff 

1987). (ND= No SCI data) 

Streams in the Project analysis area are within the expected summer temperature range for the 

zoogeographic province described by Moyle (2002), which should be appropriate for native 

aquatic/riparian species. The Project Hydrology Report (Stone 2010) identifies that maintenance 

level 2 (“native surface”) roads throughout the Fish Camp Project area are in poor condition and 

many of these roads lack adequate drainage. This is increasing hydrologic connectivity in the 

project subdrainages, which is contributing to increased sediment input and overall watershed 

degradation resulting in CWE response in some areas. 

Subwatershed Acres 

Perennial

(mi) 

Fish 

(mi) 

Stream 

Shading 

(% cover) 

Max. Water 

Temp. (o C) 

Hilsenhoff 

Biotic Index 

Taxa 

Richness 

(# taxa) 

Tolerant 

Taxa 

Richness 

(# taxa) 

501.5002 587 0.5 0 ND 12.7 ND ND ND 

501.5004 2436 4.9 3.6 ND 15 ND ND ND 

501.5005 2229 3.9 2.7 31% 17.1 4.14 37 0 

501.5006 638 1.6 1.1 67% 19.2 3.87 46 0 

501.5007 668 0.4 0.3 ND ND ND ND ND 

501.5008 2261 3.9 2.6 ND ND ND ND ND 

501.5053 1817 4.6 4.3 46% 17.4 3.13 33 1 

501.5054 1480 4.5 4.5 69% 19.4 4.13 40 0 

501.7052 2891 3.4 0.9 77% 16.8 3.56 59 1 
Final Environmental Impact Statement Fish Camp Project 

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Figure 7: Expected summer temperature range

Species Accounts and Status 

The following provides summarized information on aquatic/riparian threatened, endangered, 

candidate, and Forest Service sensitive (FSS) species that are either known to occur or have 

potential habitat within the analysis area, along with the system used to quantify and evaluate 

potential habitat. Complete descriptions are available in the project aquatic species biological 

assessment/ evaluation (Strand 2011). Species evaluated are based on the August 12, 2010 online 

database of federally threatened (T), endangered (E), proposed (P), and candidate (C) species for 

the Fish Camp Project area from the USFWS (USDI USFWS); 

(http://www.fws.gov/sacramento/is /spp_lists/NFActionPage.cfm). FSS are additionally 

considered. Species potentially affected by this project are the: 

 Sierra Nevada yellow-legged frog (MYLF) (R. sierrae) (C/FSS) 

 Yosemite toad (YT) , Anaxyrus(=Bufo) canorus (C/FSS) 

Sierra Nevada yellow-legged frog (mountain yellow-legged frog) 

Distribution: The Sierra Nevada yellow-legged frog (MYLF) occurs at high elevation (4,500-

12,000 ft) only in the Sierra Nevada Mountains of California (CDFG 2005). DNA sequencing by 

Vredenburg et al. (2007) suggest two species within the historic range of MYLF. R. muscosa

(Sierra Madre yellow-legged frog) would apply to populations south of the divide between the 

Middle and South Forks of the Kings River. Populations to the north (including the analysis area) 

would be considered R. sierrae (Sierra Nevada yellow-legged frog). The USFS sensitive species 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 93 Chapter 3 – Affected Environment 

list and the USFWS continue to refer to the species as mountain yellow-legged frog (MYLF) and 

this evaluation includes that nomenclature. 

Life History: The MYLF is diurnal and is seldom far from water. The species prefers well 

illuminated lakes and tarns, sloping banks of meadow streams, riverbanks, and isolated pools 

(Mullally and Cunningham 1956; Zeiner et al. 1988; Martin 1992). At high elevations, breeding 

occurs between May and August as soon as the meadows and lakes are free of snow and ice 

(CDFG 2005). In lower elevations breeding occurs between March and June once high water in 

streams subsides. Male frogs lack vocal sacks, but produce a call underwater to attract females 

(Vredenburg et al. 2005). Following amplexus the female deposits their 30-400 eggs in clusters 

submerged along stream banks or on vegetation (Zweifel 1955), and tadpoles develop after 2-3 

weeks. 

Tadpoles maintain a relatively high body temperature by selecting warmer microhabitats 

(margins of waterbodies) where they may congregate in the hundreds feeding on algae (Bradford 

1984). Tadpoles may require up to three years before metamorphosis. Following metamorphosis, 

it can take up to four years for juveniles to reach sexual maturity. MYLF may move several 

hundred meters between breeding, feeding, and overwintering habitats (Pope and Matthews 

2001). They tend to follow lake shores and streams, but will move short distances across dry land 

(Matthews and Pope 1999). Since the adults and tadpoles overwinter underwater, at high 

elevations they are restricted to relatively deep lakes (over five feet deep) which do not freeze 

solid in winter (Knapp 1996). Over-wintering of tadpoles in an aquatic habitat makes them more 

susceptible to fish predation and diseases. 

Status: Vredenburg et al. (2007) report that MYLF no longer occur at more than 92% of its 

historic sites, in the Sierra Nevada, with even greater declines in the Tranverse Range and 

southern California. The USFWS (2003) found that listing was warranted as threatened or 

endangered for this species. However the listing was precluded at the time based on other higher 

priority issues (68 FR 2283). It is designated as a candidate species and is currently managed as 

sensitive by the USFS. 

Species Occurrence in the Analysis Area: On the SNF there are 38 known locations currently 

occupied by MYLF. The majority of occupied sites are at high elevations within wilderness areas. 

The Museum of Vertebrate Zoology (Berkeley, California) indicates a foothill yellow-legged frog 

was collected at Big Creek in 1953. This site could be within the Project area boundary, although 

at the elevation (5100 feet) there is possibility the animal could be Rana sierrae (both species 

were classified as Rana boylii prior to Zwiefel’s revision of taxonomy (1955)). There are no 

records from the California Academy of Sciences, California Natural Diversity Database, or 

Forest Service databases of MYLF within or adjacent to the Fish Camp Project area, and the 

species was not located during 2007 herpetofauna surveys. The nearest occupied site is 

approximately 0.25 mile beyond the aquatic analysis area boundary (Figure 3). 

Potential Habitat: MYLF typically live along the edge of watercourses and rely heavily on an 

aquatic environment for foraging, shelter, breeding and protection from predators. The CWHR 

highly suitable habitats (CDFG 2005) for this species are lacustrine, montane riparian, riverine, 

and wet meadows with mostly submerged and flooded gravels, cobbles, and boulders with trees 

greater than one inch in diameter, short or tall herbaceous cover, and vegetation and canopy 

closures greater than 10%. Essential elements for habitat are identified as algae, invertebrates, 

terrestrial insects, and water. 

Habitat for MYLF was evaluated as the perennial streams and lakes above 4,900 feet in elevation. 

Potential habitat was determined by GIS within the analysis area. There is approximately 29 
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miles of stream habitat, and 3 acres of pond and lake habitat. An estimated acreage of suitable 

habitat is derived from the total miles of stream with a 165-foot habitat on each bank (CDFG 

2005) and total acres of lake/pond habitat with a 165-foot dispersal area for an approximate total 

of 1,020 acres of potential suitable habitat for this species (Figure 8, Table 15). 

The CWHR habitat values for the acres of potential MYLF habitat for breeding, cover, and 

feeding are displayed in Table 15. The table also displays the % of habitat represented as low 

quality (<0.33); medium quality (>0.33 and <0.67); and high quality (>= 0.67). The table 

indicates that most the habitat in the analysis area is of medium or high quality for MYLF 

reproduction, cover, or feeding. As displayed in Figure 3, habitat connectivity is available via 

riparian corridors associated with the perennial stream system. 

Table 15: Amount and value of MYLF habitat in the analysis area based on CW HR. 

Habitat Quality Repro (ac) Repro (%) Cover (ac) Cover (%) Feeding (ac) Feeding (%)

None 59 0.06 59 0.06 59 0.06

Low 169 0.16 169 0.16 169 0.16

Medium 720 0.70 768 0.75 768 0.75

High 75 0.07 28 0.03 28 0.03

Yosemite toad 

Distribution: The original range of the Yosemite toad (YT) extends from Ebbetts Pass in Alpine 

County to south of Kaiser Pass and Evolution Lake in Fresno County (Karlstrom 1962, CDFG 

Figure 8: Potential habitat for MYLF in the analysis area (yellow are 

lands in Yosemite NP).
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 95 Chapter 3 – Affected Environment 

2005) above 6000 feet elevation. However, populations have been found as far south as Spanish 

Mountain on the SNF during Forest-wide inventories conducted between 2002 and 2004. 

 

Life History: YT breed in shallow pools and small, slow moving, shallow streams usually in 

meadows (Martin 1992). Movement to and from breeding sites could be extensive, including 

travel over extensive snowfields from over-winter hibernation sites in forested areas (CDFG 

2005). Males arrive at breeding pools several days before females (Kagarise Sherman 1980; 

Kagarise Sherman and Morton 1984). Breeding takes place from mid-May to mid-August 

(Kagarise Sherman 1980; Martin 1992). Males appear to outnumber females at breeding sites 

(Karlstrom 1962; USDI-USFWS 2002a), and females may only breed once in three years. Eggs 

are laid in single or double strands, typically in pools or streams not more than three inches deep 

with a loose silt substrate (Martin ibid; USDI-USFWS 2002a). A single female lays an estimated 

1,500 to 2,000 eggs (Martin ibid). Individual males only stay at breeding ponds for a week or 

two, and females leave shortly after breeding (Kagarise Sherman and Morton 1984; USDIUSFWS 2002a). Eggs hatch in about 10-12 days, and tadpoles metamorphose seven to nine 

weeks after the eggs are laid (Kagarise Sherman and Morton ibid; USDI-USFWS 2002a). 

After breeding both sexes were thought to remain in meadow areas to feed for two to three 

months before hibernating (Kagarise Sherman and Morton 1984), although recent studies indicate 

adults may move several hundred meters from meadows to upland foraging sites (Martin 2008; 

Liang per. comm. 2010). Seasonal variation in home range size is considerable. Mullally (1953) 

estimated home ranges of some toads to be about 20 ft, but suggested that individuals may travel 

long distances away from water (CDFG 2005). Martin (2008) estimated home range at 

approximately 8,460 m2 (2.1 ac), while Liang (per. comm. 2010) estimated mean home range of 

27,430 m2 (6.8 ac), and noted female home range was more than 1-1/2 times larger than males. 

YT seek cover during non-breeding seasons (approximately August to March) in abandoned 

rodent burrows (Jennings and Hayes 1994) or by moving into adjacent forested areas (CDFG 

2005). 

In the late fall the toads are only active on warm days. Yosemite toads enter hibernation in late 

September or early October, and emerge in the spring. The toads utilize rodent burrows, crevices 

under rocks, or the base of willows for hibernation (Martin 1992; 2008). Males emerge from 

hibernation for breeding as soon as snow melts from meadows (Martin ibid). Females first breed 

at 4-6 years and males at 3-5 years of age (USDI-USFWS 2002a). 

Status: Current estimates indicate disappearance of 47 to 69 percent from historical locations 

(USDI-USFWS 2002a). Remaining populations seem more scattered than they were historically 

and frequently appear to consist of small numbers of breeding adults. The USFWS (2002a) 

determined that listing was warranted as threatened or endangered for this species. However, the 

listing was precluded at the time based on other higher priority issues (67 FR 75834). The species 

is managed as sensitive by the USFS, which is preparing a Conservation Assessment for the 

species that is not available for direct attribution. 

Occurrence in the Analysis Area: This species was inventoried for occurrence across the SNF 

between 2002 and 2004. No breeding meadows or individual YTwhere identified within the 

analysis area during Forest-wide or project level surveys. Two occupied meadows are located 

outside of the analysis area (Figure 4), but may have foraging habitat within the Fish Camp 

Project analysis area based on CWHR 900 meter dispersal for the species. 

Potential Habitat: This species occurs above 6,000 feet in elevation in meadows, lake edges, and 

some stream habitats only in the central Sierra Nevada Mountains. The dispersal patterns are not 

totally understood, but similar high elevation toads in Colorado can disperse up to 0.6 miles (900 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 96 Chapter 3 – Affected Environment 

m)(CDFG 2005) to reach breeding or over-winter habitats. The CWHR highly suitable habitats 

(CDFG ibid) for this species are wet meadows that have short (< 12 inches) herbaceous plants 

with vegetation closures greater than 10%. Essential elements for habitat are identified as algae, 

invertebrates, water, and slow water. 

YT also require terrestrial habitat. Metamorphs appear to overwinter their first year in the 

terrestrial meadow habitat adjacent to their rearing site and move to more distant terrestrial 

habitat during mid-summer of their second year (Kagarise Sherman and Morton 1993; USDIUSFWS 2002a). In meadows, metamorphs and yearlings appear to be associated with willows 

and long sedges and grasses. Moist upland areas such as seeps and springheads are important 

summer non-breeding areas for adults (USFWS 2002a). 

Suitable breeding habitat for this analysis was considered all meadows above 6000 feet elevation. 

There are approximately 205 acres of meadow habitat above 6000 feet elevation within the 

analysis area. The CWHR model evaluates wet meadows as providing high quality habitat for YT 

reproduction, cover, and feeding. YT habitat was evaluated as 900 meters surrounding meadows 

above 6000 feet elevation (approx. 8140 acres). Figure 9 and Table 16 display information on 

habitat and occupancy. 

The CWHR habitat values for the acres of occupied YT habitat for breeding, cover, and feeding 

are displayed in Table 16. The table also displays the % of habitat represented as low quality 

(<0.33); medium quality (>0.33 and <0.67); and high quality (>= 0.67). The table indicates that 

most the habitat in the analysis area is of low quality for YT reproduction, cover, or feeding. As 

displayed in Figure 4, habitat connectivity is provided via a network of meadows distributed 

across the landscape. 

Figure 9: YT occupied habitat, potential habitat, and dispersal 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 97 Chapter 3 – Affected Environment 

Table 16: Amount and value of occupied YThabitat in the analysis area based on CWHR. 

Habitat Quality Repro (ac) Repro (%) Cover (ac) Cover (%) Feeding (ac) Feeding (%)

None 818 0.10 818 0.10 818 0.10

Low 7187 0.88 7187 0.88 7187 0.88

Medium 5 0.00 5 0.00 5 0.00

High 132 0.02 132 0.02 132 0.02

Aquatic Management Indicator Species 

Benthic macroinvertebrates and Pacific tree frog are aquatic/wet meadow associate Management 

Indicator Species (MIS) for the SNF, and analyzed in a separate report (Strand 2011a). Benthic 

Macroinvertebrates (BMI) have been demonstrated to be very useful as indicators of water 

quality and aquatic habitat condition (Resh and Price 1984; Karr et al. 1986; Hughes and Larsen 

1987; Resh and Rosenberg 1989). They are sensitive to changes in water chemistry, temperature, 

and physical habitat. BMI are an important component of the foodweb, providing a food source 

for birds, mammals, amphibians, reptiles, and fish. The 29 miles of perennial streams within the 

Project area represent potential habitat for BMI. 

The Pacific tree frog was selected as an MIS for wet meadow habitat in the Sierra Nevada. This 

broadly distributed species requires standing water for breeding; tadpoles require standing water 

for periods long enough to compete aquatic development, which can be as long as 3 or more 

months at high elevations in the Sierra Nevada (CDFG 2005). There are approximately 217 acres 

of wet meadow habitat within the Project analysis area. 

Habitat Summary Table 

Table 17 summarizes potential habitat within the Fish Camp aquatic analysis area for each the 

special interest herpetofauna and MIS habitats. The CWHR essential habitat elements for the 

species are: 

 MYLT: algae, invertebrates (aquatic and terrestrial), water 

 YT: algae, invertebrates, water, slow water 

Table 17: Summary of potential habitat within Project area subwatersheds. 

Desired 

Condition 

Desired 

conditions for 

the Project area were described in the Fresno River Landscape Analysis (USDA - Forest Service 

2005). The Fresno River is adjacent to the Project area and has similar vegetative conditions to 

Fish Camp. The watershed analysis established desired conditions for a number of resource areas. 

Canopy cover was a riparian vegetation indicator identified in the Landscape Analysis. While not 

identified in the Fresno River Landscape analysis, water temperature is also be used as an aquatic 

indicator. Desired conditions are: 

Species Potential Habitat (ac/mi) 

MYLT 1020 ac 

YT 8140 ac 

Lacustrine/riverine habitat 29 mi 

Wet Meadows 217 ac 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 98 Chapter 3 – Affected Environment 

 Stream shading of > 70-80% of the riparian zone as a desired condition. Data 

summarized in Table 14 indicates that some stream segments are currently less than 

the desired condition. 

 Daily mean water temperatures < 21° C. A desired condition for water temperature 

was not identified in the Fresno River Landscape Analysis; however the CDFG 

discontinues trout stocking if water temperatures exceed 21° C (CDFG 2010). This 

temperature is also consistent with that described by Moyle (1976; 2002) within the 

rainbow trout assemblage. Water temperature data collected over the summer of 2008 

(Figure 2) indicates that water temperatures are currently meeting the desired 

condition. 

Environmental Consequences 

This section analyzes the effects of the Fish Camp Project on aquatic/riparian species and their 

habitats. A list of past, present, and foreseeable projects for the Project area is located in Chapter 

3, page XX Proposed management actions have the potential to directly alter stream shading 

(solar radiation); and indirectly or cumulatively alter water temperature; water quantity; water 

quality; sediment, nutrient, and litter inputs; woody debris; and channel structure. All of these 

elements can affect aquatic habitat and nutritional resources of aquatic organisms (Gregory et al. 

1987; Chamberlin et al. 1991; Furniss et al. 1991; Dwire et al. 2006). 

BMI are recognized for their importance in the aquatic/riparian systems within the Project area. 

Thus, if the project alters stream temperature, canopy cover, hydrologic regime, sediment inputs, 

seeps/springs/headwater areas, and nutrient cycling (LWD or litter inputs), it could affect 

aquatic/riparian species indirectly through affects to the invertebrate community. Various life 

stages of resident trout and herpetofauna utilize BMI as a food source. 

Stream flow may increase as forest basal area (and evapotranspiration) declines, and peak flows 

can be indirectly affected by vegetation removal (Chamberlin et al. 1991; Kattleman 1996). 

Troendle (2006) indicated increased water yields following timber harvest, although treatments 

were primarily clearcuts rather than thinnings that are being proposed for the Fish Camp Project. 

Alteration of the hydrologic regime (timing, duration or magnitude of flows) from the combined 

effects of silviculture and underburning could affect spawning for fish, amphibian breeding, and 

MIS habitat (BMI and Pacific tree frog). Such an alteration could also result in channel 

downcutting, bank instabilities and degradation of aquatic habitat through additional 

accumulations of sediment in pool habitat and covering of spawning gravels. In snow-dominated 

areas, such as the Fish Camp drainage area, nearly all of the change in flows would occur during 

spring runoff, and spring runoff may occur slightly sooner if reductions in canopy allow faster 

melting of the snowpack. 

Fire Effects 

One of the objectives of the Fish Camp Project is to modify the intensity and spread of fire in the 

WUI near the communities of Fish Camp. This would be accomplished using a combination of 

thinning and fuels reduction. Nakamura et al. (2008) noted some success with reducing crown fire 

after thinning and burning for the Cone and Megram Fires. They also note that some fires are so 

large (McNally or Cedar Fires) that would likely continue to burn through or around treatment 

areas. 

Little is known about fire history of riparian areas in the west, but it is expected to vary from 

those experienced in upland areas (Dwire and Kauffman 2003; Bisson et al. 2003). Riparian areas 

differ from upland areas in topography, microclimate, geomorphology, and vegetation. Further 

they are characterized as having cooler air temperatures, lower daily maximum air temperatures, 

and higher relative humidity. These characteristics may contribute to higher moisture content of 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 99 Chapter 3 – Affected Environment 

live and dead fuels, and riparian soils, which presumably lowers the intensity, severity and 

frequency of fire (Dwire and Kauffman 2003). 

Fire, both prescribed and wild, has potential to affect aquatic/riparian systems. Prescribed burning 

could indirectly affect streambank stability, aquatic foodwebs, stream temperature, and large 

wood dynamics (Dwire et al. 2006; Bêche et al. 2005). High intensity fires can severely disrupt 

aquatic ecosystems, and that these affects can be prolonged (up to 300 years for LWD). Specific 

influences may include decreased channel stability; greater and more variable stream discharge; 

altered woody debris delivery and storage; increased nutrient availability; higher sediment 

delivery and transport; and increased solar radiation and altered water temperature regime (Bisson 

et al. 2003; Dunham et al. 2003). 

Impact of fire on the BMI community varies by burn intensity and extent; steam size and 

gradient; precipitation and amount of runoff; vegetative cover; geology; and topography. Some 

indicators of community health may return to pre-fire conditions within 1 to 2 years, but the 

overall community will probably vary for 5 to 10 years after the fire (Minshall 2003; Reardon et 

al. 2005). 

The extent of fire effects on fish populations would be related to recovery of suitable water 

temperatures, suitable water quality, and connectivity to population refugia. Trout are noted as 

being resilient and adapted to disturbance (Rieman and Clayton 1997; Dunham et al. 2003; Rinne 

and Jacoby 2005), but recovery could take a decade or more. Sestrich (2005) reported that native 

trout populations recovered rapidly, with some sites exceeding pre-fire population levels within 

three years following fires in the Bitterroot River Basin (2000). Greswell (1999) considered the 

disturbance regime resulting from wildfire could facilitate invasion by nonnative fish species. 

The ecological diversity of riparian corridors is maintained by natural disturbance regimes 

including fire and fire-related flooding, debris flows, and landslides (Dwire and Kauffman 2003). 

Many species have adapted life histories that are shaped by, and may depend on disturbance 

events (Dunham et al. 2003; Bisson et al. 2003; Rieman et al. 2005). There remains debate among 

Aquatic Ecologists regarding the need to treat riparian areas, and the types of treatments. Part of 

the controversy is related to the diverse and complex effects that fire can have on aquatic systems 

(Dunham et al. 2003). Researchers agree that aquatic systems have developed under a disturbance 

regime. Some aquatic biologists believe that wildfire poses additional risk to endangered species, 

while others feel affects from treatments are more likely to damage aquatic systems than fire 

(Erman 1996; Bisson et al. 2003). Analysis following the Angora Fire (USDA-FS 2007), 

identified fire spread was facilitated in part by corridors provided in the no-treatment Streamside 

Environmental Zones. 

Canopy Cover 

Canopy cover is the degree to which tree canopies obscure the sky or block the sun. Canopy 

cover was measured as the percentage of stream shading and varies by the width of the stream 

channel, which is generally a function of stream order. Stream shading is important in 

maintaining water temperature with the effect varying by the height of adjacent vegetation, 

proximity to the stream, topography, angle of the sun, and aspect (Beschta et al. 1987; USGS 

1997, 2000; Moore et al. 2005). The Fresno River Landscape Analysis (USDA-FS 2005a) 

identifies stream shading of 70 to 80% within the riparian zone as a desired condition. 

Large Woody Debris 

LWD is of both physical and biological importance within stream channels and riparian zones 

(Bisson et al. 1987; Sedell et al. 1988). LWD provide sediment traps, affect stream channel 

morphology to create pool habitat, increase channel roughness to dissipate energy, provide 

complexity to habitat, provide structural cover, and provide nutrient inputs (Bisson et al. 1987). 

LWD provide cover for fish and animal species, are directly consumed by specialized 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 100 Chapter 3 – Affected Environment 

macroinvertebrates. Factors influencing LWD in the Sierra Nevada mountain range may include 

geomorphology, decay resistance of local species, floods and past management (Ruediger and 

Ward 1996). The desired condition from the Fresno River Landscape Analysis is that project 

streams should average (over the watershed) between 3 to 15 LWD/100 m of the larger (stable) 

class. 

Water Temperature 

Water temperature has multiple effects on aquatic/riparian species and their behavior. Thermal 

effects relate to directing behavior (trigger migration or spawning); controlling factors (time of 

incubation and emergence); lethal (lead to breakdown of homeostatic system and increased 

susceptibility to disease); and growth (metabolic regulation; affected by food supply) (Beschta et 

al. 1987; Armour 1988; USGS 1997; 2000; Sauter et al. 2001). Elevation, aspect, stream width, 

channel roughness coefficient, riparian shading, solar radiation, air temperature, cloud cover, and 

stream discharge levels can affect water temperature. Of these elements, direct effects on riparian 

shading and indirect effects on stream discharge level could have the most effect on stream 

temperature (Beschta et al. 1987; Moore et al. 2005). A desired condition for water temperature 

was not identified in the Fresno River Landscape Analysis. The CDFG discontinues trout 

stocking if water temperatures exceed 21° C (CDFG 2009), thus the desired condition for this 

analysis is that water temperatures be less than 21° C. This temperature is also consistent with 

that described by Moyle (1976; 2002) within the rainbow trout assemblage. 

Alternative 1 – No Action 

Alternative 1 is the No Action alternative. Under the No Action alternative, current management 

plans would continue to guide management of the Project area. This includes all ongoing 

activities with existing decisions or permits that would not be changed if this alternative were 

selected including: plantation maintenance under separate document, cattle grazing, recreation, 

and recreation residences. The No Action alternative would not implement the Fish Camp Project 

to reduce fire ladder conditions (thinning); pile slash for burning; burn slash piles; masticate 

and/and or precommercially thin stands; plant trees; reduce fuel loading through controlled 

burning; or reconstruct and maintain roads. No treatments would be implemented in any 

subwatershed as displayed in Table 18, while projected acres potentially affected MIS habitat or 

habitat for frogs and toads is displayed in Table 19. 

Table 18: Activities proposed under Alternative 1 HUC8 Subwatershed 501.5002 501.5004 501.5005 501.5006 

501.5007 501.5008 501.5053 501.5054 501.7052 

Total 

Commercial or precommercial thinning or 

tractor piling 0 0 0 0 0 0 0 0 0 0 

Mastication 0 0 0 0 0 0 0 0 0 0 

Underburn 0 0 0 0 0 0 0 0 0 0 

No Treatments 587 2436 2229 638 668 2261 1817 1480 2891 15007

Subwatershed Acres 587 2436 2229 638 668 2261 1817 1480 2891 15007
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 101 Chapter 3 – Affected Environment 

Table 19: Potential effects to habitat from Alternative 1 (acres are approximate) 

Direct Effects 

There would be no direct effects on threatened, endangered, or sensitive aquatic species or MIS 

habitat as a result of the implementation of Alternative 1 (No Action). No fuels ladder reduction 

or underburning would occur under this alternative. No direct effects to riparian canopy cover 

would be anticipated from Alternative 1. Water temperature would meet the desired condition, 

while canopy cover would be expected to remain near current levels through attrition at current 

and expected stocking levels. 

Indirect Effects 

There would be no anticipated indirect effects to special interest herpetofauna or MIS habitat as a 

result of the implementation of Alternative 1. Water temperature data collected from the Project 

area in 2008 indicates it currently meets the desired condition. However, Pilliod et al. (2003) 

suggest that no action may have consequences for amphibians due to overgrown forests changing 

the quality of amphibian habitat and increasing susceptibility for a high severity fire. Roads 

maintained by the U.S. Forest Service would continue to remain in poor condition and contribute 

sediment to aquatic systems. 

Cumulative Effects 

As no action is being taken by the SNF under the No Action Alternative by definition there would 

be no cumulative effects. See FEIS page 31 for more explanation. 

Summary of Effects 

Table 20 indicates that greatest potential effects to species habitat in the analysis area results from 

cattle grazing and the Sugar Pine Adaptive Management Project. As noted under occurrences in 

the species accounts, there are no known sites occupied by YT or MYLF within the aquatic 

analysis area. There would be no anticipated cumulative effects to aquatic MYLF or Yosemite 

YT as a result of the implementation of Alternative 1. Lacustrine/riverine and wet meadow 

habitats would be expected to remain stable. 

 Acres of habitat cumulatively affected under Alternative 1. (*lacustrine/riverine miles converted 

to acres assuming 10 ft wide stream) 

Species Potential 

Habitat 

(ac/mi) 

Potential 

Habitat in 

Treatment 

Area (ac) 

Sierra Nevada yellow-legged 

frog 

1020 ac 0 

Yosemite toad 8140 ac 0 

Lacustrine/riverine habitat 29 mi 0 

Wet Meadow 217 ac 0 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 102 Chapter 3 – Affected Environment 

Table 20: Acres of habitat cumulatively affected under Alternative 1. 

(*lacustrine/riverine miles converted to acres assuming 10 ft wide stream) 

Alternative 2 – Proposed Action 

The Proposed Action would reduce fire ladder conditions through removing understory and 

intermediate trees (thinning); pile slash for burning; burn slash piles; masticate and/and or 

precommercially thin stands; reduce fuel loading through controlled burning; and reconstruct 

roads. Table 21 summarizes gross acres from proposed activities (net treatment acres would be 

less due to implementation of SMZs; Controlled Areas; portions of treatment units lacking access 

or not requiring treatment). 

Table 21: Alternative 2 activities (acreages approximations generated by GIS). 

Acres represent gross area. 

Table 22 displays habitat potentially directly affected by the Proposed Action. There are 

approximately 21 acres of proposed treatment adjacent (within 100 feet), but not within wet 

meadows. Similarly, there are approximately 3 miles of proposed treatments along perennial 

Species 

Potentia

l habitat 

(ac) 

Grazing 

Primary 

Use (ac) 

Rec/OHV 

Effected 

(ac) 

Suga

r 

Pine 

(ac) 

Fish 

Camp 

(ac) 

Fire 

(ac) 

Roads 

(ac) 

Cum. 

Effect 

(ac) 

% 

Habitat 

Affected 

Sierra Neveda 

yellow-legged 

frog 

1020 141 27 7 0 0 10 186 18 

Yosemite toad 8140 1196 6 449 0 26 20 1700 21 

Lacustrine/riverin

e* 35 4 1 0 0 0 0.1 5 15 

Wet meadow 217 217 0 0 0 0 2 217 100 HUC8 Subwatershed 501.5002 501.5004 501.5005 501.5006 501.5007 501.5008 501.5053 501.5054 501.7052 

Total 

Commercial or precommercial thinning or tractor 

piling 134 331 280 0 1 0 52 81 85 964 

Mastication 0 0 36 5 0 0 0 0 0 41 

Underburn 32 55 0 0 0 0 0 0 104 192 

Subwatershed Acres 587 2436 2229 638 668 2261 1817 1480 2891 15007 

% Subwatershed treated 28% 16% 14% 1% 0% 0% 3% 5% 7% 8% 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 103 Chapter 3 – Affected Environment 

stream channels. It is expected that project design features would provide protection to both 

MIS habitat types. 

Table 22: Overlap of Proposed Treatment Areas and Potential Habitat for species. 

(*lacustrine/riverine miles converted to acres assuming 10 ft wide stream) 

Direct Effects 

There is overlap between proposed activities and potential effects on MYLF and YT. 

Approximately 40 acres of MYLF and 505 acres of YT habitat are within areas proposed for 

treatment under Alternative 2. Project design measures would be expected to protecting breeding 

and rearing sites from direct effects, thus sub-adult and adult life stages would potentially 

affected. Project design measures include the OFL corridors for Pacific fisher. These migration 

corridors extend 150 feet from both streambanks along the perennial streams within the Project 

area. There are no proposed treatments within the inner 50 feet from each streambank. The outer 

50 feet would implement hand treatments to remove the understory ladder fuels. No heavy 

equipment would be allowed within 100 feet of the streambank within these corridors. 

The potential for direct effects from crushing would be expected to be limited under the Proposed 

Action. The possibility of direct effects from crushing would be most likely during rainy periods 

when species may move beyond riparian areas. Operation of heavy equipment ceases during 

periods of prolonged precipitation to prevent compaction. Adult YT leave breeding meadows for 

foraging sites where they spend the majority of the summer, which makes them more susceptible 

to direct effects. 

Introduced fire could directly affect herpetofauna. Some species may use slash piles for cover or 

for estivation. The possibility of direct effects on individual animals from burning piles within the 

OFL corridors would be reduced by implementing the project design measure to light piles on 

one side to allow an escape from the pile. Underburning may also represent a direct effect to 

herpetofauna. Underburning is proposed adjacent to perennial streams in units RX 3, 4, 5, and 22, 

potentially affecting MYLF. Prescribed burning would be expected to occur during the spring or 

fall. During spring, amphibians may be moving to breeding sites or dispersing after breeding. 

During the fall, herpetofauna may be moving to overwintering sites or estivating within areas to 

be burned. Allowing fire to creep into the SMZ (as opposed to active introduction) would provide 

opportunity for herpetofauna to move away from areas burning, but not eliminate the possibility 

of mortality. 

Direct effects to listed herpetofauna would not be anticipated from implementing the Proposed 

Action due to Project Design Measures; non-detection of listed species during surveys; and 

nearest known occupied sites are not within species dispersal distance of project treatment areas. 

The nearest known occupied YT site is more than 1.5 miles from the nearest proposed treatment 

unit, while the nearest known MYLF population is 1.3 miles from the nearest treatment unit. 

Indirect Effects 

Alternative 2 has a risk of compacting soil (tractor thinning, mastication, and machine piling of 

slash), which could result in both short and long-term sediment delivery to riparian and aquatic 

Species Potential 

Habitat 

(ac) 

Habitat 

thinned (ac) 

Habitat 

masticated 

(ac) 

Habitat 

underburned 

(ac) 

Total ac. 

Habitat 

Treated 

Sierra Nevada yellow-legged frog 1020 12 0 27 39 

Yosemite toad 8140 452 41 12 505 

Lacustrine/riverine* 35 0 0 0 0 

Wet Meadow 217 0 0 0 0 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 104 Chapter 3 – Affected Environment 

habitats. Reduction in stand densities could affect canopy cover (indirectly affecting microclimate and water temperatures), availability of LWD; macroinvertebrate community, and 

changes to water yield (indirectly affecting stream channel stability). Most of the potential 

indirect effects to herpetofauna would be related to habitat alteration. Thinnings are proposed 

within the red fir and Sierra mixed-conifer CWHR types. The primary changes may reduce size 

groups and reduce density for a 20-30 year period. CWHR habitat quality would remain 

unchanged for both species based on projected stands following thinning. Changes to 

microclimate (such as increased air temperatures, reduced soil moisture, and lower relative 

humidity) within treated areas may not be accounted for at the CWHR scale. 

Compaction has the potential to increase erosion through overland flow; alteration to flow 

regime; and alteration of stream channel equilibrium. Increased sediment could decrease 

available pool habitat for herpetofauna. According to Reid (2006), the impacts of mechanical 

treatments on erosion and sediment yield are likely to result from direct soil disturbance where 

these activities affect swales and low-order stream channels. In this project, swales and Class V 

channels have no SMZs – mechanized access is not prohibited and could occur. Class IV 

channels have a 25-foot SMZ where equipment is excluded. Implementation of Best Management 

Practices (BMP) 1-19 mitigate the potential effects and include requiring that stream crossings on 

Class IV and V streams be agreed to by the sale administrator. Unscoured swales that are dry 

during operations receive no special protection. Activities that will be accomplished by hand, 

such as felling and leaving trees, hand piling, and planting, are assumed to have no effect on 

hydrology or water quality (Robichaud et al. 2006). Roads maintenance and reconstruction would 

reduce hydrologic connectivity and reduce sediment from that existing source. 

Stream Shading: Naiman et al. (2000) note that riparian forests strongly influence stream 

microclimate; including air, soil, and surface temperatures; relative humidity; and solar radiation. 

Streamside shading affects the amount of solar radiation that filters to the surface of the water, 

and Matlack (1993) indicates that aspect also exerts influence on microclimate. Cushman (2006) 

identifies the importance in habitat connectivity for amphibian dispersal, suggesting juvenile 

dispersal as a possible limiting factor. Water temperature affects various life activities, such as 

breeding and rearing time for amphibians. If forest harvesting were to occur in streamside areas 

there could be an increase in solar radiation to the stream channel, affecting water temperature 

however project design criteria prevent streamside harvesting. 

Perennial stream channels are included under the OFL (Riparian Migration Corridor). These 

corridors extend 150 feet from both streambanks along the perennial streams within the Project 

area. There are no proposed treatments within the inner 50 feet from each streambank. The outer 

50 feet would implement hand treatments to remove the understory ladder fuels. No alteration of 

the existing stream shading is anticipated from the Proposed Action. There would be no indirect 

effects on water temperature anticipated from the Proposed Action. Changes to microclimate 

beyond the riparian corridors may affect habitat and dispersal of herpetofauna through changes to 

air temperature, wind speed, and relative humidity. 

Additionally aquatic invertebrates serve as food source for various lifestages of herpetofauna. 

Kattelmann (1996) notes several studies have demonstrated that communities of aquatic 

invertebrates changed significantly in response to upstream logging, with some of these effects 

persisting for two decades. Much of the food base for stream ecosystems is derived from adjacent 

terrestrial ecosystems with litter fall from deciduous stands exceeding that of coniferous stands. 

Deciduous input (leaves) generally breaks down in less than half the time necessary for the 

breakdown of coniferous input (needles; Gregory et al. 1991). Buffer strips 30 meters (98.4 feet) 

wide are noted as protecting invertebrate communities from logging induced changes (Gregory et 

al. 1987; EPA 1991). 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 105 Chapter 3 – Affected Environment 

Dwire et al. (2006) suggest that prescribed fire may top-kill some riparian trees and shrubs. A 

study at Blodgett Forest in northern California introduced prescribed fire into the riparian zone 

and found that a 4.4% mortality rate resulted, occurring in trees 11 – 40 centimeters (4.5 - 15.7 

inches) dbh (Bêche et al. 2005). Prescribed fire is not proposed for introduction into the perennial 

SMZs for this project, but it would be allowed to creep within the SMZ. Pilliod et al. (2003) 

suggest that prescribed burning could benefit amphibians by reducing forest canopy cover and 

providing breeding habitat, if reduced transpiration increased baseflow. However, habitat could 

be negatively affected if sediment was increased as a result of the burning. 

Water temperature: Elevation, aspect, stream width, channel roughness coefficient, riparian 

shading, solar radiation, air temperature, cloud cover, and stream discharge levels can affect 

water temperature. Of these elements, solar radiation has the most effect on water temperature 

(Beschta 1987; USGS 1997, 2002). Shading effects from forest canopies are important during the 

summer months due to high levels of radiation (high sun angles, long days, clear skies) 

accompanied by low stream discharges (Beschta et al. 1987). Solar radiation through forest 

canopies depends on the heights of the crowns and density, along with the foliage (Moore et al. 

2005). If forest harvesting occurred in streamside areas there could be a direct increase solar 

radiation (reduction in canopy cover) to the stream channel. However, in evaluating possible 

project direct effects to canopy cover it was noted that changes in overhead canopy from stands 

adjacent to perennial streams would not be anticipated. There would no harvesting under any 

prescription within the inner 50-feet of the Class I SMZ. In the outer 50-feet of treated SMZs 

there is a possible increase of open space within the understory and intermediate components of 

the treated stand. This provides an opportunity for increased angular solar radiation. It is 

anticipated that the majority of the trees would be retained and the inner 50-foot No-Treatment 

zone would intercept angular solar radiation and there would be no change to water temperatures. 

Wilkerson et al. (2006) found that a 23 m (75 feet) buffer resulted in no change to water 

temperature. 

Of the remaining elements that may affect water temperature, only stream discharge level could 

be affected by the proposal. Changes to stream discharge would be an indirect effect from the 

proposal due to decreases as basal area (and evapo-transpiration) declines due to changes in stand 

density (Chamberlin et al. 1991; Kattelmann 1996). If more water were available as baseflow 

during the late summer, there would be a possible reduction in stream temperature. Potential 

increases in peak flows are related to changes in snow accumulation and snow melt. In the Rocky 

Mountains, any reduction in stand density will increase snowpack accumulation. This would 

apply mostly to the snow-dominated Fish Camp Project area. Troendle et al. (2006) state that the 

potential for thinning to have an effect on streamflow due to reduced evapotranspiration depends 

on the amount of precipitation. In wet summers, there may be surplus water to contribute to 

increased stream flow, while in dry years; it is likely that the residual stand will use all of the 

available water. In snow-dominated areas such as Fish Camp, nearly all of the change in flows 

would occur during spring runoff, and spring runoff may occur slightly sooner if reductions in 

canopy allow faster melting of the snowpack. 

Late summer, when solar radiation potential is greatest, air temperatures are warmest, and stream 

flows are lowest, is the period when canopy cover is essential in moderating water temperatures. 

Typically only perennial channels flow during this period, thus concerns over water temperature 

focus on these stream channels. Forest thinning projects have the potential to affect water 

quantity through changes in interception of precipitation, changes in snow accumulation and 

snowmelt (important in snow-dominated areas but less so in rain-dominated and ‘warm snow’ 

zones such as the Project area), and changes in available soil moisture due to decreased 

evapotranspiration. The Project Hydrology Report (Stone 2010) notes that any changes in flow 

resulting from thinning would be unlikely to persist beyond 10 years. 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 106 Chapter 3 – Affected Environment 

Figure 2 displays daily mean water temperature collected across the analysis area. As measured 

during the summer of 2008, daily mean water temperatures in the analysis area were less than 21

C (Desired Condition). The period monitored represents that of highest air temperatures and 

lowest stream flow, thus most stressful on aquatic/riparian species. There would be no anticipated 

alterations to canopy cover or flow, thus there would be no effects on water temperature expected 

from the Proposed Action. 

Cumulative Effects 

Known activities occurring spatially and temporally within the analysis area are recreational use 

(both developed and undeveloped), vegetation and fuels projects, existing roads, cattle grazing, 

fish stocking, and fires. Table 20 summarizes overlap of potential habitat by other Actions. 

Habitat may also be altered by climate change, fire, and the alteration of the fire return interval. 

Recreation: There are approximately 6.5 miles of inventoried Off-Highway Vehicle (OHV) routes 

within the analysis area, some which cross habitat for Forest Service sensitive herpetofauna. Slow 

moving species (such as reptiles and amphibians) are more susceptible to vehicle mortality 

because their life histories often involve migration between wetland and upland habitats 

(Trombulak and Frissell 2000). The SNF has completed a Travel Management Plan (USDA – 

Forest Service 2010a) that would eliminate cross-country travel by OHVs, designate routes 

approved for OHV use, and establish a season of use. Approved routes require improvements to 

protect resources. This analysis considers the currently inventoried routes (6 miles) within the 

analysis area, although no routes (0 miles) were approved under the Record of Decision for the 

Travel Management Plan. 

Within the project analysis area there are 3 developed campgrounds and day use sites, and several 

other developed sites (snowplay, trailheads, etc). These facilities total approximately 80 acres. 

Some of the campgrounds and day use areas are located adjacent to water, thus are within habitat 

for amphibians (approximately 30 acres). Amphibians and reptile species adjacent to 

campgrounds may be subject to handling; collection; consumption; or translocation (Maxwell and 

Hokit 1999). Handling may harm animals or in some instances handlers. Increased mortality rates 

may result from pets accompanying recreationists, along with mortality associated with use areas 

from pets or predators (ravens, skunks, raccoons, coyotes or foxes) that may occur at greater 

frequency at these sites due to refuse. Ravens are noted as natural predators for a variety of 

herpetofauna (Kagrise-Sherman and Morton 1993; Jennings and Hayes 1994; Ashton et al. 1997; 

Maxell and Hokit 1999; and Boatman 2002). Ashton et al. (1997) note that areas of human 

influence can drive out larger predators. Thus, the numbers of small predators (such as ravens) 

may be supported at artificially high numbers near areas of increased human activities. Boatman 

(2002) identifies that increased forage opportunities for raven may be associated with road 

mortality and landfills. Rainbow trout are stocked by the California Department of Fish and 

Game at several sites along Big Creek. 

Vegetation and Fuels Projects: Approximately 670 acres of the Sugar Pine Adaptive Management 

Project are within the analysis area. The project overlaps approximately 450 acres of YT and 7 

acres of MYLF habitat. Activities within habitat could include felling, bucking (cutting into logs), 

skidding to the road, and piling of slash. Amphibians could be subject to direct effects from 

crushing related to felling of trees, or when skidding logs to the road. Skidding can also reduce 

ground cover, increase site compaction, and result in off-site erosion. Project design criteria, 

Forest S&G and Best Management Practices have been provided to reduce potential effects to 

species and habitat. 

 

Use of heavy machinery can result in compaction and potentially stream channel disturbance. 

Application of SMZs and implementation of Best Management Practices reduces the risk of 

compaction, or project-associated erosion being transported to stream channels. 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 107 Chapter 3 – Affected Environment 

Roads: The existing National Forest Transportation System (approximately 63 miles in the 

analysis area) could result in mortality to aquatic/riparian species in a variety of ways including 

collisions. Roads overlaps approximately 20 acres of YT and 10 acres of MYLF habitat. Slow 

moving species (such as reptiles and amphibians) are more susceptible to road mortality because 

their life histories often involve migration between wetland and upland habitats (Trombulak and 

Frissell 2000). Literature suggests that highest road-kill rates are near wetlands and that 

amphibians represent the largest percent of species. Some frogs and toads disperse at night due to 

lower temperatures and increased relative humidity. 

Cattle grazing: The aquatic analysis area includes portions of the Soquel and Iron Creek 

allotments. Cattle grazing also occurs on private property within the two allotments. There are 

approximately 1,520 acres of Primary Use within the analysis area, which represents available 

forage overlaps with YT and Pacific tree frog breeding habitat. Primary Use Areas were defined 

as meadows buffered by 250 feet. 

Numerous effects on aquatic habitat and species have been attributed to prolonged use of riparian 

areas by cattle. Literature suggests potential effects from cattle grazing relating to channel 

function, water quantity, hydrologic alteration, and water quality. Cattle grazing has been 

identified as altering channel function, which reduces natural processes, habitat diversity and 

habitat complexity for aquatic or riparian animals (Elmore and Beschta 1987; Clary and Webster 

1989; EPA 1991; Meehan et. al. 1991; Belsky et. al. 1999). Movement of cattle within riparian 

zones can lead to reductions in stream shading, compaction of stream banks, and trampling of 

stream banks (Meehan et. al. 1991; Armour et. al. 1994). All of these factors could result in 

negative effects to habitat for herpetofauna. However, quantifying effects related to continued 

cattle grazing and recovery from past effects has proved difficult to evaluate due to absence of 

reference sites that have never been grazed by livestock (Kattelmannn 1996). Some of the effects 

described in literature are noted as resulting from “heavy” or “overgrazing”. 

Cattle grazing is administered under U.S. Forest Service permits, which include compliance with 

S&G from the SNF-LRMP (USDA – Forest Service 1992; 2001; 2004). It is expected that cattle 

grazing is locally resulting in exposed streambanks and erosion at some sites. 

Climate Change: Climate change has been suggested as a contributing agent in the decline of 

amphibians (Pounds and Crump 1994; Steward 1995; Pounds et al. 1999). The Species Survival 

Commission (2008) notes that over 50% of the amphibians may be potentially susceptible to 

climate change. Reaser and Blaustein (in Lannoo 2005) summarize that site specific review of 

amphibian declines indicate possible global changes, and that regional warming, increasing 

ultraviolet radiation, and diseases are a potential result of global change. California anticipates 

warmer temperatures, accompanied by altered patterns of precipitation and runoff related to 

climate change (DWR 2007). Annual runoff in the San Joaquin River basin has declined by 19% 

over the past 100 years, and projected precipitation alterations could reduce the snowpack by 

25% by the year 2050. 

It is expected that air temperatures and precipitation patterns may change within the aquatic 

analysis area over time. The Fish Camp Project is within an elevational zone characterized as 

having warm/hot summers (varies by elevation) and cool winters. Most precipitation above 5500 

feet falls in the form of snow from fall through spring. Change is expected to be reflected through 

an increase in daily maximum, minimums, and mean air temperatures, along with altered rainfall 

patterns. In a review of weather station data for sites within or adjacent to the SNF, Meyer and 

Safford (2010) note that mean annual temperature at Huntington Lake has increased by 1.8o F, 

with a mean minimum (nighttime) increase of 4o F since 1915. Information from Meyer and 

Safford (ibid) project an increase in annual precipitation of 2.1 inches at Huntington Lake over 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 108 Chapter 3 – Affected Environment 

the 10-year period, but the projections at Grant Grove in Kings Canyon National Park project no 

change. 

The Big Creek drainage in the Project area is influenced by snowmelt runoff. Spring runoff is 

occurring earlier in the year and fraction of runoff occurring in the spring is decreasing. With less 

snowfall expected to result from elevated air temperatures associated with climate change, it is 

likely that less water would be available during the late summer and that the water would be 

warmer than current conditions. An increasing snow level would reduce the amount of shallow 

pools during the springs which provide breeding habitat for YT and Pacific tree frog. A similar 

effect to shallow lakes would reduce the suitability of habitat for MYLF. The changing conditions 

of habitat would provide conditions more favorable for invasion by species currently occurring at 

lower elevational sites. 

Alteration of the fire return interval: The USFWS (2003) identified that “Fire suppression, and 

changes in fire frequency and hydrology, has probably contributed to the decline of Yosemite 

toads through habitat loss caused by conifer encroachment on meadows. Under natural 

conditions, conifers are excluded from meadows by fire and soils too saturated for their survival. 

But as conifers begin to encroach on a meadow, if they are not occasionally set back by fire, they 

transpire water out of the meadow, reducing the saturation of the soils, and facilitating further 

conifer encroachment. Therefore, some vegetation treatment may be needed to maintain or 

restore YThabitat.” 

 

In the event of a wildfire there could be varied response depending on size and severity. A large, 

high severity fire could disrupt flow regime and alter stream channel dynamics. Soil water 

storage; baseflow; streamflow regime; peak flow; water quality (sediment, temperature, pH, ash 

slurry); and chemical characteristics can be affected by wildfire (Neary et al. 2005). If a wildfire 

followed by a large precipitation event occurred, accelerated erosion and increased sedimentation 

will occur and sediment will be transported to the stream system via overland flow from burnt 

slopes and roads. Accumulations of sediment could reduce habitat for BMI. Vieira et al. (2004) 

also reported that a 100-year flood following the Dome wildfire (New Mexico) resulted in an 

almost total loss in density and taxon richness. 

Meyer and Safford’s (2010) review of fire literature indicates increases in fire frequency, size, 

total area burned and severity in the Sierra Nevada over the past 20-30 years. Since 2002 (year of 

Vegetation Typing), there has been not been any fire within the analysis area. There is an overlap 

of approximately 26 acres within potential habitat for YT, and 0 acres of potential habitat for 

MYLF that burned in 1990. Habitat has recovered since the fires. In an analysis of occupied YT 

sites on the Sierra NF, Liang et al. (2010) note that YT were less likely to occur in areas where 

the fire regime was significantly altered. 

CWE Analysis: The Cumulative Watershed Effects Analysis (CWEA) prepared for this project 

(Gallegos 2010) includes consideration of actions on private lands in addition to Forest Service 

permitted actions. The baseline or existing condition of most of the subwatersheds is below the 

Lower Threshold of Concern (TOC)%, but subwatersheds 501.5006, 501.5007, 501.5053 are over 

their Lower TOC%. No adjustment to TOC would result from Alternative 1. The Project 

Hydrology report (Stone 2010) notes that, “Essentially the only watershed considered to be 

at or near CWE prior to field investigations is a segment of 501.5005. Specifically, 

subwatershed 501.5005 has a sub-basin where CWE response is occurring, which 

includes Long Meadow.” 

Cumulative Watershed Effects: The Project CWE Report (Gallegos 2010) notes that there is a 

low potential that a CWE would occur from proposed treatments in subwatersheds 501.5005 and 

501.5006. Evidence of existing CWE in the Long Meadow Creek portion of subwatershed 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 109 Chapter 3 – Affected Environment 

501.5005 and planned mechanical treatments in the SMZ of Long Meadow make this 

subwatershed vulnerable to CWE. Planned treatments from the Sugar Pine Project in 

subwatershed 501.5006 will result in ERA approaching the upper TOC for CWE and make this 

subwatershed vulnerable to CWE. 

Stream Shading: Current and foreseeable actions and Alternative 2 would include SMZs 

(including private land operating under Timber Harvest Plans). It is expected that riparian canopy 

cover would be maintained at current levels as described under Indirect Effects. 

Water Temperature: Changes to flow would be similar to those described under Indirect Effects. 

Riparian canopy cover would be anticipated to remain at current levels based on use of Class I 

SMZs (minimum 100 ft) that include no action within the inner 50 ft, thus a cumulative effect to 

water temperature through implementation of Alternative 2 would not be anticipated. 

Summary of Effects 

Table 23 summarizes overlap of potential habitat by other Actions and the Fish Camp Project. 

Most of the Forest Service actions over the past decade, along with those proposed in the next 

decade, relate to cattle grazing, fuels reduction or forest thinning. These actions have BMP 

(USDA – Forest Service 1983, 2002), along with Forest standards and guidelines to restrict offsite erosion and activities within SMZ. BMPs have also been developed to reduce effects from 

livestock grazing and movement of cattle through riparian zones. Literature has shown BMPs to 

be effective in minimizing the erosion in treatment areas and at preventing sediment from 

reaching streams. In a study of sediment redistribution after harvesting, Wallbrink and Croke 

(2002) found that sediment derived from skid trails was deposited both within the treated area and 

the stream buffers (23-30 m). BMPs are expected to protect stream channels from sediment for 

treatments areas near streams. Monitoring of BMP on Forest Service lands in California has 

shown that, when implemented, timber management BMP are 95-98% effective (USDA- Forest 

Service 2004a) at protecting stream channels. 

Table 23: Acres of habitat cumulatively affected under Alternative 2. 

(*lacustrine/riverine miles converted to acres assuming 10 ft wide stream) 

It is not expected that the Fish Camp Project (Alternative 2), in addition to other activities in the 

Project area subwatersheds, would contribute to cumulative effects to MYLF or Yosemite toad, 

nor to lacustrine/riverine or wet meadow habitats. 

Alternative 3 (Lower and Limited Mid-Level Canopy Treatments, All 

Treatment Areas 

In Alternative 3, treatment areas would remain the same as in Alternative 2, treatments within 

these areas would include only those needed to reduce the surface and ladder fuels (within the 

lower and limited mid-level canopy levels) needed to achieve fire and fuels objectives. Under 

Species 

Potential 

habitat 

(ac) 

Grazing 

Primary 

Use (ac) 

Rec/OHV 

Effected 

(ac) 

Sugar 

Pine 

(ac) 

Fish 

Camp 

(ac) 

 Fire 

(ac) 

Roads 

(ac) 

Cum. 

Effect 

(ac) 

% 

Habitat 

Affected 

Sierra Nevada 

yellow-legged frog 

1020 141 27 7 39 0 10 224 22 

Yosemite toad 8140 1196 6 449 505 26 20 2205 27 

Lacustrine/riverine* 35 4 1 0 0 0 0.1 5 14 

Wet meadow 217 217 0 0 0 0 2 217 100 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 110 Chapter 3 – Affected Environment 

Alternative 3 there would be no additional treatments (i.e. additional thinning in the mid-level 

canopy) to fully address stand density and forest health objectives. 

This alternative would receive treatment only to achieve fire and fuels objectives and limit 

treatments to mechanical clearing of ladder and surface fuels. As such, all design criteria and 

SNFPA ROD (USDA- Forest Service 2004) standards and guidelines associated with Pacific 

Fisher would be implemented with this alternative. Of the 5700 total acres within the Project 

boundary, approximately 1200 acres were analyzed as areas where some form(s) of treatment are 

proposed (so named as treatment areas). The remaining 4500 acres have no treatments proposed 

due to slopes greater than 35 percent, standard and guideline limitations on treatment and/or no 

treatment is needed to meet the purpose and need. Table 21 for Alternative 2 would also represent 

treatments by subwatershed. Table 22 from Alternative 2 also represent overlap of treatments and 

species habitat for Alternative 3. 

Direct Effects 

Similar to Alternative 2 there is an overlap between proposed activities and potential effects on 

MYLF and YT. Potential direct effects could occur from crushing of individual animals by tractor 

thinning, tractor piling, or mastication, or from burning of animals. 

Introduced fire could directly affect herpetofauna similar to Alternative 2. Allowing fire to creep 

into the SMZ (as opposed to active introduction) would provide opportunity for herpetofauna to 

move away from areas burning, but not eliminate the possibility of mortality. 

Similar to Alternative 2, it would be expected that direct effects to herpetofauna or habitat from 

Alternative 3 would be limited due to project design measures; non-detection of listed species 

during surveys; and nearest known occupied sites are not within species dispersal distance of 

project treatment areas. Buffers along wet meadows and perennial streams are anticipated to 

provide protection from direct and indirect effects. Any increases in soil moisture would be 

expected to be utilized by the remaining vegetation, so it would not likely be available for stream 

flow. No changes to direct or indirect effects on meadow hydrology are anticipated as a result of 

implementing Alternative 2. 

Indirect Effects 

Thinning to reduce ladder fuels, mastication, and underburning would occur on over the same 

acreage analyzed under Alternative 2. Table 22 in Alternative 2 identifies that treatment areas 

represent approximately 40 acres of Sierra Nevada yellow-legged frog; and 505 acres of BUCA 

habitat. Alternative 3 has a risk of compacting soil (tractor thinning, mastication, new road 

construction, and machine piling or slash), which could result in both short and long-term 

sediment delivery to riparian and aquatic habitats. Implementation of Best Management Practices 

(USDA – Forest Service 1983; 2002); streamside management zones; and project design criteria 

are expected to reduce the potential for sedimentation and protect aquatic habitat (Stone 2010). 

As noted under Alternative 2, reduction in stand densities could affect canopy cover (indirectly 

affecting micro-climate and water temperatures), availability of LWD; macroinvertebrate 

community, and changes to water yield (indirectly affecting stream channel stability). Most of the 

indirect effects to herpetofauna would be related to habitat alteration. Thinnings are proposed 

within the red fir and Sierra mixed-conifer CWHR types. The primary changes may reduce size 

groups and reduce density for a 20-30 year period. CWHR habitat quality would remain 

unchanged for both species based on projected stands following thinning. Changes to 

microclimate (such as increased air temperatures, reduced soil moisture, and lower relative 

humidity) within treated areas may not be accounted for at the CWHR scale, but the reduction in 

mid-canopy tree removal under Alternative 3 may represent reduced effects to microclimate. 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 111 Chapter 3 – Affected Environment 

Stream Shading: Similar to Alternative 2, there would be no alteration to current stream shading. 

 

Water temperature: Similar to Alternative 2, there would be no anticipated alterations to canopy 

cover, thus there would be no direct effects on water temperature expected from Alternative 3. 

Cumulative Effects 

Past, present, and reasonably foreseeable actions within the Project areas would be as displayed 

under Alternative 2. Acres of habitat potentially affected would be similar to Table 23 under 

Alternative 2. Effects to Stream Shading, Water Temperature and CWE would be similar to 

Alternative 2. 

