United States Department of Agriculture

1st 48 Roadside Fuelbreak 

Collaborative Project

Final Environmental Assessment

Forest 

Service

Pacific Southwest 

Region

Six Rivers 

National Forest

R5-MB-313

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

Prescott.

In accordance with Federal civil rights law and US 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 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: US Department of Agriculture Office of the Assistant Secretary for Civil Rights, 

1400 Independence Avenue SW, Washington, DC 20250-9410; (2) fax: (202) 690-7442; or (3) email: 

program.intake@usda.gov.

USDA is an equal opportunity provider, employer, and lender.
Final Environmental Assessment – i

1st 48 Roadside Fuelbreak Collaborative Project

Environmental Assessment

Trinity County, California

Responsible Official: Merv George Jr., Forest Supervisor

Six Rivers National Forest

1330 Bayshore Way

Eureka, CA 95501

(707) 441-3534

mgeorge@fs.fed.us

For Information Contact: Dan Dill, District Ranger

Mad River Ranger District

741 State Highway 36

Bridgeville, CA 95526

(707) 574-6233

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

This page intentionally left blank.
Final Environmental Assessment – iii

Table of Contents

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

Changes between Draft and Final Environmental Assessments................................................. 1

Introduction................................................................................................................................. 2

Trinity County Collaborative ...................................................................................................... 3

Project Location .......................................................................................................................... 4

Purpose and Need for the Proposal............................................................................................. 5

Principle Laws and Regulations that Influence the Scope of this EA........................................... 7

Collaboration, Public Involvement and Tribal Consultation .................................................... 13

Chapter 2. Alternatives Considered in Detail................................................................................ 17

Alternative 1 – No Action......................................................................................................... 17

Alternative 2 – Proposed Action............................................................................................... 18

Chapter 3. Environmental Consequences...................................................................................... 45

Fire, Fuels and Vegetation ........................................................................................................ 47

Wildlife Resources.................................................................................................................... 59

Watershed Resources................................................................................................................ 94

Geologic Resources................................................................................................................. 102

Soil Resources......................................................................................................................... 105

Cultural Resources.................................................................................................................. 122

Threatened, Endangered, Sensitive Botanical Resources ....................................................... 124

Survey and Manage Plants...................................................................................................... 131

Invasive Non-Native Plants..................................................................................................... 138

Finding of No Significant Impact................................................................................................ 143

Context.................................................................................................................................... 143

Intensity................................................................................................................................... 143

Chapter 4. Consultation and Coordination .................................................................................. 159

Preparers and Contributors...................................................................................................... 159

References................................................................................................................................... 161

Forest Service Reports............................................................................................................ 161

Literature Cited ....................................................................................................................... 161

Appendix A. Response to Comments.......................................................................................... 173

Scoping Period ........................................................................................................................ 173

Comment Period on Draft Environmental Assessment........................................................... 195

Appendix B. Proposed Activities................................................................................................ 227

Appendix C. Best Management Practices................................................................................... 229

Prevention – Terrestrial Invasive Plants (USDA/USFS 2014) ............................................... 229

Timber and Fuels .................................................................................................................... 229

Roads....................................................................................................................................... 230

Soils......................................................................................................................................... 230

Water Quality.......................................................................................................................... 232
iv – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Tables

Table 1. Six Rivers National Forest Land and Resource Management Plan (LRMP) 

management areas. .................................................................................................................. 8

Table 2. Crown class definitions. .................................................................................................. 21

Table 3. Treatment crown spacing and trees per acre by seral type.............................................. 22

Table 4. Proposed Action treatment summary. ............................................................................. 28

Table 5. NFTS temporary road and trail closures. ........................................................................ 34

Table 6. Percent seral stage of 1st 48 Project area by series.......................................................... 49

Table 7. Acres of vegetation series in the 1st 48 Project area........................................................ 50

Table 8. Existing and post-treatment basal area for Douglas-fir in the 1st 48 Project area........... 51

Table 9. Existing and post-treatment retention basal area by strata in the 1st 48 Project area. ..... 52

Table 10. Predicted tree species, age and diameter classes proposed for removal........................ 58

Table 11. Current northern spotted owl (NSO) nesting/roosting and foraging habitat 

by activity center (AC). ......................................................................................................... 79

Table 12. Proposed treatments by activity center (AC)................................................................. 80

Table 13. Combined treatments for 1st 48 (48) and Kelsey Peak (KP) projects 

in foraging habitat by activity centers (AC) that overlap both projects................................. 92

Table 14. Combined treatments for 1st 48 (48) and Kelsey Peak (KP) projects 

in nesting/roosting habitat by activity centers (AC) that overlap both projects. ................... 92

Table 15. Equivalent Roaded Acres (ERA) and percentage of watersheds. ................................. 97

Table 16. Soil map units, acreage, and GIS-derived slope stats from a USGS 10-meter 

DEM (Digital Elevation Model).......................................................................................... 110

Table 17. Soil families in descending extent, including select properties and interpretations. 

Acreage is prorated from map unit components, less inclusions. Abbreviations 

are standard soil science. ..................................................................................................... 110

Table 18. Erosion hazard ratings for soil map units (calculations may be seen in Appendix C 

of the Soils Report)............................................................................................................... 111

Table 19. Soil map unit acres by logging system method (Alternative 2). ................................. 114

Table 20. FACTS database activities intersecting with project units.......................................... 121

Table 21. Ruth Timber Sale activities intersecting with project units......................................... 121

Table 22. Seral stage composition in shaded fuelbreak............................................................... 125

Table 23. Sensitive species considered in the project as a result of pre-field analysis................ 126

Table 24. Survey results, Sensitive species detected in the planning area. ................................. 127

Table 25. List of Survey and Manage plant species that have the potential to, or are known 

to occur, in the project area. ................................................................................................ 134

Table 26. Yellow star thistle infestations and their location within the project area................... 139

Table 27. Interdisciplinary team (IDT) members........................................................................ 159

Table 28. Trinity County Collaborative working group members. ............................................. 159

Table 29. Listing of the names and locations of the commenters, the organization 

or entity each commenter represents, and the type and date of the comment submitted..... 173

Table 30. Listing of the names and locations of the commenters, the organization or entity 

each commenter represents, and the type and date of the comment submitted................... 196
Final Environmental Assessment – v

Table 31. Total treated acres in NSO Critical Habitat, Subunits ICC1 and ICC2. 

PCE= primary constituent element; PCE2=nesting roosting habitat; PCE3=foraging 

habitat; PCE4= dispersal habitat; CT=commercial thin from below; FR= fuels 

reduction, understory only; L/R acres removed for landings and roads.............................. 222

Table 32. Predicted tree species, age and diameter classes proposed for removal...................... 225

Table 34. Summary of the proposed shaded fuelbreak activities by unit – Cable/Leave 

Tree Mark............................................................................................................................ 227

Table 35. Summary of the proposed shaded fuelbreak activities by unit – Ground/Leave 

Tree Mark............................................................................................................................ 228

Table 36. Summary of the proposed shaded fuelbreak activities by unit – Cable/Cut 

Tree Mark............................................................................................................................ 228

Table 37. Summary of the proposed shaded fuelbreak activities by unit – Ground/Cut 

Tree Mark............................................................................................................................ 228

Figures

Figure 1. Project area vicinity map.................................................................................................. 4

Figure 2. In 2015, the TCC and SRNF visited the area burned by the Lassics Fire, about 

12 miles north/northwest of the 1st 48 Project. As illustrated by forest conditions after 

the fire, all agreed the visible impacts of active crown fire behavior is the primary concern... 6

Figure 3. Fire history within and surrounding the project area. ...................................................... 7

Figure 4. SRNF forest plan management area designations in and around the project area............. 9

Figure 5. Shade created by a healthy tree crown........................................................................... 20

Figure 6. Live Crown Ratio: the ratio of live crown to total tree height; expressed as a 

percentage.............................................................................................................................. 21

Figure 7. Competition between suppressed and intermediate trees growing underneath 

and around a healthy predominant black oak with a full, healthy live crown, being 

measured by a forester........................................................................................................... 23

Figure 8. Proposed Action treatment map..................................................................................... 30

Chapter 1. Purpose and Need

Final Environmental Assessment – 1

Chapter 1. Purpose and Need

Changes between Draft and Final Environmental Assessments

The US Forest Service (USFS or Forest Service) made minor grammatical changes, corrected inadvertent 

misspellings and technical errors, and added the response to public comments and findings of consulting 

regulatory agencies following the distribution of the 1st 48 Roadside Fuelbreak Collaborative Project 

Draft Environmental Assessment (1st 48 Project draft EA). Specific changes made include:

o All sections. Minor grammatical edits to improve clarity and inadvertent formatting were 

corrected throughout the final environmental assessment (final EA).

o Chapter 1. Principle Laws and Regulations that Influence the Scope of this EA. Table 1 was 

revised to improve clarity of management area prescription goals relevant to Proposed Action 

treatments, including the addition of the omitted Special Regeneration Management Area

description.

o Chapter 1. Comments on the Draft EA. This new section discloses how the public was notified 

of the start of the comment period, the length of the comment period, and how many individuals 

and organizations were provided the draft EA for review.

o Chapter 2. Developing, Establishing and Maintaining Fuelbreaks. Unit 417 (2 acres) was 

dropped from consideration to retain northern spotted owl habitat (NSO) within an activity center 

(AC), thereby reducing the total project acreage from 823 to 821. Hence, Unit 417 was deleted 

from Table 4 (Proposed Action treatment unit summary). Table 4 also reflects changes to treatment 

methods from thin from below and hazardous fuels reduction to hazardous fuels reduction only 

across multiple units (62 acres), where overlapping suitable NSO habitat within 0.5 miles of AC 

347 and as a result of further field investigations. Figure 8 (Proposed Action treatment map) was 

revised to reflect these changes.

o Chapter 2. Connected Actions, Existing Temporary Roads. A description of the proposed use 

of existing temporary road spurs totaling 1.06 miles inadvertently omitted was incorporated to 

disclose this connected action required for motorized access during operations. A low-water 

crossing option on Forest Service Road (FSR) 2S53 was included involving the Forest Service 

installing a temporary portable bridge.

o Chapter 2. Project Design Features and Mitigation Measures. Further description of the 

allowable proposed treatment mitigations and applicable units within suitable NSO habitat within 

0.5 miles of AC 347 were included in the wildlife section. Further description of the mitigations 

linked to water drafting were included in the aquatics section.

o Chapter 3. Wildlife Resources. This section reflects recalculated acres informing the NSO

analysis of effects to suitable foraging, roosting and nesting habitat, resulting from new 

information (private land timber harvest (62 acres)), effects of temporary road use, inadvertent 

identified computer-based mapping error and additional field reconnaissance (NSO habitat typing

where new landings are proposed) and change in proposed treatments.

o Chapter 3. Watershed Resources. This section reflects recalculated Region 5 Equivalent Roaded 

Acre (ERA) values for cumulative watershed effects to incorporate effects of temporary road use, 

new information (private land timber harvest (62 acres)) and additional disturbance from grazing.
Chapter 1. Purpose and Need

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

o Chapter 3. Fire, Fuels and Vegetation. This section includes additional discussion of predicted 

tree species, age and diameter classes proposed for removal. The information presented in Table 8

was erroneously duplicated in Table 9 in the draft EA. Table 8 was replaced to display existing 

stand density index information.

o Chapter 3. Invasive Non-Native Plants. Cumulative effects were supplemented under Alternative 

1 (No Action) and Alternative 2 (Proposed Action) to address risk of introduction and spread of 

invasive plants from open range (grazing) within the Van Horn Allotment, which overlaps the 

southern portion of the project area.

o Chapter 3. Finding of No Significant Impact. This section was updated in response to comments 

and consultation for Endangered Species Act (ESA) species.

o Appendix A. Response to Comments, Comment on the Draft EA. This new section was added to 

Appendix A of this final EA to disclose the Forest Service responses to comments on the draft EA.

o Appendix B. Proposed Activities. Table 33 through Table 36 were revised accounting for the

changes in treatment prescriptions and potential for forest byproduct utilization.

Introduction

The Six Rivers National Forest (forest or SRNF) prepared the 1st 48 Project in collaboration with the

Trinity County Collaborative (TCC)1. This environmental assessment of the Proposed Action on the 

forest’s Mad River Ranger District (RD) was prepared to determine if there is potential for significantly 

affecting the quality of the human environment, which warrants preparation of an environmental impact 

statement per the National Environmental Policy Act (NEPA).

The Proposed Action would establish roadside fuelbreak networks (both tree shaded and unshaded where 

open forest conditions occur) over approximately 821 acres within the wildland-urban interface (WUI)2

. 

All proposed treatments would occur at varying widths, from a minimum of 25 feet on one side of a road,

up to 275 on the other, not exceeding a total 300-foot-width. Fuelbreaks would be established along either 

side of FSR 01S23 (Route 23), 02S02, 2S47, 2S48, 2S49, 2S50, 2S51, 2S52 and 2S53) and one motorized 

trail (Jeep Trail 8E20). All proposed treatments would reduce hazardous surface and ladder fuels and 

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

The Proposed Action would thin suppressed, intermediate and co-dominant trees (see Table 2) using

cable- and ground-based mechanical methods (tractor). Hazardous fuels (trees up to 8-inch diameter at 

breast height (dbh)) would be hand-cut with chainsaws, chipped, pruned and brush masticated, followed 

by machine (dozer or small excavator equipped with a brush rake) and hand-piling debris, manually 

lopping and scattering surface and small ladder fuels, prescribed jackpot burning and underburning in oak 

woodlands to stimulate oak regeneration.

In addition, the Proposed Action would thin trees growing in plantations and oak woodlands bordering 

roadways, beyond the 275-foot maximum on one side of FSRs. Additionally, along the outer perimeter of 

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

owners, local and regional conservation groups, timber industry representatives, fire safe councils, local non-governmental 

organizations, federal and county government agencies. 2 2 Wildland Urban Interface (WUI): An area where human habitation is mixed with areas of flammable wildland vegetation. It 

extends out from the edge of developed private land into federal, private, and state jurisdictions. The WUI boundaries generally 

extend approximately 11⁄4 miles out from the defense zone boundary; however, actual extents of threat zones are based on fire 

history, local fuel conditions, weather, topography, and natural barriers to fire.
Chapter 1. Purpose and Need

Final Environmental Assessment – 3

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

flank or buffer intersecting with the roadway.

Trinity County Collaborative

The TCC vision is to build consensus to address environmental, economic and social concerns identified 

during the development of the Weaverville Community Forest Strategic Plan (2010). With 76 percent of the 

land base in Trinity County under the jurisdiction of federal agencies (USFS and Bureau of Land 

Management (BLM)), the TCC formed in response to controversy over management of national forest lands, 

wildfire risks and impacts, water use and rights and the decline of the natural resource-based economies.

Since 2012, the TCC, encouraged by former USDA Secretary Tom Vilsack, helped to develop a strategy 

and the landscape Trinity Community Protection and Landscape Restoration Project, spanning 742,000 

acres across the SRNF and Shasta-Trinity National Forest (STNF), along with interspersed private 

timberlands, ranches, and six isolated rural communities. In 2013, the TCC brought forward a “proof of 

concept” proposal, seeking collaboration with SRNF leadership, to establish a network of linear, roadside 

shaded fuelbreaks on national forest lands to facilitate safe evacuation, firefighter access and landscape 

fire management.

In 2016, the SRNF and TCC collaborated, coming to mutual agreement and endorsement of the 1st 48 

Project as a demonstration and adaptive learning opportunity. The project aims to facilitate the protection 

of dispersed private property, residents, and the at-risk community of Ruth3, in alignment with the 

National Cohesive Wildland Fire Management Strategy (Cohesive Strategy). An integral component of 

the proposal is adaptive management or ‘learning by doing’, making incremental adaptive adjustments 

with each project to accelerate planning and on-the-ground implementation.

 3 The community of Ruth, population 195 (US Census 2010), is located in southern Trinity County. In 2001, the State of California, 

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

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

was updated. Federal, state and local organizations convened information to refine the spatial designation of the WUI.
Chapter 1. Purpose and Need

4 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Project Location

The project area (Figure 1), is located on the SRNF’s Mad River RD, lies within T2S, R8E, Sec. 6, 7, 8, 

18, 19, 20, 21, 28, 29, 30, 31, 32 and 33; and T2S, R7E, Sec. 11, 12 and 13, Humboldt Baseline and 

Meridian. The Proposed Action lies near the community of Ruth, ranging from 2,700 feet in elevation to 

the top of South Fork Mountain (5,800 feet), in Trinity County, California.

Figure 1. Project area vicinity map.
Chapter 1. Purpose and Need

Final Environmental Assessment – 5

Purpose and Need for the Proposal

The purpose and need of this project is to provide rural communities and residents travel 

zones that allow for safer evacuation during wildfires; allow greater, faster wildland 

firefighter response and suppression; and reduce the risk of roadside fire starts traveling 

into high-value landscape-level forest resources.

There is a need to establish, develop and maintain shaded fuelbreaks along either side of public access 

and egress roads serving both firefighters and residents living in the WUI. The proposed treatments target 

reducing surface fuel accumulations (forest woody debris) and thinning thickets of ladder and crown fuels 

associated with high tree densities to lower the threat of large-scale high-intensity fire behavior. Citizens 

rely on effective wildfire suppression to safeguard them and their assets during a wildfire. Since the 

1940s, wildfire suppression activities intended to protect urban growth prevented these isolated forested 

areas on public lands from burning, contributing to the high levels of fuel accumulations that exist today.

This 1st 48 Project capitalizes on the benefits that roads and motorized trails provide in rapidly deploying

firefighters, making the most of suppression tactics. Establishing a break in the continuity of the forest 

canopy and decreasing fuel loading would create a defensible space from which firefighters could contain 

a flame front and local residents living in and around the town of Ruth to evacuate quickly and safely. The 

Proposed Action aims to influence fire behavior and facilitate safe fire suppression and containment 

underlying the need to 1) reduce hazardous fuels, 2) increase forest canopy base height, and 3) lower tree 

densities to separate intermingled forest understory and overstory tree crowns4

.

Reduce hazardous fuels.

Between 2006 and 2011, the Forest Service completed 600 assessments on wildfires that burned into 

areas where HFR treatments had previously been conducted. These assessments provided an evaluation of

the effects of prescribed fire, as well as mechanical and chemical treatments, on fire behavior and fire 

suppression actions. Forest Service data collection indicated 90 percent fuels reduction treatment 

effectiveness to lower fire intensity. As fires moved from untreated locations to where thinning and/or

mastication and/or prescribed burning had occurred, the fire behavior changed. Where untreated, active 

crown fire behavior occurred, involving the consumption of the entire upper story of the forest. Where 

fuels reduction treatments occurred prior to burning, active fire behavior changed to passive crown fires 

(where only an individual tree or small group of trees burned) or from passive crown fires to surface fires 

(burning only dry grass, shrubs, pine needles, and other flammable materials on the ground) (DellaSala et 

al. 2004, Stein et al. 2013).

Increase height of live crown or forest canopy base height.

Forest canopy base height (FCBH) describes the average height from the ground to the bottom of a forest 

stand’s canopy. Specifically, it is the lowest height in a stand at which there is a sufficient amount of 

forest canopy fuel to propagate fire vertically into the canopy. The FCBH is an effective value that targets

ladder fuels, such as shrubs and understory trees (Scott and Reinhardt 2001).

 4 Overstory refers to forest canopy made up of the tops of trees. The understory is made of trees that are growing to reach the canopy.
Chapter 1. Purpose and Need

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

Lower tree densities separating intermingled tree crowns.

Intertwined tree crowns provide a route for fire to spread from tree crown to tree crown. This potential for 

surface or passive crown fire to become active crown fire, particularly during wind-driven events (Figure 

2), can create unsafe conditions for evacuations and firefighter suppression. Thinning functions to 

increase the spacing between individual trees and their crowns to lower flame lengths, while retaining 

shade to minimize growth response of understory brush species. Adequate tree shade minimizes loss of 

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

increasing flammability and residence time.

Numerous fires have occurred within and around the project area and the community of Ruth. The size of 

the fires, as illustrated by Figure 3, are primarily influenced by the distribution and size of fuels, 

topography, wind speed, air temperature, and the amount and moisture content of forest floor debris.

Where forest conditions within the proposed roadside fuelbreaks feature pole-sized trees, dead trees 

(snags), and debris scorched by the Ruth Fire, the treatment objective is to “grow” trees large enough to 

provide for shaded fuelbreaks in the future.

Desired future condition

The desired future condition is continuous roadside shaded-fuelbreak networks featuring vigorously 

growing trees with healthy, full, live crowns, spaced to promote sustainable, fire resilient crown and bole 

growth over time. The amounts and distribution of surface, ladder, and crown fuels with head-high tree 

limbs promote low- to moderate-fire intensities and rapid containment. The desired canopy closure varies

considerably, with sufficient canopy closure to inhibit the growth of brush and other ladder fuels to sustain 

long-term shaded-fuelbreak effectiveness. Oak woodlands are healthy and ecological processes restored.

Figure 2. In 2015, the TCC and SRNF visited the area burned by the Lassics Fire, about 12 

miles north/northwest of the 1st 48 Project. As illustrated by forest conditions after the 

fire, all agreed the visible impacts of active crown fire behavior is the primary concern.
Chapter 1. Purpose and Need

Final Environmental Assessment – 7

Principle Laws and Regulations that Influence the Scope of this EA

Land management direction and regulations relevant to the 1st 48 Project that provide the legal framework 

for determining the environmental effects to the human environment analyzed in the final EA. As 

described in Table 1 and displayed in Figure 4, the design of the Proposed Action is consistent with 

designated management areas identified in the SRNF Land and Resource Management Plan (LRMP or 

forest plan) and Record of Decision (ROD; USDA Forest Service 1995).

Figure 3. Fire history within and surrounding the project area.
Chapter 1. Purpose and Need

8 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Each management area contains unique prescriptions, different management goals, desired conditions, 

resource potential and limitations. A management area represents lands managed in a uniform manner, 

through a set of management area prescriptions unique to that area. In some cases, several management 

areas spatially overlap the same land base. In these cases, the Proposed Action conforms to the most 

restrictive prescription-related standards and guidelines (S&Gs).

Table 1. Six Rivers National Forest Land and Resource Management Plan (LRMP) management areas.

Management Area Prescription Acres

Riparian Reserves

There are five categories of streams or waterbodies defining riparian reserves within the project area 

including fish-bearing streams; permanently flowing non-fish bearing streams; intermittent streams, and 

unstable or potentially unstable areas. Under the Aquatic Conservation Strategy (ACS), riparian 

reserves are used to maintain and restore riparian structures and functions of intermittent streams, 

confer benefits to riparian-dependent and associated species other than fish, enhance habitat 

conservation for organisms that are dependent on the transition between upslope and riparian areas, 

improve travel and dispersal corridors for many terrestrial animals and plants, and provide for greater 

connectivity of the watershed. The riparian reserves will also serve as connectivity corridors among the 

late-successional reserves. As a general rule, standards and guidelines for riparian reserves prohibit or 

regulate activities in riparian reserves that retard or prevent attainment of the ACS objectives.

130

Matrix /

General Forest

This management area includes forested land where commercial timber management may occur. 

Silvicultural activities may include timber harvest, reforestation, conifer release, precommercial 

thinning and forest pest management.

210

Special 

Regeneration

Some areas of the forest meet all national forest management area criteria for timber suitability, but 

would require extremely high investments for successful regeneration within five years of harvest. These 

are areas with 11′′ to 24′′ of rock on' the surface, but good soil below the rock, or areas with relatively low 

conifer productivity that support dense stands of mature hardwoods: Low productivity sites, including 

ultramafic soils with poor conifer stocking, make up a large part of this management area.

25

Retention Visual 

Quality Objective 

(VQO)

Viewsheds with a VQO of retention will have a natural appearance as seen from the viewing location. 

Although the quality of scenery from the viewing locations may be affected by activities on private 

lands, the direction for the management area applies only to National Forest lands. Most management 

activities are acceptable, considered on a project-by-project basis, and would be designed according 

to the retention objectives of the visual management system. The overall character of the landscape in 

a retention area may change over time, but individual and cumulative project effects should not

dominate the viewed landscape.

145

Partial Retention

VQO

These areas are typically middleground and background viewing areas as seen from highly sensitive 

viewing area, or are foreground areas as seen from moderately sensitive viewing locations, such as 

county roads, streams, or trails. Most management activities are acceptable, considered on a 

project-by-project basis, and should be designed to meet the partial retention objectives of the visual

management system. The overall character of the landscape in a partial retention area may change 

over time, but individual and cumulative project effects should not dominate the viewed landscape.

