United States Department of Agriculture

1st 48 Roadside Fuelbreak 

Collaborative Project

Decision Notice & Finding of No Significant Impact

Forest 

Service

Pacific Southwest 

Region

Six Rivers 

National Forest

R5-MB-313

July 2018
Cover photo: Densely growing young trees along Forest Road 2S48. US Forest Service photo by Christy 

Prescott.

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Decision Notice & Finding of No Significant Impact – i

1st 48 Roadside Fuelbreak Collaborative Project

Decision Notice & Finding of No Significant Impact

Trinity County, California

Responsible Official: Elizabeth A. Berger, Acting Forest Supervisor

Six Rivers National Forest

1330 Bayshore Way

Eureka, CA 95501

(707) 441-3534

eaberger@fs.fed.us

For Information Contact: Dan Dill, District Ranger

Mad River Ranger District

741 State Highway 36

Bridgeville, CA 95526

(707) 574-6233

drdill@fs.fed.us
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iii – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Table of Contents

Decision Notice ............................................................................................................................................1

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

Purpose and Need .....................................................................................................................................1

Decision....................................................................................................................................................1

Permits, Licenses and Authorizations Needed to Implement the Decision ..........................................3

Mitigation and Monitoring....................................................................................................................3

Reasons for the Decision ..........................................................................................................................4

Relevant Issues .....................................................................................................................................6

Public Involvement...................................................................................................................................9

Collaboration ........................................................................................................................................9

Tribal Consultation .............................................................................................................................10

Scoping Period....................................................................................................................................10

Comment Period on the Draft EA.......................................................................................................11

Objection Period on the Draft Decision Notice, Finding of No Significant Impact, and Final EA....11

Alternative Considered in Detail, but not Selected.............................................................................12

Finding of No Significant Impact ............................................................................................................13

Context ...................................................................................................................................................13

Intensity ..................................................................................................................................................13

Implementation Date ..............................................................................................................................32

Figures

Figure 1. Densely growing trees alongside public roads will be thinned to breakup intermingled tree 

crown fuels, while maintaining sufficient tree shade to curb brush response.......................................5

Figure 2. Without frequent low/moderate intensity wildfire, black oaks die off once conifers encroach 

and shade crowns over an extended period...........................................................................................6

Figure 3. The US Forest Service works with the Trinity County Collaborative Group to discuss 

concepts and project design in the woods...........................................................................................10
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Decision Notice

Decision Notice & Finding of No Significant Impact – 1

Decision Notice

Introduction

In 2013, the Trinity County Collaborative Group (TCCG)1 approached Six Rivers National Forest (SRNF or 

forest) leadership seeking to collaborate on a “proof-of-concept” proposal for establishing roadside-shaded 

fuelbreaks on National Forest System (NFS) lands to facilitate safe evacuation, firefighter access and 

landscape-scale fire management. This Decision Notice and Finding of No Significant Impact (DN and 

FONSI) documents my selection to implement Alternative 2, representing the TCCG’s proposal, as 

disclosed in the 1st 48 Roadside Fuelbreak Collaborative Project (1st 48 Project) Final Environmental 

Assessment (final EA). The 1st 48 Project final EA discloses the environmental effects of Alternative 2—

developed in detail to meet the Purpose and Need and respond to public issues—and Alternative 1 (No 

Action), as a comparison of what could happen without management (final EA pp. 17-44).

The 1st 48 Project was designed in compliance with 1995 Six Rivers Land and Resources 

Management Plan (LRMP or forest plan) standards and guidelines (S&Gs); the 1999 Six Rivers National 

Forest Late Successional Reserve Assessment (LSRA), incorporating the 1999 Shasta-Trinity National 

Forest’s LSRA; the 2011 Recovery Plan for the Northern Spotted Owl (Recovery Plan); the 2012 

Northern Spotted Owl Critical Habitat Rule (Critical Habitat Rule); the 1994 Aquatic Conservation 

Strategy (ACS); and other federal, state, and local laws and requirements (final EA pp. 7-13).

The project area lies within the Mad River Ranger District (RD) of the SRNF, in Trinity County, 

California, in T2S, R8E, Sec. 6-8, 18-21, and 28-33; and T2S, R7E, Sec. 11-13, Humboldt Baseline and 

Meridian. The 1st 48 Project, near the community of Ruth, ranges from 2,700 feet in elevation to 5,800 

feet at the top of South Fork Mountain (final EA p. 4).

Purpose and Need

The Purpose and Need for the 1st 48 Project is to provide rural communities and residents safer travel zones 

during wildfire evacuations; allow greater, faster wildland firefighter response and suppression; and reduce 

the risk of roadside fire starts traveling into high-value landscape-level forest resources (final EA pp. 5-6).

Decision

Based on a review of the analysis disclosed in the April 2018 1st 48 Project final EA, the project record, 

best available science and consideration of public comments, I have decided to select Alternative 2

(Selected Alternative), as described in Chapter 2 of the final EA (pp. 17-42). This decision authorizes

decommissioning a segment of Forest Service Road (FSR) 2S54, an identified legacy sediment source

 1 Trinity County Collaborative Group (TCCG): The collaborative is composed of 55 diverse stakeholders including landowners, 

business owners, local and regional conservation groups, timber industry representatives, fire safe councils, local nongovernmental organizations, federal and county government agencies.
Decision Notice

2 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

impacting water quality, and thinning up to 821 acres of trees to separate intertwined ladder and crown 

fuels, while maintaining sufficient tree shade to curb brush response on NFS lands within the wildlandurban interface (WUI2

; final EA pp. 2, 18).

All treatments will occur at varying widths on FSRs open to the public, from a minimum of 25 feet on 

one side, up to 275 on the other, not exceeding a total 300-foot width. Fuelbreaks will be established 

along either side of FSRs 01S23 (Route 23), 02S02, 2S47, 2S48, 2S49, 2S50, 2S51, 2S52 and 2S53, and 

one (1) motorized trail (Jeep Trail 8E20). The 1st 48 Project will thin trees (final EA pp. 28-29 (Table 4)) 

using cable- and ground-based mechanical methods (e.g., tractor and masticator). Hazardous fuels (i.e., 

trees up to 8-inch diameter at breast height (dbh)) will be hand-cut with chainsaws, chipped, pruned and 

brush masticated, followed by machine (e.g., dozer or small excavator equipped with a brush rake) and 

hand-piling debris, manually lopping and scattering surface and small ladder fuels, and prescribed jackpot 

burning and underburning in oak woodlands to stimulate oak regeneration.

In addition, trees in plantations and oak woodlands that border roadways will be thinned beyond the 

275-foot-maximum to improve conditions throughout the entire stand. Along the outer perimeter of 

plantations, hazardous fuels reduction (HFR) treatments will be implemented to establish a 150-foot flank 

or buffer intersecting with the roadway (final EA p. 18).

The 1st 48 Project will alter live and dead surface, ladder and crown fuels by implementing 

mechanical treatments (i.e., ground and cable yarding, mastication, grapple piles using dozers or small 

excavators (equipped with a brush rake)), followed by manual (hand) cutting using chainsaws and piling, 

pruning, and/or lopping and scattering woody debris, periodic prescribed jackpot burning, and 

underburning in oak woodlands three (3) to five (5) years apart. Fuelbreak maintenance, primarily 

through mastication, will occur to cut back vegetative sprouting, accumulated forest litter, and natural 

regeneration (i.e., tree seedlings) for up to 15 years.

Specifically, this decision authorizes:

o 461 acres of mechanical thinning and mechanical, manual and jackpot burning HFR

treatments, where overstory tree canopy exceeds 60 percent in mixed conifer stands.

o 108 acres of mechanical, manual and jackpot burning HFR, where overstory tree canopy is 

below 60 percent, in mixed conifer stands managed historically under even-age forestry 

practices (i.e., plantations, shelterwood and seed tree prescriptions).

o 37 acres of mechanical thinning, and manual and phased underburning HFR in oak 

woodlands. Hand-constructed control lines (typically 18- to 20-inches wide), which include

scraping duff and debris to expose bare mineral soil, will be used to contain prescribed 

underburning to the oak woodland units.

o 215 acres of post-fire mechanical, manual and jackpot burning HFR, where there is little or 

no live-tree overstory.

 2 Wildland Urban Interface (WUI): The wildland-urban interface (WUI) zone is an area where human habitation is mixed with 

areas of flammable wildland vegetation. It extends out from the edge of developed private land into federal, private, and state 

jurisdictions. The WUI boundaries generally extend approximately 11⁄4 miles out from the defense zone boundary; however, 

actual extents of threat zones are based on fire history, local fuel conditions, weather, topography, and natural barriers to fire.
Decision Notice

Decision Notice & Finding of No Significant Impact – 3

o 784 acres of mechanical, manual, and jackpot fuelbreak maintenance.

o Decommissioning FSR 2S54 (classified as a Maintenance Level (ML) 2 road, which is 

presently undriveable. This includes removing drainage structures, restoring natural drainage 

patterns and placement of an earthen mound barrier at the entrance to prevent motorized use 

and the promotion of passive restoration of the travelway, and managing in a maintenance-free 

condition for the long term.

o Utilizing 33 existing landings to expedite operations and construct up to 20 new landings (up 

to 0.25 acres each), allowing an expansion of existing natural openings that exhibit some 

previous ground disturbance within units or existing roadside turnouts.

o Using up to 13 existing temporary road spurs totaling 1.06 miles. These existing temporary 

road spurs will be barricaded after operations, once thinning and HFR treatment operations 

are complete, to prevent motorized-vehicle access. The post-operations treatments will 

involve activities to achieve hydrologically maintenance-free conditions.

Permits, Licenses and Authorizations Needed to Implement the Decision

In accordance with 40 CFR 1502.25 (b), the EA lists all federal permits, licenses, or other entitlements that 

must be obtained in implementing the action alternatives. A waiver application will be filed with the North 

Coast Regional Water Quality Control Board (NCRWQCB) under Order No. R1-2015-0021, once this

decision document is signed. A burn permit from the North Coast Unified Air Quality Management District 

(NCUAQMD) will be acquired before initiating any prescribed burn (final EA p. 13).

Mitigation and Monitoring

There may be short-term disturbances to the human environment from machinery, field crews and an

associated increase in traffic, as well as noise and smoke when prescribed burning operations are underway. 

This decision requires application of project design features (PDFs) and mitigation measures to reduce,

minimize, or eliminate impacts to various natural and cultural resources, and ensure project compliance with 

resource protection S&GS of the SRNF LRMP; the Record of Decision for amendments to the survey and 

manage, protection buffer, and other mitigation measure standards and guidelines in Forest Service and 

Bureau of Land Management planning documents within the range of the northern spotted owl (USFS et al. 

2001), based on the district court’s remedy order issued on February 18, 2014 (Conservation Northwest v. 

Bonnie, W.WA No. C08-1067-JCC); US Forest Service Region 5 Soil Management Handbook (FSH 

2509.18); Six Rivers National Forest Best Management Practices (BMP) for Invasive Plant Species and 

Aquatic Organisms (2014); and national, regional, and state water quality BMPs.