Summary of Effects 

Table 23 under Alternative 2 summarizes overlap of potential habitat by other Actions and Fish 

Camp. Most of the Forest Service actions over the past decade, along with those proposed in the 

next decade, relate to cattle grazing, fuels reduction or forest thinning. These actions have Best 

Management Practices (USDA – Forest Service 1983,2002), along with Forest standards and 

guidelines to restrict off-site erosion and activities within Streamside Management Zones. BMPs 

have also been developed to reduce effects from livestock grazing and movement of cattle 

through riparian zones. Literature has shown BMPs to be effective in minimizing the erosion in 

treatment areas and at preventing sediment from reaching streams. In a study of sediment 

redistribution after harvesting, Wallbrink and Croke (2002) found that sediment derived from 

skid trails was deposited both within the treated area and the stream buffers (23-30 m). BMPs are 

expected to protect stream channels from sediment for treatments areas near streams. Monitoring 

of BMP on Forest Service lands in California has shown that, when implemented, timber 

It is not expected that Alternative 3, in addition to other activities in the Project area 

subwatersheds, would contribute to cumulative effects MYLF frog or YT, nor to 

lacustrine/riverine or wet meadow habitats. 

Other Relevant Mandatory Disclosures 

Tables 24 and 25 display determination of effects on threatened, endangered, and sensitive 

herpetofauna based on known information on species, habitat available, literature review, and 

anticipated effects. Lacustrine/riverine and wet meadow habitats would be anticipated to remain 

stable under any of the alternatives. 

Table 24: Effects from Alternative 1 on aquatic threatened, endangered, and 

sensitive species. 

Species Determination Rationale for the Determinations for Proposed Action 

MYLF No effect No anticipated impacts to species or habitat 

YT No effect No anticipated impacts to species or habitat 

 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 112 Chapter 3 – Affected Environment 

Table 25: Effects from Alternatives 2 and 3 on aquatic threatened, endangered, and 

sensitive species. 

Species Determination Rationale for the Determinations for Proposed Action 

MYLF 

May affect individuals, 

but is not likely to lead 

to federal listing or loss 

of viability. 

 Not detected within the Project area during surveys 

 Proposed treatments not anticipated to reduce quality of 

CWHR habitat. 

 Nearest known occupied site is 1.3 miles from any treatment 

area, which is beyond dispersal range of species. 

YT 

May affect individuals, 

but is not likely to lead 

to federal listing or loss 

of viability. 

 Species was not located during Forest-wide surveys between 

2002-2004, or during project surveys. 

 No occupied meadows are occupied within Project area 

subwatersheds 

 Nearest occupied meadows are beyond (> 1.5 miles) CWHR 

dispersal distance of species (0.6 mi) from any proposed 

treatment unit. 

 Proposed treatments not anticipated to reduce quality of 

CWHR habitat. 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 113 Chapter 3 – Affected Environment 

Terrestrial Management Indicator Species ___ 

The purpose of the terrestrial MIS report is to evaluate and disclose the impacts of the Fish Camp 

Project on the habitat of terrestrial Management Indicator Species (MIS) identified in the SNF 

LRMP (USDA-FS 1992) as amended by the Sierra Nevada Forests Management Indicator 

Species Amendment (SNF MIS Amendment) Record of Decision (USDA-FS 2007a). The MIS 

report documents the effects of the Proposed Action and alternatives on the habitat of selected 

project-level MIS. The direct, indirect and cumulative effects to the terrestrial management 

indicator species are summarized from the Terrestrial Management Indicator Species Report for 

the Fish Camp Project (Otto 2010). 

MIS are animal species identified in the SNF MIS Amendment Record of Decision (ROD) signed 

December 14, 2007, which was developed under the 1982 National Forest System Land and 

Resource Management Planning Rule (1982 Planning Rule) (36 CFR 219). The current rule 

applicable to project decisions is the 2004 Interpretive Rule, which states “Projects implementing 

land management plans...must be developed considering the best available science in accordance 

with §219.36(a)...and must be consistent with the provisions of the governing plan.” (Appendix 

B to §219.35). Guidance regarding MIS set forth in the Sierra NF LRMP (USDA-FS 1992) as 

amended by the 2007 SNF MIS Amendment ROD directs Forest Service resource managers to 

(1) at project scale, analyze the effects of proposed projects on the habitat of each MIS affected 

by such projects, and (2) at the bioregional scale, monitor populations and/or habitat trends of 

MIS, as identified in the Sierra NF LRMP (USDA-FS 1992) as amended. 

Affected Environment 

MIS Habitat Status and Trend 

All habitat monitoring data are collected and/or compiled at the bioregional scale, consistent with 

the SNF LRMP (USDA-FS 1992) as amended by the 2007 Sierra NF MIS Amendment ROD 

(USDA Forest Service 2007a). 

Habitats are the vegetation types (for example, early seral coniferous forest) or ecosystem 

components (for example, snags in green forest) required by an MIS for breeding, cover, and/or 

feeding. MIS for the Sierra Nevada National Forests represent 10 major habitats and 2 ecosystem 

components (USDA-FS 2007a and project record). These habitats are defined using the 

California Wildlife Habitat Relationship (CWHR) System (CDFG 2005). The CWHR System 

provides the most widely used habitat relationship models for California’s terrestrial vertebrate 

species (ibid). Tables explaining the acronyms used for available habitat stages in the CWHR 

system is described in detail in the Sierra NF Bioregional MIS Report (USDA-FS 2008). 

Habitat status is the current amount of habitat on the Sierra Nevada Forests. Habitat trend is the 

direction of change in the amount or quality of habitat over time. The methodology for assessing 

habitat status and trend is described in detail in the Sierra NF Bioregional MIS Report (USDA-FS 

2008). 

MIS Population Status and Trend 

All population monitoring data are collected and/or compiled at the bioregional scale, consistent 

with the LRMP as amended by the 2007 Sierra NF MIS Amendment ROD (USDA-FS 2007a). 

The information is presented in detail in the 2008 Sierra NF Bioregional MIS Report (USDA-FS 

2008). 

Population monitoring strategies for MIS of the Sierra NF are identified in the 2007 Sierra 

Nevada Forests Management Indicator Species (SNF MIS) Amendment ROD (USDA-FS 2007a). 

Population status is the current condition of the MIS related to the population monitoring data 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 114 Chapter 3 – Affected Environment 

required in the 2007 SNF MIS Amendment ROD for that MIS. Population trend is the direction 

of change in that population measure over time. 

There are a myriad of approaches for monitoring populations of MIS, from simply detecting 

presence to detailed tracking of population structure (USDA-FS 2001, Appendix E, page E-19). A 

distribution population monitoring approach is identified for all of the terrestrial MIS in the 2007 

SNF MIS Amendment, except for the greater sage-grouse (USDA-FS 2007a). Distribution 

population monitoring consists of collecting presence data for the MIS across a number of sample 

locations over time. Presence data are collected using a number of direct and indirect methods, 

such as surveys (population surveys), bird point counts, tracking number of hunter kills, counts of 

species sign (such as deer pellets), and so forth. The specifics regarding how these presence data 

are assessed to track changes in distribution over time vary by species and the type of presence 

data collected, as described in the Sierra NF Bioregional MIS Report (USDA-FS 2008). 

Methodology for Analysis 

Project-level effects on MIS habitat are analyzed and disclosed as part of environmental analysis 

under the National Environmental Policy Act (NEPA). This involves examining the impacts of 

the proposed project alternatives on MIS habitat by discussing how direct, indirect, and 

cumulative effects will change the habitat in the analysis area. 

These project-level impacts to habitat are then related to broader scale (bioregional) population 

and/or habitat trends. The appropriate approach for relating project-level impacts to broader scale 

trends depends on the type of monitoring identified for MIS in the LRMP as amended by the SNF 

MIS Amendment ROD. Hence, where the Sierra NF LRMP as amended by the SNF MIS 

Amendment ROD identifies distribution population monitoring for an MIS, the project-level 

habitat effects analysis for that MIS is informed by available distribution population monitoring 

data, which are gathered at the bioregional scale. The bioregional scale monitoring identified in 

the Sierra NF LRMP, as amended, for MIS analyzed for the Fish Camp Project is summarized in 

Section 3 of the Terrestrial MIS report. 

Adequately analyzing project effects to MIS generally involves the following steps: 

 Identifying which habitat and associated MIS would be either directly or indirectly 

affected by the project alternatives; these MIS are potentially affected by the project. 

 Summarizing the bioregional-level monitoring identified in the LRMP, as amended, for 

this subset of MIS. 

 Analyzing project-level effects on MIS habitat for this subset of MIS. 

 Discussing bioregional scale habitat and/or population trends for this subset of MIS. 

 Relating project-level impacts on MIS habitat to habitat and/or population trends at the 

bioregional scale for this subset of MIS. 

These steps are described in detail in the Pacific Southwest Region draft document “MIS 

Analysis and Documentation in Project-Level NEPA, R5 Environmental Coordination” (May 25, 

2006). This Management Indicator Species (MIS) Report documents application of the above 

steps to select project-level MIS and analyze project effects on MIS habitat for the Fish Camp 

Project. 

Mitigation and Monitoring 

Special project design measures for the Fish Camp Project were developed in concert with the 

BLRD interdisciplinary team, PSW Research scientists, and concerned public participation 

groups. These design measures would be implemented under either of the two action alternatives. 

Within this Project area special considerations have been given to maintaining higher levels of 

biodiversity through actions such as delineating Old Forest Linkages (OFLs) surrounding 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 115 Chapter 3 – Affected Environment 

perennial streams (see Terrestrial Wildlife BE/BA Otto 2010 for a description of OFLs). Higher 

levels of biodiversity have also been planned for by marking retention groups of large diameter 

trees. 473 such tree groups were identified in the Fish Camp Project area. Ideally, when available 

on the landscape these groups also contain “defect” trees: those that have cavity and platform 

creating defects such as mistletoe, rot, forked tops, broken limbs, and broken tops. No trees 

greater than 20” dbh would be cut within these groups. These large tree groups would have a 

residual basal area of 240 ft2

 or more for mixed conifer and 210 ft2 or more for pine and in many 

instances may reach 300 to 400 ft2

 per acre. 

Another project design measure which would maintain biodiversity is the identification of 

retention areas around large oaks within treatment units. Two to three large oaks per acre were 

identified and marked with paint. These oaks would retain a zone of no activity around them 

measuring 35 feet, or dripline circumference around the oak (whichever is greater). The 

delineation of OFLs, retention of large tree groups, and oak no treatment zones would ensure a 

heterogeneous post treatment landscape resulting in the continued accessibility of both hiding 

cover and prey availability within these areas of biodiversity (USDA-FS 2010). 

The project is designed to improve habitat conditions through the acceleration of latesuccessional habitat characteristics, while still maintaining current functional habitat. Specific 

project design criteria include: canopy cover would be maintained at 50 to 60% or greater where 

available; ground disturbance would be limited to those guidelines with the LRMP as amended; 

vegetation species diversity and composition would be maintained; management activities would 

be limited in designated riparian management areas; and retention of snags and downed logs 

would be retained at levels defined in the Design Criteria Common to All Action Alternatives. 

All riparian management areas within the project have been identified and buffers established. In 

addition, no operations would occur during the wet weather season. (USDA-FS 2010) 

Table 26: Selection of MIS for Project-Level Habitat Analysis for the Fish Camp 

Project. 

Habitat or Ecosystem 

Component 

CWHR Type(s) defining the 

habitat or ecosystem 

component1

Sierra Nevada Forests 

Management Indicator 

Species 

Scientific Name

Category 

for 

Project 

Analysis 2

Riverine & Lacustrine† lacustrine (LAC) and riverine 

(RIV) 

aquatic 

macroinvertebrates 

N/A 

Shrubland (west-slope 

chaparral types) 

montane chaparral (MCP), 

mixed chaparral (MCH), 

chamise-redshank chaparral 

(CRC) 

fox sparrow 

Passerella iliaca

Cat. 3 

Sagebrush Sagebrush (SGB) greater sage-grouse 

Centrocercus 

urophasianus

Cat. 1 

Oak-associated Hardwood 

& Hardwood/conifer 

montane hardwood (MHW), 

montane hardwood-conifer 

(MHC) 

mule deer 

Odocoileus hemionus

Cat. 2 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 116 Chapter 3 – Affected Environment 

Riparian montane riparian (MRI), valley 

foothill riparian (VRI) 

yellow warbler 

Dendroica petechia

Cat. 2 

Wet Meadow† Wet meadow (WTM), 

freshwater emergent wetland 

(FEW) 

Pacific tree frog 

Pseudacris regilla

N/A 

Early Seral Coniferous 

Forest 

ponderosa pine (PPN), Sierran 

mixed conifer (SMC), white fir 

(WFR), red fir (RFR), eastside 

pine (EPN), tree sizes 1, 2, and 

3, all canopy closures 

Mountain quail 

Oreortyx pictus

Cat. 3 

Mid Seral Coniferous Forest ponderosa pine (PPN), Sierran 

mixed conifer (SMC), white fir 

(WFR), red fir (RFR), eastside 

pine (EPN), tree size 4, all 

canopy closures 

Mountain quail 

Oreortyx pictus

Cat. 3 

Habitat or Ecosystem 

Component 

CWHR Type(s) defining the 

habitat or ecosystem 

component1

Sierra Nevada Forests 

Management Indicator 

Species 

Scientific Name

Category 

for 

Project 

Analysis 2

Late Seral Open Canopy 

Coniferous Forest 

ponderosa pine (PPN), Sierran 

mixed conifer (SMC), white fir 

(WFR), red fir (RFR), eastside 

pine (EPN), tree size 5, canopy 

closures S and P 

Sooty (blue) grouse 

Dendragapus obscurus

Cat. 2 

Late Seral Closed Canopy 

Coniferous Forest 

ponderosa pine (PPN), Sierran 

mixed conifer (SMC), white fir 

(WFR), red fir (RFR), tree size 

5 (canopy closures M and D), 

and tree size 6. 

California spotted owl 

Strix occidentalis 

occidentalis

Cat. 2 American marten 

Martes americana

northern flying squirrel 

Glaucomys sabrinus

Snags in Green Forest Medium and large snags in 

green forest 

hairy woodpecker 

Picoides villosus

Cat. 3 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 117 Chapter 3 – Affected Environment 

Snags in Burned Forest Medium and large snags in 

burned forest (stand-replacing 

fire) 

black-backed woodpecker 

Picoides arcticus

Cat. 1 

1 All CWHR size classes and canopy closures are included unless otherwise specified; dbh = 

diameter at breast height; Canopy Closure classifications: S=Sparse Cover (10-24% canopy 

closure); P= Open cover (25-39% canopy closure); M= Moderate cover (40-59% canopy 

closure); D= Dense cover (60-100% canopy closure); Tree size classes: 1 (Seedling)(<1" dbh); 2 

(Sapling)(1"-5.9" dbh); 3 (Pole)(6"-10.9" dbh); 4 (Small tree)(11"-23.9" dbh); 5 (Medium/Large 

tree)(>24" dbh); 6 (Multi-layered Tree) [In PPN and SMC] (Mayer and Laudenslayer 1988). 

 

2 Category 1: MIS whose habitat is not in or adjacent to the Project area and would not be 

affected by the project. 

 Category 2: MIS whose habitat is in or adjacent to Project area, but would not be either directly 

or indirectly affected by the project. 

 Category 3: MIS whose habitat would be either directly or indirectly affected by the project. 

† Species in these categories will be analyzed separately under the aquatic species MIS report for 

the Fish Camp Project 

Category 1 MIS 

Species that will not be discussed further in this document include Category 1 and Category 2 

MIS. Category 1 defines MIS whose habitat does not occur in or adjacent to the Project area. For 

the Fish Camp, Project Category 1 MIS include the greater sage-grouse and the black-backed 

woodpecker. No sagebrush (SGB) or burned forest habitat is currently present in or adjacent to 

the Project area. 

Category 2 MIS 

Category 2 defines MIS whose habitat is in or adjacent to the Project area, but whose habitat 

would not be directly or indirectly affected by the project. For the Fish Camp Project, Category 2 

MIS include: yellow warbler, sooty grouse, mule deer, California spotted owl, American marten, 

and northern flying squirrel. Though habitat for these species occurs within or adjacent to the 

Project area, that habitat will not be directly or indirectly affected by the project. The primary 

reasons for this appraisal are the Fish Camp Project design features which limit the activities 

reducing canopy closure. These design features, as well as applicable Forest Service standards 

and guidelines protecting species habitats, are discussed further in the following sections of this 

document for each Category 2 MIS. 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 118 Chapter 3 – Affected Environment 

Category 3 MIS 

The MIS whose habitat would be either directly or indirectly affected by the Fish Camp Project, 

identified as Category 3, are carried forward in this analysis, which will evaluate the direct, 

indirect, and cumulative effects of the Proposed Action and alternatives on the habitat of these 

MIS. The MIS selected for project-level MIS analysis for the Fish Camp Project are: fox sparrow, 

mountain quail, and hairy woodpecker. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest – 119 Chapter 4 Table 27: Summary of Treatments with pre- and post-treatment CWHR type acres for Alternatives 1 and 3 

CWHR 

Forest 

Structure 

Class 

Alternative 1 

Current 

Structural 

Class Acres 

Project 

boundary 

Structural 

Class Acres 

within 

Commercial 

Thinning 

Treatment 

Units 

Structural 

Class Acres 

within 

Mastication 

and Prescribed 

Burn 

Treatment 

Units 

Percent of 

Structural 

Class Acres in 

Project 

boundary 

within 

Proposed 

Treatment 

Units 

Alternative 2 

Post-Treatment 

Projected changes 

to CWHR 

Structural class 

acres 

Alternative 2 

Post-Treatment 

CWHR 

structural class 

acres 

Project 

boundary 

Alternative 3 

Post-Treatmen

CWHR 

structural class 

acres 

Project 

boundary* 

BAR 38 0 5 12% 0 38 38 

JPN2S 170 1 33 20% 0 170 170 

JPN3M 55 2 0 4% 0 55 55 

JPN3P 42 8 0 19% 0 42 42 JPN3S 18 0 0 0% 0 18 18 

JPN4D 40 7 0 0% 0 40 40 

JPN4M 466 262 0 56% 0 466 466 

JPN4P 29 4 0 14% 0 29 29 JPN4S 53 4 0 8% 0 53 53 

LAC 15 0 0 0% 0 15 15 

MCH 4 0 0 0% 0 4 4 

MCP 189 13 0 7% 0 189 189 

MHC4M 1 0 0 0% 0 1 1 

MHW3D 13 1 0 8% 0 13 13 

MRI 6 0 0 0% 0 6 6 

PPN2S 80 3 0 4% 0 80 80 

PPN3D 7 0 0 0% 0 7 7 

PPN3P 48 5 37 88% 0 48 48 

PPN4D 54 41 0 80% -9 45 54 

PPN4M 83 25 5 36% +9 92 83 

PPN4P 58 18 0 31% 0 58 58 PPN4S 6 1 0 17% 0 6 6 

RDWD4D 4 2 0 50% 0 4 4 

RFR2D 8 0 4 50% 0 8 8 RFR3D 7 0 0 0% 0 7 7 

RFR3M 25 0 0 0% 0 25 25 

RFR4D 63 0 1 2% 0 63 63 

RFR4M 27 0 0 0% 0 27 27 

RFR4P 32 0 0 0% 0 32 32 RFR4S 66 0 0 0% 0 66 66 

RFR5M 10 0 0 0% 0 10 10 
Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 120 Chapter 3 – Affected Environment 

RFR5D 229 0 0 0% 0 229 229 

RFR5P 2 0 0 0% 0 2 2 RFR5S 5 0 0 0% 0 5 5 

SMC2D 8 1 0 13% 0 8 8 

SMC2M 20 1 0 5% 0 20 20 

SMC2P 9 0 1 11% 0 9 9 SMC2S 25 0 0 0% 0 25 25 

SMC3D 16 0 0 0% 0 16 16 

SMC3M 24 0 0 0% 0 24 24 

SMC3P 40 0 0 0% 0 40 40 SMC3S 5 0 0 0% 0 5 5 

SMC4D 1708 331 110 26% -22 1686 1708 

SMC4M 914 196 7 22% +22 936 914 

SMC4P 120 15 0 13% 0 120 120 SMC4S 174 17 32 28% 0 174 174 

SMC5D 232 2 0 1% 0 232 232 

SMC5M 71 0 0 0% 0 71 71 

SMC5P 3 0 0 0% 0 3 3 

WFR5D 31 0 0 0% 0 31 31 

WTM 87 0 0 0% 0 87 87 

Total 

Analysis 

Area Acres 

5440 960 235 

 CWHR Density 

change 

31acres D to M 

5440 5440 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 121 Chapter 3 – Affected Environment 

MIS Project-level Effects Analysis for Category 3 MIS 

1. Shrubland (West-Slope Chaparral) Habitat (Fox Sparrow)

Current Condition of the Habitat Factor(s) in the Project area: There are a total of 193 acres 

of shrub-land (chaparral) habitat within the Project boundary. 189 acres are classified as montane 

chaparral (MCP) and the remaining 4 acres are classified as mixed chaparral (MCH). Of the 193 

acres of chaparral within the Project boundary, only 7%, or 13 acres occur within proposed 

treatment units. Please refer to (Fish Camp CWHR Data Table, Project area, Present Compared 

to Alternative 2 Proposal) for a full breakdown of all CWHR habitat types within the Project 

boundary pre- and post-treatment. 

Alternative 1 – No Action 

Alternative 1 is the No Action alternative. Under the No Action alternative, current management 

plans would continue to guide management of the Project area. This includes all ongoing 

activities with existing decisions or permits that would not be changed if this alternative were 

selected including: plantation maintenance under separate document, cattle grazing, recreation, 

and recreation residences. The No Action Alternative would not implement the Fish Camp 

Project to reduce fire ladder conditions (thinning); pile slash for burning; burn slash piles; 

masticate and/and or precommercially thin stands; plant trees; reduce fuel loading through 

controlled burning; construct handline around jackpot burn areas; or reconstruct roads. 

Direct and Indirect Effects to Habitat: There are no direct effects to shrubland habitat under 

this alternative as it does not propose any actions. There is a potential for indirect effects under 

the No Action alternative as the continued immediate threat of wildfire would remain unabated. 

In failing to make an attempt at density management of the stands, the eventual changes through 

drought stress and subsequent insect and disease mortality acceleration would exacerbate the 

threat of stand replacing fire. Additionally, the high probability of a drying climate change 

throughout the Western United States would have the potential to further compound these effects 

(USDA-FS 2009a, Stalter 2008, Smith 2008). 

Cumulative Effects to Habitat in the Analysis Area: As no action is being taken by the SNF 

under the No Action Alternative by definition there would be no cumulative effects. See FEIS 

page 31 for more explanation. 

Alternative 2 – Proposed Action 

Direct and Indirect Effects to Habitat: Under Alternative 2 direct effects to 13 acres of 

shrubland habitat are proposed through mastication and prescribed burning treatments. These 13 

acres would be treated to maintain the growth and vigor of existing trees, or to create conditions 

suitable for the establishment of planted trees. The change in seral stage of 13 acres of chaparral 

out of 189 acres within the Project boundary is a treatment of 7% of the total chaparral available 

within the Fish Camp Project boundary. There are an additional 180 acres of shrubland habitat 

identified within the Project boundary that are not proposed for treatment under the Proposed 

Action alternatives and would continue to provide suitable habitat for fox sparrow during 

implementation of mastication and burning activities. 

Cumulative Effects to Habitat in the Analysis Area: A table of current and future projects 

within the analysis area for the Fish Camp Project can be found in the Fish Camp DEIS Chapter 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 122 Chapter 3 – Affected Environment 

3. This project proposes to treat 7% of the existing shrubland within the Project boundary. Further 

activities taking place within the cumulative effects boundary that may alter shrubland habitat 

include road brushing and plantation maintenance. These activities may alter a very small 

percentage of the available shrubland habitat through removal of aging chapparal bordering roads 

and inside plantations, resulting in natural regeneration of early seral stage chaparral habitat. 

Alternative 3 

Direct, Indirect, and Cumulative Effects to Habitat and Conclusion: The proposed treatments 

for the shrubland habitat within Alternative 3 are the same as for Alternative 2, therefore the 

direct, indirect, and cumulative effects for Alternative 3 would be the same as those discussed 

under the Proposed Action. 

Summary of Fox Sparrow Status and Trend at the Bioregional Scale 

The Sierra NF LRMP (as amended by the SNF MIS Amendment) requires bioregional-scale 

habitat and distribution population monitoring for the fox sparrow; hence, the shrubland effects 

analysis for the Fish Camp Project must be informed by both habitat and distribution population 

monitoring data. The sections below summarize the habitat and distribution population status and 

trend data for the fox sparrow. This information is drawn from the detailed information on 

habitat and population trends in the Sierra Nevada Forests Bioregional MIS Report (USDA Forest 

Service 2008), which is hereby incorporated by reference. 

Habitat Status and Trend: There are currently 922,000 acres of west-slope chaparral shrubland 

habitat on National Forest System lands in the Sierra Nevada. Within the last decade, the trend is 

stable. 

Population Status and Trend: The fox sparrow has been monitored in the Sierra Nevada at 

various sample locations by avian point counts and breeding bird survey protocols, including: 

1997 to present – Lassen National Forest (Burnett and Humple 2003, Burnett et al. 2005); 2002 to 

present - Plumas and Lassen National Forests (Sierra Nevada Research Center 2007); on-going 

monitoring through California Partners in Flight Monitoring Sites (CPIF 2002); 1992 to 2005 – 

Sierra Nevada Monitoring Avian Productivity and Survivorship (MAPS) stations (Siegel and 

Kaschube 2007); and 1968 to present – BBS routes throughout the Sierra Nevada (Sauer et al. 

2007). These data indicate that fox sparrows continue to be present at these sample sites, and 

current data at the rangewide, California, and Sierra Nevada scales indicate that, although there 

may be localized declines in the population trend, the distribution of fox sparrow populations in 

the Sierra Nevada is stable. 

Relationship of Project-Level Habitat Impacts to Bioregional-Scale Fox Sparrow Trend: 

The 193 acres of shrubland habitat that exists within the Project boundary account for less than 

0.02% of the 922,000 acres that exists at the bioregional scale, and only 13 of these acres are 

proposed for treatment. Therefore, cumulative impacts within the CE boundary would not alter 

the existing bioregional trends in this habitat, nor would they lead to a change in the distribution 

of fox sparrows across the Sierra Nevada bioregion. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 123 Chapter 3 – Affected Environment 

2. Early and Mid Seral Coniferous Forest Habitat (Mountain quail) 

Current Condition of the Habitat Factor(s) in the Project area: There are currently 3,627 

acres of early and mid seral coniferous forest habitat within the Fish Camp Project boundary. Of 

these, 658 acres (18%) are within proposed treatment units. Refer to (Fish Camp CWHR Data 

Table, Project area, Present Compared to Alternative 2 Proposal) of this report for a full 

breakdown of all CWHR habitat types within the Project boundary pre- and post-treatment. 

Alternative 1 – No Action 

Direct and Indirect Effects to Habitat: There would be no direct effects to early and mid seral 

coniferous habitat under this alternative. There is a potential for indirect effects under the No 

Action alternative as the continued immediate threat of wildfire would remain unabated. In failing 

to make an attempt at density management of the stands, the eventual changes through drought 

stress and subsequent insect and disease mortality acceleration would exacerbate the threat of 

stand replacing fire. Additionally, the high probability of a drying climate change throughout the 

Western United States would have the potential to further compound these effects (USDA-FS 

2011, Stalter 2008, Smith 2008).

Cumulative Effects to Habitat in the Analysis Area and Conclusion: 

As no action is being taken by the SNF under the No Action Alternative by definition there would 

be no cumulative effects. See FEIS page 31 for more explanation. 

Alternative 2 – Proposed Action 

Direct and Indirect Effects to Habitat: Under Alternative 2, minimal changes in CWHR 

composition of early and mid seral coniferous habitat are proposed for less than 1% of the 3,627 

acres of habitat within the Project boundary. These changes are projected to occur on 31 acres 

spread across 11 treatment units. 9 acres of PPN4D would be converted to PPN4M and 22 acres 

of SMC4D would be converted to SMC4M through proposed mechanical thinning treatments. 

The remaining 3,596 acres of early and mid seral coniferous habitat within the treatment analysis 

acres will not experience a change in CWHR habitat type, size, or density under the Alternative 2 

proposal. Due to the thinning prescriptions proposed, additional seral stage changes beyond those 

described will not change. Stands will merely reflect less density. Where stand density is at 60% 

or greater, it will not be brought below this level. It is expected that those stands treated will 

experience better health, vigor, and growth and will be less susceptible to wildfires. 

Cumulative Effects to Habitat in the Analysis Area and Conclusion: Many of the ongoing 

management activities within the cumulative effects boundary will not contribute to significant 

cumulative impacts upon early and/or mid seral coniferous forest habitat. Of the cumulative 

effects actions elevated within the analysis area private land residential development, roadside 

hazard tree removal, on-going plantation maintenance, and past and future timber sale activity 

have the greatest potential to alter early and mid seral coniferous habitat. Additional effects 

through Alternative 2 proposed canopy cover changes of 0.5% of the total habitat in the 

cumulative effects boundary are insignificant, especially when one considers the vast amount of 

available early and mid seral coniferous habitat present within the cumulative effects boundary.

Alternative 3 

Direct, Indirect, and Cumulative Effects to Habitat and Conclusion: The proposed treatments 

for the early and mid seral stage coniferous habitat within Alternative 3 are very limited in scope 

and will not change any CWRH habitat type, size, or density, therefore no direct effects to early 

and mid seral coniferous habitat would be expected to occur with implementation of Alternative 

3.
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 124 Chapter 3 – Affected Environment 

Indirect effects can be expected by failing to make an attempt at density management of the 

stands, the eventual changes through drought stress and subsequent insect and disease mortality 

acceleration would exacerbate the threat of stand replacing fire. Additionally, the high probability 

of a drying climate change throughout the Western United States would have the potential to 

further compound these effects. (USDA Forest Service 2011, 2010c, 2010d). 

Summary of Mountain Quail Status and Trend at the Bioregional Scale 

The Sierra NF LRMP (as amended by the SNF MIS Amendment) requires bioregional-scale 

habitat and distribution population monitoring for the mountain quail; hence, the early and mid 

seral coniferous forest effects analysis for the Fish Camp Project must be informed by both 

habitat and distribution population monitoring data. The sections below summarize the habitat 

and distribution population status and trend data for the mountain quail. This information is 

drawn from the detailed information on habitat and population trends in the SNF Bioregional MIS 

Report (USDA Forest Service 2008), which is hereby incorporated by reference. 

Habitat Status and Trend. There are currently 546,000 acres of early seral and 2,766,000 acres 

of mid seral coniferous forest (ponderosa pine, Sierran mixed conifer, white fir, and red fir) 

habitat on National Forest System lands in the Sierra Nevada. Within the last decade, the trend 

for early seral is slightly decreasing (from 9% to 5% of the acres on National Forest System 

lands) and the trend for mid seral is slightly increasing (from 21% to 25% of the acres on 

National Forest System lands). 

Population Status and Trend. The mountain quail has been monitored in the Sierra Nevada at 

various sample locations by hunter survey, modeling, and breeding bird survey protocols, 

including California Department of Fish and Game hunter survey, modeling, and hunting 

regulations assessment (CDFG 2004a, CDFG 2004b) and 1968 to present – BBS routes 

throughout the Sierra Nevada (Sauer et al. 2007). These data indicate that mountain quail 

continue to be present across the Sierra Nevada, and current data at the rangewide, California, and 

Sierra Nevada scales indicate that the distribution of mountain quail populations in the Sierra 

Nevada is stable. 

Relationship of Project-Level Habitat Impacts to Bioregional-Scale Mountain Quail Trend. 

The 3,627 acres of early and mid seral coniferous habitat that exists within the Project boundary 

account for less than 0.1% of the 2,766,000 acres that exists at the bioregional scale. The change 

in canopy closure of 31 acres out of 2,766,000 acres of early and mid seral coniferous habitat in 

the Sierra Nevada bioregion will not alter the existing trend in the habitat, nor will it lead to a 

change in the distribution of mountain quail across the Sierra Nevada bioregion.

3. Snags in Green Forest Ecosystem Component (Hairy woodpecker) 

Habitat/Species Relationship. 

The hairy woodpecker was selected as the MIS for the ecosystem component of snags in green 

forests. Medium (diameter breast height between 15 to 30 inches) and large (diameter breast 

height greater than 30 inches) snags are most important. The hairy woodpecker uses stands of 

large, mature trees and snags of sparse to intermediate density; cover is also provided by tree 

cavities (CDFG 2005). Mature timber and dead snags or trees of moderate to large size are 

apparently more important than tree species (Siegel and DeSante 1999). 

Project-level Effects Analysis – Snags in Green Forest Ecosystem Component 

 

Current Condition of the Habitat Factor(s) in the Project area: 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 125 Chapter 3 – Affected Environment 

Prior to 2004, the forest implemented standards and guidelines (S&Gs) from the Sierra NF Land 

and Resource Management Plan (LRMP) (1991) which called for maintaining an average of 1.5 

snags per acre in sizes 15-24” dbh and an average of 0.5 snags per acre in sizes 25” dbh or 

greater. All countable snags had to be 20’ or greater height (S&G #64, p. 4-16). Additionally, a 

sufficient number of live trees had to be left in appropriate sizes to serve as replacement snags. 

The Sierra Nevada Forest Plan Amendment (SNFPA) (2004), modified the SNF LRMP with the 

followings guidelines: (1) in westside mixed conifer and ponderosa pine types, Forests should 

maintain 4 of the largest snags per acre, (2) in red fir forest type, they should maintain 6 of the 

largest snags per acre, (3) in eastside pine and mixed conifer forest types, they should maintain 3 

of the largest snags per acre, and (4) in westside hardwood ecosystems, they should maintain 4 of 

the largest snags (hardwood or conifer) per acre, or if standing live hardwood trees lack dead 

branches, they should maintain 6 of the largest snags per acre (S&G #11, p. 51). 

Current conditions within the Project boundary meet and in many areas exceed the snag and 

down woody material retention guidelines laid forth in the 2004 SNFPA. The following standards 

and guidelines for Snags and Down Woody Material apply to this project (SNFPA FSEIS ROD 

Pg. 51-52): 

Down Woody Material: “Determine down woody material retention levels on an 

individual project basis, based on desired conditions. Emphasize retention of wood in the 

largest size classes and in decay classes 1, 2, and 3. Consider the effects of follow-up 

prescribed fire in achieving desired down woody material retention levels.” Typically 

10-20 tons of down woody material per acre is acceptable from a fuel loading standpoint, 

and will retain sufficient material to provide for post-treatment habitat for down woody 

utilizing species, based on extrapolation of pre-European stand conditions. 

Snag Retention: “Design projects to implement and sustain a generally continuous supply 

of snags and live decadent trees suitable for cavity nesting wildlife across a landscape. 

Retain some mid- and large-diameter live trees that are currently in decline, have 

substantial wood defect, or that have desirable characteristics (teakettle branches, large 

diameter broken top, large cavities in the bole) to serve as future replacement snags and 

to provide nesting structure. When determining snag retention levels and locations, 

consider land allocation, desired condition, landscape position, potential prescribed 

burning and fire suppression line locations, and site conditions (such as riparian areas and 

ridge tops), avoiding uniformity across large areas. 

The general guidelines for large-snag retention are as follows: 

Westside mixed conifer and ponderosa pine types – four of the largest snags per acre. 

Use snags larger than 15 inches dbh to meet this guideline. Snags should be clumped and 

distributed irregularly across the treatment units. Consider leaving fewer snags 

strategically located in treatment areas within the WUI. When some snags are expected 

to be lost due to hazard removal or the effects of prescribed fire, consider these potential 

losses during project planning to achieve desired snag retention levels.” 

No snags are proposed to be removed in the Fish Camp project unless they meet the definition of 

a danger tree and are felled for safety (US Forest Service 2011). 

Additional Design criteria common to all Action alternatives includes: 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 126 Chapter 3 – Affected Environment 

 Maintain highest canopy cover possible to meet the prescription within stands, aim for 

50-60% immediately post-harvest. 

 Thinning will not remove any trees larger than 30”dbh. 

 Retain groups of larger trees (greater than 30”) at the rate of approximately one group per 

2.5-3.5 acres. Ideally these groups would contain “defect” trees, those that have cavity 

and platform creating defects (mistletoe, rot, fork topped, broken limbs and tops) for den 

and rest sites. 

 Retain largest snags and logs. Do not remove snags unless it is safety concern (project 

does not propose to remove snags). Retain largest logs to maximum allowed by fuel 

loading standards. 

Alternative 1 (No Action) 

Direct and Indirect Effects to Habitat. There is a potential for indirect effects under the No 

Action alternative as the continued immediate threat of wildfire would remain unabated. In failing 

to make an attempt at density management of the stands, the eventual changes through drought 

stress and subsequent insect and disease mortality acceleration would exacerbate the threat of 

stand replacing fire. Such a wildfire would convert current snags in green forest habitat to snags 

in burned forest habitat. Additionally, the high probability of a drying climate change throughout 

the Western United States would have the potential to further compound these effects (USDA 

Forest Service 2011, 2010c, 2010d). Other potential effects is snag development as there is a 

higher probability of insect and density related tree mortality over the life of the project. 

Cumulative Effects to Habitat in the Analysis Area and Conclusion. 

As no action is being taken by the SNF under the No Action Alternative by definition 

there would be no cumulative effects. See FEIS page 31 for more explanation.

Alternative 2 (Proposed Action) 

Direct, Indirect, and Cumulative Effects to Habitat and Conclusion. There would be 

minimal direct effects to snags under the Alternative 2 Proposed Action. Currently across the 

treatment units there are an average of 9 standing conifer snags per acre that are ≥11” dbh and 5 

standing conifer snags per acre that are ≥18” dbh. No snags are proposed for removal by any of 

the action alternatives in the Fish Camp Project, except for in rare cases where they constitute a 

safety concern. Current conditions within the Project boundary meet and in many areas exceed 

the snag and down woody material retention guidelines laid forth in the 2004 SNFPA. It is 

reasonable to assume that a few stage 4 through 7 snags may be lost in prescribed fire treatment 

areas, however this treatment is also likely to produce stage 2 and 3 snags. It is not expected that 

removal of snags that pose a safety concern along roadways or in treatment units will alter the 

available snag levels below the current standards set forth in the ROD. 

Alternative 3 

Direct, Indirect, and Cumulative Effects to Habitat and Conclusion. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 127 Chapter 3 – Affected Environment 

The proposed treatments for forest snags within Alternative 3 are the same as for Alternative 2, 

therefore the direct, indirect, and cumulative effects for Alternative 3 would be the same as those 

discussed under the Proposed Action. 

Summary of Hairy Woodpecker Status and Trend at the Bioregional Scale 

The Sierra NF LRMP (as amended by the SNF MIS Amendment) requires bioregional-scale 

habitat and distribution population monitoring for the hairy woodpecker; hence, the snag effects 

analysis for the Fish Camp Project must be informed by both habitat and distribution population 

monitoring data. The sections below summarize the habitat and distribution population status and 

trend data for the hairy woodpecker. This information is drawn from the detailed information on 

habitat and distribution population trends in the SNF Bioregional MIS Report (USDA Forest 

Service 2008), which is hereby incorporated by reference. 

Ecosystem Component Status and Trend. The current (based on 2001-2004 inventory sources) 

average number of medium-sized and large-sized snags (> 15" dbh, all decay classes) per acre 

across major coniferous and hardwood forest types (westside mixed conifer, ponderosa pine, 

white fir, productive hardwoods, red fir, eastside pine) in the Sierra Nevada ranges from 1.4 per 

acre in eastside pine to 8.3 per acre in white fir. Detailed information by forest type, snag size, 

and snag decay class can be found in the SNF Bioregional MIS Report (USDA Forest Service 

2008). 

Data from the mid-to-late 1990s were compared with the current data to calculate the trend in 

total snags per acre by Regional forest type for the 10 Sierra Nevada national forests and indicate 

that, during this period, snags per acre increased within westside mixed conifer (+0.80), white fir 

(+1.98), and red fir (+0.68) and decreased within ponderosa pine (-0.17), productive hardwoods (-

0.17), and eastside pine (-0.16). 

Population Status and Trend. The hairy woodpecker has been monitored in the Sierra Nevada 

at various sample locations by avian point counts and breeding bird survey protocols, including 

1997 to present – Lassen National Forest (Burnett and Humple 2003, Burnett et al. 2005); 2002 to 

present - Plumas and Lassen National Forests (Sierra Nevada Research Center 2007); 1992 to 

2005 – Sierra Nevada Monitoring Avian Productivity and Survivorship (MAPS) stations (Siegel 

and Kaschube 2007); and 1968 to present – BBS routes throughout the Sierra Nevada (Sauer et 

al. 2007). These data indicate that the hairy woodpecker continues to be present at these sample 

sites, and current data at the rangewide, California, and Sierra Nevada scales indicate that the 

distribution of hairy woodpecker populations in the Sierra Nevada is stable. 

Relationship of Project-Level Habitat Impacts to Bioregional-Scale Hairy Woodpecker 

Trend. The 5,440 acres of mid and late seral forest habitat that provides the green forest snag 

component within the Project boundary account for less than 0.1% of the 3,835,000 acres of mid 

and late seral coniferous forest habitat within the Sierra Nevada bioregion. Therefore, none of the 

alternatives would alter the bioregional trend in the snag component of the coniferous forest 

habitat, nor would they lead to a change in the distribution of the hairy woodpecker across the 

Sierra Nevada bioregion. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 128 Chapter 3 – Affected Environment 

Hydrology/Water Quality __________________________ 

The direct, indirect and cumulative effects to the hydrologic resource and water quality are 

summarized from the Hydrology Report (Stone, A. 12/15/2010) and Cumulative Watershed 

Effects Analysis (Gallegos, A. 12/16/2010) for the Fish Camp Project. 

Affected Environment 

The Fish Camp Project is located in the South Fork Merced River 5th-field HUC Watershed. Big 

Creek, the principal drainage in the Project area, is tributary to the South Fork of the Merced 

River. The South Fork of the Merced is tributary to the Merced River, which flows to the San 

Joaquin River in the Central Valley of California. All of the discharge from Big Sandy 

Watershed, White Chief Branch and the headwaters of Big Creek at one time flowed into Big 

Creek but are now diverted by a flume into Lewis Fork, a tributary to the Fresno River. Up to 

6000 acre-feet of water is diverted from Big Creek between December 1st and July 15th into the 

Lewis Fork. This diversion has occurred since the 1870s. Although severe degradation to 

tributary channels feeding Lewis Fork has occurred, the channel conditions have adjusted since 

the time of diversion to reach equilibrium. Table 28 provides a summary of the affected 

drainages and associated water bodies in the Project area. Figure 5 displays the location of 

perennial streams and watersheds associated with the project. 

Table 28: Subdrainage Summaries. 

Main 

Stream 

System(s) 

Watershed 

(HUC 5) 

Subdrainages 

(HUC 8) 

Stream miles 

Perennial Intermittent/Ephemeral Ephemeral Total 

Big Creek SF Merced 

(1804000803) 

501.5002 

501.5004 

501.5005 

501.5006 

501.5007 

501.5008 

501.5053 

501.5054 

501.7052 

29 18 141 188 

Summary of Existing Conditions 

Although there is evidence that past activities that have caused watershed degradation, overall the 

channels and subdrainages appear to be recovering and reaching a state of equilibrium. The 

current condition for most of the stream reaches is good or fair for channel stability using 

modified Pfankuch, after Rosgen (2004) and this has been corroborated with Stream Condition 

Inventory data. There are, however, several areas within the proposed Project boundary that are 

unstable and sensitive to disturbance. Specifically, subdrainage 501.5005 has a sub-basin where 

CWE response is occurring, which includes Long Meadow. Ground disturbance from mechanized 

equipment should be minimized or avoided in this area, especially in designated SMZ’s. If the 

use of mechanized equipment will be essential to fulfilling the purpose and need, then 

consultation with the district hydrologist will be necessary for any work in the CWE response 

area (Figure 7). 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 129 Chapter 3 – Affected Environment 

Maintenance level 2 (“native surface”) roads throughout the Fish Camp Project area are in poor 

condition and many of these roads lack adequate drainage. This is increasing hydrologic 

connectivity in the project subdrainages, which is contributing to increased sediment input and 

overall watershed degradation resulting in CWE response in some areas. 

The baseline or existing condition of most of the subdrainages is below the Lower TOC%, but 

subdrainages 501.5006, 501.5007, 501.5053 are over their Lower TOC%. When adding in the 

Proposed Action or Alternative 3, none exceeded the Upper TOC of 14%. All of the subdrainages 

have been inspected for CWE response in the field by an IDT or surveyed using various methods 

(e.g., SCI, Pfankuch). Overall, the project subdrainages did not appear to be experiencing a CWE 

response except a sub-basin within 501.5005 (Figure 7). 

Water quality in the Project area is managed under the Central Valley Basin Plan for the San 

Joaquin and Sacramento River Basins (CVRWQCB, 2007). A water body or segment of a water 

body that does not meet (or is not expected to meet) water quality standards may be considered a 

“Water Quality Limited Segment” (WQLS). These WQLS’s are added biennially by the 

CVRWQCB to the Clean Water Act Section 303(d) list of impaired waters. As of this writing, 

none of the perennial drainages within the Project area are listed for impairment on the State’s 

303(d) listing. 

Cumulative Effects of no action would be displayed under the pre project condition of the CWE 

analysis. ( Also see Cumulative Watershed Effects Report, Gallegos, 2010). Essentially the only 

watershed considered being at or near CWE prior to field investigations is a segment of 501.5005. 

Specifically, subdrainage 501.5005 has a sub-basin where CWE response is occurring, which 

includes Long Meadow. Ground disturbance from mechanized equipment should be minimized or 

avoided in this area, especially in designated SMZ’s. If the use of mechanized equipment will be 

essential to fulfilling the purpose and need, then consultation with the district hydrologist will be 

necessary for any work in the CWE response area (FLRMP, 2509.22 Supplement No. 1). 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 130 Chapter 3 – Affected Environment 

Figure 10: Subdrainages; Map showing the Fish Camp Project area with subdrainages, perennial 

streams, and meadows. The solid yellow polygon in subdrainage 501.5005 (see figure 5 for a subdrainage 

map) is the sub-drainage showing a CWE response. 

Alternative 1 – No Action 

Direct effects associated with not treating fuels in the Project area would result in a lost 

opportunity to reduce potential for catastrophic fire. This lost opportunity has the 

potential to affect not only the communities at risk; it also affects the riparian habitat and 

water quality in the Project area. As described in the affected environment, riparian areas 

have large amounts of organic material throughout the drainages. This material is not 

lying on the forest floor; it is intermingled with standing material. In the event of a 

catastrophic wildfire, riparian habitat, channel characteristics and riparian vegetation 

would be adversely affected. 

Direct Effects 

Direct effects of the No Action alternative would be continued increase of fuels in stream courses 

and continued watershed impacts from water and silt runoff of highly degraded road system. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 131 Chapter 3 – Affected Environment 

Indirect Effects 

Indirect effects of No Action alternative would be basin-wide increases of fuels in stream courses 

and continued watershed impacts from a highly degraded road system. 

Cumulative Effects 

As no action is being taken by the SNF under the No Action Alternative by definition there would be 

no cumulative effects. See FEIS page 31 for more explanation. 

Table 29: Existing (Baseline) CWE Conditions. 

Summary of Existing Disturbance Data for the Fishcamp Project area

Subdrainage 

ID 

Subdrainage

Acres 

Sensitivity Lower 

TOC 

Allotment

ERA 

Roads 

 ERA 

Harvest 

 ERA 

Total 

ERA 

Potential 

CWE 

501.5002 587.00 Moderate 5.0% 0.69 1.06 0.50 2.26 unlikely 

501.5004 2,435.00 Moderate 5.0% 0.69 0.91 0.24 1.84 Unlikely 

501.5005 2,228.00 Moderate 5.0% 0.89 0.86 0.75 2.50 Unlikely 

501.5006 638.00 Moderate 5.0% 0.95 0.71 10.74 12.40 Low 

501.5007 668.00 Moderate 5.0% 1.23 0.56 6.28 8.07 Low 

501.5053 1,816.00 Moderate 5.0% 0.78 1.45 4.57 6.80 Low 

501.5054 1,479.00 Moderate 5.0% 0.87 0.87 0.50 2.25 Unlikely 

501.7052 2,892 Moderate 5.0% 0.06 1.38 0.46 1.91 Unlikely 

Alternative 2 – Proposed Action 

 

Table 30: Activities proposed within Project area subdrainages under Alternative 2 

(approximate maximum acres generated by GIS) Subdrainage 501.5002 501.5004 501.5005 501.5006 

501.5007 501.5008 501.5053 501.5054 501.7052 

Total 

Commercial or 

pre-commercial 

thinning or tractor 

piling 134 331 269 0 0 0 52 83 86 955 

Mastication 0 0 35 5 0 12 0 0 0 52 

Underburn 32 55 0 0 0 0 0 0 105 192 

Subdrainage Acres 588 2436 2229 638 668 2261 1817 1480 2880 

% Subdrainage 28% 16% 14% 0.7% 0% 0.5% 3% 6% 7% 

CWE response 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 132 Chapter 3 – Affected Environment 

Limited or no direct treatment would occur in SMZ’s with the one exception being over stocked 

plantations adjacent to the Long Meadow complex (Figure 1). In general, all vegetation and fuel 

treatments conducted in RCA’s would focus on improving forest health, enhancing or 

maintaining hydrologic function and maintaining or enhancing the key attributes of riparian 

habitats. Attributes comprise cool, moist soil conditions; high water quality; retention of large 

snags and down logs in sufficient quantities to provide habitat and woody debris recruitment in 

stream channels; and retention of woody material to provide stability to riparian and aquatic 

habitats. Well functioning channels have good riparian vegetation, good sediment transport, and 

stable streambanks. These characteristics work together to maintain channel function and 

stability. 

A wide range of activity-specific BMP’s are designed to minimize detrimental soil disturbance, 

protect water quality, maintain physical stability, and hydrologic connectivity of riparian and 

aquatic habitats. There is little potential for the Proposed Action to adversely affect the 

geomorphic, hydrologic, or riparian characteristics and aquatic habitats in affected subdrainages 

because of the low-impact characteristics of the proposed stand treatments, the limitations that 

would be imposed on operations within RCA’s and SMZ’s, and the use of activity-specific 

BMP’s. 

The greatest potential for the Proposed Action to affect the hydrologic connectivity of streams 

and aquatic habitat exists at stream crossings. To minimize the potential for project-related effects 

on hydrologic connectivity, existing crossings would be used whenever possible. In the event that 

it is necessary to construct a temporary crossing, the methods used for construction would be 

selected to avoid or minimize detrimental soil and vegetation disturbance and to maintain 

hydrologic connectivity between upstream and downstream features (Appendix 2 of the 

hydrology specialist report). All temporary crossings would be removed following the 

completion of project-related activities and would be treated as necessary to restore to pre-project 

conditions. Implementation of the activity-specific BMP’s would further ensure that hydrologic 

connectivity in streams and special aquatic features are not adversely affected by the Proposed 

Action. 

Common to All Subdrainages 

No new roads are proposed to be constructed as part of the Fish Camp project because there are 

sufficient numbers to provide the necessary access to each of the treatment units. The existing 

road system, however, is currently in poor condition and in need of maintenance. In their current 

state of disrepair, the roads in the Project area are increasing hydrologic connectivity, 

contributing to increased sediment input and causing overall watershed degradation. This is 

contributing to CWE response in some areas. As part of the Timber Sale contract, all the roads to 

be used for project activities will be brought up to a maintenance level 3 standard (BMP 2-22). 

This includes maintaining roads in a manner that provides for water quality protection by 

minimizing rutting, failures, sidecasting, and blockage of drainage facilities, all of which can 

cause erosion, sedimentation, and deteriorating watershed conditions. Roads needed for project 

activities will be brought to current engineering standards of alignment, drainage, and grade 

before use, and will be maintained through the life of the project. Roads will be inspected at least 

annually to determine what work, if any, is needed to keep ditches, culverts, and other drainage 

facilities functional and the road stable. 

Direct Effects 

Direct effects are those occurring at the same time and place as the triggering action. The 

Proposed Action (Alternative 2) could directly affect hydrologic resources, primarily as a result 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 133 Chapter 3 – Affected Environment 

of vegetation removal, temporary road construction, slash piling, and prescribed fire 

immediately following treatment; such activities could lead to soil disturbance and its 

associated effects on water quality and therefore aquatic habitats (e.g., accelerated erosion and 

sedimentation). Any soil displacement, compaction, or change in ground cover would cause a 

direct effect on watershed condition. Most treatment units have avoided crossing stream 

channels. The exception is Class V ephemeral draws. Fuels treatments have been laid out to 

utilize designated and/or existing crossings. Figure ?displays SMZ’s assigned to streams in the 

Fish Camp Project area. Streamcourses are to be protected under on project design criteria. 

Any additional streams identified during operations would receive protection appropriate for 

the stream and the treatment. 

Subdrainage 501.5005 

14% of this 2,229 acre subdrainage is planned for treatment (Table 30). Of all project 

subdrainages, the most acute changes in ERA% with the Proposed Action occurred in 

subdrainages 501.5005 and 501.5004. An IDT evaluation for CWE response found that a subbasin within subdrainage 501.5005 was contributing excess sediment into Long Meadow creek 

and portions of White Chief Branch creek (Figure 5). The condition of Long Meadow is highly 

degraded as are the existing roads around the meadow. Approximately 270 acres of mechanical 

treatments are planned, which could further exacerbate the unstable watershed conditions around 

Long Meadow. Treatments throughout this subdrainage (in particular, units T-17c,d, T-19a,b, T22b,c, T-28a,b,f) will use a “light-on-the-land” approach and avoid, any mechanical treatments 

within 100 feet of Long Meadow unless the purpose and need for forest health is not being met. 

Under the current sale layout, some of the timber being removed from unit T-28b would require 

skidding up an adverse slope of more than 25% to FS road 5S22X A-spur or FS road 5S48. This 

could require more mitigation for winter-time closure than would be desirable, and as such, 

alternate egress from unit T-28b is being considered. The optimum route is to skid logs to FS road 

5S22X C-spur. This would require skidding across the upper reaches of Long Meadow Creek 

(Figure 8). This segment of Long Meadow Creek is a class II/III (perennial/intermittent), and was 

observed to be in stable to moderately stable condition based on professional judgment (i.e., no 

SCI or Pfankuch surveys were conducted). Figure 10 shows three potential crossing locations (it 

is important to note that only one of these locations would be selected if used). Currently, there 

are unresolved archeological concerns in this area, which may preclude any skidding through this 

part of the unit; however, should a temporary stream crossing be allowed, it would strictly follow 

the design measures outlined in Appendix B be supervised by the district hydrologist, forest 

hydrologist, or forest fisheries biologist. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 134 Chapter 3 – Affected Environment 

Figure 10: Three potential crossing locations for skidding logs out of Unit T-28b. Only one of the three 

locations would be used. A temporary crossing would be constructed following the design measure outlined 

in Appendix 2 of the hydrology specialist report.

 

Indirect Effects 

Indirect effects are those that occur at a later time or at a distance from the triggering action. 

Indirect effects are expected to be minor. Design features incorporated into the project would be 

implemented to control erosion and sedimentation. The implementation of BMPs would avoid or 

minimize potential increases in sediment loads to streams during project implementation such that 

prescribed fires are not expected to affect water quality. Over the longer term, potential adverse 

effects on water and soils from implementing the Proposed Action are expected to be minor, and 

substantially less than if an uncontrolled wildfire were to occur. 

Cumulative Effects 

Table 31 shows the CWE results for the Fish Camp project. All of the subdrainages are 

considered moderately sensitive to disturbance (i.e., 5% Lower TOC). The baseline or existing 

condition of most of the subdrainages is below the Lower TOC%, but subdrainages 501.5006, 

501.5007, 501.5053 are over their Lower TOC%. When adding in the Proposed Action, none 

exceeded the Upper TOC of 14%. All of the subdrainages have been inspected for CWE response 

in the field by an IDT or surveyed using various methods (e.g., SCI, Pfankuch). Descriptions of 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 135 Chapter 3 – Affected Environment 

each subdrainage can be found in the Hydrology Specialist Report (Stone, 2010) or in the 

Cumulative Watershed Effects report (Gallegos, 2010. 

An IDT evaluation for CWE response found that a sub-basin within subdrainage 501.5005 was 

contributing excess sediment into Long Meadow creek and portions of White Chief Branch creek 

(Figure 7). The condition of Long Meadow is highly degraded as are the existing roads around 

the meadow. Treatments throughout this subdrainage (i.e., T-17c,d, T-19b, T-22b,c, T-28f) 

should use a “light-on-the-land” approach and avoid any mechanical treatments within 100 feet of 

Long Meadow unless the purpose and need for forest health is not being met (see design 

measures section for a description of light-on-the-land equipment). Any activity proposed within 

the SMZ (i.e., the plantation adjacent to Long Meadow), would require a modified operation plan 

(FSH 2509.22, 3c, 14.17-4), which is outlined under the Design Measures section of this 

document. 

None of the subdrainages exceeded the Upper TOC of 14% (Table 27). All of the subdrainages 

have been inspected for CWE response in the field by an IDT or surveyed using various methods 

(e.g., SCI, Pfankuch); Baseline and project CWE data and IDT observations suggest that there is 

a low potential for CWE response from the Proposed Action throughout the greater subdrainage 

501.5005, but a localized CWE response is occurring in the Long Meadow sub-basin (Figure 7). 

Table 31: Alternatives 2 and 3 CWE Conditions. 

Summary of Disturbance Data with the Fishcamp Project 

Subdrainage 

ID 

Subdrainage 

Acres 

Lower 

TOC 

Allotment

ERA 

Roads 

 ERA 

Harvest 

 ERA 

Total 

Existing 

ERA 

Total 

Proposed

ERA 

Potential 

CWE 

501.5002 587 5.0% 0.69 1.06 2.79 2.26 4.55 Unlikely 

501.5004 2,435 5.0% 0.69 0.91 4.07 1.84 5.67 Unlikely 

501.5005 2,228 5.0% 0.89 0.86 5.01 2.50 6.76 Low 

501.5006 638 5.0% 0.95 0.71 10.77 12.40 12.44 Low 

501.5007 668 5.0% 1.23 0.56 6.31 8.07 8.10 Low 

501.5053 1,816 5.0% 0.78 1.45 4.99 6.80 7.22 Low 

501.5054 1,479 5.0% 0.87 0.87 2.42 2.25 4.17 Unlikely 

501.7052 2,892 5.0% 0.06 1.38 .88 1.91 2.32 Unlikely 

Alternative 3 

In Alternative 3, treatment areas would remain the same as in Alternative 2, treatments within 

these areas would include only those needed to reduce the surface and ladder fuels (within the 

lower and limited mid-level canopy levels) needed to achieve fire and fuels objectives. Under 

Alternative 3 there would be no additional treatments (i.e. additional thinning in the mid-level 

canopy) to fully address stand density and forest health objectives. 

This alternative would receive treatment only to achieve fire and fuels objectives and limit 

treatments to mechanical clearing of ladder and surface fuels. As such, all design criteria and 

SNFPA ROD (2004) standards and guidelines associated with Pacific Fisher would be 

implemented with this alternative. 

