United States Department of Agriculture

Draft Record of Decision

for the 

Inyo National Forest Land Management Plan

Forest Service Pacific Southwest Region R5-MB-304-E August 2018
In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and 

policies, the USDA, its agencies, offices, and employees, and institutions participating in or administering USDA 

programs are prohibited from discriminating based on race, color, national origin, religion, sex, gender identity 

(including gender expression), sexual orientation, disability, age, marital status, family/parental status, income derived 

from a public assistance program, political beliefs, or reprisal or retaliation for prior civil rights activity, in any program 

or activity conducted or funded by USDA (not all bases apply to all programs). Remedies and complaint filing deadlines 

vary by program or incident. 

Persons with disabilities who require alternative means of communication for program information (e.g., Braille, large 

print, audiotape, American Sign Language, etc.) should contact the responsible Agency or USDA’s TARGET Center at 

(202) 720-2600 (voice and TTY) or contact USDA through the Federal Relay Service at (800) 877-8339. Additionally, 

program information may be made available in languages other than English. 

To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, AD-3027, 

found online at http://www.ascr.usda.gov/complaint_filing_cust.html and at any USDA office or write a letter addressed 

to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, 

call (866) 632-9992. Submit your completed form or letter to USDA by: (1) mail: U.S. Department of Agriculture, 

Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, Washington, D.C. 20250-9410; (2) 

fax: (202) 690-7442; or (3) email: program.intake@usda.gov. USDA is an equal opportunity provider, employer and 

lender.

NOTE: We make every effort to create documents that are accessible to individuals of all abilities; however, limitations 

with our word processing programs may prevent some parts of this document from being readable by computer-assisted 

reading devices. If you need assistance with this document, please contact the Pacific Southwest Region Office at (707) 

562-9121.

Cover Photo: Ancient Bristlecone pines. Photo by Leeann Murphy.
Draft Record of Decision for the

Inyo National Forest Land Management Plan

Fresno, Inyo, Madera, Mono, and Tulare Counties, California

and Esmeralda and Mineral Counties, Nevada 

Lead Agency: USDA Forest Service

Responsible Official: Tammy Randall-Parker, Forest Supervisor 

For information, contact: Leeann Murphy 

Resource and Planning Staff Officer, Inyo National Forest

i 

Contents 

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

Distinctive Roles and Contributions ................................................................................................ 1

Purpose and Need and Selected Alternative .................................................................................... 2

Nature of this Decision .................................................................................................................... 3

Engagement with State and Local Governments, Indian Tribes, other Federal Agencies, and 

the Public ......................................................................................................................................... 3

Decision and Rationale for the Decision ......................................................................................... 6

Rationale for the Decision ........................................................................................................... 7

Topic 1: Fire Management and Smoke..................................................................................... 8

Topic 2: Ecological Integrity .................................................................................................... 9

Topic 3: Sustainable Recreation and Designated Areas ......................................................... 12

Requirements of the Planning Rule ........................................................................................ 14

Transition to the Revised Land Management Plan ................................................................. 17

Preliminary Administrative Recommendations ...................................................................... 18

Monitoring Program ............................................................................................................... 20

Alternative Development............................................................................................................... 20

Changes between the Draft and Final Environmental Impact Statements.............................. 21

Alternatives Considered in Detail .......................................................................................... 22

Alternatives Considered but Eliminated from Detailed Study ............................................... 23

Environmentally Preferable Alternative ........................................................................................ 25

Best Available Scientific Information ........................................................................................... 25

Assessment Phase ..................................................................................................................... 25

Planning Phase .......................................................................................................................... 26

Findings Required by Other Laws and Relevant Directives ......................................................... 31

The Effective Date of the Plan Revision ....................................................................................... 36

Administrative Review .................................................................................................................. 36

Contact Person ............................................................................................................................... 37

Signature and Date ........................................................................................................................ 37

Appendix: Recommended Wilderness Areas ................................................................................ 39

References ..................................................................................................................................... 54

Tables

Table 1. South Sierra Wilderness Addition ................................................................................... 39

Table 2. Piper Mountain Wilderness addition ............................................................................... 42

Table 3. White Mountain Wilderness Addition (West) ................................................................. 45

Table 4. White Mountain Wilderness Addition (East) .................................................................. 47

Table 5. List of eligible wild and scenic rivers and their segments, outstandingly remarkable 

values, and length .................................................................................................................. 50

Figures

Figure 1. Inyo National Forest Plan Area ........................................................................................ ii

Figure 2. South Sierra Wilderness Addition .................................................................................. 41

Figure 3. Piper Mountain Wilderness addition .............................................................................. 44

Figure 4. White Mountain Wilderness additions (west and east) .................................................. 49
Draft Record of Decision

Inyo National Forest Land Management Plan

ii

Figure 1. Inyo National Forest Plan Area 
1 

Introduction

This Draft Record of Decision (Draft ROD) documents my decision and rationale for approving 

the 2018 Inyo National Forest Land Management Plan. The decision implements the Forest 

Service’s 2012 Land Management Planning Rule1

 and advances goals of the Department of 

Agriculture, including local economic development and sound land stewardship in partnership 

with communities. 

The Inyo National Forest (also referred to as “the Inyo” or “the Forest”) plays a unique role 

supporting local economies in the eastern Sierra region, and providing clean drinking water and 

recreational opportunities for much of California. 

The Inyo National Forest is located in eastern California, and small portion in Nevada (figure 1).

The Inyo includes the crest and eastern escarpment of the Sierra Nevada from the Mono Basin to 

the Kern Plateau, plus the Glass, White, and Inyo Mountain Ranges. The Inyo encompasses 

approximately 2 million acres, intermixed with 56,481 acres of private and State lands; 26,711 

acres of the Sierra National Forest and Humboldt-Toiyabe National Forests are also administered 

by the Inyo National Forest. 

Distinctive Roles and Contributions 

The Inyo National Forest is characterized by large magnificent mountains that invite and inspire 

visitors locally, regionally, nationally and internationally. This stunning landscape is home to 

well-known attractions such as Mt. Whitney, Mono Lake, the Ancient Bristlecone Pine Forest and 

Mammoth Mountain lava dome complex. The Inyo has diverse ecosystems including portions of 

the Great Basin, Mojave Desert and Sierra Nevada bioregions. 

The Inyo was established in 1907 for the purposes of protecting lands and providing clean water 

to the city of Los Angeles. This critical function continues to this day. The headwaters and 

tributaries originating on the Inyo supply water and electricity to millions of people in local 

communities, such as Mammoth Lakes, and to communities as far ranging as Los Angeles and 

Fresno. Keeping these watersheds healthy, or restoring them where needed, is critical to support 

local and regional water security. Water provisioning activities also provide upwards of 300 jobs 

to the local Inyo County economy. 

The Inyo National Forest contributes significantly to the socioeconomic sustainability of the 

eastern Sierra region. We estimate the national forest supports approximately 3,400 jobs that 

provide $119 million of annual labor income to local communities. A majority of this economic 

activity was derived from visitor spending for recreational visitation on the Inyo, with national 

forest recreation supporting 2,600 jobs and $85 million in income. Long standing recreation such 

as pack stock use, off-highway vehicle use, camping, fishing, hunting, backpacking, and 

mountaineering continue to be important in the area today. Year-round trail use provides the 

means to high-quality recreation from hiking, mountain biking and equestrian use, to skiing, 

snowmobiling, and other motorized uses. 

 

1 36 CFR part 219
Draft Record of Decision

Inyo National Forest land Management Plan

2 

Over 2 million users visit the Inyo yearly with the majority of visitors coming from southern 

California. Recreation provides approximately 2,600 jobs to the local Inyo County economy and 

significant revenue to the local and “gateway” communities surrounding the national forest. The 

high scenic integrity of the area is an important draw for many visitors. Forty-six percent of the 

Inyo (964,360 acres) consists of nine designated wilderness areas, either wholly or partially 

within the administrative boundary of the national forest. 

For thousands of years, the area has been home to several Native American Tribes with deep 

cultural ties to the national forest and surrounding lands. In more recent times, European 

immigrants earned livelihoods from activities such as ranching and mineral prospecting. These 

activities continue on the landscape today, and provide economic contributions, through support 

for an estimated 400 jobs and $16 million in annual labor income, as well as a window into the 

rich history and culture of the area. 

Purpose and Need and Selected Alternative

The proposed action is to revise the 1988 Inyo National Forest Land and Resource Management 

Plan. The existing Inyo Land and Resource Management Plan is almost 30 years old. Over the 

last 30 years, the social, economic, and ecological conditions on the Inyo have changed, resulting 

in a land management plan that is no longer responsive to the needs of local communities and the 

relevant environmental challenges for the area. For example, recreation has expanded becoming a 

dominant economic driver for the area, wildfire has become increasingly more difficult to 

manage, and the demands on resources provided by the national forest, including water for 

millions of people, has been influenced by changing climates, such as drought. These changes, 

combined with the age of the existing land management plan, create a clear need for plan 

revision. 

The need for plan revision correlates to eight overarching issues,

2

 which were identified based on 

our assessments and input from State and local governments, other Federal agencies, Tribes, and 

members of the public. These eight issues were organized for purposes of our analysis into three 

revision topics: (1) fire management and smoke, (2) ecological integrity, and (3) sustainable 

recreation and designated areas. The following summary identifies the broad areas where changes

to the existing land management plan were needed: 

• Reduce the risk of large, high-intensity wildfires on communities and assets such as 

recreation sites and infrastructure and increase the ability to manage wildfires to meet 

resource objectives. At the same time, we need to reduce smoke impacts to communities, at 

least over the long-term. By working toward these goals, the Inyo National Forest will

continue to provide social and economic benefits to people and communities, including 

Tribes. 

• Improve resilience of our diverse terrestrial and aquatic ecosystems to stressors, including 

climate change, wildfire, invasive species, and restore wildlife and plant habitat diversity. 

We also need to apply more recent science to manage fire and fuels treatments, particularly 

on the east side of the Sierras to achieve restoration goals. By working toward these goals, 

we will provide the ecological integrity needed for ecological sustainability.

 

2 (1) Ecological resilience, wildlife habitats, and wildfire; (2) forest resilience and forest density; (3) fuels treatment and

fire management; (4) watershed restoration; (5) protecting aquatic diversity; (6) recommended wilderness; (7) smoke; 

and (8) forest products.
Draft Record of Decision

Inyo National Forest land Management Plan

3 

• Change how we address recreation, including improvement of recreation facilities, 

opportunities, settings and access. Recreation on the Inyo is important for local economies 

and provides enjoyment to local residents and visitors alike, but high volumes of recreation 

also result in impacts to resources and increased demands on existing infrastructure. 

Providing for sustainable recreation is imperative to support social, economic, and 

ecological sustainability on and near the Inyo National Forest. 

• We need to develop plan direction for lands acquired by the Inyo National Forest through 

the Nevada Enhancement Act. 

Nature of this Decision

The purpose of the revised land management plan (also referred to as “the forest plan”) is to 

guide future projects, activities, practices, uses, and protection measures to assure sustainable 

multiple-use management on the Inyo National Forest for the next 15 years. The forest plan is 

strategic in nature. It does not authorize projects or activities, commit the Forest Service to take 

action, or dictate the day-to-day administrative activities needed to carry out the Forest Service’s 

internal operations (such as personnel matters, law enforcement, or organizational changes). The 

forest plan programmatic management direction will be implemented through the design, 

execution, and monitoring of site-specific activities. The decisions for these project-level 

activities must be consistent with the strategic direction set forth in the plan.

The forest plan establishes plan components in the form of desired conditions, goals, objectives, 

standards, guidelines and suitability to provide for ecological integrity and contribute to social 

and economic sustainability, including through provision of ecosystem services and multiple-uses 

of the Inyo National Forest. Through development of plan components and unit-level monitoring, 

we incorporated best available scientific information and created an adaptive management 

framework for implementation. The architecture and components of the plan are intended to 

enable us to adapt to new social and economic opportunities that arise as well as new information 

that comes to us through science and monitoring. 

Engagement with State and Local Governments, 

Indian Tribes, other Federal Agencies, and the Public

Our public participation efforts ensured engagement and collaboration with a variety of 

stakeholders throughout the multi-year plan revision process (2011 through 2017). This provided 

transparency, understanding of the planning process, regular dialogue among different groups, 

and resulted in a plan that is responsive to State, local and other Federal agencies, Indian Tribes 

and the public. We will continue to work with these groups to reach our goals over the next 15 

years.

State and Local Governments and other Federal Agencies 

The Inyo National Forest signed memoranda of understanding with two cooperating agencies: 

Inyo County and the Environmental Protection Agency (EPA). Our memorandum of 

understanding with Inyo County led to better collaboration on developing the plan. As often as 

weekly, we met with County staff to discuss the plan revision with an emphasis on maintaining 

access and multiple uses on the Inyo. As a cooperating agency, the county provided essential 
Draft Record of Decision

Inyo National Forest land Management Plan

4 

information highlighting the contributions national forest activities provide to local economies. 

We worked with the County to determine key locations on the Inyo critical to providing these 

socioeconomic benefits. This information supported the development of a revised forest plan that 

works to sustain national forest benefits that contribute so critically to local communities and 

local economies. The County supports the recommendation for specific areas for inclusion in the 

National Wilderness Preservation System. The County recognizes recreation and recommended 

wilderness as a key economic driver in the area, and supports that the plan does not restrict any 

current uses in the county. 

We also developed a memorandum of understanding with the EPA and met with them in 2015 to 

share progress and get feedback on the draft environmental impact statement alternatives, Tribal 

Relations and Consultation, and how fire management was being addressed in the forest plan 

revision. The EPA was supportive of efforts to increase the pace and scale of restoration and 

concurred with the programmatic approach to forest plan revision. The EPA also provided 

comments on the draft environmental impact statement, encouraging us to look at stewardship 

opportunities for watershed restoration to provide the greatest opportunity for riparian and 

watershed health. 

We engaged the California Department of Fish and Wildlife, the Nevada Department of Wildlife, 

California Department of Forestry and Fire Protection, local air quality boards, Mono County, 

Esmeralda County, Mineral County, and the U.S. Fish and Wildlife Service. By working with 

these groups as we were developing the plan, we were able to address issues early in the revision

process. Such issues included: species considered for the species of conservation concern list; 

smoke impacts to recreation users and the local economy; the importance of managing for 

multiple uses; and the economic contributions of the Inyo. We addressed these issues by including 

species such as desert bighorn sheep as species of conservation concern; analyzing the effects of 

smoke based on the management proposed in each alternative; and including plan components 

that address local communities and the importance of the economic contributions of the national 

forest. 

In developing the plan, we considered relevant county general plans from Fresno, Inyo, Madera, 

Mono, and Tulare Counties in California and Esmeralda and Mineral Counties in Nevada. 

Considerations for incorporation into the forest plan included: (1) the objectives of local 

governments, as expressed in their plans and policies; (2) opportunities for the plan to address the 

impacts identified or to contribute to joint objectives; and (3) opportunities to resolve or reduce 

conflicts, within the context of developing the plan’s desired conditions or objectives. Appendix 

E in the final environmental impact statement (FEIS) describes in detail how the county plans 

were addressed in the final forest plan (FEIS, Volume 2, Appendix E: Consistency with Other 

Planning Efforts). In summary, the final plan (alternative B-modified) was considered consistent

with the County plans and incorporated elements of the following topics: opportunities for

economic development and growth; providing continued tourist and recreation opportunities; 

addressing the need to provide for public safety regarding wildland fires; provide for forest and 

wetland health and habitat for aquatic and terrestrial species; and maintaining multiple uses on the 

national forest.

We consulted with the U.S. Fish and Wildlife Service on four endangered species, three 

threatened species, and one candidate species. We used California Fish and Wildlife and Nevada 

Department of Wildlife data, in addition to other best available scientific information, to help us 

identify species of conservation concern.
Draft Record of Decision

Inyo National Forest land Management Plan

5 

Other forest management issues raised by State and local governments and other Federal agencies 

were: the pace and scale of forest restoration; partnerships and cooperation; the use of fire on the 

landscape; species of conservation concern; and sustainable recreation. The forest plan 

incorporates these groups’ input by including plan components and other plan content that 

emphasize managing for multiple uses, supporting sustainable recreation, and encouraging 

partnerships; the design of our fire management zones; and an increased pace and scale of 

restoration treatments. 

Indian Tribes 

The Inyo National Forest engaged 14 Native American Tribal entities including 9 federally

recognized Tribes (Utu Utu Gwaitu Paiute Tribe Benton Paiute Reservation; Walker River Paiute 

Tribe; Washoe; Big Pine Paiute Tribe of Owens Valley; Timb-isha Shoshone Tribe – Bishop; 

Bishop Paiute Indian Tribe; Bridgeport Paiute Indian Colony; Lone Pine Paiute-Shoshone 

Reservation; and Ft. Independence Community of Paiute Indians). We communicated through 

letters, in-person meetings, e-mails, and phone calls. Phone calls were made by the Forest 

Supervisor or heritage staff. Letters included an open invitation to request formal government-togovernment consultation (for recognized Tribes) or to meet (for nonrecognized Tribes). Big Pine 

and Mono Lake Tribes requested formal consultation in 2014. 

Throughout the plan revision, Tribal members shared input including: comments on wording and 

language; expressing desire for holistic management of ecosystems as entities rather than parts; a 

desire for collaboration between Tribes and the Forest Service in resource management; interest 

in opportunities for Tribal youth engagement and Tribal employment; application of traditional 

ecological knowledge in forest management processes; opportunities for gathering and traditional 

activities; and the important role of fire for healthy ecosystems.

Tribal input became the basis for plan components in several sections of the plan, including: 

Tribal Relations and Uses, Invasive Species, Timber and Other Forest Products, and Fire. 