My decision also requires monitoring as described in the final EA (Chapter 2 pp. 34-42). Monitoring is 

fundamental to inform decision-making that can influence future conditions. The objective of the 1st 48

Project’s monitoring plan is to 1) gather new information to determine the effectiveness of management 

decisions, 2) establish a baseline for various measures prior to implementation and mitigations, and 3) verify 
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4 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

the accuracy of analysis assumptions and conclusions. Project activities will be monitored during and after 

project implementation to ensure that mitigation measures are implemented effectively.

Monitoring is also required to evaluate the effectiveness of planned activities, including standard 

practices and mitigation measures, to ensure desired project outcomes (final EA pp. 42-43). Lessons 

learned from monitoring and evaluation will be incorporated into future project planning efforts. A full 

spectrum of techniques and methods may be used, including:

o Formal joint management and collaborative field reviews

o Site-specific observations by on-site resource specialists

o Field assistance trips by other technical specialists

o On-going accomplishment reporting processes

o Discussions with other agencies and various public users, and

o Interdisciplinary team reviews of monitoring results.

Implementation and effectiveness monitoring for cumulative watershed effects will utilize the BMP

Effectiveness Evaluation Process. The objective is for 100 percent BMP implementation. Results for any 

BMP below 85 percent trigger a review of the activity area before implementation of further projects. 

Implementation monitoring is achieved by selecting a representative number of treatment units each year 

from a sample pool of completed stands or project areas. A complete list of BMPs is included in Appendix 

C of the final EA.

Wildlife monitoring via northern spotted owl (NSO) surveys will be in compliance with the most 

current, US Fish and Wildlife Service- (USFWS) approved protocol throughout the project area. Updated 

surveys will be maintained throughout the life of the project (final EA p. 41).

The successful control of yellow star thistle will necessitate periodic monitoring and evaluation of 

treatment efficacy. If plants are present after the initial treatment, individuals will be manually pulled in 

late spring (before fruiting/seeding), ensuring removal of the roots as much as possible, and then 

handpiled and burned. This decision will implement monitoring each year to determine if retreatments are

necessary to eradicate populations (final EA pp. 38-39).

Reasons for the Decision

In reaching this decision, I considered the Purpose and Need for action, tribal and interagency 

consultation, public comments, resource reports, and the potential effects and outcomes of the No Action 

Alternative (Alternative 1) compared to the 1st 48 Project (Alternative 2) (final EA pp. 17-18 and Chapter 

3). My highest priority is to serve local residents living in and around the town of Ruth3 by establishing 

safe evacuation routes for residents during wildfires. The decision to implement Alternative 2 signifies a 

step toward protecting dispersed private properties, residents and the at-risk community of Ruth. It also 

 3 The Town of Ruth, population 195 (US Census 2010) is located in southern Trinity County. The state of California in 2001 in 

accordance with the 2001 Federal Register (Fed. Reg. 66:3) designation of “communities at risk” adjacent to federal lands that are 

at high-risk from wildfire, identified Ruth as a community at risk. In 2010, the Trinity County Community Wildfire Protection Plan 

(CWPP) was updated. Federal, state and local organizations convened information to refine the spatial designation of the WUI.
Decision Notice

Decision Notice & Finding of No Significant Impact – 5

provides an opportunity to demonstrate the TCCG’s “proof-of-concept” alignment with the National 

Cohesive Wildland Fire Management Strategy (Cohesive Strategy) and the SRNF LRMP, as disclosed in 

the 1st 48 Project final EA.

Alternative 2 will capitalize on the benefits that roads and trails provide in rapidly deploying

firefighters, making the most of suppression tactics. By establishing crown separation in the forest canopy 

and lowering fuel concentrations, firefighters will have defensible space to contain flame fronts.

My decision addresses high tree densities and associated intertwined tree crowns alongside forest roads 

as depicted in Figure 1, that promote active crown fires, particularly during wind-driven events. Thinning

will increase the spacing between individual trees and their crowns, while retaining shade to minimize 

growth of understory brush species. Retaining adequate tree shade will minimize the loss of surface 

fuel/soil moisture through solar heating, which can dry out down woody material and logs increasing 

flammability and residence time (final EA pp. 56-57).

My review of historic records indicates there have been several wildfires in and around the 1st 48

Project area. In 2011, the Ruth Fire burned 1,460 acres of NFS lands in the Upper Mad River Watershed. 

Eighty-eight (88) acres of the project are within the Ruth Fire burned area. Fire effects were variable 

according to onsite conditions at the time of the fire (final EA p. 7).

With the onset of effective fire suppression in the project area between 1930 and 1945, fire frequency 

has declined and changes to the vegetative structure have led to a denser, more homogeneous forest 

(Sugihara et al. 2006). The dramatic reduction in acres burned by wildfire over the last 80 years appears 

to have resulted in unnatural fuel profiles that are more continuous, both horizontally and vertically. 

Given this increased conifer density, future wildfires could become larger and more destructive than in the 

past. Early- and mid-seral stages of Douglas-fir are more susceptible to wildfire mortality than older, lateFigure 1. Densely growing trees alongside public roads will be thinned to breakup 

intermingled tree crown fuels, while maintaining sufficient tree shade to curb brush 

response.
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6 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

seral stands, as low-lying limbs, thin bark and intertwined crowns result in torching, high heat intensity, 

and crowns fully engulfed in flames (final EA pp. 49-55).

In the prolonged absence of fire, aggravated by other disturbance factors, these fire-adapted forests 

and grasslands have undergone dramatic changes in species composition and structure. One of the most 

threatened tree species is California black oak (Quercus Kelloggii). The presence of black oak, already 

deficit across the landscape (final EA p. 50), is vulnerable to mortality once overtopped and crowded out 

by Douglas-fir as shown in Figure 2. The decision will implement thinning conifers around these remnant 

oak trees providing more sunlight to promote the growth of fuller crowns, and increasing their health and 

resistance to disturbance. With regeneration depressed by thick shrubs, and layers of litter and duff, which 

act as barriers to seed germination, this decision includes repeated underburning, at intervals that

stimulate sprouting and tree survival.

Relevant Issues

The following relevant issues associated with implementing the 1st 48 Project were considered with the 

greatest good in mind.

Wildlife Habitat Quality

The reduction of forest ladder and select crown fuels within the project area may lower habitat quality for the 

NSO (Strix occidentalis caurina). The predicted changes in nesting, roosting, foraging and dispersal habitat 

within NSO core and home ranges under Alternative 2 were analyzed and compared to the suggested levels 

of habitat as described by the USFWS (USDI Fish and Wildlife Service 2009), published research, and 

professional judgement. Based on a review of the analysis, Alternative 2 fulfills the goals and objectives of 

Figure 2. Without frequent low/moderate intensity wildfire, black oaks die off once 

conifers encroach and shade crowns over an extended period.
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Decision Notice & Finding of No Significant Impact – 7

the USFWS’s Recovery Plan (final EA pp. 61-85). Due to its frequent fire return intervals and existing 

vegetation conditions, it makes sense for resource agencies to manage vegetative fuels in NSO critical habitat 

to ameliorate current threats of on-going habitat loss from uncharacteristic fires and further vegetation change 

largely related to past fire exclusion (USDI Fish and Wildlife Service 2012; final EA pp. 59-60).

The Record of Decision on Management of Habitat for Late-Successional and Old-growth Forest Related 

Species within the Range of the Northern Spotted Owl (1994) established a network of late-successional 

reserves (LSRs), including 100-acre core areas around NSO activity centers (ACs) known to exist in 1994, 

and larger, landscape-level-managed late-successional areas. The network of reserves is intended to provide 

old-growth forest habitat, provide for populations of species associated with late-successional forests, and 

help ensure that late-successional species diversity will be conserved.

In 1999, the Six Rivers and Shasta-Trinity national forests completed LSRAs to inform management 

decisions within LSRs and ensure achievement of forest plan goals. The majority of the 80,451-acre South 

Fork LSR is on the Shasta Trinity National Forest (STNF), with only 1,057 acres on the SRNF. The 1st 48 

Project will manage 73 acres, including 49 acres of thinning, within the South Fork LSR, as it was 

identified as a landscape where existing features and conditions give firefighters a good chance of keeping 

wildfire from entering, or conversely, from exiting the area (final EA pp. 12-13).

In 2009, the STNF received a letter of clarification from the US Forest Service Pacific Southwest 

Regional Ecosystem Office (REO) related to hazard reduction thinning activities proposed in LSRs to 

reduce the risk of large-scale disturbance. The REO reviewed the STNF LRSA and concluded that fuel 

treatments in LSRs that thin suppressed, intermediate and some co-dominant trees are consistent with 

Northwest Forest Plan (NWFP) S&Gs (USDA REO letter, October 18, 2009). This decision is consistent 

with LSRA and LRMP direction, as it will implement fuels reduction treatments aimed at reducing risk 

(i.e., potential loss due to wildfire) in younger white fir stands adjacent to FSR 2S23, and along the 

ridgetop within the South Fork LSR (final EA pp. 55-58).

The decision to implement the 1st 48 Project will expedite conservation and restoration of NSO sites and 

habitats using fuels techniques that enhance structural complexity and biological diversity, as recommended 

by the Recovery Plan and Critical Habitat Rule. Alternative 2 will apply thinning to accelerate diameter and 

height growth, while retaining a minimum 60 percent forest canopy closure in all NSO suitable habitat. No 

pre-dominant or dominant trees will be cut; large snags and downed logs will be maintained (final EA p. 61).

The wildlife analysis indicates that four (4) of the ACs in the 1st 48 Project area overlap the 2013 

Kelsey Peak Timber Sale and Fuelbreak Project (Kelsey Peak Project) planning area. The cumulative 

effects analysis considered habitat effects of these four (4) NSO ACs within their entire home ranges. The 

maximum acres treated within an AC for these two (2) projects combined is 19 percent of nesting/roosting 

habitat and 36 percent of foraging habitat. Current habitat function has been or will be maintained in all 

treated areas. The wildlife analysis indicates approximately 98 percent of the available nesting/roosting 

habitat and 90 percent foraging habitat within the Upper Mad River Watershed will be left untreated and 

available as alternative habitat for NSOs.

All habitat within the action areas will remain suitable immediately post project, as treatments will 

maintain and restore habitat function in low- to moderate-quality habitat in all units. Post-treatment 
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8 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

monitoring was conducted by the US Forest Service (Forest Service or USFS) in coordination with the 

USFWS on the Kelsey Peak Project, as well as on other forest projects (final EA pp. 91-94). These 

previously implemented projects applied treatments similar to the 1st 48 Project. Monitoring indicates 

canopy closure requirements were exceeded for all units, and pre-dominant trees, snags, and downed logs

were retained, as specified in the federal decisions (final EA p. 93). Therefore, in light of the cumulative 

effects, the 1st 48 Project will have beneficial effects, establishing healthy habitat conditions and creating 

additional alternative habitats for owls to use across the landscape.