Of the 5700 total acres within the Project boundary, approximately 1200 acres were analyzed as 

areas where some form(s) of treatment are proposed (so named as treatment areas). The 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 136 Chapter 3 – Affected Environment 

remaining 4500 acres have no treatments proposed due to slopes greater than 35 percent, standard 

and guideline limitations on treatment and/or no treatment is needed to meet the purpose and 

need. 

Though a total of 1200 acres are analyzed for treatments listed above, design criteria common to 

all alternatives and standards and guidelines from SNFPA ROD (USDA-FS 2004b) dictate areas 

where treatment cannot occur to reduce and/or eliminate adverse effects on particular resources. 

These can include, but are not limited to heritage resources areas, botanical species areas, wildlife 

habitat areas, and aquatic species areas. 

Direct Effects 

Direct effects are those occurring at the same time and place as the triggering action. The direct 

effects would be less than those described under Alternative 2, in that there would be less impact 

because the thinning methodology would only concentrate on ladder and surface fuels within the 

lower and mid-canopy levels, and not include commercial thinning.

Indirect Effects 

Indirect effects are those that occur at a later time or at a distance from the triggering action. Like 

Alternative 2, indirect effects are expected to be minor. Conservation measures incorporated into 

the project would be implemented to control erosion and sedimentation. The implementation of 

BMP’s would avoid or minimize potential increases in sediment loads to streams during project 

implementation such that impacts to aquatic habitats are not expected. Over the longer term, 

potential adverse effects on water and soils from implementing the Alternative 3 are expected to 

be minor, and substantially less than if an uncontrolled wildfire were to occur. 

Cumulative Effects 

Table 31 shows the CWE results for the Fish Camp project. All of the subdrainages are 

considered moderately sensitive to disturbance (i.e., 5% Lower TOC). The baseline or existing 

condition of most of the subdrainages is below the Lower TOC%, but subdrainages 501.5006, 

501.5007, 501.5053 are over their Lower TOC%. When adding in the Proposed Action, none 

exceeded the Upper TOC of 14%. All of the subdrainages have been inspected for CWE response 

in the field by an IDT or surveyed using various methods (e.g., SCI, Pfankuch). Descriptions of 

each subdrainage can be found in the Hydrology Specialist Report (Stone, 2010) or in the 

Cumulative Watershed Effects report (Gallegos, 2010). 

An IDT evaluation for CWE response found that a sub-basin within subdrainage 501.5005 was 

contributing excess sediment into Long Meadow creek and portions of White Chief Branch creek 

(Figure 7). The condition of Long Meadow is highly degraded as are the existing roads around 

the meadow. Treatments throughout this subdrainage (i.e., T-17c,d, T-19b, T-22b,c, T-28f) 

should use a “light-on-the-land” approach and avoid any mechanical treatments within 100 feet of 

Long Meadow unless the purpose and need for forest health is not being met (see design 

measures section for a description of light-on-the-land equipment). Any activity proposed within 

the SMZ (i.e., the plantation adjacent to Long Meadow), would require a modified operation plan 

(FSH 2509.22, 3c, 14.17-4), which is outlined under the Design Measures section of this 

document. 

All of the subdrainages calculated above their Lower TOC% when adding in the Proposed 

Action, but none exceeded the Upper TOC of 14% (Table 29). Since the treatment acreages 

would not change under Alternative 3, the %ERA calculation would be the same as in Alternative 

2 resulting in the same conclusion, that is, none of the subdrainages exceeded the Upper TOC of 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 137 Chapter 3 – Affected Environment 

14%. Baseline and project CWE data and IDT observations suggest that there is a low potential 

for CWE response from Alternative 3 throughout the greater subdrainage 501.5005, but a 

localized CWE response is occurring in the Long Meadow sub-basin (Figure 7). 

Forest Vegetation/Silviculture ______________________ 

The direct, indirect and cumulative effects to forest vegetation are summarized from the 

Silvicultural Report for the Fish Camp Project (Smith, D. 2011). 

Affected Environment 

The Fish Camp Project area has a history of heavy railroad logging activities. Between 1919 and 

1923 heavy railroad clearcut logging was carried out by the Madera Sugar Pine Co. through much 

of the Project area. Logs from railroad logged stands were transported to the mill at Sugar Pine 

over its 140 miles of track. The mill operated for 32 years averaging a 40 million board foot cut 

each year. Seven locomotives and 100 log hauling cars were in use during its peak. In 1900, 

when the Madera Sugar Pine Co. first began logging, it owned 21,616 acres of timberland in 

Madera and Mariposa Counties including land near Wawona, now a part of Yosemite National 

Park. In subsequent years it purchased additional timberlands as well as Forest Service timber. 

Lands within the Fish Camp Project area were private timber holdings at the time they were 

railroad logged. 

During the railroad logging at the beginning of the last century, logs were yarded by a system of 

cable settings. Deep gouging occurred in a number of places where logs dug into the soil as they 

were yarded to landings. As logs approached landings, more soil was generally displaced. In 

many cases, this reduced soil depths to almost bare rock. Settings can often be distinguished by a 

lack of conifer reproduction and an abundance of brush still today. However, between 

cableways, existing reproduction was often protected from damage. Logging slash was not 

treated following harvest. Today, much of this early reproduction remains as stands of generally 

90 to 110 year old 6 to 24 inch dbh incense cedar, sugar pine, ponderosa/Jeffrey pine, and white 

fir. 

During the 1960s, a significant effort was made throughout California to reforest previously 

forested areas that were understocked. Two major blocks of plantations created during this time 

period lie within the Project area; one, a ponderosa pine plantation area, near Buffin Meadow and 

the other, larger one, a mostly Jeffrey pine plantation area, near Long Meadow. Over 950 acres 

of railroad logged ground were planted within the proposed project boundaries during this time. 

Approximately 300 additional acres of plantations were created in the early 1990s. 

Over the past several years, 180 acres of these 1990s plantations were released and thinned by 

mastication. Stand Rx55 overlies 38 acres of these recently masticated plantations. The Sugar 

Pine Adaptive Management Project Big Creek hydrology study treatment units (251 acres), 

recently put under contract, comprise a portion of the 5440 acres within the total project 

boundaries. 

Many of these 40 to 50 year old plantations were precommercially thinned in past years. Some of 

the plantations were hand thinned, slash tractor piled, and piles burned while others were thinned 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 138 Chapter 3 – Affected Environment 

with mastication machines where material was shredded and left on the ground as mulch. The 

majority of the trees within these previously thinned areas are presently 10 inches and larger in 

diameter at breast height (dbh). Stocking, tree height and diameter, vigor and stand density varies 

considerably within the larger plantations where precommercial thinning has not taken place 

previously. Rocky outcrops and other lower site areas scattered throughout are generally 

vegetated with oaks and brush and more scattered conifer stocking. As a result, some stand 

heterogeneity is present within these larger plantations. Basal area stocking in these lower site 

areas runs from 40 ft2 to 100 ft2 per acre. Stocking in the more densely stocked stands varies 

from 120 ft2 to 320ft2 per acre. Conifer canopy cover varies from very light in the low site areas 

to dense (80-100%) in overstocked areas. 

Although pockets of older trees can be found scattered through the proposed Project area, past 

railroad and other logging as well as stand replacing fires have resulted in little of the area being 

vegetated with trees older than 130 years. The natural stands proposed for thinning within the 

Project area generally consist of approximately 90 to 110 year old trees that were young, shade 

tolerant saplings growing beneath the overstory trees during the railroad logging era. The 

majority of wild stands present are considered to be mixed conifer types. These stands, once 

heavy to more fire resistant, shade intolerant, ponderosa and sugar pine, have become very heavy 

to less fire resistant fir and incense cedar. Plot data indicates that in many areas white fir and 

incense cedar comprise 40 to 80 percent of the basal area sampled. Mixed conifer aggregations 

and stands occupy areas near cooler, damper draws and at the mid elevations within the Project 

area. Red fir stands are present at the higher reaches of the Project area. Pine, mixed conifer and 

white fir stand basal area stocking varies from 120 ft2 per acre in more open areas to oak pockets 

to densely stocked pockets of 350-400 ft2 per acre or more. Conifer canopy cover varies 

substantially across the Project area. Conifer canopy cover ranges from quite dense (80-100%) in 

overstocked areas to clumpy dense patches in less uniformly stocked areas to more moderate (50-

70%) to fairly light in other locations. Some scattered brushfields, resulting from previous fires 

and early 1900’s logging, are found within the Project area. 

Exclusion of fire from the vast majority of the area has resulted in the development of multilayered stands. The understory layers consist of fir and incense cedar beneath young growth 

stands of ponderosa/Jeffrey pine, sugar pine, incense cedar, and white fir with, in some cases, an 

additional layer of brush beneath or adjacent. In pine plantations, incense cedar and white fir and 

/or brush have seeded in thus creating significant fuel ladders. 

Weather Changes 

Tree ring studies have established that compared to the previous two centuries weather during the 

20th Century was relatively moist without the decades-long droughts that occurred earlier (Ferrell, 

1996). Beginning in the 1970’s temperatures began to warm noticeably. This warming resulted 

in a greater fraction of the Sierra Nevada precipitation falling as rain rather than snow, earlier 

snowmelt and earlier streamflow peaks (-van Mantgem, 2009)(Knowles, et al, 2006)(Stewart, et 

al, 2005). This shift appears to be the result from still longer term climate shifts (Knowles, et al. 

2006).The combination of reduced stand vigor and excessive stocking combined with increasing 

temperatures and decreasing soil moisture availability is greatly increasing the threat of loss due 

to mortality from insect attack, diseases, competition, or fire. 

The wetter than normal 20th Century coupled with the exclusion of fire has set the stage for stands 

to become overcrowded with competing conifers, oaks and other vegetation. Wide swings in 

weather conditions over the past thirty years have placed stress on many of these stands. Inter 

tree competition, drought, rising temperatures, and insect attacks are beginning to take a toll on 

both plantation and wild stand trees. White pine blister rust has also been killing a number of 

sugar pine over the past ten to fifteen years. Dead and down fuel loadings have been on the rise. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 139 Chapter 3 – Affected Environment 

These conditions are not unique to the Fish Camp area. More extreme examples can be found in 

the Lake Tahoe Basin, San Bernardino National Forest and in Arizona and New Mexico where 

entire stands of trees are dieing. In southern California the amount of ponderosa pine mortality 

associated with western pine beetle, D. brevicomis Le Conte, infestations reached unprecedented 

levels after years of extended drought (Fettig, 2007). 

Recurrent droughts are characteristic of the Sierra Nevada climate. Summers are usually hot and 

dry, with the bulk of the precipitation occurring in winter, much of it as snow. But in addition to 

the dry summers, there have been droughts of one or more years’ duration in every decade of this 

century. Increased mortality usually occurs first at the lower and middle elevations on both 

western and eastern slopes of the range and spreads to the upper elevations only if the drought is 

protracted. During droughts, lack of spring precipitation has a particularly large influence, not 

only by increasing the susceptibility of the trees, as indicated by their rates of growth and beetlecaused mortality, but also probably aiding dispersal of and host selection by the flying beetles. In 

the ponderosa pine type because of the relatively low elevation, water availability, not 

temperature, is the strongest factor limiting forest growth (Ferrell, 1996). 

As stated previously, beginning in the 1970s temperatures began to warm noticeably. Seasonal 

snowmelt and streamflow is projected to occur a month earlier during the current century. By the 

end of the 21st Century, 30 percent less water is anticipated to arrive in reservoirs between April 

and July. Soil moistures will dry out earlier and by summer be more severely depleted. 

Substantial changes in extreme temperature episodes (fewer frosts, more heat waves) are 

anticipated (Dettinger, et al, 2004). Over the past 17 to 29 years noncatastrophic mortality rates 

were found to have doubled over a series of 76 western forest plots which sampled undisturbed, 

200 year and older stands. Increasing mortality rates could result in substantial changes in forest 

structure, composition, and function. –A persistent doubling of background mortality -would 

cause a >50% reduction in average tree age in a forest, and a potential reduction in average tree 

size (van Mantgem, 2009). Current projections of warming climates provide a greater 

opportunity for fire ignitions due to longer fire seasons. A higher probability of fire starts 

coupled with the changes in forest fuel conditions that occurred over the past century lead many 

to predict that large, generally more intense fires will become more likely than occurred 

historically (Skinner and Stephens, 2004). 

Desired Condition 

The Sierra Nevada Forest Plan Amendment Record of Decision, 2004 (SNFPA ROD, 2004) 

addressed the desired condition, management intent and management objectives for individual 

land allocations. These were brought forward in the Fresno River Landscape Analysis (July 

2005) written for the area immediately south of this project. 

The Fish Camp Project boundary encompasses many different land allocations, some with 

specific desired conditions, i.e. spotted owl/goshawk/pacific fisher habitat and some with 

generalized desired conditions. In effect, all center on the need to restore both the structure and 

processes of old forest habitat ecosystems as a long-term strategy and with short-term goals of 

reducing the adverse effect of wildfire and reducing stand susceptibility to insects/pathogens, 

competition and drought-related tree mortality. 

Density Management Measures 

Basal Area Stocking Levels 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 140 Chapter 3 – Affected Environment 

“Normal” basal area stocking is considered to be that level at which mortality begins as additional 

growth takes place. Normal is generally described as basal area per acre and is the maximum 

amount of vegetation an acre can adequately sustain over time. For a short period of time, basal 

areas in excess of “normal” can be maintained in some areas. A normal stand—or fully stocked 

stand—is a stand that, so far as any practical consideration is involved, utilizes its site completely. 

Maximum stocking is not implied; it practically never exists over a continuous area of more than 

a few acres (Meyer, 1938). These “normal” stocking levels were calculated during the 

abnormally wet 20th Century and are most likely too dense to be maintained during the drier 

periods that are more likely the norm. Fairly recent studies have indicated that the exclusion of 

fire may have also resulted in normal basal area densities in excess of what would have been 

found during previous centuries. 

Four different yield tables are being used to determine normal stocking within the Project area: 

 Yield of Even-aged Stands of Ponderosa Pine, Technical Bulletin No 630, Meyer, 1938. 

 Preliminary Yield Table for Second-growth Stands in the California Pine Region, 

Technical Bulletin 354, Dunning and Reineke, 1933 (Mixed Conifer). 

 Yield, Stand, and Volume Tables for White Fir in the California Pine Region, Bulletin 

407, Schumacher, 1926. 

 Growth Models for Ponderosa Pine: I. Yield of unthinned plantations in northern 

California, Research Paper, PSW-133, Oliver and Powers, 1978. 

As stands approach 80 to 90 percent of normal stocking, growth rates begin to decline 

significantly, stand vigor begins to suffer, and susceptibility to insect and disease attacks and 

drought stress increases. To reduce growth losses, maintain more viable stands, and retain 

canopy covers less susceptible to crown fires, this entry would thin stands to stocking levels that 

with growth will result in reaching 80 percent of normal in 15 to 20 years when the next thinning 

entry would need to take place. Utilizing basal area to describe desired stocking automatically 

takes into account varying diameters of trees within stands. For a given basal area, more trees per 

acre are retained in the residual stand in areas with smaller diameter trees than in areas of larger 

trees. The silvicultural prescriptions for ponderosa pine, mixed conifer and fir will be described 

utilizing basal area per acre. 

The desired condition for stocking levels and the measure used for comparison of alternatives is: 

 Average basal area in pine, mixed conifer, and white fir grouped by lightly and heavily 

stocked aggregations 

 Average potential basal area growth 

 Basal area following thinning—ponderosa pine—135 ft2 per acre (45% normal) 

 Basal area following thinning—mixed conifer—210 ft2 per acre (60% normal) 

 Basal area following thinning—white fir—240 ft2 per acre (60% normal) 

Stand Density 

Another approach to stocking density management is Stand Density Index (SDI). This method 

compares stocking density to the maximum number of stems found by species which is 
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Sierra National Forest 141 Chapter 3 – Affected Environment 

substantially greater than that utilized for normal yield. Mortality studies completed in pine stands 

have been described using this density management approach rather than normal yield tables. 

Since SDI was used as a frame of reference for ponderosa pine in these studies, it will be used as 

well as basal area to describe the silvicultural prescriptions for pine stands. SDI studies have 

determined that the onset of competition between trees begins when stands reach 25 percent of 

SDI max. At 35 percent of SDI max the lower limit of full site occupancy and susceptibility to 

bark beetle attack begins, and at 60 percent SDI max is where the lower limit of self-thinning 

begins (normal stocking). Stands that approach SDI 365 usually suffer large losses from bark 

beetle epidemics—losses that equal or exceed periodic growth. The limiting SDI for ponderosa 

pine stands in northern California as defined by Dendroctonus bark beetles is 365 (45 percent of 

SDI max—approximately 200 ft2 basal area). Studies have shown that the vigor of trees in a 

stand is related to their ability to quickly respond to thinning and their susceptibility to various 

pests. A live crown ratio of at least 40 percent has been cited for a number of conifers as 

representing a generally acceptable level of individual tree vigor. For several coniferous species, 

a live crown ratio of 40 percent seems to correspond with an SDI of about 50 percent of the 

maximum SDI for the species. ’Catastrophic’ (extremely high) tree mortality from bark beetles 

can be prevented by reducing stand density below 150 ft2 per acre in basal area (33 percent of 

SDI max) (Long, 1985). To ensure prompt response to thinning and minimize mortality, pine 

stands should be maintained between 30 and a high of 50 percent of SDI max. 

For this proposed project, forested stands would meet stocking (as measured by percent of 

“normal” for the given site) and the associated density levels (as measured by basal area for a 

given site) that would maintain or improve growth rates, would increase resistance to mortality 

agents (insects/pathogens/fire) and would provide the potential to begin the perpetuation of both 

the structure and processes of old forest habitat ecosystems. This desired condition incorporates 

both short and long-term goals, but is focused on the need for continued maintenance of stands 

that are healthy and sustainable. 

The desired condition for Stand Density Index and the measure used for comparison of 

alternatives is: 

SDI—ponderosa pine 30 percent of SDI max (135 ft2/acre) 

 

Methodology for Analysis 

In determining the existing condition and analyzing the effects of the alternatives associated with 

the Fish Camp Project, many sources of information were utilized. These included aerial 

photography interpretation, field verification of stand conditions, cruise plot data validation, 

evaluation and summarization, California Wildlife Habitat Relationship site-specific vegetation 

type correction and verification, and experience in the implementation of similarly designed past 

projects. Scientific and research documentation was utilized to evaluate the potential effects of 

all alternatives and in determining the measures to be evaluated for meeting the purpose and need 

with regards to forest health. 

The SNFPA 2004 describes the use of thinning from below as the primary silvicultural 

prescription to utilize in managing stand densities to provide resiliency and sustainability during 

drought conditions and climate variations. Stand density index and basal area (ft2/acre) are used 

as common measures in determining the effects of management actions on coniferous stands. For 

retention of maximum growth and vigor, thinning entries should be timed to occur before growth 

rates in potential leave trees begin to slow. At this point, leave trees are still retaining substantial 

crown ratios and have the greatest potential for maximum growth. Thinning should be 

undertaken before crown ratios drop below 40 percent (Emmingham, 1983) (Long, 1985). As 
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competition between trees increases, crown vigor decreases. A stand’s ability to respond to 

thinning progressively declines the longer it remains in competition. Some stands proposed for 

treatment are currently at this maximum potential response level while others are beginning to 

decline and should have already been treated. 

For this project stand density (number of stems per acre) as well as basal area (ft2/acre) are used 

to determine which stands/aggregations are considered overcrowded and in need of thinning 

(treatment area designation), at what stocking level the stand/aggregation needs to be (desired 

condition), the silvicultural prescription for each alternative and the associated short (immediate) 

and long-term (length of effectiveness of treatment) effects of design criteria (specifically those 

associated with old forest habitat dependent species), and the effects the standards and guidelines 

and land allocations have on meeting the purpose and need for forest health. 

Alternative 1 – No Action 

Direct Effects 

With this alternative, no commercial or precommercial thinning would be accomplished. 

Understory incense cedar, white fir and brush cover would continue to increase in size and 

density. Fuel ladders and competition between trees would increase. Growth rates and vigor 

would continue to decline as stands, or portions of stands, continue to approach or exceed normal 

stocking. Plantations would become highly susceptible to insect and drought induced mortality. 

Shade intolerant pine and oaks would become less vigorous and continue to drop out of the 

stands. Understocked plantations would not be replanted. 

Indirect/Cumulative Effects 

Wide swings in weather conditions as has been experienced over the past thirty years would 

continue to place increased stress on these untreated stands. Trees in overstocked and/or brush 

choked plantations would continue to experience increased competition. Mixed conifer and fir 

aggregations and stands with stocking levels approaching or exceeding normal would become 

increasingly susceptible to mortality. Excessive stand/aggregation densities in ponderosa pine 

stands and ponderosa and Jeffrey pine plantations would result in the likelihood of heavy 

mortality. Drought and insect induced mortality would escalate. Snags and jack-strawed down 

material would increase. Basal area tree growth of only 15 to 20 ft2 per acre would occur over a 

15 to 20 year period (if excessive mortality does not occur) in more densely stocked aggregations. 

Forest health in the area would decline and elevate the risk of loss due to wildfire. Not only 

would the potential for loss of these stands to insect attack and drought increase, but their ability 

to respond to future thinning would continue to decline as crown vigor deteriorated as treatment 

was postponed. Experience has shown that even a course of no action is not without consequence 

(Fettig, 2007). Taking no action would result in that the Project area continuing to deteriorate 

over time because wildfire today no longer operates in its historical fashion, that of frequent lowintensity surface fires (Fitzgerald, 2005). 

Fuel continuity would not be broken up. Brushfields and over stocked precommercial size 

conifer pockets would not be treated. The threat of fire moving into or out of population centers 

within the Wildland Urban Intermix (WUI) would increase, not decrease. The threat of loss of 

wildlife habitat designated as Protected Activity Centers (PACs), Home Range Core Areas 

(HRCAs) and fisher conservation areas would increase. Agee, 2005, concludes in his report that 

the “No action” alternative is not a risk-free option, as dry climates regularly predispose forests to 

burn in a typical dry summer. He further states that the impacts of “no action” in dry forest 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 143 Chapter 3 – Affected Environment 

ecosystems must recognize the likelihood of stand-replacing, intense fire where stand density has 

increased and dead fuel accumulated in excess of historical levels. 

As no action is being taken by the SNF under the No Action Alternative by definition there would 

be no cumulative effects. See FEIS page 31 for more explanation. 

Alternative 2 – Proposed Action 

Under Alternative 2, the development of Strategically Placed Area Treatments (SPLAT’s) would 

occur. Additional areas would be treated to provide a defensible fuels profile near key 

transportation corridors and adjacent to Yosemite National Park. In addition to those treatments 

needed to meet fire and fuels objectives, treatments would be undertaken to reduce stand densities 

(basal area and/or precommercially thin) to a level that maintains or improves the growth and 

vigor of remaining trees. Treatments included in this alternative are: thinning from below in 

conifer stands (either precommercially or commercially), and/or masticating excess vegetation 

(conifers and brush) to reduce lower, mid- level (intermediates and codominants) canopy stand 

densities; masticating brush and shrub patches; prescribed burning, both understory and piles; 

manually reducing and/or prescribed burning noxious weed infestations; and site preparing, 

planting and subsequently hand releasing failed conifer plantations. 

As part of the Proposed Action, design measures common to all alternatives have been 

incorporated and are part of the Proposed Action. As such, analysis of the direct, indirect and 

cumulative effects of the action alternative addresses not only the Proposed Action, but the 

effects of these design measures as they relate to vegetation and silvicultural management in the 

Project area. 

Direct Effects 

Commercial thinning needs to be undertaken in portions of the approximately 90-110 year old 

young growth stands and 40 to 50 year old plantations to reduce competition and provide room 

for crown expansion by removing poorly growing trees, excess trees, and fuel ladders from these 

stands before competition results in much additional reduction in growth or competition, insect, 

disease or fire related mortality increases. 

 

Studies have shown that active management through thinning is critical to maintaining healthy 

trees that are less susceptible to mountain pine beetle attack. A 1998 study assessed the effects of 

thinning from below (alone and in combination with prescribed burning) on tree growth, leaf 

physiology and several environmental factors in ponderosa pine on the Gus Pearson Natural Area 

in Arizona. Soil water content was greater in thinned treatments than in the unthinned control. 

Similar findings have been reported in northern Arizona and western Montana, and can be 

attributed to increased water availability resulting from decreased tree competition. Trees in 

thinned treatments had greater foliar nitrogen content, needle toughness and basal area increment. 

The results suggest that restoration treatments improved tree vigor, growth and decreased the 

likelihood of bark beetle attacks on individual trees. A similar study compared measures of tree 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 144 Chapter 3 – Affected Environment 

susceptibility to bark beetle attack in thinned ponderosa pine plots in northern Arizona. Phloem 

thickness significantly increased with decreasing stand density. Duration of resin flow and 24 hr 

resin flow were significantly higher in thinned plots. Increases in these variables suggest 

improved host vigor and reduced likelihood of bark beetle attack. An increase in predawn xylem 

water potential, net photosynthetic rate, foliar nitrogen concentration and bud and needle size 

resulting in increasing foliar growth and uptake of water and nutrients was reported in similar 

stands. It has been noted that phloem thickness and basal area increment were lower in 

unmanaged stands than in managed. Studies have shown that thinning significantly reduced the 

amount of ponderosa pine mortality caused by mountain pine beetle in northeastern California 

(Fettig, 2007) (Egan, 2010). The largest increase in photosynthetic rate and predawn water 

potential increases due to thinning was found to be during periods of drought (Feeney, 1998). 

Several studies have shown that thinning from below not only reduces ladder fuels and the risk of 

torching, but by reducing stand density tree vigor is improved and risk to bark beetle attack 

reduced (Fitzgerald, 2005). By reducing competition through thinning, mistletoe infected 

residual trees will experience increased height growth thus slowing the upwards spread of 

mistletoe into tree crowns (Ferrell, 1996). By increasing tree vigor, diseased trees will be better 

able to withstand the effects of drought or insect attack. Based on these scientific studies, 

reducing stand density as part of Alternative 2 treatments would increase tree vigor and reduce 

the risk of bark beetle attack in the Fish Camp Project area. 

This entry would commercially thin wild stands on slopes generally less than 35% outside of 

PACs, and Old Forest Linkages to stocking levels that, with current growth, would result in 

returning stands to 80 percent of normal basal area stocking 15 to 20 years following harvesting. 

Maintaining a stocking level that remains at 80 percent or less of full (normal) stocking will 

ensure a healthy rate of growth while retaining a level of stocking that will be better able to 

survive the lower levels of yearly precipitation that were common prior to the past century. Black 

oaks will be retained in treated stands longer by reducing competition and overtopping by nearby 

conifers. Treated stands would also be less susceptible to weather fluctuations and longer 

summer dry spells which appears to be becoming more and more prevalent. Reentry in 15 to 20 

years was chosen for several reasons: (1) reduce the number of entries into the stand, (2) 

increase the volume removed to make the entry more economically viable, (3) open the stand 

sufficiently to permit harvest operations with a minimum of damage to the residual stand, (4) 

treat the stand to a level where for a period of at least 10 years fires, except under the most 

extreme conditions, would remain as ground fires and not become crown fires as directed by the 

National Fire Plan, (5) retain canopy covers that meet or exceed those directed under the SNFPA 

2004 while opening the canopy to maintain or improve growth and vigor over 15 to 20 years. 

To obtain some benefits from thinning, while retaining species specific canopy cover levels 

following harvest, thinning in wild pine stands is proposed to generally reduce stocking to leave 

basal areas of around 150 to180 ft2

 per acre depending on age, site, and existing crown condition 

(55-60 percent of normal—32 to 40 percent SDI max). This entry would still result in the 

retention of basal areas substantially above the SDI recommendations for thinning. (150 ft2

should be achieved in locations where leave trees have full crowns. 180 ft2

 per acre should be 

achieved in areas with poorer crown leave trees, higher growing sites, older trees and in HRCAs.) 

(Normal stocking for this site and age is 270 to 290 ft2

 per acre.) Portions of stands with larger 

diameter trees present will generally have fewer residual trees per acre than those with smaller 

diameter trees. Because this entry would retain a higher basal area than the desired condition, to 

maintain stand resiliency, the next thinning entry may need to take place at 10 to 15 years in these 

pine stands rather than the planned 15 to 20 as the more limited growing space becomes 

reoccupied. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 145 Chapter 3 – Affected Environment 

The portions of the 40 to 50 year old pine plantations that are planned for thinning would be 

thinned to basal areas of around 120 to 140 ft2

 per acre depending on existing crown condition 

and adjacent openings (40-45 percent of normal--26 to 30 percent SDImax). As previously 

discussed, the onset of competition between trees begins when pine stands reach 25 percent 

SDImax. Thinning to 26 to 30 percent SDImax would permit these thinned portions of the pine 

plantations to continue vigorous growth for a period of 10 or more years at a rate that can 

generally withstand insect attack and the stresses of drought. As these plantations approach the 

planned next thinning entry in15 to 20 years, the limiting SDI 365 would be reached or exceeded; 

they would become more at risk of loss due to insect attack or stress due to competition or 

drought conditions. 

Where diameter restrictions permit, young growth, approximately 90-110 year old, mixed conifer 

and white fir stands would be thinned to around 55 to 65 percent of normal. Leave basal areas, 

depending on site index and age, would be around 210 ft2

 per acre (Mix Confir) and 240 ft2

(White Fir). (Normal basal area stocking for 90 to 110 year old mixed conifer stands on similar 

sites ranges from 330 to 360 ft2

 per acre. Normal for white fir ranges from 420 to 445 ft2 per 

acre). Canopy covers that meet or exceed those directed under the Sierra Nevada Framework 

would be retained following treatment. To obtain maximum growth and reduce fuel ladders, trees 

less than 10 inches dbh trees not needed for stocking or cover for wildlife are planned to be 

removed with this entry within the treatment areas not designated as mastication or prescribed 

fire. Except for mastication equipment, equipment use on slopes greater than 35 percent would 

be avoided. 

Thinning to these target basal areas in these approximately 90-110 year old young growth stands 

would result in basal area increases of 70 to 80 ft2

 per acre over 15 to 20 years. If thinning did 

not occur, this increase in growth over the same time period would be 15 to 20 ft2

 per acre within 

the more heavily stocked aggregations if mortality does not occur. 

As previously discussed, desired leave basal areas would vary by an aggregation species 

composition. Pine aggregations would have a lower leave basal area than mixed conifer. Fir 

would retain the highest. By recognizing the variation in species composition within treatment 

units and treating accordingly, stand heterogeneity would be maintained as varying stocking 

levels are retained across the stand. The North, et al, 2009 paper proposes leaving the highest 

density stocking near the bottom of the slope and the least near the ridgetops. Since fir and mixed 

conifer stands more readily occupy the lower, cooler, damper, locations on the slope, the 

proposed retention basal areas will generally result in heavier stocking on the lower slopes and 

lighter stocking as ridgetops are reached. Wild stand pine aggregations and pine plantations 

would retain the least basal area stocking. 

Except where retained for wildlife purposes (see wildlife design criteria for descriptions), 

suppressed, intermediate, damaged and diseased then finally codominant trees, in order of 

removal, would be harvested until the prescribed stocking level has been reached. This is known 

as thinning from below as directed in the 2004 ROD and recommended in the North, et al, 2009 

paper. The poorest quality trees are generally removed first, leaving, for the most part, the best 

trees in the stand. Thinning from below retains the majority of the crown cover and generally the 

largest trees. Many small, poor crowned trees are removed during the operation. Some poorer 

crowned codominant trees are removed, as needed, to create openings on one or more sides of 

other codominant and dominant trees. These openings provide room for crown expansion of the 

residual trees. Without room for expansion, remaining tree crowns would become less vigorous 

resulting in reduced photosynthesis and declining growth. Removal of only intermediate and 

suppressed trees results in removal of “little more than the salvage of trees which will inevitably 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 146 Chapter 3 – Affected Environment 

die” (Smith,1962). Removal of some of the trees that compete for the limited water and soil 

nutrients would make more water and nutrients available for the remaining trees. Thinning also 

opens the stand’s crown canopy, making more light available for the remaining trees. The 

increased water, nutrients, and light that result from thinning increase photosynthesis in the 

remaining trees. More food is produced making more carbohydrate available for new cell 

formation and growth. After competition begins and the stand develops all crown classes, 

removing only intermediate and suppressed trees may not significantly reduce the competition 

faced by the larger dominant and codominant trees. Suppressed trees, in particular do not 

compete significantly with larger trees. Intolerant species (pines) require nearly full sunlight to 

thrive and grow. A successful low thinning removes all suppressed, most intermediates, many 

codominants, and even some dominant trees (Emmingham, 1983). 

 

The effects of fuel treatments on tree based carbon storage are currently being studied. Healthy 

forests play an important role in carbon sequesterization. Studies indicate that “in wildfire-prone 

forests, tree-based C [carbon] stocks were best protected by fuel treatments that produced a lowdensity stand structure dominated by large fire resistant pines” (Hurteau, 2009). Average stand 

diameters increase significantly following thinning as smaller diameter trees are removed in favor 

of retaining larger trees. Concentrating removal on the smaller diameter trees also reduces fuel 

ladders and susceptibility to fire loss as average residual diameters and fire resistance increases. 

Follow-up treatments to remove submerchantable trees and brush would further reduce stress on 

the remaining stand. In the majority of the stands present, stocking is very heavy to white fir 

(over 60 percent), with incense cedar comprising around 20 percent, sugar pine around 13 percent 

and ponderosa/Jeffrey pine around 7 percent. Where choices exist, more fire resistant pines 

would be favored over fir and incense cedar as leave trees. In most areas, stand composition 

following treatment would consist of a greater percentage of more fire and drought resistant 

ponderosa and sugar pine as recommended in the North paper (2009). 30 inch harvest tree 

diameter limitations dictated by the SNFPA 2004 ROD would, in many areas, result in basal area 

retention levels in excess of proposed residual basal areas. In some cases in pockets of larger 

trees, no trees would be harvested. In these types of thinnings, the smaller size of the product to 

be removed makes harvest operations much more expensive than those where larger trees are 

removed. 

 

Thinning to the proposed basal areas would result in increased diameter growth and crown 

expansion on the remaining trees as the residual trees respond to reduced competition. Since 

increased diameter growth would occur over fewer stems per acre, substantial increases in 

diameter would result. Thinning would result in larger diameter, taller, healthier crowned trees 

over much shorter time frames than in unthinned stands. Shade intolerant pines and oaks would 

be retained in a more vigorous condition as a result of more available sunlight due to reduced 

competition. To assist in the retention of oaks within plantation treatment units, an average of 

one black oak, 4-12 inches dbh, for every five acres would receive additional clearing on the 

south side of the tree to reduce competition (as described in wildlife design criteria section). As 

the diameters of the residual trees become larger and bark becomes thicker, they would become 

better able to survive a fire should one occur Thinning is an effective technique for creating 

stands that more closely represent those present prior to railroad and other extensive logging and 

the exclusion of fires during the 20th Century which is the desired condition. 

Hand and mastication thinning and release of natural stands/aggregations of conifers and 

plantation trees generally less than 10 inches dbh would be undertaken within treatment units as 

part of this proposal. These thinned aggregations would occupy large and small openings 

surrounded by larger trees as described in the North paper (2009). Depending on tree size these 

stands would be thinned to around 150 to 200 leave trees per acre. Hand thinning slash 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 147 Chapter 3 – Affected Environment 

concentrations would generally be tractor piled and piles burned. Slash concentrations on steeper 

slopes would generally be hand piled and burned. Areas of only light slash (10-20 tons per acre) 

would be lop and scattered to 18 inches. Stand heterogeneity would be maintained through 

retention of these precommercially thinned clumps as well as untreated clumps on steeper slopes, 

the more dense clumps of larger diameter trees, SMZ’s, archaeological sites, and the two to three 

untreated larger oaks per acre. In addition, shrub and understory diversity would be retained 

throughout the Project area during follow-up treatments through the retention of 15-20 percent of 

the total understory growth in approximately 1/10th acre pockets within plantation treatment units 

and 1⁄4 acre pockets within wild stand treatment units. 

 

 

Indirect Effects and Cumulative Effects 

Of the 5440 acres within the proposed project boundaries, approximately 1200 acres, comprised 

of a number of smaller treatment areas, are being analyzed for treatment as a part of this EIS, the 

remainder of the Project area is not proposed for treatments and will retain its present CWHR 

classifications. An additional 142 acres of 17 to 20 year old plantations have been recently 

released and pre-commercially thinned by mastication under a existing document. Within 

HRCAs (Home Range Core Areas) and Old Forest Linkages the aim as stated in the SNFPA 2004 

is to retain 60 percent or greater canopy cover, where available. (The intent of the Fish Camp 

project is to retain canopy cover of 60 percent or greater in CWHR 4 and 5 size classes where it 

presently exists.) Within those portions of Spotted Owl and Goshawk PACs (Protected Activity 

Centers) where thinning is proposed, the aim is to retain 70 percent or greater canopy cover, 

where available. The vast majority of the Project area would not be treated as a result of these 

past or proposed treatments. Under this alternative, vegetation present in these untreated areas 

would remain the same as presently found and therefore there would be no effect to vegetation in 

the untreated acres. 

In addition to the denser canopy cover proposed for Old Forest Linkages, groups or patches of 

five or more larger trees, generally 30 inches and larger, are planned to be retained through the 

Project area. These small groups would have residual basal areas of 240 ft2

 or more for mixed 

conifer and 210 ft2

 or more for pine and in many instances may reach 300 to 400 ft2 per acre. No 

fuel ladder or precommercial thinning treatments would occur within these pockets. 

Approximately two to three black oaks 20 inches dbh and larger per acre would also have a 35 

foot buffer, measured from the bole, around them where no fuels treatment would occur. 

Retention of these higher basal areas to provide denser canopy cover for wildlife would result in 

not fully meeting the silvicultural objectives for maintaining or improving forest health. The 

impact would not be as great in mixed conifer and fir stands as it would be in pine. Retaining 60 

percent or greater basal area in pine stands leaves them at a level where SDI studies have shown 

them to be susceptible to insect attack. Pine stands left at 70 percent or greater would remain at 

SDI max levels of 50 percent or greater (SDI 400 or more) and will be highly susceptible to insect 

attack. Oliver, 1995, stated that a SDI 365 (200 ft2/acre), defines the threshold for a zone of 

imminent bark beetle mortality where pine stands suffer large losses from bark beetle epidemics. 

These losses can equal or exceed periodic growth. This said, there is a potential for greater snag 

creation within these pockets to serve as future wildlife habitat while also maintaining structural 

diversity and heterogeneity throughout the treatment units. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 148 Chapter 3 – Affected Environment 

Subsequent growth of these stands would add further to the problem. Sufficient thinning would 

occur in some of the proposed scattered clumps to provide a short term benefit to stand vigor 

while in other clumps little, if any, thinning would occur resulting in a continued decline in clump 

vigor. Pine clumps left at these higher basal area retention levels would continue to be at a very 

high risk of loss due to insect, disease, competition, and/or drought induced mortality. A 2004 

report found that plots infested by mountain pine beetle had significantly higher total basal area, 

ponderosa pine basal area, stem density and stand density index (Fettig, 2007). Heavily stocked 

pine clumps attacked by insects have the potential to serve as infection centers for increased 

mortality in the surrounding pine stands as insect populations build and move into adjacent 

stands. To maintain more vigorous, drought and insect resistant stands, a shorter reentry period 

would be needed. The reentry time frame within HRCA, PAC, and Old Forest Linkage pine 

stands and these more heavily stocked clumps would likely be reduced by five or more years. 

Since the vast majority of the crown covers and ground cover would remain in place following 

thinning operations, properly conducted thinning has only a minor short term affect on tree 

growth. Leave trees would continue to contribute needles as well as small branches to the forest 

floor. Long term effects would be to maintain or increase growth and vigor of treated stands, 

accelerate development of old forest characteristics in plantations, and improve the protection of 

human communities from wildland fires as well as minimize the spread of fires that might 

originate in urban areas. Over the past eighteen years, the district has planned and completed 

several projects, treating several thousand acres, similar to the Proposed Action. Observations 

after these treatments has shown canopy cover retention following harvest has met or exceeded 

expectations. Residual crowns have rapidly filled in openings created by harvest treatments. 

In addition to the benefits obtained through density management several other benefits have been 

noted in treated stands. Several studies have shown that in addition to increasing residual tree 

vigor, increasing temperatures and windspeeds are common in recently thinned stands. This may 

accelerate development of certain bark beetle species and force them to overwinter in stages that 

are more susceptible to freezing or cause turbulences that disrupt pheromone plumes used for 

recruiting conspecifics during initial phases of host tree colonization (Fettig, 2008). Moderate 

thinnings may result in less potential extreme fire behavior compared to unmanaged stands. 

Greater fuel depths, mid–flame wind speeds and lower fuel moistures in heavily treated stands 

(>60 percent basal area reduction) might increase potential fire behavior compared to unmanaged 

stands. Thinning followed by sufficient treatment of surface fuels usually outweighs changes in 

fire weather factors (wind speed and fuel moisture) resulting in an overall reduction in expected 

fire behavior (Jenkins, et al, 2008). Thinning followed by tractor piling and burning or whole tree 

yarding have been shown to be effective in reducing fire severity under severe fire weather 

conditions. Thinning from below where the largest trees are retained within the stand contributed 

to increased fire resistance (Stephens, 2009). Thinning makes fire suppression more efficient. 

Once heavy fuels are removed, the residence time (duration) of the fire is reduced, often resulting 

in a non-lethal surface fire (Fitzgerald, 2005). The thinning proposed within the Fish Camp 

project is designed to reduce existing basal area by generally 30 percent or less. Follow-up 

treatments are designed to remove fuel ladders as well as slash concentrations. This relatively 

light level of thinning should both realize the benefits of thinning stands to reduce the adverse 

effect of bark beetles and competition while reducing expected potential fire behavior. 

Alternative 3

This alternative proposes to only remove submerchantable fuel ladders/fuels and precommerically 

thin throughout the wild stand treatment areas. Plantations would be commercially and 

precommercially thinned to only 20 inches dbh and fuels treated. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 149 Chapter 3 – Affected Environment 

Direct Effects 

No density management would be accomplished with this alternative in wild stands. In wild 

stands, fuel ladder removal would occur on suppressed and a very few intermediate trees only. 

No codominant trees would be removed. 95 to 100 percent of the existing basal area 10 inches 

dbh and larger would remain. The percentage of less drought resistant, more fire prone incense 

cedar and fir would remain the same as the existing condition. The average stand diameter would 

not change. Shade intolerant pine and oaks would become less vigorous and continue to drop out 

of the stands. Post treatment stocking levels would be too dense to withstand the stresses of 

drought and weather variances. 

Plantations would be thinned to a maximum of 20 inches dbh. In some areas of smaller diameter 

trees, thinning to 20 inches would remove most of the competing conifers. In others, 

aggregations would remain densely overstocked since the smaller diameter trees needing removal 

to meet residual density objectives exceed 20 inches dbh. These areas of excessive stocking 

would be highly susceptible to insect or drought induced mortality. Once successfully attacked 

by bark beetles, they would serve as dispersal points for additional mortality occurring in the 

adjoining stand, potentially resulting in large portions of these pine plantations suffering insect 

attack and subsequent mortality. 

As stated previously, Smith, 1962, stated that removal of only intermediate and suppressed trees 

results in removal of “little more than the salvage of trees which will inevitably die”. 

Emmingham, 1983, stated that a successful thinning from below requires the removal of many 

codominants as well as most intermediates and suppressed trees. Under this alternative, fuel 

ladder reduction only dealing with precommerical trees would not remove any significant levels 

of competition to meet density management objectives. Removal of only some suppressed trees 

and little to no intermediates would not provide any significant increase in nutrient or water 

availability to the residual stand. Not only would there not be a significant increase in available 

nutrients or water, failure to remove some of the codominants and intermediates growing into the 

bottom portion of the codominant layer of the stand will not create openings in the canopy to 

provide room for crown expansion of the residual trees. Shade intolerant oaks and pines will not 

be able to benefit from increased light and rates of photosynthesis as well as reduced competition 

provided by openings created in the canopy cover. This alternative does not meet the purpose 

and need for density management emphasized in the SNFPA, 2004 decision and being examined 

as a part of this project. 

Indirect and Cumulative Effects 

Wide swings in weather conditions as has been experienced over the past thirty years would 

continue to place increased stress on these untreated wild stands and dense aggregations in 

plantations. Mixed conifer and fir aggregations and stands with stocking levels approaching or 

exceeding normal would become increasingly susceptible to mortality. Excessive 

stand/aggregation densities in ponderosa pine stands and ponderosa and Jeffrey pine plantation 

aggregations of larger trees would result in the likelihood of heavy mortality. Drought and insect 

induced mortality would escalate. Snags and jack-strawed down material would increase. Basal 

area tree growth of only 15 to 20 ft2 per acre would occur over a 15 to 20 year period (if excessive 

mortality does not occur) in more densely stocked aggregations. Forest health in the area would 

decline and elevate the risk of loss due to wildfire. Not only would the potential for loss of these 

stands to insect attack and drought increase, but their ability to respond to future thinning would 

continue to decline as crown vigor deteriorated as treatment was postponed. Experience has 

shown that even a course of no action is not without consequence (Fettig, 2007). Doing little to 

nothing to reduce stand density would result in forests that continue to deteriorate over time. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 150 Chapter 3 – Affected Environment 

Fire/Fuels _______________________________________ 

The direct, indirect and cumulative effects to wildland fire and fuels are summarized from the 

Fire/Fuels Report for the Fish Camp Project (Smith,GB. 2010). 

Introduction 

Presettlement fire strongly influenced the structure, composition and dynamics of most Sierra 

Nevada ecosystems. In many areas frequent surface fires are thought to have minimized fuel 

accumulation, keeping understories relatively free of trees and other vegetation that could form 

fuel ladders to carry fire into the main canopy (Sierra Nevada Ecosystem Project [SNEP], 1996). 

Forest structure and species composition in many western U.S. coniferous forests have been 

altered through fire exclusion, past and on-going harvesting practices, and livestock grazing. The 

effects of these activities have been most pronounced in seasonally dry, low and mid-elevation, 

coniferous forests that once experienced frequent, low to moderate intensity fire regimes. 

Increased stand density, decreased overall tree size, and increased surface fuel loads are well 

documented for many forests of this type (Stephens, S. et.al., 2009). These changes concern fire 

managers because the increased fuel loads and altered forest structure have made forest 

vulnerable to fire intensities and severities outside of the desired conditions and outside of 

historic fire regimes for these ecosystems. Changing climates in the next several decades may 

further complicate fire management by increasing temperatures and fire season length (Stephens, 

S. et.al., 2009). Fires now occur less frequently and cover much less area, but are likely to be 

large and severe when they do occur (SNEP, 1996). 

Fire represents both one of the greatest threats and one of the strongest allies in efforts to protect 

and sustain human and natural resources in the Sierra Nevada. Residents and visitors alike are 

well aware of the threats posed by summer wildfires. A growing density of homes and other 

structures coupled with the increased amount and continuity of fuels resulting from twentiethcentury fire suppression have heightened concern about threats to life and property, as well as the 

health and long-term sustainability of forests, watersheds, and other natural resources. Yet fire 

has been an integral part of the Sierra Nevada for millennia, influencing the characteristics of 

ecosystems and landscapes. Today, state, federal and local agencies put enormous resources into 

efforts to reduce fire occurrence while at the same time advocating the need to use fire to promote 

healthy ecosystems. The challenge faced is how to restore some aspects of a more natural fire 

regime while at the same time minimizing the threat wildfire poses to human and natural 

resources and values (SNEP, 1996). 

The Fish Camp Project objectives are to: (1) reduce fuel ladders and excessive ground fuels that 

pose a potential for the propagation and sustainability of a crown fire, (2) minimize the effects of 

wildland fire in high risk (probability of ignition occurring), high hazard (availability of fuels to 

sustain a fire) wildland urban intermix area, (3) increase the vigor and health of mixed conifer 

stands and plantations, and (4) prevent and control the spread of noxious weeds. 

This analysis evaluates the direct, indirect and cumulative effects of proposed Alternative 2 and 3 

to meet the purpose and need of the Fish Camp Project as well as the No Action Alternative l, as 

they relate to fire and fuels. Indicators are presented to evaluate and compare alternatives and the 

resultant fire behavior/fire effects associated with their implementation. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 151 Chapter 3 – Affected Environment 

Overview of Issues Addressed 

Issues relevant to Fire/Fuels 

Presettlement fire strongly influenced the structure, composition and dynamics of most Sierra 

Nevada ecosystems. Fire not only interacts with the physical, but the living components of the 

ecosystem (Sugihara, N., et. al., 2006). The only portion of the fire behavior “triangle” that can 

be intervened with is fuels by managing vegetation (Sugihara, N., et. al., 2006). But how can fire 

be placed back into the ecosystem, if the potential resultant fire (whether management ignited as 

prescribed fire or natural-caused) is of higher intensity and severity than it was historically 

because of the unnatural accumulations of fuels? Although there is relatively little understanding 

of the ecological effects of fuel treatments, in particular the extent to which mechanical 

treatments might emulate natural ecological processes such as fire (Stephens, S., 2009), they can 

be effective tools to modify stand structure and influence subsequent fire severity and extent. 

These mechanical treatments are often a required first treatment in forests containing excessive 

fuels loads (North, M., 2009). 

This Fish Camp Project analyses the effect of treatment within the units. This analysis measures 

the combination and balance of the alternatives designed to meet the purpose and need of the 

project. The analysis measures if fuel loadings are reduced to where wildfire effects are 

moderated and where there is an ability for low intensity fire (by prescribed fire in the short term) 

to be re-introduced into a fire dependent ecosystem. Also considered in this analysis is whether 

the alternatives and the treatment intensities proposed allow for forest resiliency while providing 

for the forest structure diversity needed for wildlife habitat. 

Creating Fire Resistant Forests 

Fire resistant forests combine fire resistant tree species suitable to a site in a spatial arrangement 

that discourages surface fires from moving to the crowns. Crowns are made more resistant to fire 

by reducing surface and ladder fuels as well as increasing the height of the base of the canopy. 

Canopy Base Height (CBH) – 

 Is the lowest height above the ground at which there is sufficient canopy fuel to 

propagate fire (Van Wagner, 1993); 

 Is the average crown base height for the stand; 

 Is the lowest 20th percentile of all crown base heights in the stand (Hoffman 2005, Fulé 

et al. 2001, 2002); 

 The height at which a minimum bulk density of fine fuel (30 lb/acre/ft, 0.011 kg/m3 ) is 

found (Reinhardt and Crookston, 2003); 

 CBH is the lowest height above the ground at which there is sufficient canopy fuels to 

propagate fire vertically through the canopy (Scott and Reinhardt, 2001). 

Also decreasing the crown density and removing smaller trees while retaining larger more fire 

resistant trees reduces the risk of crown fire. Table 38 below displays recommendations for 

Table 32: Principles of Fire Resistant Forests. Adopted from Agee 2002 by Graham 

et. al. 2004 

Recommendation Physical Effects Fire Advantage Concerns 

Reduce surface and 

ladder fuel 

Reduces potential flame 

length 

Fire control easier, less 

torching 

Surface disturbance less with 

fire than other techniques 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 152 Chapter 3 – Affected Environment 

Recommendation Physical Effects Fire Advantage Concerns 

Increase canopy base 

height 

Requires longer flame 

length to ignite tree 

crowns 

Less torching Opens under story, may 

allow surface wind to 

increase 

Decrease crown density Makes independent 

crown fire less probable

Reduces crown fire 

propagation 

Surface wind may increase, 

surface fuel may be drier 

Retain larger trees Thicker bark and taller 

crowns 

Increases survivability 

of trees 

Removing only smaller trees 

is economically less feasible

Retain fire resistant tree 

species 

Promotes trees most 

likely to survive fires 

Reduces mortality from 

future fires 

Repeated treatments may be 

necessary to promote desired 

trees 

The table above is displayed in this report to assist in demonstrating the types of treatments 

proposed to achieve the purpose and need of the Fish Project, the physical effects, fire advantage 

and concerns associated with each recommended means to affect fire behavior. The following 

associates the predicted fire behavior results of each level of treatment proposed by this and all 

action alternatives. 

Fire Behavior Indicators 

Analysis Indicators Measured - The SFNPA ROD, 2004 includes specific characteristics 

(indicators) of fire behavior as desired conditions for fuels treatments. These are used as the 

“indicators” in this analysis. These include: 

Fire Behavior Characteristics Indicators: 

 Existing and Resultant Fuel Model 

 Existing and Resultant Average Rate of Spread 

 Existing and Resultant Average Flame Length 

 Existing and Resultant Average Fireline Intensity 

 Existing and Resultant Crown Fire Potential 

 Existing and Resultant Resistance to Control 

 Existing and Resultant Average Tons per Acre of Surface Fuels 

 Existing and Resultant Average Mortality in Ponderosa Pine red and white fir conifers 

(average size existing 10” dbh; post treatment 30” dbh) 

Affected Environment 

Existing Condition 

The Fish Camp Project area encompasses 5 distinctive vegetation complexes. These include: (1) 

conifer plantations, (2) mixed conifer stands, (4) true fir conifer stands and/or (5) a combination 

of these. These vegetative complexes are results of various processes including wild fires, 

effective fire suppression efforts, turn of the century timber harvesting and reforestation efforts. 

Fire Behavior in Current Fuel Loading - The Fish Camp Project area has three dominant 

arrangements of fuels that influence fire behavior. These are: ground, surface and crown fuels. 

Ground and surface fuels can be described utilizing Rocky Mountain Research Station Fuel 

Models (Scott and Burgan, 2005) for estimating fire behavior. This is used to aid in describing 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 153 Chapter 3 – Affected Environment 

the type and average amount of fuel given a particular fuel type and the prediction of the type of 

fire behavior expected under certain weather and topographic conditions. Crown fuels are 

generally described in relationship to the density of crowns (canopy bulk density) and their height 

above the surface fuels (canopy base height). 

Surface Fuels: Ground and surface fuels within the Fish Camp project vary throughout the 

project. The ground and surface fuels within plantations or where poor regeneration has occurred 

and areas consisting of mixed conifer stands located on the south and southwest facing slopes of 

the lower reaches of the Project area can be best described using a Fuel Model SH2. A Fuel 

model SH2 is described as dry climate woody shrubs’ and shrub litter with moderate fuel load. 

The ground and surface fuels within the mixed conifer and true fir stands that do not have brush 

as the main understory component fall into four Fuel Models TL8 (long needle pine litter), and 

TL3 (conifer needle litter), TU5 (conifer litter with shrub understory), and SB2 (activity fuels and 

scattered blowdown from wind damage with many trees still standing). The difference between 

these four fuel models comes from the increasing amounts of ground and surface fuels. 

Fuel Model TL3 is described as the lighter amount of ground and surface fuels associated with it 

and is used to describe the true fire stands in the higher elevations of the Fish Project that have 

not started to deteriorate from drought stress and/or overcrowding and the trees have not begun 

to fall on their own. Estimated surface fuel loadings average is between 3 and 8 tons per acre. 

Fuel models TL8 describes where there are areas where there is a moderate fuel load small 

saplings and suppressed trees have begun to fill in the understory of larger trees. Estimated 

surface fuel loadings average is between 5 and 10 tons per acre. 

Fuel Model TU5 and SB2 are used to describe conifer stands where natural fuel and activity 

generated accumulations of ground and surface fuels are beginning to increase. These surface 

fuels are of larger size, mostly 3+” in size and can increase the intensity of surface fires within the 

area. These fuels include not only the branches and needles of fallen trees, but also include the 

boles, increasing the tons/acres of natural fuels on the ground rapidly. Surface fuel loadings in the 

Fish Camp Project area that are representative of Fuel Model TU5 average between 12 and 25 

tons per acre. Surface fuel loadings that are representative of Fuel Model SB2 average between 

15 and 30 tons per acre. 

Crown Fuels: The crown fuels in the Fish Camp Project area can be described in two ways, 

crown fuels that can lead to the propagation of a crown fire and the crown fuels available to 

sustain a crown fire. There are two elements that need to fall into place for a crown fire to start 

and for it to sustain itself, fuel ladders (vegetation that “stair-steps” up in height and can allow a 

fire to reach the crowns of trees) and canopy density (in simple terms, how close together 

individual tree crowns are, usually given as a percentage of space taken up by the tops of trees).

In the Fish Camp Project area, fuel ladders are heavy and continuous, consisting of regeneration 

of conifers and brush in plantations and of natural regeneration of conifers (mainly white fir and 

incense cedar). These fuel ladders start at the surface layer and have grown to the point of having 

a continuous “stair-step” of available fuels into the bases of the canopy trees. 

The canopy fuels in the Fish Camp Project area are varied from open to heavily closed 

(approximately 100% canopy closure). Areas where there is a combination of heavy, continuous 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 154 Chapter 3 – Affected Environment 

fuel ladders and canopy closure is closed (interlocking of crowns in the canopy) the potential for 

initiation and sustainability of a crown fire is the greatest. 

Wildland Urban Intermix (WUI): Communities (wildland urban intermix zones) surrounding 

the Project area have been rapidly developing over the last several years. Adjacent the Southeast 

border of the Fish Project is the community of Fish Camp with scattered residences and 

businesses along the Highway 41 corridor. Fish Camp also includes the Teneya Lodge (a popular 

visitor destination outside of Yosemite National Park). To the Northeast is Yosemite West a 

residential area and Wawona in Yosemite National Park. To the north and Northeast is the South 

entrance to the Yosemite National Park wilderness and Mariposa Grove (a high interest attraction 

for Yosemite Park visitors.) To the northeast and east is private property. To the South and 

Southeast of the Fish Project area lie the communities of Sugar Pine and Cedar Valley and Nelder 

Grove Historical Area of giant sequoia. 

With the continuity of the fuels within the Fish Project area, a wildland fire originating from 

along Highway 41or Forest Service designated roads, under the right conditions, has the potential 

to spread northward or eastward to the community of Fish Camp, Yosemite National Park and/or 

Mariposa Grove. 

Desired Condition 

The Sierra National Forest LRMP identifies two related broad goals of the old forest and 

associated species conservation strategy, which are to: a) protect, increase, and perpetuate desired 

conditions of old forest ecosystems and conserve species associated with these ecosystems while 

meeting people’s need for commodities and outdoor recreation activities; b) increase the 

frequency of large trees, increase structural diversity of vegetation, and improve the continuity 

and distribution of old forests across the landscape. A key element in this strategy includes: a 

proactive approach for improving stand health and vigor with management objectives to reduce 

susceptibility of forest stands to insect and drought related tree mortality by managing stand 

density levels. The forest-wide standard and guidelines state that “vegetation within treatment 

areas should be modified to meet desired surface and ladder, and crown fuel conditions as well as 

stand densities necessary for healthy forests during drought conditions”. 