146

Special Habitat 

(Late Successional 

Reserve (LSR))

Within the South Fork Mountain managed habitat area, manage habitat attributes, compatible with 

ecological processes, to provide moderate to high-quality habitat conditions for the marten and other 

species dependent on late successional and old-growth forests and provide for dispersal among late 

successional reserves (LSRs) on the Six Rivers and Shasta-Trinity (STNF) national forests.

The STNF prepared an assessment for the mapped landscape-level managed late successional 

area, which partially overlaps proposed treatments along South Fork Mountain.

The Six Rivers National Forest manages LSRs under the Special Habitat Management Area, 

intended to protect and enhance habitat for a broad range of species dependent on structural 

features common to late-successional and old-growth vegetation through the context of vegetation 

management compatible with timber outputs. This management area consists of three components: 

(1) a block of designated habitat for late-successional species, particularly the marten, in a gap along 

South Fork Mountain between several large LSRs; (2) managed late-successional areas that were 

designated in the FSEIS ROD based on protection buffers for specific endemic species identified by 

the Scientific Assessment Team (SAT; 1993); and (3) travel and ecological corridors outside riparian 

reserves, where necessary. The large LSRs and other reserved areas are designated to provide 

well-distributed habitat of sufficient size and spacing to support subpopulations for mature and oldgrowth associated species. These large reserves are expected to support successful breeding pairs 

of most emphasis wildlife species. The habitat areas in this management area were established to 

encourage movement between reserves, protect species that may not receive adequate protection 

through the reserve system, and facilitate dispersal into potentially vacant habitat.

75
Chapter 1. Purpose and Need

Final Environmental Assessment – 9

National Forest Management Act of 1976

The National Forest Management Act (NFMA) is the primary statute governing the administration of 

National Forest System (NFS) lands. The Act requires the maintenance of productivity of the land and the 

protection and, where appropriate, improvement of the quality of the soil and water resources. The Act 

specifies that substantial and permanent impairment of productivity (not defined) must be avoided. 

Further, activities must be monitored to ensure that productivity is protected. This law led to subsequent 

regulation and policy to execute the law at various levels of management.

Figure 4. SRNF forest plan management area designations in and around the project area.
Chapter 1. Purpose and Need

10 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

The National Environmental Policy Act (1969)

The National Environmental Policy Act of 1969 (NEPA) requires that all major federal actions significantly 

affecting the human environment be analyzed to determine the magnitude and intensity of those impacts, the 

results be shared with the public, and the public given opportunity to comment. The regulations 

implementing NEPA further require that to the fullest extent possible, agencies shall prepare EAs 

concurrently and integrated with environmental analyses and related surveys and studies required by the 

Endangered Species Act of 1973 (ESA), the National Historic Preservation Act of 1966 (NHPA), and other 

environmental review laws and executive orders. Principle among these are the Multiple Use and Sustained 

Yield Act of 1960 (MUSYA); NFMA, as expressed through forest plans; the Clean Air Act of 1955; the 

Clean Water Act of 1948; and the Forest and Rangeland Renewable Resources Planning Act of 1974.

National Cohesive Wildland Fire Management Strategy

Wildland fire management response in the United States has evolved into an increasingly complex and 

multifaceted system. Climate change, fuels management, expanding WUI and associated infrastructure, 

budgets, along with mission differences are some of the challenges facing wildland fire managers today.

The National Cohesive Wildland Fire Management Strategy (Cohesive Strategy; USDA and USDI 2014)

seeks to ensure that the values and concerns of the public and all governments are accurately understood 

and reflected. This demands a more comprehensive understanding of the diverse perspectives 

encompassing both the social/human and scientific dimensions.

Managers and natural resource experts recognize that the creation of a truly national cohesive strategy 

would include not only the seven elements identified in the FLAME Act, but must also envision a 

broader, overarching and comprehensive consideration of all lands and fire programs. Therein lies the 

primary challenges facing wildfire managers, land managers, and communities in developing a strategy 

that meets local, regional and national needs.

A national cohesive strategy must recognize the differences and tensions that exist among the partners and 

stakeholders and why those differences exist (e.g., different priorities, planning processes, legal mandates, 

values and resources) and seek to resolve them. It must build stronger relationships based on the 

successes of intergovernmental agreements for mutual response; incorporate cost and data sharing; 

include community wildfire protection planning (CWPPs or their equivalent), regional fire risk 

assessments, state and forest resource assessments and strategies; and encourage increased use of 

partnerships, grants and other funding opportunities. Each of these tools can be used to build stronger 

collaborative processes and move toward shared understandings that resolve conflicts and enhance 

partnerships among multiple landowners across all lands and jurisdictions.

Forest and Rangeland Renewable Resources Planning Act (1974)

The primary purpose of the Forest and Rangeland Renewable Resources Planning Act is to protect, 

develop, and enhance the productivity and other values of NFS lands. This was the first Act to name soil 

as a fundamental resource, recognizing the fundamental need to protect and, where appropriate, improve 

the quality of soil, water, and air resources and harvesting timber only where soil, slope, or other 

watershed conditions would not be irreversibly damaged.
Chapter 1. Purpose and Need

Final Environmental Assessment – 11

Forest Service Manual 2550 – Soil Management (2010)

Forest Service Manual (FSM) 2550 provides a national directive to maintain or restore soil quality on 

NFS lands, and establishes the management framework for sustaining soil quality and hydrologic function 

while providing goods and ecosystem services outlined in forest and grassland land management plans. 

The FSM defines soil productivity and soil quality, and describes soil functions that may be used in 

evaluating soil quality. The FSM outlines programmatic requirements for assessments, analyses, and 

monitoring pursuant to management activities, and outlines general requirements that S&Gs be developed 

and implemented at regional and forest levels.

Standards and guidelines are intended to prevent substantial and permanent damage or degradation that 

affect inherent ecosystem processes. Substantial and permanent soil impairment is defined as detrimental 

changes in soil properties (i.e., physical, chemical, biological) that result in the loss of the inherent 

ecological capacity or hydrologic function of the soil resource, over the midterm (substantial, beyond the 

duration of the project) to long term (permanent, beyond a land management planning period), respectively.

Forest Service R5 FSM Supplement – Soil Quality Mgmt. (R5-2500-2017-1)

Soil management direction is applied to lands dedicated to growing vegetation; it is not applied to areas 

dedicated to other uses, such as roads, trails, administrative and recreation sites, etc. The Supplement 

specifies three (3) key soil functions to be used in the Pacific Southwest Region (Region 5 or R5) for 

assessment and analysis of soil quality: support for plant growth function, soil hydrologic function, and 

filtering-buffering function. Indicators and desired conditions for indicators are outlined for each soil 

function. Soil condition is rated as good, fair, or poor for each indicator relative to the desired condition. 

This approach is intended to help determine the status and trend of soil management, determine whether 

ecosystem health and long-term soil productivity is being maintained, and better determine needs and 

priorities for restoration activities.

Upper Mad River Watershed Analysis (1998)

Watershed analyses are required by the forest plan in key watersheds, for inventoried roadless areas in nonkey watersheds, and riparian reserves prior to determining how proposed land management activities meet 

the Aquatic Conservation Strategy (ACS) objectives. The project area does not overlap with a key 

watershed, or inventoried roadless areas; however, the project area does propose limited treatments in the 

outer portion of riparian reserves and would designate this area as an equipment exclusion zone. The 1st 48 

Project was developed in alignment with the ACS reflected in the NWFP ROD and S&Gs (NWFP; USDA 

and USDI 1994), as incorporated into the SRNF LRMP (USDA Forest Service 1995) described below.

The Upper Mad River Watershed Assessment (USDA Forest Service 1998) contains relevant information 

about the project area for consideration in this environmental analysis. The assessment characterized the 

watershed attributes, framed key questions, assessed vegetative and watershed conditions at the time of 

the assessment and reference conditions, and identified recommendations based on key findings. Key 

findings and recommendations of particular relevance to this project are summarized below.

Vegetation Management

Key Finding (1.3): Individual black oaks and white oaks are important components of the conifer forest 

within this watershed. These trees provide valuable habitat for wildlife as well as both rare and common 

non-vascular plant species (mosses and lichens). Pure white oak and black oak stands are ecologically 

valuable plant communities in this watershed.
Chapter 1. Purpose and Need

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

o Recommended Action: Maintain black oaks and white oaks in stands while harvesting conifers. 

Priority leave trees would be those covered with lichens and mosses. Avoid disruption of pure 

white oak and black oak stands during road and landing construction.

Fire Risk/Hazard and Air Quality

Key Finding (6.1): Human-caused fire risk has increased in the watershed since the 1960s with the 

growing number of private residents and forest visitors. Lightning risk is also high in several areas of the 

watershed, especially towards the headwaters of the Mad River.

o Recommended Action: Strategically placed fuels treatments should target areas of potentially high 

hazard and risk. To deal with the urban wildland intermix, a strategically placed fuelbreak system 

could provide defensible locations to stop wildfires from entering the national forest from fire 

starts on private lands and reduce the threat to private lands from fires originating on NFS lands.

Key Finding (6.2): The hazardous fuels situation in the Upper Mad River Watershed (UMRW) present the 

possibility of high to extreme fire behavior, especially under late summer conditions. Mapping of 

potential August rates-of-spread and flame lengths show large, contiguous areas of extreme fire hazard 

from the valley floor to the ridgetops. This is a major concern since the majority of human-caused fires 

have been started alongside roads on the valley floor. In addition, stand density has increased, resulting in 

ladder fuels that create the potential for crown fires and resulting tree mortality and habitat destruction.

o Recommended Action: Combinations of fuelbreaks, vegetation mosaics, and project-level 

treatment would be more cost effective than project-level treatment alone. Strategically placed 

shaded fuelbreaks could be used to help reduce the impacts of wildland fires along heavily used 

roads, mountain ridges, plantations, and oak woodlands to deter conifer encroachment.

Mad River Watershed Assessment (2010)

In 1992, the US Environmental Protection Agency (EPA) added the Mad River to California’s Clean 

Water Act §303(d) impaired water list due to elevated sedimentation/siltation and turbidity. The North 

Coast Regional Water Quality Control Board (RWQCB) identified water temperature as an additional 

impairment to the watershed in 2006. The watershed assessment is a part of the Mad River Watershed 

Management Plan (MRWMP), which sets forth a strategy to protect and restore the beneficial uses of the 

Mad River, particularly as they relate to sediment and temperature effects. This assessment, prepared by 

Stillwater Sciences (June 2010) focuses on potential sediment influences on instream salmonid habitat 

and channel processes.

Principal tributaries to the Mad River include South Fork Mad River, North Fork Mad River, Barry Creek, 

Pilot Creek, Deer Creek, Bug Creek, Graham Creek, Blue Slide Creek, Boulder Creek, Maple Creek, 

Canõn Creek, Lindsey Creek, and Mill (Hall) Creek. Matthews Dam impounds Ruth Lake and releases 

water that serves the industrial and residential customers of the Humboldt Bay Municipal Water District.

Shasta-Trinity’s Forest-Wide Late-Successional Reserve Assessment (1999)

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

Species within the Range of the Northern Spotted Owl established a network of late-successional reserves 

(LSR), to include 100-acre core areas located around NSO ACs known to exist in 1994, and larger, 

landscape-level managed late-successional areas. Accompanying this was a set of management S&Gs. 

The network of reserves is intended to provide old-growth forest habitat, provide for populations of 
Chapter 1. Purpose and Need

Final Environmental Assessment – 13

species that are associated with late-successional forests, and to help ensure that late-successional species 

diversity will be conserved.

This direction was incorporated into the STNF’s LRMP. Standards and guidelines for management of 

LSRs are detailed in the LRMP and can be found in several sections of the document, including forestwide S&Gs and Management Area 7 direction. The forest-wide LSR assessment (LSRA; USDA Forest 

Service 1999) developed management strategies for the LSRs, determined their sustainability, and 

provided information to decision makers for managing LSRs to meet forest plan goals and objectives. In 

brief, the assessment covers: inventory of vegetative conditions, a list of late successional forestassociated species, a history and description of current land uses, fire management plan(s), criteria for 

developing appropriate treatments, identification of general treatment conditions, a proposed 

implementation schedule, and proposed monitoring and evaluation components.

The LSR assessment evaluated approximately 389,982 acres of LSRs in federal ownership. The South 

Fork LSR encompasses 80,451 acres, with the majority being located on the STNF. Of that, 1,057 acres 

are situated on and administered by the SRNF. The 1st 48 Project proposes to manage 73 acres within the 

South Fork LSR.

Federal and State Permits, Licenses, and Certifications

A burn permit from the North Coast Unified Air Quality Management District (NCUAQMD) is required 

for all prescribed burns.

Compliance with the Clean Water Act and limits set by the total maximum daily load (TMDL) established 

in 2007 is achieved via application of project design, mitigations and application of BMPs in adherence to 

the terms and conditions of the Waiver of Waste Discharge Requirements for Nonpoint Source Discharges 

Related to Certain Federal Land Management Activities on National Forest System Lands in the North 

Coast Region (Order No. R1-2015-0021; The Waiver). Enrollment in The Waiver under Category B shall 

be granted before project activities commence. No additional federal, state or county permits, licenses, or 

other entitlements were identified as requirements for implementation of the Proposed Action.

Collaboration, Public Involvement and Tribal Consultation

Collaboration

In 2016, the Forest Service and TCC working group conducted a field trip to discuss the bounds of the 

project area and potential treatment methodology within zones of agreement. The TCC working group 

participated in interdisciplinary team meetings and discussions beginning in 2017. On-going informal 

communications (emails and telephone calls) and small group meetings involved interactive 

conversations about refining the Proposed Action and progress updates.

Tribal Consultation

On April 11, 2017, the forest initiated formal tribal consultation pursuant to §106 of the NHPA (36 CFR 

800.2(c)(2)) with the Bear River Band of Rohnerville Rancheria, Round Valley Indian Tribes: A 

Sovereign Nation of Confederated Tribes, the Wiyot Tribe, the Lassic Band of Wylacki-Wintoon Family 

Group Inc., and the Eel River Nation of Sovereign Wailaki. The forest understands that the local tribes 

continue to play an important role in this and other undertakings on the SRNF. Tribal knowledge of the
Chapter 1. Purpose and Need

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

area and potential concerns about the natural and cultural resources management within their ancestral 

territory is an important part of the project design and analysis. A comment submitted stated, “We hope 

that the proposed 1st 48 Project and the joint participants be allocated the revenue and resources to

achieve the goals of this project, a healthy, clean area of forest, managed to prevent high severity fires, 

waterways that are healthy and able to sustain our local wildlife.”

Scoping

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

On April 14 until May 5, 2017, the Forest Service initiated the 30-day scoping period with the distribution 

of a scoping letter and Proposed Action map to 120 recipients. The scoping letter was sent to the Lassic 

Band of Wylacki-Wintoon Family Group Inc., and the Eel River Nation of Sovereign Wailaki, Humboldt 

Bay Municipal Watershed District, US Fish and Wildlife Service (USFWS), Congressional Representative 

Jared Huffman, County Board of Supervisors for Humboldt and Trinity Counties, American Forest 

Resource Council, Environmental Protection Information Center (EPIC), Conservation Congress and 

Journey’s End, to name a few. The complete scoping list is available upon request.

On April 25, the Forest Service and TCC hosted a public meeting at the Ruth Lake Community Center in 

the Town of Mad River, to invite the public to participate in the development of the project, solicit public 

comment, and present the project area and proposed treatment methods. A representative from the TCC 

and ten members of the community attended the public meeting. The public interests and comments 

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

measures incorporated. Appendix A of this EA discloses a detailed account of the public comments 

received during the scoping period and the Forest Service responses. Some public comments were 

classified as non-significant issues and others were deemed relevant issues.

Non-Significant Issues

Non-significant issues were defined by the interdisciplinary team (IDT) as those 1) outside the scope of the 

Proposed Action; 2) already decided by law, regulation, forest plan, or other higher-level decision; 3) 

irrelevant to the decision to be made; 4) conjectural and not supported by scientific or factual evidence; or 5) 

the comment could not be phrased as a cause-effect relationship. The Council on Environmental Quality 

(CEQ) NEPA regulations explain this delineation in §1501.7, “...identify and eliminate from detailed study 

the issues which are not significant or which have been covered by prior environmental review... (§1506.3).”

The evaluation for determining if an issue was not significant is disclosed in the Finding of No Significant 

Impact, which discusses the context of the project and intensity of effects using the ten factors identified 

in 40 CFR 1508.27(b), relative to the definition of significance established by CEQ regulations (40 CFR 

1508.13). Appendix C of this EA presents best management practices (BMPs) the SRNF considers

standard operating practices.

Relevant Issues

For the purposes of this environmental analysis, two relevant issues were identified by the IDT in 

response to public comments received during the Scoping period that influence project design—

mitigation measures required prior and during implementation, and post-implementation monitoring of 

the Proposed Action disclosed in Chapter 2 (Alternative 2). Chapter 3 presents the analyses of the 

relevant issues, in context of the potential effects of no action, compared to the potential effects of 

implementing the Proposed Action.
Chapter 1. Purpose and Need

Final Environmental Assessment – 15

Wildlife Habitat Quality

o The reduction of forest ladder and select crown fuels may lower habitat quality for the NSO.

Soil Erosion

o Tree removal and associated operations (i.e., skidding, temporary road and landing construction), 

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

elevate sedimentation/siltation and turbidity contributing to cumulative effects for the Ruth LakeMad River (180101020203) and Barry Creek-Mad River (180101020202) watersheds (EPAlisted: Clean Water Act §303(d) impaired 1992).

Comments on the Draft EA

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

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

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

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

EA comment period and the response to these comments is located in Appendix A of this final EA.
Chapter 1. Purpose and Need

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

This page intentionally left blank.
Chapter 2. Alternatives Considered in Detail

Final Environmental Assessment – 17

Chapter 2. Alternatives Considered in Detail

The Agency is required to study, develop, and describe alternatives to the Proposed Action in any 

proposal that involves unresolved conflicts concerning alternative uses of available resources (40 CFR 

1501.2(c)). The No Action Alternative (Alternative 1) and the Proposed Action (Alternative 2) developed 

to respond to the purpose and need for action, are described below.

Alternative 1 – No Action

The No Action Alternative provides a baseline for comparing predicted effects of the Proposed Action. 

Under the No Action Alternative, proposed treatments under Alternative 2 would not occur.

How large an area wildfire may burn within and surrounding the 1st 48 Project area is influenced by fuel 

types and patterns, air and ground moisture, and wind speeds at the time of ignition; steepness of 

topography; and length of the fire season (Miller and Urban 2000). Current wildfire high-severity patch 

sizes and areas in many forests that once burned frequently with low- to moderate-intensity fire regimes 

are well outside historical conditions (Safford et al. 2009).

“The current conditions of many seasonally dry forests in the western United States, especially those that 

once experienced low- to moderate-intensity fire regimes, leave them uncharacteristically susceptible to 

high-severity wildfire today. Both prescribed fire and its manual and mechanical surrogates are generally 

successful in meeting short-term fuel-reduction objectives, such that treated stands are more resilient to 

high-intensity wildfire (Stephens et al. 2012).

Recent fire events show that continued fire exclusion and barriers to managing fire within its historic 

regime perpetuates risk to the public and fire management personnel. Former US Forest Service Chief 

Tom Tidwell reflected on this in his 2014 letter of intent:

“We do not accept unnecessary risk or transfer it to our partners or future generations.

Enabling fire to be managed at an acceptable level of risk now would mitigate 

unacceptable consequences and reduce risk to future generations.”

Fire Suppression

Within the project area, the appropriate response for a wildland fire would be direct and indirect suppression 

tactics, in alignment with the National Cohesive Wildland Fire Management Strategy (Cohesive Strategy). 

The US Forest Service (USFS or Forest Service) policy for fire suppression is to conduct fire suppression in 

a timely, effective, and efficient manner with a high regard for public and firefighter safety. It is the 

objective of the Forest Service to respond to each wildland fire ignition in a timely manner with appropriate 

forces. Firefighting resources would continue to focus strategies and tactics to suppress wildfires closest to 

at-risk parcels of private property in the wildland-urban interface (WUI), as the highest priority. A 

combination of direct attack (firefighter suppression crews) and aerial attack will likely be necessary if 

ignition occurs late summer, due flammable forest vegetation likely to contribute to high-intensity fire 

behavior that could threaten communities, infrastructure and natural resources.
Chapter 2. Alternatives Considered in Detail

18 – 1st 48 Roadside Fuelbreak Collaborative Project

Fire Prevention

Wildland fire prevention activities would continue to occur under the No Action Alternative. Wildland fire 

prevention is the informing, educating, and regulating of human behavior or activities that influence the 

various types of potential ignition sources within flammable vegetation. A review of historic wildfire 

records from 1913 to 2015 indicates the majority of ignitions occurred less than a half mile from private 

properties. Efforts to educate the public on safe fire use would continue through personal contacts, 

interpretive programs, interagency fire prevention cooperatives, the use of posters and signs, radio and 

press releases. Continuation of public neighborhood fire-prevention meetings, discussions of defensible 

space, fire apparatus access, education about home construction materials (flammability) design, etc., 

would continue to take place.

Alternative 2 – Proposed Action

The Proposed Action represents an opportunity for the Forest Service and members of the Trinity County 

Collaborative (TCC) to co-develop, establish, and maintain shaded roadside fuelbreaks along Forest 

Service roads (FSRs) classified as Maintenance Level (ML) 2 and 3, open to the public and visitors, 

providing access for firefighters during a wildfire.

The Proposed Action would establish roadside fuelbreak networks (both tree shaded and unshaded where 

open forest conditions occur) over approximately 821 acres within the wildland-urban interface (WUI). All 

proposed treatments would occur at varying widths, from a minimum of 25 feet on one side up to 275 on the 

other, not exceeding a total 300 foot width. Fuelbreaks would be established along either side of Forest 

Service Roads (FSR) 01S23 (Route 23), 02S02, 2S47, 2S48, 2S49, 2S50, 2S51, 2S52 and 2S53, and one (1) 

motorized trail (Jeep Trail 8E20). All proposed treatments would reduce hazardous surface and ladder fuels 

and breakup intermingled tree crown fuels, while maintaining sufficient tree shade to curb brush response.

The Proposed Action would thin suppressed, intermediate and co-dominant trees using cable- and groundbased mechanical methods (tractor). Hazardous fuels (trees up to 8-inch diameter at breast height (dbh)) 

would be hand-cut with chainsaws, chipped, pruned and brush masticated, followed by machine (dozer or 

small excavator equipped with a brush rake) and hand-piling debris, manually lopping and scattering 

surface and small ladder fuels, prescribed jackpot burning and underburning in oak woodlands to 

stimulate oak regeneration.

In addition, the Proposed Action would thin trees growing in plantations and oak woodlands bordering 

roadways, beyond the 275-foot maximum on one side of FSRs. Additionally, along the outer perimeter of 

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

flank or buffer intersecting with the roadway.

In the areas burned by high-intensity wildfire in 2011, proposed treatments target HFR to decrease postfire, jackstraw snags and dead woody material.

The proposed treatments considered in this project were designed in accordance with the TCC’s “proof of 

concept” criteria as follows:

o Thin existing stands to retain the best, healthiest trees that have a high canopy capacity (those 

with the strongest crown to bole ratio, have the highest needle or leaf cover and provide the most 

shade to the forest floor), capable of maintaining those objectives for a long time.
Chapter 2. Alternatives Considered in Detail

Final Environmental Assessment – 19

o Designate for removal suppressed, intermediate, and co-dominant conifer trees that compete with 

the best, healthiest trees that have a high canopy capacity, retaining trees per acre (TPA) objective 

by stand type.

o Reduce fuel loading to consistent with the Six Rivers National Forest (SRNF) Land and Resource 

Management Plan (LRMP or forest plan), including brush and down logs, maintaining largest 

downed wood to meet soil and terrestrial wildlife standards and guidelines (S&Gs) incorporated 

into the project design features (PDFs).

o Outside the dripline of larger trees designated for retention, provide for crown separation to 

prevent torching, while retaining vigorous clumps of healthy intermediate mixed conifer trees to 

provide for more complex stand diversity and a source of future mature trees.

o Retain hardwood trees. Thin hardwood clumps to one to three dominant stems where appropriate.

o Trees that provide valuable wildlife structures would be considered as part of the shade-retention 

objective.

o No new temporary road construction is permitted. Reuse of existing skid trails, temporary roads 

and Forest Service roads classified ML 1, closed roads opened temporarily to expedite operations, 

would be prioritized.

o Directional tree felling and cable end lining would occur in areas requiring limited skidding.

o Where fuel reduction prescriptions result in utilizable material, products such as sawlogs, post 

and poles, commercial and personal firewood would be offered.

o Roadside decking and reuse of existing landings and turnouts would occur. New landings on 

roads would be considered on a limited basis, but would not be located in riparian reserves.

o Retain all snags greater than 20-inch dbh, unless the snag would jeopardize the effectiveness of 

the fuelbreak or could be considered a hazard tree. Hazard trees that meet the Region 5 Hazard 

Tree Guidelines (April 2012 Report RO-12-01) would be felled and removed or, if 

unmerchantable, would be left on-site for coarse down wood retention. Snags not considered a 

hazard that are located greater than 100 feet from a road may be left standing to be utilized by 

wildlife, or felled and left onsite limbed with bole unbucked.