Soil Erosion

Tree removal and associated operations (i.e., skidding, temporary road use and expansion of existing 

landings), coupled with phased initial and maintenance prescribed burning, may increase soil erosion and 

elevate sedimentation/siltation and turbidity contributing to cumulative effects for the Ruth Lake-Mad 

River (180101020203) and Barry Creek-Mad River (180101020202) watersheds (EPA-listed: Clean 

Water Act §303(d) impaired 1992; final EA pp. 95, 101-102). However, events such as the 2011 Ruth 

Fire, which consumed forest vegetation leaving soils barren and vulnerable to erosion and displacement, 

result in substantial disruptions to watershed conditions and hydrological function.

The 1st 48 Project will not alter thermal regulation, nutrient filtering, rates of surface or bank erosion, 

channel migration, or large woody debris recruitment in riparian reserves, as equipment exclusion buffers 

along streams, low-intensity thinning and HFR are limited to 130 acres, or 16 percent of the project area.

To retain adequate surface duff and litter cover for site productivity and minimize soil erosion, jackpot 

burning and low- to moderate-intensity underburning is authorized (final EA pp 40-41, 102).

A review of the soils analysis, based on the Region 5 Soil Erosion Hazard Rating (EHR) System 

(USDA Forest Service 1990) that rates the risk of soil erosion for all soil types in the project area, 

indicates none of the soils in the project area has a high EHR with 50 to 70 percent soil cover on average 

slope gradients. Most of the soils do not even have a high EHR when bare, due to the surface loams being 

very porous (>2 in/hr. infiltration rate), which is typical of loamy and most fine-loamy forest soils.

The 1st 48 Project will maintain at least 50 percent duff and fine litter cover for soil productivity, in 

compliance with SRNF LRMP S&Gs, with perhaps more for erosion prevention as determined for the 

project. For instance, areas of bare soil are expected shortly after ground-based operations are complete

(typically less than 10 percent of the unit area on existing temporary roads and landings). This decision 

requires monitoring for vegetation recovery and mulching and/or seeding if any evidence of erosion is 

discovered in area rendered bare (i.e., greater than one-fifth of an acre).

My decision takes into consideration the intensity of the project’s tree thinning treatments (i.e., a 

minimum 60% canopy closure), which are drastically less in intensity, compared to prior clearcut practices. 

The 1st 48 Project will retain a healthy, living forest canopy and associated litterfall for self-maintaining 

favorable nutrient cycling, particularly on more developed soils (e.g., Ultisols and Alfisols). The portion of 

the Ruth Fire burn scar area that burned at high fire severity lacks a productive overstory, so surface 

organic matter levels are still recovering, particularly the duff layer thickness. Shrub regrowth has been 

aggressive, so current cover levels are adequate in extent (>50%; final EA pp. 113-122).
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Decision Notice & Finding of No Significant Impact – 9

The 1st 48 Project will act to lower erosion rates associated with FSR 2S54, a 1.95-miles-long ML 2 

road, by decommissioning it from its intersection with FSR 2S02. Activities will include barricading the 

entrance to prevent motorized travel promoting passive restoration of the travelway and removing

drainage structures to re-establish natural drainage patterns for long-term maintenance-free conditions. 

The combination of barricading and water dispersion treatments are designed to stop water from 

concentrating on the travelway surface, reduce the potential for stream diversions (i.e., prevent water from 

flowing down the road or trail) and erosion and associated off-site sediment delivery to water resources 

(final EA pp. 31-32, 100). Alternative 2 will contribute to the protection of soil resources, as roadside 

fuelbreak treatments are designed to aid wildfire containment and control decreasing the probability for 

large-scale, high-intensity fire behavior, protecting soils, down woody debris and nutrient cycling in the 

long term (final EA p. 120).

Best Available Science

My conclusions are based on a review of the project record, which demonstrates a thorough review of 

relevant best available science was considered. The resource sections in Chapter 3 of the final EA disclose

the effects analysis methodologies and reference scientific sources, which informed the analysis as well as

the assumptions underpinning the basis for the findings.

Public Involvement

Collaboration

Since 2012, the TCCG, encouraged by then-USDA Secretary Tom Vilsack, helped develop the strategy

for the landscape-scale (742,000 acres) Trinity Community Protection and Landscape Restoration Project, 

spanning the Shasta-Trinity and Six Rivers national forests, and interspersed with private timberlands,

ranches, and six (6) isolated rural communities. This project set the stage for using prescribed fire as the 

primary tool to help protect communities, watersheds and habitats, fulfilling the goals of the Cohesive

Strategy, the USFS Region 5 Ecological Restoration Intent, the Trinity County Community Wildfire

Protection Plan (CWPP), and the all-lands principles represented by the Joint Chiefs’ Landscape 

Restoration Partnership (Joint Chiefs).

In 2013, the TCCG approached SRNF leadership, submitting a proposal as a “proof of concept” to 

begin to incrementally achieve the goals of the larger landscape TCCG project. In 2016, the Forest Service 

and TCCG met in the field to discuss the bounds of the project area and potential treatment methodology 

within mutual zones of agreement, as seen in Figure 3. The TCCG participated in interdisciplinary team 

(IDT) meetings and discussions beginning in 2017. On-going informal communications (i.e., emails and 

telephone calls) and small group meetings involved interactive conversations about refining the proposal 

and progress updates (final EA p. 13).
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10 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Tribal Consultation

On April 11, 2017, the forest initiated formal tribal consultation pursuant to §106 of the National Historic 

Preservation Act (NHPA; 36 CFR 800.2(c)(2)) with the following federally recognized tribes: Bear River 

Band of Rohnerville Rancheria, Round Valley Indian Tribes: A Sovereign Nation of Confederated Tribes, and 

Wiyot Tribe. At the same time, the forest officially conferred with the following non-federally recognized 

tribes: Lassic Band of Wylacki-Wintoon Family Group Inc. and Eel River Nation of Sovereign Wailaki.

The forest understands that the local tribes continue to play an important role in this and other 

undertakings on the forest. Tribal knowledge of the area and potential concerns about natural and cultural 

resources management within their ancestral territory is an important part of the project design and analysis. 

One submitted comment stated, “We hope that the proposed 1st 48 Project and the joint participants be 

allocated the revenue and resources to achieve the goals of this project, a healthy, clean area of forest, 

managed to prevent high severity fires, waterways that are healthy and able to sustain our local wildlife”

(final EA pp. 13-14).

Scoping Period

On April 1, 2017, the project was listed in the SRNF Schedule of Proposed Actions (SOPA). The Forest 

Service initiated the 30-day scoping period on April 14, 2017, with the distribution of a scoping letter and 

Proposed Action map to 120 recipients. The scoping letter was sent to Humboldt Bay Municipal Watershed 

District, the USFWS, US Congressional Representative Jared Huffman, County Board of Supervisors for 

Humboldt and Trinity counties, American Forest Resource Council, Environmental Protection Information 

Center (EPIC), Conservation Congress and Journey’s End, to name a few. The scoping period ended on 

May 5, 2017.

Figure 3. The US Forest Service works with the Trinity County Collaborative Group 

to discuss concepts and project design in the woods.
Decision Notice

Decision Notice & Finding of No Significant Impact – 11

On April 25, 2017, the Forest Service and TCCG hosted a public meeting at the Ruth Lake 

Community Center in the Town of Mad River, to invite the public to participate in the development of the 

project, solicit public comment, and present the project area and proposed treatment methods. Ten (10) 

community members attended the public meeting (final EA pp. 14-15). The public interests and 

comments submitted during the scoping period influenced the design of the Proposed Action and the 

mitigation measures incorporated as disclosed in Appendix A of the final EA.

Comment Period on the Draft EA

On February 22, 2018, the Forest Service initiated the 30-day comment period on the draft EA, with the 

publication of the opportunity to comment in the Eureka Times-Standard, as well as on the SRNF’s website 

and postings on social media. The Forest Service received written comments from one (1) agency and three 

(3) organizations during the comment period. A compilation of public comments received during the draft 

EA comment period and the response to these comments is located in Appendix A of the final EA.

Objection Period on the Draft Decision Notice, Finding of No Significant 

Impact, and Final EA

The Pre-decisional Administrative Review (Objection Process) pursuant to 36 CFR 218 provides the sole 

means of administrative review on the 1st 48 Project. On April 13, 2018, the legal notice commencing an 

Opportunity to Object was published in the newspaper of record (Eureka Times-Standard), initiating the 

45-day objection filing period pursuant to 36 CFR 218 Subparts A and B. Following publication of the 

legal notice, an electronic copy was posted on the SRNF website within four (4) calendar days.

On May 29, 2018, an objection letter was received from Denise Boggs, on behalf of Conservation 

Congress. On June 20, 2018, forest staff sent an email to Conservation Congress to convene a meeting to 

discuss her objection issues on the 1st 48 Project. Ms. Boggs participated in the resolution meeting with 

the SRNF and the Regional Office on July 3, 2018. During the meeting, concerns were raised by the 

objector about NSO, in particular: Critical Habitat, activity centers, completion of required surveys, and 

the diameter of trees to be removed would undermine progress toward NSO recovery. The objector 

expressed a difference of opinion regarding the need for the proposed fuelbreak network to prevent and 

manage wildfires and questioned some of the scientific resources the forest consulted. Although the 

Forest Service and objector were unable to come to a consensus regarding a resolution to objection issues 

or proposed remedies brought forward, clarification was provided that two (2) years of NSO surveys will 

be completed prior to implementation per 2012 USFWS protocol. These surveys will continue for the life 

of the project.

On July 9, 2018, the Reviewing Officer provided a written response to issues raised in the objection 

letter, as required by 36 CFR 218.32(b), informed by a review of the EA, draft DN, and project record by 

a team of staff from forests throughout the region. The Reviewing Officer found that the Forest 

Supervisor’s rationale for this project is clear, and the reasons for the project are logical and responsive to 
Decision Notice

12 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

direction contained in the SRNF LRMP, and concluded the project record adequately addresses the issues 

in compliance with law, regulation and policy. The Reviewing Officer determined that the Forest 

Supervisor, as the Responsible Official, could proceed with issuance of the DN/FONSI for this project,

once the suggestions identified above have been considered.

On July 16, 2018, a corrected written response letter was provided Conservation Congress to address a 

minor procedural correction to the July 9, 2018 written response. The July 16, 2018 response affirms the 

Forest Supervisor may proceed with issuance of the DN/FONSI. There will be no further review of this 

response by any other Forest Service or US Department of Agriculture (USDA) official as per 36 CFR 

218.11(b)(2).

Alternative Considered in Detail, but not Selected

In addition to the Selected Alternative (Alternative 2), the No Action Alternative (Alternative 1) was 

considered to provide a baseline for comparison with Alternative 2 (final EA pp. 17-18). The environmental 

analysis and disclosure of the No Action Alternative provides an indication of what could happen if the 

Selected Alternative is not implemented. Although under the No Action Alternative, unavoidable short-term 

impacts from implementing thinning and HFR will not occur, the lack of action could result in discrete, 

indirect consequences, as described in Chapter 3 of the final EA.