The SNFPA ROD, 2004 establishes a desired condition for each land allocation. In particular, the 

desired condition for each land allocation incorporates how and what type of vegetation 

complexes are desired for each. These are referenced in short and long term conditions and are 

influenced by the temporal and spatial influences of fire. The land allocations and their specific 

desired conditions used in this report include: 

General Forest: (SNFPA ROD, 2004; page 48) 

Desired conditions for the general forest allocations are identical as those described for the old 

forest emphasis areas. 

 Forest structure and function generally resemble presettlement conditions. 

 Multi-tiered canopies particularly in older forest provide vertical heterogeneity. 

 Where possible, areas treated for fuels provide for the successful establishment of early 

seral stage vegetation. 

Wildland Urban Interface: 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 155 Chapter 3 – Affected Environment 

Defense Zone (SNFPA ROD, 2004; page 45) 

 Stands are fairly open and dominated primarily by larger, fire tolerant trees. 

 Surface and ladder fuel conditions are such that crown fire ignition is highly unlikely. 

 The openness and discontinuity of crown fuels, both horizontally and vertically, result in 

very low probability of sustained crown fire. 

Threat Zone (SNFPA ROD, 2004; page 46) 

Under high fire weather conditions, wildland fire behavior in treated areas is characterized as 

follows: 

 flame lengths at the head of the fire are less than four feet; 

 the rate of spread at the head of the fire is reduced to at least 50 percent of pre-treatment 

levels; 

 hazards to firefighters are reduced by managing snag levels in locations likely to be used 

for control prescribed fire and fire suppression consistent with safe practices guidelines; 

 production rates for fireline construction are doubled from pre-treatment levels; and 

 tree density has been reduced to a level consistent with the site’s ability to sustain forest 

health during drought conditions. 

Fuels treatments outside of the WUI and within other land allocations are to establish and 

maintain a pattern of area treatments that is effective in modifying wildfire behavior (SNFPA 

ROD, 2004; page 35). There are specific means and conditions by which treatments can be 

conducted within some land allocations because of maintaining habitat needs as well as 

perpetuating such conditions (i.e. old forest emphasis areas). 

The Forest Service’s primary responsibility and objective for structure fire protection is 

to suppress wildfire before it reaches structure. (Forest Service Manual, 5137.02). The spatial 

arrangement of stands and homes is crucial to the success of fuel management activities in 

changing the effects of large fires either at the local or landscape scale. (Finney and Cohen, 

2003). Thinning trees to produce gaps in the flame front significantly reduces radiant exposure, 

and that a firefighter’ s maximum radiant exposure is well below exposures necessary for piloted 

wood ignitions. The defensible space requires more vegetation fuel hazard reduction than fuels 

reductions required for preventing piloted wood ignitions. (Cohen and Butler, 1996). Agency 

WUI fuel treatment largely do not address home ignitability but rather areas outside the home 

ignition zone. Fuel treatment in the vicinity is expected to protect homes by creating conditions 

that enable successful fire suppression if a wildfire would to occur. Preventing WUI fire disasters 

require the problem be framed of home ignition potential. Because this principally involves the 

home ignition zone, the home ignition zone primarily falls within private ownership, the 

responsibility for preventing home ignition largely falls within the authority of the property 

owner (Cohen, 2008). 

Environmental Consequences 

Methodology 

Assessment of Fuel and Stand Structure - Aerial photography (2007) of the Fish Camp Project 

area was initially used to determine fuel type (shrub, brush, timber litter, and slash/windblown) 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 156 Chapter 3 – Affected Environment 

within the Project area. Due to the variability of conditions throughout the Project area, The 

Rocky Mountain Research Station Fuel Models (Scott and Burgan, 2005) was used to determine 

which stratum of surface fuel was most likely to carry the spreading fire. These fuel models were 

used to represent the average conditions within in each fuel type represented in the area. Because 

these fuel models have associated fuel loading for each time lag fuel category (1, 10, 100-hour 

fuels) and live fuel loadings, field ocular verification and timber cruise plot data, that included 

recording of ground and surface fuels utilizing the Photo Series for Quantifying Forest Residues 

in the Sierra Mixed Conifer Type and Sierra True Fir Type (General Technical Report PNW-95, 

October 1997), was used to adjust and/or include additional fuel models to represent the average 

fuel loading conditions existing within the Project area. 

Predicted Fuel Model Conversion - In assessing the effects of future conditions in the no action 

alternative and the action alternatives, fuel models were chosen to represent the predicted fuel 

group and average post treatment conditions by fuel group being treated. It was assumed that 

treatments would move existing conditions from one fuel model to another, but remain within the 

same fuel group (i.e. a Fuel Model TU1, Timber Group would post treatment convert to a Fuel 

Model within the Timber Group). For the shrub group, dependent on the type of treatment, it 

may be converted from the shrub group into any of the fuel groups. Studies within the Sierra 

Nevada range and similar to those existing and resulting from the Fish Camp treatments 

proposed (Kaufman, 2002; Stephens, S., 2009; USDA Forest Service, PSW, 2001) were used to 

determine and verify the fuel models chosen as well as field verification in areas on the district 

where similar treatment prescriptions have been implemented 

Crown Fire Prediction - In order to determine the potential for crown fire initiation and/or the 

type of crown fire (if initiated), average canopy bulk density as well as average canopy base 

height were needed for stands within the Project area. Tree list were developed utilizing timber 

cruise sample plot data collected within the Project area and processed through the Forest 

Vegetation Simulator program for verification. The collected data was for trees over 10 inches in 

diameter (dbh) only. Utilizing studies conducted within the Sierra Nevada Range and in similar 

conditions as that within the Project area (Kaufman, 2002; Stephens, S., 2009; USDA Forest 

Service, PSW, 2001) average existing and post treatment canopy characteristics were determined. 

Average canopy base heights were based on measured tree heights, stand position and field 

verification for both existing and post treatment condition. 

Modeling For Potential Fire Behavior and Fire Effects -Modeling of potential fire behavior and 

the resultant intensity and severity of such fire behavior requires several inputs for calculation. 

These include, but are not limited to fuel, weather and topography conditions of the area being 

analyzed. These conditions can change slowly over time and space or can change rapidly. For 

this analysis, conditions (except for fuel model) were held constant and were based on what are 

considered 90th percentile weather conditions for the Project area. Ninetieth percentile 

conditions, as used here, is representative of the high fire weather conditions under which wildfire 

behavior in treated areas is to be characterized for desired conditions (SNFPA ROD, 2004; page 

46). 

Fire Family Plus (a program used for analyzing historic weather and fire danger rating records) 

was used to determine what 90th percentile weather conditions are from representative Remote 

Automated Weather Station (RAWS) historic weather records. Twenty years of recorded weather 

data (1990-2010) from the Batterson and Minarets RAWS were analyzed. Conditions analyzed 

and used were: 1-hour, 10-hour and 100-hour dead fuel moistures, live fuel moistures, air 

temperature, and windspeed. Because treatments are proposed on slopes generally less than 35 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 157 Chapter 3 – Affected Environment 

percent, an average slope of 20 percent was used for fire behavior modeling. It is assumed that 

with an increase in slope percentage, fire spread and intensity would increase. 

Fire behavior was modeled, for existing, short term conversions and post activity treatments, 

using BEHAVE Plus 5 and Nexus. BEHAVE Plus 5 was used to model surface fire behavior for 

the initial fuel models selected for existing, short term conversions and post activity treatment 

conditions as well as the predicted mortality of conifers within the stands given the constant 

weather conditions and the representative fuel bed. Nexus was used to model both surface and 

crown fire. The modeled results were compared to observations made of past wildfires burning 

under the same conditions and same fuel models to determine if modeled results were 

representative and/or realistic 

The inputs utilized for this analysis are; 

 Fuel Models: SH2, TL3, TL8, TU5, and SB2 (for existing 

conditions) 

1-hour Fuel Moisture (%): 3 

10-Hour Fuel Moisture (%): 4 

100-Hour Fuel Moisture (%): 6 

Live Woody Fuel Moisture 

(%): 

80 

Foliar Moisture (%): 80 

Air Temperature (%): 80 

20 foot Windspeed (mph):

Wind Reduction Factor:

15 

 0.3 

Canopy Bulk Density (lb/ft3): 0.0119 and 0.0874 

Canopy Base Height (feet): 10 and 20 For timber 

0.1 and 5 For brush 

Slope (%): 20 

Analysis Indicators Measured - When interpreting fire behavior and predictions, guidelines or 

“trigger-points” have been established to determine the most effective means or resources that 

should be used on fires based on rates of spread, flame length and fireline intensity that are 

observed or predicted for given conditions. Intuitively, a resource(s) used to suppress a fire must 

have line building capability faster than the rate of spread to be effective in stopping the fire’s 

spread. Rate of Spread, flame length and fireline intensity determine which type of resources and 

how “close” to the fire they can attack it. These effects result to the resistance to control or the 

difficulty to control a fire. Resistance to control relates the difficulty of constructing and holding 

a control line as affected by resistance to line construction and by fire behavior. Because every 

fire is different these are used as general guidelines in assisting fire managers in determining 

appropriate tactical decisions. The tables below displays trigger points for

Table 33: Adapted from How to Predict the Spread and Intensity of Forest and Range 

Fires. Richard C. Rothermel, 1983 and Rocky Mountain Research Station Fuel Models, 

Scott and Burgan, 2005

ROS (Ch/h) 

Flame 

Length 

(Feet) 

Fireline 

Intensity 

(Btu/ft/s) 

Interpretations 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 158 Chapter 3 – Affected Environment 

ROS (Ch/h) 

Flame 

Length 

(Feet) 

Fireline 

Intensity 

(Btu/ft/s) 

Interpretations 

0 - 5 <4 <100 

Fire generally can be attacked directly at the 

head or flanks by using hand tools. Use of hand 

crews with tools is effective. 

Hand line should hold fire. 

5-20 4-8 100-500 

Fires are too intense for direct attack at the head 

of the fire by persons using hand tools. 

Hand line cannot be relied on to hold fire. 

Equipment such as fire engines, dozers, and 

aerially delivered fire retardant can be effective 

in control efforts on the fire. 

20-50 8-11 500-1,000 

Fires may present serious control problems as 

the following can be expected in forests: 

torching of trees, initiation and spread via a 

crown fire, and the occurrence of spot fires up in 

front of the main fire. 

Control efforts at the head of the fire will 

probably be ineffective. 

50-150 >11 >1,000 

Crowning, spotting, and major fire runs are 

probable. Fire usually spreads via rapid runs in 

surface fuels and crown fires in timber stands. 

Major fire spread and spotting 1 to 2 miles in 

front of the main fire is expected. 

Control efforts at the head of the fire are 

ineffective. 

To measure the degree of change between existing and resultant conditions between alternatives, 

the table above and an adjective class guide below was used as a guide to quantify the spread 

rates, flame length, fireline intensity and resistance of control. These guides rates the rates of 

spread, and flame lengths for predicted fire behavior and are referred as being very low, low, 

moderate, high, very high, and extreme. Because every fire responds differently to various 

environmental conditions and topography actual predictions may be slightly high or lower. 

Table 34: Rocky Mountain Research Station Fuel Models, Scott and Burgan, 2005 

Adjective Class ROS (Ch/h) FL (Ft) 

Very Low 0-2 0-1 

Low 2-5 1-4 

Moderate 5-20 4-8 

High 20-50 8-12 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 159 Chapter 3 – Affected Environment 

Adjective Class ROS (Ch/h) FL (Ft) 

Very High 50-150 12-25 

Extreme >150 >25 

Incomplete and Unavailable Information 

Assumptions 

Locations of cruise plots were done randomly and not all trees were cruised therefore leaving 

insufficient data during the collection of plot surveying. 

Fire Behavior Prediction and Fuel Modeling System BEHAVE Plus 5 Fire Modeling System, 

Version 4 (Patricia LAndrews,.Collins D. Bevins, Robert C. Seli, USDA Forest Service General 

Technical Report RMRS-GTR-106WWW Revised, Jul, 2008.) computer model was used as a 

baseline to analyze the environmental effects of the alternatives. Through mathematical 

equations this modeling program uses inputs from fuel, topography, and weather in which 

produce predicted fire behavior outputs. Because fuel, fuel moisture, wind, and slope are 

assumed constant and can only be applied to fires spreading through surface fuels this modeling 

program estimates basic fire behavior. 

The rate of spread and flame length adjective class guide table (Table 34) assumes live 

herbaceous fuels are two-thirds cured, dry dead fuels (1 hour/six percent, 10 hours/seven percent, 

100 hours/eight percent), midflame wind speed of 5 mil/h, and zero slope. 

Connected Actions, Past, Present, and Foreseeable Activities 

Relevant to Cumulative Effects Analysis 

Fire plays a pivotal role in reshaping and maintaining mixed-conifer ecosystems (North, M. et. 

al., 2009). The role fire plays in an ecosystem is characterized by the fire regime attributes that 

describe the pattern of fire occurrence, behavior, and effects. Temporal attributes include 

seasonality and fire return interval. Spatial attributes are fire size and spatial complexity of the 

burns. Magnitude attributes are fire intensity, fire severity, and fire type. Many species and most 

communities show clear evidence of adaptation to recurrent fire, further demonstrating that fire 

has long been a regular and frequent occurrence. This is particularly true in the chaparral and 

mixed conifer communities, where many plant species take advantage of or depend on fire for 

their reproduction or as a means of competing with other biota. In many areas frequent surface 

fires are thought to have minimized fuel accumulation, keeping understories relatively free of 

trees and other vegetation that could form fuel ladders to carry fire into the main canopy (Sierra 

Nevada Ecosystem Project [SNEP], 1996). 

Past Activities:

 Fire History - The Fish Camp Project lies within the Big Creek watershed, where during 

the period before significant Euro-American influence, natural fires occurred frequently 

and were low intensity with return intervals ranging from 5 to 10 years. During the past 

century, fire history maps indicate that wildland fires have played a role around the Fish 

Camp and the Southern Yosemite National Park area. Between 1911 and 2008 there 

have been 8 fires within 3 miles of Fish Camp area. The majority of the fires occurred 

between 1911 and 1934 and ranged in size from 106 to 3930 acres. These fires were 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 160 Chapter 3 – Affected Environment 

mostly to the south and west of Fish Camp. Although there is no documented history of 

large fire occurrence in the Project area, numerous residual trees and cut stumps show 

witness to fire. In 1990, a 26 acre fire started in or near two adjacent plantations, causing 

severe damage to the plantations. In 1924, an 800 acre fire to the south west of Fish 

Camp was stopped within a tenth of mile of the community. 

Though this area has had a small fire occurrence, given the proper burning conditions as 

documented fire history around the Project area shows a fire could have the potential to 

burn with such severity that could result in resource damage that would be greater than 

the ecosystem could sustain. It also can easily threaten and has burned into the Yosemite 

National Park, the community of Fish Camp and Yosemite West residential area. 

Tables 35 and 36 show the Fire History Records (fires >100 Acres) within and outside of 

the Fish Camp Project area. Map 1 in the appendix of this document shows the 

approximate perimeters of these fires and their proximity to the community of Fish Camp 

and the Project area. 

 Table 35: Fire History within the Project boundary 

Year Size/Acres General Location 

1990 26 1⁄2 mile north of Little Sandy Campground 

 Table 36: Fire History Outside of the Project boundary (within a 4 mile radius) 

Year Size/Acres Year Size/Acres

1911 162 1924 106 

1917 2,236 1926 540 

1920 508 1930 701 

1920 99 1934 3,930 

1924 800 2008 102 

1924 160 2008 235 

 Logging - The areas east of Fish Camp received extensive logging between 1918 and 

1925 which resulted in slow natural regeneration of conifer species. Railroad and 

ground-based logging activities as well as stand replacing fires have resulted in little of 

the area with trees over 100 years of age. The natural stands proposed for thinning 

generally consist of approximately 85 to 100 year old shade tolerant trees. A large 

number of the resulting brush fields were prepared and planted in the late fifties and early 

sixties. Fire exclusion from the vast majority of the area since the 1920’s, has resulted in 

development of dense fuel ladders in the natural regeneration areas along with areas that 

escaped early day logging. 

Hundreds of small trees per acre are common beneath these stands of white fir, sugar 

pine, incense cedar, and ponderosa/Jeffrey pine in the lower elevations and red fir in the 

higher elevations. These stems consist of mostly shade tolerant incense cedar and white 

fir. Ponderosa pine and incense cedar have naturally reseeded into small portions of fire 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 161 Chapter 3 – Affected Environment 

impacted areas where they are severely overstocked, creating significant fuel ladders. 

Due to drought and beetle infestation in the late eighties and nineties logging was used to 

salvage dead and dying trees. Activity fuels were treated with machine piling and pile 

burning. 

Present Activities -The community of Fish Camp borders the west side of the Project area. This 

project also affects three Forest Service campgrounds, a State Snow Play area and a county refuge 

transfer site. Also within the project is a 244 room hotel situated on 35 acres with numerous out 

buildings and guest cottages. There is also a special use permit for a wilderness pack station and 

horseback riding. Most of the homes in the Fish Camp area do not have adequate clearance to 

protect them if a fast moving wildland fire were to move into the subdivision. Compounding this 

problem is poor access in the subdivision, with narrow winding roads and only one main road as 

access in the event of a wildfire. 

Foreseeable Activities - Fish Camp sets at the southern entrance to Yosemite National Park and 

as the tourism increases recreation activities spills into the National Forest and the Project area. 

With high concentrations of recreation visitors during the height of the summer season, 

evacuations would be difficult if a fast moving fire started. Natural and/or human caused fires 

starting to the south of the project or near Fish Camp would have the greatest potential for threat. 

Other issues beginning to appear are pockets of insect and drought induced mortality within 

conifer plantations and mixed conifer stands along with accumulations of heavy dead and downed 

material as a result of fire exclusion and past harvest operations. 

Alternative 1 – No Action 

Under Alternative1, current management plans would continue to guide activities in the Project 

area. No thinning of commercial and/or pre-commercial operations of mixed conifer and pine 

stands, mastication of brush/shrub patches, prescribed burning to reduce natural fuel 

accumulations and/or treatment of infestations of noxious weeds and replanting of conifers in 

failed conifer plantations would be implemented to accomplish the purpose and need. 

Direct Effects 

Natural fuel accumulations would continue to increase as more trees begin to succumb to 

overcrowding, drought, insect and pathogens. This would increase the amount of ground and 

surface fuels within the area. This increase in ground and surface fuels would gradually begin to 

shift the potential fire behavior in the area, to a more severe stature if a wildfire were to start. 

This increase would be to a more severe surface fire as the type of fuels changed from branches 

and needles (0-1” material) to the larger size material (3+”). This change is best represented by 

fuel model changes or conversions mixed conifer areas that begin as Fuel Model TL8 would 

convert to Fuel Model TU5. As accumulated natural surface fuel loadings increased, a further 

conversion from Fuel Model TU5 to Fuel Model SB2, similar to that of a moderate slash fuel 

loading could occur in some areas. 

Fuel Model SH2 is used to present the surface fuel conditions in existing in some conifer 

plantation. Under Alternative 1, this would not change, but additional accumulations of larger 

diameter branch wood, twigs and perhaps boles of trees could increase the average tons/acre of 

surface fuels, increasing the fireline intensity and resistance to control. Firefighters with 

handtools or water from fire engines would become less effective. Crown fire (a fire that 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 162 Chapter 3 – Affected Environment 

advances from the top to top of trees or scrubs more or less independent of surface fire) potential 

would also remain high because none of the elements needed to propagate and sustain a crown 

fire would be removed (fuel ladders and canopy density). Because of the increased amount of 

surface fuels and the increased fire behavior associated with them, these potential crown fires 

would have the potential to propagate over a larger area. Table 37 below shows the indicators for 

current existing conditions and those associated with the conversions in Fuel Models under 

Alternative 1. 

FL - Average Flame Length ROS - Average Rate of Spread 

FLI - Average Fireline Intensity Crown - Crown Fire Potential 

Resistance to Control - Resistance to Control Average Fuel Loading - Average Fuel Loading 

Mortality - Mortality in White Fir / Ponderosa Pine 

Table 37: Indicator for Fuel Models in Shrub/Brush Areas. 

Fuel Model

ROS 

(ch/hr)

FL 

(feet) 

FLI 

(Btu/ft/s

)

Crown 

(transition 

and type)

Resistance to 

Control (low, 

mod., high) 

Fuel 

Loading 

(tons/acre

) 

Mortality

(%) 

WF/PP 

Existing Conditions– SH2 8.4 5.3 217 Yes/Crown

ing Mod 3-8 12/9 

Future Conditions – SH5 68.0 15.7 2,259 Yes/Crown

ing Extreme 5-10 99/80 

It is assumed that mortality in the shrub/brush species would be from stand replacing (100%) or 

patchy dependent on the percent of the brush cover. For mortality to occur in the scrub there 

needs to be enough fire to girdle the main stem. With the predicted fire behavior, as shown above 

it is anticipated that in the Fuels model SH2 as currently exists, there would be mortality, but not 

as great as in Fuel Model SH5 (heavy shrub load covering at least 50% of the site), because of the 

lower amount old dead woody material found on the brush. 

Table 38: Indicators for Fuel Models in Timbered Covered Areas. 

Fuel Model

ROS 

(ch/hr)

FL 

(feet) 

FLI 

(Btu/ft/s

)

Crown 

(transition 

and type)

Resistance to 

Control (low, 

mod., high) 

Fuel 

Loading 

(tons/acre

) 

Mortality

(%) 

WF/PP 

Existing Conditions– TL8 7.6 4.0 117 Yes;Crown

ing Mod 5-10 7/7 

Future Conditions – TU5 11.3 8.6 606 Yes;Crown

ing Mod/High 12-25 34/44 

 Further Future 

 Conditions -SB2 19.4 7.3 431 Yes;Crowning High 15-30 21/22 

The above tables give an indication of what type of fire behavior could be expected if a fire were 

to occur within these fuel beds as they currently exist and in the anticipated fuel beds into the 

future with no management action taken. Because of the variability in the three facets needed to 

predict fire behavior; fuel, weather and topography that exist within the Fish Project area, there 

would be variations in the conditions and results of wildfire. On northern aspects, conditions 

would be expected to be cooler than southern aspects, lending to slightly slower and slightly less 

intense fires. Lower fuel loadings could produce slower rates of spread and intensities than 

predicted above. There are conditions that could produce higher rates of spread and intensities 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 163 Chapter 3 – Affected Environment 

than in the above tables as well. These would include increased slopes, wind conditions, greater 

surface fuel loadings (both small and large down-woody debris) and increased density of ladder 

fuels. 

Indirect Effects 

Past actions in the Fish Project area, along with fire management policy of full suppression at the 

smallest size (97 percent of all fires will be controlled at 10 acres or less from SNF LRMP, 1996) 

have contributed to the current existing condition for the Fish Camp Project area and are used to 

depict the existing condition and the resultant fire behavior within the Project area. 

Under Alternative 1, there would be very limited to no potential to allow fire to play its natural 

role on the landscape. The risk of escape and the consequential effects associated with utilizing 

fire without some form of management activity to reduce current surface fuel loadings and ladder 

fuels would be too great. Although prescribed fire could be implemented under more 

“controlled” conditions than those conceivably present during the summer fire season, it would 

be a very narrow prescription window that could produce reasonable outcomes that would be 

beneficial versus detrimental. Just like wildfire, prescribed fire produces air quality concerns, 

risk of escape, potential negative impacts to resources (from control lines and fire itself), resource 

commitments and political/social impacts. 

Fire Suppression 

As surface fuels continue to accumulate naturally, with no additional management actions, 

suppression efforts will gradually become more difficult, whereby direct attack could no longer 

be used in suppressing a fire, but have to be changed to more indirect tactics, whereby more area 

has the potential to be affected by fire, in some cases high intensity and more severe fire. With the 

increases in fire behavior generated by these surface fuel changes, fire suppression forces would 

have higher resistance to control due to fuel loading and by fire behavior. Aerial retardants 

would be less effective due to closed continuous canopy. If fire were to start in or burn into the 

Fish Project area, ground and aerial initial attack operations as well as extended attack would 

become less effective and firefighter and public safety would be difficult to ensure.

Fire Effects 

Fire influences many portions of a fire dependent ecosystem by either its presence or even its 

absence. Forest stand structures, wildlife habitat, aquatic communities, watersheds, plant 

communities and soil conditions, to name a few can be influenced. Without frequent fire to clean 

the understory of stands, excessively dense stands lead to drought stress and bark beetle 

outbreaks, resulting in wide spread mortality of trees in many areas and the potential for extensive 

mortality. This leads to a large increase in the amount and continuity of both live and dead forest 

fuels, resulting in a substantial increase in the probability of large, severe wildfires 

(Weatherspoon, C.P., 1996). These are directly correlated to the conversions of Fuel Models 

discussed in the Existing Conditions section. 

With increased rates of spread, flame lengths, and fireline intensities there is potential for greater 

fire effects to occur. Because of existing changes in tree species composition, from fire resistant 

to fire susceptible, tree mortalities would increase with small incremental changes in wildfire 

intensity. This, in combination with drought or insect/pathogen induced mortality in overstocked 

stands, could greatly increase the amount of surface fuel loading, thus increasing fire behavior 

and intensity of subsequent wildfires. Under Alternative 1, there would be no reduction in 

surface and ladder fuels, to raise mean canopy base heights and/or decrease canopy bulk densities 

as has been suggested in the Desired Condition for creating fire resilient stands. Vertical 

continuity of fuels from the forest floor to the crowns of overstory trees would be present and 

with sufficient radiant/convective heat could produce crown fire. Some studies and models, 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 164 Chapter 3 – Affected Environment 

however, suggest a crown fire entering a stand is rarely sustained (i.e., sustained only under 

extreme weather conditions) (North, M., et.al., 2009). Calculated and predicted crown fire 

potential show that conditions are present in the Fish Project area to produce the potential for 

crown fire. This could be in the form of torching single trees, groups of trees and/or active crown 

fire dependent on weather, fuels and topography of where the fire were to occur. 

Crown fires remove much or the entire tree canopy in a particular area, essentially resetting the 

successional and growth processes of stand and forests. These fires typically, but not always kill 

or temporarily reduce the abundance of understory shrubs and trees. Crown fires have the largest 

immediate and long-term ecological effects and the greatest potential to threaten human 

settlements near wildland areas (Graham, R., et.al., 2004). For wildlife species dependent on 

diverse forested landscapes (heterogeneity) and old forest characteristics for habitat, this 

successional “set-back” could pose negative consequences. 

Although crown fires would be considered of higher consequence of negative effects, surface and 

ground fires with higher intensities similar to those predicted and anticipated in this alternative, 

can also have negative impacts. While surface fires can reduce vegetation and woody, moss, 

lichens and litter strata, ground fires that consume large amounts of woody fuels and organic soil 

horizons can produce disproportionately large amounts of smoke. Ground fires reduce the 

accumulation of organic matter and carbon storage and contribute to smoke production during 

active fires and long after flaming combustion has ended. These fires can also damage and kill 

large trees by killing their roots and the lower stem cambium. Because ground fires are often of 

long duration, they may result in greater soil heating than surface or crown fires, with the 

potential for reducing organic matter, volatilizing nutrients, and creating a hydrophobic layer that 

contributes to erosion. Areas where the ground cover is removed and severely burned will likely 

see decreased infiltration of water, increased surface runoff and peak flows, and the formation of 

pedestals, rills and gullies (Graham, R., et.al., 2004). 

Depending on the setting (in particular topography and soil), perennial streams downstream from 

fires can be impacted by large volumes of sediment. Depending on the recovery of the hill 

slopes, these fire effects can be long lasting, and relatively little can be done to stop the problem. 

Large amounts of sediment can be delivered to reservoirs, reducing water storage capacity and 

potentially affecting fish and macroinvertebrate habitat (Graham, R., et.al., 2004). 

Cumulative Effects 

As no action is being taken by the SNF under the No Action Alternative by definition there would 

be no cumulative effects. See FEIS page 31 for more explanation. 

Compliance with Forest Plan and Other Relevant Laws, Regulations, 

Policies and Plans 

Alternative 1-No Action, would not comply with the Forest Plan and other Relevant Laws, 

Regulations, Policies and Plans. The No Action Alternative continues with permitted and 

authorized projects; however the goals and objectives for the Fish Camp Project would not be 

met. This action does not accomplish integrating a strategy for vegetation management that is 

aggressive enough to modify fire behavior over the broader landscape and reduce the risk of 

wildfire to communities in the WUI as directed by the SNFPA ROD 2004 and the Sierra LRMP. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 165 Chapter 3 – Affected Environment 

Summary of Effects 

Alternative 1-No Action would not meet the purpose and need for this project. There would be 

no thinning; commercial and precommercial thinning accomplished. Forest health in the area will 

continue to decline. No connection and augmentation of fuel treatments within and adjacent to 

the Wildland Urban Interface would be completed. No fuelbreak maintenance work would be 

completed. 

The predicted rate of spread, flame length, and fireline intensity would increase due to fuel 

accumulation if left untreated. Full suppression would continue to be the management direction 

for the Fish Camp Project area. Because of the continued and potential increased threat to life 

and property, under Alternative 1, firefighting resources would focus strategies and tactics on 

reducing the impacts on communities, protecting infrastructure and private property as the highest 

priority followed by protection of natural resources. The resistance to control would increase 

from Low/Moderate to Moderate to Very High. Aerial fire suppression would not support ground 

forces due to the inability of retardants to reach ground fuels because of closed canopy cover. 

Alternative 2 – Proposed Action 

Treatment areas within the Project area boundary were delineated to include those areas where 

some form of treatment was necessary to meet the purpose and need. First treatment areas were 

designed to create Strategically Placed Area Treatments (SPLAT’s) to reduce the intensity and 

spread of wildfires in and around WUI. Treatment areas near key transportation corridors and 

within the defense zone of the WUI were designed next. Treatment areas were further designed 

to not only focus on those treatments needed to meet fire and fuel objectives (treatments defined 

for fire/fuels are designed to reduce the ladder and surface fuels and occur within the lower and 

limited mid-level canopy[Fire/Fuels Objectives]), but areas where the stands were considered 

overstocked with conifers and are in higher levels than can be sustained with changing 

environmental conditions and are vulnerable to loss from insect, disease and wildfire (Forest 

Health Objectives) (treatments defined for forest health are designed to reduce basal area and 

stocking to such a level that the stands are resilient to changing environmental conditions, 

increase growth and are vigorous with reduced susceptibility to insect and disease attack and 

wildfire. These treatments occur within the lower and mid-level canopy). A treatment area map 

can be found in the project folder. 

Design Features and Mitigation Measures 

The utilization of prescribed fire to maintain appropriate levels of surface and ladder fuels to meet 

fire and fuels objectives would be conducted in prescribed treatment areas and portions of T-8 

north of road 5S06, T-9, T12, portion of T-10 north of road 5S06 and all except the very east 

portion of T-12. To reduce the potential impacts (fire effects) that may occur with the 

implementation of prescribed fire, the following criteria would need to be considered in the areas 

where prescribed fire would be used: 

 Prescribed fire areas should be considered where there are larger residual trees (of size 

less susceptible to fire damage) with light fuel loadings, and/or areas where conifer 

reproduction is not being used for re-generation of openings. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 166 Chapter 3 – Affected Environment 

 Prescribed fire should be used during the late fall, winter or early spring, to minimize 

effects to trees during active growing period and within Pacific fisher denning habitat 

areas. 

Direct Effects 

Under this alternative, thinning from below, through precommercial and commercial treatment 

would focus first on the smaller trees for removal gradually moving through the lower canopy 

levels with the potential to remove trees within the mid-level canopy to reach a silviculturally 

prescribed basal area and stocking level. Through the treatments in Alternative 2, the 

recommendations in Table 32 are accomplished by reducing surface and ladder fuels, increasing 

canopy base height, decreasing crown density, retaining larger trees and retaining fire resistant 

tree species. 

Fuel Model Changes 

Under Alternative 2, existing fuel model would be converted to another fuel model, typically a 

fuel model with lower surface fuel loadings and reduced fire behavior. In areas currently 

represented by Fuel Model SH2, mastication would be used to convert it to a Fuel Model SB1 

(light dead and down activity fuel) and/or SB2. Mastication in effect does not remove the fuel 

from the site, but changes the structure of the fuel from a vertical orientation to a horizontal 

orientation. Small chips, shredded material and/or crushed fuels (dependent on masticator head) 

are left on site. A fuel model that represents an increase in fuel loading in the 10 and 100-hour 

time lag categories is needed to show this. SB1 and SB2 are used as base fuel models with 

increases in 10 and 100-hour fuel loadings to approximately 10- 30 tons per acre each and the 

removal of live woody fuel loading to approximate this conversion. 

In timbered stands represented as Fuel Model TL3 and TL8, there would be or no conversion to a 

different fuel model. In stands represented by Fuel Model TU5 and SB2, treatment would 

convert them to a Fuel Model TL8 dependent on the overstory and surface fuels remaining. In 

some cases, a short-term conversion to a Fuel Model SB2 or TU5 may occur until post activity 

treatments were completed, then a conversion to a Fuel Model TL8 would result. 

The fuel model conversions shown are used to depict the conditions anticipated in the surface fuel 

bed changes as a result of the treatments proposed in this alternative. This alternative is also 

anticipated to raise canopy base heights, with the thinning or removal of ladder fuels from an 

average of 0-10 feet to an average of 20 feet. Canopy bulk density would also be decreased 

through the thinning of lower and mid-level canopies. It is estimated that, on average the canopy 

bulk density would be changed from 0.0119 lb/ft3

 to 0.00874 lb/ft3 under Alternative 2. 

Surface and ladder fuels 

The removal and/or thinning of the lower canopy in effect removes the ladder fuels that can 

provide the means for surface fires to “climb” into the overstory canopy. In areas where there is a 

significant amount of ladder fuels present, a combination of tractor or hand piling and burning 

would be used to remove excess material. In areas where brush species are the dominant 

vegetation cover, masticators would be used to in effect change the vertical continuity of the fuel. 

While mastication does not actually remove fuel from the area, it does change the structure from 

a vertically oriented fuel (ladder fuel) to a horizontal fuel potentially making fire suppression 

resistance to control lower and fire effects less in most cases. In areas where there are lower 

amounts of ladder fuels and/or smaller areas, mastication and/or hand cutting would be used to 

open or separate the lower canopy from the mid to upper level canopy. Typically, these areas 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 167 Chapter 3 – Affected Environment 

have lower levels of surface fuels existing (smaller amount of trees/vegetation, less amounts of 

naturally accumulated or activity generated surface fuels). 

Dependent on the type of harvest system used for removal of excess commercial-sized material, it 

is anticipated there may be a short-term increase in surface fuel loading or no significant increase. 

Whole-tree yarding, used as a harvesting system, can minimize the amount of activity generated 

fuels (Stephens, S., 2009). If whole tree yarding is not used, additional post harvest treatments 

would be needed to reduce surface fuel loadings that are in excess of 20 tons/acre (SNFPA ROD, 

2001). These post activity treatments would include dozer and/or hand piling and burning and/or 

broadcast/jackpot burning. 

Fire Behavior / Fire Effects 

Table 39: Shows the predicted results of fuel model conversions anticipated with this 

Alternative. 

Fuel Model ROS 

(Ch/hr)

FL 

(Feet)

FLI 

(Btu/ft/s)

Crown 

(Transition and 

type)

Resistance to 

Control 

(Low/Med/ 

High) 

Fuel 

Loading 

(Tons/ac0

Mortality 

(%) WF/PP

True Fir 

(above 6,000 ft) 

 

Existing Conditions- TL3 2.2 1.3 9 No/Surface Low 3-8 0/0 

Short Term ConversionTL5 

5.7 2.6 44 No/Surface Low 7-10 4/6 

Future Condition -TL1 1.2 0.7 3 No/Surface Low 2-6 0/0 

Future Condition - TL3 2.2 1.3 9 No/Surface Low 3-8 0/0 

 

Mixed Conifer 

(light fuel loading w/some brush) 

 

Existing Conditions- TL8 7.6 4.0 117 Yes/Crown Low/Mod 5-10 7/7 

Short Term ConversionTL5 

5.7 2.6 44 No/Surface Low 7-10 4/6 

Short Term ConversionSB2 

19.4 7.3 431 Yes/Torching High 15-30 21/22 

Future Condition - TL1 1.1 0.7 3 No/Surface Low 2-6 0/0 

Future Condition - TL8 7.6 4.0 117 No/Surface Low/Mod 5-10 0/0 

 

Mixed Conifer 

(mod-heavy fuel loading) 

 

Existing Conditions- TU5 11.3 8.6 606 Yes/Crowning Mod/High 12-25 34/44 

Short Term ConversionSB2 

19.4 7.3 431 Yes/Torching Mod 15-30 21/22 

Short Term ConversionTU5 

11.3 8.6 606 Yes/Torching Mod/High 12-30 34/44 

Future Condition - TL8 7.6 4.0 117 No/Surface Low/Mod 5-10 0/0 

 

Mixed Conifer 

(heavy fuel loading) 

 

Existing Conditions- SB2 19.4 7.3 431 Yes/Crowning Mod 15-30 21/22 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 168 Chapter 3 – Affected Environment 

Fuel Model ROS 

(Ch/hr)

FL 

(Feet)

FLI 

(Btu/ft/s)

Crown 

(Transition and 

type)

Resistance to 

Control 

(Low/Med/ 

High) 

Fuel 

Loading 

(Tons/ac0

Mortality 

(%) WF/PP

Short Term ConversionSB2 

19.4 7.3 431 Yes/Torching Mod 15-30 21/22 

Future Condition - TL8 7.6 4.0 117 No/Surface Low/Mod 5-10 5/6 

 

Conifer Plantations 

(with brush understory) 

 

Existing Conditions-SH2 8.4 5.3 217 Yes/Crowning Mod 5-8 12/9 

Future Condition - SB1 8.0 3.7 100 No/Surface Low 5-25 0/0 

Future Condition - TU1 3.3 2.0 27 No/Surface Low 5-10 0/0 

Future Condition - SB2 19.4 7.3 431 No/Surface Low/Mod 15-30 17/14 

Table 39 above gives an indication of what type of fire behavior could be expected if a fire were 

to occur within these fuel beds as they currently exist, short term conversion after the treatment 

but before the disposal of activity created fuels, and anticipated future condition fuel beds after 

disposal of activity created fuels were to occur. The range of fuels models in the future condition 

are based on mitigation measures in mixed conifers areas and brush density in plantations. 

Because of the variability in the three facets needed to predict fire behavior; fuel, weather and 

topography within the Fish Camp Project area, there would be variations in the conditions and 

results of wildfire. On northern aspects, conditions would be expected to be cooler than southern 

aspects, lending to slower and less intense fires. Lower fuel loadings could produce slower rates 

of spread and intensities than predicted above. There are conditions that could produce higher 

rates of spread and intensities than in the above tables. These would include increased slopes, 

wind conditions, greater surface fuel loadings (both small and large down-woody debris) and 

increased density of ladder fuels. 

Fire Suppression 

Alternative 2 in effect reduces ladder fuels which in turn increases canopy base height. Canopy 

density (in the form of canopy bulk density) is decreased through the thinning of the mid-level 

canopy, but to a small extent through the reduction in fuel ladders. These, in combination, 

reduce rates of spread, flame length, fireline intensity, resistance to control and the potential for a 

fire to transition into crown fires. As shown in Table 39, decreasing crown density may increase 

surface winds (less canopy to reduce winds before they reach the ground) and surface fuels may 

be drier (more sunlight reaching the ground). These do have the potential to increase fire 

behavior. It is estimated that Alternative 2 would not open canopies to the extent needed to 

realize these concerns. It is estimated that in most areas, canopies would remain at 60 percent or 

greater in the overstory even after treatment. This change would not be significant enough to 

change the amount of wind reaching the surface. There would be small amounts of increased 

sunlight to dry fuels, but not significant enough to dramatically change fire behavior. If full fire 

suppression continues as the management strategy for unplanned ignitions within the Project area, 

fire suppression resources would have an increased capacity to control fires at initial attack with 

minimized risk to their safety (and the public) and increased ability to keep these fires small in 

size with the use of direct attack tactics versus indirect tactics. Fires would typically drop from 

the crowns to the forest floor. Aerial firefighting resources would be better able to penetrate the 

canopy to aid ground resources with reduced canopy density, even moderate amounts as an 

indirect effect of treatments in Alternative 2.
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 169 Chapter 3 – Affected Environment 

Design features used to minimize effects and/or retain habitat structures preferred by wildlife 

species such as; grouping of larger trees, oak retention with ladder fuels retained under them and 

Old Forest Linkages with limited treatments would have lower potential for loss since there 

would be treated areas between them and are not continuous. This would be similar to the 

variability in forest conditions produced by frequent fire (North, 2009). 

In utilizing mechanical treatments, as in Alternative 2, stand structures are modified quickly and 

more precisely than with prescribed fire alone (North, 2009). Under this alternative, treatments 

are effective in breaking up the horizontal and vertical continuity of live fuels in the lower canopy 

layers and/or in effect pre-treating the stands to more readily allow prescribed fire to be 

introduced. Silvicultural cuttings can only partially substitute for fire (Weatherspoon, 1996). 

This alternative allows increased potential to utilize prescribed fire as either a maintenance 

treatment and/or in conjunction with mechanical treatments as a follow-up process to achieve 

forest resilience. Fire could mimic the natural ecosystem functions of frequent low-to-moderate 

severity fire. Under this alternative, prescribed fire, whether burning of piles and/or broadcast 

burns can be implemented with less risk of escape, with a broader range of acceptable conditions 

and in some cases less impacts to air quality (Weatherspoon, 1996). 

Fire Effects 

With the removal of what is considered the suppressed, intermediate and some co-dominates 

within a stand, the vegetation considered ladder fuels would be removed. Conifer species such as 

Ponderosa Pine and Sugar Pine, which are considered more fire resistant, would be favored to 

remain in a stand over shade tolerant and fire sensitive species, such as incense cedar and white 

fir. Incense cedar and white fir make up the largest percentage of conifers found in the 

understory of stands in the Fish Project area (based on sampled plot data). These species also 

tend to have increased susceptibility to wildfire as well tend to have limbs that stay closer to the 

ground providing increased ability to take surface fires into the crowns in the form of single tree 

torching or group torching. With species composition favored towards the more fire resistant, 

shade intolerant species and fire behavior modified, effects to stands (mortality) would be 

decreased. 

As part of this alternative, treatments would be implemented to reduce surface fuels, where 

needed. In most cases, as been experienced in past projects similar to this alternative, these areas 

are not continuous over the entire treatment area. If a fire was to start in an area where these 

surface fuels have not been reduced, fire behavior would be increased (as represented by Fuel 

Model SB2). The results of wildfire impacts on areas treated only with mechanical methods are 

mixed. Some burned with higher intensity, than those where mechanical treatments were 

followed by prescribed burning, though with lower severity than untreated control areas 

(Stephens, S. 2009). The timing and sequence of these “clean-up” treatments are dependent on 

several factors, such as adequate funding and completion of harvesting operations. Those 

treatment areas closest to WUI would be treated first and then would progress into other areas 

from there. As stated earlier the surface fuel load changes would be largely based on harvesting 

system used. If whole-tree yarding is used, post treatment areas where natural fuel accumulations 

are above 20 tons/acre would be the areas where secondary treatment would be used. These are 

areas expected to be less (acres) in need of surface fuel reduction. 

With reduction in fire behavior, the effects of fire on other ecosystem components would be 

reduced and perhaps enhanced. Many are resistant or often have favorable responses to low to 

moderate fire intensity and severity. The idea of preemptive work that restores historic fire 

regimes has not been widely discussed, considered, or used to address both the ecological and 

social issues surrounding fires and watershed resources. The same can be said for many of the 

wildlife species that live and depend on the forested ecosystem. At-risk species, and the 
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Sierra National Forest 170 Chapter 3 – Affected Environment 

ecological functioning systems they depend on, cannot be sustained or recovered without the 

immediate and longer-term ecological functioning provided by fire. In Alternative 2, integrating 

fire and fuels management objectives and forest health restoration with at-risk species 

conservation and protection are made. This is needed to provide both the viability of human 

communities and at-risk species where both overlap (Sugihara, N., et.al. 2006). 

Indirect Effects 

Climate Change and Fire Severity Relationships 

As stated earlier, weather has a large influence on fire behavior and is also the most difficult to 

predict. Associated with the purpose and need to reduce stand densities to levels where trees 

would be more resilient to drought conditions, reducing surface and ladder fuels to reduce 

wildfire intensity and spread, can also produce benefits in drought conditions. Research suggests 

global mean minimum temperatures may have already begun to rise. One effect of this change 

for western forests would be earlier spring melt of mountain snow packs. An analysis of western 

U.S. fire season length over the last 50 years suggests that during the last two decades, fires begin 

earlier in the spring and occur later in the fall possibly due to this trend in elevated nighttime 

minimum temperatures. Though there are variations in predictions and models, one point of 

consensus is that most agree the climate would become more extreme, suggesting oscillations 

between wet and drought conditions would be more common (North, 2009).

Managing forests under these conditions would be challenging. In the face of uncertainty, 

adaptive strategies should focus on three responses; resistance (forestall impacts and protect 

highly valued resources), resilience (improve the capacity of ecosystems to return to desired 

conditions after disturbance), and response (facilitate transition of ecosystems from current to 

new conditions) (North, 2009). All of these are focuses that Alternative 2 is attempting to address 

through its purpose and need for changes in forest structure capable of surviving climate changes 

and reduction in fuels to adapt fire behavior that occurs under current climate and ignition 

conditions (North, 2009). 

Cumulative Effects 

Railroad logging and subsequent extensive reforestation efforts along with fire management 

policy of full suppression at the smallest size (97 percent of all fires will be controlled at 10 acres 

or less from SNF LRMP, 1996) have contributed to the current existing condition for the Fish 

Project area and are used to depict the existing condition and the resultant fire behavior within the 

Project area. 

 

Compliance with Forest Plan and Other Relevant Laws, Regulations, 

Policies and Plans 

Regulatory Framework 

In the recent past several fire policies and initiatives have been enacted to address the national 

wildfire problem in the United States. These include, but are not limited to the U.S. National Fire 

Plan, Ten-Year Comprehensive Strategy and Implementation Plan, and Healthy Forest 

Restoration Act (Stephens, S. et. al., 2009). These have provided the basis of management goals, 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 171 Chapter 3 – Affected Environment 

intents and directions that are within the Forest Land and Resource Management Plans. By 

implementing the Fish Camp Project fire policies and forest plans would be met.

The Sierra National Forest Land and Resource Management Plan (LRMP) (dated 1991) was 

amended in January, 2001 with the Sierra Nevada Forest Plan Amendment Record of Decision 

(SNFPA ROD 2001). Although, the priority for fuels treatments is in the Wildland Urban 

Intermix (WUI). This decision also employed strategically placed fuels treatment outside the 

WUI to support one another across the landscape so that wildland fire behavior spread and 

intensity be reduced. WUI is defined in the Federal Register, Forest Service Manual 5106 and the 

10-Year Comprehensive Strategy Implementation Plan as “the line, area, or zone where structures 

and other human development meet or intermingle with undeveloped Wildland or vegetative 

fuels. 

In 2004, a Supplemental Final Environmental Impact Statement Record of Decision, known as 

the Sierra Nevada Forest Plan Amendment Record of Decision, 2004 (SNFPA ROD, 2004) was 

signed by the Pacific Southwest Region Regional Forester and replaced the 2001 decision in its 

entirety. The SNFPA ROD, 2004 identifies the fire and fuels management strategy to integrate 

the strategy for old forest ecosystems. Outside the WUI defense zone, strategic placement of area 

treatments to occur across all land allocations. Desired conditions, management intents, 

management objectives, and standards and guidelines guide the managers in placing and 

designing effective area treatment while incorporating needs for retaining key habitat elements 

for sensitive species. (SNFPA ROD, 2004 pp 33- 34). 

The standards and guidelines listed in the SNFPA ROD, 2004 give direction for locating area 

treatments. Site-specific fuels treatment prescriptions are designed to modify fire intensity and 

spread in treated areas. Managers are to consider topographic position; slope steepness; 

predominant wind direction; and the amount and arrangement of surface, ladder, and crown fuels 

in developing fuels treatment prescriptions for each treatment area. Fuels treatments are intended 

to reduce surface, ladder, and crown fuels. Crown fuels are modified to reduce the potential for 

spread of crown fire. 

Fuels objectives have first priority in developing treatment area prescriptions. However, 

prescriptions for treatment areas may also address identified needs for increasing stand resistance 

to mortality from insects and disease. Thinning densely stocked stands may be used to reduce 

competition and improve tree vigor thereby reducing levels of insect- and disease-caused 

mortality (SNFPA ROD, 2004; page 35). 

Revenues from the sale of commercial forest products may be obtained from some fuels 

treatments. This increases the likelihood of accomplishing the projected acres of treatment, an 

essential first step in achieving the desired reductions in acres burned. Where consistent with 

desired conditions, area treatments are designed to be economically efficient and meet multiple 

objectives (SNFPA ROD, 2004; page 35). 

Within the SNFPA ROD, 2004, fire and fuels goals include reducing threats to communities and 

wildlife habitat from large, severe wildfires and re-introducing fire into fire-adapted ecosystems. 

Broad-scale goals include: 

 Treating fuels in a manner that significantly reduces wildland fire intensity and rate of 

spread, thereby contributing to more effective fire suppression and fewer acres burned; 
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 Treating hazardous fuels in a cost-efficient manner to maximize program effectiveness; 

and 

 Actively restoring fire-adapted ecosystems by making demonstrated progress in moving 

acres out of unnaturally dense conditions. 

Management of hazardous fuels in and around communities is to be combined with strategic 

placement of fuels treatments across broad landscapes to modify wildfire behavior. Goals for 

fuels treatment include: 

 Strategically placing treatment areas across landscapes to interrupt potential fire spread, 

 Removing sufficient material in treatment areas to cause fire to burn at lower intensities 

and slower rates of spread compared to untreated areas, and 

 Considering cost-efficiency in designing treatments to maximize the number of acres that 

can be treated under limited budget (SNFPA ROD, 2004 pp.34-35). 

Summary of Effects 

Under Alternative 2, ladder and surface fuels are reduced to levels that would meet the purpose 

and need for fire and fuels. The development of SPLATs which reduces the risk of wildfire and 

modifies fire behavior over the broader landscape would occur. Additional areas would be 

treated to provide a defensible fuels profile near key transportation corridors and within the 

defense zone of the wildland urban intermix. By decreasing fuel ladders, which raises canopy 

base heights and reducing surface fuels, fuelbeds are converted from ones that produce moderate 

to high fire behavior to fuelbeds that produce moderate to low fire behavior. In addition to those 

treatments needed to meet fire and fuels objectives, treatments would be created to reduce stand 

densities (basal area) to such a level as to improve the growth and vigor of remaining trees. 

Treatments included in this alternative are: thinning from below in conifer stands, either by precommercially, commercially, and/or mastication of vegetation (conifers) to reduce lower and 

mid- level canopy stand densities; mastication of brush and shrub patches; prescribed burning, 

both understory and piles; manual reduction and/or prescribed burning of noxious weed 

infestations; and prepare and plant failed conifer plantations. 

Alternative 3 – Lower and Limited Mid-Level Canopy Treatments, All 

Treatment Areas 

In Alternative 3, treatment areas would remain the same as in Alternative 2, treatments within 

these areas would include only those needed to reduce the surface and ladder fuels (within the 

lower and limited mid-level canopy levels) needed to achieve fire and fuels objectives. Under 

Alternative 3 there would be no additional treatments (i.e. additional thinning in the mid-level 

canopy) to fully address stand density and forest health objectives. All design criteria and SNFPA 

ROD (2004) standards and guidelines would be implemented with this alternative. 

Design Features and Mitigation Measures 

The design feature and mitigation measures are the same as those in Alternative 2. 

Direct Effects 

Under Alternative 3, there would be no significant change in the direct effects from those listed 

under Alternative 2. There is a potential for a decreased amounts additive surface fuel loading 
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Sierra National Forest 173 Chapter 3 – Affected Environment 

within all “T” treatment areas resulting from less conifers being removed. As stated in 

Alternative 2, resultant increases or decreases in surface loadings from harvesting operations are 

dependent on the type of harvesting operations that are used. By increasing canopy base heights 

and reducing surface fuel loadings, fire and fuels objectives are met 

Indirect Effects 

Under Alternative 3, there would be no significant change in the indirect effects from those listed 

under Alternative 2. There is a potential for aerial firefighting resources to be less effective in all 

“T” treatment areas with no reduction in mid-level canopy densities. Residual crown densities 

would make it difficult for retardant and/or water dropping from helicopters to penetrate to the 

ground. In assuring the reduction in ladder fuels to raise canopy base heights from 0-10 to 20 feet 

and reducing surface fuel loadings, fire intensity and spread are reduced to desired condition 

levels and meet the fire and fuels objectives stated in the purpose and need of the project. 

Long-term, these types of disturbances could induce increases in surface fuel loadings and/or 

increased snag levels producing conditions similar to those already existing in the Project area 

with resultant fire behavior (intensity and spread rates) similar to those predicted in Alternative 1, 

with the exception of crown fire potential. It is assumed that with the reduction in ladder fuels, 

there would be increases in rates of spread, increase flame lengths, increased fireline intensity, 

and increased resistance to control, similar to that seen in Fuel Model TL8 in Alternative 1, but 

this would be as a surface fire with potential for crown fire reduced and/or eliminated. Fire 

intensities could cause the potential for single or group tree torching because of the increased 

number of fire susceptible trees such as white fir and incense cedar left in the stand, but this is 

expected to be less than in Alternative 1 

Cumulative Effects 

Under Alternative 3, there would be no significant change in cumulative effects from those listed 

under Alternative 2. 

Compliance with Forest Plan and Other Relevant Laws, Regulations, 

Policies and Plans 

Alternative 3 would be in compliance with the Forest Plan and other regulatory direction. Fire 

and fuels objectives would be met and the purpose and need for the project would be 

accomplished. The project is designed to develop SPLATs to reduce the risk of wildfire in WUI 

and modify fire behavior over the broader landscape. By decreasing fuel ladders, which raises 

canopy base heights and reducing surface fuels, fuelbeds are converted from ones that produce 

moderate to high fire behavior to fuelbeds that produce moderate to low fire behavior. 

While fire and fuels objectives are met in this alternative, all “T” treatment areas of Alternative 3 

would not meet the multi-objective purpose and need of the Fish Project which includes reducing 

stand densities to sustain healthy forest. 

Summary of Effects 

Alternative 3 reduces ladder and surface fuels to levels that would meet the purpose and need for 

fire and fuels. But Alternative 3 does little to nothing for the multi-objective purpose and need of 

the project which includes reducing stand densities to improve forest health. 

Monitoring 

Monitoring of the conditions following initial treatments would be done to determine if additional 

treatments are needed to meet fire and fuels objectives. Particular attention would be given to 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 174 Chapter 3 – Affected Environment 

those treatment areas associated with SPLAT’s and DFPZ’s surrounding the community of Fish 

Camp, as these are the priority areas within the project for follow-up treatments to reduce surface 

fuels, if needed. 

As stated in the SNFPA ROD 2004, treatments are to be designed and effective for at least 10 

years before re-entry is needed. With the implementation of the Fish Camp Project, there is a 

potential to return fire (in the form of prescribed fire) back into a fire dependent ecosystem. 

Existing conditions do not allow the opportunity, without some form of mechanical treatment to 

reduce surface and ladder fuels, to do this in a controlled manner without detrimental fire effects. 

Potential exist where prescribed fire can and would be utilized as maintenance for the proposed 

treatments. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 175 Chapter 3 – Affected Environment 

Air Quality ______________________________________ 

The direct, indirect and cumulative effects to air quality and visibility are summarized from the 

Air Quality Report for the Fish Camp Project (Smith, G. 2010). 

Introduction 

The purpose and need of the Fish Camp Project is to reduce stand densities to improve forest 

health and reduce the intensity and spread of wildland fires. This report analyzes the direct, 

indirect and cumulative effects to Air Quality and visibility from the alternatives proposed to 

meet this purpose and need as well determines the General Conformity of these actions to the 

Clean Air Act. 

Overview of Issues Addressed 

Fire is an important part of California ecosystems, but it also produces combustion by-products 

that are potentially harmful to human health and welfare. Carbon dioxide and water are the two 

products of complete combustion and generally make up 90 percent of the total emissions from 

wildfire. In incomplete combustion that occurs under wildfire conditions, smoke is composed of 

carbon dioxide, water vapor, carbon monoxide, particulate matter, hydrocarbons, and other 

organic compounds, nitrogen oxides, trace minerals and several thousand other compounds. 

Particulate matter is the principle pollutant of concern to human health from wildfire smoke for 

the short-term exposures typically experienced by firefighters and the public. Studies indicate 

that 90 percent of smoke particles emitted during wildland burning are particles that measure less 

than ten microns in size (PM10), and about 90 percent of these are less than 2.5 microns in size 

(PM2.5). Hydrocarbons and nitrogen oxides from large wildfires contribute to increased ozone 

formation (which causes injury to plants) under certain conditions (Ahuja 2006). 

Issues Relevant to Air Quality 

There are two general strategies to managing wildfire smoke: (1) emission reduction and (2) 

emission redistribution. All pollutants except nitrous oxide are negatively correlated with 

combustion efficiency, so actions that reduce one pollutant result in the reduction of all. 

Emission redistribution techniques may effectively keep smoke impacts away from sensitive 

areas, but does little to reduce the amount of emissions produced. But optimal use of reduction 

techniques can reduce emissions by approximately 20 to 25 percent, assuming all other factors 

(vegetation types, acres, etc.) were held constant and land management goals were still met. 

Emission reduction techniques can include reducing the area burned, reducing fuel loading, 

reducing fuel production, reducing fuel consumption, and scheduling burning before new fuel 

appears and increasing combustion efficiency (Ahuja 2006). These reduction techniques, which 

can include prescribed fire, mechanical harvesting (which includes road work, cutting, and 

hauling of material) and vegetation management treatments (mastication and mechanical piling) 

can produce emissions that can affect human health and visibility. 

Affected Environment 

The Fish Camp Project is within two air basins that are regulated by two air districts: San 

Joaquin Valley Air Pollution Control District (SJVAPCD) for Madera County and Mountain 

Counties Air Pollution Control District for Mariposa County. Each are responsible for 

implementing and regulating sources that degrade air quality and are responsible for meeting 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 176 Chapter 3 – Affected Environment 

Federal and State air quality standards. The Air Resources Board (ARB) has oversight authority 

to monitor performance of district programs. The affected environment (geographic area) in this 

analysis includes areas that would or could experience degradation as a result of the actions 

proposed. SJVAPCD and the Mountain Counties Air Pollution Control District are considered 

the air basin downwind from the Fish Camp Project and are the air basins direct, indirect and 

cumulative impact analysis is focused on. 

The community of Fish Camp borders the west boundary of the Fish Camp project. Within this 

project are three Forest Service campgrounds, a State Snow Play area and a county refuge transfer 

site. There is also a special use permit for a wilderness pack station and horseback riding. Also 

within the project is a 244 room hotel situated on 35 acres with numerous out buildings and guest 

cottages. State Highway 41, also borders the west boundary of the Fish Camp project, is the 

southernmost route into Yosemite National Park. Vehicular traffic increases during the summer 

months with visitors travelling into the park, but is also used to access Badger Ski Area in the 

park during the winter months. 