Comments about fire use helped shape the Strategic Fire Management Zones, which provide 

direction for returning fire to our eastside ecosystems. Engagement with the Tribes also resulted 

in additional field trips to discuss other important topics on the Inyo, including Jeffrey pine 

management, pinyon-juniper expansion into sage-grouse habitat, and priority watershed 

restoration. Tribal youth participated in Jeffrey pine forest restoration, using traditional tools to 

clean understory needle build-up in areas used to gather piaga, a traditional food source. 

Public Participation 

We engaged the public in plan revision by sharing information during in-person meetings held in 

local communities and virtually (via websites, social media and an open wiki). Webinars, 

newspaper articles, feature articles (for Devil’s Postpile National Monument Visitors’ Guide and 

the Yosemite Gateways Partner Newsletter) reached other audiences. We worked with Tribal 

interns for two summers and discussed forest planning and the role the Tribes play. We partnered 

with the Eastern Sierra Interpretive Association on a Latino Outdoor Family Day in 2016, which 

introduced the Inyo National Forest to local Latino families, shared the Forest Service mission, 

interpreted their connection to the national forest, and facilitated discussions about national forest 

management and planning. In July 2016, we hosted a public meeting in Los Angeles devoted 

specifically to youth during the 90-day public comment period for the draft environmental impact 

statement. More than 30 young adults attended. 
Draft Record of Decision

Inyo National Forest land Management Plan

6 

In addition to comment periods required by the 2012 Planning Rule, we asked for input and 

feedback on topics the public was most interested in throughout the planning process: wilderness 

recommendations, wild and scenic rivers evaluations, species of conservation concern, and 

monitoring. We used data gathered through these and formal comment periods to refine plan 

components; improve the plan’s architecture; develop specific, integrated direction for 

sustainable recreation; refine the aquatic-riparian resource management strategy; reevaluate rivers 

considered for inclusion in the National Wild and Scenic Rivers System; and finalize the Inyo’s 

list of species of conservation concern. We also worked with the Eastern Sierra Recreation 

Collaborative, a nongovernment group focused on sustainable recreation for quality of life and a 

tourism-based economy. This engagement strengthened the plan’s emphasis on recreation 

opportunities and management. 

The overall result of our public participation efforts was that forest plan revision was routinely 

discussed with a variety of stakeholders throughout the multi-year process. This provided 

transparency, understanding of the planning process, and allowed for regular dialogue among and 

between different groups. Stakeholders had various opportunities to discuss resource issues with 

Inyo National Forest staff, to provide their ideas, and help shape the forest plan. 

Decision and Rationale for the Decision

I have reviewed the analysis disclosed in the final environmental impact statement and the 

planning record, as well as comments from our State and local government partners, Indian 

Tribes, other Federal agencies, and the public, and considered how the revised plan meets the 

identified needs to change and the requirements of the 2012 Planning Rule (36 CFR part 219). 

Based on this review, I have selected alternative B-modified as described in the final 

environmental impact statement and the accompanying Inyo National Forest Land Management 

Plan. This decision affects the Inyo National Forest, 5,400 acres of the Humboldt-Toiyabe 

National Forest and 25,000 acres of the Sierra National Forest administered by the Inyo National 

Forest.

By this decision, I approve the following: 

• Forestwide desired conditions, objectives, suitability, standards, guidelines and goals that 

meet the social, economic, and ecological sustainability requirements of the 2012 Planning 

Rule and are consistent with the goals and objectives of the Forest Service National 

Strategic Plan (USDA Forest Service 2015). 

• Plan components that apply to management areas including Strategic Fire Management 

Zones, Sustainable Recreation Management Areas, Riparian Conservation Areas, 

Conservation Watersheds, Pacific Crest Trail Corridor, eligible Wild and Scenic Rivers, and 

Recommended Wilderness. 

• Four areas recommended for inclusion in the National Wilderness Preservation System: (1) 

South Sierra Wilderness Addition; (2) Piper Mountain Wilderness Addition; (3) White 

Mountains Wilderness Addition (West); and (4) White Mountains Wilderness Addition 

(East). This recommendation is a preliminary administrative recommendation that will 

receive further review and possible modification by the Chief of the Forest Service, the 

Secretary of Agriculture, and the President of the United States. The Congress has reserved 

the authority to make final decisions on the wilderness designation. Plan implementation is 
Draft Record of Decision

Inyo National Forest land Management Plan

7 

not dependent upon subsequent action related to recommendations for wilderness 

designation. 

• Identification of 73 segments on 32 rivers (241.5 miles) eligible for inclusion in the Wild 

and Scenic Rivers System and plan components associated with their management.

• Plan components that apply to designated areas, including Wilderness, Mono Basin 

National Forest Scenic Area, Wild and Scenic Rivers, Ancient Bristlecone Pine Forest 

(National Protection Area), Pacific Crest National Scenic Trail, Inventoried Roadless Areas, 

National Recreation Trails, Research Natural Areas, Scenic Byways and Wild Horse and 

Burro territories; these are included in the “Designated Areas” section of chapter 3 in the 

plan. 

• The monitoring program for the plan in chapter 4. 

• Identification of 84,795 acres as suitable for timber production. 

• Other plan content such as the description of the distinctive roles and contributions of the 

Inyo National Forest, where scenic beauty includes the highest peak in the lower 48 states, 

Mount Whitney, and where travel and tourism-related industries support over 50 percent of 

the jobs in the counties bordering the Inyo, far exceeding the state average of 15.7 percent. 

Rationale for the Decision 

I chose alternative B-modified because it: 

• Meets the purpose and need for the plan revision, and best responds to the pertinent issues 

and the associated needs for change from the 1988 Land and Resource Management Plan 

with all its amendments. 

• Is broadly supported by State and local governments, tribes, other Federal agencies, local 

communities, non-governmental organizations and other entities. 

• Was developed through a collaborative effort, with frequent engagement with those 

mentioned above, as well as formal cooperating agency status with Inyo County and the 

Environmental Protection Agency, Region IX. 

• Meets the substantive requirements of the 2012 planning regulations (36 CFR Part 219), 

including contributing to the social and economic sustainability of local communities and 

providing for the ecological sustainability of the Forest. 

• Was developed using the best available scientific information, supported by the “Science 

Synthesis to Support Socioecological Resilience in the Sierra Nevada and Southern 

Cascade Range,” a science consistency review, the Inyo National Forest Assessment, and 

scientific references provided by the public. 

The overall approach used included establishment of three sustainable recreation management 

areas, four strategic fire management zones, and several conservation watersheds that are 

designed to achieve outcomes in a more flexible and opportunistic framework. Through 

deliberative planning and integration across spatial and temporal scales, this would achieve 

multiple objectives at once, including safety, forest restoration, recreational opportunities, and 

watershed health. In a similar vein, I considered the locations of wilderness and inventoried 

roadless areas when developing conservation watersheds with the intended result of positive 
Draft Record of Decision

Inyo National Forest land Management Plan

8 

synergistic effects for species and habitats across a broader landscape. The intent is to provide 

greater adaptability to changing conditions in the 21st century. 

My decision responds directly to the needs for change, summarized into three topic areas, and to 

interests and concerns received from State and local governments, Tribes, other Federal agencies

and the public. Alternative B-modified applies innovative approaches and ideas that represent a 

balanced approach to meeting resource goals, and achieving ecological, social and economic 

sustainability over the next 15 years. 

Topic 1: Fire Management and Smoke

Fire Management

The approach to fire management meets the needs for public safety, given that communities are

located immediately next to the national forest, and supports increasing the pace and scale of 

restoration. Components of the final plan (alternative B-modified) related to fire management 

strive to achieve both. The plan establishes four zones (as management areas) with plan 

components associated with them. The zones represent a range of different objectives (protection 

and resource) and conditions (social, ecological, and environmental) in which fires can be 

managed to achieve multiple objectives. 

The final plan (alternative B-modified) emphasizes active management in the form of fuel 

reduction treatments (such as mechanical thinning and prescribed burning) and managing 

naturally ignited wildfires to meet resource objectives when it can be safely done. The riskmanagement approach is consistent with the National Cohesive Wildland Fire Management

Strategy, meeting the three primary goals of restoring and maintaining landscapes, creating fireadapted communities, and responding to wildfires safely and effectively. The long-term goal is to 

move toward conditions more in line with the natural range of variation, recognizing this could 

take several planning cycles (Final EIS, chapter 2). 

Alternative B-modified was selected because it uses a risk-based approach to managing fire and 

corrected underlying data used in the model (Final EIS, chapter 2). This approach spatially 

incorporates large-fire simulations and highly valued resources and assets (such as homes and key 

habitat) to quantify wildfire hazards across the landscape. A geographic information system 

model combined the fire simulations and highly valued resources and assets to identify the four 

fire management zones. The zones indicate where potential damages or benefits from fire are 

likely to occur by considering two factors: the likelihood of a wildfire occurring and the intensity 

at which it would likely burn. The zones identify areas with different levels of risk (low, 

moderate, and high) to assets and natural resources. By identifying these zones and assessing the 

level of risk in advance, it will allow managers to prioritize fuels treatments and identify when 

and where wildfires can be managed to meet resource objectives and achieve desired conditions. 

Conversely, alternatives A and C (in part) do not use the risk-based management approach. These 

two alternatives use the distance-based wildland-urban intermix defense zone which was created 

using a quarter-mile buffer around structures. This method does not consider the vegetation type 

(which directly affects fire behavior) or consider the potential benefits or damages to other 

resources or assets. The other zones in alternative A were not created using the risk-based 

approach and only one zone in alternative C was created using the risk-based approach. The four 

zones identified in alternative B-modified provide a better strategic and risk-based approach by 

assessing the effects of wildfire to highly valued resources and assets (Final EIS, chapter 3). 
Draft Record of Decision

Inyo National Forest land Management Plan

9 

Smoke

My decision responds to stakeholder concerns over the impacts of smoke on visitation and air 

quality. With current conditions, large catastrophic fires produce smoke that has an impact on air 

quality, recreation and visibility, and this situation is expected to continue in the short term. All of 

the plan revision alternatives would increase restoration treatments aimed at moving the forest 

vegetation and fuels toward desired conditions by changing the current situation. Because

alternatives B, B-modified and D use a mechanical approach intended to mitigate unintended 

effects of prescribed fire as well as catastrophic fires, they were preferable to alternative C. Of 

these 3 alternatives, I believe alternative B-modified uses a better balance of fire and fuels 

treatments, which result in more predictable smoke effects and better results for wildlife over the 

long term. 

Topic 2: Ecological Integrity

With elevations ranging from 3,800 to 14,495 feet, there is a variety of ecosystems on the Inyo 

National Forest. Three major biological provinces, the Sierra Nevada, the Great Basin, and the 

Mojave Desert converge in this distinctive area. One of the reasons the Inyo is a “recreation 

forest” is because of the diverse scenic beauty that includes unique and healthy ecosystems, 

which all need to be managed to ensure ecological integrity. 

Terrestrial Ecosystems

Resilience of ecosystems is critically important in the face of fire, drought, and climate change. 

The final plan (alternative B-modified) includes desired conditions for different habitat types to 

guide restoration and ensure ecological conditions are present for plant and animal communities 

in the face of these stressors. In particular, terrestrial vegetation desired conditions strive to 

achieve heterogeneity in age classes and species composition across the Inyo National Forest. 

Best available scientific information was used to determine habitat characteristics and species 

associations. Alternative B-modified also identifies management direction of the unique habitat 

types and species such as sagebrush and pinyon-juniper that occur on the Inyo. In alternative Bmodified, we made a stronger distinction regarding our restoration strategy for sagebrush, 

employing more mechanical means to control woody encroachment since frequent fire regimes 

tend to promote the spread of cheatgrass, a nonnative invasive species. 

Aquatic and Riparian Resources

The final plan (alternative B-modified) incorporates a strategic approach to aquatic conservation, 

which better integrates water, watersheds, and aquatic and riparian resource conservation with 

short- and long-term strategies and tactics (Appendix G, Final EIS). This strategy was developed 

in response to public comments on the draft plan that suggested some confusion over what 

happened to parts of the Aquatic Management Strategy under the Sierra Nevada Forest Plan 

Amendment (2001 and 2004). In addition, in alternatives B and B-modified, we added plan 

components for meadows and fens to better integrate vegetation condition, soils, hydrologic 

function, water quality, and biodiversity. 

In response to the issues raised through public comments, I decided to introduce conservation 

watersheds in alternative B-modified and integrate them with the overall watershed and riparian 

conservation area direction in the plan. The conservation watershed approach focuses 

management toward desired conditions and looks at the broader landscape. This approach is 

consistent with the best available scientific information on aquatic conservation. Conservation 
Draft Record of Decision

Inyo National Forest land Management Plan

10

watersheds are functioning watersheds where aquatic and riparian conservation is prioritized to 

benefit at-risk species and ensure that high quality water for beneficial uses is available over the 

long term. This new approach was shared with the public in July 2017. At that time, six areas 

were proposed as conservation watersheds and were accompanied by new plan components. 

After further review by the Inyo interdisciplinary team and consideration of how these 

management areas interact with other areas on the national forest (like Destination Recreation 

Areas), we updated the plan components. Our intent with these areas was to better provide 

ecological conditions for at-risk species, and to strengthen the association with terrestrial species 

of conservation concern, which would benefit from the habitat connectivity by having larger scale 

refugia in case of stochastic events. To address these issues raised by the team, I decided to 

update the criteria for development of conservation watersheds to better reflect functioning 

watersheds with high water quality for beneficial uses, which benefited both terrestrial and 

aquatic at-risk species. As a result, the plan components will better achieve our objectives for the 

unique setting and ecology of the Inyo by allowing for current uses, such as recreation, and 

providing direction to maintain watershed function for the long term. 

Conservation watersheds are different from critical aquatic refuges, introduced in the Sierra 

Nevada Forest Plan Amendment. As proposed in alternatives A, B, C, and D, critical aquatic 

refuges occur at a smaller spatial scale than conservation watersheds and plan components for 

these management areas are more prescriptive, oftentimes limiting the ability for restoration 

activities needed to provide for at-risk species habitat. I am choosing alternative B-modified and 

the use of conservation watersheds because I want to provide for management of at-risk species at 

a larger, landscape scale, and allow for active restoration, if needed, to benefit these species’ 

habitats, all of which will support maintaining the functionality of these watersheds over the long 

term. 

I also want to ensure that this new approach, and the accompanying plan components, will not 

have negative effects on local economies. Within conservation watersheds, recreation activities, 

like fishing, and rangeland livestock grazing will not be affected. These activities will continue to 

occur and be permitted within these watersheds. Plan components related to these activities 

within riparian conservation areas will still apply within conservation watersheds, as will other 

forestwide and designated area direction (wilderness and rangeland livestock grazing). 

For those species that will no longer be covered under critical aquatic refuge plan direction within 

the final plan (alternative B-modified), there is species-specific plan direction (for example, for

Lahontan and Paiute cutthroat trout). This plan direction will provide for vegetation cover along 

streambanks and limit sedimentation in occupied habitat. This direction complements 

conservation watershed and riparian conservation area direction, and is part of the overall strategy 

for aquatics management. 

Rangeland Livestock Grazing

Rangeland livestock grazing was not identified as a need for change, but the public raised certain 

issues relative to impacts on aquatic and riparian resources. The public was in favor of more or 

fewer restrictions, and there wasn’t broad agreement. While I acknowledge that legacy impacts 

are still present in certain areas, based on monitoring, I believe current management is moving 

toward desired conditions. As a result, grazing direction will only change in the following ways: 

Plan components are updated to reflect the 2012 Planning Rule language and rangeland 

assessment procedures are updated based on updated scientific information. The utilization 
Draft Record of Decision

Inyo National Forest land Management Plan

11

standards in the Inyo’s final plan (alternative B-modified) continue to be based on previous 

standards from the Forestwide Rangeland Standards Amendment (Amendment 6) to the 1988 

Inyo National Forest’s Land and Resource Management Plan. Methodologies on data collection 

and protocols for vegetation and watershed monitoring have been updated and can now be found 

in an Inyo National Forest supplement to the Pacific Southwest Region’s Rangeland Analysis and 

Planning Guide. By using technical guides, we are able to update them more easily in response to 

best available scientific information, which is consistent with 2012 Planning Rule guidance. I 

believe this is the best approach in clarifying our rangeland livestock grazing management 

direction. 

Providing for Plant and Animal Diversity, including At-risk Terrestrial and Aquatic 

Species

There are several important habitat types on the Inyo, such as sagebrush, pinyon-juniper, and 

aspen, which provide ecological conditions for many species. I find alternative B-modified has 

the appropriate plan components to provide the ecological conditions for at-risk species and to 

restore and maintain the diversity of ecosystems needed to maintain viable populations within the 

plan area.

Following direction outlined in the 2012 Planning Rule (36 CFR 219.8 for sustainability and 36 

CFR 219.9 for diversity of plant and animal communities), the final plan under alternative Bmodified includes plan components that address maintaining or restoring ecological integrity of 

terrestrial and aquatic ecosystems. These components occur both at the ecosystem and habitatscale (coarse-scale) and are species-specific (fine-scale). For example, forestwide direction is 

included for sagebrush ecosystems, but additional plan direction was needed to address bi-state 

sage-grouse habitat within the sagebrush ecosystem. 

Based upon the biological assessment, I find that the final plan (alternative B-modified) 

components may affect, and are likely to adversely affect seven federally listed threatened or 

endangered species: Sierra Nevada bighorn sheep, Mountain yellow-legged frog, Sierra Nevada 

yellow-legged frog, Yosemite toad, Lahontan cutthroat trout, Paiute cutthroat trout, and Owens tui 

chub. The U.S. Fish and Wildlife Service is expected to provide a biological opinion determining 

that adopting the forest plan would not jeopardize the continued existence of these species and 

would not adversely modify designated critical habitat.

For the federally listed species on the Inyo, the final plan includes plan components addressing 

specific listed species, such as Sierra Nevada bighorn sheep, Lahontan cutthroat trout, Paiute 

cutthroat trout, Yosemite toad, Mountain yellow-legged frog, and Sierra Nevada yellow-legged 

frog. These components, along with ecosystem components, aid in limiting threats to these 

species, such as from disease or invasive species. Recovery of these species is also addressed in 

the forestwide at-risk species direction, which provides for the ecological conditions to support 

self-sustaining populations. 