The No Action Alternative does not respond to the Purpose and Need to implement the SRNF LRMP 

or the “proof-of-concept” proposal submitted by the TCCG to establish strategically placed, roadside

fuelbreaks or reduce potential flame lengths adjacent to private lands and around the community of Ruth,

at risk of wildfire. Without active forest management, the vigor and growth rates of trees growing in 

overstocked forest stands and oak woodlands will continue to stagnate or decline, as oaks become 

overtopped by conifers and water availability becomes more limited from inter-tree competition. The No 

Action Alternative would tend to maintain forest conditions prone to high-intensity fire behavior,

challenging for fire suppression crews to manage safely (final EA pp. 49-56). In addition, point source 

erosion on FSR 2S54 would continue, as this segment would not be decommissioned (final EA p. 95). For 

these reasons, the No Action Alternative was not selected.
Finding of No Significant Impact

Decision Notice & Finding of No Significant Impact – 13

Finding of No Significant Impact

Based on the site-specific analysis summarized in the 1st 48 Roadside Fuelbreak Collaborative 

Project Final Environmental Assessment (1st 48 Project final EA) and the associated project file, I 

have determined that the Selected Alternative (Alternative 2) is not a major federal action and 

will not significantly affect the quality of the human environment; therefore, an environmental 

impact statement (EIS) is not required. Under the 1978 regulations written by the Council on 

Environmental Quality (CEQ; 40 CFR 1500-1508), significance is evaluated for both context and 

intensity. The following summarizes the evaluation of the 1st 48 Project’s context and intensity.

Context

The significance of an action must be analyzed in several contexts, such as society as a whole, the 

affected region and interests, and locality. Significance varies with the setting. In the case of a 

site-specific action, significance usually depends upon the effects in the locale, rather than in the 

world as a whole. Both short- and long-term effects are relevant.

The 1st 48 Project’s context is limited to 821 acres within the wildland-urban interface (WUI) 

around the community of Ruth, two (2) 6th-field watersheds, and the South Fork Late-Successional 

Reserve (LSR). Seventy-three (73) acres of this 80,451-acre LSR lie within the project area on the 

Six Rivers National Forest (SRNF or forest). Any adverse effects will be limited and short-term, 

while benefits will be long lasting.

Even in a local context, the 1st 48 Project will not pose significant short- or long-term effects.

This decision requires resource protection measures to minimize and avoid adverse impacts to the 

extent that all impacts are within accepted levels, and are consistent with all standards and 

guidelines (S&G) in the SRNF’s land and resource management plan (LRMP or forest plan).

Intensity

Intensity refers to the severity of impact, which is evaluated based on ten factors. The following 

summarizes the findings of intensity relative to those factors:

1. Impacts that may be both beneficial and adverse. A significant effect may exist even if the 

federal agency believes that on balance the effect would be beneficial.

There will be positive response to thinning from implementing the 1st 48 Project, since suppressed, 

intermediate and select co-dominant trees will be removed to allow upper canopy trees (i.e., 

healthy dominant and pre-dominant) to expand into the additional growing space achieving desired 

shaded-fuelbreak conditions. Thinning acts to increase the residual size of trees left in a stand 

(Agee and Skinner 2005, Smith et al. 1997; final EA pp. 56-57).
Finding of No Significant Impact

14 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Reducing stand density will also allow these forested stands to become more resilient to 

disturbances, such as wind, heavy snow and ice, bark beetle infestations and fire processes. 

Thinning throughout the diameter classes (with the exception of pre-dominant and dominant 

trees) will increase crown-spacing and reduce stand densities, resulting in less inter-tree 

competition that promotes individual tree vigor and forest stands more resilient to insects, 

disease, wildland fire, and drought (Agee and Skinner 2005, Fettig et al. 2007, Hessburg et al. 

2016, van Mantgem et al. 2009, Vernon 2017; final EA p. 57).

The 1st 48 Project will reduce ladder fuels, increase canopy base heights, and decrease canopy 

densities through thinning activities. As a result, the project will help reduce flame lengths, resistance 

to control, and the potential for ground fires to transition into crown fires (final EA pp. 54-57).

One of the most threatened species within the project areas is the California black oak 

(Quercus kelloggii), which is vulnerable to being overtopped and crowded out by Douglas-fir. In 

addition, one of the biggest deficits on the landscape is the old upland oak woodland (CR). 

Thinning around these remnant oak trees, overtopped and shaded out by faster growing Douglasfir, would enable them to receive more sunlight promoting the growth of fuller crowns, which 

would increase their health and resistance to disturbance (final EA pp. 50-51, 58).

2. The degree to which the Proposed Action affects public health or safety.

Clean Air Act.

The Clean Air Act and its amendments provide for the protection and enhancement of the nation’s 

air resources. The North Coast Unified Air Quality Management District (NCUAQMD) regulates 

the air in Humboldt, Del Norte and Trinity counties, considered to be in “in attainment” of state 

and federal ambient air quality standards. The greatest concern is associated with particulate matter 

(PM) less than 2.5 microns in diameter that can permanently lodge in the deepest, most sensitive 

areas of the lungs, and cause respiratory and other health problems. The 1st 48 Project will 

generate PM during operations from increased off-road vehicles use (e.g., engine exhaust and dust 

from paved and unpaved roads), and jackpot burning and underburning of vegetation and slash.

However, to protect public health, the decision to implement the 1st 48 Project will not exceed 

federal and state ambient air quality standards.

Project design and mitigation measures will effectively address public health and safety 

concerns. Each entry to apply jackpot burning and underburning in oak woodlands will be 

implemented over several seasons and limited in size (i.e., likely 20 to 30 acres at a time). 

Handpiles will be covered with Kraft waxed paper to minimize smoke production during burning. 

In addition, a burn plan will be developed that identifies specific tactics to reduce smoke 

emissions, including identifying sensitive smoke receptors and when favorable winds will

promote smoke dispersal prior to scheduling burn ignition (final EA p. 45).
Finding of No Significant Impact

Decision Notice & Finding of No Significant Impact – 15

Clean Water Act.

The protection of water quality and quantity is an important part of the US Forest Service mission

(USFS or Forest Service; USDA Forest Service 2015). Management activities on NFS lands must 

be planned and implemented to protect the hydrologic functions of forest watersheds, including the 

volume, timing, and quality of streamflow. The 1st 48 Project is designed to be in compliance with 

the Clean Water Act; Porter-Cologne Water Quality Control Act; applicable water quality control 

plans, including the North Coast Regional Water Quality Control Board (NCRWQCB) Basin Plan; 

and the NCRWQCB waiver of waste discharge requirements. A waiver application will be filed 

after the Decision Notice is signed (final EA pp. 13, 98).

The NCRWQCB Basin Plan contains water quality objectives, implementation plans for meeting 

those objectives, and other policies of the State Water Quality Control Board and the federal 

government, which are applicable to timber and fuel treatment projects. The water quality standards 

in the Basin Plan for sediment most closely apply to the 1st 48 Project. The standard for sediment 

states that sediment load and suspended sediment discharge rate of surface waters shall not be altered 

in such a manner as to cause nuisance or adversely affect beneficial uses (final EA p. 98).

The 1st 48 Project lies within the Upper Mad subarea (comparable to the Upper Mad River 5thfield watershed), which produces only 6 percent of the sediment within the larger Mad River 

Watershed. For the Upper Mad River Watershed, the total sediment is estimated at 234 tons per 

square mile per year with an average of 38 percent from management-related sources. The total 

maximum daily load (TMDL) target for sediment in the Upper Mad subarea was set at 173 tons, a 

reduction of 26 percent for the Upper Mad watershed. The Environmental Protection Agency 

(EPA) specified that to meet a 26 percent reduction in total sediment within the Upper Mad 

watershed, management-related sediment must be reduced by 68 percent over time. The project 

will minimize, and in some areas, reduce management-related sediment and move towards 

meeting the EPA sediment load allocation (final EA pp. 95-98, 101).

There are 3.7 miles of intermittent streams and one (1) mile of perennial streams within the 

project units. Due to limited project activities in riparian reserves and 60-plus percent canopy 

retention, stream temperature will not be affected. The streams coming off South Fork Mountain 

are high gradient and steeply incised, with mostly stable banks and little true riparian vegetation. 

The 1st 48 Project will not construct new permanent (system) or temporary roads. For the project 

as a whole, there are 141 acres of riparian reserves deemed equipment exclusion zones.

Compliance with the Clean Water Act, and the limits set by the TMDL established in 2007, is 

through best management practices (BMPs) and adherence to the terms and conditions of the 

Waiver of Waste Discharge Requirements for Nonpoint Source Discharges Related to Certain 

Federal Land Management Activities on National Forest System Lands in the North Coast Region

(The Waiver; Order No. R1-2015-0021). Enrollment in The Waiver under Category B must be 

granted before project activities commence. The direct, indirect, and cumulative watershed effects 

of the 1st 48 Project will not result in any significant impacts to water quality, as directed in the 

terms and conditions of The Waiver (final EA pp. 95-96, 101-102).
Finding of No Significant Impact

16 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Wildland-Urban Interface.

The reduction in fire hazards will enhance public safety for those living within the wildland-urban 

interface (WUI), as the 1st 48 Project is designed to promote efficient wildfire containment and 

control. Between 2006 and 2011, about 600 assessments were completed by the Forest Service on

wildfires that burned into areas where hazardous fuels reduction (HFR) treatments had previously 

been conducted (Stein et al. 2013). These assessments evaluated the effects of prescribed fire, as 

well as mechanical and chemical treatments, on fire behavior and fire suppression actions. The 

data indicates that 90 percent of treatments helped reduce wildfire intensity, allowing firefighters 

to achieve better control. In most of these cases, as fires moved from untreated locations to areas 

treated by thinning, mowing, or prescribed burning, the fire behavior changed from active crown 

fires (i.e., burning an entire upper story of forest) to passive crown fires (i.e., where only a single 

tree or small group of trees burned), or from passive crown fires to surface fires (i.e., burning 

only dry grass, shrubs, pine needles, and other flammable materials on the ground; Della Sala et 

al. 2004, Stein et al. 2013; final EA pp. 5, 52-55).

3. Unique characteristics of the geographic area such as the proximity to historical or cultural 

resources, parklands, prime farmlands, wetlands, wild and scenic rivers, or ecologically 

critical areas.

Caves.

The Federal Cave Resources Protection Act of 1988 (102 Stat. 4546; 16 USC 4301 et seq.) 

provides that federal lands be managed to protect and maintain, to the extent practical, significant 

caves. There are no known caves within the project area; therefore, there will be no effect to this 

resource from implementing the 1st 48 Project (final EA pp. 102-104; Geology Report).

Geologic Resources.

Surveys identified eight (8) active landslides within the project area. There are no Forest Service 

or private land activities occurring within these sites. Cumulative effects are minimal to none for 

increased risk of landslide activity. Landslide activity has been shown to increase about 10 years 

after all vegetation has been removed by fire or harvest due to loss of root strength. This decision 

will not remove all vegetation, thereby preserving root strength in the long term to avoid risks of 

increased landslide activity. Concentrated flow from skid trails will not occur due to application 

of skid trial remediation. When S&Gs, BMPs, project-design features (PDFs) and mitigation 

measures are applied, the negative effects to slope stability will be minimal or absent, as 

compared to the likelihood that extensive landslide reactivation could be triggered by a hot, largescale wildfire (final EA pp. 104-105).

Late Successional Reserve.