Communities, State Highways, Class I Airsheds, and recreation sites are considered smoke 

sensitive receptors where smoke and air pollutants can adversely affect public health, safety and 

welfare. These areas could be affected by smoke if weather patterns produce a stable air mass and 

smoke is unable to vent into the upper atmosphere. Since PM10, PM2.5and ozone are public health 

hazards, prescribed burns would be planned during periods of unstable air, which would allow for 

proper ventilation and temperatures less than 95 degrees. However, since prescribed underburns 

could last for several days or weeks there is the potential for recurring shifts in air masses toward 

more stable conditions. For this reason, all prescribed fire activities are coordinated with 

Mountain Counties Air Pollution Control District and the SJVAPCD and would be implemented 

under optimum conditions using best available control measures (listed in Chapter 2 under Air 

Quality [Fuels]) to prevent smoke concentrations from affecting local communities. Sensitive 

receptors were considered within 100 kilometers (10 miles) of the Project area and are listed in 

Table 40 below. 

Table 40: Sensitive receptors identified within 10 miles of the Fish Camp Project 

Sensitive Receptor Type Location

Towns, Communities Fish Camp, Yosemite Mountain Ranch, 

Oakhurst, Wawona, Bass Lake 

Recreation Areas Miami Motorcycle Trails, Westfall Day Use, 

Lewis Creek Natural Scenic Trail, Goat 

Meadow Winter Sports Area, Yosemite Sugar 

Pine Railroad, Yosemite Pack Station, Bass 

Lake 

Campgrounds Nelder Grove, Big/Little Sandy, Kelty Meadow, 

Fresno Dome, Summerdale, Summit, Soquel, 

Westfall, Greys Mtn., Bass Lake C.G.s 

FS Work Center/Ranger Station Westfall, Batterson, Oakhurst Visitor 

Information Center 

Roads State Highway 41, Forest Service and County 

Roads 

Class I Federal areas See Table 3 for Class I areas 

Other Private lands within and adjacent to the Project 

area 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 177 Chapter 3 – Affected Environment 

Existing Condition 

The air quality in the San Joaquin Valley is among the poorest in the state. On average, the San 

Joaquin Valley experiences 35–40 days when it exceeds the federal health-based standards for 

ground-level ozone, and more than 100 days when it exceeds the state ozone standard. While 

levels of airborne particulates exceed the federal standard less than five times annually, the state 

standard is set at a lower and more protective level. The valley exceeds the state particulate 

standard an average of 90–100 days per year (www.arb.ca.gov; Trends Summary). 

The BLRD underburns approximately 350 acres per year, this program would continue 

unaffected by the alternative chosen. The district’s underburn program covers approximately 

25,000 acres. None of these are within the Project area. The underburns are in ponderosa pine or 

mixed conifer vegetation and most have had at least one entry of prescribed fire. Most of the 

underburns are considered to be in maintenance status and will continue to be burned on a 

rotational schedule. Cumulative effects may also be the occurrence of respiratory or pulmonary 

distress if a wildland fire were to occur in the area while a prescribed fire was being conducted. 

This would be a rare occurrence. Table 41 displays the tons of estimated emissions from the 

BLRD underburns each year. The 56.1 tons of PM10 emissions is the cumulative effect for the 

underburn program by project. It reflects the potential smoke emissions affecting residents of the 

local communities. 

Table 41: Tons of Estimated Pollutants per Individual Project—Annual Underburn Program of 

Work. 

PM10 PM2.5 NOx SO2 VOC CO 

56.1 50.9 15.0 0.2 36.1 520.0 

PM10 = Particulate matter <10 microns in size, PM2.5 = Particulate matter <2.5 microns in size, NOX = 

Nitrous oxide, SO2 = Sulfur dioxide, VOCs = Volatile Organic Carbon, CO = Carbon monoxide 

Past analysis has shown that emissions associated with thinning operations and road use is minimal due to 

contractual dust abatement requirements. 

Desired Condition 

The desired condition for Air Quality and Visibility in the Fish Camp Project is to meet the 

purpose and need for the Fish Camp Project while accomplishing the Sierra National Forest Land 

and Resource Management Plan (SNF-LRMP) goal to manage Forest activities so air quality is 

compatible with federal, state and local laws, including a program that achieves the Clean Air Act 

(CAA) responsibilities. 

Regulatory Frameworks 

The SNF LRMP as amended provides the standards and guidelines for the Proposed Action. It 

states that “Forest activities will be managed so air quality is compatible with federal, state and 

local laws; including a program that achieves the CAA responsibilities” (SNF LRMP 1992, pg. 4-

2). The SNF LRMP has Standards and Guidelines for Air Quality (SNF LRMP 1992, pgs. 4-25) 

that includes the following: 

 Avoid cumulative impacts to air quality by coordinating prescribed burning activities 

within the Forest, with burning activities conducted by others (SNF LRMP 1992 S&G # 

216) 
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Sierra National Forest 178 Chapter 3 – Affected Environment 

 Mitigate fugitive dust impacts on air quality by including dust abatement as a 

requirement for construction activities that have potential to generate dust (SNF LRMP 

1992 S&G # 217). 

 Avoid prolonged effects from prescribed burning activities on air quality by burning only 

on Air Quality Control Board (AQCB) approved burn days when satisfactory wind 

dispersion conditions prevail (SNF LRMP 1992 S&G # 218). 

 Participate with AQCB to qualitatively define air quality control regulations and 

guidelines and effects of air quality on the Forest, from sources outside the Forest (SNF 

LRMP 1992 S&G # 219). 

 Obtain appropriate permits prior to conducting prescribed burning activities (SNF LRMP 

1992 S&G # 220). 

 Incorporate air quality management considerations into fire management (SNF LRMP 

1992 S&G # 230). 

Federal Conformity Requirements - The CAA requires that all projects receiving federal funds 

must conform to the appropriate State Implementation Plan (SIP). Federal actions are subject to 

either the Transportation Conformity Rule (40 CFR 51[T]), which applies to federal highway or 

transit projects, or the General Conformity Rule (40 CFR 51[W]), which applies to all other 

federal actions. Because the Fish Camp Project is not a federal highway or transit project, it is 

subject to the General Conformity Rule. 

General Conformity Rule Requirement - The purpose of the General Conformity Rule is to 

ensure that federal actions conform to applicable SIPs so that they do not interfere with strategies 

employed to attain the National Ambient Air Quality Standards (NAAQS). The rule applies to 

federal actions in areas designated as nonattainment, or in some cases maintenance, for any of the 

six criteria pollutants. The rule applies to all federal actions except: 

 Programs specifically included in a transportation plan or program that is found to 

conform under the federal transportation conformity rule. 

 Projects with associated emissions below specified de minimus threshold levels. 

 Certain other projects that are exempt or presumed to conform. 

A general conformity determination would be required if a proposed federal action’s total direct 

and indirect emissions fail to meet one of these two conditions: 

 Emissions for each affected pollutant for which the region is classified as a maintenance 

or nonattainment area for the NAAQS are below the de minimus levels indicated in Table 

42. 

 Emissions for each affected pollutant for which the region is classified as a maintenance 

or nonattainment area for the NAAQS are regionally insignificant (total emissions are 

less than 10% of the area’s total emissions inventory for that pollutant). 

If either of these conditions is met, the requirements for general conformity do not apply because 

the Proposed Action is presumed to conform to the applicable SIP for each affected pollutant. As 

a result, no further analysis or determination would be required. If neither of these conditions is 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 179 Chapter 3 – Affected Environment 

met, a general conformity determination must be performed to demonstrate that total direct and 

indirect emissions for each affected pollutant for which the region is classified as a maintenance 

or nonattainment area for the national standards would conform to the applicable SIP. 

The Fish Camp Project is within two different air basins, the San Joaquin Valley (Madera 

County) and Mountain Counties (Mariposa County).Currently, the San Joaquin Valley is 

classified by both the federal and state standards as non-attainment extreme for ground-level 

ozone and as maintenance status for PM10. The valley is designated as in attainment for all other 

criteria pollutants. (www.valleyair.org). The Mariposa County Federal attainment status for 

Criteria Pollutants is in non-attainment for 8-hour ozone and is unclassified for each of the other 

criteria pollutants. The two air basins are considered in attainment for all other criteria pollutants. 

The Environmental Protection Act (EPA), for determining conformity, has developed de minimus

levels for each of the criteria pollutants based on an air basins attainment status for each pollutant. 

The table below shows these de minimus level thresholds and are bolded based on air basin status. 

Table 42: Federal de minimus Threshold Levels for Criteria Pollutants based on Air 

Basin attainment status. 

Pollutant Area Type Tons/Year

Ozone (NOx or VOC) 

Nonattainment Extreme (SJV Air Basin) 25 

Other O3 Nonattainment Area Outside an O3 Transport 

Region (Mountain Counties) 100 

Carbon monoxide, SO2 and 

NO2 All nonattainment & maintenance 100 

PM-10 

Serious nonattainment 70 

Moderate nonattainment and maintenance (SJV Air Basin) 100 

Lead (Pb) All nonattainment & maintenance 25 

Note: Federal de minimus threshold levels in bold type are those where status is non-attainment or 

maintenance. 

California Clean Air Act - Responsibility for achieving California’s air quality standards, 

which are more stringent than federal standards, is placed on the ARB and local air districts, and 

is to be achieved through district-level air quality management plans that are incorporated into the 

SIP. In California, the EPA has delegated authority to prepare SIPs to the ARB, which in turn has 

delegated that authority to individual air districts. 

The ARB has traditionally established state air quality standards, maintaining oversight authority 

in air quality planning, developing programs for reducing emissions from motor vehicles, 

developing air emission inventories, collecting air quality and meteorological data, and approving 

SIPs. 

Responsibilities of air districts include overseeing stationary source emissions, approving permits, 

maintaining emissions inventories, maintaining air quality stations, overseeing agricultural 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 180 Chapter 3 – Affected Environment 

burning permits, and reviewing air quality–related sections of environmental documents required 

by California Environmental Quality Act (CEQA). 

The California Clean Air Act (CCAA) of 1988 substantially added to the authority and 

responsibilities of air districts. The CCAA designates air districts as lead air quality planning 

agencies, requires air districts to prepare air quality plans, and grants air districts authority to 

implement control measures. The CCAA focuses on attainment of the state ambient air quality 

standards, which, for certain pollutants and averaging periods are more stringent than the 

comparable federal standards. 

The CCAA requires designation of attainment and nonattainment areas with respect to state 

ambient air quality standards. The CCAA also requires that local and regional air districts 

expeditiously adopt and prepare an air quality attainment plan if the district violates state air 

quality standards for CO, sulpher dioxide (SO2), NO2, or ozone. These air quality attainment 

plans are specifically designed to attain these standards and must be designed to achieve an 

annual 5% reduction in district-wide emissions of each nonattainment pollutant or its precursors. 

Where an air district is unable to achieve a 5% annual reduction in district-wide emissions of each 

nonattainment pollutant or its precursors, the adoption of “all feasible measures” on an 

expeditious schedule is acceptable as an alternative strategy (Health and Safety Code Section 

40914(b)(2)). No locally prepared attainment plans are required for areas that violate the state 

PM10 standards, but the ARB is currently addressing PM10 attainment issues. 

The CCAA requires that the state air quality standards be met as expeditiously as is practicable 

but, unlike the federal CAA, the CCAA does not set precise attainment deadlines. Instead, the 

CCAA establishes increasingly stringent standards for areas that will require more time to 

achieve the standards. 

Local Air Districts - Local districts are given the responsibility to develop programs and plans 

for achieving both Federal and State air quality standards and are given the authority to 

implement control measures to reduce emissions of each nonattainment pollutants or its 

precursors. This is implemented through the use of Rules and Regulations.

Smoke Management 

In accordance with the California Code of Regulations, Title 17, all persons or entities subject to 

subchapter 2 Smoke Management Guidelines for Agricultural and Prescribed Burning shall 

comply with the requirements therein and those requirements adopted by applicable districts in 

local smoke management regulations. Such persons or entities proposing to conduct prescribed 

burning must submit a Smoke Management Plan (SMP) to the air district of jurisdiction and: 1) 

receive a permit to burn, 2) receive authorization to burn on a given day, and 3) maintain 

communication with the local air district and report on the status of the burn until it is concluded.

San Joaquin Valley Air Pollution Control District - As agreed upon by San Joaquin Valley Air 

District staff and the Southern Sierra Interagency Smoke Management Group, all land managers 

planning to implement prescribed fire treatments will follow the Unified Guidelines and 

Procedures for Smoke Management, which includes the submission of a required prescribed Fire 

Burn Plan and Smoke Management Summary. These are reviewed by district personnel and are 

conditionally approved. Burners are required to register prescribed burns prior to the fall burn 

season and authorization to burn is required prior to ignition based on air quality conditions and 

forecasts. For prescribed understory burning, seven days prior to ignition a Prescribed Fire 

Ignition Advisory (PIFA) form must be completed and submitted to district meteorology and 

compliance staff to begin receiving forecast for burn day potential. Participation on daily smoke 

management conference calls for burn project coordination is also required on a daily basis prior 
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Sierra National Forest 181 Chapter 3 – Affected Environment 

to and during implementation. On the day of ignition, final approval must be received from the 

compliance officer at the district. Pile burning approval is received through the calling the 

Hazard Reduction Burning phone number on a daily basis. A burn fee is applied to the total 

blackened acres accomplished on a yearly basis. These conditions are enforced through Air 

District Rules and Regulations (Rule 4103, Rule 4106).

Mountain Counties Air Pollution Control District - A SMP is required for all prescribed burns, 

upon review and approval a burn permit will be issued with a fee for issuance. For prescribed 

understory burning, seven days prior to ignition a Controlled Burn form (CB-3) must be 

completed and submitted to the district compliance staff and to California Air Resources’ 

Meteorology to begin receiving forecast for burn day potential. Participation on daily smoke 

management conference calls for burn project coordination is also required on a daily basis prior 

to and during implementation. On the day of ignition, final approval must be received from the 

compliance officer at the district. Pile burning approval is received through the prescribed Fire 

Information Reporting System (PFIRS) website on a daily basis. 

Prevention of Significant Deterioration - The Prevention of Significant Deterioration (PSD) 

provisions of the CAA require measures to “preserve, protect and enhance the air quality in 

national parks, national wilderness areas, national monuments, national seashores, and other areas 

of special national or regional natural, recreation, scenic or historic value.” The most stringent 

requirements for air quality apply to those established as Class I areas. These include 

international parks, national wilderness areas greater than 5,000 acres, national memorial parks 

greater than 5,000 acres, and national parks greater than 5,000 acres, and national parks greater 

than 6,000 acres established prior to August 7, 1977.

There are no Class I airsheds within the Project area. However, there are Class I airsheds nearby 

that must be considered and protected. These airsheds are listed in the Table below. 

Table 43: Class I airsheds near the Fish Camp Project area. 

Class I Airshed Proximity to Project area 

Yosemite National Park Southern Park boundary borders the North 

boundary of Project area. 

Ansel Adams Wilderness Area 

Western wilderness boundary 

approximately 9 miles East of Project 

boundary. 

Visibility Protection - Visibility is an air-quality related value that is protected in all federal 

Class I areas. Since 1984, states have been required to protect the visibility in national parks and 

wilderness areas, as mandated by the 1977 Clean Air Act Amendments. The 1977 amendments 

established a national goal for the “prevention of any future and the remedying of any existing 

impairment of visibility in mandatory Class I federal areas which impairment results from 

manmade pollution.” The regulations specifically require states to consider strategies for 

reducing visibility impairment from prescribed burning.
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 182 Chapter 3 – Affected Environment 

Environmental Consequences 

Methodology 

For each alternative proposed for the Fish Camp Project, associated emissions are calculated. 

This is used to determine if any alternative’s total direct and indirect emissions fail to be (1) 

below Federal de minimus thresholds, in this case thresholds for ozone (precursors NOx and 

VOC) and PM-10, or (2) considered regionally insignificant (less than 10% of the area’s total 

emissions inventory for that particular pollutant). If any alternative’s estimated emissions do not 

meet either of these conditions, a General Conformity Determination must be performed to 

ascertain how the alternative would conform to the applicable SIP. 

Smoke Emissions Modeling - Four pieces of information are needed to calculate potential 

emissions produced from either wildfire or prescribed fire; acres burned, fuel loading, fuel type 

and type of burning (pile, understory or wildfire) that can determine the amount of fuel 

consumed. The actions proposed by each alternative are used to estimate these as well as 

information within the Fire/Fuels Report-Fish Camp Project. Associated emissions for criteria 

pollutants are derived utilizing an emissions spreadsheet developed and approved for prescribed 

fire emission reporting purposes. This form was developed and built by the Interagency Smoke 

Management Group and SJVAPCD staff from emission formulas from publications (EPA, AP42).

Vegetation Harvesting Equipment Emissions Modeling - Information needed to calculate 

associated emissions produced by vehicular traffic from road work and mechanical treatments 

included in Alternatives 2 and 3 (thinning operations, mastication and dozer piling) are; type of 

equipment and the number of hours this equipment is expected to run. The actions proposed by 

each are used to estimate these. Equipment hours are based on average production rates from 

similar projects. Equipment typically used for this type of work includes; heavy duty dieselpowered vehicles (tractor-trailers log trucks), wheeled skidders and loaders, track type 

dozers/masticators, road graders, and smaller gasoline powered engines such as chainsaws. 

Emission factors for criteria pollutants are from “A Desk Reference for National Environmental 

Policy Act (NEPA) Air Quality Analysis” (CH2Hill 1995) and converted to total tons of 

pollutant.

Fugitive Dust Emissions - The Forest Service routinely requires timber sale operators to abate 

dust during use of the forest development roads. This is required for several reasons among 

which are: retaining road surface fines which help keep the larger supporting aggregate together; 

reduce dust visibility traffic hazards; reduce environmental dust plumes; and minimize loose fine 

material accumulations which can create muddy, road rutting conditions. (Lowe, 1994)

Fugitive (visible) dust emissions (VDE) by general vehicle movement are calculated at 10 pounds 

per day for 5 vehicles per day on unpaved roads. This figure is reduced to 3.63 pounds per day 

per mile of VDE after dust abatement. This is accomplished through watering of roads or other 

dust abatement measures which are incorporated into the project design. Dust abatement is 

required for roads below 3000 feet in elevation in the San Joaquin Valley Air Basin. The Fish 

Camp Project is above 3,000 feet in elevation and is exempt from Regulation VIII, Rule 8011 

General Requirements (www.valleyair.org), though dust abatements is still required by the Forest 

Service. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 183 Chapter 3 – Affected Environment 

Because of this exemption and the use of abatement measures when they are not a requirement, 

specific calculations for fugitive dust emissions are not used in the analysis of potential emissions 

from this project, but are considered part of the direct, indirect and cumulative effects. 

Modeling Used in Analysis - Associated emissions for criteria pollutants are derived utilizing an 

emissions spreadsheet developed and approved for prescribed fire emission reporting purposes. 

This form was developed and built by the Interagency Smoke Management Group and SJVAPCD 

staff from emission formulas from publications (EPA, AP-42). 

 Forest Vegetation Simulator with the Fire/Fuels Extension was used to model PM2.5 

emissions to show a comparison between the action and no-action alternatives. PM2.5 

was used as a surrogate for PM10 emissions. FVS models a fire in the year 2022, 10-

years after treatments. 

Incomplete and Unavailable Information 

Assumptions - This determination assumes that prescribed burning would occur under optimal 

atmospheric conditions for the transport of smoke and pollutants away from the San Joaquin 

Valley as regulated by SJVAPCD. Burning of natural and activity created dead and down woody 

material would occur under Best Available Control Measures (BACMS) for Air Quality as 

defined in Chapter 2.

Past, Present, and Foreseeable Activities Relevant to Cumulative 

Effects Analysis 

Cumulative effects analysis for the Fish Camp project air quality analysis is spatially bounded by 

the San Joaquin Valley air basin and temporally bounded by a period of 20 years which is the 

expected rotation based on the life of the stand. The potential cumulative effects are from 

exposure to organic hydrocarbons (precursors to smog under high daytime temperatures), large 

particulate matter, and PM10 and PM2.5 produced from prescribed burning. These emissions are 

easily inhaled and cause respiratory and pulmonary distress. 

The dispersion of pollutants is affected by local meteorological conditions. Pollutants can stay 

trapped in one place if there is no mixing caused by wind and temperatures. Prescribed burns are 

conducted on days when atmospheric ventilation transports smoke and pollutants away from the 

San Joaquin Valley and pollutants are not normally a problem. Burns are conducted on authorized 

burn days only in consultation with the APCD. Poor ventilation occurs during summer and fall 

months when the valley is characterized by relatively stable air masses. Ozone concentrations can 

reach peak levels when strong sunshine and temperatures above 95 degrees F accompany periods 

of poor ventilation. Although ozone is not released directly to the atmosphere, it is produced by 

chemical reactions involving VOCs and NOX. The meteorological factors favorable to significant 

ozone formation occur only during the summer. 

Past Activities - Air quality in the San Joaquin Valley air basin is among the poorest in the State. 

With the hot, dry summers, the San Joaquin Air Basin, in 2009, experienced 98 days above the 

federal standard for 8-hour ozone and 122 days above the state standard. Madera County, by 

itself, was above the federal 8-hour ozone standard 13 days and 27 days above the state standard 

(www.arb.ca.gov ; Trends Summary). For PM10 in 2009, the estimated days over the federal 

standard was two, with 123 days estimated over the state standard. For PM2.5 in 2009, the annual 

average days over the federal standard were 23, with 21 days over the state standard 

(www.arb.ca.gov ; Trends Summary). 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 184 Chapter 3 – Affected Environment 

Present Activities – Mariposa County is considered in nonattainment for both federal and state 

standards for ozone, Madera County is considered in nonattainment for state PM10, PM2.5 and 

ozone standards. The air basin is in federal attainment (maintenance level) for PM10, but is in 

federal nonattainment for PM2.5 and is expecting a reclassification from serious to extreme 

nonattainment for 8-hour ozone. 

The Bass Lake Ranger District’s (BLRD) prescribed fire program continues to be part of the 

district program of work. All of the prescribed fire projects have gone through an air quality 

analysis during the NEPA process. The cumulative effect of smoke emissions and degradation of 

visibility may occur if prescribed burns were to continue during stable atmospheric conditions 

that are present when wildfires occur. For this reason, all prescribed fire activities are coordinated 

with SJVAPCD and would be implemented under optimum conditions using best available 

control measures to prevent smoke concentrations from affecting local communities. 

Reasonably Foreseeable Activities – Reasonably foreseeable projects on the BLRD that could 

contribute to cumulative effects include the afore-mentioned district prescribed burn program, the 

Yosemite National Park prescribed fire program, Sugar Pine Adaptive Management and Cedar 

Valley projects, cattle grazing, special use permits, vegetation management within plantations 

(mastication), hazard tree sales, Off Highway Vehicle (OHV) use, and private land management 

activities. 

Projects that could contribute to air quality cumulative effects from exhaust emissions and/or 

fugitive dust through vehicle and heavy equipment can be expected from mechanical treatment 

for the Sugar Pine Adaptive Management and Cedar Valley project, vegetation management 

(mastication) within plantations, hazard tree sales, and OHV use. It is unknown how much heavy 

equipment use and vegetation management may occur on private property.

Projects that could and possible will contribute to air quality cumulative effects from particulate 

matter PM10 and NOx include Yosemite National Park prescribed fire program, BLRD’s 

prescribed fire program, vegetation treatments through prescribed fire for the Sugar Pine 

Adaptive Management project. It is unknown how much prescribed burning may take place as 

part of the Yosemite National Park burning program. All prescribed burn activities on private 

and public lands follow the same general conformity rules and are governed by the decisions of 

the Mountain Counties APCD, SJVAPCD and the Sierra National Forest. 

In conjunction with the typical period when prescribed burn implementation occurs, is an 

increased use of wood burning stoves and hazard reduction burning by local residences in the 

area. There are restrictions in place on the valley floor (residences below 3000 feet in elevation) 

to limit the use of wood burning stoves during poor dispersion days, but because older residences 

above 3000 feet in elevation typically only have wood burning stoves as their sole source of heat, 

there are little restrictions above 3000 feet elevation. Hazard reduction burning is regulated by a 

permitting process as well as burning only on “affirmative” burn days when meteorological 

conditions are adequate for good dispersion and dilution of pollutants. These affirmative burn 

days are fairly sporadic and can lead to high numbers of residences burning on the same day, 

especially during weekends. The SJVAPCD has created an educational program for the public on 

how to burn “cleaner” and presented some of the Best Available Control Measures for Hazard 

Reduction burning activities. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 185 Chapter 3 – Affected Environment 

Alternative 1 – No Action 

No actions would be taken to reduce stand densities to improve forest health and reduce the 

intensity and spread of wildland fires The opportunity would be loss for undertaking treatments 

to reduce the impacts that a wildland fire, starting in hot dry conditions, would cause the 

environment; both the forest environment and the airshed. 

Direct Effects 

No direct effects from management actions to air quality or visibility would occur under this 

alternative since no treatments would be completed outside of that which is already permitted or 

authorized. 

Indirect Effects 

The indirect and cumulative effects include the potential for unplanned ignitions and uncontrolled 

wildfires to occur in the area. The resultant smoke caused by these would have large amounts of 

emissions released and could potentially be of long duration. Values measured such as PM10 and 

visibility range used to determine the Health-Protective Value would be in the ranges assumed to 

be Unhealthy. Values associated with this rating are PM10 ranging from 176 to 300 μg/m3 and 

visibility of 1.24 to 2 miles (considered moderate smoke conditions). This would be considered 

the lower of the Health-Protective Values a wildfire would produce, if it occurred in the area. It 

is anticipated that for short periods of time the values may rise to the levels considered Very 

Unhealthy or perhaps Hazardous. The Statewide Emission Inventory in 2002 reported emissions 

(tons/day, annual average) from wildfires (Ahjua 2006) and is demonstrated in Table 44. 

Table 44: Statewide Emission Inventory for Natural Sources-Wildfire 

Emissions Total 

Organic 

Gases 

Reactive 

Organic 

Gases 

Carbon 

Monoxide 

Nitrogen 

Oxides 

Sulfur 

Oxides 

PM10

Natural 

Sources: 

Wildfire 

6,522 3,046 17,474 3,441 302 2,418 

Total Organic Carbon (TOC) and Reactive Organic Carbon (ROC) are similar to Volatile Organic Carbon (VOC) and 

all are used by the air resources board to describe gases that lead to Ozone formation. 

The high summer temperatures and light wind speeds that occur during the summer months, 

places a cap on valley air with no means for cleansing itself by dispersion or transport. Because of 

the poor air quality associated with the San Joaquin Valley Air Basin it does not take large 

amounts of additional emissions to degrade air quality into unhealthy ranges especially in the 

summer and fall months, where storm systems are less likely to occur and disperse smog and 

emissions. Emissions from a wildfire could potentially have long lasting impacts beyond the 

initial burning period because of this. Uncontrolled wildfires are clearly responsible for the most 

widespread, prolonged, and severe periods of air quality degradation (Ahuja, 2006). For 

comparison purposes with the purposed Alternative, table 45 below demonstrates the emissions 

produced from a wildfire if the acres in the Fish Camp Project were affected by an uncontrolled 

wildfire during typical fire season. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 186 Chapter 3 – Affected Environment 

Table 45: Potential emissions if a wildfire were to burn within the entire Fish 

Project boundary. 

Emissions 

Fuel Type Total 

Acres 

Fuel 

Loading 

(Tons/ 

acre) 

Total tons Tons 

PM10

Tons 

PM2.5

Tons Nox Tons SO2 Tons VOC Tons 

CO 

Forest 5440 20 108800 1332.80 1196.00 190.4 5.4 788.80 12675.2

Cumulative Effects 

As no action is being taken by the SNF under the No Action Alternative by definition there would 

be no cumulative effects. See FEIS page 31 for more explanation. 

Common to Alternative 2 and 3 

Treatments are proposed to reduce surface, ladder fuels and some aerial fuels to meet the purpose 

and need of reducing the intensity and spread of wildland fires as well as reduce stand densities. 

This is to occur, if these alternatives were chosen, through the use of mechanical methods 

(thinning from below and mastication) as well as management ignited fire in the form of 

prescribed fires such as pile burning, understory burning and/or broadcast burning. Prescribed 

fire would be applied to the Project area for three purposes: (1) as a final “cleaning” after 

vegetation management treatments to further reduce 1, 10 and 100 hours fuels (those fuels that 

have the greatest influence on fire spread); (2) to maintain the lower levels of the 1, 10, and 100 

hours fuels; (3) to reintroduce the fire element back into a fire dependent ecosystem. 

Emissions from smoke produced by prescribed fire implementation are estimated using the 

number of acres to be burned, the surface fuel loading of the area being burned and the amount of 

consumption. 

Within the treatment areas and based on the criteria provided in the Fire/Fuels Design Criteria 

Common to all Alternatives, it is estimated that approximately 1,367 acres could have prescribed 

fire used for maintenance treatment of surface fuels. There is a total of 401 acres that is proposed 

to utilize prescribed fire as the primary treatment type (prescribed treatment areas). This 

treatment involves the application of prescribed fire over a broad area and would need to have 

specific conditions prior to ignition. It is estimated that, as conditions permit, these types of 

prescribed fires could take up to 10 years to fully implement and would be used, as needed, to 

maintain surface fuel loadings at or below 10 to 20 tons/acre. 

Dependent on where and how prescribed fire treatments are being utilized, the fuel loading can 

range from 3 to 30 tons per acre and be in the form of machine or hand created piles and/or in 

concentrations across a broad area such as the case in understory burning. On average the fuel 

loading for an area requiring prescribed fire as a primary treatment, maintenance and/or post 

activity treatment would be 20 tons/acre. 

The main focus of prescribed fire implementation is to reduce surface fuel loadings that 

contribute to fire behavior rates of spread and flame length the greatest. These are the 1, 10 and 

100 hour time lag categories (mainly needles, twigs and branches less than 3 inches in diameter). 

prescribed fire burn plans set objectives for what percent consumption of these fuels are to be 

accomplished by the implementation of the prescribed fire. For pile burning, burn plan objectives 

typically set the objective at 75 to 80 percent consumption. Pile burning is conducted when the 

fuels have had a period of time to dry and are no longer green. For understory burning, burn plan 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 187 Chapter 3 – Affected Environment 

objectives typically set the objectives at 60 to 70 percent consumption (or reduction) of these 

fuels, though this would not be across the entire burn area. A typical understory burn is 

implemented to create a “mosaic” burn pattern, leaving patches of unburned areas amongst 

burned areas. 

Alternative 2 – Proposed Action 

Associated emissions from mechanical equipment used in thinning and hauling operations and 

emissions produced from burning are shown in table 45. Hazard fuels treatments, including 

prescribed fire, proposed for this Proposed Action can be found in Chapter 2 – Alternatives 

Considered in Detail of the Fish Camp Environmental Impact Statement 

Design Features and Mitigation Measures 

The following are BACMs for prescribed fire as required under Section 190 of the CAA, as 

amended in 1990. The U.S. Environmental Protection Agency developed implementation 

strategies and BACMs for areas that are designated serious non-attainment for particulate matter 

less than 10 microns (PM10) in 1992. Specific techniques to reduce fire emissions include the 

following: 

 Employ commonly used reduction techniques such as burning units after harvest 

before new live fuels appear; burning in the springtime prior to “green-up,” burning 

when 1,000-hour fuels (woody debris larger than 3 inches in diameter) moistures are 

high, and burning when the duff is wet (after fall precipitation, or during winter and 

spring). 

 Employ avoidance techniques such as burning on cloudy days when the plume and 

residual smoke cannot be seen, burning during periods of atmospheric instability for 

better smoke dispersal, and burning during periods of low visitor use. 

 Employ techniques to optimize flaming combustion, including burning piled fuels 

rather than broadcast burning, reducing the amount of soil in piles, and employing 

rapid ignition to create a high intensity fire. 

 Ensure that all activities conform to the State Implementation Plan (SIP) 

 Conduct a full conformity analysis, as required by the Clean Air Act and the SIP to 

assess whether the Proposed Action produces less than de minimus emissions. (For 

full determination, refer to the Kings River Project Air Determination, available in 

the project record.). 

Direct Effects 

Smoke Emissions - This alternative proposes to accomplish up to1,367 acres of prescribed fire; 

both underburning and pile burning combined. If feasible, there could be the option to dispose 

activity fuels through masticate thus reducing the need of pile burning in some areas. When 

completed, prescribed fire activities proposed under this action would create the following 

emissions.

Table 46: Total Emissions from All Prescribed Fire Treatments Proposed in this 

Action (in tons) 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 188 Chapter 3 – Affected Environment 

Treatment 

Type 

Tons 

per 

acre 

Total 

Acres PM10 PM2.5 NOx SO2 VOC CO 

Dozer Pile 20 966 75.35 70.52 50.23 .10 60.86 637.56 

Underburn 

Only 20 401 98.25 82.22 14.04 0.40 58.15 934.33 

PM10 = Particulate matter <10 microns in size, PM2.5 = Particulate matter <2.5 microns in size, 

NOX = Nitrous oxide, SO2 = Sulfur dioxide, VOCs = Volatile Organic Compounds, CO = 

Carbon monoxide 

Vegetation Harvesting Equipment - Equipment hours are based on average production rates 

from similar projects on the BLRD. Most of the material would be thinned by chainsaw and 

skidded. Piling and mastication of activity created slash and brush would be with a track type 

tractor. For this analysis, all emissions are based upon use of wheeled skidders and loaders, 

heavy duty diesel powered highway truck and track type dozer or dozer with mastication head. 

Table 47: Total tons of emissions for mechanical treatments and road maintenancereconstruction activities for the completion of operations in Alternative 2. 

Type of 

Equipment 

Total 

Number 

of Hours 

PM Exhaust 

Hydrocarbons NOx CO SOx 

Wheeled Tractor 1344 0.09 0.13 0.85 2.48 0.06 

Wheeled Loader 378 0.01 0.02 0.16 0.04 0.01 

Heavy Duty Diesel 

Powered Truck 7404 0.95 0.71 15.42 6.64 1.68 

Track Type Tractor 14,000 0.78 0.85 8.82 2.42 0.96 

Motor grader 77 0.00 0.00 0.03 0.01 0.00 

Total 

(Entire Project) 23,203 1.83 1.71 25.28 11.59 2.71 

Fugitive Dust Emissions - The Forest Service routinely requires timber sale operators to abate 

dust during use of the forest development roads. This is required for several reasons, including 

retaining road surface fine particles, which helps keep the larger supporting aggregate together; 

reducing dust visibility traffic hazards; reducing environmental dust plumes; and minimizing 

loose fine material accumulations which can create muddy, road rutting conditions (Lowe 1994 as 

cited in USDA Forest Service 2008). 

Visible dust emissions (VDE [PM10] by general vehicle movement are calculated at 10 lbs per 

day for 5 vehicles per day on unpaved roads. This figure is reduced to 3.63 pounds per day per 

mile of VDE after dust abatement through watering of roads or other dust abatement measures, 

which are incorporated into the project design features. For the Proposed Action, 3.63 pounds per 

day x 22 days to haul = 79.86 pounds, which is below de minimus. De minimus is set at 100 

pounds per day for 50 vehicle trips on unpaved roads. Dust abatement is required for roads below 

3,000 feet in elevation. The Fish Camp Project area is above 3,000 feet in elevation and is exempt 

from Regulation VIII, Rule 8011 General Requirements, though dust abatement is still required 

by the Forest Service. 

 Table 48: Emissions conformity to General Conformity Rule for Criteria Pollutants 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 189 Chapter 3 – Affected Environment 

Total Emissions 

(smoke and equipment) 

PM10 

175.43 

PM2.5 

158.74 

NOx 

44.55 

Percent of Areas Total 1.45% 0.5% 0.08% 

 Criteria Pollutants are those that determined by EPA to have de minimus levels 

Indirect Effects 

The community of Fish Camp, state highways, Class I Airsheds, and recreation sites are 

considered smoke sensitive areas. These areas could be affected by smoke if weather patterns 

produce a stable air mass and smoke is unable to vent into the upper atmosphere. Since PM10 and 

ozone are public health hazards, prescribed burns would be planned during periods of unstable 

air, which would allow for proper ventilation of smoke and temperatures less than 95 degrees. 

However, since prescribed underburns could last for several days or weeks there is the potential 

for recurring shifts in air masses toward more stable conditions. For this reason, all prescribed fire 

activities are coordinated with SJVAPCD and would be implemented under optimum conditions 

using best available control measures (listed in the Proposed Action) to prevent smoke 

concentrations from affecting local communities. 

Cumulative Effects 

Annual trends in ozone and PM air pollution are decreasing largely due to State regulations for 

vehicle emissions. This is expected to continue as technology and regulations to reduce 

emissions are implemented. In addition, mechanical treatments (harvesting) contribution to air 

pollution in particular appears to be on a downward trend likely due to decreased logging activity. 

The incremental effects of Alternative 2 when added to past, present and foreseeable future 

activities, are not likely to influence this trend of reduced logging associated emissions. 

From past implementation of prescribed burning on the Bass Lake Ranger District and in 

particular prescribed burns within the vicinity of the Fish Camp Project, mitigations limiting the 

number of acres burned per day, burning during optimal transport wind directions/speeds, higher 

mixing heights and the quantity of other prescribed fires being conducted are considered prior to 

air district final approval to reduce potential impacts to sensitive receptors. This has been 

extended into limiting the number of days burning can occur, and requiring all active ignitions to 

end by late afternoon to reduce smoke production at night time and to limiting the number of 

consecutive days burning can occur to reduce the amount of emissions produced at any one time. 

Close communication with the APCD compliance staff before and during implementation and 

monitoring smoke conditions will aid in determining if there are impacts on sensitive receptors 

and Class I airsheds in the area are beginning and additional mitigations are required. 

Cumulative effects can be caused by outside influences not associated with the project itself. 

Because of the rural surroundings, many residences utilize wood burning stoves as their main 

source of home heating. Hazard reduction burning is also permitted in rural communities in 

Madera and Mariposa counties. This can lead to cumulative impacts if prescribed fire is 

conducted on what is considered a marginal dispersal day when added to wood stove smoke and 

increased numbers of hazard reduction burns within the communities in or surrounding the 

Project area. 

Compliance with Forest Plan and Other Relevant Laws, Regulations, 

Policies and Plans 

The conformity decision for the CAA prohibits federal agencies from permitting or approving 

any activity that does not conform to the SIP. The CARB under the General Conformity Rule 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 190 Chapter 3 – Affected Environment 

regulates actions that require conformity determinations for specific pollutants. The CARB rules 

indicate that projects would be determined to conform to the applicable SIP if it meets the 

following criteria: 

a. The total direct and indirect emissions from the action is in compliance with all 

requirements of SIP, because the actions meet one or more of the following: 

a. The emissions from the action are identified and accounted for in the applicable SIPs 

attainment or maintenance demonstrations, 

b. The emissions are offset, 

c. Based on air quality monitoring, the actions do not: 

i. Cause or contribute to any new violation of any standard in any area, or 

ii. Increase the severity or frequency of any existing violations of any standard, 

d. The state commits to modify SIP in accordance with the EPA rules, or 

e. Where the EPA has not approved a revision of the relevant SIP, the total emissions 

do not exceed the historical level (based on the calendar year 1990 or other 

appropriately agreed to year). 

 Title 17 of the California Code of Regulations – Subchapter 2, Smoke management 

Guidelines for Agriculture and Prescribed Burning 

 San Joaquin Valley Unified Air Pollution Control District Rule 3160 (Prescribed 

Burning Fee), Rule4106 (Prescribed Burning and Hazard Reduction Burning), and 

the District’s Smoke Management Program, Rule 4103 (Agricultural Burning) 

 Wildland Fires Coordination and Communication Protocol as it applies to the Current 

Smoke Management Program 

 Public Resource Code 4291 – for hazard Reduction Burning in the foothill and 

mountain areas of the District. 

Other Relevant Mandatory Disclosures 

Exhaust hydrocarbons and pollutant levels produced from thinning activities are lower than 

historical levels of logging and similar activities for the Sierra National Forest. Historical timber 

harvesting and thinning operations were at all time highs in 1987 with 154 million board feet of 

timber harvested. The thinning in this alternative is approximately 2.5precent of that historical 

level.

Summary of Effects 

This project meets the General Conformity Rule; it does not interfere with the strategies 

employed to attain NAAQS. The emissions from this project are considered regionally 

insignificant (total emissions are less than 10%) of the area’s total emissions inventory for PM10

and NOx. This conformity is accomplished by maintaining burn ignitions and acres within rules 

and guidelines developed by the SJVAPCD, as provided for by the CARB, under the Unified 

Guidelines for Smoke Management as developed by the Southern Sierra Interagency Smoke 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 191 Chapter 3 – Affected Environment 

Management Group. These guidelines and rules are based on the requirements found in the 

following: 

Based upon meeting the SIP standards of CARB, the Unified Smoke guidelines discussed above 

and SJVUAPCD rules, the project is determined to be in compliance with SIPs General 

Conformity Rule and Title 17 of the California Code of Regulations. It is important when 

considering the determination that compliance with SIP is based upon meeting rules and 

guidelines managed by SJVUAPCD. These rules and guidelines are designed to meet historical 

emissions levels and keep projects from violating the SIP. The alternatives propose activities that 

will meet the rules and guidelines. Rules and guidelines along with daily SJVUAPCD direction 

control acres and ignitions. Meeting the acres and ignition rules and guidelines meets conformity 

with the SIP emission standards. 

Alternative 3 – Lower and Limited Mid-Level Canopy Treatments, All 

Treatment Areas 

Design Features and Mitigation Measures 

Design features would remain the same as described in Alternative 2. 

Direct Effects 

Alternative 3 would not alter the number of acres where ladder and surface fuels are to be 

reduced through treatments, but would potentially have lower amounts of post activity surface 

fuels (tons/acre). As in Alternative 2, prescribed burning would be utilized to reduce surface fuel 

loading as either an initial treatment (understory/broadcast) or as a post activity treatment (pile 

burning). Mastication and road reconstruction/maintenance would continue with Alternative 3. 

With no commercial thinning operations, emissions from mechanical treatments would be 

reduced significantly from Alternative 2 and would have the potential of reducing the amount of 

acres in which pile burning would be needed reducing the amount of emissions from prescribed 

burning. Understory burning would remain the same as in alternative 2. Thus the direct effects 

of Alternative 3, would be the similar to Alternatives 2, but would be to a lesser degree. 

Indirect Effects 

Indirect effects for this alternative are the same as those described in Alternative 2. 

Cumulative Effects 

The cumulative effect of this alternative is similar to those under Alternative 2. The changes in 

the diameter limit of thinning among the alternatives alter the amount of trees removed under 

each alternative. These changes alter the amount of emissions that would be generated by 

prescribed fire. The differences in each alternative are represented by the amount of smoke that 

would be produced by a wildfire. 

Compliance with Forest Plan and Other Relevant Laws, Regulations, 

Policies and Plans 

Alternative 2 & 3 would comply with the SNF-LRMP, Regulatory Frameworks, and Air Quality 

regulations and Policies. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 192 Chapter 3 – Affected Environment 

Other Relevant Mandatory Disclosures 

The incremental effects of smoke, dust and emissions created by the Proposed Actions in 

Alternative and 3 when added to the past, present and foreseeable future activities are not 

expected to 1) cause or contribute to any new violation of any standard in any area; 2) increase 

the frequency or severity of any existing violation of any standard in any area; or 3) delay timely 

attainment of any standard or any required interim emission reductions or other milestones in any 

area. (CAA Sec 176 (c) (1)) as further defined by San Joaquin Valley APCD Rule 9110-General 

Conformity, §51.853 and is expected to conform to the State Implementation Plan for the 

associated criteria pollutants of NOx, VOC, PM10 and PM2.5. This determination would be in 

compliance with the Sierra National Forest Land and Resource Management Plan’s goals as well 

as meet the Standards and Guidelines written for air quality and visibility. 

Monitoring 

As part of prescribed fire implementation, burn bosses are to make observations on a regular basis 

of the smoke conditions that are being created by implementation. These include the travel 

direction and dispersion quality of smoke such as smoke settling into smoke sensitive areas and 

continued or potential for visibility degradation especially across main travel routes. When 

possible, lighting techniques and/or burn operations are changed to minimize the continuance of 

these impacts. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 193 Chapter 3 – Affected Environment 

Engineering / Transportation _______________________ 

The direct, indirect and cumulative effects to the transportation resource are summarized from the 

Engineering Report for the Fish Camp Project (Hosford, A. 11/15/2010). 

Affected Environment 

The existing transportation system for the Fish Camp Project consists of approximately 42.2 

miles of National Forest System Roads [(NFSR) map 11]. Mariposa County maintains 0.7 miles 

of roadway. The transportation system for the analysis area is nearly complete. Small areas may 

be identified during project planning where minor amounts of new permanent road and temporary 

road construction are needed. 

 

There are 35.9 miles of NFS native and aggregate surfaced roads and approximately 6.3 miles of 

paved roadway. These native surfaced roads are not suited for wet weather use due to erosive 

soils and lack of armoring. 

Most system roads are in poor condition and are experiencing erosion problems due to limited 

road maintenance, wet weather use, and erosive soils. Many of the local roads have received 

little to no maintenance over the years and will require heavy maintenance and/or reconstruction 

to eliminate resource damage and meet acceptable standards established in the Forest Service 

Handbook 7709.58. 

Alternative 1 – No Action 

Direct, Indirect and Cumulative Effects 

Under the No Action alternative, no project activities would take place. Existing road 

maintenance and reconstruction needed to eliminate resource damage and support equipment 

access would not take place. No road reconstruction activities would take place on local roads 

and no new road construction would be needed. The transportation system for the area would not 

be updated and improved by this project to meet current access management direction. The 

results are negative effects on access and environmental resources and loss of the infrastructure 

investment. 

As no action is being taken by the SNF under the No Action Alternative by definition there would 

be no cumulative effects. See FEIS page 31 for more explanation. 

Alternative 2 – Proposed Action 

Direct, Indirect Effects 

This relatively low traffic volume road system has received less maintenance in recent years. 

These roads, mostly maintenance level 2, comprise most of the miles of the road system. Many 

of them are brushing in and washing out. The highest priority for District road management will 

continue to be safety for the traveling public and employees and improvement and restoration of 

roads with resource or access needs. 

The Fish Camp Adaptive Management project is proposing to perform road maintenance and/or 

road reconstruction activities on all or portions of roads 5S06, 5S06A, 5S06G, 5S06GA, 5S22, 

5S22X, 5S22XA, 5S22XC, 5S37, 5S43, 5S43C, 6S07 and 6S10. These roads will require a final 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 194 Chapter 3 – Affected Environment 

field review prior to project activities to determine complete road reconstruction and/or road 

maintenance needs. There may be short term road control/limited public access during project 

implementation. 

The transportation system for the area will be updated and improved by this project to meet 

current access management direction. These updates will result in preserving and updating access, 

increased safety of the system roads in the Project area, protection of environmental resources, 

and continuation of the infrastructure investment. 

Existing road densities, in general, are acceptable from a wildlife perspective. Any system roads 

or unclassified roads not needed will be decommissioned to enhance wildlife habitat and reduce 

road densities to a more desired level. 

Alternative 3 

Direct, Indirect and Cumulative Effects 

In Alternative 3, treatment areas would remain the same as in Alternative 2. Direct, indirect and 

cumulative effects would remain the same as in Alternative 2. 

Economics ______________________________________ 

The Fish Camp Project area was selected for treatment based on analysis of stand density and 

forest health in the upper Big Creek watershed. Hazardous fuel reduction and stand density 

management is important here due to the proximity of the Project area to the community of Fish 

Camp and Yosemite National Park. The area supports recreation opportunities on and off the 

SNF, including special use permits issued by the forest. Treatments are needed to prevent similar 

situations that occurred in the last decade in Arizona and New Mexico and on the San Bernardino 

National Forest, where thousands of acres of trees died from insect mortality due to over-stocked 

conditions. Fuel reduction and density management treatments proposed would: (1) generate 

sawtimber volume, (2) help stimulate the economy through the utilization of forest projects, and 

(3) maintain jobs in the local timber and vegetation management industries. 

Currently (2009) the Sierra NF is providing timber for three remaining sawmills, Sierra Forest 

Products (SFP), Terra Bella, CA, and Sierra Pacific Industries (SPI), at Chinese Camp, CA, and 

at Standard, CA. The SFP mill is the last remaining sawmill in California south of Yosemite 

National Park. This mill also operates a wood-fired electrical power plant co-located with its 

mill, which utilizes a portion of its lumber manufacturing waste product. Lumber manufacturing 

waste products are also utilized in several other markets including landscaping. SFP is a 

qualifying Small Business and SPI is a Large Business in computations for Small Business 

Administration market share monitoring purposes. SFP is approximately 80% dependent upon 

raw material from Federal Lands Conversely, the Sierra, and Sequoia National Forests are almost 

100% dependent upon the SFP milling infrastructure to process and give value to excess tree 

inventories in the woods when considering fuels and fire management, forest health maintenance, 

and wildlife habitat restoration. In order to implement the types of projects considered in this 

analysis, an economically viable infrastructure is necessary now and into the future. Maintenance 

of such an infrastructure is voiced as a concern by some segments of the public. 

The current depressed lumber market has caused sawtimber value to drop to historic lows. This 

depressed lumber market is the result of reduced housing starts and the consequences of the 

current global recession. In addition to the poor lumber market, local sawmills are in dire need of 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 195 Chapter 3 – Affected Environment 

forest products to keep them open. If these mills close, the ability to utilize forest products in the 

future and offset treatment costs would be lost. The district recognizes that the project would cost 

more money than it could generate from the forest products removed. Therefore, additional 

appropriated dollars would need to be requested to complete any of the action alternatives. 

Treatments prescribed were developed with regard to those activities necessary to reduce the 

intensity and spread of wildfire and reduce stand density, not to provide positive economic 

returns. An economic analysis is required to comply with NEPA guidelines and can generally be 

helpful in selecting an alternative by showing comparative costs and\or revenues between 

alternatives. However, economics will not be a deciding factor for selecting any action 

alternative for the Fish Camp Project. Instead, alternative selection will be based on the 

alternative that best accomplishes the purpose and need of the project. This economic analysis, 

will give the public an approximate comparison of costs between alternatives. 

The economic analysis for the Fish Camp Project is divided into three sections. The first section 

is the net value of harvested sawtimber taking into account the value of the sawtimber minus the 

stump to mill cost. The second section is the cost of other prescribed treatments within the 

Project area that address non-commercial vegetation treatments. The final section is an analysis 

of employment benefits both directly and indirectly based on the relationship between 

employment and harvesting in California. Besides the above described cost and benefits, other 

fixed costs are associated with the proposal. The cost of producing the environmental document 

is approximately $95,000. Prior to project implementation there are project preparation costs of 

$11.80/ccf. During project implementation there are contract administration costs of $10.80/ccf. 

Tables 49 and 50 display the comparison of both action alternatives for product value, 

implementation costs, and employment benefits. Both action alternatives would require 

appropriated dollars to complete the work. Alternative 2 would require the most appropriated 

dollars to complete implementation and is estimated at $779,057. It would require approximately 

$31,426 more in appropriated funds than alternative 3. However, the employment benefits would 

be approximately $1,323,140 higher than alternative 3. The extra $31,426 required to implement 

alternative 2 would result in 562 more acres treated for density management, providing improved 

stand vigor and creating a more resilient forest to density induced mortality. The density 

management treatments also create more stand heterogeneity by promoting oak growth with the 

removal of larger trees that are overtopping oaks and by influencing the selection of tree removal 

over a greater extent. This is an investment of only an extra $55.92 per acre to fully implement 

the project purpose and need. Fire and fuel objective treatments in the Project area would reduce 

fire risk and provide public benefit. Measurement of this benefit is outlined in the paper 

Investment in Fuel Removals to Avoid Forest Fires Result in Substantial Benefits (Mason et al, 

2006). For both action alternatives, fire risk would be reduced in units proposed for commercial 

thinning (404 acres) and those treatment areas where hand thinning/tractor pile/burn pile, 

mastication, and underburn take place outside of alternative 3 cut units. The fire reduction 

benefit could be as much as $654,100 in either action alternative. 

This analysis compares the project value based on product value, implementation cost, and 

employment benefits for the action alternatives. The no action alternative does not have any 

product value or implementation costs, but has the cost of producing the environmental document 

and the benefit of providing Forest Service employment. The no action alternative is neutral in 

respect to this analysis because its cost equals its benefit. 

The employment benefit of implementing product removal and fuel reduction treatments is an 

important aspect in project economics. Whenever you have a project that puts people to work 

and provides a product to the free market, there are societal benefits derived. Woods workers, 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 196 Chapter 3 – Affected Environment 

truck drivers, and mill workers are directly employed and the taxes they pay benefit both Federal 

and State Government. Yield taxes are collected from Purchasers upon cutting sawtimber and are 

paid to the State. Processed materials from mills eventually reach retail stores and provide jobs 

for retail workers and income and sales tax to Federal and State Government. These societal 

benefits are a by-product of the prescribed treatments designed to meet the purpose and need of 

this project. When greater amounts of forest products are removed from a project, more societal 

benefits are realized. Alternative 2 would provide the greatest societal benefits. Generally, for 

each million board feet of product removal, approximately 13 jobs are supported both directly 

and indirectly. This ratio can range from 10 jobs to 18 jobs depending on location and the type of 

products removed. In addition to product removal, other vegetation treatments in the Project area 

help support the local economy. Table 51 displays the anticipated number of full time jobs 

supported by vegetation treatments other than product removal. 

Table 49: Fish Camp economic analysis for alternative 2

Value - Sawtimber1

Total Acres = 966 

PP 10 inch - 29.9 

inch sawtimber 

54% 4980 ccf x $85.24 /ccf $424,495 

SP 10 inch - 29.9 

inch sawtimber 

6% 518 ccf x $98.34 /ccf $50,940 

WF 10 inch - 29.9 

inch sawtimber 

30% 2757 ccf x $162.15 /ccf $447,048 

IC 10 inch - 29.9 

inch sawtimber 

10% 888 ccf x $174.39 /ccf $154,858 

LP 10 inch - 29.9 

inch sawtimber 

0% 3 ccf x $110.26 /ccf $331 

 

Total Value 9146 ccf $1,077,672 

Stump to Mill Cost 

Stump to truck Cost 9146 ccf @ $67.62 /ccf $618,453 

Other Cost 9146 ccf @ $8.97 /ccf $82,040 

Road Reconstruction Cost 9146 ccf @ $12.84 /ccf $117,435 

Road Maintenance Cost 9146 ccf @ $3.94 /ccf $36,035 

Temp Road Cost 9146 ccf @ $0.21 /ccf $1,921 

Haul Cost 9146 ccf @ $75.00 /ccf $685,950 

Sawtimber Scale 1143 trips @ $1.60 /trip $1,829 

Advertise Rate Sawtimber 9146 ccf @ $4.40 /ccf ($40,242)

Total Other Cost $1,503,419 

Net Value ($425,747)

Forest Service Agency 

Responsibility 

Full-time 

jobs3

 

Mastication 201 acres x $520 /acre 1 $104,520 

Hand Thin/Stand Clean 393 acres x $125 /acre 4 $49,125 

Tractor Pile 393 acres x $280 /acre 1 $110,040 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 197 Chapter 3 – Affected Environment 

Underburn 401 acres x $150 /acre 1 $60,150 

Burn Tractor Piles 393 acres x $75 /acre 2 $29,475 

 9 jobs 

Total Non Harvest Cost $353,310 

Total Project Value ($779,057)

Fire Reduction Benefits2 $602 /acre 1055 acres $654,100 

Harvest Employment3 59 jobs 

Total Full Time Jobs 68 

Total Employee-Related 

Income $2,737,960 

Table 50: Fish Camp economic analysis for alternative 3

Value - Sawtimber1

Total Acres = 404 

PP 10 inch - 29.9 

inch sawtimber 

98% 3987 ccf x $83.26 /ccf $331,958 

SP 10 inch - 29.9 

inch sawtimber 

0% 12 ccf x $69.74 /ccf $837 

WF 10 inch - 29.9 

inch sawtimber 

0% 18 ccf x $156.90 /ccf $2,824 

IC 10 inch - 29.9 

inch sawtimber 

1% 40 ccf x $167.24 /ccf $6,690 

LP 10 inch - 29.9 

inch sawtimber 

0% 0 ccf x $0.00 /ccf $0 

 

Total Value 4057 ccf $342,308 

Stump to Mill Cost 

Stump to truck Cost 4057 ccf @ $68.93 /ccf $279,649 

Other Cost 4057 ccf @ $8.49 /ccf $34,444 

Road Reconstruction Cost 4057 ccf @ $28.66 /ccf $116,274 

Road Maintenance Cost 4057 ccf @ $4.22 /ccf $17,121 

Temp Road Cost 4057 ccf @ $0.47 /ccf $1,907 

Haul Cost 4057 ccf @ $75.00 /ccf $304,275 

Sawtimber Scale 507 trips @ $1.60 /trip $811 

Advertised Rate Sawtimber 4057 ccf @ $4.40 /ccf ($17,851)

Total Other Cost $736,629 

Net Value ($394,321)

Forest Service Agency 

Responsibility 

Full-time 

Jobs3

 

Mastication 201 acres x $520 /acre 1 $104,520 

Hand Thin/Stand Clean 393 acres x $125 /acre 4 $49,125 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 198 Chapter 3 – Affected Environment 

Tractor Pile 393 acres x $280 /acre 1 $110,040 

Underburn 401 acres x $150 /acre 1 $60,150 

Burn Tractor Piles 393 acres x $75 /acre 2 $29,475 

 9 jobs 

Total Non Harvest Cost $353,310 

Total Project Value ($747,631)

Fire Reduction Benefits2 $620 /acre 1055 acres $654,100 

Harvest Employment3 26 jobs 

Total Full Time Jobs 35 

Total Employee-Related 

Income $1,414,820 

1

Quality Value from R5 Transactional Evidence Appraisal Spreadsheet 

2

C. Larry Mason et al. Jan/Feb 2006. Investment in Fuel Removals to Avoid Forest Fires Result in Substantial Benefits.

Journal of Forestry:27-31 (total of firefighting cost avoided and timber loss avoided) 

3

Based on historical relationships between employment and harvest in California during the 1980's, each million board 

feet harvested supports 6.5 year-around jobs (1 in logging, 4 in sawmill, and 1.5 in US Forest Service employment). In 

regional economic models of employment for California and the Pacific Northwest, an estimate of one indirect or 

induced job for every direct timber job is added. Indirect jobs result from the employment created by the local 

purchase of materials for the sawmill, local expenditures by workers, and the demand for local government employees. 

Each million board feet harvested supports a total of 13 jobs that are timber related. The restoration and fuel work 

would support additional direct and indirect employment. There are approximately 1.4 indirect jobs for every full time 

field job. All jobs are equivalent to year-around employment. 