Developing, Establishing and Maintaining Fuelbreaks

The proposed treatments apply to a diverse range of fuel conditions associated with variable fuel profiles, 

vegetative types, tree densities and age, and crown classes. The following presents the proposed treatment 

methods under two overarching categories—shaded fuelbreaks and unshaded fuelbreaks.

Shaded Fuelbreaks (SFB)

A shaded fuelbreak is a wide-strip or block strategically located where fuel concentrations and forest 

vegetative flammability have been reduced and some forest canopy is retained to affect fire behavior, so 

that fires burning into them can be more readily controlled. In addition to reducing ground and understory 

ladder fuels, and increasing crown spacing, a shaded fuelbreak should maintain effective shade to subdue 

understory re-growth. It is recognized tree species is relevant to the trees potential to provide shade, as 

conifers maintain live tree crown year-round, whereas hardwoods lose their leaves seasonally. Slope 

steepness can affect the width of the area that provides effective shade. As slope steepness decreases, the 

width of the area providing effective shade will be narrower; as slope steepness increase, the width of the 
Chapter 2. Alternatives Considered in Detail

20 – 1st 48 Roadside Fuelbreak Collaborative Project

area producing effective shade will increase. The sun’s position throughout the day and the topographic 

characteristics influence the angle and timing of maximum shade, as depicted in Figure 5.

Shaded fuelbreaks would be established where existing live-tree overstory canopy closure of roadside 

forest stands is greater than 60 percent. These forested stands are predominately Douglas-fir dominated, 

inter-mixed with incense cedar, ponderosa and sugar pine and hardwoods. These conditions are referred 

to as natural stands, although most have experienced some level of land management such as individual 

tree selection and sanitation. Treatments within shaded fuelbreaks would be implemented as follows:

o Initial Entry: Thin from below (TFB), treating crown fuels and larger ladder fuels.

o Secondary Entry: Hazardous fuels reduction (HFR), treating smaller ladder and surface fuels 

using mechanical and manual treatments, and prescribed jackpot burning (see HFR section below 

for the treatment description).

o Maintenance: Hazardous fuels reduction, primarily through mastication, unless slope or resource 

protection prohibits mechanical ground-disturbance, whereby manual treatments and jackpot 

burning would occur.

Thin from Below (TFB)

Thin from Below (TFB) is the removal of trees when forest conditions are overly dense, with high crown 

density and ladder fuels. The TFB treatments are designed to retain sufficient tree canopy to provide shade

to suppress brush response, while separating intertwined crowns that would likely carry flames from treetop to tree-top. The fuels material not removed by TFB treatments would be treated during a second entry,

as described under the HFR section below.

Crown Class

Crown class is a method to identify leave trees in the field by its tree height relative to other trees around it 

(Table 2; Helms 1998). For the purposes of this EA, crown class is correlated the trees’ potential to provide 

shade, tree health and growth rate. Thin from below treatment prescriptions would leave the largest trees 

Figure 5. Shade created by a healthy tree crown.
Chapter 2. Alternatives Considered in Detail

Final Environmental Assessment – 21

with the fullest crowns (refer to the discussion about live crown ratio below) at or above the average 

canopy height. The trees selected for retention would have sufficient vigor to respond to thinning release to 

sustain healthy live crowns and shade for the long term. In order to achieve the desired density, thinning 

would begin with the smallest diameter trees and move up in size class until the desired canopy base 

height, spacing between trees, and spacing between live tree crowns is achieved. The live crown is the top 

part of a tree, the part that has green leaves (as opposed to the bare trunk, bare branches, and dead leaves).

Table 2. Crown class definitions.

Crown Class Definition

Pre-dominant A tree whose crown has grown above the general level of the upper canopy.

Dominant

A tree whose crown extends above the general level of the main canopy in even-aged stands, or in unevenage stands, above the crowns of the tree’s immediate neighbors and receiving full light from above and 

partial light from the sides.

Co-dominant

A tree whose crown helps form the general level of the main canopy in even-aged stands, or in uneven-age 

stands, the main canopy of the tree’s immediate neighbors, receiving full light from above and comparatively 

little from the sides.

Intermediate

A tree whose crown extends into the lower portion of the main canopy of even-aged stands, or in unevenaged stands, into the lower portion of the canopy formed by the tree’s immediate neighbors, but shorter in 

height than the co-dominants; receiving little direct light from above and none from the sides.

Suppressed

(overtopped) A tree whose crown is completely overtopped by the crowns of one or more neighboring trees.

Live Crown Ratio

Live crown ratio (LCR) provides a measure of tree vigor and crown shading potential. The LCR is a 

measure used to determine tree health and the level of competition with neighboring trees, in terms of 

ratio of crown length relative to total tree height, or the percentage of a tree’s total height that has foliage 

as illustrated in Figure 6.

Tree-level productivity can be assessed using crown size and aboveground vigor, but light availability 

ultimately controls growth. Thin from below involves the selective cutting, disposal or removal of some trees 

Figure 6. Live Crown Ratio: the ratio of live crown to total tree 

height; expressed as a percentage.
Chapter 2. Alternatives Considered in Detail

22 – 1st 48 Roadside Fuelbreak Collaborative Project

within a stand, in order to reduce over-topping and provide space between tree crowns to promote tree bole 

and crown growth. Lowering tree densities reduces competition of underground root systems for limited 

resources (water and soil nutrients) between the remaining trees. The proposed treatments were designed to:

o Maintain and enhance the existing vegetative diversity, including hardwoods.

o Retain pre-dominant and dominant trees that provide the healthiest shade-producing canopy and 

leaf density, while removing suppressed, intermediate, and some co-dominant trees that interfere 

with the health or canopy of the designated retained trees.

First priority for removal would be the smaller suppressed and intermediate crown classes, as these 

smaller diameter trees have the poorest crowns and tend to grow below the forest canopy. They are at the 

highest risk for tree mortality, because of competition for light, water and nutrients.

Some co-dominant trees would also be removed to improve the function of the fuelbreak, increase growth 

of adjacent trees and to meet the desired residual stand density. The following conditions for removal of 

co-dominant conifers include where:

o Co-dominant conifers do not have growing space in the canopy for further crown development, or 

removal of co-dominant trees is needed to reduce stand density to desired levels.

o Removal of co-dominant conifers adjacent to dominant and pre-dominant conifers and 

hardwoods, or pockets of smaller diameter hardwoods, would facilitate the survival of these trees.

Thin from Below (TFB) – Treatment Descriptions by Vegetative Stratum

The TFB treatment prescriptions are described to retain variable tree canopy spacing and trees per acre, as 

presented in Table 3.

Table 3. Treatment crown spacing and trees per acre by seral type.

Seral Stage5 Age Dominant Tree Species Trees per Acre Proposed Treatment Spacing 

between Trees Crowns (ft.)

P 35-45 DF 120-180 5-10

EM 70-100 DF-BO 55-80 5-15

EM/MM 70-120 DF-PP-BO 45-60 5-15

MM 100-120 DF-BO 45-55 5-10

EM 60-100 WF 90-105 2-5

As linear roadside treatment units feature multiple stratum and seral stages, tree canopy spacing and number 

of trees per acre would vary in response to stratum types discussed below and micro-site conditions.

White Fir Dominated – Thin from Below

White fir dominates the higher elevations, generally above 4,600 feet and down to 4,000 feet on northerly 

slope aspects. Douglas-fir is a component of these stands at lower elevations, with the higher elevations 

stands primarily composed of white fir. Ponderosa pine, sugar pine, incense cedar, black oak and white 

oak are minor components, dispersed throughout the strata.

Below 4,000 feet, natural stands are dominated by Douglas-fir, inter-mixed with cedar, pine and 

hardwoods with varying structural complexity and age classes.

 5 Pole (P), Early Mature (EM), Mid-mature (MM)
Chapter 2. Alternatives Considered in Detail

Final Environmental Assessment – 23

The priority consideration for identifying desired shade trees to be retained for the long term are those 

tree with healthy, full, live crown characteristics. Tree crown separation would be variable (hardwood 

canopy would not be taken into account for crown spacing).

Oak-Dominated Woodlands – Thin from Below and Prescribed Burning

The early and mid-mature stands dominated by hardwoods and grasses include black oak, white oak and 

big-leaf maple. Through restoration activities, the oak woodlands within 150 feet of the roadside would 

also contribute to the function of the shaded fuelbreaks. Fire exclusion has allowed vegetation such as 

shrubs and Douglas-fir to encroach upon the oak woodlands. Forage value for wildlife species has 

declined, choked out by competing, decadent brush. Regeneration of oak has waned, as thick dead and 

matted grass is preventing seedling germination, establishment and survival.

The following criteria define healthy black oaks to be retained:

o Greater than 6-inch dbh (for groups of trees or in stands with very little hardwood component),

o Relatively straight (lean is less than 20 degrees from base to top of crown),

o Live crown ratio of at least 20 percent, and

o Basal portion of bole of trunk mostly sound with less than 50 percent noticeable rot or large 

cavity present.

Thin from below treatments in oak woodlands would:

o Remove conifers (suppressed, intermediate and co-dominant trees) competing with hardwoods, 

that would respond favorably to increased sunlight, as depicted in Figure 7.

o Retain pre-dominant and dominant conifers.

Figure 7. Competition between suppressed and intermediate trees growing 

underneath and around a healthy predominant black oak with a full, healthy live 

crown, being measured by a forester.
Chapter 2. Alternatives Considered in Detail

24 – 1st 48 Roadside Fuelbreak Collaborative Project

In areas of extensive brush, pre-treatment (hand piling and burning) of shrubs and small diameter trees 

may be necessary prior to underburning to promote low-intensity fire behavior. In some cases, debris 

would be manually raked back from the base of pre-dominant trees to protect surface roots and trees from 

scorching and to buffer a Forest Service Sensitive-listed lichen species to protect habitat.

The project would restore the grassy areas through pre-treatment to allow for application of prescribed 

fire to rejuvenate and reinvigorate the grass and other grassland species and to remove encroaching 

vegetation. Low-intensity fire would be allowed to creep into brushy areas, killing the brush and small 

diameter trees, maintaining approximately 10 to 20 percent of the small trees in these areas. Not all areas 

of brush would be burned; some would be retained as cover areas for wildlife. Some post treatment piling 

and burning may also occur in areas where brush is not completely consumed during the first entry 

burning operations. These areas may be burned more than once in order to achieve the desired results. 

Burning the area more than once would allow the use of low-intensity fire, which would maintain 80 to 

90 percent of the overstory trees, while reducing the amount of brush and small trees.

Understory burning would be prescribed in the oak woodland to help maintain the desired species 

composition and retard conifer encroachment in these units. Maintenance burns would be implemented 

every 5 to 15 years or as the need is identified.

Unshaded Fuelbreaks

Unshaded fuelbreaks (USFB) occur where current overstory forest canopy cover is less than 60 percent. 

These conditions are associated with forest stands managed using even-age land management practices 

such as clearcutting (existing plantations), shelterwood and seed tree harvesting, and moderate and high 

severity burn areas within the Ruth Fire perimeter, where isolated live tree canopy exists.

The HFR treatments in USFB would implemented as follows.

o Initial Entry: Hazardous fuels reduction, treating small and mid-size ladder and surface fuels 

using mechanical and manual treatments, and prescribed jackpot burning.

o Maintenance: Hazardous fuels reduction, primarily through mastication, unless slope or resource 

protection prohibits mechanical ground-disturbance whereby manual treatments and jackpot 

burned would occur.

Hazardous Fuels Reduction Treatment Methods

A combination of the following HFR treatment methods may be applied, depending on the variability of 

fuel concentrations, distribution and size of hazardous material.

Hand Cutting of Trees and/or Shrubs

This treatment manually cuts dense brush or small trees using chainsaws, and entails the removal or 

rearrangement of forest understory vegetation and is often used in conjunction with lop and scatter.

Where large overstory trees are not present, a mosaic of smaller, vigorous trees and large shrubs such as 

old growth manzanita would be maintained to provide shade.

Removal

This treatment removes cut material not removed as sawlogs, poles or firewood, in excess of wildlife 

standards. Ground-based equipment, such as a dozer or small excavator (equipped with a brush rake) are 

used on slopes less than 35 percent to remove material to the roadside or nearby landings. On slopes 

greater than 35 percent, a block and tackle cable system is typically used to achieve one-end suspension.
Chapter 2. Alternatives Considered in Detail

Final Environmental Assessment – 25

Tree and Large Shrub Pruning

This method eliminates ladder fuels and raise crown base height by cutting branches from residual trees 

or mature shrubs. Large trees would be pruned above the ground and smaller trees to about 50 percent of 

the live canopy. Large shrubs would be pruned to remove dead limbs and lower branches. This is typically 

accomplished with chain saws or long-handled pole saws.

Lop and Scatter

Lop and scatter is a method of slash reduction where down fuel accumulations and concentrations are 

manually cut and dispersed to a maximum depth of 18 inches (with chainsaws and hand labor). This 

places woody material in proximity to the soil, where decomposition and soil building processes occur.

Mastication

Masticators are typically small-tracked vehicles, such as a skid steer with a forward mounted drum-like 

attachment with external masticating teeth, used to cut and shred woody material and live vegetation. 

Excavators may also be employed, utilizing a smaller masticating head (drum or rotary), which attaches to 

the boom. Mastication within treatment units would occur on slopes less than 35 percent. Cutting brush and 

small trees within road prism cut and fill slopes greater than 35 percent may be accomplished by an 

excavator masticator (while positioned in the road) in lieu of cutting and chipping. Shrubs and trees 

generally less than 8-inch dbh may be masticated to achieve desired inter-tree (ladder fuel) spacing and be 

applied to treat re-sprouting brush, regrowth and fallen debris to maintain desired fuelbreak conditions.

Chipping

Roadside mechanical cutting and shredding of existing surface fuels and slash created from tree felling 

and yarding. Existing ground fuels, thinning and pruning residue, and cut brush would be pulled to the 

road and chipped into small pieces using a chipper. Chipping residue would be distributed back into the 

treatment unit, utilized for biomass, or utilized as a cover to reduce the risk of invasive plant 

establishment at landings.

Machine or Grapple Pile

This method would utilize equipment to pile slash and surface fuels into larger piles.

Handpile

Down fuel accumulations and concentrations are mechanically broken up (with chainsaws and hand 

labor) and manually piled in concentrations of 3 to 6 feet in diameter. Excessive existing forest debris, 

along with woody debris (slash) from tree felling and shrub cutting, would be manually gathered into 

small piles.

Pile Burning

Piles would be covered with Kraft paper to allow woody debris to dry out prior to ignition, promoting 

rapid consumption of debris to minimize smoke production. Piles are usually burned after the area has 

received sufficient rainfall so that fire does not spread pile to pile.

Jackpot Burning

Jackpot burning is the burning of discontinuous, concentrated areas of slash created from vegetation 

treatments or natural fuel concentrations. Burning would typically occur following an extended period of 

dry weather to allow the slash to cure for optimal consumption. Fuel concentrations would be burned just 

prior to or during wet weather conditions to ensure controlled fire.
Chapter 2. Alternatives Considered in Detail

26 – 1st 48 Roadside Fuelbreak Collaborative Project

Underburning – Oak Woodlands

Prescribed underburning involves the controlled application of fire to understory vegetation and coarse 

woody material. This would occur when fuel moisture, soil moisture, and weather and atmospheric 

conditions allow the fire to be confined to a predetermined area and intensity can be managed to achieve 

the desired resource objectives. Where no local features are present to contain prescribed fire (roads, 

trails, streams), hand fire line or a wet control line would be established along the outside edge of 

treatment burn areas.

Hand Fireline Construction

Hand-constructed control lines (typically 18 to 20 inches wide), involving scrapping duff and debris to 

expose bare mineral soil, would be used to contain prescribed fire within burn plan specifications.

Hazardous Fuels Reduction Treatment Descriptions by Stand Type

Plantations

Treatments within plantations would be designed to improve tree vigor and fire resiliency of the stand. 

For the purposes of this EA, plantations represent stands managed prior under even-age forestry practices 

(clearcut, shelterwood and seed tree methods). The goal of HFR treatments are to retain the largest trees 

with the best crowns promoting bole and crown growth and tree vigor. The management of tree densities 

aims to reduce inter-tree competition for limited resources in overstocked, reforested stands (plantations), 

as environmental stressors can make trees prone to disease and insects, slowing growth or resulting in tree 

mortality. As the objective is to develop shaded fuelbreak conditions, maintaining sufficient live tree 

canopy becomes essential to achieve long-term goals.

Where trees of different species are clumped, and any species would achieve desired canopy closure, 

preference for leave trees would be native species (over planted off-site pine). Residual overstory trees 

(dominant shade trees) scattered within plantations would be retained, except in the event it is highly 

infested with mistletoe (over 80 percent) and/or there are visible signs of imminent mortality. These 

overstory trees would be felled and left on-site.

Hazardous fuels reduction would increase inter-spacing to 5- to 20-foot spacing (15-plus-foot tall or more 

desired leave trees), depending on the size of trees growing within plantations. In addition, ladder and 

surface fuels would be treated in the 150-foot-wide buffer around them. One or more of the following 

treatments may be applied:

o Hand treatments would be by chainsaw.

o Mastication would occur only in ground-based units (less than 35% average slope) and use lowground-pressure mechanical equipment to cut live vegetation.

o Material would be masticated to treat surface and ladder fuels above the ground surface. 

Approximately 48 acres may be masticated depending on cost and availability of equipment.

o If mastication does not occur, the units would be hand piled and burned. Two of the units, 409 and 

615, have larger diameter boles with the potential to be removed and utilized commercially as poles.

o Remaining trees would have limbs pruned on the bole from the ground, maintaining at least 50 

percent of the crown.

Jeep Trail 8E20

Hazardous fuel reduction would occur along Jeep Trail 8E20, considered a strategic feature during fire 

suppression as a containment fireline. Along the trail, overly stocked live early to mid-mature white fir 
Chapter 2. Alternatives Considered in Detail

Final Environmental Assessment – 27

stands exist. Dead snags would either be masticated, pushed over with a small dozer and/or machine piled 

and burned (10% of the handpiles would be left for wildlife).

o Hazardous fuels reduction treatments would include thinning ladder fuels and may involve cutting 

of understory vegetation, tree pruning, chipping and/or mastication of surface and small ladder 

fuels, lopping and scattering of fuel, hand or grapple piling of fuel, and jackpot and, or pile burning.

o In areas dominated by brush and grass, live trees would be maintained to provide shade and their 

limbs pruned to six feet above the ground.

Burned Forests – Mixed and High-Severity Burn Areas

Mixed and high severity burn areas within the 2011 Ruth Fire footprint are composed of mostly dead 

standing trees (snags), scattered and small patches of live trees, and areas of brush. Since sufficient live 

overstory crowns are not present to establish shaded fuelbreaks, the Proposed Action would treat these 

unshaded fuelbreaks as follows:

o In high severity burn areas dominated by snags, all green trees would be retained.

o In low or moderate severity burn areas, some green trees would be removed.

o Standing dead trees may be either masticated, pushed over with a small dozer and/or grapple 

piled and burned (10% of piles would be left for wildlife).

o Within riparian reserves, limit snag felling within 160-foot buffer using chainsaws only. Hand 

pull slash concentrations upslope to the outer 80 to 160 feet of riparian buffers.

o Handpile and burn slash.

A small meadow enhancement area on the south edge of the burn is primarily composed of off-site pine 

and standing, dead burned fir. All dead conifers would be removed. Live oaks, madrone, and maples 

would be retained.

Maintenance of Fuelbreaks

Once initial treatments have been completed, maintenance would be performed as needed over 15 years. 

The areas may be retreated by utilizing a combination of aforementioned treatments (Table 4). On slope 

less than 35 percent, mastication would be the primary maintenance method. On steeper slopes, lop and 

scatter and/or handpiling and/or jackpot burning would be applied.

Understory burning would be the primary maintenance method applied in the oak woodland stand. This 

method would have mutual benefits to maintain the desired species composition and retard conifer 

encroachment. Site-specific review by a fuels specialist would be conducted prior to understory burning 

to assess fuel loading and necessity for manual pre-treatment to ensure that a low-intensity underburn can 

be achieved.
Chapter 2. Alternatives Considered in Detail

28 – 1st 48 Roadside Fuelbreak Collaborative Project

Table 4. Proposed Action treatment summary.

Unit # Acres Treatment Types Forest Byproducts6

100 3 Shaded Fuelbreak and Hazardous Fuel Reduction Timber, Pole and Firewood

101 3 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

102 4 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

103 2 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

104 7 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

105 5 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

106 8 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

107 1 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

108 3 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

109 11 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

111 5 Shaded Fuelbreak and Hazardous Fuel Reduction Timber, Pole and Firewood

112 2 Shaded Fuelbreak and Hazardous Fuel Reduction Timber, Pole and Firewood

201 3 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

202 1 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

203 2 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

204 2 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

205 7 Shaded Fuelbreak and Hazardous Fuel Reduction Timber, Pole and Firewood

206 3 Shaded Fuelbreak and Hazardous Fuel Reduction Timber, Pole and Firewood

207 10 Shaded Fuelbreak and Hazardous Fuel Reduction Firewood

301 4 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

302 3 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

303 0.5 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

304 0.5 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

305 1 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

306 13 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

307 1 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

308 3 Hazardous Fuel Reduction Firewood

309 1 Shaded Fuelbreak and Hazardous Fuel Reduction Elk Habitat; Firewood

310 1 Shaded Fuelbreak and Hazardous Fuel Reduction Firewood

311 2 Shaded Fuelbreak and Hazardous Fuel Reduction Timber, Pole and Firewood

312 7 Shaded Fuelbreak and Hazardous Fuel Reduction Timber, Pole and Firewood

313 1 Shaded Fuelbreak and Hazardous Fuel Reduction Elk Habitat

401 19 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

402 15 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

403 7 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

404 4 Oak Woodland Maintenance – Hazardous Fuel Reduction Elk Habitat; Firewood

405 12 Shaded Fuelbreak and Hazardous Fuel Reduction Timber, Pole and Firewood

406 4 Shaded Fuelbreak and Hazardous Fuel Reduction Timber, Pole and Firewood

407 16 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

408 6 Shaded Fuelbreak and Hazardous Fuel Reduction Timber, Pole and Firewood

409 15 Plantations – Hazardous Fuel Reduction Pole and Firewood

410 9 Shaded Fuelbreak and Hazardous Fuel Reduction Timber, Pole and Firewood

411 16 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

412 24 Shaded Fuelbreak and Hazardous Fuel Reduction Timber, Pole and Firewood

413 30 Hazardous Fuel Reduction Firewood

 6 Timber – potential commercial sale of sawlogs; Poles – potential for commercial forest products sale; Firewood – potential for 

commercial firewood sale or where roadside or on landings, potential for personal firewood cutting.
Chapter 2. Alternatives Considered in Detail

Final Environmental Assessment – 29

Unit # Acres Treatment Types Forest Byproducts6

414 20 Hazardous Fuel Reduction Firewood

415 3 Hazardous Fuel Reduction Firewood

416 3 Oak Woodland Maintenance – Hazardous Fuel Reduction Elk Habitat; Firewood

419 17 Hazardous Fuel Reduction Firewood

420 26 Shaded Fuelbreak and Hazardous Fuel Reduction Firewood

421 2 Shaded Fuelbreak and Hazardous Fuel Reduction Timber, Pole and Firewood

422 2 Shaded Fuelbreak and Hazardous Fuel Reduction Pole and Firewood

423 6 Shaded Fuelbreak and Hazardous Fuel Reduction Pole and Firewood

424 4 Shaded Fuelbreak and Hazardous Fuel Reduction Timber, Pole and Firewood

501 6 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

502 5 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

503 3 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

504 4 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

505 1 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

506 14 Hazardous Fuel Reduction Firewood

507 31 Hazardous Fuel Reduction Firewood

508 12 Plantations – Hazardous Fuel Reduction Pole and Firewood

509 13 Shaded Fuelbreak and Hazardous Fuel Reduction Timber, Pole and Firewood

510 8 Plantations – Hazardous Fuel Reduction Pole and Firewood

511 2 Hazardous Fuel Reduction Firewood

601 6 Hazardous Fuel Reduction Firewood

602 4 Hazardous Fuel Reduction Firewood

603 7 Hazardous Fuel Reduction Firewood

604 12 Hazardous Fuel Reduction Firewood

605 41 Shaded Fuelbreak and Hazardous Fuel Reduction Timber, Pole and Firewood

606 20 Plantations – Hazardous Fuel Reduction Pole and Firewood

607 11 Plantations – Hazardous Fuel Reduction Pole and Firewood

608 32 Plantations – Hazardous Fuel Reduction Pole and Firewood

609 7 Hazardous Fuel Reduction Firewood

610 5 Oak Woodland Maintenance – Hazardous Fuel Reduction Elk Habitat; Pole and Firewood

611 8 Shaded Fuelbreak and Hazardous Fuel Reduction Timber, Pole and Firewood

612 2 Plantations - Hazardous Fuel Reduction Pole and Firewood

613 25 Oak Woodland Maintenance – Hazardous Fuel Reduction Elk Habitat; Pole and Firewood

614 2 Shaded Fuelbreak and Hazardous Fuel Reduction Pole and Firewood

615 8 Plantations Hazardous Fuel Reduction Pole and Firewood

616 8 Shaded Fuelbreak and Hazardous Fuel Reduction Timber, Pole and Firewood

617 7 Shaded Fuelbreak and Hazardous Fuel Reduction Pole and Firewood

801 15 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

802 37 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

803 10 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

804 7 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

805 23 Shaded Fuelbreak and Hazardous Fuel Reduction Timber

806 27 Shaded Fuelbreak and Hazardous Fuel Reduction Firewood

807 18 Hazardous Fuel Reduction Firewood

Total Acres – 821
Chapter 2. Alternatives Considered in Detail

30 – 1st 48 Roadside Fuelbreak Collaborative Project

The Proposed Action would establish a network of roadside fuelbreaks either side of open FSR roads that 

abut private lands and along Route 23, as displayed in Figure 8.