A very small portion of the 1st 48 Project is located within the South Fork LSR (RC-330). The 

majority of this 80,451-acre LSR is on the Shasta-Trinity National Forest (STNF). Only 1,057 acres 

are on the SRNF, with the 1st 48 Project affecting 73 acres on the LSR’s westernmost boundary. The 
Finding of No Significant Impact

Decision Notice & Finding of No Significant Impact – 17

South Fork LSR is a land allocation established in the Northwest Forest Plan (NWFP), incorporated 

into both the SRNF and STNF LRMPs, and managed to protect and enhance late-successional forest 

ecosystems through prescribed understory fire and thinning. The 1999 South Fork LSR Assessment 

(LSRA) prepared by the STNF was incorporated by reference in its entirety into the SRNF’s 1999 

Forest-Wide LSRA. These LSRAs describe current conditions, general desired conditions, and 

management recommendations that would move the LSRs, including the South Fork LSR, toward 

desired conditions. One of the desired conditions is the reduction of risk to large-scale disturbance.

In 2009, the STNF received a letter of clarification from the US Forest Service Pacific 

Southwest Regional Ecosystem Office (REO) related to thinning activities proposed in LSRs to 

reduce the risk of large-scale disturbance. The REO had reviewed the STNF’s LRSA and concluded 

that fuel treatments proposed in LSRs that thin suppressed, intermediate and some co-dominant 

trees are consistent with the S&Gs under the NWFP (USDA REO letter, October 18, 2009).

The 1st 48 Project area was identified as a landscape where existing features and conditions 

give firefighters a good chance of keeping wildfire from entering, or conversely, from exiting the 

area. The NWFP S&Gs (C 12-13) for risk reduction treatments does not limit the size of trees that 

can be removed when reducing risk of large-scale disturbance is the primary objective of 

treatments within LSRs. In the letter, the LSR work group concurred with an upper 150-year age 

limit on trees removed, as opposed to a 20-inch diameter limit, which could be cut to enhance 

development of late-successional habitat. The LSR work group deemed it logical to assume that 

trees this old would be larger than 20 inches in diameter. Based on tree-age data collected on 

stand exam plots in the LSR for this project, white fir ranging from 18 inches to 35 inches in 

diameter were between 75 and 127 years old.

Consistent with the LSRAs and SRNF LRMP direction, the 1st 48 Project will reduce risk 

(i.e., potential loss due to wildfire) on 59 acres of younger white fir stands adjacent to Forest 

Service Road (FSR) 2S23 and along the ridgetop within the South Fork LSR. Trees targeted for 

removal in the early mature white fir stands have a diameter range of 14 to 24 inches, and are less 

than 120 to 150 years old. Some trees in this age class are larger than 24-inch dbh (diameter at 

breast height) and may be removed to meet crown-spacing objectives.

In addition, there are approximately 14 acres of Douglas-fir or ponderosa pine-dominated stands 

within the LSR that are early-, mid-, or late-mature stands that have had previous entries of 

individual tree harvest. The trees targeted for removal in these stands are similar to the white fir 

stands in terms of age and diameter range. In the patches of mid-mature and remnant late-mature 

seral forest, trees range from 70 to 120 years in age, with diameters ranging from 12- to 32-inch dbh. 

However, the 1st 48 Project targets removal of trees with under-developed crowns that are typically 

less than 150 years old, while retaining trees with the fullest crowns, characteristic of co-dominant, 

dominant and pre-dominant trees with late-seral characteristics (final EA pp. 57-58, 203-206).
Finding of No Significant Impact

18 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Northern Spotted Owl Critical Habitat.

On December 4, 2012, the final 2012 Northern Spotted Owl Critical Habitat Rule (Critical 

Habitat Rule) was published. Critical habitat consists of those areas that have physical or 

biological features essential to the conservation of the species. The Critical Habitat Rule states 

“we encourage land managers to consider implementation of forest management practices 

recommended in the Revised Recovery Plan to restore natural ecological processes where they 

have been disrupted or suppressed (e.g., natural fire regimes), and application of ecological 

forestry management practices ...”. In the Critical Habitat Rule, the US Fish and Wildlife Service 

(USFWS) acknowledged that “Compared to other zones (in the Klamath and Northern California 

Interior Coast Ranges), additional foraging habitat for this zone showed greater divergence from 

nesting habitat, with much lower canopy cover and tree size.”

Approximately 28,413 acres of the 36,267-acre action area occur within Unit 11, Interior 

California Coast Subunits 1 and 2 of the Critical Habitat Rule. There will be 12 units of HFR

(152 acres), four (4) units of oak woodland restoration (37 acres), eight (8) units of plantation 

thins (108 acres) and 61 units of fuelbreak construction (461 acres) that would occur in northern 

spotted owl (NSO) critical habitat units (CHU). A total of 784 acres of NSO nesting/roosting/

foraging/dispersal habitat and 37 acres of non-habitat would be treated between the two (2) CHU 

subunits (final EA pp. 59, 62-64).

Post-treatment monitoring was conducted by the Forest Service in coordination with the 

USFWS Level 1 Team on the 2013 Kelsey Peak Timber Sale and Fuelbreak Project (Kelsey Peak 

Project), as well as on similar projects elsewhere on the forest. All the units exceeded canopyclosure requirements, and protected pre-dominant trees, snags, and downed logs. The units are 

still functional habitat and should respond well to the treatments. The Level 1 Team agreed these 

types of treatments will have a beneficial effect on future habitat conditions of the area and create

more alternative habitats for owls to use as additional treatments occur on the landscape (final 

biological assessment (BA)).

Parklands and Prime Farmlands.

There are no parklands or prime farmlands within or immediately adjacent to the project area. 

Therefore, there would be no effect to these resources from implementing the 1st 48 Project (final 

EA p. 146).

Research Natural Areas.

Research natural areas (RNA) are areas allocated for research, education and to protect biodiversity 

on NFS lands. There are no RNAs within the project area. Therefore, there will be no effect to these 

resources from implementing the 1st 48 Project (final EA p. 146).

Van Horn Range Allotment – Barry Creek Sub-Unit.

The Van Horn Allotment – Barry Creek sub-unit is an active allotment in the southern half of the 

project area, which includes the upper half of FSR 2S48, including all of Jeep Trail 8E20; the 

portion of FSR 1S23 south of Jeep Trail 8E20; a portion of FSR 2S02; and all of FSRs 2S47, 
Finding of No Significant Impact

Decision Notice & Finding of No Significant Impact – 19

2S53 and 2S54. There are 357 cow-calf pairs allowed during the allotment’s June 1 to October 15 

season. The 1st 48 Project will improve secondary range conditions through thinning and 

prescribed burning operations, but improved tree crown growth will shade out forbs and grasses

in less than 5 years. Cattle will continue to travel through the area as available forage is minimal.

Wetlands and Floodplains.

No floodplains associated with Executive Order 11988 or wetlands associated with Executive 

Order 11990 exist within the project area. Therefore, there will be no effect to these resources from 

implementing the 1st 48 Project (final EA p. 146).

Wilderness Areas.

Wilderness areas are managed according to the Wilderness Act of 1964 and the California Wilderness 

Act of 1984. There are no wilderness areas designated within the project area. Therefore, there will 

be no effect to these resources from implementing the 1st 48 Project (final EA p. 146).

Wild and Scenic Rivers.

There are no designated and/or recommended national wild and scenic rivers, per the National 

Wild and Scenic Rivers Act of 1968, within the project area. Therefore, there will be no effect to 

these resources from implementing the 1st 48 Project (final EA p. 146).

4. The degree to which the effects on the quality of the human environment are likely to be 

highly controversial.

The project area lies within the Upper Mad River watershed, encompassing 120 square miles 

(24% of the basin) from the headwaters of the Mad River to Robert Matthews Dam. The dam, 

built in 1961 by the Humboldt Bay Municipal Water District (HBMWD), impounds runoff from 

the upper watershed in the Ruth Lake Reservoir, the only existing impoundment on the Mad 

River. The reservoir has a storage capacity of about 48,030 acre-feet and was designed to provide 

a safe yield of 75 million gallons per day (mgd; 230 acre-feet/day), approximately 8 percent of 

the total annual runoff for the watershed.

Prior to construction of Matthews Dam, late summer and early fall flows in the Mad River 

above Pilot Creek were intermittent. At the former US Geological Survey (USGS) gauge near 

Forest Glen (No. 11480500, located approximately 9 miles downstream of Matthews Dam), mean 

daily flow for August 1953 to 1961 ranged from 2 to 8 cubic feet per second (cfs), with an 

average of 4 cfs. The HBMWD currently manages the release of water from Ruth Reservoir to 

meet domestic and industrial water needs, as well as instream flow requirements for the protection 

of listed fish species (HBMWD 2004; final EA p. 101).

The watershed resources analysis indicates the extent, duration and intensity of treatment 

activities under Alternative 2 are not sufficient to adversely affect instream flows. Evapotranspiration 

rates will not be further altered, nor will sufficient ground compaction occur to alter rates of surface 

runoff. Due to the limited magnitude of the treatments and the very small and localized spatial extent 

of the treatments, the 1st 48 Project will not result in changes to spatial and temporal hydrology. 
Finding of No Significant Impact

20 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Therefore, the timing, magnitude, and duration of flows will not be altered by treatment activities.

Instream flows and fluvial processes will continue to occur at the rates under which the stream 

system evolved and aquatic habitat diversity, channel stability, and water quality will continue to be 

moderate to high (final EA pp. 95-102).

5. The degree to which the possible effects on the human environment are highly uncertain or 

involve unique or unknown risks.

Asbestos Airborne Toxic Control Measure for Surface Application.

The Asbestos Airborne Toxic Control Measure (ATCM) rule was adopted by the California Air 

Resource Board (CARB) in 1990 and amended in 2000. The amendment lowered the asbestos 

content to 0.25 percent for asbestos-bearing ultramafic rock materials used for surfacing 

applications subject to vehicular, pedestrian or non-pedestrian use, such as cycling and horseback 

riding. In remote areas, the naturally occurring asbestos (NOA) content can be as high as 1 

percent without concern. No ultramafic bedrock or NOA exists within the project area. The SRNF 

has samples and tests for presence of NOA as close as 10 miles from the project area. Two (2) of 

the 42 samples within a 20-mile radius from the project area contained asbestos at 0.5 percent in 

small serpentenite outcrops; however, the project area contains no similar outcrops. In addition, 

no groundwater resources will be developed or exist within the project area. The treatment 

prescriptions and mitigation measures incorporated have been applied on numerous projects 

across the SRNF with predictable effects and outcomes (final EA pp. 104-105; Geology Report).

Executive Order 12898 – Environmental Justice.

Executive Order 12898 (Environmental Justice) requires an assessment of whether there would be 

disproportionate effects to minority or low-income populations. Although there are minorities and 

low-income populations living in the North Coast California area, they would benefit from the 

proposal.

Environmental justice means, to the greatest extent practicable and permitted by law, all 

populations are provided the opportunity to comment before decisions are rendered on, are 

allowed to share in the benefits of, are not excluded from, and are not affected in a 

disproportionately high and adverse manner, by government programs and activities affecting 

human health or the environment. There would be no discernable difference between Alternative

1 (No Action Alternative) and Alternative 2 regarding effects on minorities or the civil rights of 

any American citizen.