Table 51: Full time Job relationship to specific project tasks

Task 

# of 

Workers Production 

Acres of 

Treatment 

Direct full 

time jobs 

Indirect full 

time jobs 

Total full 

time jobs 

Mastication 2 4 ac./day 201 0.4 0.6 1 

Hand Thin/Stand 

Clean 1 1 ac./day 393 1.5 2.2 4 

Tractor Pile 2 5 ac./day 393 0.6 0.9 1 

Underburn 10 30 ac./day 401 0.5 0.7 1 

Burn Tractor Piles 7 15 ac./day 393 0.7 1.0 2 

Short-term Uses and Long-term Productivity 

NEPA requires consideration of “the relationship between short-term uses of man’s environment 

and the maintenance and enhancement of long-term productivity” (40 CFR 1502.16). As declared 

by the Congress, this includes using all practicable means and measures, including financial and 

technical assistance, in a manner calculated to foster and promote the general welfare, to create 

and maintain conditions under which man and nature can exist in productive harmony, and fulfill 

the social, economic, and other requirements of present and future generations of Americans 

(NEPA Section 101). 

Maintenance and enhancement of long-term productivity is accomplished through restoration 

treatments that reduce basal area and number of stems (stand density) in over crowed stands. 

Stands that exist presently are no longer sustainable or resilient to changing environmental 

conditions that can and are occurring now and into the future. Drought induced stress, insect or 

disease attacks and wildfire all can have detrimental effects on the forest of today. Short-term 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 199 Chapter 3 – Affected Environment 

activities described in the action alternatives are intended to lead to the enhancement of long-term 

productivity by beginning to restore forest conditions that resilient to disturbances. 

Actions described in Chapter 1 lead to enhancement of long-term productivity, especially: 

 The need to increase the proportion of large trees across a landscape, 

 The need to increase the proportion of fire resistant species such as pines, 

 The need to reduce wildfire intensity and spread across the landscape, and 

 The need to reduce stand density. 

Unavoidable Adverse Effects 

No unavoidable adverse effects would occur in the Project area. 

Irreversible and Irretrievable Commitments of Resources 

Irreversible commitments of resources are those that cannot be regained, such as the extinction of 

a species or the removal of mined ore. Irretrievable commitments are those that are lost for a 

period of time such as the temporary loss of timber productivity in forested areas that are kept 

clear for use as a power line rights-of-way or road. 

Approximately 0.5 miles of temporary road construction is proposed for the Fish Camp Project. 

Road construction results in removal of surface soils and subsoil and complete loss of soil 

productivity within the road prism. 

The 0.5 miles of road is approximately 0.9 acres of ground with total loss of soil productivity. 

The direct effect of this new road construction is irreversible and irretrievable. Erosion on newly 

constructed roads is usually higher immediately after the road is constructed. There is potential 

that accelerated erosion could occur off the road prism and reduce soil productivity off site and 

after the road is constructed. Applicable soil and water conservation Best Management Practices 

(BMP) will be implemented, including erosion control measures, such as water bars, straw 

mulching of fills and fertilization of soils to re-vegetate the bare soils. Road reconstruction and 

road maintenance operate within the road prism and have little effect to the soil resource. 

However, there can be a positive effect to the soil resource outside of the road prism from road 

reconstruction by restoring proper drainage features of the road. Restoration of drainage features 

will result in less surface erosion and soil loss that leads to loss in soil productivity. 

Legal and Regulatory Compliance 

NEPA at 40 CFR 1502.25(a) directs “to the fullest extent possible, agencies shall prepare draft 

environmental impact statements concurrently with and integrated with ...other environmental 

review laws and executive orders.” The Proposed Action and alternatives must comply with the 

following regulation. 

Principle Environmental Laws 

The following laws contain requirements for protection of the environment that apply to the 

Proposed Action and alternatives. 

Endangered Species Act 

The Forest Service is directed to comply with this Act and does so through Biological 

Assessments and Evaluations that are used to analyze the effects of the proposed alternatives. 

These assessments and evaluations make determinations on Federally-listed endangered, 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 200 Chapter 3 – Affected Environment 

threatened, candidate and proposed species and their habitat. The analysis was conducted in part 

to determine whether formal consultation or conference is required with the United States 

Department of the Interior, Fish and Wildlife Service (USDI-FWS), pursuant to this act. 

The Fish Camp Project, through the inclusion of design criteria established for all action 

alternatives for species covered under this Act as well as the completion of Biological 

Assessments and Evaluations for Botanical, Aquatic and Terrestrial species, is in compliance with 

this act. 

Clean Water Act 

The Fish Camp Project would comply with this Act by adoption of Best Management Practices 

and other design criteria established for all action alternatives as detailed in Chapter 2. 

Clean Air Act 

Under the General Conformity Rule the Fish Camp Project has been determined to comply with 

this Act and the California State Implementation Plan through the implementation of treatments 

following Best Available Control Measures (BACMs) for prescribed burning as well as Rules 

and Regulations established by the San Joaquin Valley Air Pollution Control District and 

Mountain Counties Air Pollution Control District as required under section 190 of this Act, as 

amended in 1990. 

National Historic Preservation Act (NHPA) 

The USDA Forest Service is directed to identify, evaluate, treat, protect, and manage historic 

properties by several laws. However, the National Historic Preservation Act of 1966, as amended 

(16 U.S.C. 470 et seq.) (NHPA) provides comprehensive direction to Federal agencies about their 

historic preservation responsibilities. 

Section 106 of the NHPA and the ACHP implementing regulations, Protection of Historic 

Properties (36 CFR Part 800), require that Federal agencies take into account the effect of their 

undertakings on historic properties, and that agencies provide the ACHP with an opportunity to 

comment on those undertakings. Programmatic agreements (36 CFR 800.14(b)) provide 

alternative procedures for complying with 36 CFR 800. Pacific Southwest Region 5, USDA 

Forest Service has such an agreement: Programmatic Agreement among the U.S.D.A. Forest 

Service, Pacific Southwest Region, California State historic Preservation Officer, and Advisory 

Council on Historic Preservation Regarding The Identification, Evaluation and Treatment of 

Historic Properties Managed by the National Forest of the Sierra Nevada, California (Sierran 

PA). This agreement provides specific standards for conducting cultural resources inventory, 

evaluation, and management, including Forest Heritage Program requirements, identification 

standards, standard procedures for protecting cultural resources, reporting and public 

participation. 

Cultural resource design criteria are established for all action alternatives and are based on 

stipulations within the Sierran PA. All alternatives would be in compliance with historic 

preservation law, policy and regulation, as this project meets the stipulations of the Sierran PA. 

National Forest Management Act 

The National Forest Management Act (16 U.S.C. 1604) and the Multiple-Use Sustained-Yield 

Act of 1960 (16 U.S.C. 528–531) gives direction to National Forests to develop National Forest 

Land and Resource Management Plans that (A) insure consideration of the economic and 

environmental aspects of various systems of renewable resource management, including the 

related systems of silviculture and protection of forest resources, to provide for outdoor recreation 

(including wilderness), range, timber, watershed, wildlife, and fish; (B) provide for diversity of 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 201 Chapter 3 – Affected Environment 

plant and animal communities based on the suitability and capability of the specific land area in 

order to meet overall multiple-use objectives, and for steps to be taken to preserve the diversity of 

tree species. As set forth by these Acts, the Sierra National Forest Land and Resource 

Management Plan, as amended by the Sierra Nevada Forest Plan Amendment (SNFPA) in 2004, 

set specific standards and guidelines which are to be followed during project level planning and 

implementation. 

By the inclusion of design criteria as part of all action alternatives to minimize or eliminate 

significant environmental effects from proposed management actions as well as the inclusion of 

standards and guidelines from the SNF-LRMP and SNFPA ROD (USDA-FS 2004b) used to 

design this project, this project would comply with this act. 

Soil Productivity 

Soil resource management is achieved by maintaining soil productivity using Regional Soil 

Quality Standard and Guidelines and management direction provided in the LRMP (USDA-FS 

1992). The Geology/Soils section, starting on page 39 in Chapter 3, analyzes the existing soil 

productivity and effects of alternatives on soil productivity. 

Management Indicator Species (MIS) 

The bioregional scale monitoring strategy for the SNF MIS is found in the Sierra Nevada Forests 

Management Indicator Species Amendment (SNF MIS Amendment) Record of Decision (ROD) 

of 2007. Bioregional scale habitat monitoring is identified for all twelve of the terrestrial MIS. In 

addition, bioregional scale population monitoring, in the form of distribution population 

monitoring, is identified for all of the terrestrial MIS except for the greater sage-grouse. For 

aquatic macroinvertebrates, the bioregional scale monitoring identified is Index of Biological 

Integrity and Habitat. The current bioregional status and trend of populations and/or habitat for 

each of the MIS is discussed in the Sierra Nevada Forests Bioregional Management Indicator 

Species (SNF Bioregional MIS) Report (USDA-FS 2008). 

Other Standards and Guidelines, especially those dealing with Water 

Quality 

Best Management Practices will be applied to all action alternatives and are listed in Appendix 

B of this document. Design criteria listed in Chapter 2 incorporate additional protection measures 

to minimize and/or eliminate impacts to water quality. 

Executive Orders 

The following executive orders provide direction to Federal agencies that apply to the Proposed 

Action and alternatives: 

Indian Sacred Sites, Executive Order 13007 of May 24, 1996, applies to the Proposed Action 

alternatives because of historic and prehistoric uses known in the area. This is specifically 

addressed in Chapter 3 under Heritage Resources and Tribal Relations. All project alternatives 

comply with this order. 

Protection and Enhancement of the Cultural Environment, Executive Order 11593 of May 

13, 1971, directs Federal agencies to inventory cultural resources under their jurisdiction, to 

nominate to the National Register of Historic Places all Federally owned properties that meet the 

criteria, to use due caution until the inventory and nomination processes are completed, and to 

assure that Federal plans and programs contribute to preservation and enhancement of nonFederally owned properties. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 202 Chapter 3 – Affected Environment 

Cultural resource design criteria are established for all action alternatives and are based on 

stipulations within the Sierran PA. All alternatives would be in compliance with historic 

preservation law, policy and regulation, as this project meets the stipulations of the Sierran PA. 

Invasive Species, Executive Order 13112 of February 3, 1999, applies to the Proposed Action 

alternatives. A risk of introducing invasive species does exist. Measures need to be in place to 

prevent the spread of these species. The Proposed Action alternatives comply by providing 

measures to prevent the introduction and spread of invasive species. 

Recreational Fisheries, Executive Order 12962 of June 6, 1995, applies to the Proposed Action 

alternatives. Action alternatives comply with this order by implementing Best Management 

Practices and other design criteria and correcting existing resource problems. These design 

criteria are detailed in Chapter 2 and the list of specific Best Management Practices associated 

with this project are included in Appendix B of this document. 

Migratory Birds, Executive Order 13186 of January 10, 2001. 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 (MOU) between the USDA Forest Service 

and the U.S. 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. 

The SNF is proposing to manage lands on the BLRD that are located in the Big Creek watershed. 

Proposed management is intended to implement direction contained within the SNF-LRMP 

(LRMP, USDA-FS 1992) as amended by the SNFPA ROD (USDA-FS 2004b). Opportunities to 

promote conservation of migratory birds and their habitats in the Project area were considered 

during development and design of the Fish Camp Project (MOU Section C: items 1 and 11 and 

Section D: items 1 and 3). 

Within this Project area special considerations have been given to maintaining higher levels of 

biodiversity through actions such as delineating OFLs surrounding perennial streams (see DEIS 

and BE/BA for a description of OFLs). Higher levels of biodiversity have also been planned for 

by marking retention groups of large diameter trees. Over four-hundred and seventy two (472) 

such tree groups were identified in the main Project area. These tree groups are composed of a 

cluster of 3 or more trees, 30-inch dbh or greater, with touching crowns, and will benefit those 

species which utilize dense groupings of large trees. Another project design measure which will 

maintain biodiversity is the identification of retention areas around large oaks within treatment 

units. Two to three large oaks per acre were identified and marked with paint. These oaks will 

retain a zone of no activity measuring 35 feet, or dripline circumference around the oak 

(whichever is greater). The delineation of OFLs, retention of large tree groups, and oak no 

treatment zones will ensure a heterogeneous post treatment landscape resulting in the continued 

accessibility of both hiding cover and prey availability within these areas of biodiversity. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 203 Chapter 3 – Affected Environment 

Likely impacts to habitats and select migratory bird populations resulting from the Fish Camp 

Project have been assessed in detail within the project MIS report and impacts to select TES 

birds and their habitats have been analyzed in the project BA and/or BE. 

The project will not adversely impact migratory landbird species or their associated habitats. 

Potential impacts to migratory species would be minimized through the adherence of LRMP 

Standards and Guidelines as well as Design Criteria common to All Action Alternatives (pages 

16-26). These define the retention levels for snags/down woody debris, activities occurring 

within riparian management areas which include SMZs, OFLs, how to minimize ground 

disturbance and maintenance of canopy cover. The project is designed to improve habitat 

conditions through the acceleration of late-successional habitat characteristics, while still 

maintaining current functional habitat. Specific project design criteria include: canopy cover will 

be maintained at 50 to 60% or greater where available; ground disturbance will be limited to 

those guidelines with the LRMP as amended; vegetation species diversity and composition will 

be maintained; management activities will be limited in designated riparian management areas; 

and retention of snags and downed logs would be retained at levels defined in the Design Criteria 

Common to All Action Alternatives. All riparian management areas within the project have been 

identified and buffers established. In addition, no operations will occur during the wet weather 

season. 

Floodplain Management, Executive Order 11988 of May 24, 1977, does not apply because of 

exclusions and buffers that are in place through design criteria for the action alternatives and are 

found in detail in Chapter 2. 

Protection of Wetlands, Executive Order 11990 of May 24, 1977, does not apply because of 

exclusions and buffers that are in place through design criteria for the action alternatives and are 

found in detail in Chapter 2. 

Environmental Justice, Executive Order 12898 of February 11, 1994, applies to the Proposed 

Action alternatives. Compliance has been attempted by making this document understandable and 

accessible. 

Use of Off-Road Vehicles, Executive Order 11644, February 8, 1972, does not apply to this 

proposal. No off road use is being proposed nor existing use changed in this document. 

Special Area Designations 

The selected alternative will need to comply with laws, regulations and policies that pertain to the 

following special areas. 

Research Natural Areas 

No research natural areas are located in the Project area. This project would comply with 

applicable laws, regulations and policies for research natural areas. 

Inventoried Roadless Areas 

No Inventoried Roadless Areas are located in the Project area. This project would comply with 

applicable laws, regulations and policies for Inventoried Roadless Areas. 

Wilderness Areas 

No Congressionally-designated wilderness areas are located in the Project area. This project 

would comply with applicable laws, regulations and policies for wilderness areas. 

Wild and Scenic Rivers 

No Congressionally-designated wild and scenic rivers occur in the project planning area. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 204 Chapter 3 – Affected Environment 

Municipal Watersheds (FSM 2540) 

No municipal watersheds occur in the project planning area. 

Other Required Disclosures 

NEPA at 40 CFR 1502.25(a) directs “to the fullest extent possible, agencies shall prepare draft 

environmental impact statements concurrently with and integrated with...other environmental 

review laws and executive orders.” 

Species surveys, review of recent literature, and professional judgment have been incorporated 

into determinations of possible effects on species. Surveys provide information on species 

presence and habitat on a local scale. An element of uncertainty exists for effects on species with 

distributions beyond the project or Sierra N.F. boundaries. The Pacific fisher and YTare Forest 

Service sensitive species that have also been designated by the U.S. Fish and Wildlife Service as 

candidate species for listing under the Endangered Species Act. A candidate species is determined 

by the U.S. Fish and Wildlife Service through a 12-month finding as warranted for listing. The 

listing process is precluded by other priorities. The Sierra N.F. requested and received technical 

advice from the U.S. Fish and Wildlife Service to address uncertainty related to these candidate 

species. Their advice is integrated extensively throughout the Terrestrial and Aquatic Species 

sections of Chapter 3 as well as in the design criteria for all action alternatives. 

 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 205 Chapter 4 - Consultation 

Chapter 4. Consultation and Coordination 

Preparers and Contributors _______________________ 

The Forest Service consulted the following individuals, Federal, State, and local agencies, tribes 

and non-Forest Service persons during the development of this environmental document: 

ID Team Members 

Mark Lemon, District Fuels Officer; ID Team Leader 

Gloria Smith, Fire/Fuels Analysis 

David Smith, District Silviculturist; Vegetation/Silvicultural Analysis; Core Team Member 

Anae Otto, District Wildlife Biologist-Terrestrial; Biological Assessment/Biological Evaluation 

for Terrestrial Wildlife; Core Team Member 

Keith Ballard, District Timber Management Officer; Data Collection/Analysis; Core Team 

Member 

Denise Tolmie, Forest Fuels Officer; 

Phillip Strand, Fisheries Biologist; Aquatics-Riparian Analysis; ID Team Member 

Keith A. Stone, Hydrologist; Hydrology Analysis; ID Team Member 

Joanna Clines, Forest Botanist; Botanical Biological Assessment/Biological Evaluation/Noxious 

Weed/Invasive Species Analysis; ID Team Member 

Marie Mogge/Erin Potter, District Archeologist; Archeology Analysis; ID Team Member 

Andy Hosford, District Engineer; Transportation Analysis; ID Team Member 

Alan Gallegos, Province Geologist; Cumulative Watershed Effects Analysis/Soils Analysis; ID 

Team Member 

Karen Nooney, District Lands/Special Uses; Special Uses Analysis; ID Team Member 

Federal, State, and Local Agencies 

Although no formal or informal consultation was required for this project, personnel 

communications with Federal, State and Local Agencies including, but not limited to; U.S. Fish 

and Wildlife Service, California Department Fish and Game, and The Resources Agency 

(CalFire); Sierra Nevada Adaptive Management Project, California University System. 

Tribes 

North Fork Mono Rancheria; Picayune Rancheria of the Chukchansi Indians; Mariposa Indian 

Council; Mono Nation; California Indian Basketweavers Association. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 206 Chapter 4 - Consultation 

Distribution of the Environmental Impact Statement ___ 

This draft environmental impact statement has been distributed to individuals who specifically 

requested a copy of the document. In addition, copies have been sent to the following Federal 

agencies, Federally-recognized tribes, State and local governments, and organizations: 

Advisory Panel on Historic Preservation, USDA-Animal and Plant Health Inspection Service, 

USDA-Natural Resources Conservation Service, USDA-National Agricultural Library, 

National Oceanic and Atmospheric Administration, National Marine Fisheries Service, South 

Pacific Division-US Army Engineer, Region 9-Environmental Protection Agency, US 

Department of the Interior, US Coast Guard, Western Pacific Region-Federal Aviation 

Administration, US Department of Energy, Federal Highway Administration, U.S. Fish and 

Wildlife Service, California Department of Fish and Game, North Fork Mono Rancheria, 

Picayune Rancheria of the Chukchansi Indians, Mariposa Indian Council, Mono Nation, 

Madera and Mariposa County Board of Supervisors, San Joaquin Valley Air Pollution 

Control District, local Chapter of Society of American Foresters, Eastern Madera Fire Safe 

Council, Mariposa Fire Safe Council, Coarsegold Resource Conservation District, Sierra 

Forest Legacy, National Chapter and Tehipite Chapter-Sierra Club, John Muir Project, 

California Indian Basketweavers Association, Sugar Pine Railroad, Yosemite Trails Pack 

Station and Tenaya Lodge. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 207 Glossary 

Glossary 

Adaptive Management: A type of natural resource management that implies making decisions 

as part of an on-going process. Monitoring the results of actions provides information that may 

indicate the need to change a course of action. Scientific findings and the needs of society may 

also indicate the need to adapt resource management to new information. 

Air Shed: A geographical area that shares the same air mass due to topography, meteorology, 

and climate. 

Analysis Area: A collection of land area, not necessarily contiguous, sufficiently similar in 

character that they can be treated as if they were identical. 

Aspect: A position facing a particular direction, usually expressed as a compass direction in 

degrees or cardinal directions. 

Bark Beetle: A member of the family Scolytidae (Coleoptera). Adults and larvae tunnel in the 

cambial region (either in the bark only or in the bark and xylem) of living, dying and recently 

dead or felled trees and utilize these areas for food and shelter. 

Basal Area: The area of the cross section of a tree trunk near its base, usually 41⁄2 feet above the 

ground. Basal area is a way to measure how much of a site is occupied by trees. The term basal 

area is often used to describe the collective basal area of trees per acre. 

Baseline: Starting point for analysis of environmental consequences. A baseline may be 

conditions at a point in time or collected over a specified period of years. 

Best Management Practices (BMPs): Practices determined to be the most effective and 

practicable means of controlling pollutants at levels compatible with environmental quality goals. 

BMPs were conceptualized in the 1972 FUS Federal Water Pollution Control Act. BMPs as 

defined in the USDA Forest Service Soil and Water Conservation Handbook. 

Biomass thin: Used in this document to describe the cutting of vegetation (conifers) that may or 

may not have a market value, but are removed from site after cutting. For this document this is 

considered a conifer approximately 4-10 inches in diameter. 

Breast Height (as referred to as dbh): A standard height from ground level, generally 4.5 feet 

for recording diameter, circumference or basal area of a tree. 

Broadcast Burn: A type of prescribed fire allowed to burn over a designated area within defined 

boundaries to achieve land management objectives. 

Buffer: A land area designated to block or absorb unwanted impacts to the area inside the buffer. 

Bulk Density: The weight per unit volume of a measured material. Bulk density of plants is 

measured at a specified moisture tension. 

Catastrophic: a violent usually destructive natural event 

California Wildlife Habitat Relationship System (CWHR): A wildlife information and 

predictive system for mammals, reptiles, and amphibians. This system is considered a state-ofthe-art information system for California’s wildlife. The system provides the most widely used 

habitat relationship models for California’s terrestrial vertebrate species. CWHR is operated and 

maintained by the California Department of Fish and Game, in cooperation with the California 

Interagency Wildlife Task Group (CIWTG). 

Canopy: Foliar cover in the forest stand consisting of one or several layers. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 208 Glossary 

Chaparral: Dense growth of mostly small-leaved evergreen shrubs. Found in the foothills of 

California. 

Classified Roads: Roads wholly or partially within or adjacent to National Forest System lands 

that are determined to be needed for motor vehicle access including State roads, County roads, 

privately owned roads, National Forest Transportation System roads, and roads authorized by the 

Forest Service that are intended for long-term use. 

Climate: The composite or generally prevailing weather conditions of a region, throughout the 

year, averaged over a series of years 

Clump: An isolated, generally dense, group of trees. 

Codominant: Tree species in a forest that are about equally numerous and exert the greatest 

influence. 

Cohort: A group of trees developing after a single disturbance, commonly consisting of trees of 

similar age. A considerable range of tree ages of seedling or sprout origin and trees that predate 

the disturbance can be included. 

Commercial thin: Used in this document to describe the cutting and removal from site of 

vegetation (conifers) that typically has a market value. For this document this is considered a 

conifer over approximately 10 inches in diameter. 

Conflagration Threat: Likelihood that a wildfire capable of causing considerable damage will 

occur. National Wildfire Coordinating Group (NWCG) Glossary of Wildland Fire Terminology 

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. Cover may be dead or live vegetation, boulders, 

or undercut streambanks. Animals use cover to rest, feed, and escape from predators. 

Crown: The upper part of a tree that carries the main branch system and foliage. 

Crown Closure: The point at which the vertical projections of a crown’s perimeter within a 

canopy touches. 

Crown Density: The amount and compactness of foliage for trees or shrubs. 

Crown Fire –A fire that advances from top to top of trees or scrubs more or less independent of a 

surface fire. Crown fires are sometimes classed as running or dependent to distinguish the degree 

of independence from the surface fire. 

Cumulative Effects: Combined effects resulting from sequential actions on a given area. 

Cumulative impact: The impact on the environment that results from the incremental impact of 

the action when added to other past, present, and reasonably foreseeable future actions regardless 

of what agency (federal or non-federal) or person undertakes such other actions. Cumulative 

impacts can result from individually minor but collectively significant actions taking place over a 

period of time. 

Danger Tree: 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 and lean of the tree. (OSHA 29 CFR 1910.266(c) and FSH 6709.00, glossary)

Den Tree: A tree that contains a weather tight cavity for wildlife. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 209 Glossary 

Defensible fuels profile(s), Defensible Fuel Profile Zone(s), DFPZ(s): A strategically located 

strip(s) of land where the vegetation has been modified to a less dense fuel type. These are 

typically located along ridgetops and roads and are areas where fire fighters would make a stand 

to contain a fire. The width is based on potential fire behavior based on available fuels, weather 

and wind, and topography. They are not designed to stop an oncoming wildfire by themselves, 

but rather to provide a safe location to facilitate fire suppression efforts and provide an anchor 

point for prescribed burning projects. The DFPZ strategy initially treats a lower proportion of the 

landscape; treatments are located to protect specific values and are typically placed in wildland 

urban intermix areas. After a network of DFPZs is established, area fuel treatments (SPLATs) can 

be placed to enhance DFPZ effectiveness and increase the likelihood tat the overall landscape 

strategy will reduce wildfire intensity and size. 

Diameter Class: Intervals into which a range of diameters of tree stems or logs may be divided 

for classification or use. 

Disturbance: A force that results in changes in the structure and composition through natural 

events such as wind, fire, flood, avalanche, or mortality caused by insect or disease outbreaks or 

human events (e.g. timber harvest). 

Duff: Organic material covering the forest floor (includes fresh litter from plants and older, well 

developed humus). 

Ecosystem: An arrangement of living and non-living things and the forces that move among 

them. Living things include plants and animals. Non-living parts of ecosystems may be rocks and 

minerals. Weather and wildfire are two of the forces that act within the ecosystems. 

Elevation: Vertical distance of measure displayed in feet above sea level. 

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. 

Endemic Species: Plants or animals that occur naturally in a certain region and whose 

distribution is relatively limited to a particular locality. 

Environmental Effects: Includes ecological (such as the effects on natural resources and on the 

components, structures, and functioning of affected ecosystems), aesthetic, historic, cultural, 

economic, social, or health whether direct (which are caused by action and occur at the same time 

and place), indirect (which are caused by the action and are later in time or farther removed in 

distance, but are still reasonably foreseeable), or cumulative (results from the incremental impact 

of the action when added to other past, present or reasonably foreseeable future actions). 

Environmental Impact Statement (EIS): A document prepared by a Federal agency in which 

anticipated environmental effects of a planned course of action or development are evaluated. 

Federal statute (Section 102 of the National Environmental Policy Act of 1969) requires that such 

statements be prepared. An impact statement includes: (1) the environmental impact of the 

Proposed Action, (2) any adverse impacts which cannot be avoided by the action, (3) alternatives 

courses of actions, (4) relationships between local short-term use of the human environment and 

the maintenance and enhancement of long-term productivity, and (5) a description of the 

irreversible and irretrievable commitment of resources which would occur if the action were 

accomplished. 

Ephemeral Stream: A stream or portion of a stream that flows only in direct response to 

precipitation, receiving little or no water from springs and no long continued supply from snow or 

other sources and whose channel is at all times above the water table. 

Erosion: The wearing away of land surface by rain, running water, wind, ice, gravity, or other 

natural agents including gravitational creep and tillage. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 210 Glossary 

Existing Condition: for the purpose of this DEIS it represents a summary of the known 

information, which may serve as a baseline for comparison of effects from an action and from 

cumulative actions. 

Feasibility: Capability and suitability for specific use. 

Fire Behavior: The over-arching means by which to describe how an ignited fire reacts to the 

influences of fuels, topography and weather when combined together. Typical terms used when 

describing fire behavior include rate of spread (how fast a fire travels over a given distance in a 

given period of time); flame height (as measured in feet from ground through middle of flame); 

intensity (BTUs given off from flaming front); fire type (surface vs. crown) to name a few. 

Computer based models are used to predict fire behavior for given environmental and fuel 

conditions. 

Flow: The movement of a stream of water or other mobile substances from place to place. The 

movement of water and the moving water itself. The volume of water passing a given point per 

unit of time. 

Forage: All browse and non-woody plants that are eaten by wildlife. 

Forb: A grouping or category of herbaceous plants which are not included in grass, shrub or tree 

groupings, generally smaller flowering plants. Forbs contain little or no woody material. 

Forest: An ecosystem characterized by a more or less dense and extensive tree cover, often 

consisting of stands of varying in characteristics such as species composition, structure, age class, 

and associated processes. Commonly includes meadows, streams, fish and wildlife. 

Forest Health: The perceived condition of a forest derived from concerns about such factors as 

its age, structure, composition, function and vigor, presence of unusual levels of insects or 

disease, and resilience to disturbance. Individual and cultural viewpoints, land management 

objectives, spatial and temporal scales, the relative health of the stands that make up the forest, 

and the appearance of the forest at a point which influences the perception and interpretation of 

forest health. 

Forest Plan: Also referred to as a Land and Resource Management Plan (LRMP). A signed 

document that is the source of management direction for an individual National Forest that 

specifies activity and output levels for a period of 10-15 years. Management direction in the 

Forest Plan is based on issues identified at the time of Plan development. 

Forestry: The profession embracing the science, art and practice of creating, managing, using 

and conserving forests and associated resources for human benefit and in a sustainable manner to 

meet desired goals, needs and values. 

Forest Type: A category of forest usually defined by its vegetation, particularly its dominant 

vegetation as based on percentage cover of trees. 

Fragmentation: The process by which a landscape is broken into small islands of forest within a 

mosaic of other forms of land use or ownership. 

Frequency: 1. biometrics: the number of occurrences of a given type of event of the number of 

members of a population falling into a specified class; 2. ecology: the number of individuals in a 

community. 

Fuelbreak: A wide strip or block of land on which the native vegetation has been modified so 

that fires burning into it can be more readily suppressed. Usually strategically build in 

conjunction with a roadway (for access) and along ridgelines. Terms like shaded fuelbreak is used 

to differentiate the amount or type of vegetation that is removed to create the fuelbreak. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 211 Glossary 

Fuel Model – A fuel model is a set of numerical values that describe the fuel inputs for 

Rothermel’s mathematical model that predicts surface fire spread. 

Geographic Information System (GIS): A system of computer maps with corresponding sitespecific information that can be electronically combined to provide reports and maps. 

Habitat: The place where an animal, plant or population normally lives and develops. 

Habitat capability: The ability of a land area or plant community to support a given species of 

wildlife. 

Headcuts: Land erosion at the head of a stream, creek, or river. 

Headwater: The source of a stream. The upper tributaries of a drainage basin. 

Herb: A non-woody, vascular plant. 

Herbaceous: A class of vegetation dominated by no-woody plants known as herbs. 

Home Ignition Zone – Includes an area surrounding the home within 100 to 200 feet. The 

potential for ignition depends on the home’s exterior materials and design and the amount of heat 

to the home form the flames within the home ignition zone. 

Home Range Core Area (HRCA): A home range core area is a management area established 

surrounding each territorial California spotted owl activity center on National Forest lands after 

1986. Acreage of the HRCA on the Sierra National Forest is 600 acres, which includes the 300 

acre Protected Activity Center (PAC).

Horizon (soil): A layer of soil approximately parallel to the land surface and differing from 

adjacent genetically related layers in physical, chemical and biological properties or 

characteristics such as color, structure, texture, consistency, kinds and number of organisms 

present, degree of acidity or alkalinity. 

Indigenous: Native to a specified area or region. 

Indirect Effects: Effects that are caused by an action and occur at a later time, or at another 

location, yet are reasonably foreseeable in the future. 

Insect: A member of the class Insecta characterized by a body segmented into three distinct 

regions (head, thorax, abdomen), by a head with one pair of antennae, by a thorax with three 

segments each with a pair of legs, and usually one or two pairs of thoracic wings. 

Interdisciplinary Team (IDT): A group of specialists assembled to solve a problem or perform a 

task. 

Invasive Plants: Plant species that are introduced into an area in which they did not evolve and 

in which they usually have few or no natural enemies to limit their reproduction and spread. 

These species can cause environmental harm by significantly changing ecosystem composition, 

structure, or processes and can cause economic harm or harm to human health. 

Kernel: Technical term used to define a animals calculated home range 

Ladder fuels or fuel ladders: Arrangement of vegetation (trees, brush, etc.) that provides 

vertical continuity from the forest floor to the crowns of overstory trees. Example would be 

similar to steps on a ladder. 

Land and Resource Management Plan (LRMP): See Forest Plan 

Landscape: A large land area composed of interacting ecosystems that are repeated due to 

factors such as geology, soils, climate and human impacts. Landscapes are often used for coarse 

grain analysis. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 212 Glossary 

Maintenance: The work of keeping something in proper condition or standard.

Masticate or Mastication: Means by which vegetation is mechanically “mowed” into small 

pieces and changed from a vertical to horizontal arrangement. 

Management Indicator Species (MIS): Animals or plants identified in Forest Land and 

Resource Management Plans (LRMPs or forest plans) developed under the 1982 Planning Rule, 

that are selected because their population changes are thought to indicate the effects of Forest 

Service management activities. 

Mechanical Methods: Utilization of machinery such as bulldozers and skidders for tractor 

logging; helicopter logging, skyline cable logging, mechanical harvesters and 

shredders/masticators. 

Merchantable: Having the size, quality and condition suitable for marketing under a given 

economic condition. 

Mitigation: Actions taken to avoid, minimize or rectify the impact of a land management 

activity. 

Model: A representation of reality used to describe, analyze or understand a particular concept. A 

model may be a relatively simple qualitative description of a system or organization or a highly 

abstract set of mathematical equations. A model has limits to its effectiveness and is used as one 

of several tools to analyze a problem. 

Mortality: Trees dying from natural causes, usually by size class in relation to sequential 

inventories or subsequent to incidents such as storms, wildfire or insect and disease epidemics. 

Mosaic: A pattern of vegetation in which two or more kinds of communities are interspersed in 

patches, such as clumps of shrubs with grassland between. 

National Environmental Policy Act (NEPA): Congress passed in 1969 to encourage productive 

and enjoyable harmony between people and their environment. One of the major tenets of NEPA 

is its emphasis on public disclosure of possible environmental effects of any major action on 

public lands. Section 102 of NEPA requires a statement of possible environmental effects to be 

released to the public and other agencies for review and comment. 

Native Species: Indigenous species normally found as part of a particular ecosystem. 

Natural Fuel: Term used to describe vegetation, live or dead, in a given area that is not 

associated with being created by management activities. It is usually described in terms of natural 

fuel accumulations or build-up from naturally falling leaves, branches and/or logs from fallen 

snags. 

Notice of Intent (NOI): A notice printed in the Federal Register announcing that an 

Environmental Impact Statement will be prepared. The NOI must describe the Proposed Action 

and possible alternatives, describe the proposed agency scoping process and provide a contact 

person for further information. 

Noxious Weeds (Plants): An undesirable, non-native plant that is difficult to control and is on 

either the California Department of Food and Agriculture Noxious Weed list or the California 

Invasive Plant Council Inventory of invasive plants in California. 

Old-growth (forest): Old forests often containing several canopy layers, variety in tree sizes and 

species; and standing and dead woody materials. 

Protected Activity Center (PAC): A Protected Activity Center is a management area for certain 

Forest Service Sensitive raptor species. PACs are delineated surrounding all known and newly 

discovered breeding territories of California spotted owls (300 acres), Northern goshawks (200 

acres), and great gray owls (50 acres) on National Forest System lands. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 213 Glossary 

Patch: An area of homogeneous vegetation, in structure and composition. 

Pathogen: A parasitic organism directly capable of causing disease. 

Perennial Stream: A stream that has running water on a year-round basis under normal weather 

conditions. 

Piloted Wood Ignition: When wood is sufficiently heated, it decomposes to release combustible 

volatiles. At a sufficient volatile-air mixture, a small flame or hot spark can ignite it to produce 

flaming; thus, a piloted ignition 

Pre-commercial thin: Used in this document to describe the cutting of vegetation (conifers) that 

does not typically have a market value and not removed from site after cutting. For this document 

this is considered a conifer approximately 4-10 inches in diameter. 

Prescribed burning (fire): With a given range environmental condition (air temperature, fuel 

moisture, windspeed and direction, etc.) and approved plan, a fire that is management ignited to 

meet specific resource management objectives. This can include dozer/hand pile; understory and 

broadcast burning. 

Rate of Spread: The relative speed with which a fire increases in size usually expressed in chains 

(66 feet) per hour. 

Record of Decision (ROD): An official document in which a deciding official states the chosen 

activity (alternative) that will be implemented from a prepared EIS. 

Reforestation: The restocking of an area with forest trees, by either natural or artificial means, 

such as planting. 

Regeneration: The renewal of a tree crop by either natural or artificial means. The term is also 

used to refer to the young crop itself. 

Residual: A tree or snag remaining after an intermediate of partial cutting of a stand. 

Resilience: The ability of an ecosystem to maintain diversity, integrity and ecological processes 

following a disturbance. 

Resistance: The ability of a community to avoid alteration of its present state by a disturbance. 

The ability of plants to avoid, suppress, prevent, overcome, or tolerate insect or pathogen attack. 

Responsible Official: The Federal employee who has the delegated authority to make and 

implement a decision on a Proposed Action. 

Riparian Area: The area along a watercourse or around a lake or pond. 

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 Conservation Areas (RCAs): These are land allocations that are managed to maintain 

or restore the structure and function of aquatic, riparian and meadow ecosystems. The intent of 

management direction for RCAs is to (1) preserve, enhance, and restore habitat for riparian-and 

aquatic-dependent species; (2) ensure that water quality is maintained or restored; (3) enhance 

habitat conservation for species associated with the transition zone between upslope and riparian 

areas; and (4) provide greater connectivity within the watershed. 

Risk: The relative probability of any of several alternative outcomes as determined or estimated 

by a decision maker when the outcome of an event or series of events is not known. 

Road Maintenance: The ongoing upkeep of a road necessary to retain or restore the road to the 

approved road management objectives. 

Road Reconstruction: Activities that result in road realignment or road improvement. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 214 Glossary 

Sample: A part of a population selected and examined as a representative of the whole. 

Sediment (sedimentation): Solid materials, both mineral and organic, in suspension or 

transported by water, gravity, ice or air; may be moved and deposited away from their original 

position and eventually will settle to the bottom. 

Sensitive Species: Plant or animal species which are susceptible to habitat changes or impacts 

from activities. The official designation is made by the USDA Forest Service at the Regional 

level and is not part of the designation of threatened or Endangered Species made by the U.S. 

Fish and Wildlife Service.

Shade tolerant: When used to describe a conifer, the trees prefers to grow in the shade. 

Silvicultural System: The cultivation of forest; 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 art and science that promotes the growth of single trees and the forest as a 

biological unit. 

Simulation: An operations research technique that represents physical, natural, social and 

economic systems by models in order to study the factors affecting the system and to aid decision 

making. 

Site: The area in which a plant or a stand grows, considered in terms of its environment, 

particularly as this determines the type and quality of the vegetation the area can carry. 

Site Preparation: 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. 

Skid Road (skid trail): A road access cut through the woods for skidding of logs. 

Skidder: A self-propelled machine (cable, clam-bunk or grapple) used for dragging trees or logs. 

Skidding: Hauling logs by sliding, not on wheels, from stump to a collection point. 

Slash: Residue left on the ground after timber cutting or left 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. Snags are important as habitat for a variety of wildlife species and 

their prey. 

Soil Compaction: Reduction of soil volume. The weight of heavy equipment, for example, on 

soils can compact the soil and thereby change it in some ways, such as in its ability to absorb 

water. 

Species: The main category of taxonomic classification into which genera are subdivided, 

comprising a group of similar interbreeding, individuals sharing a common morphology, 

physiology and reproductive process. 

Spotted Owl Protected Activity Center: The best available 300 acres of habitat surrounding 

each territorial owl activity center detected on National Forest System lands since 1986. Owl 

activity centers are designated for all territorial owls based on 1) the most recent document nest 

site, 2) the most recent known roost site when a nest location remains unknown, and 3) a central 

point based on repeated daytime detections when neither nest or roost locations are known. 

Stand: A group of trees that occupies a specific area and is similar in species, age, and condition. 

Stand density: A quantitative measure of stocking expressed either absolutely in terms of 

number of trees, basal area, or volume per unit area or relative to some standard condition. A 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 215 Glossary 

measure of the degree of crowding of trees within stocked areas commonly expressed by various 

growing space ratios. 

Stand Structure: The physical and temporal distribution of plants in a stand. Silviculture the 

horizontal and vertical distribution of components of a forest stand including the height, diameter, 

crown layers and stems of trees, shrubs, herbaceous understory, snags and down woody material. 

Standards and Guidelines: Direction outlined in the Forest Land and Resource Management 

Plan (LRMP) for specific aspects of project planning and analysis. 

Stocking: An indication of growing-space occupancy relative to a pre-established standard. 

Strategically Placed Landscape Area Treatments (SPLATs): As defined in the SNFPA ROD 

(USDA-FS 2004b), SPLAT is a wildland fire modification strategy (created from research 

conducted by Dr. Mark Finney [1999]) by which a fire is forced to go around areas, by dropping 

the fire out of the crownsand to the ground, where fuels have been reduced or otherwise modified. 

Fire will continue to burn in ground litter in these areas but at lower intensity. The treated areas 

function as “speedbumps” on the landscape to slow the spread and reduce the intensity of 

oncoming fires and thereby reduce damage to both treated and untreated areas. The term SPLAT 

is being used in this document to describe a specific area proposed for vegetation treatment, not 

an area where treatment intensity would change. 

Streamside Management Zones (SMZs): Management Zones established to protect and 

maintain water quality, site productivity, channel stability, wildlife habitat, and riparian 

vegetation. 

Structure: Sizes, shapes and/or ages of the plants and animals in an area. 

Surface Fuels: Vegetation, either dead or live, that is on the surface, which includes dead 

branches, blowdown timber, leaves, and low vegetation, as contrasted with crown fuels. 

Thinning from below: A silvicultural technique by which cutting is done in an immature stand 

of trees to accelerate growth of the remaining trees or to improve the form of the remaining trees. 

From below describes the incremental cutting of trees based on its position in the stand. First 

starting with suppressed, then intermediates, then co-dominates to reach a desired or prescribed 

basal area for the stand. 

Threatened Species: Plant or animal species likely to become endangered throughout all or part 

of their range in the foreseeable future. Designated by the U.S. Fish and Wildlife Service under 

the Endangered Species Act of 1973. 

Uncharacteristic severe wildfire: Uncharacteristically Severe Wildfire is defined as fire 

occurring beyond the historical range of natural variation in terms of scope, intensity and 

duration. 

Understory: The trees and woody shrubs growing beneath the overstory in a stand of trees. 

Viability: The ability of a population of a plant or animal species to persist for some specified 

time into the future. Viable populations are populations that are regarded as having the estimated 

numbers and distribution of reproductive individuals to ensure that its continued existence is well 

distributed in a given area. 

Watershed: The entire region drained by a waterway (or into a lake or reservoir). More 

specifically, a watershed is an area of land above a given point on a stream that contributes water 

to the streamflow at the point. 

Weather: The state of the atmosphere with respect to wind, temperature, cloudiness, moisture, 

pressure, etc. Weather refers to these conditions at a given point in time (e.g., today's high 

temperature). 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 216 Glossary 

Weed: A valueless, troublesome or noxious plant often exotic, growing wild especially on 

growing profusely. A plant growing where it is not wanted. 

Wildfire: Any wildland fire that is not a prescribed fire. 

Wildland: Land other than that dedicated for other uses such as agriculture, urban, mining or 

parks. 

Wildland Urban Intermix (WUI): The line, area, or zone where structures and other human 

development meet or intermingle with undeveloped wildland or vegetative fuels. WUI has three 

zones associated with it and these zones have standards and guidelines associated with them. The 

urban core, as defined in the USDA-FS 2004 FSEIS, is an area whereby the next zones are 

designated from. The defense zone is the area nearest the urban core and in this project is defined 

as the area 1⁄4 mile distance from the outer edge of the entire urban core. The threat zone is the 

next designated zone and in this project is defined as the area 1 1/4 mile distance from the outer 

edge of the defense zone. The total distance of the Defense and Threat Zone is 1 1⁄2 miles. The 

USDA-FS 2004, FSEIS mapped these areas based on 1990 Census data and were not redefined 

for this project. 

Wildfire Intensity: Describes the buildup of heat within a fire, both in amount and in rate of 

transmission-a function of heat release. Usually described as low, moderate or high intensity fires. 

Wildlife: All non-domesticated animal life. 

Woodland: A forested area; a plant community in which, in contrast to a typical forest, the trees 

are often small, characteristically short-boled relative to their crown depth and forming an open 

canopy with the intervening area being occupied by lower vegetation, commonly grass. 

90th – 97th Percentile: These terms are used to describe the hottest 10 percent and 3 percent fire 

weather conditions during a given period
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 217 Literature Cited 

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 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 233 Index 

Index 

aquatic ... 11, 12, 23, 94, 95, 96, 123, 126, 192, 

204, 207, 209, 215, 226, 228, 229, 230, 

232, 233 

California spotted owl .......................... vii, 2, 5 

conifer . iii, vi, vii, 4, 10, 19, 27, 111, 121, 122, 

198, 199, 203, 204, 242, 244, 246, 247, 249 

crowns ................................................ 193, 202 

cultural resources ................................ 191, 192 

desired conditions ............................... 1, 5, 234 

disease iii, vi, vii, 96, 112, 114, 189, 200, 201, 

203, 245, 247 

ecosystem ......... vii, 1, 109, 201, 202, 203, 204 

endangered .............................. 23, 95, 190, 206 

fuels . iii, vi, viii, 1, 4, 5, 11, 16, 22, 33, 44, 53, 

94, 95, 122, 126, 199, 200, 202, 205, 206, 

215, 216, 225, 230, 232, 236, 237, 243, 

246, 250 

Management Indicator Species .... 86, 109, 110, 

192, 202 

MIS ....... 94, 109, 110, 111, 112, 192, 193, 202 

Pacific fisher ............... vii, 2, 27, 194, 237, 242 

plants ..... 39, 44, 198, 200, 201, 202, 203, 204, 

205 

prescribed burning ............. iii, vii, 10, 191, 199 

riparian ...... 23, 94, 95, 96, 193, 204, 205, 207, 

208, 209, 213, 225, 229, 232, 233, 234, 

235, 237, 247 

sensitive ... 14, 23, 44, 194, 225, 226, 227, 229, 

230, 232 

soil ..... 13, 14, 53, 56, 190, 192, 202, 205, 214, 

226, 227, 228, 229, 231, 233, 235 

SPLATs ........................................... vi, 10, 199 

stand density .............. viii, 4, 12, 121, 126, 189 

thinning ... vii, viii, 4, 10, 11, 14, 26, 32, 56, 94, 

126, 237, 244, 245, 246, 247, 248, 249 

threatened ..................................... 23, 190, 204 

wildfires ............iii, vi, vii, 4, 10, 121, 122, 234 

WUI .. vi, vii, 1, 4, 5, 6, 10, 121, 206, 243, 245, 

248 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 234 Appendices Maps 

Appendices 

Appendix A – Map Package for Fish Camp Project _____ 

See Map Package 

 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 235 Best Management Practices 

Appendix B – Best Management Practices - Stream 

Crossing Design Measures 

Specific to Fish Camp Project 

BMP Name, Objective, and 

Direction Application to the Fish Camp Project 

BMP 1-1 Timber Sale Planning 

Process: To incorporate water 

quality and hydrologic 

considerations into the timber sale 

planning process.

Implemented through the Riparian Conservation Objectives/Forest Plan 

Consistency report, specification of operational BMPs, Environmental 

Analysis including interdisciplinary team office and field discussions, 

and incorporation of water quality protection measures in the Timber 

Sale Contract for the KRP EIS. 

BMP 1-4 Use of Sale Area Maps 

(SAM) and/or Project Maps for 

Designating Water Quality 

Protection Needs: To ensure 

recognition and protection of areas 

related to water quality protection 

delineated on a SAM or project 

map. 

The sale administrator and purchaser will review these areas on the 

ground prior to commencement of ground disturbing activities. 

Examples of water quality protection features that will be designated on 

the project map include: 

1) Location of streamcourses and riparian zones to be protected, 

including the width of the protection zone for each area. 

2) Wetlands (meadows, lakes, springs, etc.) and other sensitive areas 

(such as shallow soils) to be protected. 

3) Boundaries of harvest units, specified roads and roads where 

hauling activities are prohibited or restricted, areas of different 

skidding and/or yarding methods, including post-harvest fuels 

treatments, and water sources available for purchaser’s use. 

BMP 1-5 Limiting the Operating 

Period of Timber Sale Activities: 

To ensure that the purchasers 

conduct their operations, including 

erosion control work, road 

maintenance, and so forth, in a 

timely manner, within the time 

frame specified in the Timber Sale 

Contract. 

The purchaser’s contract operation period will be limited to contractspecified periods when adverse environmental effects are not likely. 

The Sale Administrator will close down operations due to rainy periods, 

high water, or other adverse operating conditions in order to protect 

resources. 

BMP 1-8 Streamside 

Management Zone Designation: 

To designate a zone along riparian 

areas, streams and wetlands that 

will minimize potential for adverse 

effects from adjacent management 

activities. Management activities 

within these zones are designed to 

improve riparian values. 

Streamside management zones (SMZs ) have been supplemented with 

RMAs and RCAs (USDA 2004b) as described in the Design Measures 

section of the EIS. 

Within SMZs, the constraints defined in Sierra Supplement No. 1 

(USDA Forest Service, 1989) apply. This includes no self-propelled 

ground based equipment, a minimum groundcover of 50%, and shade 

canopy may not be modified in a way that affects stream temperature. 

Modifications to these guidelines are possible where site-specific needs 

exist if the action is reviewed by a hydrologist or fisheries biologist. 

BMP 1-9 Determining Tractor 

Loggable Ground: To minimize 

erosion and sedimentation resulting 

from ground disturbance of tractor 

logging systems. 

Limit ground skidding and machine piling with tractors to slopes less 

than 35%. Endlining can be used to remove logs from steeper slopes. 

Ground disturbance on areas of shallow soils, notably soils adjacent 

and abutting to rock outcrops, will be avoided. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 236 Best Management Practices 

BMP Name, Objective, and 

Direction Application to the Fish Camp Project 

BMP 1-10 Tractor Skidding 

Design: By designing skidding 

patterns to best fit the terrain, the 

volume, velocity, concentration, 

and direction of runoff water can be 

controlled in a manner that will 

minimize erosion and 

sedimentation.

The sale administrator and purchaser will designate all skid trails prior 

to ground disturbing activities. If uncertainty arises regarding potential 

resource impacts of skid trail location, consult with an earth science 

specialist (i.e., hydrologist, aquatic biologist, or soil scientist). 

BMP 1-12 Log Landing Location: 

To locate new landings in such a 

way as to avoid watershed impacts 

and associated water quality 

degradation 

The following criteria are to be used by the Sale Administrator when 

evaluating landings: 

a. The cleared or excavated size of landings will not exceed that 

needed for safe and efficient skidding and loading operations. 

Trees considered dangerous will be removed around landings to 

meet the safety requirements of OSHA. 

b. Selected landing locations will involve the least amount of 

excavation and fill possible. Landings must be located outside of 

SMZs. 

c. Locate landings near ridges away from headwater swales in areas 

that will allow skidding without crossing stream channels, violating 

SMZs, or causing direct deposit of soil and debris to a stream. 

d. Locate landings where the least number of skid roads will be 

required, and sidecast can be stabilized without entering drainages 

or affecting other sensitive areas. Keep the number of skid trails 

entering a landing to a minimum. 

e. Position landings such that the skid road approach will be nearly 

level as feasible, to promote safety and to protect soil from erosion. 

f. Avoid excessive fills associated with landings constructed on old 

landslide benches. 

g. Construct stable landing fills or improve existing landings by using 

appropriate compaction and drainage specifications. 

In some cases, using an existing landing located within an RCA or CAR 

is preferable to constructing a new landing outside of it. These 

situations will be reviewed on a site-by-site basis by an earth science 

specialist (aquatics, hydrology, geology, or soils). 

BMP 1-13 Erosion Prevention 

and Control Measures during 

Timber Sale Operations: To 

ensure that the purchasers’ 

operations will be conducted 

reasonably to minimize soil 

erosion.

Timber purchaser responsibilities for erosion control will be set forth in 

the Timber Sale Contract. Equipment will not be operated when ground 

conditions are such that excessive damage will result. The kinds and 

intensity of control work required of the purchaser will be adjusted by 

the sale administrator to ground and weather conditions with emphasis 

on controlling overland runoff, erosion, and sedimentation. 

Erosion control work required by the contract will be kept current. At 

certain times of the year this means daily, if precipitation is likely or 

weekly when precipitation is predicted for the weekend. Erosion 

prevention measures must be applied no later than October 1 and 

immediately upon completion of activity begun after November 1. 

If the purchaser fails to perform seasonal erosion control work prior to 

any seasonal period of precipitation or runoff, the Forest Service may 

temporarily assume responsibility, complete the work, and use any 

unencumbered deposits as payment for the work. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 237 Best Management Practices 

BMP Name, Objective, and 

Direction Application to the Fish Camp Project 

BMP 1-16 Log Landing Erosion 

Protection and Control: To 

reduce the impacts of erosion and 

subsequent sedimentation 

associated with log landings by use 

of mitigating measures. 

Landings will be properly cross-ditched, ripped (if soils are compacted), 

re-contoured (as necessary), and mulched after use and before the 

winter precipitation period, whichever comes first. Excess material not 

needed for erosion control can be piled and burned. Upon completion of 

the project, consult with the hydrologist or soil scientist to determine the 

need for additional soil protection measures. 

BMP 1-17 Erosion Control of 

Skid Trails: To protect water 

quality by minimizing erosion and 

sedimentation derived from skid 

trails. 

Erosion control measures will be installed on all skid trails, tractor 

roads, and temporary roads. Erosion control measures include, but are 

not limited to, cross ditches (water bars), organic mulch, and ripping. 

Cross ditches will be spaced according to the guidelines below, 

maintained in a functioning condition, and placed in locations where 

drainage would naturally occur (i.e., swales). The level of maintenance 

will be contingent upon existing or predicted weather patterns as 

determined by the Sale Administer (see BMP 1-13). 

 Minimum Cross Drain Spacing 

% Slope Maximum Spacing 

0 - 15 125 feet 

15 - 35 45 feet 

BMP 1-18 Meadow Protection 

during Timber Harvesting: To 

avoid damage to the ground cover, 

soil, and hydrologic function of 

meadows.

Mechanical equipment is not permitted in meadows unless specifically 

authorized by an aquatic biologist and hydrologist. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 238 Best Management Practices 

BMP Name, Objective, and 

Direction Application to the Fish Camp Project 

BMP 1-19 Streamcourse and 

Aquatic Protection: The 

objectives of this BMP are: 

a. To conduct management 

actions within these areas in a 

manner that maintains or 

improves riparian and aquatic 

values. 

b. To provide unobstructed 

passage of stormflows. 

c. To control sediment and other 

pollutants entering 

streamcourses. 

d. To restore the natural course 

of any stream as soon as 

practicable, where diversion of 

the stream has resulted from 

timber management activities. 

a. The location and method of crossings on Class IV and V streams 

must be agreed to by the sale administrator (SA) prior to construction. 

b. Stream crossings on Class I – III streams must be approved by the 

hydrologist and aquatic biologist. 

c. Damage to stream banks and channels will be repaired to the 

extent practicable. 

d. All sale-generated debris will be removed from streamcourses, 

unless otherwise agreed to by the SA, and in an agreed upon manner 

that will cause the least disturbance. 

e. Felled trees will not be pulled across perennial or intermittent 

stream channels without prior approval by the hydrologist or aquatic 

biologist. 

f. Methods for protecting water quality while utilizing tractor skid trail 

design in stream course areas where harvest is approved include: (1) 

end lining, (2) falling to the lead, and (3) utilizing specialized 

equipment with low ground pressure such as feller buncher harvester. 

g. Water bars or other erosion control structures will be located so as 

to disperse concentrated flows and filter out suspended sediments 

prior to entry into streamcourse. 

h. Material from temporary road construction and skid trail 

streamcourse crossings will be removed and streambanks restored to 

the extent practicable. 

i. Special slash treatment site preparation activities will be prescribed 

in sensitive areas to facilitate slash disposal without use of 

mechanized equipment. 

j. Project-related bare soil areas (e.g. skid trails, landings, temporary 

roads, etc.) will be covered with existing native vegetation mulch, 

organic debris, or certified weed free straw to at least 50%, well 

distributed cover, and cross-ditched per BMP 1-17 requirements. 

BMP 1-20 Erosion Control 

Structure Maintenance: To 

ensure that constructed erosion 

control structures are stabilized and 

working

During the period of the timber sale contract, the purchaser will provide 

maintenance of soil erosion control structures contracted by the 

purchaser until they become stabilized, but not more than one year 

after their construction. If the purchaser fails to do seasonal 

maintenance work, the Forest Service may assume the responsibility 

and charge the purchaser accordingly. The Forest Service sale 

administrator is responsible for ensuring erosion control maintenance 

work is completed. 

BMP 1-21 Acceptance of Timber 

Sale Erosion Control Measures 

before Sale Closure: To ensure 

the adequacy of required erosion 

control work on timber sales. 

The sale administrator must inspect erosion control measures to ensure 

their adequacy prior to accepting closure on the unit and/or sale. 

The effectiveness of erosion control measures will be evaluated using 

BMPEP protocols (see Monitoring Plan) after the sale area has been 

through one or more wet seasons. This evaluation is to ensure that 

erosion control treatments are in good repair and functioning as 

designed before releasing the purchaser from contract responsibility. 

The purchaser is responsible for repairing erosion control treatments 

that fail to meet criteria in the Timber Sale Contract, as determined by 

the Sale Administer, for up to one year past closure of the sale. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 239 Best Management Practices 

BMP Name, Objective, and 

Direction Application to the Fish Camp Project 

 BMP 1-22 Slash Treatment in 

Sensitive Areas: To maintain or 

improve water quality by protecting 

sensitive areas from degradation 

which would likely result from using 

mechanized equipment for slash 

disposal. 

All burn piles made with mechanical equipment must be located outside 

of the SMZ. 

Hand piles will be kept at least 20 feet away from all streams, 

meadows, springs, seeps, and other sensitive aquatic areas. 

BMP 2-1 General guidelines for 

the Location and Design of 

Roads: To locate and design roads 

with minimal resource damage. 

The following considerations are incorporated into the planning process 

of road location and design. These measures are preventative, apply to 

all transportation activities, and indirectly protect water quality: 

(a)Transportation facilities will be developed and operated to best meet 

the resource management objectives with the least adverse effect on 

environmental values. 

(b)The location, design, and construction of roads will include the use of 

the IDT. 

(c)Sensitive areas such as wetlands, inner gorges, and unstable ground 

will be avoided to the extent practicable. 

(d)Stream crossings will be designed to provide the most cost efficient 

drainage facility consistent with resource protection, facility needs, and 

legal obligations. 