The Regional Forester identified 22 terrestrial and aquatic wildlife species of conservation 

concern, and 105 plant species of conservation concern on the Inyo National Forest. As required 

under the 2012 Planning Rule,3

 I find that the final plan components will provide, to varying 

degrees, the ecological conditions necessary to maintain a viable population of each species of 

conservation concern in the plan area. The “Wildlife, Fish, and Plants” section in volume 1 of the 

 

3 36 CFR 219.9(b)(1)
Draft Record of Decision

Inyo National Forest land Management Plan

12

FEIS outlines the ecosystem habitat types and threats for each of the species. In analyzing 

persistence of species of conservation concern, each species was evaluated individually. The 

persistence determinations are summarized in the “Wildlife, Fish, and Plants” section in volume 1 

of the FEIS, and the details are displayed in appendix F in volume 2, including outlining plan 

components that specifically address ecological conditions and threats needed to provide or 

contribute to their persistence.

Although the plan addresses many of the threats identified for species of conservation concern, 

there are several that are not entirely within the control of the Inyo National Forest’s management 

actions. For example, disease risks from domestic sheep on adjacent lands on bighorn sheep 

populations, or introduction of invasive species in special habitats occupied by at-risk plants. 

Topic 3: Sustainable Recreation and Designated Areas

Sustainable Recreation 

The planning process affirmed the importance of outdoor recreation and tourism on the Inyo 

National Forest and the surrounding “gateway” communities. Given increasing visitor use and 

expectations, plan direction needs to provide a framework for managing visitor use now and into 

the future. There are many ways visitors recreate on the Inyo, having many preferences ranging 

from challenging experiences to more tranquil ones. 

In response to extensive public comments on plan direction for sustainable recreation, alternative 

B-modified was developed to include a “zoned” approach for sustainable recreation management. 

While the origin of managing visitor use on the national forests is found in the recreation 

opportunity spectrum approach, the contemporary needs of managers led to the development of 

other frameworks over the decades, such as “limits of acceptable change,” and “visitor experience 

and resource protection,” which address visitor use issues beyond settings. Alternatives B, C and 

D rely completely on the recreation opportunity spectrum to manage visitor use. The approach in

alternative B-modified considers these other frameworks by creating distinct areas that 

complement and strengthen the recreation opportunity spectrum foundation. The plan includes 

components for three spatially distinct management areas ranging from highly developed and 

concentrated (Destination Recreation Areas), to general use (General Recreation Areas), to

remote and challenging (Challenging-Backroad Recreation Areas). 

This approach creates clear expectations to help the public understand where recreation 

opportunities can be found to meet the needs of a wide variety of activities that visitors have 

come to expect on the Inyo National Forest. I believe the approach in alternative B-modified best 

meets the needs for the greatest number of people without compromising ecological 

sustainability. 

Throughout the forest planning process, stakeholders provided input on the winter recreation 

opportunity spectrum. I have considered this input in my decision to complete forest planning 

prior to travel management planning. I believe this approach allows for collaboration with 

partners and stakeholders to assess current conditions and changing designations in developing a 

winter recreation opportunity spectrum. I am including a winter recreation opportunity spectrum 

map that will serve as a baseline for current management and will then be updated if needed once 

travel management planning (subpart C, over-snow use) is complete. The final plan (alternative 

B-modified) also includes an updated summer recreation opportunity spectrum map that responds 

to public comments on errors in that map. 
Draft Record of Decision

Inyo National Forest land Management Plan

13

Partnerships are a key element to helping us accomplish management actions on the Inyo 

National Forest. Partnerships not only bring extra funding opportunities, but can also add 

capacity, especially in recreation. Throughout the planning process, the need for us to increase 

and improve upon partnerships was raised as an important topic. All of the plan revision

alternatives include plan components related to volunteers, interpretation, partners, and 

stewardship. I believe having these components will be key to managing the Inyo, especially in 

terms of outdoor recreation-based tourism, managing impacts, and opportunities in the future. 

Designated Areas

Following a science synthesis, a bioregional assessment, and the Inyo National Forest assessment, 

our proposed action at the very beginning stated that “no new designated areas” were being 

recommended aside from what would be recommended through the wilderness recommendation 

process. I considered information provided by the public relative to current land designations we 

have on the Inyo (such as inventoried roadless areas and designated wilderness) and our 

recommendations through this current decision (recommended wilderness areas and conservation 

watersheds), and believe we have a good balance of land allocations that help meet multiple 

interests and protect resource values. As a result, there was not a need for new designated areas. 

Pacific Crest National Scenic Trail Management Area

My decision on the management of the Pacific Crest National Scenic Trail is based on the unique 

qualities of the trail and its surroundings on the Inyo. The majority of the Pacific Crest Trail is

within or next to designated wilderness or in remote roadless areas within the Inyo National 

Forest. With a few exceptions, the trail is located next to high summer visitor use or developed 

recreation areas in Reds Meadow and Kennedy Meadows. The Pacific Crest National Scenic Trail 

Corridor and associated plan components are designed to protect the hiking and horseback riding 

experiences and the scenic resources of the trail. This direction addresses the new planning 

requirements for designated areas outlined in the Forest Service Handbook.4

There was a wide range of public comments on the draft environmental impact statement 

regarding public use and management activities allowed within the trail corridor. In response, we

analyzed four different corridor sizes, which ranged from 3 feet to up to 4 miles of centerline of 

the trail and the ability of each alternative to protect the resources, qualities, and values of the 

trail. The final plan (alternative B-modified) defines a corridor of the visual foreground of up to 

one-half mile from the trail centerline where visibility is not obscured by terrain. The corridor 

size provides a management emphasis for what is most visually sensitive to the hiker and 

equestrian traveling at slower speeds of travel. The management direction provides for the unique 

characteristics of the Pacific Crest Trail and the associated resource values and qualities of the 

trail.

My decision takes into account the desired conditions for the Pacific Crest Trail on the Inyo. 

Within designated wilderness, specific Pacific Crest Trail direction will not override the 

wilderness management direction but will be complementary. It is with this in mind that I was 

comfortable with management direction of a one-half-mile corridor on either side of the trail. 

Unlike other national forests with sections of the Pacific Crest Trail outside designated 

wilderness, the Inyo’s situation is unique, as the few miles of trail outside designated wilderness 

are located next to wilderness, but occur within high-use recreation areas with supporting 

recreation facilities, such as campgrounds, resorts, and designated roads (such as Kennedy 

 

4 FSH 1909.12, Chapter 20, section 24.43
Draft Record of Decision

Inyo National Forest land Management Plan

14

Meadows and Reds Meadow). Management direction for these areas of the Inyo includes desired 

conditions and suitability determinations that would apply to the one-half-mile corridor; however, 

standards and guidelines would only apply to the Pacific Crest National Scenic Trail itself. This 

allows for flexibility in managing both the recreation facilities that support Pacific Crest Trail 

users and other recreational uses in these areas. Motorized and mechanized use prohibitions on 

the Pacific Crest Trail are existing trail-wide closures are not part of my decision and will 

continue to be implemented. 

The 11.5 miles of road and trails within the Pacific Crest Trail Corridor that are currently 

authorized for motorized and mechanized use will be allowed to continue. This use was 

determined by the 2009 Travel Management decision for the Inyo. Any future designations of 

motorized roads or trails would be accomplished at the project level and would require sitespecific environmental analysis. Similarly, over-the-snow (winter) travel would be determined by 

Subpart C Travel Management Analysis. Future decisions will consider the desired conditions for 

the trail and plan direction that allows for motorized use on designated crossings, on interim 

routes, and on designated roads and trails. 

The final plan (alternative B-modified) is compatible with the Pacific Crest National Scenic Trail 

Comprehensive Plan (1982) and provides desired conditions and components to protect the 

resources, qualities, and values of the trail and allows for other uses that do not substantially 

interfere with the nature and purposes of the trail.

Requirements of the Planning Rule

The final plan has been prepared in compliance with the Forest Service’s 2012 Land Management 

Planning Rule at 36 CFR Part 219. The plan meets the specific Rule requirements at 36 CFR 

219.8 – 219.11 as follows.

219.8 Sustainability

The plan contributes to social and economic sustainability by:

• Facilitating opportunities for local employment and economic development associated with 

recreation and restoration activities. 

• Providing drinking water to millions of people, as well as other beneficial uses of water that 

contribute to economic growth and ecosystem integrity.

• Establishing plan components that support a wide variety of recreational opportunities for 

local, national and international visitors. 

• Advancing collaboration to develop new and additional recreational activities that meet 

emerging interests of the public.

• Providing for Tribal use for artisan and craft materials, medicines, fuel, traditional foods, 

and heritage tourism and recreation. 

• Providing Tribal communities with opportunities for traditional ceremonies and religious 

practices that strengthen the communities’ sense of place and self and providing gathering 

activities on the national forest that contribute to Tribal social, economic, familial, and 

religious well-being. 
Draft Record of Decision

Inyo National Forest land Management Plan

15

• Providing for the continuation of traditional land use activities, including livestock grazing, 

which contribute to the sense of place and provide a window into the rich history of the 

eastern Sierra region. 

• Providing desired conditions, goals, and objectives that maintain and improve watersheds at 

a landscape scale to improve resilience in the face of unforeseen disturbance events like 

fires and flooding. 

The plan provides for ecological sustainability by:

• Providing for ecological integrity by having desired conditions, objectives, standards and 

guidelines to maintain and restore diverse terrestrial and aquatic ecosystems in the Inyo 

National Forest.

• Providing desired conditions for all of the unique habitat types of the Inyo National Forest, 

including composition, structure, function and connectivity of terrestrial and aquatic 

ecosystems, and descriptions of the ecological processes, threats and stressors across these 

systems. 

• Developing strategic approaches to address ecological resilience of Inyo National Forest 

ecosystems, including through strategic fire management zones and a sustainable recreation 

framework, that provide for flexibility and adaptability while considering issues such as 

health, safety, and access. 

• Incorporating a strong focus on maintaining and restoring ecological conditions across 

aquatic and terrestrial habitats over the long term through plan direction linked to an 

aquatic and riparian conservation strategy and to strategic fire management zones. 

Strategies are based on an increasing body of best available scientific literature, supported 

by current geospatial information. 

• Providing the range of ecological conditions needed for many at-risk species across the 

landscape, including through species-specific plan direction (see next section).

• Including standards and guidelines to protect unique ecosystems, such as sagebrush, and 

their associated species.

• Including standards and guidelines to protect air, soil and water quality over the long term.

219.9 Diversity of Plant and Animal Communities

In addition to providing for ecological integrity per 36 CFR 219.8 (above), the plan meets 

the requirements in providing for diversity of plant and animal communities by:

• Identifying management designed to maintain and restore key ecological characteristics of 

important habitats for plant and animal communities, such as sagebrush and special habitats 

like desert springs and fens.

• Addressing key threats to species and habitats from large-scale catastrophic events, 

invasive species, and climate change.

• Identifying management needed for seven threatened, endangered, and candidate species (1 

plant and 6 animal) and 128 species of conservation concern (23 animal and 105 plant 

species) including through species-specific plan components, where needed. 
Draft Record of Decision

Inyo National Forest land Management Plan

16

The plan uses the complementary approach identified in the 2012 Planning Rule to conserve and 

maintain species diversity, which first involves an analysis of the ecosystems on the national 

forest and the species whose habitats are dependent on those ecosystems. The plan components 

for conserving, restoring, or maintaining these ecosystems are referred to as “ecosystem plan 

components” or “coarse filter components.” However, when needed to help protect sensitive 

habitats such as roost sites, additional “species-specific” or “fine filter” plan components were 

used. 

For the federally listed threatened and endangered species on the Inyo and their designated 

critical habitat, the plan includes components that are designed to contribute to their recovery. 

While future restoration projects and activities may affect individual members of a species, the 

long-term outcomes of restoration will provide conditions to improve recovery of these species. 

The plan includes standards and guidelines that will result in reduced effects to individual 

members of species from future projects and activities. For example, within Sierra Nevada 

bighorn sheep habitat, the plan addresses the risk of disease from domestic sheep and goats under 

a standard that would not allow this use where the developed risk assessment shows there is a 

high risk of contact. 

To support this plan revision, the Pacific Southwest Regional Forester identified 105 plants and 

23 animal species of conservation concern in the Inyo National Forest. Several data sources were 

used to compile this list; sources included but were not limited to NatureServe, California Native 

Plant Society, the State Natural Heritage Programs, State Wildlife Plans, and the Regional 

Forester’s list of sensitive species. These sources provided the best available scientific 

information to identify these species and associated ecological conditions. Most species of 

conservation concern habitat needs are met by plan components for aquatic and terrestrial 

ecosystems. For those species or species groups with specific habitat needs or threats, the final 

plan (alternative B-modified) has species-specific plan components to meet those needs. For 

example, bi-state sage-grouse has been addressed through fine-filter components that provide for 

continued persistence in the plan area. 

219.10 Multiple Uses

While meeting the 2012 Planning Rule requirements of 36 CFR 219.8 (sustainability) and 219.9 

(diversity of plant and animal communities), the plan also provides for ecosystem services and 

multiple uses, including outdoor recreation, range, timber, watershed, wildlife, and fish, within 

Forest Service authority and the inherent capability of the plan area by: 

• Ensuring continued dialogue with State and local governments, Tribes, and the public to 

more fully realize the multiple goods and services provided by the Inyo National Forest. 

• Providing fuelwood and other forest products to support local uses through the projected 

wood sale quantity. 

• Providing rangeland for livestock grazing to support livelihoods while also supporting 

ecological integrity of rangelands, riparian conservation areas and fens.

• Providing opportunities for the development of mineral resources, where appropriate. 

• Providing opportunities for hunting and fishing, with their associated cultural and 

socioeconomic benefits.

• Providing desired conditions, objectives, goals, standards, guidelines and potential 

management approaches for multiple uses and ecosystem services in the plan area. 
Draft Record of Decision

Inyo National Forest land Management Plan

17

• Designing sustainable recreation strategies for a range of recreational opportunities, with 

their associated socioeconomic benefits that are responsive to the public. 

• Maintaining and restoring watershed conditions for provision of water for beneficial uses 

through an integrated aquatic and riparian resource conservation approach. 

• Maintaining and restoring vegetation conditions, soils, and riparian areas to ensure multiple 

benefits, including biodiversity, wildlife habitat, and resilience to natural disasters through 

fire management zones and through desired conditions for different vegetation types. 

• Recognizing and protecting historical, cultural and Tribal uses associated with the Inyo 

National Forest.

• Providing access to nature and maintaining scenic integrity through an integrated 

sustainable recreation strategy. 

• Providing desired conditions, objectives, goals, standards, guidelines to maintain 

wilderness character of the designated wilderness areas and providing for those areas 

recommended for wilderness designation. 

• Protecting designated wild and scenic rivers and managing rivers and streams found 

eligible for the National Wild and Scenic River System.

219.11 Timber Requirements based on the National Forest Management Act

While meeting the 2012 Planning Rule requirements of 36 CFR 219.8 through 219.11, the plan 

includes objectives, standards and guidelines, and other plan content regarding timber 

management within Forest Service authority and the inherent capability of the plan area by: 

• Identifying approximately 84,795 acres of land suitable for timber production, mostly in the 

northwest portion of the forest. 

• Identifying lands not suited for timber production (forest plan, Appendix D). 

• Specifying that while timber production is not a primary use for the Inyo National Forest, it 

complements desired conditions for maintaining and restoring ecological integrity and 

restoration. 

• Recognizing that timber harvest may occur on lands not suitable for timber production to 

protect multiple-use values other than timber production, and for salvage, sanitation, or 

public health. 

• Providing timber harvest for purposes other than timber production to contribute to the 

local forest products infrastructure.

• Identifying the Inyo’s sustained yield limit is 40 million cubic feet (MMCF) per decade and 

the projected wood sale quantity is 7 to 9 MMCF per decade (Forest Plan Appendix D). 

Transition to the Revised Land Management Plan

This section addresses project and activity consistency with the final plan (alternative Bmodified) and includes direction for: (a) application to existing authorizations and approved 

projects or activities; (b) application to projects or activities authorized after the plan decision; 
Draft Record of Decision

Inyo National Forest land Management Plan

18

(c) resolving inconsistency; (d) determining consistency; and (e) consistency of resource plans 

within the planning area with the land management plan.5

• Authorizations of occupancy and use made before the revised forest plan will proceed 

unchanged. 

• Regarding previously approved and ongoing projects and activities, whose initiation date 

proceeded the revised forest plan, these projects and activities are not required to meet the 

direction of the revised forest plan and will remain consistent with the direction in the 1988 

forest plan, as amended. 

• The final plan direction will apply to all projects and or activities that have a decision made 

on or after the effective date of the final record of decision. With the exception of those 

projects mentioned in the paragraph above, projects and activities authorized after approval 

of the revised forest plan will be consistent with applicable plan components in the revised 

forest plan. A project or activity approval document will describe how the project or 

activity is consistent with the applicable plan components.

• Any resource plans developed by the Inyo National Forest that apply to the resources or 

land areas within the planning area must be consistent with the plan components. Resource 

plans developed prior to plan decision will be evaluated for consistency and then made 

consistent with the revised forest plan. 

Preliminary Administrative Recommendations

Recommended Wilderness

Based on our analyses and input from local governments, Tribes, and the public, I am 

recommending four additional areas (37,029 acres) for inclusion in the National Wilderness 

Preservation System on the Inyo National Forest. These areas are adjacent to existing wilderness 

managed by the Inyo National Forest or the Bureau of Land Management. These recommended 

wilderness areas are called South Sierra Addition (table 1, figure 2), Piper Mountain Addition

(table 2, figure 3), White Mountains Addition (West) (table 3, figure 4) and White Mountains 

Addition (East) (table 4, figure 4) (see the final environmental impact statement, Appendix B, 

Maps and “Descriptions of Areas Analyzed” section). Plan components provide for managing 

these areas to protect and maintain the ecological and social characteristics that provide the basis 

for each area’s suitability for wilderness recommendation; these plan components can be found in 

chapter 3 of the final Land Management Plan for the Inyo National Forest. 