Figure 8. Proposed Action treatment map.
Chapter 2. Alternatives Considered in Detail

Final Environmental Assessment – 31

Connected Actions

In addition to the aforementioned Proposed Action treatments, there are additional and inherent connected 

actions associated with off-site removal of fuels. According to Council on Environmental Quality (CEQ) 

Regulations (§1508.25) connected actions are closely related actions that automatically trigger (or are 

triggered by) other actions, cannot or would not proceed unless other actions are taken previously or 

simultaneously, and/or are interdependent parts of a larger action and depend on the larger action for their 

justification. The provisions to avoid, rectify or minimize adverse effects of connected actions are 

disclosed in the following project design features (PDFs) and mitigation measures section.

Road Decommissioning

The 1st 48 Project proposes to decommission FSR 2S54. This ML 2 road is 1.95-miles long, and has four (4) 

low-water crossings and three culverted stream crossings. Two of the culverted crossings have small fills 

(150 and 318 cubic yards). One crossing is larger (800 cubic yards). There is a large landslide near milepost 

(MP) 0.65, encompassing the entire road prism, making it impassable for motor vehicles. This landslide 

would not be treated, nor would any other decommissioning activities take place beyond the slide.

Decommissioned NFTS roads are managed in a maintenance-free condition (i.e., drainage structures are 

removed and natural drainage patterns restored). They are not drivable by motor vehicles and are not part 

of the NFTS. Decommissioning FSR 2S54 would require the following activities:

o Waterbar. Water-dispersion treatments are designed to stop water from concentrating on the 

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

the road or trail), which reduces the potential for off-site sediment delivery to water resources.

o Remove culverts and associated fill. This action is aimed at eliminating the need for road 

maintenance, re-establishing pre-road construction drainage patterns, and placing the stream 

crossing road fill in stable locations, away from streams.

o Culvert disposal. Culverts, once removed, would be removed from government property and 

disposed.

o Erosion control. Newly excavated stream channel banks and fill disposal sites would be mulched 

to reduce surface erosion. Mulch would consist of locally available slash, wood chips, wood 

straw, or certified weed-free rice or barley straw.

o Barricade. This includes the placement of an earth mound barrier at the entrance to a road or route. 

The objective is to prevent motorized use and the promotion of passive restoration of the travelway.

o Timing. Work would occur after the limiting operation periods (LOPs) for wildlife are lifted and 

before the onset of winter weather.

o Invasive Plant Species and Aquatic Organisms. If there is a risk of spread of invasive plants from an 

existing occurrence on or along the road to be decommissioned into unoccupied wildland settings 

(e.g., in settings where the vegetative ground and canopy cover in the adjacent habitat is minimal), 

implement the following mitigations prior to decommissioning as per Best Management Practices: 

Invasive Plant Species and Aquatic Organisms, Six Rivers National Forest (2014), forest roadrelated projects (e.g., maintenance including storm-proofing, and road decommissioning):

 Remove entire plant (including roots).

 Mechanically or manually remove any invasive plant occurrence (remove entire plant) at 

the intersection of the decommissioned road and forest system road.
Chapter 2. Alternatives Considered in Detail

32 – 1st 48 Roadside Fuelbreak Collaborative Project

 Apply ground cover in the form of native mulch/finely masticated material spread to 

depth of 6 inches over the area where plants were removed, or

 If feasible, de-compact/rip and revegetate area with suitable native planting stock that 

optimizes resistance to invasive plant establishment (e.g., tree stock, earlysuccessional/disturbance tolerant shrubs).

Felled Tree and Slash Removal

The removal of timber byproducts such as sawlogs, posts and poles, or firewood generated from 

implementing TFB treatments would accomplished through:

o Whole tree yarding and yarding tops to landings. Sawlog material would generally be removed at 

the time of felling operations; posts/poles and firewood may be removed at the time of felling 

operations, decked for future removal, or disposed of by chipping or burning. If these areas are not 

large enough to accommodate the volume of material, existing landings along haul routes that are 

not associated with proposed harvest units could serve as alternate sites for the excess material.

o Any remaining logging/skidding slash concentrations would be treated by one or more methods 

including:

 Lopping and scattering slash to a maximum depth of 18 inches,

 Hand or grapple piling, then burning of piles, including jackpot burning, or

 Yarding materials to landings or disposal areas for future treatment by chipping, burning,

or firewood gathering.

Landings

The project would require one (1) to two (2) landings/disposal sites per unit. Existing landings, roadside 

turnouts and natural openings would be used to the extent they are safe and feasible. The majority of 

additional ground and cable landings would be located within the roadbed; however, some limited 

expansion may be needed. Landings are up to approximately 0.25 acres in size (1/3 acre for disposal sites).

Thirty-three (33) existing landings would be made available to expedite operations, and up to 20 new 

landings would be constructed. Existing and new cable and ground landings would be located either 

within, or adjacent to, treatment units. New landings are generally an expansion of existing areas that 

exhibit some previous ground disturbance located in natural openings within units or roadside turnouts. 

Anchor points above landings/unit would be needed for safety support of cable logging systems. Anchor 

points include 18- to 20-inch trees, sound snags, or heavy equipment parked above the landing. After 

landings have served operations, they shall be ditched and sloped to permit water to drain or spread. 

Unless agreed otherwise, cut and fill banks around landings shall be sloped to remove overhangs and 

otherwise minimize erosion.

Change in Road Maintenance Level

Forest Service Road 2S02B (MP 0.0 to 0.2) is an ML 1 classified road closed to public and administrative 

uses. The maintenance-level classification correlates to how the agency administers the intended use—
Chapter 2. Alternatives Considered in Detail

Final Environmental Assessment – 33

type of vehicle and season(s), closed or open for travel—and maintenance frequency and methods, based 

upon road design, surface conditions, intended vehicle speed, season and amount of motor-vehicle use7

.

Machinery access and log hauling would require this segment of road be upgraded to an ML 2 road, 

allowing for administrative uses. During operations, regular road maintenance would be applied; 

frequency would depend on road surface type and weather. The road would be downgraded to an ML 1 

classification, placed in a hydrologically maintenance-free condition and barricaded to prevent motorized 

access upon completion of the TFB and HFR treatments.

Road Maintenance

In 2015, the forest supervisor authorized the Six Rivers Road Maintenance Project to implement road 

maintenance across the forest (ML 1 to 5), confined to previously maintained surfaces, ditches, culverts 

and cut-and-fill slopes within the road prism, not intended to substantially improve conditions above 

those originally constructed (i.e., did not change maintenance levels). The Forest Service would 

coordinate with the landowners to protect the waterline infrastructure during operations. The following 

maintenance would be completed as previously authorized to expedite operations:

o 2S02B: Heavy brushing, blading, ditch cleaning, and removal of five (5) waterbars.

o 2S02C: Pre-haul blading, moderate brushing, ditch cleaning, and removal of two (2) waterbars.

o 2S47: Pre-haul blading, light brushing, culvert and ditch cleaning, berm removal and removal of 

two (2) waterbars. There is a low-water crossing at about MP 0.8 that would likely dry up during 

the normal operating season. If the road were needed for commercial log hauling, a temporary 

crossing may be required, which involves layering coarse aggregate and removing it post-haul. 

The Forest Service would coordinate with the private land owner prior to operations to ensure 

protection of above ground waterline which supplies water to Ruth Mutual Water Company; 

recently moved in coordination with the permittee to just the outside of the road berm, roughly a 

foot or two from the edge of the road.

o 2S02: The Forest Service would coordinate with the landowner to protect the waterline strung 

across Littlefield Creek near the low water crossing.

o 2S48C: Pre-haul blading, light brushing, culvert and ditch cleaning.

o 2S49: Pre-haul blading, light brushing, and ditch cleaning.

o 2S50: Pre-haul blading, light brushing, culvert and ditch cleaning.

o 2S51: Pre-haul blading, light brushing, waterbars, culvert and ditch cleaning.

o 2S52: Pre-haul blading, light brushing, culvert and ditch cleaning. The forest would coordinate with 

the landowner to protect the waterline that crossed under FSR 2S52 through a Forest Service culvert.

o 2S53: Heavy blading, ditch cleaning, removal of two (2) waterbars, and moderate brushing. There 

is a low-water crossing at MP 0.4 on Littlefield Creek, the same stream as the crossing on 2S02 

downstream. If water is not present during operations, commercial log hauling may proceed. If 

water is present, a temporary low water crossing would be installed and removed prior to the 

onset of high winter flows. The two (2) proposed options include:

 7 Maintenance Level (ML): The Forest Service maintains NFS roads and NFS trails to meet user needs, protect natural resources 

and ensure public safety. There are five maintenance level classifications (FSH 7709.56), responsive to road or trail management 

objectives, design standards, quantity and types of traffic, and availability of funds.
Chapter 2. Alternatives Considered in Detail

34 – 1st 48 Roadside Fuelbreak Collaborative Project

 Temporary vented ford: Install three (3) parallel 36-inch culverts, 30-feet long and build 

the road prism above them. A geotextile would be laid as the foundation of the structure 

and the road prism built on top of it.

 The Forest Service installs a temporary portable bridge.

Existing Temporary Roads

The proposed action includes using up to thirteen existing temporary road spurs, totaling 1.06 miles. 

These existing temporary roads would be barricaded post operations, once the thin from below and HFR

treatment operations are complete to prevent motorized vehicle access. The closure activities would 

involve actions needed to achieve hydrologically maintenance-free conditions.

Haul Routes, and Temporary Trail and Road Closures

Operations occurring on or along forest roads and the existing Jeep Trail 8E20 would require temporary 

closures for public safety during logging operations (tree felling and hauling). There are inherent dangers 

associated with logging with heavy equipment working on and adjacent to the roads, log truck traffic, 

branches, and other debris falling from the canopy. These forest roads are single-lane roads with minimal 

turnouts and it would be difficult to provide for public safety during logging operations. These hazards to 

the public and logging operators would be mitigated through the implementation of temporary road and area 

closures. The following roads and trail (Table 5) may be subject to temporary closures.

Table 5. NFTS temporary road and trail closures.

Road / Trail Maintenance Level Operations

2S47, 2S48, 2S49, 2S50, 2S51, 2S52, 2S53, 2S02 2

1S23 3 Tree removal and hauling

8E20 Motorized Trail

Project Design Features and Mitigation Measures

This section discusses PDFs and mitigation measures to avoid, rectify or minimize adverse effects (or 

implement positive impacts) during implementation of the Proposed Action. These measures would be 

applied during implementation. Upon a final decision, as documented in a Decision Notice, selected 

measures would become a requirement.

The Forest Service is required by CEQ regulations to implementing the procedural provisions of NEPA to 

identify all relevant, reasonable mitigation measures that could improve the project. Mitigation, as defined 

in the CEQ regulations (40 CFR 1508.20) includes:

o Avoiding the impact altogether by not taking a certain action or parts of an action.

o Minimizing impacts by limiting the degree or magnitude of the action and its implementation.

o Rectifying or eliminating the impact over time by preservation and maintenance operations 

during the life of the action.

o Compensating for the impact by replacing or providing substitute resources or environments.

o Rectifying the impact by repairing, rehabilitating or restoring the affected environment.

In order to meet S&Gs, minimize impacts to resources and implement project objectives design features 

and mitigation measures were generated by the SRNF interdisciplinary team (IDT) and TCC:
Chapter 2. Alternatives Considered in Detail

Final Environmental Assessment – 35

Air Quality

• Dust abatement with water would be required during hauling operations (see water drafting design 

features).

• Burning would only be conducted on days approved by the North Coast Unified Air Quality 

Management District (NCUAQMD).

• To reduce negative effects to local air quality, handpiled material would be covered with Kraft paper to 

maintain dry conditions so that when burning does occur the material will be consumed and not smolder.

Aquatic Resources

• The forest would follow the guidance of the wet weather operation standards. The wet weather/winter 

season normally begins October 16 and ends around May 14, but wet weather conditions can happen 

anytime of the year. The Forest Service would monitor ground conditions and make a determination 

when wet weather conditions apply.

• Handlines would be constructed prior to burning operations. After operations are complete and before 

the wet weather season, waterbars would be constructed and the handline footprint would be covered 

(at least 50%) with mulch or duff.

• Riparian Reserves. According to the Northwest Forest Plan (NWFP) S&Gs, the Aquatic Conservation 

Strategy (ACS) was developed to improve and maintain the ecological health of watersheds and 

aquatic ecosystems contained within them on public lands. The following design and mitigation 

measures would be applied to attain ACS objectives:

o All riparian reserves would be buffered on both sides of stream channels. Perennial non-fish 

bearing, intermittent, and ephemeral with scour stream buffers are 160 feet, fish-bearing stream 

buffers are 320 feet, unless intersecting with road networks. The “inner” riparian reserve boundary 

generally extends from the stream channel to one-half the width of the total buffer or break-inslope, with the “outer” riparian reserve boundary corresponding to the full width of the riparian 

reserve. In the case of Littlefield Creek, a fish-bearing stream, the “inner” riparian reserve south of 

the stream would extend to the edge of the road, which is less than 160 feet in many areas, but this 

buffer is considered adequate to prevent impacts to the stream because the area is so flat.

o Canopy closure in the outer riparian reserve buffers would be maintained at 60 percent or greater 

where the shaded fuelbreaks intersect riparian reserves. In unshaded fuelbreaks and oak 

woodlands, existing live trees providing shade would be retained.

o No tree removal is permitted within the inner riparian reserve buffers. Exceptions include hand 

cutting (e.g., chainsaws, brush cutters) trees less than 6-inch dbh within 25 feet where riparian 

reserves intersect roads.

o Directional felling away from streams is required for all vegetation removal within the riparian 

reserves.

o Within the oak woodlands, underburning ignition may occur within riparian reserves only when 

necessary to minimize prescribed fire behavior intensity and/or the potential for burning material 

to roll down into a riparian reserve. No fire lines (scraped to mineral soil) would be constructed 

within riparian reserves; however, a hand-cut brush-only control line would be allowed for 

holding purposes on prescribed fires. Hand piling and pile burning may only occur within a 

riparian reserve if the hand piles are 6 feet or less in diameter, and less than 6 feet in height.
Chapter 2. Alternatives Considered in Detail

36 – 1st 48 Roadside Fuelbreak Collaborative Project

o Best management practices (BMPs) would be followed for activities associated with the project 

to comply with the Clean Water Act.

• Water Drafting

o Draft water only at designated water drafting sites in compliance with 806 dust abatement 

specifications. The pumping rate shall not exceed ten percent of the stream flow.

o Seek streams and pools where water is deep and flowing, as opposed to streams with low flow and 

small isolated pools. The effect of single pumping operations, or multiple pumping operations at 

the same location, shall not result in obvious drawdown of either upstream or downstream pools.

o Conduct operations at water source developments in such a manner as to avoid, minimize or 

mitigate adverse effects to aquatic species and habitats from water drafting. Screens are required 

in fish-bearing steams.

o Adhere to Water Quality BMP water-drafting specification and guidelines at designated water 

sources including:

 Pumping rate would not exceed 350 gallons-per-minute in fish-bearing streams.

 Make no improvements to drafting sites.

 Water drafting by more than one truck shall not occur simultaneously.

 Coordinate with district or forest fisheries biologists to avoid potential effects from water 

drafting.

Botany

• Dendriscocaulon intriculatum (Manage Known Sites) – in Unit 802

o Dendriscocaulon intricatulum is a lichen that grows on the bole and branches of oak trees. 

Lichens exchange water and gases through their “skin” and thus are influenced by changes in 

atmospheric moisture. In light of these ecological variables associated with lichens, the 1st 48 

Project includes design features to reduce potential negative effects of heat and smoke as well as 

maintain residual substrate for Dendriscocaulon intricatulum.

o A 0.25-acre buffer (radius approximately 50 feet) was established at the detection in Unit 802. This 

buffer area is considered a no-disturbance buffer. Trees shall not be fallen into the buffered area.

• Cypripedium montanum (Pre-disturbance Surveys and Site Management) – Adjacent to Unit 421

o Potential habitat disturbing activities related to Cypripedium montanum known sites pertain to 

mechanical disturbance that removes plants, disrupts upper soil horizons, triggers a shift in associated 

species composition, and opens the canopy beyond the tolerance threshold of mountain lady’s 

slipper. To reduce the potential for edge effects to known sites, buffers, their size and dimension, 

would be established considering aspect, slope position, and proximity to riparian areas in mind.

o A 0.5-acre buffer would be established around the occurrence in the riparian zone adjacent to Unit 

421, to account not only for protection of the plants, but to account for habitat elements 

associated with Cypripedium montanum, specifically overstory shading and existing canopy 

layers, existing moisture conditions, maintenance of coarse woody debris, maintenance of 

existing tree, shrub and forb diversity, and adequate habitat around the existing plants for shortrange dispersal of seeds and rhizome. Trees shall not be fallen into the buffered area.

• Ptilidium californicum (Pre-disturbance Surveys and Site Management) – Within Units 419 and 805
Chapter 2. Alternatives Considered in Detail

Final Environmental Assessment – 37

o Dead and down woody debris may be hand removed from the buffered area. No understory 

burning or pile burning would occur within 50 feet of the occupied tree to protect plants.

o Potential habitat disturbing activities related to Ptilidium californicum pertain to extent of canopy 

opening and vegetation manipulation in the vicinity of the documented occurrence which could 

increase drying effects of solar radiation and wind, removal of mature trees around the occupied 

tree which would remove sites for future dispersal opportunities, and broadcast burning that could 

result in torching the base of the occupied tree.

o Two occurrences of Ptilidium californicum were detected, one in Unit 419 and the other in Unit 

805, both on the base of a 36-inch-diameter white fir in a mid-mature stands.

o A no-disturbance buffer of approximately 0.5 acres was established around the occupied trees to 

ensure the retention of the existing vegetation and stand structure, which provides the shade to the 

forest floor surrounding the occupied tree. The buffer incorporated mature trees for future 

dispersal opportunities. Trees shall not be fallen into the buffered area.

• Peltigera gowardii (PEGO, veined water lichen, Sensitive) in Dashield Creek – Unit 421, Outside 

Unit 418

o PEGO sites found in units 421 and 418 are afforded protection based on their locations in the 

creek.

o The no-disturbance buffer would be established around sensitive plant sites in Unit 421 and the 

one outside Unit 418 to protect them from damage.

• Ramaria rubrievanescens (Equivalent Effort Surveys and Site Management) – Immediately adjacent 

to Unit 402

o Ramaria rubrievanescens, a Category B Survey and Manage (S&M) fungi, effects are linked to 

potential habitat disturbing activities, such as removal or severance of mycelial components 

(which comprise the fungal organism) residing in the organic or topsoil layer for mycorrhizal 

fungi, reduction in canopy shade and organic forest floor cover, reduction in the abundance of 

host trees and refuge species to sustain inoculum through periods of successional change in the 

stand, removal or reduction of forest floor organics and coarse woody debris which form the 

primary micro-habitat for saprobic species, and breakdown of soil structure (e.g., compaction) 

which not only affects the mycelia therein but also damages fine root tips to which the mycelia 

attach (Amaranthus et al. 1996).

o A no-habitat disturbance buffer would be established.

o Soil porosity would be maintained to at least 90 percent of its natural condition over at least 85 

percent of the unit area.

o Skid roads and trails would be limited to no more than 15 percent of the harvest area. At the end of 

project activities, a layer of litter and duff would occur over at least 50 percent of the activity area.

o Retain at least five logs per acre of existing coarse woody debris (at least 20 inches in diameter 

and 10 feet long) on the ground.

o All existing large snags (20 inches or greater in diameter) would be retained in units unless they 

pose a safety concern.

o Trees shall be directionally felled away from the buffered area.
Chapter 2. Alternatives Considered in Detail

38 – 1st 48 Roadside Fuelbreak Collaborative Project

Heritage

• Standard Resource Protection design/mitigation measures as defined in the Programmatic Agreement 

among the USDA Forest Service, Pacific Southwest Region (Region 5), California State Historic 

Preservation Officer, Nevada State Historic Preservation Officer, and the Advisory Council on Historic 

Preservation Regarding the Processes for Compliance with Section 106 of the National Historic 

Preservation Act for Management of Historic Properties by the National Forests of the Pacific 

Southwest Region (R5 PA) would be applied to archaeological sites within the APE as follows:

• All known sites would be flagged and heavy equipment would be excluded from working within site 

boundaries.

o FS Site 05-10-54-384, located in a hazardous fuel reduction unit, shall be flagged as an equipment 

exclusion zone prior to implementation.

o FS Site 05-10-54-385 was located in a hazardous fuel reduction/shaded fuelbreak unit, but was 

excluded from the unit after discussions between district staff (archaeologist, foresters, and 

ranger) concluded it would be best for the protection of the resource.

• No landings shall be located within fifty feet of archaeological sites FS Site 05-10-54-384 and FS Site 

05-10-54-385.

• No roadwork shall be done within the boundary of archaeological site FS Site 05-10-54-384.

• No firelines shall be constructed within the boundary of archaeological sites FS Site 05-10-54-384 

and FS Site 05-10-54-385.

• In the event any cultural resources are discovered during implementation, all work in the area shall 

cease and the forest heritage program manager shall be notified immediately. Work shall not continue 

at the location until authorized by the forest heritage program manager.