BMP 2-2 Erosion Control Plan: 

To mitigate and control erosion 

through effective planning prior to 

initiation of construction. 

Any new construction would be subject to erosion control measures as 

per an IDT approved plan that may include but not be limited to 

waterbar installation, sediment fencing, culvert installation and 

armoring, placement of straw waddles, approved straw cover and/or 

slash and any other method necessary to mitigate erosion and 

sediment routing in the project subwatershed(s). 

BMP 2-3 Timing of Construction 

Activities: To minimize erosion by 

conducting operations during 

minimal runoff periods and when 

soils are dry and less prone to 

compaction. 

Ground-disturbing activities will occur when soils are dry. In some 

cases soils may never dry sufficiently. Ground-disturbing work that 

occurs off of existing roads will occur during the dry season and will 

reduce ground disturbance as much as possible. 

BMP 2-5 Road Slope 

Stabilization Construction 

Practices: To reduce 

sedimentation by minimizing 

erosion from road slopes and slope 

failure along roads.

An adequate soils and geologic investigation will be conducted when 

finalizing new road construction designs for: correct cut and fill 

steepness based on the angle of repose for the type of material; 

methods to handle surface runoff; and necessary compaction standards 

and surfacing needs. 

BMP 2-7 Control of Road 

Drainage: To minimize the erosive 

effects of water concentrated on 

roads, to disperse runoff from road 

surfaces, to lessen sediment yield 

from roaded areas, and to minimize 

erosion of the road prism. 

Newly constructed or reconstructed roads will be designed to reduce 

hydrologic connectivity and soil erosion wherever feasible. The sale 

administrator or other Forest Service representative will ensure that 

roads are adequately maintained during project implementation to 

ensure that road drainage features function as designed. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 240 Best Management Practices 

BMP Name, Objective, and 

Direction Application to the Fish Camp Project 

BMP 2-8 Constraints Related to 

Pioneer Road Construction: To 

minimize sediment production and 

mass wasting from pioneer road 

construction. 

(a)Roads will be constructed within the planned roadway limits unless 

otherwise specified or approved by the ER or COR. 

(b)Pioneer roads will be located to prevent undercutting of the 

designated final cut slope, avoid deposition of materials outside the 

designated roadway limits, and accommodate drainage with temporary 

culverts or log crossings. 

(c)Erosion control work will be completed prior to the rainy season and 

in accordance with the contract. 

(d) Crossing sites on live streams will be dewatered during construction 

with diversion devices (see BMP 2-15). 

BMP 2-9 Timely Erosion Control 

Measures on Incomplete Roads 

and Stream Crossing Projects: 

To minimize erosion and 

sedimentation from disturbed 

ground on incomplete projects. 

Erosion control must be completed before the rainy season (usually 

October in the KRP Project area). Preventative measures for timely 

erosion control include: 

(a)Removal of temporary culverts, culvert plugs, diversion dams, or 

elevated stream crossings. 

(b)Installation of temporary culverts, side drains, flumes, cross drains, 

diversion ditches, energy dissipaters, dips, sediment basins, berms, 

debris racks, or other facilities needed to control erosion. 

(c)Removal of debris, obstructions, and spoil material from channels 

and floodplains. 

(d) Planting vegetation, mulching, and/or covering exposed surfaces 

with jute mates or other protective material. 

BMP 2-10 Construction of Stable 

Embankments: To construct 

embankments with materials and 

methods which minimize the 

possibility of failure and 

subsequent water quality 

degradation. 

Roadways will be designed and constructed as stable and durable 

earthwork structures with adequate strength to support the treadway, 

shoulders, subgrade and road traffic loads. 

BMP 2-11 Control of Sidecast 

Material During Construction 

and Maintenance: To minimize 

sediment production originating 

from sidecast material during road 

construction or maintenance.

Sidecasting is not permitted within SMZs. 

Waste areas must be located where excess material can be deposited 

and stabilized. 

BMP 2-12 Servicing and 

refueling equipment: To prevent 

pollutants such as fuels, lubricants, 

bitumens and other harmful 

materials from being discharged 

into or near rivers, streams and 

impoundments, or into natural or 

man-made channels. 

Storage of hazardous materials (including fuels) and servicing and 

refueling of equipment will be conducted at pre-designated locations 

outside of RCAs and CARs. If fueling and/or storage of hazardous 

materials are needed within RCAs or CARs, those sites must be 

reviewed and approved by the District Hydrologist or Aquatic Biologist. 

Additional protection measures, such as containment devices, may be 

necessary. 

BMP 2-13 Control of 

Construction and Maintenance 

Activities Adjacent to SMZs: To 

protect water quality by controlling 

construction and maintenance 

actions within and adjacent to 

SMZs so that SMZ functions are 

not impaired. 

Construction and maintenance fills, sidecast, and end-hauled materials 

will be kept out of SMZs except at designated crossing sites to minimize 

the effect to the aquatic environment. 

BMP 2-14 Controlling In-Channel 

Excavation: To minimize stream 

channel disturbances and related 

sediment production.

There will be no in-channel or streambank excavation during any phase 

of project activities unless authorized by the district hydrologist or 

aquatic biologist. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 241 Best Management Practices 

BMP Name, Objective, and 

Direction Application to the Fish Camp Project 

BMP 2-16 Stream Crossings on 

Temporary Roads and Skid 

Trails: 

Mechanical equipment crossing of perennial and intermittent (generally 

class I – III) streams is not permitted unless approved by the district 

hydrologist or aquatic biologist. Ephemeral streams (stream class IV 

and V) may be crossed at designated locations as agreed upon by the 

sale administrator and purchaser. Designate skid trails to avoid stream 

crossings and SMZs wherever possible. Designated crossings must be 

as perpendicular to the channel as possible and avoid sensitive soils 

and riparian vegetation damage. Stream banks must be repaired upon 

completion of the project. 

BMP 2-19 Disposal of Right-ofWay and Roadside Debris: To 

ensure that organic debris 

generated during road construction 

is kept out of streams so that 

channels and downstream facilities 

are not obstructed. 

If slash generated by road work is disposed of within SMZs, it will be 

piled and burned or chipped. Material may also be removed from the 

SMZ for disposal. 

BMP 2-21 Water Source 

Development Consistent with 

Water Quality Protection: To 

supply water for roads and fire 

protection while maintaining 

existing water quality.

Water drafting will not occur in streams when the base discharge is less 

than 1.5 cfs, and will not draft more than 50% of the ambient discharge 

over 1.5 cfs. New drafting sites shall be approved by the District 

Hydrologist or Fisheries/Aquatic Biologist and located to minimize 

sediment and maintain riparian resources, channel condition, meadow 

integrity, and aquatic species viability and habitat. Approaches will be 

as near perpendicular to the stream as possible and will be gravel 

surfaced or otherwise stabilized. 

If water-drafting is required, pumps with low entry velocity and suction 

strainers with screens less than 2 mm in size (1/8 in.) will be used. 

BMP 2-22 Maintenance of Roads: 

To maintain roads in a manner that 

provides for water quality protection 

by minimizing rutting, failures, 

sidecasting, and blockage of 

drainage facilities, all of which can 

cause erosion, sedimentation, and 

deteriorating watershed conditions.

Roads needed for project activities will be brought to current 

engineering standards of alignment, drainage, and grade before use, 

and will be maintained through the life of the project. Roads will be 

inspected at least annually to determine what work, if any, is needed to 

keep ditches, culverts, and other drainage facilities functional and the 

road stable. 

BMP 2-23 Road Surface 

Treatment to Prevent Loss of 

Materials: 

Surface stabilization will be considered where grades exceed 12% or 

road is within riparian conservation areas. 

BMP 2-24 Traffic Control During 

Wet Periods: To reduce road 

surface disturbance and the rutting 

of roads, and to minimize sediment 

washing from disturbed road 

surfaces.

On roads not designated for all weather or winter haul, heavy 

equipment operations will be limited until the period after the soil has 

dried in the top 12 inches in the spring. 

BMP 2-26 Obliteration or 

Decommissioning of Roads: To 

reduce sediment generated from 

temporary roads, unneeded system 

and non-system roads by 

obliterating or decommissioning 

them at the completion of the 

intended use.

Temporary roads will be obliterated after serving their intended purpose 

for this project. This includes: (1) road effectively barricaded; (2) road 

effectively drained by measures such as re-contouring or outsloping to 

return surface to near natural hydrologic function; (3) a well distributed 

mulch or organic cover provides at least 50% cover, or road surface is 

revegetated using local native species; (4) sideslopes are reshaped and 

stabilized to match the natural contour (as necessary); and (5) stream 

crossings are removed and natural channel geometry is restored. 

If non-local mulch is used (such as straw), it must be approved by the 

Forest Service as weed free. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 242 Best Management Practices 

BMP Name, Objective, and 

Direction Application to the Fish Camp Project 

BMP 5-8 Pesticide Application 

According to Label Directions 

and Applicable Legal 

Requirements: To avoid water 

contamination by complying with all 

label instructions and restrictions 

for use. 

This BMP requires glyphosate applicators to strictly adhere to pesticide 

label instructions. 

BMP 5-11 Cleaning and Disposal 

of Pesticide Containers and 

Equipment: To prevent water 

contamination resulting from 

cleaning or disposal of pesticide 

containers. 

The cleaning and disposal of glyphosate containers will be done in 

accordance with Federal, State, and local laws, regulations and 

directives. 

BMP 5-12 Streamside Wet Area 

Protection During Pesticide 

Spraying: To minimize the risk of 

pesticide inadvertently entering 

waters, or unintentionally altering 

the riparian area, SMZ, or wetland. 

When spraying glyphosate, an untreated strip of land and vegetation 

will be left alongside surface waters, wetlands, riparian areas, or SMZ. 

Strip widths established by the IDT are 5 feet for dry channels and 25 

feet for flowing channels (see Herbicide Use design criteria). 

BMP 6-1 Fire and Fuel 

Management Activities: To 

reduce public and private losses 

and environmental impacts which 

result from wildfires and/or 

subsequent flooding and erosion by 

reducing or managing the 

frequency, intensity and extent of 

wildfire. 

The project action alternatives are designed to achieve the desired 

conditions of BMP 6-1. 

BMP 6-2 Consideration of Water 

Quality in Formulating Fire 

Prescriptions: To provide for 

water quality protection while 

achieving the management 

objectives through the use of 

prescribed fire. 

Prescribed burning is planned at the minimum intensity and severity 

necessary to achieve management objectives, and each Burn Plan will 

incorporate all relevant design measures from this EIS. 

BMP 6-3 Protection of Water 

Quality from Prescribed fire 

Effects: To maintain soil 

productivity, minimize erosion, and 

minimize ash, sediment, nutrients, 

and debris from entering water 

bodies.

Fires will be allowed to back into riparian vegetation, but direct lighting 

within riparian vegetation will not occur. 

All fire lines within RCAs and CARs will be water barred per BMP 1-17 

spacing requirements. Fire lines within RCA (i.e., 150 ft., seasonal 

streams, and 300 ft. perennial streams, springs, and meadows) will be 

designed and constructed to reduce sediment entry into channels. Fire 

lines in RCAs will cross perpendicular to streams and follow the natural 

landscape contour as much as possible. Firelines within the SMZ will 

be hand cut. Waterbars will be placed on either side of each stream 

crossing to prevent or reduce sediment entry into streams. 

BMP 6-5 Repair or Stabilization 

of Fire Suppression Related 

Watershed Damage: To stabilize 

all areas that have had their 

erosion potential significantly 

increased, or their drainage pattern 

altered by suppression related 

activities.

In the event of a wildfire, protection of resources would be evaluated 

under the Burned Area Emergency Response, assessment and 

treatment Implementation protocol. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 243 Best Management Practices 

BMP Name, Objective, and 

Direction Application to the Fish Camp Project 

BMP 6-6 Emergency 

Rehabilitation of Watersheds 

Following Wildfires: To minimize 

as far as practicable: 1.) loss of soil 

and onsite productivity; 2.) overland 

flow, channel obstruction and 

instability; 3.) threats to life and 

property both on-site and off-site

In the event of a wildfire, protection of resources would be evaluated 

under the Burned Area Emergency Response, assessment and 

treatment Implementation protocol.. 

BMP 7-3 Protection of Wetlands: 

To avoid adverse water quality 

impacts associated with 

destruction, disturbance, or 

modification of wetlands.

Ground disturbing activities will not occur in wetlands or meadows. 

BMP 7-4 Oil and Hazardous 

Substance Spill Contingency 

Plan and Spill Prevention 

Containment and 

Countermeasure (SPCC) Plan: 

To prevent contamination of water 

from accidental spills.

A spill contingency plan and spill prevention and countermeasure plan 

(SPCC) must be prepared if hazardous materials (including fuels and 

oils) stored on the Sierra National Forest exceed 1320 gallons, or if a 

single container exceeds 660 gallons. 

The plan will at a minimum include: the types and amounts of 

hazardous materials located in the Project area, pre-project identified 

locations for hazardous materials storage and fueling/maintenance 

activities (must be located outside of RCA and CAR unless prior 

approval by District Hydrologist or Aquatic Biologist is obtained), 

methods for containment of hazardous materials and contents of on-site 

emergency spill kit, and a contingency plan (including contact names 

with phone numbers) to implement in the event of a spill. 

The SPCC plan must be approved by the Forest Service prior to project 

implementation. 

 

 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 244 Best Management Practices 

Stream Crossing Design Measures 

The idea of using logs to fill-in around a culvert, placed in a live, running stream was developed 

over the years between several specialists (Hydrologist, Botonist, Soils and Fisheries) and myself. 

It started during the use of traditional logging and further refined during the use of Cut-to-Length 

(CTL) operations. The main emphasis was to eliminate disturbance (or to radically reduce it) 

within the Streamside Management Zone (SMZ); additional emphasis items were: to reduce 

erosion/sediment movement, to eliminate or reduce loss of plant and habitat strucure, in and 

around the stream crossing. 

Traditonal live stream crossings, with traditional logging equipment for skid trails or temporary 

roads, was constructed by excavating the crossings out and placing a culvert in the stream, but 

filling around the pipe with dirt. When the crossings served its purpose, the culvert and fill dirt 

were removed, usually with the bulldozer. This practice caused sediment load into the stream, 

along with much disturbance of the stream banks. Rehabilitation (rehab) work consisted of 

placing waterbars on each bank of the stream along with grass-seed and straw. The grassseed/straw combo was placed from stream bank to the first waterbar ditch, on each bank, 

depending on slope gradient. 

CTL operations changed the way operations were conducted in the woods. The harvester/tree 

processor establishes their route of travel (forwarding trails) thru the unit. The harvester cuts 

trees down, delimbs and produces logs along these trails, all the while leaving the resulting limbs 

and tree tops (slash) in the trails as a “slash mat” for ground cover. The forwarder follows the 

harvester, driving over the “slash mat” to pick up the logs and returns to the landing. This 

procedure works well when abundant material is available in the stands, on the hand, when 

material is not available or is light the disturbance is limited to the vehicles tracking numerous 

times over the bare ground. 

Over the years, starting from the late 1980’s, the need to get away from non-native materials and 

grass seed took shape, along with the idea that using native materials like pine needles and tree 

limbs (logging slash) to control erosion or to use as a ground cover. The CTL operations lent 

itself to this “new” concept because of the amount of “on-site” material that could be produced 

and how it incorperated the material as a ground cover on the trails. This is why the CTL stream 

crossings works well under live flow conditions. The placement and removal of the log fill is 

accomplished with the harvester, which can grasp the processed logs with its cutting-head, feed 

wheels and limb knives. This allows the logs to be lifted into and out of position, much like a 

crane or boom. This not only reduces or eliminates the amount of soil disturbance and stream 

sediment loading, but the amount of the distubed area is greatly reduced. 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 245 Best Management Practices 

During 

After 
Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 246 Best Management Practices 

After 

Before 
 Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 247 CommeAppendix C – Response to Comments The SNF provided the Fish Camp Project (DEIS) to interested parties for public comment on February 18, 2011 The Envir

Agency published a Notice of Availability (NOA) for the DEIS in the Federal Register on the same date. The 45-day com

on April 4, 2011. In response to the SNF request for comments, seven interested parties submitted comments. After b

letter into the individual comments contained in those letters the SNF determined that 147 unique comments needed t

tracking purposes, the SNF assigned a letter number to each letter; and, an ID number for each specific comment. The Forest Service has documented, analyzed, and responded to the public comments received on the DEIS. Appen

comments received on the DEIS and provides the agency’s response to those comments. In general, the agency responfour basic ways to the substantive public comments as prescribed in 40 CFR 1503.4 and responses to CommenEnvironmental Policy Act (NEPA) regulations. 

 Developing and analyzing alternatives not given serious consideration in the DEIS. 

 Supplementing, improving, or modifying the analysis that the DEIS documented.  Making factual corrections.  Explaining why the comments do not need further Forest Service response. 

The following individuals, agencies and organizations provided timely comments during the 45-day comment period: 

 Sierra Forest Legacy/Sierra Club Environmental Law Program (SFCSC) 

 Richard E. Kangas, Sierra Club-Tehipite Chapter (RKSCTC) 

 American Forest Resource Council (AFRC)  United States Environmental Protection Agency-Region IX (USEPA)  Kirby D. Molen for Sierra Forest Products (SFP)  California Forestry Association (CFA)  National Park System Partnership Program (NPSPP) 
 Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 248 Comme

Fish Camp DEIS Comments 

 Comment Response 

Sierra Forest Legacy April 4, 2011 

1-1 Defer or limit treatments in fisher 

habitat until studied results from adjacent projects direct a conservation strategy. 

In the Purpose and Need-“Why here, Why now” section of the FEIS, a full dthis project is described. While total analysis area is 5,440 acres in size, witharea treatment units are planned for less than 30% of the total landscape. WitAdaptive Management Project treatment units are planned for less than 35pelandscape. Numerous design criteria have been developed limiting treatmentThese include measures requiring high canopy cover retention, OFL’s, oak cand shrub and understory retention. These design criteria have been developehabitat post treatment for the fisher and other TES species while allowing the the purpose and the need of the project by lowering the hazardous fuels thro

decreasing the potential for uncharacteristically severe wildfires, and improvwithin the Project areas. 

1-2 Need of pre- and post treatment stand 

data. It is incomplete in BE. 

At this time, stand data is only available for the treatment units in Fish Camp cruised/marked. The remaining stand data will be collected during marking/cstands during May-July of 2011 if the decision is made to move forward with alternative is selected, the crew would utilize the same silvicultural prescript

other treatment units in Fish Camp; therefore any deviation from the trend shwill be minimal. The post treatment stand data for the treatment units displayrepresentative sample of what the remaining mark will be, with an average o

inches dbh remaining post-treatment. 

1-3 Need >20”DBH disclosed pre and 

post treatment, also stand information, such as basal area, mean diameter and canopy cover. 

Data tables have been added to the FEIS in appendix D. 

1-4 Explanation of CWHR D5 overlap in 

to wild stands, e.g. units T-7b, T-8a, T-8b, T-9. 

Map 6 in the DEIS Map package used the base GIS feature class delineated b

(RSL). This coarse GIS vegetation layer was designed for forest-level manag

is insufficient for project-level analysis. This feature class was refined for the 

district silviculturist and forest GIS specialist using existing structure analysi

examination plots, as well as detailed aerial photography interpretation and f
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 249 Comment 

has been corrected in the FEIS. (Wrong symbology used to create map 6 in the DEIS map packet. 

1-5 Increase or create potential for large 

snags and down logs (>20” DBH) in units with little representation (Snag/Down Log generating treatments). 

Because this comment can be addressed from a number of different specialisaddressed from the individual specialist areas below. Silviculture: A number of factors contribute to the creation of snags and snaeventually contribute to down logs. Some of these factors are: competition fattack, fire, diseases, etc. Due to the highly variable density of snags and dowquite difficult to obtain an accurate per acre number. Only 562 acres of wiltreatment in this project, slightly more than 10 percent of the gross Project ar

percent, groupings of heavily stocked larger diameter trees are being retained

archaeological sites, and steep areas, etc. are being left untreated. All these Spresent are not planned to be treated unless in excess of LMP standards and g Wildlife snag: The Fish Camp Project forest vegetation types are primarily and ponderosa/Jeffrey pine, both of which require maintenance of four of the distributed irregularly across the landscape according to the SNFPA 2004 RO15 inches dbh to meet this guideline. Snags should be clumped and distributetreatment units.” (S&G 11: SNFPA ROD, 2004) Across the Fish Camp treatmaverage of 9 standing dead conifers per acre 

≥11” dbh; and an average of 5 s

acre 

≥18 inches dbh. Although there are two individual treatment units: T-13 

acres) which appear snag deficient, on average across the Fish Camp project acres) the number of snags per acre >15” dbh is 5, which exceeds the minimu

the SNFPA 2004 ROD. Wildlife large down logs: The Fish Camp Project emphasizes retention of Cclasses and decay classes 1-3. Although there are three individual treatment u21d (23 acres), and T-19a/b (25 acres) which fall below the recommended ra

CWD (Brown et al. 2003) for warm, dry ponderosa pine and Douglas-fir foreFish Camp project treatment units (1200 acres) the level of CWD is 12 tons pwithin the recommended range. The alternative of Snag/Down Log Generating Treatments was considering bdetailed study because ... as explained in more detail in FEIS Chapter 2 Alte
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 250 Comment 

Eliminated from Detailed Study . 

1-6 Increase or expand past/present 

cumulative effects in BE to include Graham Mountain. 

The Fish Camp FEIS and BE cumulative effects analysis has been updated to Mountain. 

1-7 DEIS and BE (wildlife) minimize 

cumulative effects by assuming individual effects are small. Page 5 Sweitzer et al. (2011) find that mortality for fishers in the SNAMP study area is a concern and that bobcats are a dominant predator in the fish camp area (Sweitzer and Barrett 2010 

BE updated with strengthen analysis to include fisher predation: Sweitzer emortality for fishers in the SNAMP study area is a concern and that bobcats athe Fish Camp area (Sweitzer and Barrett 2010). To date, the SNAMP fisher team has not documented any fisher mortalities wProject area. To verify this, updated mortality information was requested from on 4/5/2011. Rick Sweitzer provided maps at two different scales displaying SNAMP has recorded over the duration of the study. He noted that to date, thnot documented any fisher mortalities in the Rainier Creek Watershed east ocommunication). Rick also verified that the bobcat that may be targeting fisharea, which lies 8 miles straight line distance southeast of the Fish Camp proj

1-8 Increased vulnerability of predation 

due to lack of hiding cover by combining adjacent projects. 

Several design criteria have been developed to maintain adequate levels of h

prey, and to retain landscape heterogeneity. One new design measures developroject planning takes into account the amount of shrub and understory diver

within the treatment units. This design measure with the newest addition itali

Shrub and understory diversity will be retained throughout the Project area. 

will be maintained in Old Forest Linkages associated with riparian areas (coo

oak buffer zones; as well as areas where no treatment will be conducted such botanical areas, slopes >35 percent, and rocky areas. Tree species associated as dogwoods, alders, and willows will not be removed. In addition, post sale 

pockets of understory growth spread throughout the treatment units so that aof the total understory growth will be maintained in 1/10 acre pockets within pockets within wild stand treatment units. This will preserve stand diversity w

posed by ladder fuels.
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 251 Comment 

1-9 Hazard tree removal within the 

Project area and cumulative effects, Has recent tree removal been incorporated? 

There are currently no hazard tree removal timber sales within the Project areHazard Reoffer is a current sale located southwest of the community of Fish 5S66. The last Hazard tree timber sale in the Project area was the White Hazterminated in 2002. The sale was located along Forest Road 5S06 in the eastarea. 

1-10 Because the Forest Service violated 

NEPA in adopting the 2004 Framework, logging projects that implement and rely upon the 2004 Framework are also contrary to law [see e.g., Klamath Siskiyou Wildlands Ctr. v. Boody, 468 F.3d 549, 562 (9th 

Cir. 2006), Northwest Ecosystem Alliance v. Rey, 2006 WL 44361, at *8 (W.D. Wash. 2006), Citizens for Better 

Forestry v. USDA, 2009 WL 

1883728, at *13 (N.D. Cal. 2009)]. Thus, to the extent that the Fish Camp Project implements any of the changes to the 2001 Sierra Nevada Forest Plan Amendment made by the 2004 ROD, the project is contrary to law. 

The commenter expresses concern that projects predicated on the 2004 FramNEPA and NFMA. August and September 2008 court decisions found “that complied with the provisions of the National Environmental Policy Act (NEP

Forest Management Act (NFMA), except to the extent that the 2004 Framewwithout sufficient review of alternatives other than the chosen option.” Judg2009 ruling (United States District Court Eastern District of California No. 2Memorandum and Order dated 11/04/09) denied the request to enjoin the For

continuing to develop projects based on the 2004 Framework but rather requaddressed by development of a supplemental EIS (which is underway and cucomment) and by requiring future fuels reduction projects to have a non-comalternative. The 2004 Framework can legally be used as the basis for projectcomplies with Judge England’s November 2009 ruling. The Fish Camp Proj

component in the purpose and need, contains a non-commercial funding alterwhich is compliant with Judge England’s instructions in the November 2009 

project is not contrary to law as asserted. 

Richard E. Kangas Tehipite Chapter, Sierra Club April 4, 2011 

2-1 DEIS is not clear throughout as required 

by NEPA. 

Comment not specific enough to address or correct. 

2-2 Throughout the DEIS there are citations 

to references. Unfortunately many of those references are not included in your Literature Cited list. That leaves the 

The DEIS references were reviewed and citations have been added to the 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 252 Comment 

DEIS unclear. That also is a scientific shortcoming. 

2-3 The WUI needs to be defined more 

thoroughly in the DEIS glossary.

The definition of WUI has been added to the FEIS glossary. 

2-4 SPLATS and DFPZ’s are not clearly 

differentiated. To what extent are they to 

be thinned? In the extreme, they could be clearcuts. 

The FEIS Glossary definitions for SPLATs and DFPZs have been refined are used in the context of this document. Within those definitions, it is sta

reference a specific geographical location of a treatment area and the treatchange within these areas. 

2-5 The definition of SPLAT in the DEIS 

glossary states that the SPLAT will force fire to go around the SPLAT. That is 

confusing. It implies that the fire will only be detoured around the SPLAT. 

The FEIS Glossary definition of SPLAT has been updated. 

2-6 SPLATS are shown on Map 3, but 

DFPZ’s are not.

FEIS Map packet Map #3 has been revised to display the DFPZs. 

2-7 According to the Glossary, DFPZ’s are 

to be placed along roads and on ridgetops as places of safety for firefigthers. Those are places where 

earlier timber project plans left larger trees for viewshed and wildlife. With the Fish Camp Project those viewshed and wildlife trees would be removed. In addition, roads are already clearings where firefighters can organize and ridgetops are locations where fires generally decrease in intensity and often just stop. 

The term DFPZ is being used in this document to describe the geographic 

an area of proposed vegetation treatment near roads, not an area where trechange. While no basis is offered for the commenter’s perception of why “larger t

wildlife characteristics will be maintained (see BA/BE). 

2-8 In the Summary Table on p. viii, the 

comment about “artifact looting” in case a “conflagration” occurs is a scare tactic. The Project area was extensively 

It is the experience and judgment of the District Archaeologist that intens

visibility of cultural resources and artifact looting has occurred post-fire d

visibility of artifacts on the ground surface. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 253 Comment 

cleared of trees in the last century. During that time artifacts already were looted. Furthermore, since less than 1⁄4 of the of the area (1200 acres of 5,440 acres) is to be treated in this Fish Camp Project and since slash from logging and chunks from masticating are highly flammable, there is no certainty that the project actions will lessen the chances of fire or provide protection from looters. 

The Purpose and Need as well as Environmental Consequences clearly arreduction in risk of uncharacteristically severe fires. 

2-9 In the Summary Table on p. ix, the 

comment about increased spread of noxious weeds should fire fighting equipment be brought in, shows there need to be better standards for cleaning any equipment brought into the forest.

The text has been clarified to show that the danger exists mostly under ex

situations. The Forest Service has made great strides in implementing exiprevention of noxious weeds via firefighting equipment, as evidenced by weed-washing stations at fire camps over the past decade. However, undwhen a wildfire first breaks out, the need to put equipment on the line can for equipment cleaning (human life and safety take priority over noxious wwhy there is a greater risk for weed spread when a higher risk of catastropnoxious weeds continue to spread within the Project area. 

2-10 In the Summary Table on p. xii, the 

comment that implies air quality will be more threatened by wildfire under the No Action Alternative is unfounded. If 

logging and masticating lessened the smoke effects of fire, then the clearcutting of the past should have fireproofed our forests. 

The FEIS Summary Table relative to the Air Quality Resource Area for thhas been edited to include the following: “If an uncontrolled wildfire was 

smoke would produce unhealthy, widespread, prolonged and sever perioddegradation. Depending on upper level atmosphere Class 1 air sheds coul

2-11 Near the bottom of p. 3 of the DEIS the 

phrase, “Wide swings in weather conditions over the last 30 years...” is incorrect. A climate is based on 30 years of weather, evapotranspiration analysis, and other data. It takes 30 years to determine a climate. 

The FEIS wording has been changed to use the word “weather” instead of conditions stated in this paragraph such as drought and rising temperatureto climate changes. There is evidence for increased variability in select cli

Sierra National Forest, such as increased variation in annual precipitation 

the past 85 years of climate records (Western Regional Climate Center 20in the SNF indicates a general warming trend (especially increasing mean especially over the past 30 years, that may be decreasing the diurnal temp
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 254 Comment 

2010, LaDochy et al. 2007). 

The word “weather” has been corrected to “weather”. 

2-12 On p. 10 the DEIS includes that 

“Commercial thinning” would take up to five years to complete after implementation. That seems a long time. 

Also that does not ensure that implementation would occur in the near future. Many projects on the Sierra NF have been planned and contracted, but not completed. Thus completing plans does not assure action to remedy what the plans pretend to remedy. However, completing the plans does allow contracts to be written and then extended until the private timber industry wants the logs. We propose that contracts not be written until the timber is needed. Otherwise the U. S. Treasury is stuck with maintaining the standing inventory of logs essentially owned by the timber industry until industry sees a market gain for the product. 

The Forest Service plans on a contract term of two years based on producmechanical thinning equipment. This time period accounts for unforeseea

inclement weather and fire weather shutdowns. It is expected that timber year of contract execution based on the need for raw material at local sawSince there is a concern over supply needed to maintain the current indust

little concern that this project would not be completed within normal contwith a depressed market (see Economic Analysis). 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 255 Comment 

2-13 At the bottom of p. 17, is 

written,”Thinning will not remove any trees larger than 30-inch dbh.” This implies that even 30-inch dbh might be exceeded for some other purpose. That should not happen. The 30-inch size already is too big. It should be 10 inches generally for the expressed needs and purposes. 

The only exception where a tree 

≥30-inches dbh may be felled is if it is a 

Snags may only be felled if they meet the definition of a danger tree as deDesign Criteria. Snags that meet this definition and are felled during projeremain on site for down woody debris. All snags not meeting these criterisnags within the Project area. An alternative addressing limiting lree removal diameter to 10 inch DBH eliminated from detailed study. See FEIS Chapter 2 Alternatives ConsideDetailed Study . 

2-14 At the bottom of p. 26 discussion of 

Alternatives Considered but Eliminated form Detailed Study does not list any such. Those should be explained. If 

there were none, it should be so stated. 

The FEIS has been corrected to specifically address alternatives consideredetailed study. 

2-15 Table 3 (p. 27) lists miles of roads, but 

the numbers are not clear.

Table 3 has been updated to include total miles of road. These total miles in each alternative would not change by alternative. 

2-16 Table 3 (p. 28) lists brush areas only for 

Alternative 1. The rationale is not clear. 

Changed “Brush Areas” on Table 3 to; Forest Plantations – Further Future is described in Chapter 3-Fire/Fuels section, Alternative 1-Direct Effects. 

2-17 Table 3 (p. 29), for “Estimated Range of 

Tree Diameter” suggests that average tree diameter does not increase for the No Action Alternative. That is true, but 

the opportunity for fire to release the larger trees still present (not logged under this project) is still there. If fire were applied, the average diameter of trees would likely increase. 

The average tree size would not increase under the No Action Alternative applied. Since there would be Forest Service actions taken. 

2-18 On p. 30 of the DEIS begins a discussion 

of cumulative impacts. On p. 31 the last sentence leaves the reader hanging as it is incomplete and with no ending punctuation. 

The FEIS was changed to direct the reader from the introductory paragraptable on the following pages..... 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 256 Comment 

2-19 On pp. 30-31 of the DEIS the discussion 

of cumulative impacts is disconcerting as it shows that the unfortunate White House Council on Environmental Quality (CEQ) cumulative impacts doctrine from the Administration of President George W. Bush is still being utilized. That doctrine streamlines the cumulative impacts essentially to “current aggregate effects of past actions without delving into the historical details of past actions.” Such 

an aggregate of impacts is a moving target. We say that is unfortunate since all types of activities are thus not necessarily being considered. Of course each activity of the past, whether by a Federal or non-Federal agency or by a person, must be considered. That especially includes effects of historic logging on private lands that have now become Federal lands. And that also includes effects of fire suppression. And it includes the placement of buildings and roads as well. Each type of activity has its own types of impacts. So where will the Proposed Actions from this DEIS take the cumulative impacts? You must quantify effects of planned activities. Not all activities have the same level or type of effect. 

The Fish Camp FEIS has followed the current Forest Service NEPA Regu

address past actions in the cumulative effects of the alternatives. CEQ regulations do not require the consideration of the individual effects determine the present effects of past actions (40 CFR 1508.7). 

2-20 Table 4, p. 32, title caption is incorrectly The title caption for Table 4 has been corrected in the FEIS. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 257 Comment 

written. It is not clear as required by NEPA. 

2-21 In Table 4 the use of an X, or not, to 

represent an impact, or not, is misleading since the X implies impacts are equal when so marked for various activities. You need to use a numeric 

code to show with which activity, which characteristics are affected to a greater or lesser extent. For instance, Trail Work will not have much effect (and a trail is essentially a fire line), while masticating will have a greater effect while creating a great surface fuels load. Any firefighter knows those are not equal values. 

The use of a numeric code or not is not significant, the table was developereader to show that impacts could occur in the indicated areas. When the 2 are implemented actions to the landscape past, present and foreseeable athe use of Standards and Guidelines as well as Design Criteria mitigate anrelative value is irrelevant. 

2-22 In Table 4 on p.34, impacts have not 

been marked for: motorized recreation (at cultural resources and vegetation) and livestock grazing (at fuels, vegetation, and transportation). In fact, 

virtually every category in the entire table could be marked to show an impact, large or small, since there is no numeric code to represent intensity of impact. 

There were no marks made under these resource areas because there was effects that would occur. 

2-23 On p. 35 under Archaeological and 

Historic Values is written, “Cultural resources are not distributed equally across this landscape....” Nevertheless 

they are spread over the landscape. Thus the impacts of actions on cultural resources are greater than implied and farther reaching than implied. 

Chapter 2 articulates the direct, indirect and cumulative effects of all alterwas offered by commenter showing “greater” impacts to cultural impacts
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 258 Comment 

2-24 On p. 38 under Alternative 1 and 

Alternative 2 it is implied that treatment actions will significantly decrease likelihood of fire, thus increasing protection (from burning and looting) of cultural resource sites. This is a scare 

tactic. Less than 1⁄4 of the Project area will receive treatments. Furthermore, we suspect the cultural resource sites will not receive those treatments. In that case, those sites will still have the present fuel load under either Alternative 1 (No Action) or Alternative 2 (Proposed Action). 

Treatment around cultural resources will reduce the fuel loading and will adversely affecting cultural resources due to fire. This will also increase tprotect cultural resources from fire should one occur in the Project area. Additionally although treatments affect only 30 percent of the treatment areduce the potential for uncharacteristically severe wildfire effects over th

2-25 On p. 38 the use of the term 

“conflagration” to represent fire effects is not defined in any technical sense. It is not listed in the DEIS glossary. Using 

that term is a scare tactic. 

The term “conflagration” has been replaced with “uncharacteristically sthe FEIS and this term has been added to glossary. 

2-26 The section on Botany that begins on p. 

40 is confusing since it includes both those plants that need to be protected and those plants that need to be removed.

For future documents we will consider changing this, however the two issfield surveys for rare plants and weeds are done by the same crew; the prinoxious weeds to spread is that native plants are crowded out and weeds pRare plants are threatened by the spread of weeds. Removing non-native preventing their spread protects and restores native vegetation, including r

2-27 On p. 40, under General description of 

the vegetation with an emphasis on rare plant habitat, where are “Brush Areas” (listed at the top of Table 3, p. 28)? In Table 3, are you alluding to chaparral as a “brush area”?

Yes. Botanists tend to call areas dominated by shrubs “chaparral” while t

tend to call these areas “brush”. 

2-28 From the bottom of p. 40 to p. 41 is a 

comment that plant species considered “sensitive” are that way in the Sierra 

Text has been added to the EIS with citations to explain that many species thought by experts to be naturally rare. Thank you for pointing out that thexplanation. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 259 Comment 

National Forest because they are naturally rare and not because their numbers have been reduced by human activity. Gee! That is unlike other parts of the planet where human activity is wiping species off the map. What conditions (actions/inactions) could make them plentiful? Maybe those designated “sensitive” could be so from fire suppression effects or climate change. Certainly some special environment might benefit the rare and sensitive species. 

2-29 At the bottom of p. 44 is suggested that 

fire suppression equipment, as a vector, can spread noxious species. To prevent 

that, the equipment needs to be cleaned thoroughly before traveling from infested areas. 

The Forest Service has made great strides in implementing existing direct

noxious weeds via firefighting equipment, as evidenced by the increasing stations at fire camps over the past decade. However, under emergency s

first breaks out, the need to put equipment on the line can supersede requicleaning (human life and safety take priority over noxious weed preventiowould be cleaned upon leaving an infested area. 

2-30 At the top of p. 46 it says, “No 

cumulative effects are expected for Botanical Resources as the project has been designed to reduce or eliminate direct and indirect effects to rare plants and to avoid the introduction of noxious weeds.” That is so easy to say on p. 46, 

but is refuted previously (See # 28 and #29, above.) 

The FEIS has been reviesed to state that by definition the No Action alterneffects (see page 31 of the FEIS). As the No Action alternative has no agcumulative effects which are defined as the effects of the action in additioreasonably foreseeable actions. 

2-31 The Geology/Soils section needs to be 

edited. It is not clear. There are significant organizational and syntactical problems throughout this section of the 

The Geology/Soils section was reviewed for clarity and edited as appropredits suggested it is difficult to make sure the commenter’s concerns are a
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 260 Comment 

DEIS. 

2-32 On p. 57 under Large Woody Debris 

(LWD) it is written that there is a minimum of five logs per acre for LWD desired condition. What is the maximum 

number of logs desired per acre? 

The maximum amount of large woody debris (logs/acre) is not available i

maximum fuel loading levels dictate the maximum amount of large wood

loading is displayed in Table 35 of the FEIS. Fuel loading varies by vegeand 5-10 tons per acre. 

2-33 At the bottom of p. 65 is written, 

“Project design criteria common to all alternatives were developed through the collaborative process of the SNAMP Integration Team meetings.” The 

SNAMP Team, however, is not listed in Chapter 4-- Consultation and Coordination. 

The FEIS has been corrected to include the SNAMP team in Chapter 4, CCoordination. 

2-34 On p. 66 the term “catastrophic fire” is 

used. There is no definition for this term 

in the glossary. This reminds us that the term “conflagration” was used earlier. These terms should be replaced with proper technical vocabulary. 

The term “catastrophic fire” has been replaced with “uncharacteristicall

throughout the FEIS and this term has been added to glossary. 

2-35 Under Indirect effects on p. 67 the 

“Detailed CWHR assessment” is not attached to this DEIS

Environmental Impact Statements are meant to be focused on the effects osignificant issues. The effects analysis draws upon various reference sciesummarized. These referenced scientific documents are part of the projec

upon request. In this case page 67 of FEIS states that: “Detailed CWHR a

Appendix C and G of the Fish Camp Terrestrial Wildlife BE/BA (Otto 20

2-36 Under Pacific Fisher on p. 68, a more 

thorough explanation of percent canopy cover needs should be included.

Otherwise the reader is at a disadvantage. 

Update in FEIS. (Add general CWHR classifications of SPMD...) 

2-37 Prescribed burning described on p.71 

sounds good.

The comment has been reviewed and noted. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 261 Comment 

2-38 On p. 77 under Fish Camp Project, 

canopy cover should be maintained ABOVE 60percent, not down to 50 

percent. And trees above 10 to 16 inches dbh should not be logged. 

Desired Conditions for the SSFCA: Within known or estimated female fisthe WUI, a minimum of 50 percent of the forested area has at least 60 perpg. 41) SPOW PAC’s will remain at 60-70 percent cover (ROD 45) and SPOW Hleast 50-70 percent canopy cover. As stated in the Fish Camp EIS, p. 142, “the intent of the Fish Camp projecover of 60 percent or greater in CWHR 4 and 5 size classes where it presis planned to be accomplished by removing excess trees up to the 30 inch  An alternative addressing limiting tree removal diameter to 10 inch D

eliminated from detailed study. See FEIS Chapter 2 Alternatives ConsideDetailed Study. 

2-39 On p. 77 the term “catastrophic, stand 

eliminating” wildfires should be 

eliminated and replaced with a proper technical term. 

The term “catastrophic, stand eliminating fire” has been replaced with “u

wildfire” throughout the FEIS and this term has been added to glossary. 

2-40 On p. 77 where it says “partially 

opening the forest overstory”, we 

suggest that fire rather than chainsaws be used. 

Where applicable, both thinning and prescribed burning activities are toolachieve the desired conditions for the treatment units. Light underburning in most instances, will not open the overstory since ge

than 10 inches dbh would be killed. Partial opening of the overstory is ne

crown expansion of residual trees. Intermediates and some codominant trduring the thinning operation to create room for crown expansion. As stawild stands proposed for thinning consist of mostly shade tolerant species surviving advance reproduction present during logging. These stands are sensitive fir and incense cedar instead of the more shade intolerant less firpine and sugar pine species that were prevalent before the railroad logging small diameters and thin bark of these fire sensitive species and the existinstands that have resulted from 100 years of fire exclusion, the initial treatm
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 262 Comment 

mechanically thin the stands and treat slash concentrations through piling mastication rather than underburning. 

2-41 At the bottom of p. 77 is written that 

Cedar Valley Project is “nearing the end of the implementation phase”. That is 

not clear. By what date will it be completed? These fuels reduction/forest health/community protection projects have been lingering while more projects are planned and contracted (with contracts extended due to low market demand for lumber) at low prices in this bad economy. 

The Cedar Valley Project is scheduled for completion during 2011. A tota

completed. 

2-42 Table 12 on p. 78 has the term 

“Kernal”. What is that? 

The 95 percent use kernel is the technical term used to define the animals 

The UC Berkeley SNAMP study is using a statistical method to develop heach individual fisher based on radio-collar tracking information. 

2-43 At the top of p. 81, it is said that 

“implementation of the Sugar Pine Project will be completed before any ground operations occur on the Fish Camp Project” and that will likely be at least two years. This again brings to 

question the amount of planning and contracting (low price for timber) when there is low market demand. If progress in fuels reduction needs to be made, we should not wait for market demand. Prescribed fire should be used to accomplish the needs. 

The Cedar Valley Project is scheduled for completion during 2011. A tota

completed. 

2-44 On p. 82 is written, “The combination of 

a stable or slightly increasing amount of 

Although some aspects of the behavior of the Pacific fisher are known, insurvival and other basic vital rates are not. These types of data are being g
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 263 Comment 

suitable fisher habitat on the SNF over the last ten years and perhaps an increasing spatial distribution of fishers make it reasonable to conclude the cumulative effects of vegetation management activities on the SNF have not reduced overall habitat suitability for fishers on the Forest.” What about before 2001? Is this due to the elimination of clear-cutting? How much better should it get for the Pacific fisher?

fisher science team, and the information will be crucial for understanding management practices are influencing fisher populations, and whether chaunder different types of treatments may or may not contribute to further dthese rare animals in California. SNAMP fisher team research will continu

2-45 On p. 82 is explained that California 

Department of Fish and Game (CDFG) has assessed that the Pacific fisher does not deserve protected status in the Southern Sierra Nevada. Further comments on p. 82 imply that clearcutting may have been the cause of a previous downward trend in fisher populations. That clearcutting resulted 

from Forest Service management decisions. In October 2010 the SNAMP Fisher Team presented a mid-2010-11 population year update on adult female survival. They found the adult female survival had decreased as of October 2010 in comparison to the previous two years. Perhaps CDFG should have another look at the sensitive status of the Pacific fisher.

A lawsuit was filed by the Center for Biological Diversity in November 2

decision made by the California Department of Fish and Game Commissiunder the state Endangered Species Act. Hearings will be held throughoua decision on the merits of the case in late Summer 2011. Recent scientific information presented in 2011 at The Western Section omeeting indicates that the fisher population on the Sierra National Forest 

Values of lambda (

λ) greater than 1 indicate that a population is decreasin

were presented for fisher populations within the SNAMP study area ( 

λ 1.

Ranger District, and the Kings River Fisher Project area (

λ 1.2) on the Hig

(Sweitzer et al. 2011). Based on this data, fisher populations on both distrForest are stable to increasing, 

2-46 HRCA and PAC are not in the glossary. HRCA and PAC have been added to the FEIS glossary 

PAC=Protected Activity Center (Management area for Spotted Owls = 30

goshawks = 200 acres) 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 264 Comment 

HRCA=Home Range Core Area (Management area for Spotted owls = 30

2-47 On p. 89 and on numerous other pages 

the term “existing condition” appears.

This seems to be the same as “cumulative impacts” or “cumulative effects”. Is there a difference? The DEIS glossary lists only “cumulative effects”. 

Existing Condition on page 89 of the DEIS represents a summary of the k

which serves as a representation of the past actions for the cumulative effe

2-48 Units for data in Tables 13 and 14 are 

not explained.

The columns in Tables 13 and 14 (pages 89 and 90 of the DEIS) indicate Further clarification will be provided in the FEIS, such as (miles = mi.). 

2-49 On p. 97, under Fire Effects is written, 

“This would be accomplished using a combination of thinning and fuels reduction.” The difference between 

“thinning” and “fuels reduction” is not clear. 

Thinning mentioned on page 97 of the DEIS involves the selective removreduction in stand density. Fuels reduction refers to decreasing the amoun

with thinning representing a technique that may contribute toward an obje

2-50 On p. 97, under Fire Effects is written 

(in reference to Nakamura, et al. (2008) –incidentally, not listed in the Literature Cited section of this DEIS), “They also note that some fires are so large (McNally or Cedar Fires) that would likely continue to burn through or around treatment areas.” (sic) But the 

McNally Fire did slow at, and did not go around, a treatment area below Packsaddle Grove in the Giant Sequoia National Monument. 

The referenced fire effects citations have been corrected in the FEIS and aCited section. There is no information provided within the cited reference McNally Fire did slow at, and did not go around, a treatment area below PGiant Sequoia National Monument. The commenter did not provide a southat information. The reference to a specific fire effect for a specific fire in a specific area iprediction of future fire behavior for another area. That being said, slowewith less intensity and generally do not result in stand replacing crown fireffects we are anticipating. 

2-51 On p. 97 under Fire Effects is written, 

“Prescribed burning could indirectly 

The literature cited on page 97 of the FEIS identified possible indirect effburning. The FEIS does not indicate that these effects would be expected 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 265 Comment 

affect streambank stability, aquatic foodwebs, stream temperature, and large wood dynamics (Dwire, et al. 2006; Bêche, et al. 2005).” We believe these effects are more likely with logging by choice and design. The pre-1850 forest condition was the cumulative effect of natural processes without logging and fire suppression. 

for Fish Camp. 

2-52 Many references cited on p. 98 and on 

other pages throughout the DEIS are not listed in the Literature Cited section.

The FEIS was reviewed and all references have been included in the Liter

2-53 On p. 99 a maximum temperature for 

trout stocking by CDFG is given as 21° F. This should be related to Figure 4: 

Expected Summer Temperature Range, as titled, on p. 90. The title of Figure 4 seems incorrect however since its graph is labeled “2008 Mean Daily Water Temperatures”. Data from one year likely are not the range of possible temperatures from year to year. This is misleading and needs to be corrected. 

The Figure 4 on page 99 of the FEIS has been corrected to indicate it repr

data from 2008. 

2-54 Under Alternative 1 – No Action on p. 99 

is written, “The No Action alternative, would not implement the Fish Camp Project to reduce fire ladder conditions (thinning); pile slash for burning; burn slash piles; masticate and/or precommercially thin stands; plant trees; 

No project-generated slash would result from Alternative 1 as noted on pa

Exsisting fuel ladders and fuel loadings conditions would remain. 

These conditions promote crown fire and stand replacing conditions. Witstructural manipulation prior to reintroduction of fire forest health and stabe met. An alternative addressing maximizing the use of fire as the agent for achie
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 266 Comment 

reduce fuel loading through controlled burning; or reconstruct and maintain roads.” Yes, there would be no slash to burn as flammable logging slash would not be produced since there would be no logging, and there would be no need for logging roads either. This reminds us that fire could be introduced (ending fire suppression) to do the work economically and efficiently without logging, road building, mastication, and tree planting.

objectives was considered but eliminated from detailed study. See FEIS C

Considered but Eliminated from Detailed Study. 

2-55 In Table 19 Lacustrine/riverine habitat 

miles is 29, while in Table 22 it is 35 miles. 

It should be 29 miles and has been corrected in the FEIS. 

2-56 At the bottom of p. 101 to p.102 there is 

written, “Numerous effects on aquatic habitat and species have been attributed to prolonged use of riparian areas by cattle. Literature suggests potential effects from cattle grazing relating to channel function, water quantity, hydrologic alteration, and water quality. Cattle grazing has been identified as altering channel function, which reduces natural processes, habitat diversity and habitat complexity for aquatic or riparian animals (Elmore and Beschta 1987; Clary and Webster 1989; EPA 1991; Meehan et. al. 1991; Belsky et. al. 1999). Movement of cattle within riparian zones can lead to reductions in stream shading, compaction of stream 

It was identified in the paragraph in question on page 101 of the DEIS tharepresented potential effects to prolonged use of riparian areas. Further, it these effects were described in literature as being a result of heavy or overindicate at any place in the DEIS or supporting specialist reports that thes

effects were observed. Table 13 (page 89 of the DEIS) and the Existing C

Aquatic Biology (page 89 of the DEIS) and Hydrology/Water Quality (padescribe current stream bank stability as generally in being in fair or bettecattle is not part of the decision to be made for Fish Camp and unrelated t
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 267 Comment 

banks, and trampling of stream banks (Meehan et. al. 1991; Armour et. al. 1994). All of these factors could result in negative effects to habitat for herpetofauna. However, quantifying effects related to continued cattle grazing and recovery from past effects has proved difficult to evaluate due to absence of reference sites that have never been grazed by livestock (Kattelmannn 1996). Some of the effects described in literature are noted as resulting from “heavy” or “overgrazing”. Cattle grazing is administered under U.S. Forest Service permits, which include compliance with S&G from the SNF-LRMP (USDA – Forest Service 1992; 2001; 2004). It is expected that cattle grazing is locally resulting in exposed streambanks and erosion at some sites.” If cattle are the cause of this degradation, then the cattle should be removed. 

2-57 At the bottom of p. 102 it is indicated 

that fire is needed in meadows to deter encroachment of conifers. But then at the top of p.103 it is implied that fire in the vicinity of a meadow will cause all sorts of changes that could be damaging.

We understand that fire causes alterations that are beneficial to forests and meadows. Incidentally, the reference citation for these ideas 

As quoted on page 102 of the DEIS, the US Fish and Wildlife Service ideof the fire regime as a potential adverse effect on Yosemite toad habitat (msome vegetation management may be necessary to maintain or restore habreference has been added to the Literature Cited in the FEIS. 

Page 103 of the DEIS noted that “In the event of a wildfire there could be depending on size and severity”. The potential effects were prefaced as thhigh severity fire and can be contrasted to the occasional setback of conife

the U. S. Fish and Wildlife Service quote. As explained in comment respis not part of the decision to be made for Fish Camp. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 268 Comment 

(USFWS, 2003) is not listed in the Literature Cited list. We believe that cattle continue to degrade meadows. 

The FEIS was reviewed and all references have been included in the Literincluding The reference has been corrected to (USFWS, 2002a. 

2-58 On p. 103 is a statement, “Meyer and 

Safford’s (2010) review of fire literature indicates increases in fire frequency, size, total area burned and severity in the Sierra Nevada over the past 20-30 years.” The Meyer and Safford paper 

seems to be an in house Sierra NF document and not peer reviewed. For that reason we suspect it may not be thorough.

Meyer and Safford (cited on page 103 of the DEIS) represents a working 

Service ecologists examining fire trends presented in the peer-reviewed 

J.D., Safford, H.D., Crimmins, M., Thode, A.E., 2009. Quantitative evifire severity in the Sierra Nevada and southern Cascade Mountains, CaEcosystems 12:1632. 

The working paper includes temperature and precipitation trends based on 

with long-term meteorological data in order to localize potential effects 

Forest. Both Miller et al. and Meyer and Safford are available in the pro

2-59 On p. 115, for “retention groups of large 

diameter trees”, it is said no tree greater than 20” dbh will be cut. We believe no 

trees over 10” dbh should be cut from within those groups. We suspect larger boles have already been cut during earlier logging. 

The intention of the large tree groups is to retain a heterogeneous mix of h

treatment units rather than creating a uniform/homogenous spacing of treethinning/fuels reduction. An alternative addressing limiting tree removal diameter to 10 inch D

eliminated from detailed study. See FEIS Chapter 2 Alternatives ConsideDetailed Study. 

2-60 No map is included that shows the dates 

of plantation establishment and locations and dates of earlier logging units (historic private and Forest Service) within the Project area. Such maps 

would better help the reader understand the nature of past extractive logging and replanting. 

Plantations planned for treatment under this document are displayed throuthe Fish Camp EIS. As stated in the EIS, these plantations range in age frplanned plantation treatment areas are the more densely stocked portions following the 1919 to 1923 railroad logging. All wild stands proposed for and 8b were previously heavily railroad logged. Locations of past railroabeen determined through the use of 1944 aerial photography. The entire arailroad logging era. Units were not delineated. As stated in the Forest V

Affected Environment section (p. 133) of the EIS, wild stands present wit

railroad logged areas, both proposed treatment and non treatment areas, oshade tolerant, fire sensitive, advance reproduction present during logging

2-61 At the bottom of p. 115 a Table 1 is The reference to “Table 1” was deleted from the FEIS on page 20. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 269 Comment 

listed. That does not seem to be the Table 1 on p. 20. That needs to be corrected or clarified. 

2-62 Pages 116 to 117 regarding “MIS 

Project-level Effects AnalysisShrubland...” is not clear as it includes 

more than just shrubland. Table 2 that is referred to is not the Table 2 on p. 21. CWHR referred to is not with the DEIS.

This has been addressed in the FEIS in Chapter 3-Terrestrial Managemen

2-63 Map 6 key is without explanation of 

CWHR Typing. 

The FEIS Map 6 Key has been revised to explain CWHR typing. 

2-64 On p 121 is written, “Currently across 

the treatment units there are 9 standing conifer snags that are >11” dbh and 5 

standing conifer snags that are >

18”dbh.” Is that all? You will need to plan for production of large snags for wildlife. No trees over 10” dbh should be cut. 

The Fish Camp Project forest vegetation types are primarily Westside mixPonderosa/Jeffrey pine, which requires maintenance of four of the largest 

distributed irregularly across the landscape (SNFPA ROD pgs 51-52). Thretain an average of 9 snags per acre 

≥11” dbh and 5 snags per acre 

≥18” 

units, exceeding the minimum requirement set forth in the SNFPA ROD. will also retain an average of 47 large (

≥20” dbh) live conifers per acre to 

snags in the future as some of these large trees receive environmental dam

succumb to disease and/or insect attacks. An alternative addressing limiting tree removal diameter to 10 inch D

eliminated from detailed study. See FEIS Chapter 2 Alternatives ConsideDetailed Study. An alternative of Snag/Down Log Generating Treatments was considered detailed study. See FEIS Chapter 2 Alternatives Considered but Eliminate

2-65 It is not clear how the term ROD got 

inserted at the bottom of p. 121. We 

assume it is boilerplate erroneously left 

The statement at the bottom of DEIS page 121 has been deleted from the 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 270 Comment 

in.

2-66 Hydrology references at the top of p. 123 

are inconsistent with the Literature Cited list. 

The FEIS was reviewed and all references have been included in the Literincluding the mentioned hydrology references. 

2-67 “BMP 7-8 (Table 9)” on p. 124 is not 

clear. 

The SNF reviewed this section of the DEIS and determined that it would b

a table that summarizes the baseline CWE conditions of the No Action Al

determined not to be needed and has been deleted from the FEIS. 

2-68 On p. 125 is written, “Conifers between 

8 and 30 inches DBH exceeding desired stocking levels will be removed during harvest operations.” We believe larger 

size boles > 10” and up to 30” and greater are not in excess of stocking levels and should be left in place. Of course the smaller trees 8” dbh and 

below which ACTUALLY constitute the fuels problem are the ones that could 

easily be removed by use of fire. Then the forest would be restored to a “healthy” condition more quickly (Shown as desired on p. 126.). This would be in accordance with North, et al. PSW-GTR-220 (2009).

On page 6 of the 2004 Sierra Nevada Forest Plan Amendment ROD, a conthe negative influence of drought and weather variances throughout the raThe 2004 ROD provides for density management to improve the forest’s rinsect and disease conditions. The Fish Camp EIS Forest Vegetation/Silv145) describes the existing vegetation condition, the rational and the procstocking levels as well as the direct, indirect and cumulative effects of dendescribed in the EIS, boles /basal area in excess of stocking levels are deteyield tables (basal area) or stand density index (SDI) methods not diametereports substantiate the use of these methods to accomplish thinning objecNeed section of the Fish Camp EIS describes the need for density manage2009 and the February 2010 addendum to the North, et al., PSW_GTR-22

of ecological benefits of density management through the removal of treereport to be intermediate in size.. Thinning of the intermediate-size trees described by North, et al., is in accordance with GTR220 as described in rcomments. An alternative addressing limiting tree removal diameter to 10 inch D

eliminated from detailed study. See FEIS Chapter 2 Alternatives ConsideDetailed Study. Also see response to comment 2-13, 2-59 & 2-64. 

2-69 On p. 128 is written, “As part of the 

Timber Sale contract, all the roads to be used for project activities will be brought up to a maintenance level 3 standard (BMP 2-22). This includes maintaining roads in a manner that provides for water quality protection by minimizing 

All project roads will receive post haul maintenance upon completion of pincludes blading, surface repair, and culvert and ditch cleaning. Level 1 roand barricaded to prevent access. Level 2 and level 3 roads will remain o
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 271 Comment 

rutting, failures, sidecasting, and blockage of drainage facilities, all of which can cause erosion, sedimentation and deteriorating water conditions.”We ALSO want to know what will happen to the roads after project completion.