The 1st 48 Project will not cause disproportionately high or adverse effects to human health, 

high or adverse environmental effects, substantial environmental hazard, or effects to differential 

patterns of consumption of natural resources. Extensive scoping did not reveal any issues or 

concerns associated with the principles of environmental justice. No mitigation measures to offset 

or ameliorate adverse effects to these populations were identified (final EA pp. 14-15).
Finding of No Significant Impact

Decision Notice & Finding of No Significant Impact – 21

Relationships between local, short-term uses of the human environment and maintenance 

or enhancement of long-term productivity.

Short-term uses are expected to change the human environment during mechanical, manual, 

prescribed burning and logging/hauling operations. Long-term effects should not appreciably 

change the human environment after fuelbreak maintenance operations have concluded, as 

treatment prescriptions will be low intensity and implemented as phased entries to minimize 

disturbance to nearby neighbors and natural resources.

The availability of natural resources contributes to the quality of life for many county 

residents. Families can experience benefits from healthy forest environments associated with food 

gathering, firewood for heating, forest-management job opportunities and supply of natural 

resources from forest ecosystems. The 1st 48 Project will provide jobs, firewood, poles, enhance 

oak-dominated stands (e.g., aiding acorn production, native herbs and forbs) and produce 

commercial timber products (final EA pp. 35-39).

6. The degree to which the action may establish precedent for future actions with significant 

effects or represents a decision in principle about a future consideration.

Irreversible or Irretrievable Commitments of Resources.

Vegetation.

A review of the 1st 48 Project final EA and project record indicates there will be no irreversible 

commitment of resources resulting from implementation; however, the production lost will be 

irretrievable. Irretrievable commitment applies to losses that are temporary, such as use of 

renewable natural resources. Vegetation removed as commodity byproducts is considered an 

irretrievable impact. Forest conditions will return, as tree growth over one (1) or more decades 

will feature increased canopy closure serving wildlife habitats per the Endangered Species Act 

(ESA; final EA pp. 56-57, 92, 113-122). In the long term, this decision will promote the 

development of healthy, sustainable stand densities, more resilient to natural processes that can 

revert mature forest stands to early seral stage conditions (final EA pp. 56-58).

Soils.

The 1st 48 Project design is consistent with SRNF LRMP and Soil Quality Standards (SQS) for 

soil productivity, in compliance with the National Forest Management Act (NFMA). Standards 

and guidelines and SQS indicators were used as the context to describe and analyze the extent and 

magnitude of expected soil impacts, spatially and temporally. The requirement to implement 

project-specific design features and mitigation measures, along with monitoring, will minimize 

effects to ensure compliance with these LRMP provisions for long-term soil productivity (final 

EA pp. 117-120).

Existing detrimental effects of past actions within the project areas are minimal. The 1st 48 

Project will not produce significant amounts of adverse direct or indirect soil impacts, as 15 

percent of the area in detrimental soil condition will not exceed the threshold for significance, per 
Finding of No Significant Impact

22 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

current management direction. There are no reasonably foreseeable future actions that could 

contribute to significant impairment of soil quality or productivity. Since there are no additive 

significant effects of past, present, and foreseeable future actions expected, there will be no

significant cumulative effects to soil resources (final EA pp. 106-122; Soils Report).

The 1st 48 Project will involve adverse environmental effects to soil resources that cannot be 

wholly avoided or mitigated. While no new temporary roads will be constructed, the expansion 

and grading of new landings associated with ground-based (tractor) operations will be the most 

impactful due to severe compaction, causing reduced infiltration and soil runoff. However, this 

decision requires construction of drainage features to control runoff and avoid adverse impacts, in 

compliance with BMPs. In addition, the decision applies PDFs and mitigation measures 

stipulating site rehabilitation via decompaction by ripping (i.e., furrowing using conventional

rock-rippers common on logging equipment) or dibbling (i.e., working the ground with an 

excavator bucket, also called potato patch). This will be followed by re-contouring to the 

approximate original terrain in cases where the feature was “constructed” by blading topsoil to 

create a favorable grade or bench constructed using cut and fill.

The new landings are mostly along roadsides on gentle grades, so little blading should be 

necessary to make them usable, and thus little to no re-contouring is expected; however, some 

form of decompaction will be necessary. These areas will also be rendered bare, so some form of 

soil cover may be required to prevent erosion, either organic mulch, slash, and/or seeding to 

establish vegetation. In most cases, old access roads and landings are in favorable locations to be 

re-utilized, which will minimize new disturbance and cumulative effects. Even with rehabilitation 

measures, new and re-utilized temporary roads and landings will have long-term effects left to 

slowly recover naturally over time.

Skid trails will be created as necessary to operate within the mechanical ground-based units. 

These will also have compaction, but not as severe as temporary roads and landings. These may 

or may not have “detrimental” levels of compaction, depending on traffic intensity. A few passes 

with a tracked grapple-skidder will generally not produce a detrimental degree of compaction if 

soils are dry. Most soils have a moderate compaction risk (final EA Table 17), but some have a 

high compaction risk, namely Kistirn (SMU 260), Hugo (SMU 265-266) and Hecker (SMU 250-

256), which intersect with many of the ground-based units. Thus, it is conservatively assumed 

that skid-trail compaction will be detrimental. This decision requires equipment trails, in 

combination with temporary roads and landings, be limited to less than 15 percent of the unit 

area. If equipment trails are deeply rutted, they may be decompacted by ripping, if necessary, to 

promote natural revegetation (final EA pp. 114-115; Soils Report).

Energy Requirements.

The implementation of the 1st 48 Project will expend various amounts of fossil fuels and human 

labor. Fossil fuel energy will not be retrievable. None of them are in short supply and their use 

will not have an adverse effect upon continued availability of these resources.
Finding of No Significant Impact

Decision Notice & Finding of No Significant Impact – 23

7. Whether the action is related to other actions with individually insignificant but cumulatively 

significant impacts. Significance exists if it is reasonable to anticipate a cumulatively 

significant impact on the environment. Significance cannot be avoided by terming an action 

temporary or by breaking it down into small component parts.

Fire and Fuels.

The absence of recent mixed-severity fire has likely been a factor in the rather uniform, evenaged, single-layer structure of Douglas-fir stands, as well as the continued loss of black oak 

through competition from Douglas-fir. Due to fire suppression that began in the early 1900s, these 

sites have likely missed several fire events that would have created more horizontal and structural 

diversity in the early- and mid-mature stands (Weisberg 2004, Taylor and Skinner 2003).

In the northern part of the planning area, ponderosa pine and ponderosa pine/black oak stands 

are prevalent. Fire-scar evidence indicates that these stands were historically maintained at low 

densities by frequent fire regimes. Many of these stands contain large, old specimens of both 

species. Stand densities and ladder fuels have increased to the point that there is a risk of losing 

them to a stand-replacing fire. This decision will lower stand densities aiding in forest protection 

of this natural resource (final EA pp. 56-57).

Invasive Plant Species.

Forest Service Manual (FSM) 2900 (Invasive Species Management) guides management of 

invasive species on NFS lands and require that land management activities not foster the 

introduction and spread of invasive species. The 1st 48 Project design features and mitigation 

measures described in Chapter 2 of the final EA will reduce the risk of introduction and spread of 

invasive non-native plant species from high to low and eradicate isolated populations.

All mechanical equipment used in the project area, including equipment related to road

maintenance, will be pressure-washed prior to operation (USDA Forest Service 2014), as well as

after operation if moving from an infested to an un-infested area. Treatment of mechanical units 

will also follow a progression of work schedule, whereby treatment occurs first where invasive 

plants are limited to non-existent before moving to heavily infested areas (e.g., lower infested 

stretch of 2S48). The following units occur near yellow star thistle infestations so they will be 

treated last to reduce the risk of introduction and spread: 308, 401, 402, 403, 404, 405, 406, 407, 

408, 409, 410, 411, 418 and 421. Successful control of yellow star thistle will necessitate periodic 

monitoring and evaluation of treatment efficacy. If present after initial treatment, this decision 

authorizes manually pulling or using tools to remove individual plants in late spring (before 

fruiting/seeding; final EA pp. 38 and 39, 138-142; Appendix C; Botany Weed Risk Assessment).

Management of direct and indirect effects to invasive plant species via the PDFs and 

mitigation measures required under Alternative 2 will reduce the risk of introduction and spread, 

and remove sources of infestation, leading to beneficial cumulative effects (final EA pp. 138-142; 

Botany Weed Risk Assessment).
Finding of No Significant Impact

24 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Recreation

The entire project area falls within the recreational opportunity spectrum (ROS) of Roaded Natural

per the SRNF LRMP. Roaded Natural is defined as an area characterized by predominantly 

natural-appearing environments with moderate evidence of the sights and sounds of man, usually 

harmonizing with the natural environment. The 1st 48 Project will slightly modify the visual 

resources, but not to such an extent as to fundamentally change existing dominant form, color, 

pattern, or texture of the Roaded Natural character.

Soil Resources.

The 1st 48 Project design is consistent with the regulatory framework outlined in the Six Rivers’ 

LRMP S&Gs and SQS, in compliance with NFMA by maintaining soil productivity. The S&Gs 

and SQS indicators were used as the context to describe and analyze the extent and magnitude of 

expected soil impacts, spatially and temporally. Implementing project-specific mitigations will 

ensure compliance with these LRMP provisions; and it is thus deduced, that long-term soil 

productivity will be maintained within the project area.

The 1st 48 Project alone will not produce significant amounts of adverse direct or indirect soil 

impacts, using 15 percent of the area in detrimental soil condition as the threshold to determine if 

soil impacts are significant, per current management direction. Current existing detrimental 

effects of past actions are minimal in extent. There are no reasonably foreseeable future actions

that will produce significant impairment of soil quality or productivity. Thus, there are no additive 

significant effects of past, present, and foreseeable future actions expected; and therefore, no 

significant cumulative effects for soil resources (final EA p. 122).

SRNF LRMP Retention and Partial Retention Management Areas – Visual Quality Objectives.

There are 275 acres within the project area that fall within the visual quality objective (VQO) 

Retention management area, 234 acres within Partial Retention management area, and 312 acres 

within the Modification management area. The majority of the project area has experienced 

substantial alterations in visual quality from historic road and log landing construction and evenage timber harvest management. The 1st 48 Project will retain variable forest canopy closure at or 

above 60 percent, limit new landing construction to existing flat openings, and will not involve 

new road construction to minimize further visual impacts. The removal of boundary flagging and 

placing stump marks away from viewpoints will minimize visual impacts in compliance with 

LRMP S&Gs. Thinning treatments will blend well with adjacent untreated forest lands to 

conserve the scenic quality, while reducing hazardous fuels to promote scenic integrity at risk 

from wildfire (final EA p. 46).