I arrived at my decision on recommended wilderness after extensive discussions with interested 

stakeholders, including local governments, Tribes and the public. My decision is based on their 

input, in addition to the technical inventory and evaluation process. About 46 percent of the Inyo 

National Forest is designated wilderness. Many members of the public want the wilderness 

characteristics maintained on the Inyo, but were concerned about potential limitations in the types 

of recreational and management options if these areas eventually became wilderness. Others 

voiced support for wilderness designation as a way to ensure long-term protection of the areas. 

Taking into account their input, I considered several additional areas for potential recommended 

wilderness under alternatives B, B-modified, and C. I ultimately decided to recommend the four 

areas in alternative B-modified, which best represent ecological and social characteristics that 

make them eligible for wilderness designation in the National Wilderness Preservation System 

 

5 36 CFR 219.15
Draft Record of Decision

Inyo National Forest land Management Plan

19

(NWPS). These areas not only had good ecological condition where roadless characteristics 

provided opportunities for solitude and primitive and/or unconfined recreation, but also had other 

features of value that set them apart from other areas evaluated in alternative C for wilderness 

designation (table 1, table 2, table 3, table 4). These other features added to the uniqueness of 

these areas, such as the presence of Mojave Desert, oak woodlands, bristlecone pine, or pinyonjuniper woodlands, which are ecologically under-represented in the National Wilderness 

Preservation System. 

I also weighed the needs for protection of at-risk species and the management trade-offs 

associated with management activities that could be greatly reduced based on the constraints of 

the tools allowed and access within recommended wilderness areas. I carefully considered the 

alternatives and their effects on species such as sage-grouse. For example, alternative C, would 

limit our ability to take management actions to favor the species with an additional 315,000 acres 

of recommended wilderness in suitable sage-grouse habitat. 

In addition to the four recommended areas, I considered other ways to meet the interests of 

people who are interested in maintaining wilderness characteristics, but who also articulated 

concern about the potential for wilderness designation to limit future uses for both recreation and 

management. We have since updated the plan to delineate Challenging, Backroad Recreation 

Areas as a sustainable recreation management area intended to provide largely undeveloped 

landscapes suited for dispersed recreation use. This new management area overlaps 84 percent of 

the areas that were potentially recommended as wilderness under alternative C. Management of 

these Challenging, Backroad Recreation Areas would allow for these landscapes to provide 

opportunities for challenging and remote recreation experiences and have a low density of 

infrastructure and designated roads and trails, similar to the solitude and unconfined recreation 

offered in wilderness. Unlike wilderness however, motorized uses along designated roads and 

trails within these areas would continue and motorized opportunities would be managed. 

This recommendation is a preliminary administrative recommendation that will receive further 

review and possible modification by the Chief of the Forest Service, the Secretary of Agriculture, 

and the President of the United States. The Congress has reserved the authority to make final 

decisions on wilderness designation. Plan implementation is not dependent upon subsequent 

action related recommendations for wilderness designation. 

Wild and Scenic Rivers

The number of eligible segments and rivers was corrected between the draft and final plan 

(alternative B-modified) in response to public comments. There are now 73 segments on 32 rivers 

that are eligible for inclusion in the Wild and Scenic Rivers System (table 5 and final 

environmental impact statement, Appendix C, Table C-6). Public comments drove additional 

segments and rivers to be identified as eligible due to information provided on outstandingly 

remarkable values that were not previously identified, new information on changing conditions, 

and corrections to information originally provided in the draft. The forest plan includes 

components for eligible wild and scenic rivers that provide for the continuance of free-flowing 

conditions, water quality, and outstandingly remarkable values identified for each river. 

This recommendation is a preliminary administrative recommendation that will receive further 

review and possible modification by the Chief of the Forest Service, Secretary of Agriculture, or 

the President of the United States. Congress has reserved the authority to make final decisions on 

designation of rivers as part of the National Wild and Scenic Rivers System.
Draft Record of Decision

Inyo National Forest land Management Plan

20

Monitoring Program

The plan monitoring program includes a broad range of monitoring questions and associated 

indicators for specific plan components. A biennial monitoring evaluation report will be prepared 

every other year to indicate whether a change to the forest plan, management activities, or 

monitoring program may be needed, or whether a new assessment may be warranted based on 

new information. 

We made several changes to the final plan (alternative B-modified) monitoring program in 

response to comments we received on the draft document. In particular, we added monitoring 

questions on the subjects of water quality, riparian area function, wilderness character, 

partnerships with volunteers, bighorn sheep habitat, sage-grouse habitat, and large tree snags and 

downed logs. 

The monitoring questions in the plan monitoring program address each of eight required 

monitoring categories6 (see chapter 4 of the forest plan). Within these categories, key ecological 

characteristics in the plan area were identified to focus the available monitoring resources on the 

national forest. For the Inyo, this included the condition of sagebrush, pinyon-juniper, montane 

forest, high-elevation white pines, riparian areas, meadows, and the Inyo’s waterways. In 

addition, key socio-economic metrics were identified in the plan monitoring program. These 

included visitor use and satisfaction, forest economic contributions, local community economies, 

access to the national forest, and partnerships. Furthermore, there are two monitoring questions to 

address the role of fire on the landscape as both a stressor and driver of ecological processes on 

the landscape. The associated indicators for each of the monitoring questions vary from standard 

scientific data collection variables, to management implementation data specific to the Inyo 

National Forest.

6 36 CFR 219.12(a)(4)

Alternative Development

As “early adopters” under the 2012 planning rule, the Inyo, Sequoia, and Sierra National Forest 

planning teams identified the needs to change their land management plans together and 

developed a proposed action based on this need for change. The proposed action identified three

revision topics: fire management and smoke, ecological integrity, and sustainable recreation and 

designated areas. Alternatives were developed in response to issues raised by the public to the 

proposed action. Issues analyzed under these topics included ecological resilience, wildlife 

habitats and wildfire, forest resilience, fuels treatment and fire management, smoke, watershed 

restoration and aquatic diversity, recommended wilderness, and forest products. A table 

comparing the alternatives can be found in the final environmental impact statement Summary.

As noted above, the three national forests (Inyo, Sequoia, and Sierra) initiated plan revision 

together and one draft environmental impact statement was prepared for all three national forests. 

Because the Inyo was not affected to the same degree by changed conditions (specifically 

widespread bark beetle and drought-induced tree mortality) as other national forests in the 

southern Sierra, the responsible official decided in March 2017 to continue progress toward 

completing the Inyo National Forest planning documents, separating its process from that of the 

Sierra and Sequoia National Forests. As a result, the accompanying final environmental impact 

 
Draft Record of Decision

Inyo National Forest land Management Plan

21

statement only addresses the Inyo National Forest. The section directly below highlights other 

changes made between the draft and final environmental impact statements.

Changes between

the Draft and Final Environmental Impact Statements

Comments on the draft environmental impact statement, new information and additional analyses 

resulted in updates to the final environmental impact statement and the final plan (alternative Bmodified). There were significant organizational changes made to provide a reader with a more 

logical layout of plan components. 

Excluding minor editorial changes, clarifications, and typographical errors, modifications are 

summarized here:

• We corrected data used in the fire model. This resulted in an updated spatial configuration 

of fire management zones. Clarification was added that the boundaries of the fire 

management zones are determined by conditions on the ground and are mapped based on 

current conditions. Adjustments to language about the fire management zone maps was 

clarified to show that the Strategic Fire Zones may be made administratively to reflect 

changes on the ground.

• We integrated water, watershed, aquatic, and riparian resource issues into a more cohesive 

strategy. We replaced critical aquatic refuges with conservation watersheds (a management 

area), updated plan components, and described linkages to the Watershed Condition 

Framework and priority watersheds.

• We replaced recreation “places” with three new sustainable recreation zones (management 

areas). We developed new plan components and updated draft components, including plan 

direction for the recreation opportunity spectrum based on stakeholder comments. In 

response to comments, we corrected the summer recreation opportunity spectrum map and 

added a winter recreation opportunity spectrum map. 

• We reassessed eligibility for wild and scenic rivers, based on input from the public, and 

updated the list of eligible rivers. 

• We included appropriate forest plan direction from the Mono Basin National Forest Scenic 

Area comprehensive management plan in the final plan. 

• We clarified range livestock grazing management direction. 

• We updated the Regional Forester’s species of conservation concern list, adding Pacific 

fisher, great gray owl, California spotted owl, Mt. Pinos sooty grouse, dune horsebrush, 

many-flowered thelypodium, rabbit-ear rockcress, and Virgate halimolobos. We removed

fringed myotis bat, Townsend’s big-eared bat, American peregrine falcon, Sierra skipper, 

White Mountains skipper, Atronis fritillary, Denning’s cryptic caddisfly, California sallfly, 

Coyote gilia, hidden rockcress, Alpine slender buckwheat and Lake Tahoe serpentweed. 

During our review of best available science, we discovered previously unknown occurrence 

records for some species, like Pacific fisher, on lands within the Inyo National Forest. As a 

result, it was determined that fisher meets the criteria for species of conservation concern 

status on the Inyo, and it has also been added to the list. 

• We added species-specific plan components for the great gray owl and California spotted 

owl.
Draft Record of Decision

Inyo National Forest land Management Plan

22

• We updated our desired conditions for sage-grouse nesting and brood-rearing habitat based 

on new scientific information. 

• We organized the final plan by resource area, so all relevant plan components can be found 

in one location. 

Alternatives Considered in Detail

The no action alternative (retaining the 1988 plan) and four plan revision alternatives are 

summarized below. A more detailed comparison of these alternatives can be found in chapter 2 of 

the final environmental impact statement. 

Alternative A: No Action (1988 Land and Resource Management 

Plan, as amended)

Under alternative A, the 1988 LRMP and amendments would continue to guide management of 

the plan area. This alternative did not explicitly address ecological, social and economic 

sustainability or climate change.

Alternative B: Draft Forest Plan

Alternative B, the proposed action, was the draft forest plan. This alternative proposed a new 

planning approach based on ecological, social, and economic sustainability, and took climate 

change into consideration. Information gathered from local governments, Tribes, and the public 

during the collaborative process combined with a science synthesis and bioregional assessment 

informed the approaches we used. 

Where appropriate, we carried forward forest plan content still applicable from the 1988 plan, as 

amended. The approach to fire and fuels management changed by replacing the current two 

distance-based allocations in the wildland-urban intermix with four risk based strategic fire zones 

that respond better to advances made in the field of fuels, fire and smoke management. 

Alternative B proposed a management framework that allowed an increase in the amount of 

restoration treatments using multiple techniques to achieve resource objectives and move toward 

desired conditions, recognizing unique habitats like sagebrush. It also incorporated relevant 

findings from conservation strategies for California spotted owls and developed specific plan 

components for sagebrush and sage grouse, building on existing conservation partnerships for the 

species. It replaced plan direction for Forest Service sensitive species with plan direction 

addressing plant and animal diversity, including through species of conservation concern. One 

additional critical aquatic refuge was added in a watershed with high aquatic biodiversity. An 

approach to sustainable recreation using “places” was developed, and plan components for four 

recommended wilderness areas and eligible wild and scenic river segments were included.

Alternative B-modified: Selected Alternative for Final plan

This alternative is the selected alternative for the forest plan. It is fundamentally the same as 

alternative B (the draft plan) with modifications made to respond to public comments and to 

refine the concepts presented in the draft plan. Alternative B-modified would:

• Address sustainability and climate change, as in the draft plan

• Adjust the model inputs for the strategic fire management zones to better account for low 

elevation sagebrush and its natural fire regime and make corrective adjustments for 

habitation information used to develop the Community Wildfire Protection Zone.
Draft Record of Decision

Inyo National Forest land Management Plan

23

• Address ecological integrity in terrestrial and aquatic systems, as in the draft plan, with 

slight modifications, including through development of fine-scale plan components for atrisk aquatic species.

• Develop a more evident aquatic and riparian conservation strategy that addresses watershed 

conditions, including through establishment of conservation watersheds to better ensure 

persistence of at-risk species at a landscape scale and provide for long-term maintenance 

and restoration of functioning watersheds.

• Clarify sustainable recreation direction to address confusion in the draft plan. Changes 

include introducing a three-zone approach to recreation management and developing a 

winter recreational opportunity spectrum map. 

• Recommend the same wilderness as the draft plan and add several additional eligible 

segments of wild and scenic rivers.

• Adjust timber suitability to remove the added eligible wild and scenic river segments and 

riparian conservation areas.

• Adjust rangeland livestock grazing so technical guides are moved outside of the plan into 

an appendix to Regional grazing direction, and clarify relationships among different 

resources affected by and affecting rangeland livestock grazing. 

Alternative C 

Alternative C emphasized wilderness values and a passive management approach to restore fire 

as an ecosystem process, primarily by using prescribed fire and natural disturbance processes to 

achieve desired conditions. It was designed to manage the forest landscape to minimize shortterm impacts on habitats from management activities while accepting the risk of large highintensity wildfires that could affect mature and old forests. It added the most critical aquatic 

refuges and retained previous direction on riparian conservation areas. It also included the most 

areas of recommended wilderness.

Alternative D

Alternative D included an emphasis on increasing the pace and scale of restoration to improve

forest resilience to fire, drought, climate change, insects, and diseases while enhancing economic 

and social sustainability. It increased the intensity of treatments and the amount of area treated 

using mechanical methods combined with larger landscape prescribed burns, allowing more 

removal of trees to address the impact of drought-related stress on the forests. This alternative did

not recommend additional wilderness, and it established the same critical aquatic refuges as the 

draft plan (alternative B).

Alternatives Considered but Eliminated from Detailed Study

Council on Environmental Quality regulations requires Federal agencies to explore and 

objectively evaluate all reasonable alternatives and to briefly discuss the reasons for eliminating 

any alternatives that were not developed in detail.7 Public comments we received in response to 

the proposed plan provided suggestions for alternative methods of achieving the purpose and 

need. Some of these alternatives were outside the scope of what could be included in the revised 

Inyo National Forest Land Management Plan, duplicative of alternatives considered in detail, or 

 7 40 CFR 1502.14
Draft Record of Decision

Inyo National Forest land Management Plan

24

determined to contain components that would cause unnecessary environmental harm. There were 

seven alternatives considered but eliminated from detailed study. For a full description of 

alternatives considered but eliminated from detailed study, see chapter 2 of the final 

environmental impact statement.

Alternative Eliminated 1: Restore over half the landscape within 10-15 years

This alternative was not feasible because it would require more workforce and budget than is 

feasible for the agency based on given budgets in recent years. 

Alternative Eliminated 2: Include all areas identified by the public as 

recommendations for additions to the National Wilderness Preservation System

This alternative was eliminated because the Forest Supervisor determined that it would be 

impractical to manage such a vast wilderness area, if designated by Congress, and the impacts to 

other uses of the land would be greater than the benefits provided by the additional wilderness 

areas.

Alternative Eliminated 3: Identify critical aquatic refuges around all areas of high 

aquatic species diversity

The proposal identified 15 areas on the Inyo National Forest. The staff evaluated these and eight

were included in at least one alternative considered in detail. The remainder were not included 

because they did not appear to substantially increase the habitat protection of existing critical 

aquatic refuges, were located in large part on lands outside of Forest Service jurisdiction, or were 

in watersheds already identified as priorities for restoration. This proposal was eliminated 

because it was not believed to substantially improve benefits suggested. 

Alternative Eliminated 4: Evaluate an alternative that has minimal active 

management and “let nature take its course.”

This “hands off” approach was contrary to the best available scientific information that 

recommends a combination of active and passive restoration for many ecosystems that are outside 

their natural range of variation, and would not have met the requirements of the 2012 Planning 

Rule that calls for providing for ecological integrity and contributing to social and economic 

sustainability. 

Alternative Eliminated 5: Apply the Aquatic Conservation Strategy from the 2001 

Sierra Nevada Forest Plan Amendment

The essential components of the original 2001 aquatic management strategy are included in 

alternative A (the 1988 plan), and much of the intent of the strategy is included in the selected

alternative (B-modified), updated to be consistent with requirements under the 2012 Planning 

Rule.

Alternative Eliminated 6: Consider the document “National Forests in the Sierra 

Nevada: A conservation strategy” as an alternative

Many concepts presented in this document are already in place under the current forest plan, 

some will be incorporated into the planning process, and others are largely consistent with the 

forest plan. However, this alternative does not meet the 2012 planning regulations that require 

plans to provide for social, economic and ecological sustainability and it does not adequately 

meet the Multiple Use Sustained Yield Act.
Draft Record of Decision

Inyo National Forest land Management Plan

25

Alternative Eliminated 7: Allow existing motorized and mechanized uses to 

continue in recommended wilderness

The use of motorized and mechanized transportation in recommended wilderness affects the 

wilderness characteristics of undeveloped settings, and such uses could only be allowed if they

did not prevent the protection and maintenance of the social and ecological characteristics that 

provide the basis for wilderness designation. Because of these potential impacts and the difficulty 

of monitoring, this alternative was eliminated.

Environmentally Preferable Alternative 

The environmentally preferable alternative is that which causes the least harm to the biological 

and physical environment and best protects, preserves historic, cultural and natural resources. 

Alternative B-modified is the environmentally preferred alternative. When compared to the other 

alternatives it best contributes to ecological, social and economic sustainability. Alternative Bmodified helps advance desired conditions for the Inyo National Forest by establishing strategic 

fire management zones, by focusing on the most important watersheds for at-risk species through 

the conservation watershed approach, by continuing to provide and promote socioeconomic 

development, by maintaining cultural and historic uses of the national forest, and by providing for 

future outdoor recreational activities and uses by diverse populations.