2-70 On p. 129 references to “Figure 6” 

should be Fig. 8. 

Figure 8 has been correctly identified in the FEIS. 

2-71 On p. 133 reference is made to the 

condition of 40 to 50 year old plantations that have been “precommercially thinned” in the last few years. Some of that “thinning” was done by mastication, and left “shredded” material on the ground as “mulch”. We consider that mulch as 

highly flammable surface fuels. We would like an explanation for how you will prevent further such accumulations of highly flammable surface fuels if mastication is to be used during this Fish Camp Project. 

Mastication does not reduce the fuels loading but changes the structure of orientation to a horizontal orientation by shredding material and/or crushi

By changing the fuel structure from a vertical orientation to a horizontal oeliminates ladder fuel that could provide conditions for crown fire ignitionresistance of control providing a safer environment for firefighters to engaincrease the likelihood of successfully controlling a wildland fire at small

2-72 On p. 133 it is written that most of those 

trees in 40 to 50 year old thinned plantations are now “10 inches and larger...dbh”. That seems remarkably 

small for trees of that age in the Fish Camp Project area. Still, 10-inch trees could have been harvested and not masticated. All that is unclear. Were any of the trees harvested for lumber? 

The average tree diameter within the 40 to 50 year old plantations propose15 and 17 inches dbh. The precommecial thinning previously done in the treatment within these stands was completed over 20 years ago. Average time were well below 10 inches dbh. Excess trees removed were below cnot harvested. Excess trees planned for removal with this entry are plannand not biomass. An explanation of the plantation maintenance across the SNF is outside th
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 272 Comment 

Or is the quality of those trees not good for lumber? Is the present quality of those trees now good only for cogeneration biomass even after 40 to 50 years of growth? We would like a separate explanation of this situation regarding plantations on the entire Sierra National Forest. 

2-73 On p. 134 under Weather Changes a 

reference, Ferrell, 1996, is not in the Literature Cited list. 

The FEIS was reviewed and all references have been included in the Literincluding the mentioned Weather Changes Ferrell reference. 

2-74 On p. 134 is written, “Beginning in the 

1970’s temperatures began to warm noticeably. This warming resulted in a greater fraction of the Sierra Nevada precipitation falling as rain rather than snow, earlier snowmelt and earlier streamflow peaks (Dettinger, 2004).” (sic) If we read Dettinger, et al.PSWGTR-193 (2004, in press) correctly, the 1970’s temperatures you refer to are “simulated temperatures”, NOT actual 

temperature data. (NOTE: Your reference citation does not include reference to Dettinger’s co-authors.)

The Dettinger, et al, 2004, reference covers simulated temperatures projec

green house gas buildups. The actual temperature warming and snowmelhave been rewritten to: van Mantgen, 2009; Knowles, et al, 2006; and Stebeen clarified in the FEIS.. ”Et al” has been added to the Dettinger citation to include Dettinger coaut

2-75 On p. 134 under Weather Changes, is 

written, “Wide swings in weather conditions over the past thirty years have placed stress on many of these stands.”

That statement shows a basic misunderstanding of how climate is determined. Climate is determined on the basis of 30 years of consecutive data. 

The FEIS wording has been changed to use the word “weather” instead of Knowles, et al, 2006, states: “...they (earlier runoff, less snow, earlier snoresult from still longer term weather shifts.” Knowles statement indicates to warmer temperatures with less snowfall and earlier snowmelt. Stewart, et al, 2005, states: “almost everywhere in western North Americadecrease in the spring-summer stream flow fractions will accentuate the tydrought with important (adverse) consequences for warm-season supplies
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 273 Comment 

See World Meteorological Organization at: http://climate.weatheroffice.gc.ca/prods_servs/normals_documentation_e.html

Weather varies continuously during the succeeding 30 years, but the climate classification does not. 

risks.” Malcolm North’s GTR 220 also makes reference to improving forest resilconditions. 

2-76 Again, on p. 134 under Weather 

Changes, the last paragraph shows the confusion of actual weather data as compared to the simulated values from Dettinger, et al. (2004). The “projected” 

snowmelt and streamflow values, as such, are predictions based on a model.

The projected snowmelt and streamflows referred to in this reference are, 

projections based upon a combination of existing data and projections. Fu

a combination of present and expected (projected) conditions. Dettinger, 

as the projections of others, provide a basis for future planning. 

2-77 There is no entry in the Literature Cited 

list for van Mantgem (2009) cited on p. 134. 

The FEIS was reviewed and all references have been included in the Literincluding the mentioned van Mantgem 2009 reference. 

2-78 On p. 134 is written, “Over the past 17 

to 29 years noncatastrophic mortality rates were found to have doubled over a series of 76 western forest plots. Increasing mortality rates could result in substantial changes in forest structure, composition, and function. This doubling of background mortality could cause a >50percent reduction in average tree age in a forest, and a potential reduction in average tree size (van Mantgem, 2009).” It is not clear if all of these quoted ideas are from van Mantgem. The nature of those 76 western forest plots is not explained. They could range from old forest stands to totally clearcut 

The description of the 76 plots has been rewritten in the EIS to describe thin undisturbed, more than 200 year old stands. This reference is entirely f
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 274 Comment 

stands for all we can see. Those forest plots might be places where all big old trees have been logged. Those plots might be overcrowded plantations where fire has been excluded and where no other thinning has been applied. The reader should not be left to mentally fill in the blanks. Each reader would likely have a different perception.

2-79 On p. 147 you allow, “Although there is 

relatively little understanding of the ecological effects of fuel treatments, in particular the extent to which mechanical treatments might emulate natural ecological processes such as fire (Stephens, S., 2009), they can be effective tools to modify stand structure and influence subsequent fire severity and extent. These mechanical treatments are often a required first treatment in forests containing excessive fuels loads (North, M., 2009).” sic We are glad that you 

admit there is a lack of research to support mechanical treatments as an ecological surrogate for fire. We are surprised that such research has not been carried out considering the vast amount of logging over time. That is shocking.

We want to remind you that the nearby National Parks (Yosemite, Kings Canyon, and Sequoia) utilize fire successfully without first applying mechanical treatments. Fire is best ecologically. And since your ultimate 

While it is true that there are tractor units adjacent to Park’s wilderness boconcerns expressed regarding these treatments during scoping and there pwilderness values. The Sierra NF has collaboratively been working with Park in regards to reducing fire threat along shared boundaries . Whole trewill be utilized during project implementation to minimize the impacts of The purpose and need of this project to reduce the intensity and spread of wildfires far outweighs the potential short-term effects of mechanical treavalues. An alternative addressing maximizing the use of fire as the agent for ac

objectives was considered but eliminated from detailed study. See FEIS 

Considered but Eliminated from Detailed Study. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 275 Comment 

goal is to reintroduce fire, why not do much more of that in this project. We notice that your plan includes underburning as shown on Maps 1 and 2. We also notice that those underburning units are on the boundary with Yosemite National Park, but not elsewhere and that there also are tractor units on the Park boundary as well. We are concerned that such mechanical work will have negative impacts on the Park. While you suggest North, et al. (2009) support mechanical pre-treatments, it is not clear to what severity those mechanical treatments would best be applied.

2-80 Use of the term “this report” at the 

beginning of paragraph 2 on p. 147 is a switch of content without a lead-in. That 

needs to be clarified.

In this particular sentence, it should state the Fish Camp project analyses twithin the units, not this report. This has been corrected in the FEIS. 

2-81 Near the bottom of p. 147 is written, 

“Also decreasing the crown density and removing smaller trees while retaining larger more fire resistant trees reduces the risk of crown fire.” For this reason 

only smaller trees should be removed as per North, et al., (2009).

The purpose and need for the Fish Camp Project is multi faceted and utilithat compares the current condition of key ecosystem components against sentence near the bottom of page 147 “ Also decreasing the crown density 

trees while retaining larger more fire resistant trees reduces the risk of cro

one of multiple purposes and needs for the Fish camp project which is to clandscape area treatments and defensible fuels profiles near key transportathe intensity and spread of wildfires across the landscape and near commu

provides opportunity to apply treatment for larger sized trees to improve finter-tree competition and improving tree vigor to provide an increased stconditions, insect and disease attack. An alternative addressing limiting tree removal diameter to 10 inch D

eliminated from detailed study. See FEIS Chapter 2 Alternatives ConsideDetailed Study. Also see response to comment 2-13, 2-59, 2-64 & 2-68. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 276 Comment 

2-82 On p. 150 you indicate that General 

Forest allocations desired conditions are identical as those for Old Forest Emphasis areas and should resemble presettlement conditions. That seems 

admirable. But your general forest designation is reduced a great deal since your Wildland Urban Interface (called “Wildland Urban Intermix” in the DEIS glossary) is too expansive at a total distance of 1 1⁄2 miles from structures. The National Parks use a 200 foot zone recommended by Jack Cohen of the Forest Service Fire Lab instead. We note that you do not include any citation or reference to Mr. Cohen’s work. We believe you are thus in violation of doctrine to avoid “selective science”.

The Forest Service’s primary responsibility and objective for structure firwildfire before it reaches structure. (Forest Service Manual, 5137.02). Th

stands and homes is crucial to the success of fuel management activities in large fires either at the local or landscape scale. (Finney and Cohen, 2003produce gaps in the flame front significantly reduces radiant exposure, anmaximum radiant exposure is well below exposures necessary for piloted defensible space requires more vegetation fuel hazard reduction than fuels 

preventing piloted wood ignitions. (Cohen and Butler, 1996). Agency WU

do not address home ignitability but rather areas outside the home ignition the vicinity is expected to protect homes by creating conditions that enablsuppression if a wildfire would to occur. Preventing WUI fire disasters reframed of home ignition potential. Because this principally involves the hhome ignition zone primarily falls within private ownership, the responsibignition largely falls within the authority of the property owner (Cohen, 2

2-83 On p. 151 you describe the desired 

conditions of the Wildland Urban Interface (WUI). But something major is 

missing. Human structures are now part 

of the forest. A major part of the desired condition is that home fire-safe measures must be followed and that vegetation modifications out to 200 feet from structures should be made so that the structures will not ignite due to nearby wildfire. Jack Cohen has shown this is so. You need to cite Mr. Cohen’s work. You need to explain that. Then you need 

We agree that home fire-safe measures must be followed and that vegetat200 feet from property owner’s structure(s) should be made. But because around property owner’s structures falls within private ownership, the resmodifications out to 200 feet largely falls within the authority of the propService does not have the authority to enforce private home owners to con

studies. An alternative addressing limiting treatments to 200 foot zones from s

but eliminated from detailed study. See FEIS Chapter 2 Alternatives Consfrom Detailed Study . 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 277 Comment 

to write an Alternative without your expansive WUI.

2-84 Table 31 on p. 155 shows that only one 

small fire has occurred within the Project boundary, yet on p. 156, is written, “The areas east of Fish Camp received extensive logging between 1918 and 1925 which resulted in slow natural regeneration of conifer species. Railroad and ground-based logging activities as well as stand replacing fires have resulted in little of the area with trees over 100 years of age.” Your bias is 

showing. Logging stripped the trees off the landscape. Trees have grown back slowly since fire exclusion has allowed overstocking and consequent competition and thus slow growth of individual trees and stress related tree die off. Reintroduction of fire is the answer to your need to thin and to do so ecologically.

The header “Past Activities” was added to page 155 of the FEIS to better 

logging are addressed as past activities relevant to cumulative effects of thAn alternative addressing maximizing the use of fire as the agent for achieobjectives was considered but eliminated from detailed study. See FEIS C

Considered but Eliminated from Detailed Study. 

2-85 On p. 158 is written, “Under Alternative 

1, there would be very limited to no potential to allow fire to play its natural role on the landscape. The risk of escape and the consequential effects associated with utilizing fire without some form of management activity to reduce current surface fuel loadings and ladder fuels would be too great.” Here you are suggesting that fire would be used under Alternative 1, the No Action Alternative. 

Under the No Action Alternative existing projects continue as planned. Trefers to other National Environmental Policy Act (NEPA) compliant projProject boundary. When the reader interprets the statements made and as 

misinterpretation of what is being said. Natural fire (unplanned ignitions)(planned ignitions) would not be able to play a role on this landscape becaconditions. This FEIS section has been reworded for better clarification i

An alternative addressing maximizing the use of fire as the agent for achie

objectives was considered but eliminated from detailed study. See FEIS C

Considered but Eliminated from Detailed Study. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 278 Comment 

That cannot be correct since no action means there will be no change from current plans. Do your current plans already require you to use fire in place of mechanical treatments? Please explain this to us in writing. We request that you rewrite the DEIS with another Alternative with fire use in place of mechanical treatments. The National Parks do that. You should see the obvious need for such a Fire-Use Alternative in the Fish Camp Project Plan and include one.

2-86 On p. 159 is written, “Crown fires have 

the largest immediate and long-term ecological effects and the greatest potential to threaten human settlements near wildland areas (Graham, R., et.al., 2004).” Here you should also cite the work of Jack Cohen as he has found that a properly designed 200 foot home modification zone will prevent ignition of homes when a crown fire is only 200 feet away. Again, to ignore Cohen, is to show bias through application of selective science. 

We agree that Jack Cohen’s design of 200 feet modification zone might pa crown fire were 200 feet away. He also states the home ignition zone faownership, the responsibility for vegetation modifications out to 200 feet authority of the property owner. 

2-87 On p.161 for Alternative 2 – Proposed 

Action, you suggest retaining larger trees to create a more fire resistant forest as per Table 28 (pp 147-148). But Table 28 also provides that “Removing only smaller trees is economically less feasible”. In this DEIS the plan is to log 

One of the purpose and needs for the Fish Camp Project is to create a netwtreatments and defensible fuels profiles near key transportation corridors t

spread of wildfires across the landscape and near communities. The Projestrategically planned to concurrently leave larger trees that will be retaineold forest emphasis and open up the crown density of larger trees improve 

inter-tree competition and improve tree vigor to provide an increased stanconditions, insect and disease attack. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 279 Comment 

up to 30” dbh. Those are larger trees that should be retained to develop the desired old forest emphasis areas extending from the 200 foot zone emphasized by Jack Cohen. North, et al. (2009) suggests that for ecological considerations only trees much smaller should be considered for logging.

Malcolm North, et al.’s PSW-GTR-220, February 2010 addendum states: climate conditions, how can managers improve forest resiliency?” GTR-2

is improved by producing a forest structure that keeps insects and pathoge

levels. “One method of changing this pattern is to reduce tree moisture st

beetle activity by reducing stand density with mechanical thinning.” The 

“in dense, fire-suppressed stands, thinning can significantly reduce the amarea often leading to decreased transpiration and increases in soil water co

states: “removing such (intermediate-size trees (20-30 inches dbh) may gecological goal. (Such as) locations (where) intermediate-size trees contrithat are moisture stressed and at risk of bark beetle attacks.” This project 

below, concentrating removal on smaller diameter trees, as recommended Excess intermediate-size trees (20-30 inches dbh) are only proposed for reobtain desired residual stocking levels. In most cases, residual trees will bthose removed. Thinning will generally remove the least fire resistant tretreatments are being proposed to reduce density stocking levels in order to better enable these stands to face changing weather conditions. Thinning diameter growth resulting in larger diameter trees in shorter time periods. growth will result in creation of thicker bark in shorter time periods thus ebetter withstand the effects of potential future wildfires or underburning. An alternative addressing limiting treatments to 200 foot zones from s

but eliminated from detailed study. See FEIS Chapter 2 Alternatives Consfrom Detailed Study. An alternative addressing limiting tree removal diameter to 10 inch D

eliminated from detailed study. See FEIS Chapter 2 Alternatives ConsideDetailed Study.  Also see response to comment 2-13, 2-59, 2-64, 2-68 & 2-81. 

2-88 On p. 161 mastication is emphasized as Mastication does not reduce the fuels loading but changes the structure of 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 280 Comment 

a means of fuels reduction. Masticated material is highly flammable surface fuel, just witness the American River Complex fire of a few years ago. Incidentally, you have referred to various wildfires that were in the news over the last decade and more. You should also refer to the American River Complex Fire. To leave out that information is misleading and unclear as a violation of NEPA.

orientation to a horizontal orientation by shredding material and/or crushiBy changing the fuel structure from a vertical orientation to a horizontal oeliminates ladder fuel that could provide conditions for crown fire ignitionresistance of control by reducing the rate of spread and flame length, prov

for firefighters to engage in initial attack and increase the likely hood of swildland fire at smaller acreage. American River Complex fire report states that three masticated units weron a day of moderate fire behavior, two were burned through with loss of of severe fire weather. These two 20 year old plantations were masticated year later when the high severity fire occurred in a two day period beginn

inversion lifted, temperatures rose and humidity dropped. Energy Release measure of fuel dryness values exceeding the 90th percentile for the season 

were probably record or near record values for the dates. The Sierra National forest has experienced two wildfire incidents that burunits. These treated units modified wildfire behavior and increased fire liallowed fires to be suppressed to less than one acre. The term 90th – 97th Percentiles has been added to the glossary. These ter

hottest 10 percent and 3 percent fire weather conditions during a given pe

2-89 At the bottom of p. 161 is written, “In 

areas where there is a significant amount of ladder fuels present, biomass operations will be used to remove excess material.” We want to know who will 

get this uneconomic biomass. As we understand it, no one wants to take a loss to obtain the biomass. Will there be a service contract to remove this biomass to a cogeneration facility?

In this particular sentence, the FEIS has been revised to state: “In areas wamount of ladder fuels present, combination of tractor or hand piling and 

remove excess material, not biomass operations.” 

2-90 On p. 164, it is suggested that prescribed 

fire will be “reintroduced”. Do you 

In this particular sentence, the FEIS has been revised to state: “introduced“reintroduced”. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 281 Comment 

really mean “introduced”? Will you really use prescribed fire as the preferred treatment in the future, or will you continue to find rationales to continue with logging?

2-91 On p. 165 is written, “As stated earlier, 

weather (climate) has a large influence on fire behavior and is also the most difficult to predict. Here, again, to you 

need to make corrections to distinguish between what is climate and what is weather. 

In this particular sentence, the FEIS has been revised to state: “weather”, (climate)”. The definitions of weather and climate have been added to thWeather : The state of the atmosphere with respect to wind, temperature, pressure, etc. Weather refers to these conditions at a given point in time (etemperature). Climate: The composite or generally prevailing weather conditions of a r

averaged over a series of years. 

2-92 On p. 165 is written, “Managing forests 

under these conditions will be challenging. In the face of uncertainty, adaptive strategies should focus on three responses; resistance (forestall impacts and protect highly valued resources), resilience (improve the capacity of ecosystems to return to desired conditions after disturbance), and response (facilitate transition of ecosystems from current to new conditions) (North, 2009). All of these are focuses that Alternative 2 is attempting to address through its purpose and need for changes in forest structure capable of surviving climate changes and reduction in fuels to adapt fire behavior that occurs under current 

See response to comment 2-87. The Fish Camp Project uses resistance annot a response strategy. The FEIS has been changed accordingly. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 282 Comment 

climate and ignition conditions (North, 2009).” This general statement does not convey what will be done. Certainly, using adaptive management to change ecosystems from present to new conditions is not explained nor is it necessarily (or perhaps even likely) desirable.

2-93 On p. 166 is written, “The standards and 

guidelines listed in the SNFPA ROD, 2004 give direction for locating area treatments. Site-specific fuels treatment prescriptions are designed to modify fire intensity and spread in treated areas. Managers are to consider topographic position; slope steepness; predominant wind direction; and the amount and arrangement of surface, ladder, and crown fuels in developing fuels treatment prescriptions for each treatment area. Fuels treatments are intended to reduce surface, ladder, and crown fuels. Crown fuels are modified to reduce the potential for spread of crown fire.” Here we see 

the perpetuation of fire suppression.

The purpose and need for the Fish Camp Project is multi faceted and utilithat compares the current condition of key ecosystem components against One purpose for the Fish camp project is to treat surface and ladder fuels 

wildfire spread and fire intensity levels. This is proposed to be completed 

biomass thinning of pre-commercial and commercial conifers, mastication 

burning in order to improve the ability of firefighters to suppress and contbetter measure of safety for the public and personnel. 

2-94 On p. 166 is written, “Revenues from the 

sale of commercial forest products may be obtained from some fuels treatments. This increases the likelihood of accomplishing the projected acres of treatment, an essential first step in achieving the desired reductions in acres burned. Where consistent with desired 

The total project cost is approximately $1,856,729 for Alternative 2 and $3. The value of commercial forest products harvested is $1,077,672 from $342,308 from Alternative 3 as displayed in Table 45 of the Economics Salternatives, the cost of logging, haul to the mill and other identified activcommercial forest product value. An estimated additional $779,057 for A

for Alternative 3 of appropriated funds from the National Treasury would 

accomplish the proposed activities for the project. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 283 Comment 

conditions, area treatments are designed to be economically efficient and meet multiple objectives (SNFPA ROD, 2004; page 35).” First, why is “an essential first step” going to be to reduce the acres burned in the project? This is unclear. Earlier you said you wanted “reintroduce” prescribed burning. Second, how much of the project cost will not be covered by revenues from sale of commercial forest products? Finally, what is likely to be the overall expense to the U.S. Treasury as planned versus the cost if a Fire-Use Alternative with a 200 foot home modification zone (as per Jack Cohen) were implemented instead?

An alternative addressing limiting treatments to 200 foot zones from s

but eliminated from detailed study. See FEIS Chapter 2 Alternatives Consfrom Detailed Study.  An alternative addressing limiting tree removal diameter to 10 inch D

eliminated from detailed study. See FEIS Chapter 2 Alternatives ConsideDetailed Study. As these alternatives were eliminated from detailed study, an economic an

2-95 On pp. 166 to 167 is written, “Within the 

SNFPA ROD, 2004, fire and fuels goals include reducing threats to communities and wildlife habitat from large, severe wildfires and re-introducing fire into fire-adapted ecosystems. Broad-scale goals include:  Treating fuels in a manner that significantly reduces wildland fire intensity and rate of spread, thereby contributing to more effective fire suppression and fewer acres burned;  Treating hazardous fuels in a costefficient manner to maximize program effectiveness; and 

The purpose and need for the Fish Camp Project is multi faceted and utilithat compares the current condition of key ecosystem components against the implementation of the Fish Camp Project, there is an opportunity to trloadings and modifying forest structure to provide the ability for low intenfire in the short term) to be re-introduced into a fire dependent ecosystem effects are moderated to a level that provides a better measure of safety to See response to comments 2-82, 2-83, 2-86, & 2-94. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 284 Comment 

 Actively restoring fire-adapted ecosystems by making demonstrated progress in moving acres out of unnaturally dense conditions. Management of hazardous fuels in and around communities is to be combined with strategic placement of fuels treatments across broad landscapes to modify wildfire behavior. Goals for fuels treatment include:  Strategically placing treatment areas across landscapes to interrupt potential fire spread,  Removing sufficient material in treatment areas to cause fire to burn at lower intensities and slower rates of spread compared to untreated areas, and  Considering cost-efficiency in designing treatments to maximize the number of acres that can be treated under limited budget (SNFPA ROD, 2004 pp.34-35). We see this as continuing fire suppression even though “re-introducing fire” is claimed as a major goal. This is contradictory. Use of fire is costefficient as well (another goal). Additionally, if communities were managed as Jack Cohen would (that is as though the community were the firebreak) then your rationale for SPLATS would vanish. We believe your 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 285 Comment 

real rationale for creating SPLATS is to send logs to the mill. Again, you need to consider the work of Jack Cohen and create a cost-efficient “Fire-Use Alternative for the Fish Camp Project”. 

2-96 On p. 169 in relation to creating 

SPLATS and DFPZ’s and treatments in the WUI, it is written, “In some cases, initial treatments can in effect increase, not decrease the intensity and spread of wildfire without further treatment to remove residual (activity generated) debris (in the form of surface fuels) or vegetation that does not have a commercial value. These follow-up treatments can take up to 5 years or more or in some case less to complete dependent on funds available and location of treatments. The timeframes for follow-up treatment is dependent on several factors including the amount of funds available to do such work.” This 

is all the more reason to use fire to complete the work more quickly and cost-efficiently. With all the additional fuels buildup in succeeding years following mechanical treatment deposition of slash and masticated wood, the fire risk will likely increase so much that prescribed burning will look even more attractive for fuels reduction while it provides ecological benefits as well.

The comment has been reviewed and noted. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 286 Comment 

2-97 On p. 169 in two places the term “Fish” 

is used in place of “Fish Camp”. 

The Fish Camp Project is appropriately identified in the FEIS on page 169

2-98 In regard to air quality (from pp. 170 to 

187) we believe smoke will eventually occur, no matter what methods are implemented. Biomass removal will not be effective in preventing fires and their smoke. Fire use seems a reasonable option for management.

Biomass wording has been deleted from the FEIS on page 161. 

2-99 The “Economics” section beginning on 

p. 189 seems to be mainly to support local jobs while there is to be great expense to the U.S. Treasury. We 

believe forest jobs could be created in other ways than timber harvest. Such other jobs could be more continuous over time and could better improve forest conditions.

 The comment has been reviewed and noted. 

2-100 On p. 189 is written, “The district 

recognizes that the project will cost more money than it could generate from the forest products removed. Therefore, additional appropriated dollars would need to be requested to complete any of the action alternatives.” This is not surprising The late forest economist Bob Wolf (He drafted the NFMA.) said the Forest Service has always lost money on timber ever since 1905 (Personal Communication).

The comment has been reviewed and noted. 

2-101 On p. 189 is written, “...economics will 

not be a deciding factor for selecting any action alternative for the Fish Camp 

The alternative selected will be the alternative that best meets the purpose project. The Economics Section acknowledges that additional appropriate

necessary to implement the project. The Proposed Action treats more lan
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 287 Comment 

Project.” We believe economics is your only reason for selection of Alternative 2, the Proposed Alternative. The deciding factor is not to save the expense to the U. S. Treasury (that is always a loss), but rather to provide work and profits for local industry. This is made possible by selling timber at low bids and extending contracts until the lumber industry can market the wood profitably. Furthermore, since timber prices are low now, we assume the contracts for the timber will be fixed at low values. The timber then will not be harvested until demand and thus prices are higher for the finished material in the market. Then the implementation of the Fish Camp Project work will be delayed and fuels reduction and proposed improved ecological conditions will wait. All the while the U.S. Treasury will provide the costs to maintain the standing inventory of contracted timber. 

will require more appropriated funds. Local industry will benefit from the 

products from the forest and the Forest Service wants a healthy and viable 

tool to help maintain a resilient forest. Timber sale contract terms and connational level. The contract will allow some room for timing of market coService sells timber at the current market rate. Depending on the type of tfor stumpage can escalate up and down with lumber market rates during t

Fish Camp project will have a two year contract term for timber removal 

2-102 Table 45 on p. 191 includes units of ccf 

or hundreds of cubic feet for timber volume based on sizes of boles. The ccf 

units, through some manipulation, are not directly converted to the more traditional thousands of board feet (MBF). That leads to lack of clarity as to how much timber will be harvested. Furthermore, Table 45 does not reveal the volume from individual project units. 

The Region 5 Timber Sale Appraisal Handbook uses costs based on CCF the tables in the DEIS have volume and costs in CCF units. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 288 Comment 

Those stand data are needed for clarity.

2-103 On p. 193 in relation to improving forest 

conditions is written, “The need to increase the proportion of large trees across a landscape,” We believe the 

proportion of large trees will increase faster if the larger trees are selected to be left standing in the forest by the use of fire.

Thinning from below will reduce the competition among residual trees. Nas others, states that thinning can result in increased soil water content whand metabolic function in the remaining trees. In addition, thinning will p

expansion. Increased crown size and water availability will result in increresulting in increased diameter and height growth. Intermediate-size trees selected for removal will generally be smaller than trees. These larger residual trees will have more full crowns and be better 

water and nutrients. Larger diameter trees with fuller crowns will be obta

thinning.  An alternative addressing maximizing the use of fire as the agent for achi

objectives was considered but eliminated from detailed study. See FEIS C

Considered but Eliminated from Detailed Study. 

2-104 At the bottom of p. 193 under 

Unavoidable Adverse Effect, once the multiple negatives are removed from the single short sentence in this highlighted section, you say that NO BAD EFFECTS will occur in the Project area. We 

believe you should put on your thinking caps.

The FEIS, page 199, has been corrected to state “No unavoidable adverse Project area”. 

2-105 On p. 194 under Irreversible and 

Irretrievable Commitments of Resources you fail to include the commitment of timber under contract for many years until it is finally harvested. Once the 

contracts are signed with allowance for perpetual extensions, the U.S. Treasury is burdened with the requirement to provide opportunities for profits to industry even if alternative 

The Forest Service expects a two year timber sale contract. Contract modcontract terms due to interrupted operations during normal operating seaschanges. Due to the local demand for logs at mills, the Forest Service expoperations within the two year contract period. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 289 Comment 

implementation procedures were found to be needed to complete project goals. 

American Forest Resource Council April 4, 2011 

3-1 Support of Proposed Action The comment has been reviewed and noted. 3-2 Summary, p.1 that “A variety of 

species are highly dependent on conditions provided by functioning ecosystems .... and are susceptible to possible loss of viability ......” is vague, and could apply to any forest land in the Sierras. Anything is possible, but unless the cause and probability of viability loss is known, meaningful remedies cannot be taken. 

There are numerous on-going research projects such as the Sierra Nevada AdProject (SNAMP) whose goal is to ascertain and clarify some of the causes aviability for TES species in the Sierra Nevada. The Forest Service will incorprecommendations from the best available science and scientific literature as m

further research is conducted. 

3-3 The Design Criteria common to the 

action alternatives starting on page 12 of Chapter 2 should be reviewed by the Interdisciplinary Team to insure that the listed criteria are the most effective, and least constraining for efficient project implementation. It appears that many criteria require specific actions instead of the end results to be obtained. Often flexibility to use other methods or procedures becomes apparent during field operations. For instance, some of 

The Design Criteria common to the action alternatives have been reviewed aLOPs for Spotted Owls and Northern goshawks were set in place only on un

determined presence of nesting raptors. LOPs for Pacific fisher and marten asuitability. Due to the limited duration, timing, and location of these fisher an

not appear they will be limiting to the available operating days for potential pDesign criteria need to be determined fairly specifically prior to analysis sinc

themselves have affects beyond those that they were designed to ameliorate. proposed alternatives including the design criteria need to be evaluated in the 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 290 Comment 

the many Limited Operating Periods (LOPs) appear to greatly limit the already scarce operating days available to potential purchasers and will increase costs and lower bids. 

3-4 An example is the silvicultural 

requirement for a LOP which would limit logging of any unit with greater than 50 percent true fir until after August 1. (Page 17, Chapter 2). The criteria should define the allowable percentage of damage to the residual stand, and leave it up to the operator to meet that standard. Standard contract language gives the sale administrator (SA) or Contracting Officer’s Representative (COR) the authority to minimize unnecessary damage. To restrict logging to the period of highest fire danger when operations are often restricted for other reasons is unnecessary. 

The EIS states the LOP would be imposed in well stocked stands heavy to fir states the District Silviculturist will determine which stands require a LOP duphase. Data collected to date indicate that few stands exceed 50 percent fir. 

little, if any, impact on limiting overall operations. See response to comment 3-3. 

3-5 Another example is the requirement 

to “leave a 100-foot wide buffer of 100 percent soil cover below large rock outcrops, especially in units ...” (7 units listed). Geology/Soils, P 13, Chapter 2. This criteria needs qualifying language such as “when disturbed by contractor’s operations”. What happens if current ground cover is less than 100 percent and the area is not impacted by operations? Will a 

Soil cover includes rock fragments, leaf, litter, and woody debris. If soil covthe intent is for the contractor to increase soil cover with available material oreduction in ground cover will not lead to measurable effects. These treatmebecause rock outcrop is located within the treatment unit and the Proposed Athe areas adjacent to the rock outcrop. If the project is contracted as a Timbcontract will have to provide for this design measure. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 291 Comment 

one percent reduction in ground cover lead to measureable effects? Will special contract provisions need Regional Office approval for such restrictive requirements? 

3-6 The discussion on when snags may be 

felled on Pages 10 and 18 of Chapter 2 should reference California OSHA (Occupational Safety and Health Act) standards in addition to the Forest Service engineering handbook. (FSH 7709.59, Chapter 40). The California OSHA definition of a “Danger Tree” controls how the purchaser must operate on the sale area. The FSH may give additional internal guidance.

OSHA29 CFR 1910.266(c) and FSH 6709.11 both define a “danger tree” as 

presents a hazard to employees due to conditions such as, but not limited to, 

damage to the root system, trunk, stem or limbs, and the direction and lean o

3-7 All requirements that a specific action 

be supervised or approved by a person who does not have contract administrative authority should be qualified to permit waivers when little or no adverse impact will occur, or when the person with designated contract authority has the skills and knowledge to supervise compliance with that criteria. For instance the discussion of possible approval of a temporary crossing of a stream course on Page 127 of Chapter 3 states that any temporary crossing will “strictly follow design measures in Appendix 2 and will be supervised by the District Hydrologist”. No allowance 

If the district hydrologist is not available, then other qualified personnel will such a crossing (e.g., the High Sierra RD hydrologist, the forest hydrologist, biologist). Direct supervision by the district hydrologist during construction is not neces

crossing location must be approved and documented prior to construction of crossing and inspected after the temporary crossing has been removed to ens

caused to the channel in that location. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 292 Comment 

is made if the District Hydrologist is not available, or if the criteria for the crossing are such that personal supervision is not necessary. 

3-8 Certain streamside management zones 

(SMZs) require special inspections. Item c, on Page 23, Chapter 2, requires “In all cases, the SMZ will require inspection by the district hydrologist prior to releasing the contractor”. Is this a duplication of work by the Contract Administrator or will the district hydrologist have contract authority? Is disturbance of ground cover really such a technical issue that a qualified Contract Administrator can’t evaluate simple cases? 

Evaluation by the district hydrologist would be done in consultation with the who would retain contract authority. Due to the environmentally sensitive nature of SMZ’s, any disturbance in an evaluation by a hydrologist or fisheries biologist (2509.22 SNF Supplement N

3-9 A minor editorial comment is that two 

references to papers by Fettig are listed in the text of Chapter 3 on pages 131(Fettig 2007) and 141 (Fettig 2008). Fettig is not listed in the Literature Cited section of the DEIS. 

The FEIS was reviewed and all references have been included in the Literatuthe mentioned Fettig references. 

Environmental Protection Agency Region IX April 4, 2011 

4-1 Page 170 of the DEIS discusses the 

Clean Air Act (CAA) attainment status for the San Joaquin Valley and Mountain Counties air basins. Some updating/correction are needed in this 

 In this particular sentence, the FEIS has been correct to state: “non attainme“severe”. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 293 Comment 

section. The document states that the “San Joaquin Valley is classified by both the federal and state standards as severe non-attainment” this is a conflict with Table 37 which correctly identifies the San Joaquin Valley as Non-attainment Extreme for 1-hour Ozone. See Recommendations EPA comments 

4-2 The project requires further general 

conformity analysis. The general conformity rule has been revised. The new rule was published in the Federal Register on April 5, 2010 (Volume 75, Number 64) and went into effect on July 6, 2010. See recommendations EPA comments. 

After reviewing the new rule of the Federal Register (Volume 75, Number 64

6, 2010. Pages 176, 182 – 186 of the DEIS properly demonstrate and ensure 

will conform to the approved state Implementation Plans and not cause or coNAAQS in accordance to the general conformity rule. 

Sierra Forest Products – April 4, 2011 

5-1 Page 3 DEIS section titled “Purpose 

and Need for Action, within the 2nd

sentence, “of fire” should be reviewed and, if necessary, revisit as the language does not appear to make sense. 

The FEIS has been edited to further clarify. ......... 

5-2 Page 3 DEIS under the second 

sentence of the second paragraph under Existing Conditions, I believe the word “refuge” should actually be “refuse”. 

The FEIS has been edited to correctly reference “refuse” as the commenter su

5 - 3 Page 53 DEIS, under soil conditions, 

the first paragraph makes reference to 

The FEIS has been edited to correctly reference the “Fish Camp Project” as t
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 294 Comment 

Dinkey South Project. Should this be in the Fish Camp Project? 

5 - 4 

Regarding the content of the document, some flexibility under cultural resources site protection should be added to allow entry into specific sites with mechanical equipment as long the integrity of the site can be preserved. This is a common practice used on private lands within California and under the jurisdiction of the California State Department of Forestry and Fire Protection. 

Under the First Amended Regional Programmatic Agreement Among the U.SPacific Southwest Region, California State Historic Preservation Officer, an

Historic Preservation Regarding the Process for Compliance with Section 10Preservation Act for Undertakings on the National Forests of the Pacific Sou

mechanical equipment is allowed to operate inside cultural resource boundartraveling along FS system roads or the explicit removal of hazard trees that thsafety. 

5 - 5 

Under the silvicultural section within the Limited Operating Period (LOP) restrictions due to bark slippage, we do not think this is necessary as long as the operator exhibits care with equipment operations. We propose the ability to operate within these wild stands be flexible based upon the conduct of operations. 

The LOP mentioned is only planned to be imposed in well stocked stands hefir). The District Silviculturist would determine which stands would require 

ground conditions. It is anticipated that few wild stands would need this LO

component below 50 percent and therefore this LOP would have a minimal amost of the Project area will retain the opportunity to be treated during the LSee response to comment 3-4. 

5 - 6 

Under the remaining basal area on the wild sands, we believe the top of the 240 square feet of basal area for white fir is too high. We believe a lower cap on the residual basal area within the white fir and the wild stand can be met and still meet the goals of the agency. Perhaps 160 – 180 square feet of basal area would be more in 

Normal Yield Tables for 90-100 year old white fir aggregations on high sites 

would be expected to carry quite high basal areas per acre. Thinning to the s

160-180 square feet per acre would be too heavy for these stands It would alresidual canopy cover below that required by the 2004 SNFPA standards an

in fir aggregations will also contribute to recommended stand heterogeneity. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 295 Comment 

line with the goals of the fire protection of the resource. 

5 - 7 

We would propose that there not be any biomass product component to be removed from the Project boundary unless it has been designed as a stewardship project. The inclusion of biomass will make the project grossly uneconomical in a normal timber sale format. 

The biomass component of the proposed treatments would only be included available under the contract to accomplish it. Residual basal area calculationinches dbh and larger. At this time it is unlikely that the value of the materiaoffset biomass product removal costs. If excess trees less than 10 inches are 

then they will be treated during post sale treatments as funding becomes avaiwill be given to SPLATS first. 

5 - 8 

Regarding the need to upgrade the transportation system, we would suggest that due to the economic uncertainty of the project, that road reconstruction be kept to a minimum while still meeting the goals of the project. A suggestion on constraining the reconstruction costs would be to keep the placement of aggregate to a minimum. The cost is expensive due to the remote location of the project. 

There is 1⁄2 mile of rock aggregate placement scheduled for 5S22 along Long proximity of the road along the edge of Long Meadow, BMP’s and S&G’s drock along this segment. A visual inspection of the meadow indicates lots of the meadow. 5S22 is the only road in the Fish Camp Project which is scheduplacement. 

California Forestry Association April 4, 2011 

6-0 Concurs with Alternative 2 The comment has been reviewed and noted. 6-1 Summary, p. 1 – There is no scientific 

evidence to our knowledge that could lead to the statement that “... Pacific fiisher, California spotted owl and Northern goshawk, to name a few [and] are susceptible to possible loss of viability...) from a project action in the Fish Camp Project area. 

There are numerous on-going research projects such as the Sierra Nevada AdProject (SNAMP) whose goal is to ascertain and clarify some of the causes aviability for TES species in the Sierra Nevada. The Forest Service will continmanagement recommendations from the best available science and scientific 

remedies as further research is conducted. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 296 Comment 

6-2 Ch. 1, bottom of page 1 and top of 

page 2 – reword to say declining forest health in part due to unsustainable densities of trees that also have a negative effect of CA Spotted Owl, Marten, Fisher, and Goshawk habitat. 

The comment has been reviewed and noted 

6 - 3 Ch. 2, p. 16 – LOPs – shouldn’t there 

be language that states that LOP periods may be modified should surveys during implementation be done showing no denning activity occurring for a given species. 

The FEIS and BEBA were updated to per comment made. 

6 - 4 Ch. 2, p.17 – Pacific Fisher Den Site 

700 acre buffer – doesn’t this SNFPA standard and guide only apply to “occupied” dens? 

Appendix A of the SNFPA FSEIS p. 372 states the objective of Forest Carni“Protect all known fisher natal (birthing) and maternal (kit rearing) den sites, 

future” and therefore the 700 acre den site buffer requirement covers both ocden sites. 

6 - 5 Ch. 2, p.18 – Fisher Denning Habitat 

LOP – since Fishers are telemetered and monitored, shouldn’t this LOP be modified to say the time period will be based on fisher telemetry detection? 

One of the main objectives of the SNAMP project is to test the 2004 SNFPA Guideline #85 that states “Protect fisher den site buffers from disturbance wiperiod (LOP) from March 1 through June 30 for vegetation treatments as lon

suitable or until another Regionally-approved management strategy is implemwaived for individual projects of limited scope and duration, when a biologicthat such projects are unlikely to result in breeding disturbance considering th

timing, and specific location.” Additionally, as not all active Pacific fishers w

be collared and tracked through telemetry by the SNAMP study, it is importafisher LOPs standard and guideline . 

6 - 6 Ch. 2, p.18 – are there detected 

Marten in the Project area? If marten have only been detected above 6,000 foot elevation then why would a Marten LOP apply? 

Remote camera surveys conducted by the SNAMP fisher team have verified occupancy in the Fish Camp Project area, primarily during the winter and earFeb, Mar, Apr, Oct, Nov, Dec. A marten LOP from May 1 through July 31 w

treatment units at and above the 7000’ level within the Fish Camp Project to 

6 – 7 Ch. 2, p.18 – what science is being 

used to establish a guideline that there 

PSW-GTR-220, An Ecosystem Management Strategy for Sierran Mixed-Con2009) stresses the importance of forest heterogeneity. The authors examined 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 297 Comment 

will be a dense group retained every 2.5 to 3.5 acres? What size is a group? We know of no science that would support this density of “leave islands”. It’s hard to imagine how this guideline is consistent with the Purpose and Need fuel reduction objective. 

role of fire, forest resilience under changing climate conditions, and habitat r

wildlife. “Research in all these areas stresses the ecological importance of fo(North et al 2009). The design measure of large tree groups was incorporated project to maintain landscape heterogeneity throughout the treatment units w

stated purpose and need of fuels reduction and forest health thinning. (See Fi

6 – 8 Ch. 2, p. 18 – Unit 9 – has any 

telemetered Pacific Fisher used the 5 acre decadent stand that has been found? 

The SNAMP fisher team has tracked several telemetered fishers that have utparticular, female F34 has a den site located 400 meters southwest of this sta

6 – 9 Ch. 2, p.20 – In the Table, the 

heading should be changed from “Distance from Stream” to Distance from Perennial Stream”. 

The FEIS and BEBA were updated as stated in the comment. 

6 - 10 Ch. 2, p.23 – “light on the land” 

equipment should be defined (e.g. track mounted feller/bunchers...). Throughout the document, the term is used and refers to the Design Measures section for a description of what light on the land means; I can’t find any such description in that section. 

Since “Light on the Land” (LOL) equipment and techniques vary widely, speapplication of LOL will be done in consultation with the Contract AdministrLOL (e.g., SMZ’s). Thus specific equipment is not detailed in the DEIS. For 

see: http://www.nrs.fs.fed.us/fmg/nfmg/fm101/silv/p3_harvest.html

6 – 11 Ch. 3, top of page 48 – the italicized 

section should add to it “for finetextured soils only”. It needs to be absolutely clear that the porosity requirement only applies to fine textured soils. 

The soil effects analysis identifies treatment units where fine textured soils (Ulocated and where the moist soil design measure will mostly be applied. The question stands as written because soil compaction is a concern in coarse texhydrologic function and cumulative watershed effects concern. This is discusection prior to the italicized section. 

6 - 12 Ch 3, p.127 – additional discussion as 

to how it is practical to adverse skid 

As part of the analysis process, specialists must analyze all aspects of the effhave on their particular resource area. As such, this paragraph does just that. 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 298 Comment 

on a gradient that exceeds 25 percent. Does the current language mean that the unit is an average sideslope of 25 percent and a designated skid trail is needed to adverse skid the logs? Or does the language actually mean that there will have to be a designated skid trail that is greater than 25 percent? 

initial sale layout would have an area in T-28b that would require a skid on a would need to be mitigated, if used. It also states in the same paragraph that being considered based on this information, if this alternative was chosen. When writing about Unit T-28b, the area shown in the initial sale layout for spercent slope occurs, not the entire unit. 

NPS Partnership Program April 4, 2011 

7 - 1 Has no comment The comment has been reviewed and noted. 
 Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 299 Plot DatAppendix D – Data Tables Fish Camp Project _________ Fish Camp Plot Data Summary Table Existing and Proposed Action Conditions The Fish Camp plot data summary table displays plot data collected within the proposed treatment areas displayed on the F

Variable plots were taken using a 30 Basal Area Factor prism for wild stands and 20 Basal Area Factor prism for plantation

inches dbh were not sampled. Due to the wide variability of vegetation present within these proposed treatment areas and t

whole, plots representing similar stand conditions were grouped together by proposed treatment area. It would be misleadiaverage for the Project area. The column labeled “No. Plots” displays the number of plots within each grouping. Although within specific potential treatment areas, similar stand conditions may be present in other areas as well. Plot conditions var

basal area low of 90 ft2 to 450 ft2 per acre. Plot data recorded variations in trees 5 inches dbh and larger per acre from 15 some plots no small trees were captured in the sample while in others hundreds per acre were. Several plots represent “growith increased BA retention (20-30” dbh)” similar to those retained in the Cedar Valley and Sugar Pine Project areas. The term “light” which accompanies some of the proposed treatment areas refers to those areas/plots where the basal area p

light and would result in minimal removal of trees 10 inches dbh and larger. Although an area may be designated as “light

basal areas present, there may still be a need to treat heavily stocked pockets of smaller diameter trees (less than 5 inches d

have been sampled during the sampling process. One grouping of plantation aggregations of moderate stocking has been teThe majority of the Fish Camp Project area was heavily railroad logged between 1918 and 1924. Logs were processed at t

Pine. The 1944 aerial photos provide a graphic display of the extent of that activity. In some areas scattered older trees welogging. The vast majority of conifers present today were seedlings and saplings present in the understory that survived the 

Numerous pine plantations are present within the Project area. Over 950 acres were planted between 1959 and 1970 during 

to reforest previously railroad clearcut lands that had turned into large brushfields. More than 250 acres of additional pine created during the early 1980s. Wild stands proposed for treatment average 90 to 110 years of age. Overall average site qu

Dunning 1. Plot data indicates that wild stands proposed for thinning consist mostly of pine and mixed conifer cover. Stands heavy to in only a few small areas. Since these stands originated from advance reproduction present in the understory during the rai

they are heavy to shade tolerant, more fire prone, species of incense cedar and white fir. Crown closures present were take
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 300 Plot Data sheets with a reduction made for crown overlap. A small portion of the suppressed tree canopy cover was included as part crown closure. The mean diameter shown for these plots was taken from FIA data runs utilizing the plot data collected. The leave mean d

from the projected leave basal area and projected number of leave trees per acre. Since this data is a representative sample 

found in the stands, it is not intended to imply that any particular unit averages a particular diameter. As can be seen from the average diameter following treatment will be larger than before due to the removal of many small trees per acre across 

The plot data and summaries shown provide insight into the variability of the vegetation present within the proposed treatmcollection of the plot data, trees that might be selected for removal under the proposed thinning prescription for that species noted. From that data, potential leave and cut basal area, leave and cut tree sizes and numbers and existing and post harveswere determined. On a number of plots, for various reasons, leave basal area exceeds targets for that species composition. 

Legend for Sugar Pine Plot Data Summary Tables Location 

Number Corresponds to the Treatment Area Number on Project Map (MC) represents an area that is considered a Mixed Conifer dominated stand (plt) represents a pine plantation (WF) represents an area that is considered a White Fir dominated stand (PP) Pine dominated stands 

Species Composition 

PP – Ponderosa Pine SP – Sugar Pine WF – White Fir RF – Red Fir IC – Incense Cedar 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 301 Plot Data Crown Closure Given in percent (reduced for crown overlap). CWHR relationship for crown closure designation. 

P: 25-39% M: 40-59% D: 60% + 

Desired leave Basal Area for comparison 

Pine dominated stands = 150-180 ft2 per acre 

Mixed Conifer (MC) dominated stands = 210 ft2 per acre 

White Fir (WF) dominated stands = 240 ft2 per acre 

Pine plantations = 120-140 ft2 per acre

For Alternative 3 a surrogate of 10 inches dbh was used to display the changes that would occur based on only removing la

alternative. It is anticipated that some trees larger than 10 inches dbh that contribute to fuel ladders will be removed. Since intermediate or suppressed trees, overall crown closures following treatment will not change. 

Age Calculated from one sampled tree per plot. The majority of the conifers within the proposed treatment area are 90-110 yearMean Diameter (Dia) Calculated from trees within plots 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 302 Plot Data Fish Camp Plot Data Summary Existing and Proposed Action Conditions Alt. 2 

Location Species Composition Age Site Trees 5" dbh & larger Basal Area 5" & larger 

PP SP WF RF IC OK Total Cut 5-10 Cut 11-20 Cut 21-29 Lv 21-29 Tot Lv Total Cut 5-20 Cut 21-29 Lv 21-29 

 Plantations 

5,6,10&14 100 0 0 0 0 0 45 1 197 18 93 3 7 81 260 110 10 10 

10&28 light 86 0 7 0 7 0 45 1 82 0 15 0 14 67 140 20 0 40 

16,20&28 100 0 0 0 0 0 45 1 200 24 81 2 4 93 240 95 5 10 

28 mod 98 0 0 0 2 0 45 1 128 9 43 0 5 76 180 60 0 17 

19&22 97 1 0 0 2 0 50 1 219 13 120 3 11 83 286 137 9 31 

21 96 0 4 0 0 0 45 1 165 18 91 0 31 55 260 120 0 90 

Wild Stands 

7&8 (PP/MC) 12 48 27 0 12 0 104 1 263 38 29 2 31 116 248 45 7 143 

7&9 light(PP/MC) 11 28 50 0 11 0 104 1 62 0 0 0 40 62 180 0 0 160 

9(PP/MC)&13 11 44 28 0 17 0 95 1 105 0 22 10 24 73 270 30 30 90 

12 (PP/MC) 29 12 18 0 41 0 79 1 104 0 24 4 39 76 255 30 15 150 

17 &19 (MC) 3 9 43 0 46 0 103 1 249 73 52 13 30 111 350 80 50 170 

18 (MC) 2 13 40 0 46 0 97 1 171 58 39 24 39 50 360 67 90 173 

40&41 (WF) 8 0 92 0 0 0 83 1 167 34 65 7 54 61 360 105 30 210 

Note: The data displayed above represents the majority of the vegetation present within a particular treatment area. Due 

vegetation present, other aggregations are also present within treatment areas. Refer to the description and legend pages explanations. (A number of aggregations combine to form a stand.) 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 303 Plot Data Fish Camp Plot Data Summary Existing and Alternative 3 Conditions 

Location Species Composition Age Site Trees 5" dbh & larger Basal Area 5" & larger 

PP SP WF RF IC OK Total Cut 5-10 Cut 11-20 Cut 21-29 Lv 21-29 Tot Lv Total Cut 5-20 Cut 21-29 Lv 21-29 

Plantations 

5,6,10&14 100 0 0 0 0 0 45 1 197 18 93 0 10 84 260 110 0 20 

10&28 light 86 0 7 0 7 0 45 1 82 0 15 0 14 67 140 20 0 40 

16,20&28 100 0 0 0 0 0 45 1 200 24 81 0 6 95 240 95 0 15 

28 mod 98 0 0 0 2 0 45 1 128 9 43 0 5 76 180 60 0 17 

19&22 97 1 0 0 2 0 50 1 219 13 120 0 14 86 286 137 0 40 

21 96 0 4 0 0 0 45 1 165 18 91 0 31 55 260 120 0 90 

Wild Stands 

7&8 (PP/MC) 12 48 27 0 12 0 104 1 263 38 0 0 33 147 248 0 0 150 

7&9 light(PP/MC) 11 28 50 0 11 0 104 1 62 0 0 0 40 62 180 0 0 160 

9(PP/MC)&13 11 44 28 0 17 0 95 1 105 0 0 0 34 105 270 0 0 120 

12 (PP/MC) 29 12 18 0 41 0 79 1 104 0 0 0 43 104 255 0 0 165 

17 &19 (MC) 3 9 43 0 46 0 103 1 249 73 0 0 43 176 350 20 0 220 

18 (MC) 2 13 40 0 46 0 97 1 171 58 0 0 63 113 360 15 0 263 

40&41 (WF) 8 0 92 0 0 0 83 1 167 34 0 0 61 133 360 15 0 240 

 Note: The data displayed above represents the majority of the vegetation present within a particular treatment area. Due 

vegetation present, other aggregations are also present within treatment areas. Refer to the description and legend pages explanations. (A number of aggregations combine to form a stand.) 
 Final Environmental Impact Statement Fish Camp Project 

 Sierra National Forest 304 CWHR Appendix E - Sugar Pine California Wildlife Habitat Relationship MappinAcres CWHR Mapped Polygons vs. CWHR Table of Acres: Polygons on the CWHR map (Map 6) shows the gener

CWHR vegetation types found in the Project area based on Geographic Information System vegetation mappingdegree of variability in stand structure within the Project area and the existence of aggregations within stands, furof the CWHR vegetation typing was conducted through aerial photo interpretation and field verification by the DSilviculturist/Wildlife Biologist to develop CWHR Table of acres (See next pages-Table 52 & 53). This refinem

increases or decreases in total acreage amounts from what is displayed in the map polygons for particular CWHR Legend for CWHR Map and Table: All CWHR size classes and canopy closures are included unless otherwise specified. 

D.B.H. = Diameter at breast height (consider 4.5 feet from the ground). 

Tree size classes:
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 305 CWHR Da 1 Seedling (<1" dbh)  2 Sapling (1"-5.9" dbh) 

3 Pole (6"-10.9" dbh) 4 Small tree (11"-23.9" dbh) 5 Medium/Large tree (>24" dbh) 

6 Multi-layered Tree [In Ponderosa Pine and Sierra Mixed Conifer] 

(From Mayer and Laudenslayer, 1988) Canopy Closure classifications:

S = Sparse Cover (10-24% canopy closure) P = Open cover (25-39% canopy closure) M= Moderate cover (40-59% canopy closure) D = Dense cover (60-100% canopy closure)
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 306 CWHR DaCalifornia Wildlife Habitat Relationships (CWHR) Sugar Pine CWHR Data, Main Project area; Present Compared to Proposed Action (Alternative 2) 

CWHR 

Total Project 

Acres 

Treatment 

Analysis 

Area Acres 

 Acres Before Treatments Acres After Treatments 

Tractor Mastication 

1 Rx2 Tractor Mastication1 Rx2

MCH 6 1 0 0 0 0 0 0 MCP 38 24 0 19 0 0 19 0 MRI 1 0 0 0 0 0 0 0 MHW3M 5 1 0 0 0 0 0 0 MHW3D 27 15 0 0 0 0 0 0 MHW4M 81 15 3 7 0 3 7 0 MHW4D 26 17 1 14 0 1 14 0 MHC4P 23 23 13 5 0 13 5 0 MHC4M 62 50 15 26 0 15 26 2 MHC4D 605 325 115 66 31 115 66 29 MHC5D 21 4 0 4 0 0 4 0 PGS 3 3 0 3 0 0 3 0 PPN3P 6 6 1 5 0 1 5 0 PPN3M 16 14 5 8 1 42 8 1 PPN3D 186 186 167 19 0 130 19 0 PPN4S 8 6 0 0 0 0 0 0 PPN4P 56 40 40 0 0 40 0 0 PPN4M 312 261 136 93 0 136 93 1 PPN4D 1429 762 314 210 11 314 210 10 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 307 CWHR Da

CWHR 

Total Project 

Acres 

Treatment 

Analysis 

Area Acres 

 Acres Before Treatments Acres After Treatments 

Tractor Mastication 

1 Rx2 Tractor Mastication1 Rx2

PPN5M 88 80 22 56 0 22 56 0 PPN5D 17 7 5 0 0 5 0 0 SMC3S 5 5 0 0 5 0 0 5 SMC3M 16 16 9 2 0 12 2 0 SMC3D 35 21 7 14 0 4 14 0 SMC4S 4 4 0 0 4 0 0 4 SMC4P 54 36 8 21 7 8 21 7 SMC4M 149 120 12 55 50 12 55 55 SMC4D 1016 410 98 132 71 98 132 66 SMC5M 8 0 0 0 0 0 0 0 SMC5D 30 6 0 4 2 0 4 2 WFR4D 9 7 1 0 6 1 0 6 Total 4342 2465 972 763 188 972 763 188 

1Note: Acres Before and After Treatment for Mastication and Rx are gross acres 2Approximately only 65% of mastication acreage will be treated. Rx burning acreage % may be substantially less than show
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 308 CWHR Da Sugar Pine CWHR Data, Hydrology Study Area; Present Compared to Proposed Action (Alternative 2) 

CWHR 

Total Project 

Acres 

Treatment 

Analysis 

Area Acres 

 Acres Before Treatments Acres After Treatments 

Tractor Mastication Rx Tractor Mastication Rx 

MCP 27 2 0 0 2 0 0 2 BAR 16 2 0 0 0 0 0 0 JPN2S 34 32 0 32 0 0 32 0 JPN3P 24 24 6 16 0 6 16 0 JPN3M 45 45 39 6 0 44 6 0 JPN3D 5 5 5 0 0 0 0 0 SMC3S 7 3 2 0 0 2 0 0 SMC3P 33 2 0 0 0 0 0 0 SMC3M 8 6 3 0 0 3 0 0 SMC3D 7 0 0 0 0 0 0 0 SMC4S 14 14 1 1 4 1 1 4 SMC4P 23 12 8 1 1 8 1 1 SMC4M 78 65 36 6 8 36 6 8 SMC4D 26 11 7 0 0 7 0 0 SMC5S 4 4 4 0 0 4 0 0 SMC5M 65 65 48 3 3 48 3 3 SMC5D 109 63 57 0 0 57 0 0 RFR4S 5 5 5 0 0 5 0 0 RFR4P 33 33 10 23 0 10 23 0 RFR4M 22 16 9 2 5 9 2 5 
 Final Environmental Impact Statement Fish Camp Project 

Sierra National Forest 309 CWHR Da

CWHR 

Total Project 

Acres 

Treatment 

Analysis 

Area Acres 

 Acres Before Treatments Acres After Treatments 

Tractor Mastication Rx Tractor Mastication Rx 

RFR4D 9 3 0 3 0 0 3 0 RFR5M 23 20 14 1 0 14 1 0 RFR5D 51 19 13 0 0 13 0 0 WTM 14 0 0 0 0 0 0 0 Total 682 451 267 94 23 267 94 23