The 1.29-mile-long Jeep Trail 8E20 is a special vehicle designation trail (i.e., four-wheeldrive non-highway legal vehicle wider than 50 inches/all-wheeled vehicle 50-inches wide or less) 

located in T2S R8E. The Forest Service’s national resource management (NRM) database 

indicates the trail was added to the NFST (NFS trails) by the Lower Trinity/Mad River Motorized 
Finding of No Significant Impact

Decision Notice & Finding of No Significant Impact – 25

Travel Management Record of Decision in April 2010. This trail is displayed on the revised motor 

vehicle use map (MVUM) for that area.

The decision to implement the 1st 48 Project will allow the existing footprint of Jeep Trail 8E20 

to be graded and temporarily closed to public use during logging operations to ensure public safety. 

Other than the short-term disruption in public use, grading and constructing waterbars will be 

visually evident in the short-term, likely only one season. Although these impacts are unavoidable, 

this action will contribute to protecting scenic quality in the long term (final EA pp. 45-46).

Vegetation.

The 1st 48 Project differs from past actions, in that historic timber harvest (pre-1990s) consisted of 

clearcut or shelterwood logging, broadcast burning, and planting with Douglas-fir seedlings. The 

project will employ thinning (Tappeiner et al. 2007) in 70- to 80-year-old early and early/midmature Douglas-fir/black oak stands, early mature white fir stands, and young Douglas-fir or 

ponderosa pine plantations. These stands are generally single-layered and consist of even-aged 

patches. A positive response to thinning is expected, since subordinate trees (i.e., suppressed, 

intermediate and select co-dominant trees) will be removed to allow upper canopy trees, which 

have more fully developed crowns, to utilize the additional growing space and increase in size

(Agee and Skinner 2005, Smith et al. 1997).

This decision will retain all dominant and pre-dominant trees, including those with defects. 

The thinning prescription will not alter existing seral stage condition, and will in fact, accelerate 

development of the remaining trees into late-seral size classes. This will promote an increase in 

the acres of late-seral stands as an incremental step toward achieving the minimum Douglas-fir 

Recommended Management Range (RMR) threshold.

Similar thinning projects are being carried out within this watershed, including the 2009 

Beaverslide and the Kelsey Peak Project. Other foreseeable actions within the analysis area are 

additional HFR projects, and shaded-fuelbreak construction and maintenance. In terms of past, 

proposed, ongoing, and foreseeable actions, the 1st 48 Project will have no cumulative effects to 

the vegetation structural stages within the south zone of the forest (i.e., the entire Mad River 

Ranger District). The current distribution has been molded by past activities, which removed 

older forest types, and past wildfires. This project will improve the distribution of structural 

stages over the long term for species needing older forest habitats for part or all of their life cycle

(final EA pp. 56-58, 184-185, 206-207).

Watershed Resources.

The 1st 48 Project area is not within a key watershed under the NWFP. Barry Creek-Mad River 

and Lost Creek-Mad River (the next watershed upstream; outside of the 1st 48 Project area) 

watersheds were identified as Priority Watersheds under the Watershed Condition Framework

(WCF). As such, these watersheds had developed watershed restoration action plans (WRAPs). 

The primary strategies for restoring these watersheds are fuels reduction projects, road 

maintenance, stormproofing and decommissioning. Although this project was not anticipated 
Finding of No Significant Impact

26 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

when the WRAP was created, it meets the goals and intent of the WRAP. The 1st 48 Project area 

is small in acreage and widely dispersed across the landscape, along open roads in narrow 300-

foot-strips, in existing roadside plantations and oak woodland stands. Thinning to establish 

shaded fuelbreaks will retain forest overstory canopies at 60-plus percent, functioning to provide 

sufficient shade from solar radiation preventing increases in water temperature.

This decision will restrict tree-thinning prescriptions to the outer portion of riparian reserves

to retain tree root systems that hold soil and stream channels in place, minimizing soil erosion and 

protecting water quality from increased sedimentation. Alternative 2 incorporates design features 

and mitigation measures that will retain large woody debris, limiting thinning of trees to 6-inch 

dbh using only manual methods within inner riparian reserve buffers to maintain suitable stream 

habitat conditions and mitigate introduction and spread of invasive and non-native weeds due to 

open range and other operational vectors (final EA pp. 97-98).

The 1st 48 Project will treat a very small percentage of the affected watersheds. The results of 

the ERA (Equivalent Roaded Acres) model used by the Forest Service to analyze cumulative effects 

on the Ruth Lake-Mad River watershed from grazing and private land timber harvesting, indicates 

operational disturbances will contribute an additional 0.4 percent to the 11.2 percent existing 

condition. The threshold of concern (TOC) for Ruth Lake-Mad River is 12.8 percent. This project 

would not lead to adverse cumulative watershed effects in the Ruth Lake-Mad River watershed.

For the Barry Creek-Mad River watershed, the ERA model indicates that the existing 

condition is 9.7 percent; the 1st 48 Project would add 0.4 percent for a total of 10.1 percent. This 

watershed does have foreseeable future actions, although there are units remaining from the 

Beaverslide and Kelsey Peak timber sales. Assuming that all the remaining units are treated in 

2018, the ERA would increase to 10.3 percent. The TOC for Barry Creek-Mad River is 12.8, so 

this watershed would remain under threshold. This project would not lead to cumulative 

watershed effects in the Barry Creek-Mad River watershed.

8. The degree to which the action may adversely affect districts, sites, highways, structures, or 

objects listed in or eligible for listing in the National Register of Historic Places or may 

cause loss or destruction of significant scientific, cultural, or historical resources.

Heritage Resources

Pre-field research was conducted to comply with the regulatory framework protecting cultural 

resources that examined previous archaeological surveys in the planning area, site records, maps and 

GIS data. The data indicated that seven (7) of the surveys, conducted between 1978 and 2012,

included the Area of Potential Effect (APE), defined as the project’s treatment units. The surveys 

resulted in the identification of 32 archaeological sites, none located within the APE. Two (2) 

archaeological sites were identified during surveys conducted within the project’s APE between 

October 2016 and August 2017. These surveys were recorded in the cultural resources inventory 

reports (CRIRs) on file in the Heritage Department of the SRNF Supervisor’s Office. Standard 

resource protection measures, as defined in the Programmatic Agreement among the USDA Forest 
Finding of No Significant Impact

Decision Notice & Finding of No Significant Impact – 27

Service, Pacific Southwest Region (Region 5), California State Historic Preservation Officer, Nevada 

State Historic Preservation Officer, and the Advisory Council on Historic Preservation Regarding the 

Processes for Compliance with Section 106 of the National Historic Preservation Act for 

Management of Historic Properties by the National Forests of the Pacific Southwest Region (R5 PA),

would be applied to fully protect archaeological sites within the APE (final EA pp. 122-124).

9. The degree to which the action may adversely affect an endangered or threatened species or 

its habitat that has been determined to be critical under the Endangered Species Act of 1973 

(ESA).

The Endangered Species Act (ESA) of 1973 (16 USC 1531 et seq.) requires any action authorized 

by a federal agency to not jeopardize the continued existence of a threatened or endangered species, 

or result in the destruction or adverse modification of the critical habitat of such species. Section 7 

of the ESA, as amended, requires the responsible federal agency to consult with the USFWS and 

the National Marine Fisheries Service (NMFS) concerning endangered and threatened species under 

their jurisdiction as follows:

Threatened and Endangered Wildlife Resources.

The 2011 Recovery Plan for the Northern Spotted Owl (Recovery Plan) recognizes the importance of 

maintaining and restoring habitat for the recovery and long-term survival of the spotted owl. The 

Recovery Plan relies on federal lands to provide the major contribution for recovery (USDI Fish and 

Wildlife Service 2011). The 1st 48 Project was designed to meet the objectives of the Recovery Plan.

The SRNF definition of suitable nesting/roosting NSO habitat includes mid-mature (starting 

at 21-inch dbh), late-mature and old-growth seral stages. The definition of NSO nesting/roosting 

habitat used for this project was based on the definition found in the SRNF LRMP and fieldverified by wildlife biologists with extensive experience with the species. The LRMP definition 

was based on extensive published literature and represents the best available science for SRNF

habitat types. All potential habitat was considered during project evaluation, and all high-quality 

habitat—no matter what seral stage—was dropped from treatment. Low-quality habitats were 

evaluated for habitat improvement measures.

Because SRNF leadership strives toward NSO recovery, all activity centers (ACs) receive the 

same level of protection, which exceeds the requirement of Recovery Action 10 in the Recovery 

Plan. In addition, the USFWS requires a 70-acre nest grove protection zone.

The 2017 and 2018 wildlife analysis was disclosed in the February 2018 draft EA and draft 

BA, pending completion of USFWS consultation under the ESA’s streamlined consultation 

procedures (Forest Service and USFWS MOU, January 31, 2013). Northern spotted owl surveys 

were conducted in all suitable habitats in the 1st 48 Project area in accordance with the 2012 

USFWS protocol. In addition, NSO surveys were conducted within the planning area in the early 

and mid-1990s. There are three (3) 100-acre LSRs located in association with ACs 290, 239 and 
Finding of No Significant Impact

28 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

236; however, the LSRs coincide with the actual nest groves, which is based on the owl’s location,

for the AC. Therefore, this decision will not treat these 100-acre LSRs.

The wildlife analysis and revisions from USFWS review and comment during the Level 1 

streamlined consultation process on ESA-listed species, prompted clarifications and minor revision 

to the analysis disclosed in the final EA and April 9, 2018 final BA prepared for the 1st 48 Project. 

The final EA and final BA disclose protection measures of designated nest groves and acres of 

individual treatments by Critical Habitat subunits, accounting for combined treatments for the 1st

48 and the Kelsey Peak projects.

The final BA indicates treatments will restore and accelerate development of important 

habitat characteristics for the NSO. Treating plantations and overstocked stands will increase 

available habitats and help reduce inter-species competition between the barred owl and the NSO.

The 1st 48 Project was designed to ensure no adverse impacts to listed species will occur.

Informal consultation with the USFWS was initiated through the interagency Level 1 process. 

The Level 1 team determined that the project is not likely to adversely affect the NSO or 

designated NSO Critical Habitat. 

On May 14, 2018, the USFWS provided a letter of concurrence upholding the Level 1 team 

determination (final EA pp. 61-85; final BA).

Threatened and Endangered Botanical Resources.

No federally listed plant species are known to occur, nor does suitable habitat exist in the project 

area (final EA pp. 46, 124; biological assessment/biological evaluation (BA/BE)).

Threatened and Endangered Aquatic Species.

Three (3) species of threatened and endangered (TE) salmonids are found in the Mad River 

watershed. Northern California steelhead trout (Oncorhynchus mykiss) are found in the mainstem 

Mad River up to Matthews Dam with Critical Habitat designated up to County Line Creek. 

Chinook (California Coastal ESU; O. tshawytscha) and coho (Southern Oregon/Northern 

California ESU; O. kisutch) are found in the in mainstem Mad River up to “Bug Creek Falls,”

approximately 27 miles downstream from Matthews Dam. As the roadside treatment areas are 

located upstream of the Ruth Lake Dam, threatened, endangered and Forest Service Sensitive 

(TES) anadromous fish species cannot reach the project area. Therefore, this decision will have 

no effect on anadromous TE species and their habitats (final EA pp. 46-47).