Best Available Scientific Information

The 2012 Planning Rule requires the responsible official to document how the best available 

scientific information was used to inform the assessment, the plan decision, and the monitoring 

program.8

 During the planning process for the Inyo National Forest’s plan revision, we identified 

best available scientific information and incorporated it at numerous steps. While several of these 

process steps had overlapping timeframes during the planning process, each served to 

complement the other with each successive phase. 

Assessment Phase 

The planning process unofficially began with the preparation of a Bio-Regional Assessment

(USDA 2014). While a Bio-Regional Assessment is not a requirement of the 2012 Planning Rule, 

it was written to inform and guide development of each national forest assessment within its 

boundaries. The Sierra-Nevada Bio-Regional Assessment includes the entire Sierra Nevada 

mountain range, as well as the parts of the Southern Cascades, Great Basin, White Mountains and 

Modoc Plateau located in California. The Bio-Regional Assessment described resource conditions 

and trends over this large continuous geographic area, including the Inyo National Forest. The 

Bio-Regional Assessment focused on five themes: water quality and quantity, fire resilience, 

sustainable recreation, ecological integrity, and community resilience. Information in the draft 

version of the Science Synthesis (discussed below) was also integrated into the Bio-Regional 

Assessment. Additional information was gathered during the preparation of the Bio-Regional 

Assessment through two collaborative processes with external stakeholders: the Sierra Cascade 

Dialog and Living Assessment wiki site. The Sierra Cascade Dialog began in the lead up to the 

release of the 2012 Planning Rule. It included a series of meetings held between 2010 and 2015 

across California with members of the public. The goal of this Dialog was to create a shared 

 

8 36 CFR 219.6(a)(3) and 219.14(a)(4)
Draft Record of Decision

Inyo National Forest land Management Plan

26

understanding of forest management by bringing together engaged stakeholders with different 

perspectives. The Living Assessment was a collaborative and interactive website where users 

could contribute information and knowledge on the condition and trend of the 15 national forest 

assessment topics. The shared information on this website helped guide the development of the 

Inyo National Forest Assessment (USDA Forest Service 2013).

We prepared the Inyo National Forest Assessment in accordance with the 2012 Planning Rule 

regulations.

9 Unlike the Bio-Regional Assessment, the Inyo Assessment was focused only on the 

plan area. Like the Bio-Regional Assessment, the Inyo Assessment used peer-reviewed scientific 

information as well as other sources of accurate, relevant, and reliable information such as U.S. 

Forest Service expert opinion and public feedback to best address conditions and trends of the 15 

assessment topics. 

A Science Synthesis (Long et al. 2014), was prepared by a team of scientists from the Pacific 

Southwest Research Station along with scientific contributors from outside of the U.S. Forest 

Service. Unlike the Inyo Assessment, which collected a range of scientific information from 

many sources to specifically address the 15 assessment topics, the Science Synthesis focused on 

presenting recently published peer-reviewed literature. The Science Synthesis integrated this 

accurate and reliable peer-reviewed scientific information across relevant disciplines for the 

Sierra Nevada and Southern Cascade Range on six focal topics: forest and fire ecology, soils, 

aquatic ecosystems, forest carnivores, air quality, and socioecological systems. The two-volume 

Science Synthesis served as a foundation of information from which the Forest Service and 

stakeholders could evaluate land management options—including serving as a basis for 

evaluating NEPA alternatives—by focusing on the key ecological processes. The Science 

Synthesis did not include the Great Basin areas of the Inyo National Forest, hence it did not 

address key habitat types like sagebrush and pinyon-juniper. However, the Inyo staff developed

separate supplemental reports to specifically cover these habitat types and this information was 

included in the planning process.

Planning Phase

The Bio-Regional Assessment, Inyo National Forest Assessment, and Science Synthesis as well 

as the need-to-change document (prepared after the Inyo Assessment), contributed current and 

relevant information for preparation of the draft forest plan and draft environmental impact 

statement. In particular, the issues and topics identified in these documents formed the basis for 

the plan components found in the forest plan. In May 2016 we prepared a summary table of the 

references used as best available scientific information that we considered accurate, reliable, and 

relevant to the environmental impact statement and forest plan. We shared this information with 

the public, and incorporated it into the planning record. This summary table was updated in 

response to modifications to the forest plan, public comments, and Science Consistency Review 

(described below). Along with this best available scientific information determination, 18 

additional supplemental reports were made public on the Inyo National Forest’s website in May 

2016. These supplemental reports covered all the relevant major resource areas and were used to 

support the analysis in the environmental impact statement and forest plan. 

Following publication of the draft environmental impact statement, a panel of U.S. Forest Service 

and external scientists prepared a Science Consistency Review Report (Ritchie et al. 2016). This 

report reviewed the scientific information presented in the draft environmental impact statement

 9 36 CFR 219.6
Draft Record of Decision

Inyo National Forest land Management Plan

27

on the eight main ecological topics, with a focus on four review subtopics: (1) scientific 

relevance; (2) accurate and reasonable interpretation of scientific information; (3) 

acknowledgement and documentation of scientific uncertainty; and (4) identification of relevant 

management consequences. Within this report, each reviewer provided specific ratings on these 

topics and subtopics, along with clarifying comments. The panel and authors held a meeting to 

discuss the review in October 2016. Feedback in the report and from the meeting was

incorporated into the plan documents between the draft and final stages. 

Within the forest plan and environmental impact statement, additional determinations were made 

for each of the major resource areas to further refine and apply the best available scientific 

information as the documents were written. These determinations involved a process-specific set 

of decision steps to evaluate all of the scientific information within the context of the plan 

components and the three best available scientific information criteria, which are “accurate, 

reliable, and relevant” to the issues being considered.

10 In particular, these evaluations were

necessary for topics where the science may have contradictory information. Below is a synopsis 

of how these determinations contributed to plan direction. 

10 36 CFR 219.3

Scientific Information related to Vegetation Management

An earlier publication, “An Ecosystem Management Strategy for Sierran Mixed-Conifer Forests” 

(North et al. 2009), served as the foundation for much of the planning direction on forest 

vegetation management. This summary of recent scientific literature presented a conceptual 

approach for forest management using silvicultural prescriptions (such as fire and thinning) to 

restore stand structure and density. Then, in 2012, a companion publication “Managing Sierra 

Nevada Forests” (North 2012) was released to fill-in management gaps that were identified 

during implementation. Using observational information collected during field visits and more 

recent publications, it provided summaries of a range of forest management topics including fuels 

and wildlife. This information was used to inform the plan direction related to habitat diversity 

including the need for a mosaic of resilient vegetation types at multiple scales across the plan 

area. Relatedly, fire has been identified as a key ecological process in fire-adapted ecosystems. 

Scientific Information related to Fire Management

Fire ecology, management, and risk assessment were a major theme during the Inyo National 

Forest’s planning phase. Recently, many peer-reviewed scientific publications on fire ecology 

have identified that the return of fire to dry forests restores ecological processes and maintains 

biodiversity. The subset scientific information determined to be the best available scientific 

information was compiled in a fire ecology reference list and incorporated into the planning

record. Management approaches, as described in North et al. 2009 and North 2012, also continue 

to be refined using this scientific information. In particular, better remote sensing technology and 

geospatial analytical tools (such as geographic information systems or GIS) provided a more 

robust risk assessment in the plan area than previously attempted. Improvements in climate 

modeling science also allowed for detailed analysis of fire emissions (both treatments and 

wildfire) under various scenarios (Hurteau et al. 2014). Consequently, this detailed geographic 

information and the pre-assessment of fire risks along with benefits were used to create specific 

Strategic Fire Management Zones. The plan direction included four strategic fire zones, each with 

 
Draft Record of Decision

Inyo National Forest land Management Plan

28

management options tailored to the zone: Community Wildfire Protection Zone, General 

Wildfire Protection Zone, Wildfire Restoration Zone, and Wildfire Maintenance Zone. 

Scientific Information related to At-risk Species

The evaluation of at-risk plant and wildlife species involved an iterative process of using both 

readily available scientific information and internal Forest Service databases. Initial information 

on at-risk species11 was compiled using U.S. Fish and Wildlife Service publications such as 

recovery plans, Forest Service databases such as NRIS, California Department of Fish and 

Wildlife occurrence data from the California Natural Diversity Database, peer-reviewed 

publications, NatureServe Explorer Database, external expert opinion, and local knowledge of 

national forest staff. This information was evaluated and then used to develop supplemental 

specialist reports that later served as the basis for preparing the environmental impact statement 

and forest plan. 

The species of conservation concern identification process used best available scientific 

information to determine if there is a substantial concern about the species’ capability to persist 

over the long term in the plan area. This process took the information compiled in the initial 

phase and applied threat status rankings. These rankings were based primarily on NatureServe 

data, and included species identified as being a high priority by local governments (such as State 

of California and federally recognized Tribes). During public feedback on the Regional Forester’s 

recommended lists of species of conservation concern and the identification process that was 

used, the public provided additional sources of information including additional published 

literature and observational data. These additional data were reviewed and incorporated when 

they were determined to be accurate, reliable, and relevant. Consequently, the great grey owl and 

California spotted owl were included on the species of conservation concern list for the Inyo plan 

area. Two species of conservation concern determinations were considered controversial: blackbacked woodpecker and goshawk. The decision not to include them on the species of 

conservation concern list was made based on the most accurate, reliable, and relevant scientific 

information for the plan area, including no indication for substantial concern based on their 

existing range and habitat factors in the plan area. 

11 Federally listed threatened and endangered species, including proposed and candidate species, as well as nonlisted 

species meeting criteria to be considered as potential species of conservation concern. 

Scientific Information related to Aquatic and Riparian Management

The development of an aquatic and riparian strategy occurred between the draft and final phases 

of the forest plan and environmental impact statement in response to public comment on the draft 

plan. The Aquatic and Riparian Strategy was adapted from the Aquatic Management Strategy of 

the Sierra Nevada Forest Plan Amendments (USDA 2001 and 2004) and modified using recent 

scientific publications. In particular, the aquatic strategy used the principles outlined by Moyle 

(1996) for the Sierra Nevada Range, in addition to findings from Rieman et al. (2010), Rieman et 

al. (2010), Hessburg et al. (2015), and Reeves et al. (2016). The strategy also incorporated 

methods used by the National Fish Habitat Partnerships to establish a more landscape-scale 

approach characterized by an integration of plan components for riparian conservation areas, 

conservation watersheds, and overall watershed direction. Conservation watersheds replaced 

critical aquatic refuges found in the Sierra Nevada Forest Plan Amendment that were carried 

forward in the draft forest plan. Still there was some overlap between the two managed areas. 

 
Draft Record of Decision

Inyo National Forest land Management Plan

29

While conservation watersheds and critical aquatic refuges are similar in concept (to provide 

additional protection to watersheds with high biodiversity) the scientific approach was different. 

Unlike critical aquatic refuges, conservation watersheds focused on identifying large watersheds

adjacent to, or otherwise connected with, similarly managed watersheds to augment the overall 

resilience of the ecosystem. In particular, conservation watersheds included some of the highest 

quality waters on the national forest based on the Watershed Condition Framework (USDA Forest 

Service 2011) analysis. The management strategy is to invest in the maintenance and protection 

of these large, high-quality watersheds first, rather than restoring degraded watersheds first. The 

decision to remove critical aquatic refuges was controversial because they have been a longstanding part of the plan area. However, the fragmented nature of critical aquatic refuges, in 

conjunction with their generally small size, was determined not to be the best approach to 

maintain and restore aquatic resources for the Inyo National Forest into the future, especially

given the increasing frequency of large catastrophic events. In addition, the Aquatic and Riparian 

Strategy elements are enhanced by scientifically based plan components that focus on individual 

or groups of species.

Scientific Information related to Recreation Management

The sustainable recreation framework was revised between the draft and final environmental 

impact statements based on public comment and the expert opinion provided in the Science 

Consistency Review. In particular, the recreation opportunity spectrum (Clark and Stankey 1979) 

approach was modified to include more contemporary information based on an increasing number 

of visitors and changing visitor uses. The plan used the recreation opportunity spectrum in 

conjunction with the concept of places to establish a clearer three-zone management approach to 

sustainable recreation. 

Scientific Information related to Range Management

Range direction did not change between the draft and final plan, but how the direction was 

incorporated into the final plan changed. Methodologies on how to gather data to determine 

utilization standards was removed from the draft plan appendix and put into a supplement to the 

Pacific Southwest Region Rangeland Analysis and Planning Guide (R5-EM-TP-004). The final 

plan language for grazing more clearly separates plan direction from the project-level 

implementation of the program. A number of public comments indicated that the scientific 

information used in the grazing standards were old and no longer valid. In response, the 

supplement was updated with additional references. Still, current grazing standards were not 

identified as a need-to-change during the scoping period. Implementation of the grazing standards 

in permitted grazing allotments will need to comply with the standards and guidelines set forth in 

the plan direction. Publically available project-level compliance monitoring and plan-level 

effectiveness monitoring will be used to ensure progress towards the intent of the plan and 

validation of the identified best available scientific information.

Monitoring

The monitoring questions and associated indicators found in the plan monitoring program were 

developed using best available scientific information for each of the eight required categories.

12

Because the central focus of the plan monitoring program is on key ecosystem conditions, the 

monitoring questions are based on many of the same sources of scientific information used to 

develop the relevant plan components. Meanwhile, development of the associated indicators 

 12 36 CFR 219.12(a)(5)
Draft Record of Decision

Inyo National Forest land Management Plan

30

required additional sources of scientific information to identify the most accurate, reliable, and 

relevant indicators.

Water Resources

The water resources and watershed condition indicators are based on two well-established Forest 

Service programs: the Watershed Condition Framework (USDA Forest Service 2011) and 

National Best Management Practices for Water Quality Management on National Forest System 

Lands (USDA Forest Service 2012). Both programs involve a rigorous evaluation of defined 

conditions related to ecological condition and management actions to produce a qualitative rating. 

While these ratings are qualitative, they have been consistently implemented across large spatial 

and temporal scales, which provides a basis from which to track changes.

Terrestrial and Aquatic Ecosystems

The selected terrestrial and aquatic ecosystem conditions13 described in the plan monitoring 

program were chosen because of their important role in the conservation and management of the 

Inyo National Forest. In particular, monitoring questions and associated indicators were written 

for the key ecosystems within the plan area that were not addressed adequately in other sections 

of the plan monitoring program, including: large trees, pinyon-juniper woodlands, sagebrush 

communities, waterbodies, and riparian areas, including meadows. These indicators are based on 

standard field sampling approaches to track changes, including: spatial extent, structure, 

composition, disturbance events, and health. For meadows, the indicators are part of the

monitoring requirements following plan direction and the forest’s supplement to the Rangeland 

Analysis and Planning Guide (R5-EM-TP-004) sampling. For riparian areas, the indicators 

included an established approach based on the Proper Functioning Condition (PFC) Assessment 

for Lotic Areas (Dickard et al. 2015), which was develop by the Bureau of Land Management in 

cooperation with the Forest Service and Natural Resources Conservation Service. While 

qualitative in nature, the proper functioning condition assessments have been carried out by the 

Inyo National Forest for years and provide a consistent baseline. The indicators of water quality 

are well established metrics and have been coordinated with the California State Water Resources 

Control Board. 

Focal Species

The requirement for focal species is new to the 2012 Planning Rule and is intended to provide 

inferences into the integrity of the larger ecological system. The Inyo National Forest selected 

two focal species; one aquatic and one terrestrial. Nonnative invasive grasses are an undesirable 

species, so their selection as a focal species seems counter-intuitive. However, by tracking the 

status and trends in spatial extent and percent cover of non-native grasses, we will be able to infer 

adverse impacts to sagebrush ecosystems (Chambers et al. 2007), sage-grouse habitat (Knick and 

Connelly 2011), and their relationship with fire dynamics. Benthic macroinvertebrates were 

selected as a focal species for aquatic systems because of their long record as indicator species for 

water quality and collaboration with the State Water Resources Control Board (Mazor et al. 

2016). 

Recreation and Wilderness

Indicators for visitor use and satisfaction are based on the Forest Service’s National Visitor Use 

Monitoring program (English et al. 2002). The program is the national standard for monitoring 

 13 36 CFR 219.12(a)(5)(ii)
Draft Record of Decision

Inyo National Forest land Management Plan

31

how, who, and why visitors use national forest lands. Because wilderness areas comprise a high 

proportion of the plan area, the monitoring of wilderness character was included in the plan 

monitoring program. The selection of wilderness performance measures and elements is based on 

the established national framework (Landres et al. 2005). 

Climate Change

Monitoring changes to the climate are critical to the Inyo National Forest given the semi-arid 

environment and high-elevation mountain ranges. As a result, the selected monitoring questions 

and indicators focused on key drivers and stressors in the plan area. The selection of white pine 

extent, health, and regeneration was based on long-running research programs in the region that 

have tracked the status and trends of these important high-elevation species. The support of 

aquatic ecosystems and the delivery of large volumes of high quality water from the plan area to 

municipalities across southern California are critical services provided by waterways in the Inyo 

National Forest. Consequently, tracking changes to the flow regimes for select waterways was 

determined to be a relevant indicator. Fire is both a stressor and ecological driver of forests and 

rangelands. The selection of indicators for changes to fire regimes (such as fire return interval 

departure and fire severity) was based on the most recent information being collected by scientists 

in the region (Miller et al. 2009(a)(b), Meyer 2013(a)(b), Safford 2013, Safford and Van de Water 

2014, Steel et al. 2015). 

Economic Contributions

The economic monitoring questions and associated indicators are based on economic principles 

and publically available datasets (Headwaters Economics 2018). The complementary approach of 

tracking both the contributions from the national forest and the conditions of the communities that 

depend upon it is considered the most accurate approach. The economic health and diversity 

monitoring indicators include identifying the relevant sectors and models to track these data. In 

particular, the IMPLAN modeling system (IMPLAN Group 2016) has been reliably used since 

1996 and generated hundreds of peer-reviewed citations. 