• Should inadvertent effects to or unanticipated discoveries of human remains be made on Region 5 

lands, the county coroner (California Health and Safety Code 7050.5(b)) shall be notified 

immediately. If the remains are determined to be Native American or if Native American (Indian) 

cultural items pursuant to NAGPRA are uncovered, the provisions of NAGPRA and its regulations at 

43 CFR 10 and ARPA at 43 CFR 7 shall be followed on federal lands (Stipulation 7.9 (a)).

Invasive Species

In keeping with Forest Service policy on invasive species management (USDA Forest Service 2013a), the 

following project design features are identified to reduce the risk of introduction and spread of Centaurea 

solstitialis (yellow star thistle) from its current risk rating of high to a low risk. Priority areas for 

treatment along 2S50 and 2S48 would be flagged in the field prior to treatment. All mechanical 

equipment used in the project, including equipment related to road maintenance, shall be pressured 

washed prior to operating on the forest (USDA Forest Service 2014).

o All mechanical equipment used in the project shall be washed after operating if moving from an 

infested to an un-infested area.

o Treatment of mechanical units shall follow a progression of work schedule, whereby treatment 

occurs first where invasive plants are limited to non-existent before moving to heavily infested areas 

(e.g., lower infested stretch of 2S48). If progression of work is not feasible, equipment operating in 

infested road segments shall be cleaned before relocating (USDA Forest Service 2014). Progression 

of work applies to road maintenance associated with this project as well (see Appendix C).

o Avoid yarding/skidding through yellow star thistle infestations.
Chapter 2. Alternatives Considered in Detail

Final Environmental Assessment – 39

o Immediately before using existing landings occupied by yellow star thistle, mechanically remove 

the plants to the edge of the landing, away from where equipment would be operating; then pile 

and subsequently burn. Use native material (e.g., wood chips produced on site) to mulch landings 

following their use.

o Avoid masticating sections of 2S50 and 2S48 occupied by yellow star thistle.

o Where yellow star thistle infestations are present, surface blade 2S48 in such a way that bladed 

material in not reincorporated into the road travel way but rather is push completely off the travel 

way to prevent it from re-establishment. At landings, use equipment to blade localized invasive 

population to an area where it would not be disturbed.

o In the fall, following surface blading, manually pull or use tools to remove individual plants, 

removing as much of the roots as possible.

o Pile treated plants and burn where treated, or if plant numbers are few, incorporate plant material 

into a nearby burn pile.

o Include treated areas in the prescribed burn footprint.

o If practicable, stockpile wood chips generated on site for application to treated yellow star thistle 

sites.

• Progression of Work. Successful control of yellow star thistle would necessitate periodic monitoring 

and evaluation of treatment efficacy. If present after initial treatment, manually pull or use tools to 

remove individual plants in the late spring of the year (before fruiting/seeding) ensuring removal of the 

roots as much as possible. Pile treated plants and burn where treated, or if plant numbers are few, 

incorporate plant material into a nearby burn pile. The following units occur near yellow star thistle

infestations and, as such should be treated last in order to reduce the risk of introduction and spread: 

308, 401, 402, 403, 404, 405, 406, 407, 408, 409, 410, 411, 418 and 421. If this progression of work 

cannot be implemented, equipment shall be cleaned operating in any of the units associated with the 

section of road identified above, before operating elsewhere.

Range

The southern half of the project area is an active allotment (Van Horn Allotment, Barry Creek sub-unit), 

which includes the upper half of FSR 2S48 road, including all of Jeep Trail 8E20, and the portion of 1S23 

south of Jeep Trail 8E20, all of FSRs 2S47, 2S53 and 2S54, along with the portion of FSR 2S02 in project 

area. Prior to operations, the Forest Service would coordinate with the permittee to ensure cattle are 

protected from harm.

Recreation and Public Safety

• Utilize temporary trail closures during periods of log hauling operations to minimize the potential for 

accidental injury to recreationists during operations. Utilize advanced notice of closures, signing at 

appropriate locations, and notification of various user groups to keep users safe when operations are 

being implemented.

• Identify recreational features (trails, trailheads, signs) on the ground for protection during project 

implementation.
Chapter 2. Alternatives Considered in Detail

40 – 1st 48 Roadside Fuelbreak Collaborative Project

Soils

Minor modifications of PDFs may be allowed with mutual concurrence of the project soil scientist, 

hydrologist, silviculturist, and sale administration staff.

• Heavy equipment operations shall occur when soils are dry enough to avoid deep rutting or puddling; 

operate over a duff and slash “cushion” if possible.

• Limit heavy equipment operations to slopes 35 percent or less.

• Limit temporary roads, landings and skid trails collectively to less than 15 percent of the unit area; 

this is the 15 percent of the area with allowable soil disturbance.

• Maintain 50 to 70 percent soil cover in all units at all times; duff and fine litter less than 3 inches 

diameter are the most desired soil cover components, but rock and larger wood also technically count 

as cover.

• Re-utilize old temporary roads and landings and equipment trails to the maximum extent possible, 

thus minimizing new ground disturbance and avoiding cumulative effects.

• Avoid soil displacement: do not blade topsoil from skid trails, or landings when possible; full bench 

skid trails shall not be constructed.

• Feller-buncher, masticator, and excavator routes are generally NOT restricted to 15 percent of the 

area; however, these are limited to dry soil conditions as with all heavy equipment, and effort should 

be made to minimize turning-related (skid-steer) soil displacement.

• Fuels piling operations (hand and machine): seek a balance between size, number, and distribution of 

piles to maintain overall soil cover requirements and keep bare areas separated by filter strip areas. 

Do not place burn piles adjacent to streams or wet areas to avoid sediment delivery. Place burn piles 

away from existing large woody material.

• Machine piling operations: equipment shall operate from existing skid trails wherever possible to limit 

trafficked area, except where a dozer is necessary for larger material in the burn scar; minimize soil to 

disturbance in order to leave duff in place and keep piles free of topsoil to the extent practicable.

• Burning operations: include in the burn plan specific means to achieve residual soil cover 

requirements of greater than 50 percent cover on slopes less than 50 percent and greater than 70 

percent on slopes greater than 50 percent; preference is for duff and fine litter cover; monitor fuel/duff 

moisture content prior to ignition so that duff will not be consumed over too much area. Protect 

existing large woody material to the extent feasible.

• Cable and end-lining operations: maintain at least one-end suspension of the butt-end of the tree when 

possible so the top canopy end is dragged on the ground; linear gouging of the soil where it occurs 

shall require hand-waterbars and raking of duff and slash back onto the bare area in a timely manner 

with other erosion control measures.

• Rehabilitate temporary roads and landings upon completion of a unit, consider de-compaction by 

ripping with conventional rock rippers (or “dibbling” using an excavator bucket), followed by recontouring if benched or constructed (created using cut and fill), and mulching with native materials 

and/or seeding using Forest Service-approved seed mix. Exceptions may be applied where the project 

soil scientist determines erosion risk is low.

• Erosion control measures shall be kept concurrent with operations, and shall be in place 1) prior to 

any shutdown for anticipated storm events, 2) prior to weekend shutdown if storm events are 

expected, or 3) prior to seasonal shutdown.
Chapter 2. Alternatives Considered in Detail

Final Environmental Assessment – 41

• Sale administration staff should request a site visit by the project soil scientist for units where soil 

disturbance appears severe or excessive (>15% area), for the soil scientist to assess possible 

rehabilitation needs for LRMP compliance.

• Bare soil areas: larger areas (>1/5 acre, not including landings) rendered bare by mechanical 

operations or burning should be monitored for adequate and timely natural revegetation; areas that do 

not revegetate naturally over one (1) winter should be prescribed for mulching and/or seeding with 

Forest Service-approved seed mix to stabilize soils, particularly if signs of erosion are present.

Wildlife

• Shaded fuelbreak construction may occur in suitable threatened, endangered and sensitive species 

habitat. No pre-dominant or dominant trees would be removed. Canopy closure would be maintained 

at 60 percent or greater in all treatment areas.

• The project would not remove potential threatened, endangered, and sensitive species nest trees (predominant trees or dominant) or affect the canopy around potential nest trees in suitable 

nesting/roosting habitat.

• Treatments in suitable northern spotted owl (NSO) habitat within 0.5 miles of Activity Center (AC)

347 will maintain all overstory trees, existing snags (20′′ dbh or greater) unless they pose a safety 

hazard, and downed logs (20′′ dbh or greater and 10 feet long). Only understory brush and small 

diameter trees less than 8-inch dbh may be manually cut. Snags felled for safety reasons would be left 

on site. These restrictions apply to Units 413, 414, 415, 416, 419, the eastern half of 420, and the 

southern half of 806.

• Directional falling away from all pre-dominant trees would be required to protect them from 

incidental breakage during felling operations.

• Snags and logs would be retained as per SRNF LRMP, S&Gs Table IV-8, and Appendix L (treatments 

within late-successional reserves (LSRs)), riparian reserves, units within critical habitat, and suitable

NSO habitat (regardless of land allocation) would maintain snags (20-inch dbh and greater or the 

largest available in younger seral stages) and downed logs (20 inches and greater and at least 10 feet 

long or the largest available) at the 80 to 100 percent level, unless they pose a safety hazard or would 

not meet fuel treatment objectives.

• Surveys for the NSO have been conducted to determine occupancy and nesting status. Prohibit all 

timber harvest, heavy equipment use, chainsaw use, and smoke producing activities within 0.25 miles 

of known NSO ACs from February 1 through July 31. Surveys to protocol would continue for the life 

of the project or additional seasonal restrictions would be imposed on any treatment in or within 0.25 

miles of nesting/roosting habitat. A September 15 LOP would be used in occupied (breeding pair) or 

nesting/roosting habitat if no surveys are conducted.

• One mapped NSO AC (237) within this project occurs near FSR 2S48, where a nest tree is located 

approximately 75 feet outside the treatment unit. Although no NSO detections have been recorded 

since 1992, in order to protect the nest tree and maintain the effectiveness of the fuelbreak, hazardous 

fuel reduction treatments would limited to within 50 feet of the road, following the standard fuelbreak 

prescription described above.

• Surveys for goshawk in the project have been conducted, with no detections. If nesting goshawks are 

subsequently found within 0.25 miles of any treatment units, prohibit all timber harvest, heavy 

equipment use, chainsaw use, and smoke producing activities within 0.25 miles of the occupied site 

between March 1 and August 31.
Chapter 2. Alternatives Considered in Detail

42 – 1st 48 Roadside Fuelbreak Collaborative Project

• Surveys for fisher, marten and wolverine have been conducted and fishers have been detected in three 

(3) areas. Although no den sites have been located, prohibit all timber harvest activities including 

heavy equipment use, chainsaw use, and smoke producing activities within 0.25 miles of fisher 

suitable denning habitat around detection areas from February 1 to May 31.

• In early seral-stage stands lacking downed woody debris (shrub and pole seral stages), small diameter 

slash would be piled and left on site to provide cover for small mammals, birds, reptiles and 

amphibians. The size of the piles would vary depending on the availability of slash; however, the 

preferred size is at least 6 feet in diameter and 4- to 6-feet tall. Small diameter debris decomposes 

quickly, so large piles may have greater longevity. The number of piles per acre would be dependent 

on the location and potential fire risk. In high public-use areas, only one (1) or two (2) piles per acre 

would be left in the stand. In other areas, three (3) to four (4) piles per acre would be left in the stand. 

No piles would be left within 100 feet of roads.

Monitoring

This section discusses the monitoring strategy linked to proposed management activities under the NEPA 

process.

Implementation and Effectiveness Monitoring

Monitoring is important for tracking the implementation of a project; ensuring activities are implemented 

as planned, as well as to measure success in meeting the purpose of required mitigation. Monitoring and 

evaluation are separate, sequential activities that provide information to determine whether programs and 

projects are meeting forest plan direction. Monitoring collects information, on a sample basis, from sources 

specified in the forest plan. Evaluation of monitoring results is used to determine the effectiveness of the 

forest plan and the need either to change the plan through amendment or revision, or to continue with the 

plan. Overall direction is found in FSM 1922.7, FSH 1909.12 (Chapter 6), and 36 CFR 219.12(k).

Project activities would be monitored during and after implementation of management actions to ensure 

that mitigation measures are implemented as specified. Monitoring is also proposed to evaluate the 

effectiveness of planned activities, including standard practices and mitigation measures, in achieving 

desired project outcomes. Lessons learned from monitoring and evaluation would be incorporated into 

future project planning efforts. A full spectrum of techniques and methods may be used including:

o Formal joint management and collaborative field reviews

o Site-specific observations by on-site resource specialists

o Field assistance trips by other technical specialists

o On-going accomplishment reporting processes

o Discussions with other agencies and various public users

o Interdisciplinary team reviews of monitoring results.

Best Management Practices

Apply and monitor relevant national best management practices (BMPs; USDA Forest Service 2012), 

associated with all project activities, including timber harvest and road activities and development. The 

following BMPs, from the USDA Forest Service National Core BMPs, would apply to soil and waterquality protections and protection of unstable or potentially unstable areas within or adjacent to units.
Chapter 2. Alternatives Considered in Detail

Final Environmental Assessment – 43

Best management practice sites would be identified on the ground and recorded by unit. Best management 

practices would be subject to 100 percent implementation monitoring post-harvest, by means of a 

checklist and maps and cards (standard waiver provision), and to effectiveness monitoring following one 

or more post-harvest winters. Effectiveness monitoring results, and any follow-up corrective measures 

taken, would be reported to the Water Board by July 15 in the year following operations. Effectiveness

monitoring results would be scored and reported using Best Management Practices Evaluation Program

(BMPEP) methodology. A complete listing of BMPEPs is included in Appendix C of this EA.

Invasive Plants

Successful control of yellow star thistle would necessitate periodic monitoring and evaluation of 

treatment efficacy. If present after initial treatment, manually pull or use tools to remove individual plants 

in the late spring of the year (before fruiting/seeding) ensuring removal of the roots as much as possible. 

Pile treated plants and burn where treated, or if plant numbers are few, incorporate plant material into a 

nearby burn pile. Monitor annually and retreat as necessary until no plants persist. A complete listing of 

BMPs is included in Appendix C of this EA.
Chapter 2. Alternatives Considered in Detail

44 – 1st 48 Roadside Fuelbreak Collaborative Project

This page intentionally left blank.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 45

Chapter 3. Environmental Consequences

This chapter describes the legal framework, analytical basis and best available science used to determine 

the predicted environmental effects of the Proposed Action, as compared to the No Action Alternative, 

presented in Chapter 2: The Alternatives. Each resource topic section provides a summary of the projectspecific reports, assessments, consultation and input prepared by US Forest Service (USFS or Forest 

Service) specialists. Information from these ‘specialist reports’ (fish and botanical biological evaluations, 

noxious weed risk assessment, biological assessment/biological evaluation (BA/BE) for wildlife, soils, 

geology and heritage resources reports are incorporated by reference into this draft environmental 

assessment (EA). These reports or memoranda are part of the project record on file at the Six Rivers 

National Forest (SRNF or forest), in Eureka, California.

Resources that were not impacted or incur minor effects not influencing the decision are not analyzed 

further. These resources include:

Air Quality: The North Coast Unified Air Quality Management District (NCUAQMD) regulates the air in 

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

ambient air quality standards. The two pollutants of greatest concern in the region are ozone and 

particulate matter. The county’s sunny climate, pollution-trapping mountains and valleys, along with the 

growing population, all contribute to the problem.

Particulate matter (PM) is fine mineral, metal, soot, smoke and dust particles suspended in the air. 

Primary sources of particulate matter. The most concerned is associated with PM less than 2.5 microns in 

diameter (PM2.5). Particles of this size and smaller can permanently lodge in the deepest, most sensitive 

areas of the lungs, and cause respiratory and other health problems.

The Proposed Action would generate PM during operations from increased off-road vehicles use (engine 

exhaust and dust from paved and unpaved roads), and jackpot burning and underburning of vegetation 

and slash. However, the application of dust abatement during log hauling, limited amounts of burning 

annually, covering handpiles with Kraft paper to maintain low-moisture conditions minimizing smoke 

production and only burning on days approved by the NCUAQMD would maintain local air quality.

Recreational Resources: The National Visitor Use Monitoring (NVUM) report identified driving for 

pleasure as one of the top recreational activities for visitors to the national forest. Roads and trails within 

the project area provide such recreation opportunities, as well as scenic viewing opportunities. This project 

proposes one change to the National Forest Transportation System (NFTS) by decommissioning 1.9 miles 

of a Maintenance Level (ML) 2 road, Forest Service Road (FSR) 2S54, which is currently unpassable by 

passenger and high-clearance vehicles due to a landslide. The road has limited recreational driving 

opportunities, as it does not connect to other roads or trails.

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

Roaded Natural is defined as an area characterized by predominantly natural-appearing environments 

with moderate evidences of the sights and sounds of man. Such evidences usually harmonize with the 

natural environment. Given the Proposed Action would only slightly modify the visual resources, but not 

to such an extent as to fundamentally change the dominant form, color, pattern, or texture of the visual 

resources, the Proposed Action would meet the visual quality objectives (VQO) and maintain the Roaded 

Natural character of the project area.
Chapter 3. Environmental Consequences

46 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Visuals Resources: There are 275 acres within project area that fall within the VQO Retention 

management area and 234 acres within partial retention management area, while the remainder of the 

project area occurs within the Modification VQO category. The Retention management area is identified 

as having a high level of scenic integrity where the landscape appears intact. Partial Retention lands have 

a moderate level of scenic integrity where the landscape appears slightly altered, while lands classified as 

Modification have a low level of scenic integrity and deviations to the landscape’s shape, pattern, color, 

or form are readily apparent. The majority of the project area has experienced alterations in visual quality 

from road and log landing construction and even-age timber harvest management. The 1st 48 Roadside 

Fuelbreak Collaborative Project (1st 48 Project) would retain variable forest canopy closure over 60 

percent, limits new landing construction to existing flat openings and does not involve new road 

construction. The removal of boundary flagging and placing stump marks away from viewpoints would 

ensure the Proposed Action complies with land and resource management plan (LRMP or forest plan) 

standards and guidelines (S&Gs).

The Proposed Action would implement project design features (PDFs) in the mixed-conifer stands to 

reduce stand density, while maintaining a closed canopy at or greater than 60 percent canopy closure. 

Such treatments would only slightly modify the pattern of tree density in the foreground and would 

maintain the form, color, and texture of the visual resources in the mid to distance ground views. 

Similarly, oak woodland maintenance treatments would slightly modify the existing pattern of meadow 

openings by removing understory conifers and restoring the pattern of oak woodland meadow openings 

historically characteristic of the landscape. The proposed treatments would blend well with adjacent lands 

not proposed for treatment and would conserve the scenic quality and integrity of the project area.

Jeep Trail 8E20 (aka Wiregrass) is a special vehicle designation trail (i.e., four-wheel-drive non-highway 

legal vehicle wider than 50 inches/all-wheeled vehicles 50 inches wide or less) that is 1.29 miles long, 

located in T2S R8E. The USFS, national resource management (NRM database) indicates the trail was 

added to the NFST (National Forest System trails) under the Lower Trinity/Mad River Motorized Travel 

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

(MVUM) for that area. The trail would be graded within its existing footprint and temporarily closed to 

public use during logging operations to ensure public safety. Other than the short-term disruption in public 

use, grading and constructing waterbars would be visually evident in the short-term, likely one season.

Threatened, Endangered, Sensitive Botanical Resources: No federally listed plant species are known 

to occur, nor does suitable habitat exist in the project area. Two (2) Forest Service Sensitive botanical 

species were found to occur within the project planning area, the mountain lady’s slipper orchid 

(Cypripedium montanum) and the waterfan lichen (Peltigera gowardii). The mountain lady’s slipper 

orchid is also managed under the Survey and Manage (S&M) S&Gs (USDA and USDI 2001).

Forest Service Sensitive species policy is to manage rare species to avoid a trend toward federal listing or 

a loss of viability. Although both occur in the planning area, they both occur within the riparian reserve 

established for Dashield Creek where no treatment is proposed. Hence, similar to Alternative 1 (No 

Action), there are no effects to these species under Alternative 2 (Proposed Action).

Threatened, Endangered and Forest Service Sensitive Aquatic Species: Three species of Threatened 

and Endangered (TE) salmonids are found in the Mad River watershed. Northern California steelhead 

trout (Oncorhynchus mykiss) are found in the mainstem Mad River up to Matthews Dam with critical 

habitat being designated up to County Line Creek. Chinook (California Coastal ESU; O. tshawytscha)

and coho (Southern Oregon/Northern California ESU, O. kisutch) are found in the in mainstem Mad 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 47

River up to “Bug Creek Falls” (approximately 27 miles downstream from Matthews Dam). As the 

proposed roadside treatment areas are located upstream of the Ruth Lake Dam, Threatened, Endangered 

and Forest Service Sensitive (TES) anadromous fish species cannot reach the project area, and therefore, 

the Proposed Action would have no effect on the anadromous TE species and their habitats. Matthews 

Dam also blocks upstream migration for the Pacific lamprey (Entosphenus tridentatus). Neither the 

western brook lamprey (Lampetra richardsoni) nor the California floater (Anodonta californiensis) are 

present above Matthews Dam. The project would have no effect on these Forest Service Sensitive species.

Range: An active allotment (Van Horn Allotment, Barry Creek sub-unit) exists in the southern half of the 

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

of 1S23 south of Jeep Trail 8E20, all of FSRs 2S47, 2S53 and 2S54, along a portion of FSR 2S02. This 

allotment is leased to Travis Ranch LLC. There are 357 cow calf pairs allowed and the season runs from 

June 1 to October 15.

As canopy cover in forested areas would remain high, secondary range condition would experience minor 

improvement. Cattle would continue to use the area to travel through, but probably not stay since 

available forage is minimal. In oak woodland areas that would be enhanced from thinning release and 

prescribed burning, secondary range would be improved and cattle grazing would expect to occur in 

slightly higher frequency than before implementation. Plantations with thinning would have a brief 

improvement in secondary range, but improved growth would shade out forbs and grass in less than 5 

years. Conditions in the white fir stand would be similar to those occurring in the lower elevation 

Douglas-fir dominated forested stands, considered too dense to support much of an increase in secondary 

range conditions.

Key Terms

The following key terms are used in the following section, acting to frame the spatial and temporal 

analysis methodology and effects discussion by resource topic, as defined below:

o Direct effects are caused by the action and occur at the same place and time as the action.

o Indirect effects are caused by the action and are later in time, or further removed in distance, but 

are still reasonably foreseeable.

o Cumulative effects are those that result from the incremental impact of the action when added to 

other past, present, and reasonably foreseeable future actions.

o Short-term effects address environmental consequences, which could occur during operations 

and/or that arise immediately and/or several years post implementation.

o Long-term effects address environmental consequences, which are delayed, periodic, and/or arise 

post implementation and continue over many years.

Fire, Fuels and Vegetation

Introduction

This section presents the predicted effects of the Proposed Action as compared to the No Action 

Alternative on fire, fuels and vegetation resources. The project area elevation varies from approximately 

2,700 feet near the Mad River to 5,800 feet at the top of South Fork Mountain, along FSR 23. The 

majority of the proposed treatments lie between 3,500 and 4,500 feet. The area is highly dissected, 
Chapter 3. Environmental Consequences

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

creating huge variation in slope orientation, which along with soil type has a major influence on 

vegetation. Annual precipitation at Ruth Reservoir is 40 inches, and average precipitation for the Upper 

Mad River Watershed (UMRW) is 60 inches.

Environmental Consequences

Methodology

Potential Fire Behavior

Fireline intensity is commonly used as a measure to relate visible fire characteristics and interpret general 

suppression strategies. There are several ways of expressing fireline intensity. A visual indicator of 

fireline intensity is flame length (Rothermel 1983). Fire types (categorized by surface fire, passive crown 

fire, and active crown fire) are also widely used to determine strategies and tactics to maximize the safety 

of both fire fighters and the public.

A fire modeling assessment using the Fire and Fuels Extension (FFE) of the Forest Vegetation Simulator 

(FVS) was conducted to evaluate the existing potential of fireline intensity and relative hazard rating 

(expressed in flame length) and existing potential crown fire ratings for the proposed project area under 

severe and moderate fire conditions.

Based on the fire modeling assessment, approximately 31 percent project (treatment) area currently could 

generate flame lengths over 4 feet making it necessary to utilize mechanized equipment, including 

aircraft, for suppression activities. Additionally, the FFE modeling showed approximately 37 percent of 

stands in the project area would have surface fire move into crown fire conditions.

Stand Structure

Under the 1995 LRMP, the distribution of seral stages by vegetative series is evaluated relative to 

recommended management ranges (RMRs) at a landscape scale. For this project, the scale of the 

landscape is the south zone of the forest, which is the entire Mad River Ranger District (RD). The 

distribution of seral stages across the analysis area is quite variable, but most of the stands are early seral. 