10. Whether the action threatens a violation of federal, state, or local law or requirements 

imposed for the protection of the environment.

Aquatic Conservation Strategy.

The 1st 48 Project was developed in alignment with the Aquatic Conservation Strategy (ACS) 

reflected in the Record of Decision (ROD) and S&Gs of the NWFP (USDA and USDI 1994) as 

incorporated into the SRNF LRMP (USDA Forest Service 1995). The 1st 48 Project will fulfill 

specific objectives of forest goals for aquatic and riparian resources management (USDA Forest 
Finding of No Significant Impact

Decision Notice & Finding of No Significant Impact – 29

Service 1995 p. IV-107), and be consistent with the nine (9) ACS objectives and the May 22, 2007

ACS guidance memorandum. This decision will implement unique design features to ensure 

activities will contribute to maintaining or restoring the condition of the project area and, through 

these actions, watershed condition as a whole over the long term with only minor, unavoidable 

short-term impacts. Implementation of the 1st 48 Project will not retard or prevent attainment of 

ACS objectives at the hydrologic unit code (HUC) 6th and larger scales in the short term. Rather, it 

will promote attainment of ACS objectives in the long term. Cumulative watershed effects (CWE) 

will remain below the threshold for adverse watershed effects (final EA pp. 98-102).

Forest Service Sensitive Wildlife Species.

All Forest Service Sensitive wildlife species known or thought to occur in the 1st 48 Project area, 

based on habitat and range, were evaluated for this project. It was determined that the project will

not impact certain Forest Service Sensitive species, due to the lack of habitat, lack of detections 

during surveys, or the fact that habitat will not be impacted. Species not be affected by this 

project include the bald eagle (Haliaeetus leucocephalus), Townsend’s big-eared bat 

(Corynorthinus townsendii), fringed myotis (Myotis thysanodes), California wolverine (Gulo gulo 

luteus), Humboldt marten (Martes caurina), pallid bat (Antrozous pallidus), western bumblebee 

(Bombus occidentalis), western pond turtle (Clemmys marmorata), foothill yellow-legged frog 

(Rana boylii), southern torrent salamander (Rhyacotriton variegatus), and northern red-legged 

frog (Rana aurora aurora) (final EA pp. 86-89).

Pacific Fisher (Martes pennanti pacifica, also a Federal Candidate Species).

In northern California, fishers occupy mid-elevation, multi-storied mature and old-growth conifer, 

mixed conifer, and mixed-conifer hardwood forests with contiguous canopy cover. Fishers 

typically select closed canopies (>50%), but use areas of low- to moderate-canopy cover (25 to 

40%), if there is sufficient understory (Lofroth et al. 2010). They do not occur in high-elevation 

alpine or subalpine habitats.

My decision will maintain characteristics for denning, so habitats will continue to provide 

denning habitat immediately post-project. All riparian reserves will be buffered on both sides of 

stream channels and canopy closure will be maintained at 60 percent or greater. Given the lack of 

riparian-vegetation-associated ephemeral and intermittent streamcourses within the project area,

little to no true riparian habitat exists within the units. However, in the long term, project 

implementation has the potential to improve riparian habitat conditions through the release of 

conifer and hardwoods/shrubs from thinning, generating a secondary canopy.

Of the 13,686 acres of fisher denning habitat within the action area, approximately 290 acres 

of low- and moderate-quality denning habitat will be treated. This is approximately 2 percent of 

the denning habitat within the action area—98 percent of the denning habitat in the action area 

will not receive any treatment. No high-quality habitat will be treated.

In 2016, surveys were conducted in the 1st 48 Project area using camera stations. Fisher were 

detected in three (3) areas. Although no den sites were located, limited operating periods (LOPs) 
Finding of No Significant Impact

30 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

will be imposed for all noise- and smoke-generating activities within 0.25 miles of fisher suitable 

habitat around the detection sites (final EA pp 84-86).

Northern Goshawk (Accipiter gentilis).

Goshawks occupy habitat similar to that of the NSO, and are known to use mature forest habitats 

for nesting and foraging. Nesting stands are typically in dense pockets of large trees, often on 

north-facing, bench slopes near water. Foraging habitats are often more open to allow for the 

goshawk’s aerial ambush foraging strategy. While there are approximately 13,686 acres of 

suitable goshawk habitat in the 1st 48 Project area, no goshawks were detected during surveys 

conducted within the project areas in 2017.

No pre-dominant trees (potential nest trees) or dominant trees will be removed. Current 

canopy closure will be maintained. Removal of understory vegetation may improve foraging 

conditions for the goshawk. If nesting goshawks are subsequently found within 0.25 miles of any 

treatment units, LOPs will be imposed. The project may impact individual northern goshawk, but 

will not cause a trend towards listing (final EA pp. 88-94).

Foothill yellow-legged frog (Rana boylii).

The foothill yellow-legged frog is found in or near rocky streams or rivers in a variety of habitats. 

In California, breeding and egg laying usually occur at the end of spring rains, commencing

anytime from mid-March to mid-June. These frogs are diurnal with adults often basking on 

exposed rock surfaces near streams. When disturbed, they dive into the water and take refuge 

under submerged rocks or sediments.

There is suitable habitat for foothill yellow-legged frogs in the project area. In August 2017, 

tadpoles and adult frogs were observed in Littlefield Creek at the low-water crossing at milepost 0.4 

on 2S53. Operations will require commercial log hauling across this crossing. If water is present

during operations, a temporary low-water crossing will be constructed by installing a temporary 

vented ford (two or more 36-inch pipes laid over geotextile cloth on the streambed with fill on top) 

or a temporary bridge, acting to reduce habitat disturbance. The project may impact individuals, but 

will not cause a trend towards listing (final EA pp. 88-94).

Management Indicator Species and Migratory Bird Species.

Under 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” (PL 94-588 §6 (g)(3)(B)). The 1982 regulations implementing 

NFMA require that “Fish and wildlife habitat shall be managed to maintain viable populations of 

existing native and desired non-native vertebrate species in the planning area” (36 CFR 219.19).

Management indicator species (MIS) serve as a barometer for species viability at the forest level.

The SRNF LRMP uses MIS to assess potential effects of project activities on the various habitats 

and habitat assemblages associated with these species. Forty-one (41) fish and wildlife species have 

been selected as MIS or assemblages for a variety of habitats potentially affected by resource 

management activities on the forest (USDA Forest Service 1995 p. IV-97).
Finding of No Significant Impact

Decision Notice & Finding of No Significant Impact – 31

The 1st 48 Project will not adversely impact MIS. Although shaded-fuelbreak construction 

will degrade habitat for species, such as the Pacific wren and ruffed grouse through the removal 

of brush and understory trees, the majority of the project will improve and/or restore habitat 

conditions for all MIS by thinning young, homogeneous stands, accelerating the development of 

multi-storied conditions and other late-successional habitat characteristics. In addition, strategic 

fuelbreaks will help protect existing habitat from stand-replacing fire.

Due to the scope, size, and intent of this project, there are no concerns of negative cumulative 

effects for MIS, migratory bird species (MBS), or other wildlife species. Direct, indirect and 

cumulative effects to MIS and MBS were addressed based on their potential to occur within the 

project area based on habitat suitability, survey results, or incidental sighting records (final EA 

pp. 88-94).

Survey and Manage Wildlife Species.

No wildlife survey and manage (S&M) species occur within the 1st 48 Project; therefore, no preproject surveys were conducted. The 1st 48 Project is in compliance with the Record of Decision for 

amendments to the survey and manage, protection buffer, and other mitigation measure standards 

and guidelines in Forest Service and Bureau of Land Management planning documents within the 

range of the northern spotted owl (USDA and USDI 2001), the April 25, 2013 9th Circuit Court 

Order in Conservation Northwest (and others) v. Sherman (No. 11-35729), and the February 18, 

2014 District Court Order in Conservation Northwest (and others) v. Robert Bonnie (and others)

(W. WA No. C08-1067-JCC) (final EA pp. 91-94).

Survey and Manage Plant Species.

The final EA describes establishing a 0.25-acre buffer (a radius of approximately 50 feet) where 

the Survey and Manage (S&M) lichen species Dendriscocaulon intricatulum was detected in 

2003 within Unit 802 (final EA p. 36). New information from the Six Rivers’ botanist revealed 

the canopy growth of the surrounding white fir forest around the dead oak tree (the common 

substrate for this species) has rendered the habitat unsuitable for D. intricatulum. Since there has 

been a change in habitat conditions, the site is no longer suitable, and the lichen is no longer 

present in the unit, this decision will no longer provide a disturbance buffer in Unit 802.

Travel Management Rule.

In response to countrywide interests and concern for increased future use, the US Department of 

Agriculture (USDA) established new national policy (www.fs.fed.us/recreation/programs/ohv/) in 

2005, to govern the growing use of wheeled motor vehicles on NFS lands by revising travel 

management regulations (Final Travel Management Rule, Federal Register, Vol. 70, No. 216, 

Nov. 9, 2005, pp. 68264-68291). The SRNF’s Subpart A travel analysis (36 CFR 212 –

Administration of the NFTS (National Forest Transportation System)) considered the 

reclassification of NFTS road maintenance levels to better manage motorized travel and restore 

environments altered by past road construction, as well as on-going motorized uses (Six Rivers 

National Forest Roads Analysis Process (RAP), USDA 2003; Mad River Transportation Analysis 
Finding of No Significant Impact

32 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Process (TAP) 2017)4. The maintenance-level (ML) classification correlates to how the agency 

administers the intended use—type of vehicle and season(s), closed or open for travel, and 

maintenance frequency and methods, based upon road design, surface conditions, intended 

vehicle speed, season and amount of motor-vehicle use. Subpart B of the Travel Management 

Rule requires consideration of minimization criteria per 36 CFR 212.55 (a)-(e) and 40 CFR 

1508.20 when making changes to roads open to motor-vehicle use on NFS lands (36 CFR 212.54 

– Revision of Designation of Roads and Trails).

Due to continued environmental impacts informed by monitoring 1.95 miles of FSR 2S54, 

this decision authorizes a reconsideration of its designation as an ML 2 road on the NFTS, 

currently open to public use. A portion of this FSR will be decommissioned and removed from 

the NFTS. There is a large landslide near milepost (MP) 0.65, encompassing the entire road 

prism, making it impassable for motor vehicles. This landslide will not be treated, nor will any 

other decommissioning activities take place beyond the slide. This represents a change to the 

NFTS and will act to revise the SRNF MVUM.

Implementation Date

Implementation of this project is expected to take place from 2018 to 2033. Fuelbreak corridors 

will be maintained up to 15 years.

ELIZABETH A. BERGER Date

Acting Forest Supervisor

Six Rivers National Forest

 4 Travel Analyses: Roads and transportation analyses has been conducted by the SRNF per the six-step process, as 

described in the Roads Analysis: Informing Decisions about Managing the National Forest Transportation System

(FSM 7712.02), and the Forest Service issued the Administration of Forest Development Transportation System final 

travel management rule (36 CFR Part 212). The information from these travel analysis sets the context for developing 

proposed actions to improve the road system. Relevant to the 1st 48 Project, the Mad River TAP recommends 

decommissioning FSR 2S54.