Productivity of the Land

Per the National Forest Management Act, the productivity of the land monitoring question was 

included to assess the status and trend of soil conditions in relation to pre- and post-timber 

management activities. The associated indicators are based on the Forest Soil Disturbance 

Monitoring Protocol (Page-Dumroese et al. 2009). This protocol has been developed and refined 

for the Forest Service to deliver consistent, comprehensive, high-quality, monitoring data for 

timber management activities. 

Findings Required by Other Laws and Relevant 

Directives

I have considered the statutes governing management of the Inyo National Forest, and find this 

decision meets our obligations to the current statutory duties of the Forest Service. Following are 

summaries of how the revised forest plan addresses the relevant laws and executive orders.
Draft Record of Decision

Inyo National Forest land Management Plan

32

National Environmental Policy Act of 1969 

The National Environmental Policy Act requires public involvement and consideration of 

potential environmental and social effects of implementing Federal actions. I find that the 

environmental analysis and public involvement process complies with each of the major elements 

of the requirements set forth by the Council on Environmental Quality14 for implementing the 

Act. These include (1) considering a range of reasonable alternatives, (2) disclosing cumulative 

effects, (3) insuring the integrated use of the natural and social sciences, (4) considering longterm and short-term effects, and (5) disclosing unavoidable adverse effects. 

The final environmental impact statement considers a range of alternatives, including five 

alternatives considered in detail and seven additional alternatives considered but eliminated from 

detailed study (see chapter 2 of the final environmental impact statement). Alternatives were 

developed and revised based on robust public involvement, including public input and comment. 

The final environmental impact statement discloses cumulative effects of each alternative by 

evaluating past, present, and reasonably foreseeable future actions in the planning area. 

Moreover, although non-federal lands are outside the scope of this decision, effects from their use 

have been considered in the final environmental impact statement to a degree appropriate for a 

programmatic environmental analysis document at this scale. The final environmental impact 

statement also makes use of the best available scientific information. This use has been reviewed 

using a science consistency evaluation process that considered the quality of the information 

used, how the information was used, and whether risk and uncertainty were acknowledged. The 

available scientific literature was used to help estimate environmental consequences. Complex 

vegetation and wildlife habitat models were employed to better understand the relationships 

between management actions and potential impacts to forest vegetation and wildlife habitat. 

The final plan (alternative B-modified) adopts all practical means to avoid or minimize 

environmental harm, including plan components to provide the ecological conditions needed to 

support biological diversity and standards and guidelines to mitigate adverse environmental 

effects that may result from implementing various management practices. The final plan includes 

a monitoring program and an adaptive management approach to assure needed adjustments are 

made over time.

My decision does not directly authorize any ground-disturbing activities or projects; future 

ground-disturbing activities and projects will be consistent with the final plan and subject to 

additional site-specific public involvement, environmental analysis, and pre-decisional review 

processes. Therefore, the final plan is fully compliant with the National Environmental Policy Act 

and Council on Environmental Quality implementing regulations.

14 40 CFR 1500-1508

National Forest Management Act

The National Forest Management Act requires the development, maintenance, amendment, and 

revision of land management plans for each unit of the National Forest System. These plans help 

create a dynamic management system so an interdisciplinary approach to achieve integrated 

consideration of physical, biological, economic, and other sciences will be applied to all future 

 
Draft Record of Decision

Inyo National Forest land Management Plan

33

actions on the unit.15 Under the Act, the Forest Service is to ensure coordination of the multiple 

uses and sustained yield of products and services of the National Forest System.

16

The National Forest Management Act requires the Secretary of Agriculture to promulgate 

regulations for developing and maintaining forest plans. On April 9, 2012 the Department of 

Agriculture issued a Final Planning Rule for National Forest System land management planning 

(36 CFR Part 219; refer to the Federal Register at 77 FR 68, pages 21162-21276). 

My review of the planning process, the final environmental impact statement, and the information 

provided in the Record of Decision (see sections titled “Rationale” and “Substantive 

Requirements of the Rule”) indicate the final plan and its preparation meet requirements for 

revising plans under the provisions of the 2012 Planning Rule and is fully compliant with the 

National Forest Management Act. 

Endangered Species Act 

The purpose of the Endangered Species Act is to provide a means whereby the ecosystems upon 

which endangered and threatened species depend may be conserved and to provide for the 

conservation of such endangered and threatened species. Section 7(a)(1) of the Act requires 

Federal agencies to carry out programs for the conservation of listed species. In addition, the 

Endangered Species Act requires Federal agencies to ensure that any agency action does not 

jeopardize the continued existence of the species (section 7(a)(2)). The Act also requires the U.S. 

Fish and Wildlife Service and Forest Service, respectively, to base the biological opinion and 

subsequent agency action on the use of best scientific and commercially available data.17

In accordance with section 7(c) of the Act, U.S. Fish and Wildlife Service identified the listed and 

proposed threatened, endangered, or candidate species that may be present on the Inyo National 

Forest. The Forest Service prepared a biological assessment for the final plan, and a biological 

opinion will be issued by the U.S. Fish and Wildlife Service regarding effects of implementing 

the plan on the threatened, endangered, and candidate species present on or near the national 

forest. As of release of this draft record of decision we are expecting a final biological opinion 

that will determine adopting the forest plan would not jeopardize the continued existence of 

federally listed species and would not adversely modify designated critical habitat. 

Multiple-Use Sustained-Yield Act

The Multiple-Use Sustained-Yield Act requires National Forest lands to be administered to 

provide for multiple uses such as recreation, range, timber, watersheds, wildlife, and fisheries. 

The final plan establishes a strong multiple use framework by providing plan components related 

to ecosystem structure, process, and function; wildlife and fisheries; recreation; traditional and 

cultural resources; livestock grazing; forest products; special uses; mining and minerals 

extraction; and energy transmission and development. Therefore, the final plan is fully compliant 

with the Multiple-Use and Sustained-Yield Act.

 15 16 U.S.C. 1604(b), (f), (g), and (0) 16 16 U.S.C. 1604(e)(1) 17 16 U.S.C. 1536(a)(2)
Draft Record of Decision

Inyo National Forest land Management Plan

34

Clean Water Act

The final plan contains plan components to provide for the maintenance or improvement of water 

quality in the streams and waterbodies of the Inyo National Forest. Overall, implementation of the 

final plan is expected to contribute to protecting or restoring the physical, chemical, and 

biological integrity of water resources of the Inyo in accordance with the Clean Water Act, and 

satisfies all State water quality requirements. I base this finding on the extensive standards and 

guidelines contained in the final plan, the application of State and nationally approved “Best 

Management Practices” specifically designed to protect water quality, and the aquatic and 

riparian strategy, discussed briefly in the plan, and in more detail in Appendix G of the final 

environmental impact statement. Additionally, project-level analysis for subsequent activities 

under the revised forest plan will be required to demonstrate compliance with the Clean Water 

Act and State water quality standards. Therefore, the final plan is fully compliant with the Clean 

Water Act.

Clean Air Act

According to the Clean Air Act of 1990 and the Organic Administration Act of 1897, the Forest 

Service has the responsibility to protect the air, land, and water resources from the impacts of air 

pollutants produced within the Forest Service boundaries and to work with states to protect air 

resources from degradation associated with the impacts of air pollution emitted outside of 

National Forest System lands. The final plan contains plan components to protect air quality by 

reducing risk of large emissions from catastrophic wildfires. Furthermore, analysis of the effects 

of plan implementation on air quality in the Final Environmental Impact Statement indicates that 

all alternatives work towards the desired conditions for air quality over the long-term to varying 

degrees depending on the alternative selected. Conformity determinations and more detailed air 

quality impact analyses will be made at subsequent levels of planning and analysis where 

emissions can be more accurately quantified, reasonably forecasted, and local impacts assessed. 

Therefore, the final plan is fully compliant with the Clean Air Act.

National Historic Preservation Act

The California and Nevada State Historic Preservation Officers were consulted on the Inyo 

National Forest Land Management Plan complying with Stipulation 4.4(a) of the “Programmatic 

Agreement Among the U.S.D.A. Forest Service, Pacific Southwest Region (Region 5), California 

State Historic Preservation Officer, Nevada State Historic Preservation Officer, and the Advisory 

Council on Historic Preservation Regarding the Processes for Compliance with Section 106 of the 

National Historic Preservation Act for Management of Historic Properties by the National Forests 

of the Pacific Southwest Region.” Neither of the State Historic Preservation Officers provided 

comments on the forest plan, reserving consultation under 36 CFR Part 800 (as amended) for 

such time as individual undertakings initiated under the plan may have the opportunity to affect 

historic properties. 

Executive Orders 11988 (Floodplain Management) and 

11990 (Protection of Wetlands)

These Executive Orders require Federal agencies to avoid, to the extent possible, short-term and 

long-term effects resulting from the occupancy and modification of flood plains and the 

modification or destruction of wetlands. Forestwide standards and guidelines for soil and water, 
Draft Record of Decision

Inyo National Forest land Management Plan

35

wetlands, and riparian areas are designed to minimize effects to flood plains and wetlands, and 

require use of the National and Regional Best Management Practices.

Executive Order 12898 (Federal Actions to Address 

Environmental Justice in Minority Populations and LowIncome Populations)

This decision is consistent with Executive Order 12898, which requires that all Federal actions 

consider potentially disproportionate effects on minority and low-income communities, especially 

if adverse effects to environmental or human health conditions are identified. Adverse 

environmental or human health conditions created by any of the alternatives considered would 

not affect any minority or low income neighborhood disproportionately. In no case was the 

management direction in the forest plan based on the demographic makeup, occupancy, property 

value, income level, or any other criteria reflecting the status of adjacent nonfederal land. 

Federally owned lands covered by this land management plan are distributed throughout the Inyo 

National Forest and are intermixed with nonfederal lands. My decision would not affect any 

nonfederal land that would impact minority or low-income neighborhoods disproportionately. 

There is no evidence that any individual, group, or portion of the community would benefit 

unequally from this decision.

Civil Rights Laws

Civil Rights are defined as “the legal rights of United States citizens to guaranteed equal 

protection under the law” (Forest Service Manual 1730). Civil rights impact analysis for 

environmental or natural resource actions is part of the social impact analysis package necessary

in an environmental impact statement and is not a separate report (USDA Forest Service 

Handbook 1709.11). The Forest Service is committed to equal treatment of all individuals and 

social groups in its management programs in providing services, opportunities, and jobs. Because 

no actual or projected violation of legal rights to equal protection under the law is foreseen under 

the revised forest plan for any individual or category of people, no civil rights impacts are 

reported in the final environmental impact statement.

Accessibility

The Forest Service and its cooperators are required to incorporate access standards into all of the 

agency’s “Federally Conducted” or “Federally Assisted” facilities, programs, services, or 

activities. This direction is mandated in the following laws and regulations: Architectural Barriers 

Act of 1968; Section 504 and 508 of the Rehabilitation Act of 1973, as amended, 1978; 

Americans with Disabilities Act of 1990 (Title v, section 507) and 7 CFR 15(e). The Inyo 

National Forest has incorporated accessibility requirements into the forest plan components and 

associated documentation.

Executive Order 13084 (Consultation and Coordination with 

Indian Tribal Governments)

The Inyo National Forest engaged 14 Native American tribal entities including 9 federally 

recognized Tribes. We sent letters offering an open invitation to request formal government-togovernment consultation (for recognized tribes) or to meet (for nonrecognized tribes). Big Pine 

and Mono Lake Tribes requested formal consultation in 2014. Tribal representatives of the 
Draft Record of Decision

Inyo National Forest land Management Plan

36

following Tribes were involved throughout the revision process: Big Pine Paiute Tribe of Owens 

Valley; Bridgeport Paiute Indian Colony; Timbi-Sha Shoshone Tribe - Bishop; Fort Independence 

Community of Paiute Indians; Bishop Paiute Indian Tribe ; Lone Pine Paiute-Shoshone 

Reservation; Utu Utu Gwaitu Paiute Tribe Benton Paiute Reservation; Walker River Paiute Tribe; 

Washoe, Antelope Valley Indian Community; Kawiiasu Tribe; Kern Valley Indian Community; 

Mono Lake Kutzadika’a Tribe; Tübatulabals of Kern Valley; and Yosemite-Mono Lake Paiute 

Indian Community. Prior to the release of the notice of intent to revise the forest plan, we held 

meetings with the 14 Tribes to understand their unique issues and concerns. Information from 

Tribal forums, personal meetings, phone calls, and correspondence with Tribal representatives 

was considered in the selection of the alternative B-modified. 

The Wilderness Act (Public Law 88-577 [16 U.S. C. 1131-1136])

Implementation of the Inyo plan will comply with the provisions of the Wilderness Act (1964). 

Plan components for designated wilderness areas are consistent with the Act. 

The Effective Date of the Plan Revision 

This revised forest plan becomes effective 30 calendar days after publication of the notice of its 

approval in the Federal Register (36 CFR 219.17(a), 2012 Planning Rule). This approval will not 

occur until the pre-decisional review process is complete and a final record of decision is issued. 

The revised forest plan provides a framework and text to guide resource management options. It 

is a strategic, programmatic document and does not make project-level decisions or irreversible or 

irretrievable commitments of resources. Those kinds of commitments would be made after more 

detailed, site-specific proposals are initiated and further public comment opportunities occur as 

part of the site-specific environmental analysis process.

Administrative Review

This decision is subject to objection as required by Federal regulations (36 CFR part 219, subpart 

B). The objection must be filed by way of regular mail, fax, e-mail, hand-delivery, or express 

delivery with the Objection Reviewing Officer: Deputy Regional Forester, USDA Forest Service

Pacific Southwest Region, 1323 Club Drive, Vallejo, CA 94592. The fax number is 707-562-

9049. 

The office business hours for those submitting hand-delivered objections are: 8:00 a.m. to 4:30 

p.m. Monday through Friday, excluding holidays. Electronic objections must be submitted in a

format such as an e-mail message, plain text (.txt), rich text format (.rtf), or Word (.doc) to

objections-pacificsouthwest-regional-office@fs.fed.us with subject: Inyo National Forest Plan

Revision Objection. In cases where no identifiable name is attached to an electronic message, a

verification of identity will be required. A scanned signature is one way to provide verification.

Objections, including attachments, must be filed within 60 days from the publication date of this 

notice in the Inyo Register, the newspaper of record. Objections or attachments received after the 

60-day objection period will not be considered. The publication date in the newspaper of record is 

the exclusive means for calculating the time to file an objection. Those wishing to object to this 

project should not rely upon dates or timeframe information provided by any other source. 
Draft Record of Decision

Inyo National Forest land Management Plan

37

Individuals and entities who have submitted substantive formal comments related to plan revision 

during the opportunities for public comment (as provided in subpart A of 36 CFR Part 219) 

during the planning process for that decision may file an objection. Objections must be based on 

previously submitted substantive formal comments attributed to the objector unless the objection

concerns an issue that arose after the opportunities for formal comment.

All objections are open to public inspection during the objection process and must contain the 

following information as required by the 2012 Planning Rule at 36 CFR 219.54. 

Additionally, we request that objection issues related to species of conservation concern be 

identified in the cover letter or introduction of the objection along with page numbers where the 

species of conservation concern-related objections can be found in the objection document. The

decision to approve the species of conservation concern list will be subject to a separate objection 

process. The Chief of the Forest Service is the reviewing officer for species of conservation 

concern identification since the Regional Forester is the deciding official. Objections related to 

species of conservation concern will be forwarded. 

The Final Environmental Impact Statement for the Inyo National Forest Land Management Plan 

Revision documents the analysis and conclusions upon which this decision is based. 

Contact Person

For additional information concerning this draft decision or the objection process, please contact 

Leeann Murphy, Resource and Planning Staff Officer, Inyo National Forest, at 760-873-2404 or 

lbmurphy@fs.fed.us. 

Signature and Date

___________________________ _________________ 

TAMMY RANDALL-PARKER DATE

Forest Supervisor

Inyo National Forest 

Draft Record of Decision

Inyo National Forest land Management Plan

39

Appendix: Recommended Wilderness Areas

South Sierra Wilderness Addition

This recommended wilderness was derived from Wilderness Evaluation Polygon 1391 (Monache, 

Blackrock and South Sierra East).

Table 1. South Sierra Wilderness Addition

Factors Description

1. Acres 17,622 acres

2. Summarized description 

of the recommended 

boundary

This area is located on the east side of the Sierra Nevada mountains, 

southwest of the town of Olancha, CA. The boundary follows natural 

features in these areas. The northern boundary follows a drainage 

which connects to the South Sierra Wilderness boundary and continues 

south along this boundary to a ridgeline running southeast toward the 

national forest boundary. The national forest boundary is used as the 

eastern boundary of this polygon, until Forest Service road 20S02, 

where the boundary heads west following a drainage and hill line north 

back to the national forest boundary. These locations are easily 

locatable on a map or on the ground. 

3. Brief description of the 

general geography, 

topography, and 

vegetation

The area is characterized by steep slopes and forested canyons that 

descend to alluvial fans in the Mojave Desert. Haiwee Canyon, which 

contains a perennial stream, is the predominant drainage. Several other 

canyons along the escarpment contain streams that have perennial 

flows for some of their length. Ecosystem types include Jeffrey pine, 

mountain mahogany, pinyon-juniper, sagebrush, white fir and xeric 

shrublands and blackbrush. The topography is characterized as 

Eastern Sierra escarpment with steep slopes and forested canyons. 

This area contains largely intact true Mojave Desert ecosystems; 

vegetation includes Joshua trees, cholla cactus, creosote, and canyon 

live oak.

4. Current uses and 

management

The majority of this area (>90%) is managed as inventoried roadless 

area. Livestock grazing occurs in the area with no known range 

improvements associated with the allotments. The area receives low 

amounts of recreation use including backpacking, day-hiking and 

hunting. The lower section of Haiwee Canyon Trail, the only forest 

system trail in the area, has been heavily damaged by flash floods in 

recent years. There are several improvements in the area related to 

water supply.
Draft Record of Decision

Inyo National Forest land Management Plan

40

Factors Description

5. Description of the 

wilderness characteristics 

and the Forest’s ability to 

protect and manage the 

area so as to preserve its 

wilderness characteristics

Natural quality – The area has high ecological integrity. Several 

invasive species are present in the area. There are several 

improvements in the area that represents a departure from apparent 

naturalness. 