Disturbance patterns and events play a large part in determining the existing landscape. Stand types are 

defined by six (6) seral stages, based on stand attributes and conditions. These stages are defined as follows:

o Shrub/Forb (S): Generally open to dense stands dominated by shrubs and/or grasses (depending on 

location within the zone) with the top layer of conifers smaller than 6-inch dbh (size class 0 to 1). 

Shrub/forb stands resulting from natural disturbances such as wildfire, mass soil movement, or 

flood are classified as shrub natural (SN); stands resulting from regeneration harvesting or salvage 

after a natural disturbance would be classified as shrub harvest (SH) or shrub salvage (SS).

o Pole (P): Generally dense, single-layer stands, dominated by trees with the top layer of conifers 

between 6- and 11-inch dbh (size class 2). Pole stands resulting from natural disturbances are 

classified as pole natural (PN); stands resulting from regeneration harvesting (i.e., 10- to 30-yearold plantations) or natural pole stands that have been thinned are classified as pole harvest (PH).

o Early Mature (EM): Generally, dense, closed canopy, single-layer stands dominated by trees with 

the top layer of conifers between 11 and 21 inches dbh (size class 3). Early mature stands are 

further characterized by the presence of large scattered pre-dominant conifers generally greater 

than 36-inch dbh (size class 5) in the overstory (EA), evidence of past harvest, such as thinning or 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 49

individual tree selection (EH), or both the presence of large scattered pre-dominant conifers and 

past harvest (EB).

o Mid-mature (MM): Generally dense, closed canopy stands, with one or two layers dominated by 

trees with the top layer of conifers between 18 and 30 inches dbh (size classes 3 and 4; 11-to 21-

inch and 21- to 36-inch dbh). As with early mature stands, the mid-mature seral stage can also be 

further categorized as MA, MH, or MB.

o Late-mature (LM): Generally dense, closed canopy stands, with two or more layers present, 

dominated by trees within the top layer of conifers that are 30-inch dbh or larger (size classes 4 

and 5; 21- to 36-inch and 36-inch dbh and larger). Late mature with evidence of past harvest is 

classified as late harvest (LH).

o Old Growth (OG): Generally open to dense stands, with multiple layers and trees of various size 

classes, the top layer of which is generally larger than 30-inch dbh (size classes 4 and 5). Old 

growth with evidence of past harvest is classified as old growth harvest (OH).

Alternative 1 – No Action

Direct Effects – Vegetation

There are no direct effects of choosing the No Action Alternative. The current stand structure (tree 

sizes/ages, species composition, and spatial distribution) is the result of growth over time and past 

disturbances. Seral stages can be thought of as a time sequence, although disturbances such as fire, wind, 

and disease can result in alterations to this sequence. Vegetation composition is largely determined by 

climate, along with local aspect, elevation, and precipitation patterns. Both upland sites as well as riparian 

reserves are considered in the discussion, as vegetation found within riparian reserves often does not 

differ from areas outside riparian reserves.

The distribution of seral stages across the analysis area is quite variable, but most of the stands are early 

seral. Disturbance patterns and events play a large part in determining the existing landscape. The 

available data and imagery along with field review shows the seral stage distribution (Table 6) within the 

planning area is heavily skewed towards early seral stands. The current seral stage distribution across all 

species occurrence within the planning area is shrub/forb (6%), pole (9%), early-mature (43%), midmature (29%), late mature (3%) and old growth (2%).

Table 6. Percent seral stage of 1st 48 Project area by series.

Seral stage Douglas-fir Series White fir Series 

Shrub/forb 7 0

Pole harvest 6 14

Early-mature (EM) 32 59

Mid-mature (MM) 37 14

Late-mature (LM) 10 12

Old growth (OG) 6 0

White fir dominates the higher elevations, generally above 4,600 feet and down to 4,000 feet on more 

northern aspects. Douglas-fir is a component of these stands at lower elevations, and higher elevations 

stands are almost exclusively white fir dominated. Ponderosa pine, sugar pine, black oak and white oak 

are other tree species growing within this type (Table 7).
Chapter 3. Environmental Consequences

50 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Table 7. Acres of vegetation series in the 1st 48 Project area.

Series Acres Percent

Black oak 25 3

Douglas-fir 497 60

Gray pine 22 3

Ponderosa pine 68 8

Shrub 9 1

White fir 195 24

No Data 7 1

Totals 823 100

While conifer forests account for most of the trees across the analysis area, they are interspersed with oak 

woodlands, other hardwood forests, and grasslands. This combination of vegetation types contributes to a 

mosaic of seral stages across the landscape. Natural and human caused disturbance also influence seral 

stage progression. Developing stands can be set back to shrub/forb stage at any time by stand-replacing 

disturbances such as high severity fire, high wind events, occasional flooding, or regeneration harvest. In 

the analysis area, many of these stands are thought to be the result of large stand-replacing fires during the 

late 1800s and early 1900s (MWRA; USDA Forest Service 1998).

Black Oak

The amount of black oak in stands varies greatly. In many stands, black oak has been relegated to a 

subordinate position in the canopy, likely due to the reduction in fire and competition from Douglas-fir. 

Opportunities for maintaining black oak through cultural practices exist in many places.

White Oak

White oak generally grows on drier sites, such as southern aspects, shallow or very rocky soils and 

convex locations. Within the analysis area, they are often associated with meadows, south slopes and 

ridge tops. White oak generally grows on drier sites, such as southern aspects, shallow or very rocky soils 

and convex locations. Within the analysis area, they are often associated with meadows, south slopes and 

ridge tops. White fir dominates the higher elevations, generally above 4,600 feet and down to 4,000 feet 

on more northern aspects. Douglas-fir is a component of these stands at lower elevations, and higher 

elevations stands are almost exclusively white fir dominated. Ponderosa pine, sugar pine, black oak and 

white oak are other tree species growing within this type.

Stand Densities

Stand density in most stands was high enough to result in competition-induced mortality. Many white fir 

stands have high numbers of dead trees, probably due to dense growing conditions. Basal area density 

measures are above recommended stocking levels for optimizing individual tree and stand growth. These 

higher stand densities indicate that stand vigor and growth is declining. Once stands of a given species 

reach a certain density threshold that varies with different tree species, the likelihood of mortality increases 

significantly. Stand density can be measured in several way, such as basal area8 or trees per acre. However, 

because stands with the same basal area or same trees per acre may not be similar because the average size 

of trees may be very different, an index is often used to evaluate stand density. There are maximum stand 

 8 Basal area is the cross-sectional area of a tree determined from the dbh or 41⁄2 feet above ground level. The cross-sectional area 

of all stems of a species or all stems in a stand measured at breast height inclusive of the bark and expressed as per unit of land 

area. Basal area gives an idea of the stocking of trees in a stand.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 51

density index (SDI)9 values used for different species that represent the densest conditions at which growth 

can occur over a given area, and beyond this, no growth can occur without mortality occurring.

Typically, mortality starts to occur before this maximum is reached. This typically occurs is when the SDI 

value is around 60 percent of a biological maximum. The stand density index is based on the maximum 

number of trees per acre that can grow at any given average dbh. Often a management goal is to maintain 

stand densities well below 60 percent to minimize competition stress on trees, which also increase growth 

and reduces the risk of mortality. This is done by thinning trees so that there is sufficient growing space 

and available resources to maintain good growth.

Douglas-fir Stands

The Douglas-fir series is the major tree species growing in the proposed treatment area on elevations 

primarily below 4,600 feet elevation. Forest stands are mainly dominated by relatively even-aged 80- to 

120-year-old Douglas-fir trees with varying amounts of pre-dominant Douglas-fir, ponderosa pine, and 

sugar pine. Many stands appear to have a mosaic of several age classes in them indicating regeneration 

over several decades with fire possibly contributing to this “patchiness”. These stands are thought to be 

the result of large stand-replacing fires during the late 1800s. It is the major early seral conifer tree 

species that establishes itself after disturbances. This series is found at mid-elevations on warm, moist 

inland sites of moderate productivity where frequent fire played a large role in the past (Jimerson et al. 

1996). These sites lie between cooler and moister white fir series, and the ponderosa pine series, which 

often have less available moisture. The Douglas-fir/black oak subseries is predominant here. The amount 

of black oak in stands varies greatly with most stands having black oak relegated to a subordinate position 

in the canopy. This is likely due to the reduction in fire and competition from Douglas-fir. Madrone is the 

most aggressive hardwood species after disturbance.

The maximum stand density index (SDI) value used for Douglas-fir was 547. Stand density indexes 

ranged from 139 to 707, averaging 349. A 60 percent SDI value is 328. Approximately 70 percent of the 

stands had an SDI that was over 60 percent.

Douglas-fir stands in the planning area were growing under dense stocking conditions. The basal area 

within the Douglas-fir series in the project area ranged from 71 square feet per acre to 545 square feet per 

acre, with an average of 229 square feet per acre. Typical average post-thinning target basal areas for earlymature Douglas-fir stands range between 120 and 160 square feet per acre. However, approximately 85 

percent of Douglas-fir dominated stands had basal areas greater than 160 square feet per acre (Table 8).

Table 8. Existing and post-treatment basal area for Douglas-fir in the 1st 48 Project area.

Stratum Seral stage Age Dominant 

Species

Size Range in 

inches, DBH (QMD)

Existing BA

sq. ft./acre Existing SDI

1 PH 35-45 DF 4-14 (10) 180 237

2 EM 70-100 DF-BO 12-24 (16) 240 372

3 EM/MM 70-120 DF-PP-BO 12-32 (19) 200 271

4 MM 100-120 DF-BO 21-32 (17) 265 393

5 EM 60-100 WF 14-24 (21) 338 456

 9 Stand Density Index (SDI is an established (Reineke 1933) measure of stand-level inner tree competition. Designed to measure 

competition in even-aged, single-species conditions, it is used widely by forest growth models to describe how stand density 

affects stand development and growth even in uneven aged and mixed stand conditions. The average size of trees in a stand can 

be looked at and assessed in terms of quadratic mean diameter (QMD) and how it changes through time.
Chapter 3. Environmental Consequences

52 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

White Fir Stands

White fir stands within the project area currently exhibit high-density stocking conditions. Basal area 

values ranged from 107 square feet per acre to 521 square feet per acre, averaging 321 square feet per 

acre. The maximum SDI value used for white fir was 759. A 60 percent value is 455. Over 65 percent of 

the white fir stands in the planning area had SDI values greater than 60 percent, and 14 percent were just 

slightly lower than 60 percent maximum SDI.

The maximum SDI value used for white fir was 759. A 60 percent value is 455. Over 65 percent of the 

white fir stands in the planning area had SDI values greater than 60 percent, and 14 percent were just 

slightly lower than 60 percent maximum SDI.

Ponderosa Pine

Ponderosa pine often grows on drier sites within the area, mostly on ridge tops and south facing slopes. 

California black oak and Pacific madrone are the primary hardwood species, with occasional big leaf 

maple. Typical understory vegetation consists of hazel, poison oak, madrone, hawkweed, wild rose, 

snowberry, hawkweed, bunchberry, and fescue. Hazel and bunchberry typically indicate moister 

conditions, while snowberry, poison oak, madrone, hawkweed, and rose indicate drier sites. Douglas-fir 

stands grow on most of the NFTS roads within the treatment area, except for the upper portions of 2S48 

and all of 1S23, on the top of South Fork Mountain.

Indirect Effects – Vegetation and Fuels

Indirect effects of the No Action Alternative to vegetation and fuels would occur as these young stands 

continue to grow at their current high densities. Stand density indicates that competition-related mortality 

is expected to increase as resources on the site become limiting, as shown by comparing the existing 

density to the desired basal area range based on stand density index (Table 9). This has the potential to 

lead to the development of high fuel loadings, increasing the hazard of stand-replacing fires, which would 

further exacerbate the age-class/seral stage gap in the project area with the loss of up to 100 years of 

growth in these stands.

Table 9. Existing and post-treatment retention basal area by strata in the 1st 48 Project area.

Stratum Seral stage Age Dominant 

Species

Size Range in 

inches, DBH (Posttreatment QMD)

Existing BA 

ft2/acre

Post-Treatment 

BA ft2/acre

1 PH 35-45 DF 10-14 (11) 180 80-120

2 EM 70-100 DF-BO 16-24 (18) 240 100-140

3 EM/MM 70-120 DF-PP-BO 16-32 (22) 200 120-160

4 MM 100-120 DF-BO 24-32 (26) 265 140-180

5 EM 60-100 WF 20-32 (24) 338 180-210

Without treatment now, many of these stands would likely eventually develop into the desired structure as 

natural disturbances and competition-related mortality open up the stand and trigger the understory reinitiation stage of development. However, it is expected that this process would take substantially longer than 

under the proposed thinning regimes (Bailey and Tappeiner 1998). Thinning now would also broaden future 

management options by removing hazardous fuels and creating stands more resilient to fire disturbances.

No action would lose the opportunity to utilize approximately 3 million board feet of small to mid-sized 

poles and sawlogs that would be produced as a by-product from treatment. A large portion of this material 

would be in the form of trees in over-stocked stands that would die in the future from inter-tree competition.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 53

Without the additional treatment of fuels corridors, suppression forces would have fewer options for safe 

access and containment strategies based on fuelbreaks. The ability to use the thinned and treated areas as 

anchor points for containment would be compromised.

Cumulative Effects – Vegetation

Within the project area, timber harvest and associated road construction and fire suppression have been 

the dominant management activities having a cumulative effect on vegetation. Selective harvest of predominant trees and regeneration harvest using the clearcut or clearcut with reserve trees systems has 

affected the distribution of seral stages. The No Action Alternative would have no effect on the current 

distribution of these stages in the next 30 years. After 30 years, it is expected that many of the mid-mature 

stands would begin to move into the late-mature stage (understory re-initiation), as a result of inter-tree 

competition-based mortality and natural disturbances.

Direct Effects – Fire and Fuels

There are no direct effects of choosing the No Action Alternative. The project area resides in a dry 

terrestrial physiographic province where fire has been the dominant natural disturbance factor (FSEIS 

1994). Fire frequencies have been highly variable, and wildfires did not always result in complete stand 

mortality. Evidence of past fire is common on pre-dominant trees having fire scars from old surface fires. 

Much can also be inferred from the dominance of early- and mid-mature seral stages found here. The fire 

regime within the planning area would generally be considered a moderate (mixed) severity regime with 

periods of stand-replacing fire (Jimerson et al. 1996). Tree ring and fire scar studies in the Douglas-fir 

series on the SFNF found that the mean fire return intervals varied from 13 years in the south to 21 years 

in the north (Adams and Sawyer 1980 In: Jimerson et al. 1996). Taylor and Skinner (2003) reported 

median fire return intervals of 11 to 16 years for Douglas-fir/tanoak sites near Hayfork, California, to the 

north of the planning area with lightning as a common occurrence. Stand-replacing fire events historically 

created large areas of young forest, during drought periods from 1860 to 1890 and 1915 to 1935. These 

events likely resulted in the current dominance of early (70- to 110-year-old) and mid-mature (110- to 

150-year-old) stands (MRWA; USDA Forest Service 1998).

Fire has been an important disturbance factor in the planning area. Evidence of past fire is common on predominant trees having fire scars from old surface fires. Much can also be inferred from the dominance of 

early- and mid-mature seral stages found here. Aboriginal and settler burning is thought to have been 

common up until the 1930s, and fire records since 1909 indicate that lightning started 38 percent of fires. 

During the 1930s, fire suppression forces were augmented by the Civilian Conservation Corps (CCC) and 

became more effective at preventing growth of fires. Continued growth in suppression forces, along with 

improved access roads and aerial suppression and surveillance, lead to decreases in the annual area burned.

The fire regime within the planning area would continue to be a moderate (mixed) severity regime with 

periods of stand-replacing fire (Jimerson et al. 1996). Tree ring and fire scar studies in the Douglas-fir series 

on the SRNF found that the mean fire return intervals varied from 13 years in the south to 21 years in the 

north (Adams and Sawyer 1980 In: Jimerson et al. 1996). Taylor and Skinner (2003) reported median fire 

return intervals of 11 to 16 years for Douglas-fir/tanoak sites near Hayfork, California, to the north of the 

planning area. Stand replacing fire events historically created large areas of young forest, with dry periods 

from 1860 to 1890 and from 1915 to 1935 thought to have resulted in the current dominance of early (70- to

110-year-old) and mid-mature (110- to 150-year-old) stands (MRWA; USDA Forest Service 1998).

The fire regime-condition class is considered to be generally outside the natural/historic range of variation 

for the Douglas-fir series, white fir series (ponderosa pine is seral) and white oak/conifer types. At these 
Chapter 3. Environmental Consequences

54 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

elevations and latitude there is likely departure from historic conditions, since lower precipitation and the 

hotter and drier summertime conditions would have led to more ignitions from lightning and human 

sources than more mesic sites at higher elevations. These more frequent fires would indicate a mixedseverity regime with under-burning and creation of small patches of regenerating forest.

Indirect and Cumulative Effects – Fire and Fuels

The Upper Mad River Watershed Analysis (USDA Forest Service 1998) found several trends thought to 

be related to the effects of fire suppression. Permanent forest inventory plots have revealed a continuing 

increase in stand densities over the previous 30 years, with a concurrent decrease in black oak 

representation. This finding is consistent with stand data from the project area, where Douglas-fir basal 

area is at or above maximum and black oak is declining. The analysis also noted the succession of white 

oak savannahs to conifers, a trend that is also occurring in the planning area.

The absence of recent mixed-severity fire has been a likely factor in the rather uniform, even-aged, singlelayer structure of these Douglas-fir stands, as well as the continued loss of black oak through competition 

from Douglas-fir. Fire suppression since the early 1900s means that these sites have likely missed several 

fire events that would have created more horizontal and structural diversity in the early- and mid-mature 

stands (Weisberg 2004, Taylor and Skinner 2003).

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

Fire scar evidence indicates that these stands were historically maintained at low densities by frequent fire 

regimes. Many of these stands contain large, old specimens of both of these species. Stand densities and 

ladder fuels have increased to the point that there is a risk of losing them to a stand-replacing fire.

Stand structure and fuel arrangement is now such that stand-replacing fire would be expected to be a 

substantial, if not the dominant, type of fire severity during wildfires in the planning area. This condition 

differs from a mixed-severity regime, where fire would have multiple effects ranging from non-lethal 

surface fire to creation of small patches of high mortality that would lead to regeneration of early seral 

species. In the mixed-mortality areas, stand thinning by fire would typically have led to the creation of twolayered stands by creating conditions favorable to the establishment of early seral species in the understory.

The fire regime condition class is considered to be generally outside the natural/historic range of variation 

for the Douglas-fir series and white oak-conifer types. At these elevations and latitude there is likely 

departure from historic conditions, since lower precipitation and the hotter and drier summertime 

conditions would have led to more ignitions from lightning and human sources than more mesic sites at 

higher elevations. These more frequent fires would indicate a mixed-severity regime with underburning 

and creation of small patches of regenerating forest.

In 2011, the Ruth Fire burned 1,460 acres of National Forest System (NFS) lands in the UMRW. There 

are 88 acres of 1st 48 Project units within the burned area of the Ruth Fire. Fire effects were variable 

according to onsite conditions at the time of burning. However, it demonstrates the potential for large fires 

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

fire frequency has declined and changes to the vegetation structure have led to a denser, more 

homogeneous forest (Sugihara et al. 2006).

Timber Harvest

The project area was developed for timber production beginning in 1963 (MWRA; USDA Forest Service

1998). Much of the older timber harvest in the area had focused on removal of the larger fire resistant 

trees in selective cuts. Large pre-dominant trees were selectively removed without thinning the remainder 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 55

of the stand, which has created fuel conditions conducive to crown fire. This can be seen in many of the 

stands as evidenced by rotting stumps and downed logs that were not harvested. More recent harvests 

included clearcuts. The current plantations in the area are a result of this. Many of the dense plantations 

created after clearcutting or regeneration harvest have reached the pole stage and are very susceptible to 

damage from both surface and crown fire.

Planting of bare root seedlings began in the early 1960s after it became clear that natural seeding was not 

providing adequate stocking. At that time, the development paradigm was to build the long-term road 

system necessary for access to timber stands through the creation of 20- to 40-acre clearcuts spaced out 

along the road system (staggered-setting approach). This lead to the breaking up of larger areas of 

contiguous forest into patches of early- to late-mature forest with young stands interspersed throughout.

Tree Mortality and Snags

Dead trees in the project area are generally small diameter (less than 20-inch dbh), without the large snags 

found in older stands. Mortality from competition and physical damage is variable, and current snag 

densities are variable. Down wood data was also not available for the project area, but is similar to the 

snag population in that it is composed of small logs from competition-related mortality and large logs in 

advanced stages of decay.

Prescribed Fire

Due to the conditions noted above, the use of prescribed fire in Douglas-fir stands without reductions in 

stand density and fuels by mechanical means would be difficult, costly, and pose risks to firefighters and 

local communities. Many areas of oak woodland in the project area, especially along potential control 

lines, are also in need of mechanical treatment prior to use of prescribed fire.

Late-Successional Reserve

A very small portion of the 1st 48 Project is located within the South Fork Late-Successional Reserve 

(LSR; RC-330). The entire South Fork LSR is 80,451 acres, with the majority located on the ShastaTrinity National Forest (STNF). Of that, only 1,057 acres located on the SRNF, and the 1st 48 Project

affects only 73 acres located on the westernmost boundary of the entire LSR. The South Fork LSR is a 

land allocation established in the Northwest Forest Plan (NWFP), incorporated into both the SRNF and 

STNF LRMPs allocated to be managed to protect and enhance late-successional forest ecosystems 

through prescribed understory fire, and TFB. General management direction for LSR lands is found on 

pages IV-34 to IV-39 of the SRNF LRMP (USDA Forest Service 1995). The STNF included the South 

Fork LSR in the 1999 Forest-Wide Late-Successional Reserve Assessment (LRSA; USDA Forest Service 

1999), which identifies general current conditions, general desired conditions, and management 

recommendations that would move the LSRs, including the South Fork LSR, toward desired conditions. 

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

In 2009, the STNF received a letter of clarification from the Regional Ecosystem Office (REO) related to 

hazard reduction thinning activities proposed in LSR’s in order to reduce the risk of large-scale 

disturbance. The REO had reviewed the LRSA for the STNF and concluded that fuel treatments proposed 

in the LSRs that thin suppressed, intermediate and some co-dominant trees are consistent with the S&Gs 

under the NWFP (USDA and USDI 2009).

The NWFP S&Gs (C 12-13) for risk reduction treatments do not limit the size of trees that can be 

removed when reduction of risk of large-scale disturbance is the primary objective of treatments within 

LSRs. In the letter, the LSR work group also concurred with an upper 150-year age limit on trees 

removed, as opposed to a 20-inch diameter limit, which could be cut to enhance development of late-
Chapter 3. Environmental Consequences

56 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

successional habitat. The LSR work group deemed it logical to assume that trees this old would be larger 

than 20 inches in diameter. Based on tree age data collected on stand exam plots in the LSR for this 

project, white fir ranging from 18 inches to 35 inches in diameter were aged from 75 to 127 years old.

Alternative 2 – Proposed Action

Direct and Indirect Effects

The Proposed Action would employ TFB (Tappeiner et al. 2007) in early and early/mid-mature Douglasfir/black oak stands ranging in age from 70 to 80 years, early mature white fir stands, and young Douglasfir or ponderosa pine plantations. These stands are generally single-layered and consist of even-aged 

patches of varying age.

A positive response to thinning from below from implementing the Proposed Action is expected, since 

subordinate trees (suppressed, intermediate and select co-dominant trees) would be removed to allow 

trees of the upper canopy (which have more fully developed crowns) to utilize the additional growing 

space. Thinning from below increases the residual size of trees left in a stand (Agee and Skinner 2005,

Smith et al. 1997). Crowns would expand into the desired shaded fuelbreak condition. Reducing stand 

density at this time would allow these stands to quickly develop more resilience to disturbances such as 

wind, heavy snow and ice, bark beetles, and fire. Thinning, whether from below or throughout the 

diameter classes (with the exception of pre-dominant and dominant trees), increases spacing and reduces 

stand densities, resulting in less inter-tree competition, which increases individual tree vigor, resulting in 

stands that are more resilient to insects, disease, wildland fire, and drought (Agee and Skinner 2005,

Fettig et al. 2007, Hessburg et al. 2016, van Mantgem et al. 2009, Vernon 2017).

Similarly, retaining the trees with the largest crowns may initially stimulate growth response of some 

brush species. However, the resulting increase in crown growth would reduce available sunlight from 

reaching the forest floor within a few years, which would in turn, reduce understory vegetation growth, 

including brush species that might contribute to ladder fuel development.

White Fir Dominated – Thin from Below

Thin from below (TFB) would retain residual basal area from 140 square feet per acre to 180 square feet 

per acre, variable crown spacing and a minimum 60 percent canopy closure. The thinning treatment 

would retain a slightly higher target residual basal area square feet per acre, compared to drier areas 

dominated by Douglas-fir. Forest Vegetation Simulator (FVS) modeling (2018) of stand exam data 

collected by the Forest Service between 2016 and 2018, predicted over 90 percent of the TFB treatment 

area would exceed 180-plus square feet per acre residual basal area if left untreated.

Thin from below is a treatment in even-aged stands that would also produce types and quantities of 

material, such as sawlogs and poles that can be utilized to realize some economic gain, instead of 

generating a cost to be disposed of as slash. Treatments would reduce canopy bulk density, raise the 

canopy base height, and increase average stand diameters. In terms of fire resiliency, all of these factors 

would make these stands more able to withstand the effects of a fire (Graham et al. 1999). While there are 

always tradeoffs to stand manipulations in terms of fire behavior, it is expected that in the long term (10 

years and beyond) the thinning conducted in this project would lead to reduced propensity towards crown 

fires and stand-replacing fire events. This conclusion is based on the expected rapid recovery of the upper 

canopy that would inhibit continued growth of tall shrubs that could contribute to extreme fire behavior. 

In addition, the species of shrubs involved are not known for being particularly volatile during a fire.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 57

Although surface fuels in the form of shrub layers would increase, and dead and down fuels on the forest 

floor would increase even in units where tops are yarded and burned at the landing, post-thinning 

treatments consisting of piling, lop and scatter, and jackpot burning would further reduce surface fuels 

and reduce potential for tree torching and hot surface fires. Opening up these stands would increase 

potential wind speeds, which contribute to flame lengths, but this effect should be negated by the 

reductions in surface and canopy fuels (Graham et al. 2004, Agee and Skinner 2005).

Thinning would improve the ability of these stands to withstand the typical winter wind, ice, and heavy 

snow storms in the Coast Ranges and Klamath Mountains, although there may be a short-term increase in 

susceptibility to wind storms in the denser stands on exposed sites. Over time, thinning promotes a lower 

height-to-diameter ratio, which improves the ability of a tree to withstand heavy snow and ice loads, 

especially if they are associated with dynamic loadings associated with high winds (Oliver and Larson 

1996). The thinning intensity and TFB prescription considers maintaining an average of 60 percent or 

greater canopy cover with a relatively uniform crown spacing so stands exposed to prevailing winds 

would not be opened up too much. However, some blow-down is still to be expected, and these events are 

expected to provide additional coarse woody debris (CWD) and diversity to stands, while still 

maintaining an adequate growing stock for future management objectives, including wildlife habitat.

Late-Successional Reserve

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

firefighters a good chance of keeping exterior wildfire from entering; or conversely interior wildfire from 

exiting the area. Under the LSRA and LRMP direction, proposed silvicultural activities are aimed at 

reducing risk (potential loss due to wildfire) in 59 acres of younger white fir stands adjacent to FSR 2S23 

along the ridgetop within the South Fork LSR.

Project objectives are to reduce the stand density with a TFB of primarily white fir to reduce fuel and add 

space between crowns. The trees targeted for removal in the early mature white fir stands have a diameter 

range of 14 to 24 inches, and are less than 120 to 150 years old (Table 9). Some white fir trees under 150 

years old are larger than 24 inches dbh and maybe removed to meet crown spacing objectives. Tree age data 

was collected in 2017, confirming white fir ranging from 18 inches to 25 inches in diameter are aged from 75 

to 116 years old. Other conifer tree species, such as sugar pine, Douglas-fir and incense cedar are generally 

the older and larger trees remaining as components from the earlier stand and are not targeted for removal.

Additionally, there are approximately 14 acres of Douglas-fir or ponderosa pine-dominated stands within 

the LSR that exist along FSR 2S48 in small discontinuous areas averaging approximately 1 to 3 acres in 

size. These are primarily early mature and mid-mature stands, which have had previous entries of 

individual tree harvest. Remnant pre-dominant trees exist in these stands, often in or near the riparian 

reserves. In the patches of mid-mature seral forest (Table 9), trees range from 70 to 120 years in age, with 

diameters ranging from 12- to 32-inch dbh. Additionally, there are approximately eight (8) acres in the 

LSR with late mature characteristics in the overstory. These are small discontinuous areas with evidence 

of previous individual tree harvest that are generally located at the edges of unit boundaries.

The trees targeted for removal in units with the LSR are similar to the early mature white fir stands on 

South Fork Mountain ridge along FSR 1S23 in terms of age and diameter range. This means the Proposed 

Action targets those trees with under-developed crowns, which are typically suppressed and/or 

intermediate trees less than 150 years old, and retains trees with the fullest crowns characteristic of codominant, dominant and pre-dominant trees, late seral characteristics would be maintained. No trees 

considered late seral components would be cut.
Chapter 3. Environmental Consequences

58 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Approximately 95 percent of the tree targeted for removal are less than 20 inches in diameter, and the 

majority of these are less than 16-inch dbh. Table 10 provides a breakdown for species by diameter class 

proposed for thinning. Age does not correlate to tree diameter, as suppressed trees with stunted growth in 

the understory may be the same age or older than intermediate and co-dominant trees. The core samples 

taken by the Forest Service indicate the range in ages for trees that would be thinned was 75 years to 119 

years. Based on Common Stand Exam (CSE) FVS for the Douglas-fir stands, approximately 28,600 trees 

total were modeled to be thinned. The predicted estimate is 530 Douglas-firs 24-inch dbh and greater 

would be cut, representing 1.8 percent of the trees. In the white fir stand, approximately 18,570 trees total 

were modeled to be thinned; of these, 186 white firs 24-inch dbh and greater would be cut, representing 

1.0 percent. An estimated 95 percent of the tree targeted for removal are less than 20 inches in diameter, 

and the majority of these are less than 16-inch dbh.

Table 10. Predicted tree species, age and diameter classes proposed for removal.

DBH grouping 2"-DBH class

Estimated number of trees modeled to be cut by species, based on plot data

DF WF PP IC

9" – 10" 10" 11,890 6,128 0 0

11" – 12" 12" 7,100 3,343 0 0

13" – 14" 14" 3,905 2,693 93 278

15" – 16" 16" 2,310 2,878 186 186

17" – 18" 18" 1,420 1,764 0 0

19" – 20" 20" 710 836 93 0

21" – 22" 22" 710 650 0 0

23" – 24" 24" 355 278 0 0

25" – 26" 26" 177 0 0 0

Cumulative Effects

As aforementioned, past timber harvest on the Mad River RD has resulted in an altered distribution of 

seral stages compared to 60 years ago, when active timber harvest began. The Proposed Action differs 

from past actions, in that historic timber harvest (pre-1990s) consisted of clearcut or shelterwood logging, 

broadcast burning, and planting with Douglas-fir seedlings. The actions proposed here are to reduce 

hazardous fuels and to construct shaded fuelbreaks to promote resiliency of stands from fire effects. These 

treatments would not detract or stall these stands in development of structure to mid-mature/late-mature 

and understory re-initiation and would not alter the current distribution of seral or development stages 

(also called structural stages) within the analysis area.

Similar thinning projects are being carried out within this watershed. The 2009 Beaverslide and the 2013 

Kelsey Peak Timber Sale and Fuelbreak projects have portions recently implemented. Other foreseeable 

actions within the analysis area are additional hazardous fuel reduction projects and shaded fuelbreak 

construction and maintenance.

In terms of past, proposed, ongoing, and foreseeable actions, this project would have no cumulative 

effects to the vegetation structural stages within the south zone of the forest, which is the entire Mad 

River RD. The current distribution has been molded by past activities, which removed older forest types, 

and by past wildfires. This project would improve the distribution of structural stages over the long term 

for species needing older forest habitat for part or all of their life cycle.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 59

Wildlife Resources

Introduction

This section summarizes the predicted effects of the Proposed Action as compared to the No Action 

Alternative on TES, disclosed comprehensively in the 1st 48 Project BA/BE; Smith 2018). The BA/BE 

contains the list of species considered, local population information, survey results, and suitable habitat 

descriptions on which effects of proposed projects are evaluated.

On June 28, 2011, the US Fish and Wildlife Service (USFWS; USDI Fish and Wildlife Service 2011) 

released the Revised Recovery Plan for the Northern Spotted Owl (Recovery Plan). The purpose of recovery 

plans is to describe reasonable actions and criteria that are considered necessary to recover a listed species. 

The Recovery Plan recommends increased conservation and restoration of northern spotted owl (NSO) sites 

and high-value spotted owl habitat.

The Recovery Plan represents the “best available science.” The forest has taken special steps to ensure 

that the 1st 48 Project is consistent with the recovery actions within the Recovery Plan.

The Recovery Plan recognizes the importance of maintaining, and restoring, habitat for the recovery and 

long-term survival of the spotted owl. “Long-term spotted owl recovery could benefit from forest 

management where the basic goals are to restore or maintain ecological processes and resilience. 

Therefore, we recommend application of disturbance-based principles to such decisions (Franklin et al. 

2002, 2006, 2007; Drever et al. 2006; Noon and Blakesley 2006; Carey 2007; Long 2009; Swanson et al. 

2010).” The Recovery Plan relies on federal lands to provide the major contribution for recovery (USDI 

Fish and Wildlife Service 2011).

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

published. Critical habitat consists of those areas that have physical or biological features essential to the 

conservation of the species. The rule states “we encourage land managers to consider implementation of 

forest management practices recommended in the Revised Recovery Plan to restore natural ecological 

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

ecological forestry management practices ...”

The wildlife analysis area used for cumulative effects is the UMRW, which is a 5th-field watershed 

consisting of 102,926 acres. There are 25,178 acres of nesting/roosting and 24,762 acres of foraging in the 

UMRW. The project area encompasses approximately 32,892 acres within these watersheds. Three 

affected NSO territories extend beyond the project area; therefore, the action area for wildlife analysis of 

direct and indirect effects is approximately 36,267 acres.

The plantations and natural pole-sized stands proposed for treatment are even-aged and lack the horizontal 

and vertical diversity components associated with late-mature habitat. These young stands have the 

potential to achieve rapid diameter and height growth with commercial thinning. As these stands develop, 

the acres suitable for NSO and other late-successional associated species should increase. By treating 

currently unsuitable habitat adjacent to existing late-successional habitat, larger patches would develop.

The planning area is prone to high risk of catastrophic or stands replacing fire (LSRA; USDA Forest 

Service 1999). Existing late-successional habitat is at risk. Early seral vegetation is highly susceptible to 

loss in a fire (dense, interlocking canopy). Treatments that reduce the time stands are in early seral stages 

may reduce the risk of stand replacing fire. In addition, construction of the fuelbreaks would reduce the 
Chapter 3. Environmental Consequences

60 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

fuels along road systems bisecting the area and serve as a control point for suppression activities. 

Removal of the ladder fuels would reduce the potential of intense heat and crown fires continuing 

unabated into existing habitat. These shaded fuelbreaks would assist suppression efforts in several ways: 

they would provide safe access for fire suppression crews, reduce the chance of a human-caused roadside 

fire from spreading into existing habitat, and create a break in the continuity of fuels to slow down the 

progress of any fire that might start within the project area. Shaded fuelbreaks in strategic areas would 

provide greater protection to existing late-successional habitat. This project would reduce fuel loads that 

could result in high-intensity wildfires that could negatively impact suitable wildlife habitat.

The SRNF forest plan used computer growth models to determine the effects of thinning prescriptions 

designed to mimic natural disturbance on stand age. The results of this modeling showed that succession 

could be accelerated by as much as 30 years per seral stage, depending on site-specific conditions. 

Treatments of shrub, pole, and early mature stands could accelerate the development of late-mature and 

old growth stands by as much as 90 years. The No Action Alternative could delay the development of 

late-successional habitat by as much as 90 years, which in turn would delay the reduction of 

fragmentation and delay achieving larger habitat patch size.

The objective of the proposal is both short and long term in its aim. The short-term aspect is to manage 

for protection from stand-replacing fire. In addition to the objective of fuels reduction and fuelbreak 

construction, the project will provide both short and long-term benefits to wildlife by protecting current 

habitat and improving/restoring lower quality or non-habitat.

Environmental Consequences

Methodology

Known or suspected species occurrence is based on historic records, current sightings, field review, and 

formal surveys. Presence of suitable habitat is based on the SRNF vegetation layer, aerial photographs, and 

field reviews conducted by the wildlife biologist. The species considered are known to or are suspected to 

occur in the project area (USDA Forest Service 2018).

Approximately 73 acres of the project occurs in an LSR, specifically LSR 330. The STNF LSRA (1999) 

determined that this area of the LSR was deficient in late-successional habitat. Portions of the LSR were 

previously harvested; therefore, extensive stands of dense plantations exist that not only create a fuels 

hazard, they also do not provide suitable habitat for late-successional species such as NSO. Plantations 

and young natural stands are even-aged and lack the horizontal and vertical diversity components

associated with late-mature stands. Young stands have the potential to achieve rapid diameter and height 

growth with thinning treatments. Silvicultural prescriptions can be applied to younger stands in order to 

accelerate their development toward late seral conditions. These treatments could increase the amount of 

late seral vegetation sooner than would occur naturally. The LSRA indicated fuels treatments are needed 

to protect the LSR, as well as extensive habitat restoration. The project would maintain and improve 

habitat conditions within the LSR.

The Recovery Plan recommends increased conservation and restoration of NSO sites and high-value NSO 

habitat.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 61

Threatened Species – Northern Spotted Owl

Alternative 1 – No Action

Direct and Indirect Effects

There are no direct effects of choosing the No Action Alternative. Under the No Action Alternative, no 

thinning, shaded fuelbreak construction, or activity fuel treatments would occur. The No Action 

Alternative would not change the current conditions. No suitable or critical habitat for any TES species 

would be modified through thinning or shaded fuelbreak construction. There would be no disturbance to 

TES species during the breeding season. However, the No Action Alternative would not accelerate the 

development of late-successional conditions in younger stands throughout the planning area, critical 

habitat, or the LSR.

The No Action Alternative would also not help alleviate the fuels problem in the area. Plantations and 

young natural stands that are left untreated would be a greater fire hazard in the long run, because they are 

greatly overstocked (many trees per acre with dense, interlocking canopies). Treatments within these 

stands would reduce existing fuels. Thinning in plantations improves growing conditions for the 

remaining trees by reducing competition for light and nutrients. Without treatment, tree-to-tree 

competition may cause far greater mortality in the stand. Periods of competition-induced die-offs could 

generate large amounts of fuel in shorter timeframes.

There are heavy fuels along the roads in the planning area. Many of these areas contain a sufficiently dense 

fuel ladder (moving from the ground up to live limbs of a trees) to allow fire to easily make its way from 

the ground to the canopy. Under the No Action Alternative no treatment would occur along these roads and 

the risk of a fire doing catastrophic damage to the existing late-successional habitat would remain high.

Cumulative Effects

There are no cumulative effects associated with no action.

Alternative 2 – Proposed Action

Direct and Indirect Effects

Implementation of Alternative 2 would protect and improve habitat conditions for numerous species 

including TES, management indicator species (MIS), S&M species and migratory bird species (MBS). The 

habitat conditions are considered low quality for the NSO throughout much of the planning area. Past 

management has removed large tracts of suitable nesting/roosting habitat and fragmented remaining patches. 

Extensive areas of 40-plus-year-old plantations and young natural stands occur throughout the planning area.

There are 461 acres proposed for TFB and 108 acres of plantation thinning that would be treated using 

conventional harvest systems. All thinning would occur in plantations (40-plus years old) and young 

natural stands. None of the thinning treatments occur in suitable high-quality nesting/roosting habitat for 

the NSO. Forest plan modeling showed that succession could be accelerated by as much as 30 years per 

seral stage, depending on site-specific conditions. Treatments of shrub, pole, and early mature stands 

could accelerate the development of late-mature and old growth stands by as much as 90 years. 

Treatments would change the stand structure and allow large trees to develop, accelerating the 

development of functional late-successional habitat. Silvicultural prescriptions for the 1st 48 Project

would ensure retention of existing stand structure, species composition, snags, and downed logs.

Little true riparian habitat exists within the units along both Littlefield and Jonathan creeks. However, in 

the long-term project implementation has the potential to improve riparian habitat conditions through the 
Chapter 3. Environmental Consequences

62 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

release of conifer and hardwoods/shrubs from thinning, generating a secondary canopy. The project would 

maintain high levels of coniferous canopy closure within the project area adjacent to riparian reserves. 

Project activities would not occur within riparian habitat. Implementation of the project would maintain 

and improve riparian habitat conditions.

Recovery Plan

The Recovery Plan recognizes the importance of maintaining, and restoring, habitat for the recovery and 

long-term survival of the spotted owl. The Recovery Plan relies on federal lands to provide the major 

contribution for recovery (USDI Fish and Wildlife Service 2011).

The USFWS found that due to “The continued decline of the spotted owl populations and low occupancy 

rates in large habitat reserves, and the growing negative impact from barred owl invasions of spotted owl 

habitats (Forsman et al. 2011, Dugger et al. in press), which is greater than anticipated in the NWFP. We 

recommend increased conservation and restoration of spotted owl sites and high-value spotted owl 

habitat to help ameliorate this impact” (emphasis added; Recovery Plan).

The Recovery Plan states, “This Revised Recovery Plan was developed using the best scientific 

information available and a “step-down” approach of objectives, criteria and actions. ... Recovery actions 

are the Service’s recommendations to guide the activities needed to accomplish the recovery criteria. 

Recovery actions are recommended throughout the U.S. range of the spotted owl and are designed to 

address the specific threats identified in this Revised Recovery Plan”.

The 1st 48 Project was designed to meet the objectives of the Recovery Plan as follows:

o Recovery Action 32 (RA 32) states, “Maintaining or restoring forests with high-quality habitat would 

provide additional support for reducing key threats faced by spotted owls” and “Protecting these 

forests should provide spotted owls high-quality refugia habitat from the negative competitive 

interactions with barred owls that are likely occurring where the two species’ home ranges overlap. 

Maintaining or restoring these forests should allow time to determine both the competitive effects of 

barred owls on spotted owls and the effectiveness of barred owl removal measures”.

Forsman et al. (2011) recommended that all potential NSO habitats should be considered, not just 

old growth. The Six Rivers’ definition of suitable NSO nesting/roosting habitat includes midmature (starting at 21-inch dbh), late-mature and old-growth seral stages. All potential habitat was 

considered during project evaluation, and all high-quality habitat (no matter what seral stage) was 

dropped from treatment. Low-quality habitats were evaluated for habitat improvements measures. 

If the habitat could benefit from a silvicultural treatment, then it was considered for the project.

The definition of NSO nesting/roosting habitat used for this project was based on the definition 

found in the SRNF LRMP and field verified by wildlife biologists with extensive experience with 

the species. The LRMP definition was based on extensive published literature and represents the 

best available science for the Six Rivers’ habitat types.

The USFWS defines “habitat maintenance” as a reduction in stand density, but the current habitat 

function would be maintained immediately post project with the purpose of improving its quality 

for the species over time. “Removal” occurs when the habitat no longer functions as 

nesting/roosting or foraging habitat (e.g., clear cutting). Habitat maintenance treatments are 

treatments designed to maintain and enhance habitat. A “downgrade” is taking a higher habitat 

quality down to a lower habitat type, such as removing too much canopy and making a 

nesting/roosting stand only suitable as foraging habitat.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 63

No habitat removal or downgrading would occur under the 1st 48 Project except for negligible 

amounts in any one area for landing construction. The most removal that would occur (foraging 

habitat only) in any location is 0.25 acres for any given landing.

All high-quality stands were dropped from treatment on this project. Approximately 96 acres of 

moderate-quality and 194 acres of low-quality nesting/roosting habitat would receive treatment 

(shaded fuelbreak construction and hazardous fuel reduction treatments) within 150 feet of a 

high-use road, but would remain suitable post-project. Treatment of these areas would help 

protect existing high-quality nesting/roosting/foraging habitat from human-caused fires. This 

project meets the intent of Recovery Action (RA) 32 and the need to reduce inter-specific 

competition between spotted and barred owls.

o Recovery Action 10 (RA 10) requires that agencies:

 “Conserve spotted owl sites and high value spotted owl habitat to provide additional 

demographic support to the spotted owl population”.

 “When planning management activities, federal and non-federal land managers should 

work with the Service to prioritize known and historic spotted owl sites for conservation 

and/or maintenance of existing levels of habitat.”

Because the Six Rivers strives towards recovery of the spotted owl, all activity centers (ACs) 

receive the same level of protection and are not prioritized with some ACs getting less protection 

as allowed by the Recovery Plan. This exceeds the requirement of the RA 10 of the Recovery 

Plan. In addition, the USFWS requires a 70-acre nest grove protection zone. In this project we 

exceeded 70 acres around each known AC (each AC has a minimum of 100 acres delineated for 

nest grove protection), which was incorporated into the project design (see the BA for the project 

for specific information relating to nest groves). No activities would occur within the nest groves.

o Recovery Action 6 (RA 6) states, “In moist forests managed for spotted owl habitat, land 

managers should implement silvicultural techniques in plantations, overstocked stands, and 

modified younger stands to accelerate the development of structural complexity and biological 

diversity that would benefit spotted owl recovery.”

The 1st 48 Project would restore and accelerate development of important habitat characteristic 

for the spotted owl. This includes plantations and overstocked stands that, if treated, would 

increase the available habitats for the spotted owl and help reduce inter-specific competition 

between the barred owl and the spotted owl. Treatment of these stands would have an immediate 

benefit to the spotted owl.

The stands selected for treatment minimally met the definition of suitable nesting/roosting/foraging 

habitat, but had a lower likelihood contributing to survivorship or reproduction. The stands had one 

or more features of suitable habitat, but lacked other important characteristics that reduce their 

likelihood of occupancy or use. For example, a stand may have an average tree size of 21-inch dbh 

and 60 percent canopy cover, but lack large nest trees and multi-layered canopy conditions. The 1st

48 Project was designed to maintain current characteristics of nesting/roosting and foraging habitat 

but, more importantly, would create the currently lacking, critically important habitat characteristics 

for nesting/roosting and foraging habitat. It is expected that current habitat function would be 

maintained in all treatment areas immediately post-project (as was seen in the post-treatment review 

of the Beaverslide Project; however, approximately 90 percent of the nesting/roosting/foraging 

habitat in the action area would not have any treatment. Therefore, “adequate alternative habitat” as 
Chapter 3. Environmental Consequences

64 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

suggested by Forsman et al. (2011) remains available in the action area for owl use. The project 

would develop functional habitat that is currently lacking in the stands.

This project has protected all high-quality habitat, all spotted owl home ranges (not just high 

priority sites, RA 10) and would restore and accelerate important habitat characteristic for the 

spotted owl (RA 6) in young overstocked stands. Such long-term protection of owl habitat is 

consistent with the recommendations in the Recovery Plan.

The Recovery Plan states, “Dugger et al. (in press) found an inverse relationship between the 

amount of old forest within the core area and spotted owl extinction rates from territories” when 

barred owls were present. The Recovery Plan also states due to the “growing negative impact 

from barred owl invasions of spotted owl habitats (Forsman et al. 2011, Dugger et al. in press) ...

We recommend increased conservation and restoration of spotted owl sites and high-value 

spotted owl habitat to help ameliorate this impact” (emphasis added). Barred owls have been 

documented using a wider range of forest types (younger seral stages with more fragmentation) 

than spotted owls (Hamer 1988, Herter and Hicks 2000, Kelly et al. 2003, Hamer et al. 2007). 

Consequently, the loss of late-successional old-growth forest and increased fragmentation of these 

forests would decrease the amount of suitable habitat for spotted owls. In other words, without 

treatment of non- or poor-quality habitats in deficit core areas we may lose these sites to barred 

owls. The Recovery Strategy of the Recovery Plan supports “active forest management” and 

states, “In addition to describing specific actions to address the barred owl threat, this Revised 

Recovery Plan continues to recognize the importance of maintaining and restoring high value 

habitat for the recovery and long-term survival of the spotted owl”. The 1st 48 Project treatments 

within owl territories, including core areas, would accelerate the development of old forest 

characteristics, which would improve habitat conditions within spotted owl territories. The 

project meets the objectives of the Recovery Plan.