Undeveloped quality – The majority of this area is undeveloped and 

not affected by human intervention. There are unauthorized routes in 

the area, which are expected to return to natural conditions through 

passive restoration processes. 

Unconfined and/or primitive recreation and solitude– The area 

provides good opportunities for solitude and primitive and unconfined 

recreation, such as horseback riding, hiking, and hunting. The steep 

terrain and lack of trails throughout most of the area support a remote 

experience away from the sights and sounds of people inside the 

wilderness. The sense of remoteness may be diminished along the 

area’s eastern periphery by U.S. Highway 395. 

Other features of value – High ecological integrity within the Mojave 

Desert and oak woodlands found in this area. 

The Inyo’s ability to protect and manage these wilderness 

characteristics is very high as this area is located adjacent to the South 

Sierra Wilderness along its western boundary, has little development, 

the majority of the area is an inventoried roadless area, and motorized 

access is limited. 

6. Brief summary of the 

factors considered and 

the process used in 

evaluating the area and 

developing the 

alternatives

• Interest in recommending this area from several members of 

the public throughout the wilderness inventory and evaluation 

process.

• The intact condition of the ecosystem types.

• Good opportunities for solitude and primitive and unconfined 

recreation.

• Opportunity to protect ecological groups (Mojave Desert, oak 

woodlands) that may be minimally represented in the National 

Wilderness Preservation System.

• The area is contiguous with existing designated wildernesses.

7. Brief summary of the 

ecological and social 

characteristics that would 

provide the basis for 

suitability for inclusion in 

the National Wilderness 

Preservation System

The ecological characteristics that provide the basis for suitability are 

as follows:

• the naturalness of the area is high because the majority of the 

area is affected primarily by natural forces, has high ecological 

integrity; and

• the undeveloped quality of the area is high because the 

majority of this area is unroaded.

The social characteristics that provide the basis for suitability are as 

follows:

• the area offers opportunities for solitude; and

• there are opportunities for primitive and/or unconfined 

recreation for horseback riding, hiking, and hunting. 
Draft Record of Decision

Inyo National Forest land Management Plan

41

Figure 2. South Sierra Wilderness Addition
Draft Record of Decision

Inyo National Forest land Management Plan

42

Piper Mountain Wilderness Addition

This recommended wilderness was derived from Wilderness Evaluation Polygon 1246 (North of 

Eureka Valley Road).

Table 2. Piper Mountain Wilderness addition

Factors Description

1. Acres 11,840 acres

2. Summarized description of 

the recommended 

boundary

The boundary uses setbacks from roads and motorized trails, which is 

consistent with other wilderness boundary setbacks on the national 

forest. The northern and western sections of the boundary closely 

follow National Forest System roads and motorized trails. The southern 

boundary generally follows a prominent natural feature, an east-west 

trending ridgeline. The eastern end of the southern boundary departs 

the ridgeline to become a 200 foot offset from a National Forest System 

road (09S109). The eastern boundary is formed by the Inyo’s 

administrative boundary.

3. Brief description of the 

general geography, 

topography, and 

vegetation

This area is located at the northern end of the Inyo Mountains, an area 

where complex geological forces have produced a striking desert range 

that contrasts with Deep Springs Valley. The area is north of the 

boundary between the White Mountain and Mt. Whitney Ranger 

Districts and southeast of Westgard Pass. Ecosystem types include 

pinyon-juniper, sagebrush and xeric shrublands and blackbrush. The 

topography includes steep to gentle slopes. Elevation ranges from 

5,000 to 8,600 feet.

4. Current uses and 

management

The entire polygon is managed as inventoried roadless area. Portions 

of the area are also used as a geological field study area. The area 

includes one water right. 

5. Description of the 

wilderness characteristics 

and the Forest’s ability to 

protect and manage the 

area so as to preserve its 

wilderness characteristics

Natural quality – The area has intact ecological integrity and reflects 

conditions that would normally be associated with the area absent 

human intervention. 

Undeveloped quality – The majority of this area is undeveloped and 

not affected by human intervention. Some historic clearing/harvesting 

for mining is evident. There are unauthorized routes in this area, which 

are expected to return to natural conditions through passive restoration 

processes. 

Unconfined and/or primitive recreation and solitude– The steep 

topography and lack of surface water supports a remote experience 

from the sights and sounds of people inside the wilderness. The sense 

of remoteness from occupied and modified areas outside the 

wilderness may be diminished along the area’s periphery by motorized 

vehicle use on forest system roads. There are opportunities for primitive 

and unconfined recreation. Travel in the lower elevation desert 

environment is challenging due to the lack of surface water and steep 

topography. The pinyon-juniper woodlands and subalpine areas offer 

primitive recreation opportunities typical of the Great Basin: hiking, 

horseback riding and deer hunting.

Other features of value – This area’s other features of value include 

the Poleta Fold geologic features, which have scientific and educational 

values, and cultural resource sites.

The forest’s ability to protect and manage these wilderness 

characteristics is very high as this area is located adjacent to the Piper 

Mountain Wilderness along its eastern boundary, has little 

development, the majority of the area is an inventoried roadless area, 

and motorized access is limited.
Draft Record of Decision

Inyo National Forest land Management Plan

43

Factors Description

6. Brief summary of the 

factors considered and the 

process used in evaluating 

the area and developing 

the alternatives

• Interest in recommending this area from several members of 

the public throughout the wilderness inventory and evaluation 

process.

• The intact condition of the ecosystem types.

• Opportunities for solitude and primitive and unconfined

recreation.

• Opportunity to protect ecological groups that may be minimally 

represented in the National Wilderness Preservation System

(Pinyon-juniper woodlands). 

7. Brief summary of the 

ecological and social 

characteristics that would 

provide the basis for 

suitability for inclusion in 

the National Wilderness 

Preservation System

The ecological characteristics that provide the basis for suitability are 

as follows:

• the naturalness of the area is high because the majority of the 

area is affected primarily by natural forces and has intact 

ecological integrity of Great Basin systems, such as pinyonjuniper woodlands; and 

• the undeveloped quality of the area is very high because the 

majority of this area is unroaded.

The social characteristics that provide the basis for suitability are as 

follows:

• the area offers opportunities for solitude; and

• there is opportunities for primitive and unconfined recreation 

such as backpacking, hiking, and hunting.
Draft Record of Decision

Inyo National Forest land Management Plan

44

Figure 3. Piper Mountain Wilderness addition
Draft Record of Decision

Inyo National Forest land Management Plan

45

White Mountain Wilderness Addition (West) 

This recommended wilderness was derived from Wilderness Evaluation Polygon 1281 (Ancient 

Bristlecone Pine Forest and Dead Horse Meadow).

Table 3. White Mountain Wilderness Addition (West)

Factors Description

1. Acres 5,062 acres

2. Summarized description of 

the recommended 

boundary

The northern portion of this boundary follows the White Mountain 

Wilderness boundary and were it is not contiguous with this boundary, 

setbacks from roads and motorized trails were used to make it more 

clearly identifiable on the ground. The eastern boundary uses the 9,000 

feet contour interval, which visitors could locate on a map or with the 

use of a GPS. The southern, eastern, and portions of the western 

boundaries follows a stream channel, which visitors could locate on a 

map and on the ground. The remainder of the western boundary is 

offset from the Wyman Canyon county road or a utility corridor adjacent 

to White Mountain road. 

3. Brief description of the 

general geography, 

topography, and 

vegetation

This area is located in the high elevations of the southern White 

Mountains. Elevations range from 9,000 feet along the southern and 

eastern boundaries, to 11,000 feet along the northern boundary near 

Blanco Mountain, a soaring pyramid-shaped mountain underlain by 

dolomite. Water Canyon and Mill Canyon, which contain perennial 

streams, are the predominant drainages in the potential recommended 

area. Vegetation communities in the area include mountain mahogany, 

pinyon juniper forests, sagebrush shrub and subalpine forest types. The 

majority of the recommended area is within the Ancient Bristlecone 

Pine Forest, and bristlecone pines are scattered across the south 

facing slopes of Blanco Mountain.

4. Current uses and 

management

The majority of this area is managed as inventoried roadless area. 

Livestock grazing occurs in this area; there is no known range 

improvement associated with the allotments in the area. The area 

receives low amounts of recreation use that includes day-hiking and 

hunting. Overnight camping is prohibited in the Ancient Bristlecone Pine 

Forest. There are forest system trails that are also used as stock trails 

in the Water Canyon and Mill Canyon drainages. There is one private 

inholding in the area, an approximately 40-acre parcel on the south 

slope of Blanco Mountain. There is no known existing road access to 

the inholding. Priority sage-grouse habitat is located adjacent and 

slightly within this area. Habitat improvement or restoration projects 

have not been identified in this area to date, but may be needed if 

pinyon expansion continues to occur in sagebrush habitat. 
Draft Record of Decision

Inyo National Forest land Management Plan

46

Factors Description

5. Description of the 

wilderness characteristics 

and the Forest’s ability to 

protect and manage the 

area so as to preserve its 

wilderness characteristics

Natural quality – The area has good ecological integrity and generally 

appears to reflect ecological conditions that would normally be 

associated with the area without human intervention. There are no 

known invasive plant species within the area. 

Undeveloped quality – The majority of this area is undeveloped and 

not affected by human intervention. There are two unmaintained forest 

system trails in the area, both of which are in small canyons.

Unconfined and/or primitive recreation and solitude– The area 

provides good opportunities for solitude and primitive and unconfined 

recreation, such as hiking, horseback riding, and hunting. The steep 

terrain and unmaintained trails support a remote experience away from 

the sights and sounds of people inside this area. The sense of 

remoteness may be diminished along the area’s western periphery by 

motorized vehicle use on Wyman Canyon road, White Mountain road, 

or the utility corridor. 

Other features of value – Ecological features of the Ancient 

Bristlecone Pine Forest that are of scientific and educational value.

The forest’s ability to protect and manage these wilderness 

characteristics is very high as this area is located adjacent to the White 

Mountain Wilderness along its northern boundary, has little 

development, the majority of the area is an inventoried roadless area, 

and motorized access is limited.

6. Brief summary of the 

factors considered and the 

process used in evaluating 

the area and developing 

the alternatives

• Interest in recommending this area from several members of 

the public throughout the wilderness inventory and evaluation 

process.

• The intact condition of the ecosystem types.

• Good opportunities for solitude and primitive and unconfined 

recreation.

• The area is contiguous with existing designated wilderness.

• The area contains ecological features in the Ancient 

Bristlecone Pine Forest that are of scientific and educational 

value.

7. Brief summary of the 

ecological and social 

characteristics that would 

provide the basis for 

suitability for inclusion in 

the National Wilderness 

Preservation System

The ecological characteristics that provide the basis for suitability are 

as follows:

• the naturalness of the area is high because much of the area 

is affected primarily by natural forces, has mostly intact 

ecological integrity, and contains unique native species such 

as bristlecone pines; and

• the undeveloped quality of the area is high because the 

majority of this area is unroaded. 

The social characteristics that provide the basis for suitability are as 

follows:

• the area offers opportunities for solitude; and

• there is opportunities for primitive and unconfined recreation 

for hunting, horseback riding, and hiking. 
Draft Record of Decision

Inyo National Forest land Management Plan

47

White Mountain Wilderness Addition (East) 

This recommended wilderness was derived from Wilderness Evaluation Polygon 1281 (Ancient 

Bristlecone Pine Forest and Dead Horse Meadow).

Table 4. White Mountain Wilderness Addition (East)

Factors Description

1. Acres 2,505 acres

2. Summarized description of 

the recommended 

boundary

The western boundary follow setbacks from roads and motorized trails 

that were consistent with other wilderness boundary setbacks on the 

national forest. The eastern boundary follows the National Forest 

Administrative boundary, which visitors can locate on a map. The 

southern boundary uses a prominent ridgeline, which visitors could 

locate on a map or on the ground. The western boundary uses an offset 

from the Dead Horse Meadow motorized trail and one of its spurs, 

which visitors could locate on a map and on the ground. The northern 

boundary follows the White Mountain Wilderness boundary. 

3. Brief description of the 

general geography, 

topography, and 

vegetation

This area is located on the southeastern slopes of the White Mountains. 

The majority of the area is within the south rim of the Cottonwood 

Creek watershed, with Black Birch Canyon the most notable 

geographic feature. The Cottonwood Creek wild and scenic river 

corridor overlays the extreme northeast corner of the potential 

recommended area. Elevations range from 8,500 feet along the 

southern boundary, to 6,800 feet along Cottonwood Creek. Vegetation 

communities in the area include pinyon juniper forest.

4. Current uses and 

management

The entire area is managed as inventoried roadless area. Livestock 

grazing occurs in the area, with no permanent range improvements 

associated with the allotments. The area receives low amounts of 

recreation use that likely includes hiking and hunting.

5. Description of the 

wilderness characteristics 

and the Forest’s ability to 

protect and manage the

area so as to preserve its 

wilderness characteristics

Natural quality – This area has good ecological integrity, and generally 

appears to reflect ecological conditions that would normally be 

associated with the area without human intervention. There are no 

known invasive plant species in the area. 

Undeveloped quality – The majority of this area is undeveloped and 

not affected by human intervention. Portions of the Cottonwood Creek 

stock trail may be evident through the area, but there are no other 

known trails. 

Unconfined and/or primitive recreation and solitude– The area 

provides good opportunities for solitude and primitive and unconfined 

recreation. The steep terrain and absence of trails support a remote 

experience away from the sights and sounds of people inside the 

wilderness. The sense of remoteness may be diminished along the 

area’s periphery by motorized vehicle use along the western boundary. 

The area is generally distant from occupied and modified areas. 

Other features of value – The area includes pinyon-juniper woodlands 

with high ecological integrity.

The forest’s ability to protect and manage these wilderness 

characteristics is very high as this area is located adjacent to the White 

Mountain Wilderness along its northern boundary, has little 

development, the majority of the area is an inventoried roadless area, 

and motorized access is limited.
Draft Record of Decision

Inyo National Forest land Management Plan

48

Factors Description

6. Brief summary of the 

factors considered and the 

process used in evaluating 

the area and developing 

the alternatives

• Interest in recommending this area from several members of 

the public throughout the wilderness inventory and evaluation 

process.

• The intact condition of the ecosystem types.

• Good opportunities for solitude and primitive and unconfined 

recreation.

• The area is contiguous with existing designated wilderness 

and contains a wild and scenic river.

• Opportunity to protect ecological groups (Pinyon-juniper 

woodland) that may be minimally represented in the National 

Wilderness Preservation System.

7. Brief summary of the 

ecological and social 

characteristics that would 

provide the basis for 

suitability for inclusion in 

the National Wilderness 

Preservation System

The ecological characteristics that provide the basis for suitability are 

as follows:

• the naturalness of the area is high because much of the area 

is affected primarily by natural forces, has mostly intact 

ecological integrity; and

• the undeveloped quality of the area is high because the 

majority of this area is unroaded. 

The social characteristics that provide the basis for suitability are as 

follows:

• the area offers opportunities for solitude; and

• there is opportunities for primitive and unconfined recreation 

for hunting and hiking. 
Draft Record of Decision

Inyo National Forest land Management Plan

49

Figure 4. White Mountain Wilderness additions (west and east) 
Draft Record of Decision

Inyo National Forest land Management Plan

50

Table 5. List of eligible wild and scenic rivers and their segments, outstandingly remarkable values, 

and length

River Name Stream 

ID No.(s)

Beginning Point End Point Outstandingly 

Remarkable Values

Preliminary 

Classification

Length 

(Miles) 

Convict 

Creek 

(Segment 1)

1.03 Headwaters Convict Lake Scenery, Recreation, 

Geology, Other 

(Botanical) 

Wild 7.0

Cottonwood 

Creek

(Segment 1)

White 

Mountains

1.028 Headwaters at 

White Mountains 

Wilderness 

Boundary

Wild and Scenic 

designated segment

Fish Populations, 

Prehistory 

Wild 1.7

Cottonwood 

Creek 

(Segment 1)

1.04.1

1.04.2

Headwaters Southeast side of 

Forest Road 16S02

Scenery, Recreation, 

Geology, Fish Habitat, 

Fish Populations, 

History

Wild 4.7

Cottonwood 

Creek 

(Segment 2)

1.04.3 Southeast side of 

Forest Road 

16S02

Los Angeles 

Department of Water 

and Power land east 

of the Old 

Cottonwood Mill site

Recreation, Fish 

Populations, History

Recreational 1.4

Cottonwood 

Creek 

(Segment 3)

1.04.4 Los Angeles 

Department of 

Water and Power 

land east of the 

Old Cottonwood 

Mill site

Golden Trout 

Wilderness boundary

Scenery, Fish 

Populations, History

Wild 3.8 

Cottonwood 

Creek 

(Segment 4)

1.04.5 Golden Trout 

Wilderness 

boundary

Intake in Section 27 

just east of Forest 

Service Road 17S01

Scenery, Fish 

Populations, History, 

Prehistory 

Recreational 2.1

Cottonwood 

Creek

(Segment 5)

While 

Mountains

1.027.2 Forest Boundary Forest Boundary History Recreational 0.7

Crest Creek 1.031 Headwaters Inlet to Gem Lake History Wild 4.0

Division 

Creek

1.041.2 Wilderness 

Boundary

Forest Boundary History Recreational 3.4

Fish Creek 1.053 Headwaters Confluence with 

Middle Fork San 

Joaquin River

Scenery, Recreation, 

Geology, Wildlife 

Populations

Wild 20.4

Golden Trout 

Creek

1.07 Headwaters 

above Big 

Whitney Meadows

Confluence with the 

Kern River

Scenery, Recreation, 

Geology, Fish 

Populations, Fish 

Habitat, History

Wild 19.0

Hot Creek

(Segment 1)

1.067 Headwaters Intersection of stream 

and Forest Road 

3S45G

History, Prehistory, 

Other

Recreational 5.6

Hot Creek

(Segment 2)

1.09.1 Intersection of 

stream and Forest 

Road 3S45G

Fish Hatchery Geology, Prehistory, 

Other (Botanical)

Recreational 4.4
Draft Record of Decision

Inyo National Forest land Management Plan

51

River Name Stream 

ID No.(s)

Beginning Point End Point Outstandingly 

Remarkable Values

Preliminary 

Classification

Length 

(Miles) 

Hot Creek

(Segment 3)

1.09.2 Fish Hatchery Forest boundary Scenery, Recreation, 

Geology, Fish 

Populations, Fish 

Habitat, Prehistory, 

Other (Botanical)

Recreational 2.9

Laurel Creek 1.11 Wilderness 

boundary

Los Angeles 

Department of Water 

and Power land

Scenery, Recreation, 

Geology

Scenic 3.8

Lee Vining 

Creek 

(Segment 1)

1.12.1 Headwaters 

tributaries

Harvey Monroe Hall 

Research Natural 

Area 

Scenery, Recreation, 

Geology

Wild 1.4 

Lee Vining 

Creek 

(Segment 2)

1.12.2 Harvey Monroe 

Hall Research 

Natural Area

Greenstone Lake Scenery, Recreation, 

Geology

Wild 0.2

Lee Vining 

Creek 

(Segment 3)

1.12.3 Saddlebag Lake Hwy 120 Scenery, Recreation, 

Geology

Recreational 3.0

Lee Vining 

Creek 

(Segment 4)

1.12.4 Southern CA 

Edison 

Powerhouse

Los Angeles 

Department of Water 

and Power Diversion 

Pond

Scenery, Recreation, 

Geology

Recreational 6.0

Lee Vining 

Creek

(Segment 7)

1.079.2

1.079.3

Highway 120 Southern California 

Edison (SCE) 

Powerhouse

Geology Scenic 2.3

Lee Vining 

Creek

(Segment 8)

1.079.1 Inlet to 

Greenstone Lake

Outlet of Saddlebag 

Lake

Scenery, Recreation, 

Geology

Scenic 1.9

Little Hot 

Creek

1.084 Antelope Spring Forest Boundary Geology, Prehistory, 

Other

Recreational 3.9

Lone Pine 

Creek/North 

fork Lone 

Pine Creek 

(Segment 1)

1.13

1.23

North Fork and 

South fork 

Headwaters

John Muir Wilderness 

boundary

Scenery, Recreation, 

Geology

Wild 4.7

Lone Pine 

Creek 

(Segment 2)

1.087 John Muir 

Wilderness 

boundary

Inyo Forest boundary 

near Lone Pine 

Campground

Scenery, Recreation, 

Geology

Recreational 3.9

Mammoth 

Creek

(Segment 2)

1.094.2

1.094.2 Intersection with 

Sherwin Creek

0.04 miles after 

intersection with 

Sherwin Creek

History, Prehistory Recreational 0.04

Mammoth 

Creek

(Segment 3)

1.094.3

1.094.3 South of Hot 

Creek by 0.02 

miles

Intersection with Hot 

Creek

History, Prehistory Recreational 0.02

Mammoth 

Creek

(Segment 4)

1.094.4

1.094.4 Wilderness 

Boundary

Twin Lakes Outlet History, Prehistory Recreational 3.5
Draft Record of Decision

Inyo National Forest land Management Plan

52

River Name Stream 

ID No.(s)

Beginning Point End Point Outstandingly 

Remarkable Values

Preliminary 

Classification

Length 

(Miles) 

Mammoth 

Creek

(Segment 5)

1.15.1

1.15.1 Twin Lakes Sherwin Campground History, Prehistory Recreational 4.5

Mammoth 

Creek

(Segment 6)

1.15.2

1.15.2 Sherwin 

Campground

South of Hot Creek 

by 0.02 miles

Prehistory Recreational 2.4

McGee 

Creek

(Segment 1)

1.16 Headwaters Wilderness boundary Scenery, Recreation, 

Geology

Wild 6.7

McGee 

Creek

(Segment 2)

1.099 Wilderness 

Boundary

Forest Boundary Geology Recreational 3.8

Middle Fork 

Bishop Creek

1.104.1 Headwaters Outlet of Sabrina 

Lake

History Wild 5.2

Middle Fork 

San Joaquin 

River

1.17 Headwaters are 

from an unnamed 

lake southwest of 

Thousand Island 

Lake

Middle Fork San 

Joaquin River at the 

northeast end of 

Thousand Island 

Lake

Scenery, Recreation, 

Geology

Wild 3.5

Mill Creek 

(Segment 1)

1.18.1

1.18.2

Headwaters Wilderness boundary Scenery, Recreation, 

Geology

Wild 4.0

Mill Creek 

(Segment 2)

1.18.3 Wilderness 

boundary

Private Property Scenery, Recreation, 

Geology

Scenic 1.4

Mill Creek 

(Segment 3)

1.18.4 Private Property Lundy Lake Scenery, Recreation, 

Geology

Recreational 0.8

Mill Creek

(Segment 5)

1.105.2 Headwaters Intersection with Mill 

Creek 1.18.1

Geology Wild 1.1

North Fork 

Big Pine 

Creek 

(Segment 1)

1.22.1

1.22.2

Northern 

headwaters on 

flank of 

Cloudripper

Wilderness boundary Scenery, Recreation, 

Geology, History

Wild 5.5

North Fork 

Big Pine 

Creek/Big 

Pine Creek 

(Segment 2)

1.02.1

1.22.3

1.22.4

Wilderness 

boundary

Private Property Recreation, Geology Recreational 3.6

North Fork 

Crooked

Creek

1.126 Headwaters Confluence with 

South Fork Crooked 

Creek

Prehistory Scenic 4.6

O’Harrel 

Canyon 

Creek

1.141 Headwaters Forest Boundary Fish Populations, 

Prehistory 

Recreational 5.3

Parker Creek 1.25.1 Headwaters Wilderness Boundary Scenery, Recreation Wild 4.4

Poison Creek 1.153 Headwaters Intersection with 

South Fork 

Cottonwood Creek

Prehistory Wild 3.4

Rock Creek 

(Segment 1)

1.27.1

1.27.2

Outlet of Box 

Lake

Wilderness Boundary Scenery, Recreation, 

Geology, Prehistory

Wild 1.2
Draft Record of Decision

Inyo National Forest land Management Plan

53

River Name Stream 

ID No.(s)

Beginning Point End Point Outstandingly 

Remarkable Values

Preliminary 

Classification

Length 

(Miles)

Rock Creek 

(Segment 2)

1.27.3 Wilderness 

boundary

Highway 395 bridge 

near Toms Place

Scenery, Recreation, 

Geology, Prehistory

Recreational 12.0

Rock Creek

(Segment 3)

1.161 Headwaters Box Lake Geology Wild 3.1

Rock Creek –

Lower 

(Segment 3)

1.14.1

1.14.2

Highway 395

bridge near Toms 

Place

Forest boundary Scenery, Recreation, 

Prehistory

Recreational 6.9

Rush Creek

(Segment 1)

1.165.1 Headwaters Inlet of Waugh Lake Scenery, Recreation, 

Wildlife Populations

Wild 3.7

Rush Creek

(Segment 2)

1.165.2 Inlet of Waugh 

Lake

Ansel Adams 

Wilderness Boundary

Scenery, Recreation, 

History, Prehistory

Wild 4.2

Rush Creek

(Segment 3)

1.28.2 Forest Boundary Inlet to Mono Lake Geology, Other 

(Cultural)

Recreational 4.3

Rush Creek 

(Segment 4)

1.165.4

1.165.6

1.165.7

Ansel Adams 

Wilderness 

Boundary

Confluence with 

Reversed Creek

History Recreational 

(1.165.4, 

1.165.6)

Wild (1.165.7)

1.9

South Fork 

Bishop Creek 

(Segment 1)

1.30.1 Headwaters Inlet at South Lake Scenery, Recreation, 

Geology

Wild 3.6

South Fork 

Bishop Creek 

(Segment 2)

1.30.2 Dam outlet at 

South Lake

Habeggers RV Park Scenery, Recreation, 

History

Recreational 5.2

South Fork 

Cottonwood 

Creek

1.180 Headwaters Intersection with 

Cottonwood Creek

Prehistory Wild 3.7

South Fork 

Mill Creek 

(Segment 1)

1.32.1 Dore Pass Lake Crystal Lake Scenery, Recreation, 

Geology

Wild 1.1

South Fork 

Mill Creek 

(Segment 2)

1.32.2 Crystal Lake Hoover Wilderness 

boundary

Scenery, Recreation, 

Geology

Wild 1.6

South Fork 

Mill Creek 

(Segment 3)

1.32.3 Hoover 

Wilderness 

boundary

Confluence with Mill 

Creek

Scenery, Recreation Scenic 0.3

South Fork 

Oak Creek 

(Segment 1)

1.187.1 Headwaters Wilderness boundary Scenery, Geology, 

Other (Botanical)

Wild 3.6

South Fork 

Oak Creek 

(Segment 2)

1.187.2 Wilderness 

boundary

Road 13S04 Scenery, Geology, 

Other (Botanical)

Recreational 3.9

Volcanic 

Creek

1.203 Volcano Meadow Intersection with 

Golden Trout Creek

Geology Wild 2.3

Walker Creek 

(Segment 1)

1.33.1 Headwaters 

tributaries

Ansel Adams 

Wilderness boundary

Scenery, Recreation Wild 2.6

Walker Creek

(Segment 2)

1.33.2 Ansel Adams 

Wilderness 

boundary

Walker Lake Recreation Scenic 0.4
Draft Record of Decision

Inyo National Forest land Management Plan

54

References

Chambers, J.C., Roundy, B.A., Blank, R.R., Meyer, S.E. and Whittaker, A., 2007. What makes 

Great Basin sagebrush ecosystems invasible by Bromus tectorum?. Ecological 

Monographs, 77(1), pp.117-145.

Clark, R.N. and Stankey, G.H., 1979. The recreation opportunity spectrum: a framework for 

planning, management, and research. Pacific Northwest Forest and Range Experiment 

Station. Gen. Tech. Rep. GTR-PNW-98. December 1979.

Dickard, M., M. Gonzalez, W. Elmore, S. Leonard, D. Smith, S. Smith, J. Staats, P. Summers, D. 

Weixelman, S. Wyman. 2015. Riparian area management: Proper functioning condition 

assessment for lotic areas. Technical Reference 1737-15. U.S. Department of the Interior, 

Bureau of Land Management, National Operations Center, Denver, CO.

English, D.B., Kocis, S.M., Zarnoch, S.J. and Arnold, J.R., 2002. Forest Service national visitor 

use monitoring process: research method documentation. Gen. Tech. Rep. SRS-57. 

Asheville, NC: US Department of Agriculture, Forest Service, Southern Research Station. 

14 p.

Headwaters Economics, 2018, Economic Profile System, 

https://headwaterseconomics.org/tools/economic-profile-system/tech-info/, Bozeman MT 

date visited January 12, 2018.

Hessburg, P.F., Churchill, D.J., Larson, A.J. 2015. Restoring fire-prone Inland Pacific landscapes: 

seven core principles. Landscape Ecology 30:1805-1835.

IMPLAN Group LLC, 2016. IMPLAN System (data and software). 16905 Northcross Dr., Suite 

120, Huntersville, NC 28078. www.IMPLAN.com.

Knick, S. and Connelly, J.W. eds., 2011. Greater sage-grouse: ecology and conservation of a 

landscape species and its habitats (Vol. 38). Univ of California Press.

Landres, P., Boutcher, S., Merigliano, L., Barns, C., Davis, D., Hall, T., Henry, S., Hunter, B., 

Janiga, P., Laker, M. and McPherson, A., 2005. Monitoring selected conditions related to 

wilderness character: a national framework. RMRS-GTR-151. U.S. Department of 

Agriculture, Forest Service, Rocky Mountain Research Station.

Long, J. W., L. Quinn-Davidson, and C. N. Skinner. 2014. Science Synthesis To Support 

Socioecological Resilience In The Sierra Nevada And Southern Cascade Range. Gen. 

Tech. Rep. PSW-GTR-247. Albany, CA: U.S. Department of Agriculture, Forest Service, 

Pacific Southwest Research Station. 723 p. 

Mazor, R.D., Rehn, A.C., Ode, P.R., Engeln, M., Schiff, K.C., Stein, E.D., Gillett, D.J., Herbst, 

D.B. and Hawkins, C.P., 2016. Bioassessment in complex environments: designing an 

index for consistent meaning in different settings. Freshwater Science, 35(1), pp.249-271.

Meyer, M. D. 2013a. Natural range of variation (NRV) for red fir forests in the bioregional 

assessment area. USDA Forest Service.
Draft Record of Decision

Inyo National Forest land Management Plan

55

Meyer, M. D. 2013b. Natural range of variation (NRV) for subalpine forests in the bioregional 

assessment area. USDA Forest Service.

Miller, J. D., E. E. Knapp, C. H. Key, C. N. Skinner, C. J. Isbell, R. M. Creasy, and J. W. 

Sherlock. 2009. "Calibration and validation of the relative differenced Normalized Burn 

Ratio (RdNBR) to three measures of fire severity in the Sierra Nevada and Klamath 

Mountains, California, USA." Remote Sensing of Environment 113 (3):645-656.

Miller, J. D., H. D. Safford, M. Crimmins, and A. E. Thode. 2009. "Quantitative evidence for 

increasing forest fire severity in the Sierra Nevada and southern Cascade Mountains, 

California and Nevada, USA." Ecosystems 12 (1 SRC - GoogleScholar):16-32.

Moyle, P. B. 1996. Potential Aquatic Diversity Management Areas. Chapter 57 in Sierra Nevada 

Ecosystem Project, Final Report to Congress, vol. II, Assessments and Scientific Basis 

for Management Options. Davis: University of California, Centers for Water and 

Wildland Resources.

North, M., P. Stine, K. O'Hara, W. Zielinski, and S. Stephens. 2009. An ecosystem management 

strategy for Sierran mixed-conifer forests. Gen. Tech. Rep. PSW-GTR-220. Albany, CA: 

USDA Forest Service.

North, M. 2012. Managing Sierra Nevada forests. Gen. Tech. Rep. PSW-GTR-237. Albany, CA: 

USDA Forest Service.

Page-Dumroese, D.S., Abbott, A.M. and Rice, T.M., 2009. Forest Soil Disturbance Monitoring 

Protocol: Volume I: Rapid assessment. Gen. Tech. Rep. WO-GTR-82a. Washington, DC: 

U.S. Department of Agriculture, Forest Service. 31 p.

Reeves, G.H.; Pickard, B.R.; Johnson, K. N. 2016. An initial evaluation of potential options for 

managing riparian reserves of the Aquatic Conservation Strategy of the Northwest Forest 

Plan. Gen. Tech. Rep. PNW-GTR-937. Portland, OR: U.S. Department of Agriculture, 

Forest Service, Pacific Northwest Research Station. 97 p.

Rieman, B.E., Lee, D.C., Hessburg, P.F., Sedell, J.R. 2000. Toward an Integrated Classification of 

Ecosystems: Defining Opportunities for Managing Fish and Forest Health. 

Environmental Management 25 (4): 425-444.

Rieman, B.E., Hessburg, P.F., Luce, C. and Dare, M.R., 2010. Wildfire and management of 

forests and native fishes: conflict or opportunity for convergent 

solutions?. BioScience, 60(6), pp.460-468.

Ritchie, M.W. 2016. Science Consistency Review Report: Draft Environmental Impact Statement 

for Revision of the Inyo, Sequoia and Sierra National Forests Land Management Plans, 

December 8, 2016.

Safford, H.D., M. Coppoletta, B.E. Estes, S.E. Gross, K.E. Merriam, M.D. Meyer, M. Slaton, and 

H. Stone. 2013. Natural range of variation (NRV) for terrestrial ecosystems in the 

bioregional assessment area, including the Sierra Nevada, southern Cascades, and Modoc 

and Inyo National Forests.: USDA Forest Service, Pacific Southwest Region.
Draft Record of Decision

Inyo National Forest land Management Plan

56

Safford, Hugh D, and Kip M Van de Water. 2014. "Using fire return interval departure (FRID) 

analysis to map spatial and temporal changes in fire frequency on national forest lands in 

California."

Steel, Z. L., H.D. Safford, and J.H. Viers. 2015. "The fire frequency-severity relationship and the 

legacy of fire suppression in California forests." Ecosphere 6 SRC - GoogleScholar (8).

United States Department of Agriculture, Forest Service. 1990. ROS primer and field guide, R6-

REC-021-90. Washington, D.C.: U.S. Dept. of Agriculture, Forest Service.

United States Department of Agriculture, Forest Service. 2001. Sierra Nevada Forest Plan 

Amendment: Final Supplemental Environmental Impact Statement and Record of 

Decision. Vallejo, CA: U.S. Department of Agriculture, Forest Service, Pacific Northwest 

Region.

United States Department of Agriculture, Forest Service. 2004. Sierra Nevada Forest Plan 

Amendment: Final Supplemental Environmental Impact Statement and Record of 

Decision. Vallejo, CA: Forest Service, Pacific Southwest Region.

United States Department of Agriculture, Forest Service. 2011. Watershed Condition Framework: 

A Framework for Assessing and Tracking Changes to Watershed Condition. FS-977. May 

2011.

United States Department of Agriculture, Forest Service. 2012. National Best Management 

Practices for Water Quality Management on National Forest System Lands FS-990. April 

2012. 

United States Department of Agriculture, Forest Service. 2013. Final Inyo National Forest 

assessment. Vallejo, CA. R5-MB-266. December 2013.

United States Department of Agriculture, Forest Service. 2014. Final Sierra Nevada bio-regional 

assessment. Vallejo, CA. R5-MB-268. February 2014.