Barred Owl

Barred owls are recognized as a significant threat to the recovery of the NSO (USDI Fish and Wildlife 

Service 2011). The Recovery Plan addresses barred owls under RA 32 and RA 10, which are found under 

the “Barred Owl Recovery Actions”. The barred owl recovery actions were developed under the 

assumption that barred owls now occur at some level in all areas used now or in the past by spotted owls. 

This is true for the 1st 48 Project area as well. Surveys for this project found two barred owl sites. The 

Recovery Plan addresses the threat to the NSO from the barred owl through the preservation of existing 

high-quality habitat (RA 32) and preservation of high priority NSO territories (RA 10). The Recovery 

Plan also addresses the need to restore additional habitat for the owl in order to ameliorate the impact of 

the barred owl. While additional barred owls may or may not be present in the action area, 

implementation of RA 10 and RA 32 fully meets the best available barred owl mitigation measures by 

protecting, maintaining and restoring spotted owl habitat.

The Recovery Plan was informed by Forsman et al. (2011) and Dugger et al. (in press at the time, but 

subsequently published in 2011). The Recovery Plan states due to “The continued decline of the spotted 

owl populations and low occupancy rates in large habitat reserves, and the growing negative impact from 

barred owl invasions of spotted owl habitats (Forsman et al. 2011, Dugger et al. in press), which is greater 

than anticipated in the NWFP. We recommend increased conservation and restoration of spotted owl sites 

and high-value spotted owl habitat to help ameliorate this impact”.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 65

Recovery Action 32 specifically states: “Maintaining or restoring forests with high-quality habitat would 

provide additional support for reducing key threats faced by spotted owls” and “Protecting these forests 

should provide spotted owls high-quality refugia habitat from the negative competitive interactions with 

barred owls that are likely occurring where the two species” home ranges overlap. Maintaining or restoring 

these forests should allow time to determine both the competitive effects of barred owls on spotted owls 

and the effectiveness of barred owl removal measures”. All high-quality stands were dropped from 

treatment on the 1st 48 Project due to this recovery action and the need to reduce inter-specific completion 

of the owls and restoration activities are proposed for non-habitat or low-quality habitat stands.

Recovery Action 10 requires that agencies “Conserve spotted owl sites and high value spotted owl habitat 

to provide additional demographic support to the spotted owl population”. Maintaining all historic ACs is 

a standard SRNF protection measure. The Six Rivers’ database includes NSO ACs that predates the 1990 

listing of the NSO. All historic ACs (currently occupied or not) that meet the criteria of an AC (described 

in the USFWS survey protocol) are considered during project evaluation. The 1st 48 Project had eight (8) 

historic ACs mapped. One (1) AC was found to be active during first year of surveys to protocol (2017). 

All high-quality habitat, regardless if it was located within an active AC, was dropped from consideration 

during project design. In addition, the USFWS requires a nest grove protection zone of a minimum of 70-

acres around each known AC, which was exceeded for this project and incorporated into the project 

design. No activities would occur with the nest groves. The 1st 48 Project meets RA 10.

The habitat within two ACs (236 and 347) have been severely impacted by wildfires and no longer have 

100 acres of nesting/roosting habitat in close proximity to the AC. To protect these ACs, “nest protection 

areas” were delineated around the best location for the ACs (i.e., the nest protection area for AC 347 used 

the 2017 detection location). Some areas of habitat are still shown on the Six Rivers NF geospatial 

habitat-typing maps as suitable; however, field verification found much of the habitat had been burned by 

high severity fire and is no longer be suitable. Therefore, the nest protection areas consist of all available 

nesting/roosting/foraging habitat, but also includes non-habitat areas. Activity Center 236 has no activities 

planned within 0.5-mile core and activities within 0.5 miles of AC 347 will be limited to understory fuels 

reduction (brush and small diameter trees only). No actions will occur within the nest protection areas.

The 1st 48 Project has protected all high-quality habitats (not just old growth), all spotted owl territories (not 

just high priority sites) and would restore, maintain, and accelerate important habitat characteristic for the 

spotted owl. “Maintaining or restoring these forests should allow time to determine both the competitive 

effects of barred owls on spotted owls and the effectiveness of barred owl removal measures” (II-67 of the 

Recovery Plan). Protecting these forests should provide spotted owls high-quality refugia habitat from the 

negative interactions with barred owls that are likely occurring where the two species’ home ranges overlap. 

The 1st 48 Project would not exacerbate competitive interactions between the two species. Without the 

implementing the additional protection measures and recovery actions of the Recovery Plan, the barred owl 

may be successful in out-competing the spotted owl. It is imperative to the spotted owl’s recovery to take 

such actions. The 1st 48 Project is meeting the objectives of the Recovery Plan.

Fire

Another threat to the NSO addressed by the Recovery Plan is wildfire. The Recovery Plan identifies 

stand-replacing wildfire as one of the three top threats to the recovery of species stating,

o “Currently the primary source of habitat loss is catastrophic wildfire ....” The Recovery Plan

further notes that wildfire size and frequency have been increasing in the western United States

and that acres burned are expected to continue to increase due to climate changes and past land 

management practices. This overall increase in acres burned translates to a corresponding 
Chapter 3. Environmental Consequences

66 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

increase in the acres of spotted owl habitat lost to fire. While the risk of habitat loss to wildfire 

varies by location, the Recovery Plan emphasized that the Klamath region is one of the main 

areas at risk:

 “fire-prone provinces (including) California Klamath scored high on threats from ongoing 

habitat loss as a result of wildfire and the effects of fire exclusion on vegetation change.”

o “In view of the increasing risk posed to northern spotted owl habitat by wildland fire in the dry 

forests of the California Klamath Province, the Recovery Plan calls for management actions that 

result in forests that are more fire resilient and fire-resistant.”

The SRNF is within the Moist Forest zone of the spotted owl’s range as delineated in the Recovery Plan. 

However, the area’s dry, hot summers and extreme departure from its historic fire return interval mean that 

owl habitat within many areas of the Forest is at risk of being lost to, or significantly degraded by, severe fire. 

The 1999 Megram Fire (120,000 acres), 2002 Biscuit Fire (500,000 acres), the 2008 Lightning Complex 

(45,000), the 2013 Butler Fire (14,600 acres), the 2013 Coral Fire (12,500 acres), the 2015 lightning fires 

(100,000 acres forest-wide), the 2017 lightning fires (54,387 acres forest-wide), and many other smaller fires 

including the 2011 Ruth Fire (1,414 acres), all removed suitable NSO habitat on the Six Rivers, and 

demonstrates that the fire risk on the forest is genuine. Active management to reduce the fire hazard and 

increase resilience, as well as to accelerate the development of higher-quality NSO habitat, should contribute 

to the spotted owl’s persistence and recovery. Such long-term protection of owl habitat is consistent with the 

recommendations in Forsman et al. (2011), as well as the Recovery Plan and Critical Habitat Rule.

Impacts to Pacific Northwest forests from wildfire appear to be increasing along with fire occurrence, size, 

and intensity. Although some researchers disagree on the magnitude of these changes and what to do about 

them (e.g., Hanson et al. 2009, Baker 2012), most researchers believe, as does the USFWS (USDI 2012b), 

that these changes are happening, and that active management should be considered (e.g., Hessburg et al. 

2007, Healy et al, 2008, Heyerdahl et al. 2008, Kennedy and Wimberly 2009, Latta et al. 2010, Littell et al. 

2009, 2010, Spies et al. 2010, Perry et al. 2011, Syphard et al. 2011, Waring et al. 2011, Jenkins et al. 2012, 

Marlon et al. 2012, Miller et al. 2009, 2012). Thus, this project takes the active management intervention 

approach rather than a passive approach to restoring NSO habitat. This approach is what was envisioned by

the NWFP, Recovery Plan, and Critical Habitat Rule.

Northern Spotted Owl Habitat

Nesting/Roosting

The average home range of the NSO is 3,398 acres in this portion of its range, which equates to a circle 

with a 1.3-mile radius from the center of the territory or AC. Research indicates that the most activity 

within a territory occurs within 0.5 miles of the nest tree. Northern spotted owl territories with at least 400 

acres of suitable nesting/roosting/foraging habitat within 0.5 miles and 1,336 acres within 1.3 miles of the 

nest tree are generally thought to have a higher chance of occupation.

Suitable NSO nesting/roosting habitat, as defined by the Forest Service, is comprised of mature timbered 

stands having multi-layered conditions, an average canopy closure of 60 percent or greater (both conifers 

and hardwoods) and obvious decadence. The overstory should be comprised of conifer trees 21 inches or 

greater dbh. Conifer canopy closure should be 40 percent or greater. This habitat is used primarily for 

nesting/roosting. This definition shows its accuracy when compared to the actual nest locations on the 

SRNF where it is the pre-dominant type used by nesting spotted owls.

Nests are usually in snag cavities or broken tops of large trees in mature/old-growth forest. Daytime roost 

sites in northern California are in dense, multi-layered canopy forests, and average 550 feet from water.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 67

Foraging

Northern spotted owl forage in forested habitats with hunting perches and a stand structure that allows for 

flight in the understory and access to prey. The 1st 48 Project area includes a variety of habitats that 

provide the NSO with foraging opportunities.

In 2009, the USFWS Yreka office, prepared an unpublished white paper titled “Regulatory and Scientific 

Basis for US Fish and Wildlife Service Guidance for Evaluation of Take for Northern Spotted Owls on 

Private Timberlands in California’s Northern Interior Region”. In the paper, the USFWS stated, “The 

USFWS has conducted a thorough review and synthesis of published literature, unpublished data sets, and 

direct communication with NSO researchers in support of a rigorous process for evaluating the effects of 

habitat management on NSO.” The paper included information on the NSO across California with 

research specific to the SRNF.

In the white paper, the USFWS acknowledged that

o “Habitats used by NSO are highly variable, particularly in the diverse conifer-hardwood forests of 

the Klamath Province.”

o “Spotted owls also forage within intermediate (younger and/or more open) forest classes. One 

study (Zabel et al. 2003) found a positive association between NSO in the Klamath Province and 

moderate amounts of intermediate forest at the core area scale. This habitat class was based on 

conditions known to be used by foraging NSO.”

o “Foraging habitat encompasses nesting and roosting habitat but includes a broader range of structure 

and might not support successful nesting by NSO (Gutiérrez 1996, USDI Fish and Wildlife Service

2008). Foraging NSO generally use older, denser, and more complex forest than expected based on 

its availability, but they also use younger forest (Solis and Gutiérrez 1990, Carey et al. 1992, Zabel et 

al. 1993, Carey and Peeler 1995, Anthony and Wagner 1999, Irwin et al. 2007b).”

o “Foraging habitat encompasses a broad range of structure, and low-quality foraging habitat 

includes younger and more open habitats that may be important for prey production.”

o Based on the extensive research review conducted, the USFWS went on to define “infrequentlyused”, low-quality foraging habitat as having a minimum of 40 percent canopy cover and 11-inch 

dbh conifer trees.

In the Critical Habitat Rule, the USFWS acknowledged that “Compared to other zones, (in the Klamath 

and Northern California Interior Coast Ranges) additional foraging habitat for this zone showed greater 

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

In the Recovery Plan, the USFWS stated, “Because the characteristics of the stands or patches targeted by 

this recovery action vary widely across the range of the species, the Service believes implementation and/or 

mapping of this recovery action is best left to interagency teams with localized expertise.”

As stated in the white paper (USDI Fish and Wildlife Service 2009) “Determination of the amount of 

suitable habitat that must be retained in order to avoid incidental take of NSO is strongly influenced by 

the range of forest conditions that are classified as suitable habitat.” Narrowly defining what constitutes 

suitable habitat can severely underestimate impacts to the NSO. The SRNF/USFWS Arcata office Level 1 

Team conservatively and broadly defines low-quality habitat as having a minimum of 40 percent canopy 

cover and 11-inch dbh conifer trees.

Under the Proposed Action, the 1st 48 Project would treat 96 acres of moderate-quality nesting/roosting 

habitat, 194 acres of low-quality nesting/roosting habitat and 165 acres of moderate-quality foraging 
Chapter 3. Environmental Consequences

68 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

habitat, and 221 acres of low-quality foraging habitat. The 290 acres of nesting/roosting habitat and 383

acres of foraging habitat would be modified through the creation of a shaded fuelbreak and hazard fuel 

reduction (HFR) treatments. In addition, approximately 3 acres of low-quality foraging habitat removed 

for landings (0.25 acres in any one area).

Prey Species

In this area of the NSO’s range (below about 4,100 feet in southern Oregon and northern California), 

dusky-footed woodrats (Neotoma fuscipes), are the most important prey species of spotted owls, both in 

frequency and biomass (Forsman 1975, Barrows 1980, Solis 1983, Forsman et al. 1984, Ward 1990, 

Carey et al. 1992, Zabel et al. 1995, White 1996, Ward et al. 1998 Forsman et al. 2004 and Hansen and 

Mazurek 2010).

In a study conducted on the SRNF, Sakai and Noon (1993) found the highest abundance of woodrats 

occurred in 15- to 30-year-old plantations resulting from past clearcut timber harvest. The study used 

radio telemetry to track the movement of woodrats and found that although the woodrats inhabited 

younger stands, woodrats would often cross distinct ecotonal boundaries between forest types. Woodrats 

tracked during evening telemetry sessions made intermittent, short distance movements into adjacent oldgrowth forests occupied by spotted owls. A substantial number of radio tagged woodrats were killed by 

predators, with carcasses most often found in adjacent old forest. This is presumably because these 

younger, dense plantations are difficult if not impossible for the owl to forage in and must wait until the 

prey leave these refugia to be preyed upon.

Ward et al (1998) found that owls foraged along late-seral forest edges where dusky-footed woodrats were 

more abundant. Woodrats living in or dispersing from adjacent shrub lands may be more available for owls 

hunting along the ecotonal edges between habitat types. Edge or transitional habitats appear to be more 

important to foraging spotted owls when woodrats dominate the diet (Zabel et al. 1995, Ward et al. 1998). 

Edges may provide cover to conceal owls from predators while making them inconspicuous to woodrats.

These results suggest that the infrequent use of younger stands by foraging spotted owls is not due to low 

abundance of prey. Simply increasing prey densities within a stand may not result in an increase in prey 

available to spotted owls if their foraging efficiency is low in these stands (Rosenberg et al. 1994). High 

tree densities and homogeneous canopies in second-growth forests may reduce flight maneuverability and 

the ability of owls to capture prey (Rosenberg and Anthony 1992). However, silvicultural procedures that 

maintain or enhance woodrat populations adjacent to spotted owl habitat may benefit spotted owls (Sakai 

and Noon 1993, Irwin et al. 2007).

Stands occupied by woodrats gradually decline in suitability. Data from Sakai and Noon (1993) suggest 

that this occurs when the dominant trees (usually Douglas-fir) begin to over top and eventually suppress 

the low-to-mid-canopy level vegetation (<3 to 6 meters). In the inland forests of northwestern California, 

the decline in habitat quality occurs in regenerated stands at about 40 to 50 years after harvest. To enhance 

dusky-footed woodrat populations, Sakai and Noon proposed retaining brush patches during 

precommercial thinning and creating brush patches in younger stands. The existence of shrub fields or 

younger stands adjacent to older forest may increase the availability of woodrats to spotted owls that 

exploit prey from a variety of habitats but spend the majority of their time hunting in late seral stage 

forests (Sakai and Noon 1993).

The northern flying squirrel (Glaucomys sabrinus) is a smaller component of the biomass collected by the 

spotted owl in this portion of the province. In northwestern California, flying squirrels constitute only 9.3 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 69

percent of the biomass of NSO diet, while dusky-footed woodrats constitute 70.9 percent of the biomass 

of NSO diet (Ward et al. 1998).

Forsman et al. (1984) described potential negative impacts to flying squirrels through the timber harvest; 

however the conditions described by Forsman occurred in heavily thinned mature and old growth stands. 

No high-quality nesting/roosting habitat is being treated under the 1st 48 Project. Thinning might also 

affect flying squirrels through reduction or development of other important resources, such as shrubs, 

hardwoods, arboreal lichens, or deformed trees and snags (Williams et al. 1992, Carey 1995). The 1st 48 

Project would protect these important habitat components. Hansen and Mazurek (2010) found “mixed” 

results in relation to the flying squirrel, with some studies showing no effect at all from thinned forests 

compared to unharvested stands.

Northern Spotted Owl Status within the Project Area

There are eight (8) identified NSO ACs located within the project area. The project area is 32,892 acres in 

size, with 12,777 acres of NSO nesting/roosting habitat and 8,069 acres of foraging habitat. Three (3) of 

the ACs home ranges (1.3 miles) extend beyond the project area. An action area has been defined that 

addresses the entire home ranges of the three (3) NSO territories that extend beyond the project area. The 

action area is 36,267 acres. There are 13,686 acres of NSO nesting/roosting habitat and 8,648 of foraging 

habitat in the action area.

There are also four (4) additional ACs outside of the project area whose home ranges overlap the project 

area (ACs 238, 250, 274 and 388); however, no treatments would occur in the territories. These ACs were 

not addressed any further.

Nesting/roosting habitat was originally determined through use of current geospatial data. Field verification 

of this data was conducted by wildlife biologists. All high-quality habitat was dropped from treatment.

Northern spotted owl protocol surveys were conducted, using the 2012 USFWS protocol, in all suitable 

habitats for the 1st 48 Project in 2017, with the second year of surveys scheduled for 2018. In addition, 

NSO surveys were conducted within the planning area in the early and mid-1990s. There are three 100-

acre LSRs located in association with ACs 290, 239 and 236; however, the LSR does coincide with the 

actual nest grove (which is based on the owl’s location) for the AC. Therefore, no treatment would occur 

within these 100-acre LSRs.

Northern Spotted Owl Critical Habitat

Critical habitat consists of those areas that have “physical or biological features (I) essential to the 

conservation of the species and (II) which may require special management considerations or protection” 

16 USC §1532(5)(A). These physical or biological features are referred to as the “primary constituent 

elements” (PCE) associated with the terrestrial environment that support nesting, roosting, and other 

normal behaviors are essential to the conservation of the NSO. The PCEs of NSO CHU (critical habitat

unit) are coniferous forest types that support the NSO in nesting/roosting, foraging, and dispersal habitat.

Approximately 28,413 acres of the action area occurs within the Unit 11, Interior California Coast Subunits 

(ICCSs) 1 and 2 of the Critical Habitat Rule. Under the Proposed Action, there are 16 units to be treated for 

hazardous fuel reduction (215 acres), four (4) units of oak woodland restoration (37 acres), eight (8) units of 

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

CHU. A total of 821 acres would be treated in CHU, 39 acres would be treated in ICCS 1 and 784 acres 

would be treated in ICCS 2. A total of 786 acres of NSO nesting/roosting/foraging/dispersal habitat and 37 

acres non-habitat would be treated between the two subunits of CHU. In ICCS 1, fuelbreak construction 
Chapter 3. Environmental Consequences

70 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

would occur in 39 acres of low-quality foraging habitat. In ICCS 2, hazardous fuel reduction would occur in 

54 acres of low-quality nesting/roosting habitat, eight (8) acres of moderate-quality nesting/roosting habitat, 

64 acres of moderate-quality foraging habitat, and 87 acres of low-quality foraging habitat. Plantation thins 

would occur on 108 acres of dispersal-only habitat. Fuelbreak construction would occur in approximately 88 

acres of moderate-quality nesting/roosting habitat, 140 acres of low-quality nesting/roosting habitat, 101 

acres of moderate-quality foraging habitat, and 95 acres of low-quality foraging habitat.

The Critical Habitat Rule states:

We encourage land managers to consider implementation of forest management practices 

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

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

ecological forestry management practices (e.g., Gustafsson et al. 2012, entire; Franklin et 

al. 2007, entire; Kuuluvian and Grenfell et al. 2012 entire) within critical habitat to reduce 

the potential for adverse impacts associated with commercial timber harvest when such 

harvest is planned within or adjacent to critical habitat. In sum, the Service encourages 

land managers to consider the conservation of existing high-quality northern spotted owl 

habitat, the restoration of forest ecosystem health, and the ecological forestry management 

practices recommended in the Revised Recovery Plan that are compatible with both the 

goals of northern spotted owl recovery and Standards and Guidelines of the NWFP.

Nesting/Roosting and Foraging Habitat

Initial potential treatment units were selected by a silviculturist from a vegetative database and then field 

verified as to stand density and structure. Field verification to determine potential habitat status was 

completed by a wildlife biologist. All stands classified as high-quality habitat was excluded from 

treatment. Mid-mature stands with pre-dominant trees were ground verified as to whether they contained 

stand structure characteristics that would be classified as high-quality nesting/roosting habitat. All highquality nesting/roosting habitat stands (those in mid-mature stands with mature forest characteristics, late 

mature, and old growth) were dropped from treatment.

All stands were field verified assessed based on the experience of the wildlife biologist. Some stands 

labeled as mid-mature that lack some of the qualities of nesting /roosting, such as tree structures and 

deformities, were classified as foraging habitat.

Direct and Indirect Effects: The following discussions group direct and indirect effects into two primary 

categories, nesting/roosting and foraging habitat. Within each broad habitat category, effects would be 

grouped into direct habitat removal and habitat maintenance, as well as impacts to ACs. Disclosing 

impacts by individual AC can be misleading because the same acre treated may be reported more than 

once due to an overlap of ACs.

The USFWS defines “habitat maintenance” as a reduction in stand density, but the current habitat 

function would be maintained immediately post project with the purpose of improving habitat quality 

over time. “Removal” occurs when the habitat no longer functions as nesting/roosting or foraging habitat 

(e.g., clear cutting). Habitat maintenance treatments are treatments designed to maintain and enhance 

habitat. A “downgrade” is taking a higher habitat quality down to a lower habitat type, such as removing 

too much canopy and making a nesting/roosting stand only suitable as foraging habitat.

No habitat removal or downgrading would occur under the 1st 48 Project except for landing construction. 

Twenty new landings would be constructed for the project. Twelve (12) landings, up to approximately 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 71

0.25 acres in size would be constructed in foraging habitat for a total of three (3) acres of low-quality 

foraging habitat, negligible amounts of habitat reduction in any one area. The majority of landings that 

would be used for this project are existing openings that would only need minor expansion and brushing 

for safe operations; therefore, three (3) acres of foraging habitat removed is an overestimate. Anchor 

points above landings/unit would be needed for safety support of cable logging systems. Anchor points 

include 18- to 20-inch trees, sound snags, or heavy equipment parked above the landing. Landings used 

for the project would be decommissioned following project activities. In addition, a small number of trees 

may be removed along cable lines, in association with skyline landings within the unit boundaries, for 

safety reasons.

Forest Service Road 2S54 within the planning area would be decommissioned. The road is 1.95-miles 

long and decommissioning it would reduce fragmentation and disturbance, so would be beneficial in the 

long term. No new roads would be constructed within the project.

The USFWS has determined minimum habitat guidelines, or the minimum amount of nesting/roosting 

habitat) and foraging habitat, that must be maintained in a territory within a specific distance from the 

core area of use in order for an NSO pair to persist at the site. Habitat removal or downgrading that 

reduces habitat below these minimum guidelines may be considered “take” under the Endangered Species 

Act (ESA). Habitat removal that did not reduce the amount of habitat below these guidelines was not 

considered take, although the impacts could still be considered adverse. For example, depending on the 

location (spatial relationship of proposed treatment areas to existing habitat), amount treated, and 

intensity of the treatment, actions that modify habitat but maintain habitat functionality without any 

habitat removal could still have adverse impacts on the owl if a territory was already below the “take” 

threshold. The Level 1 Team developed the Project Scope and Intensity Analysis (PSIA), a series of 

questions that guide the biologist through an analysis of potential effects for each owl AC within the 

planning area. The PSIA was conducted that evaluated all eight (8) NSO ACs within the analysis area 

which addressed each AC for the current amount of nesting/roosting/foraging habitat in relation to the 

guidelines, the amount and location of proposed treatments, and the percentage of nesting/roosting/

foraging habitat affected. The results of the PSIA were used to further modify the treatments in order to 

ensure that no adverse effects would occur and that restoration activities would benefit the NSO.

The stands selected for treatment minimally met the definition of suitable nesting/roosting/foraging 

habitat, but have a lower likelihood contributing to survivorship or reproduction. The stands had one or 

more features of suitable habitat, but lacked other important characteristics that reduce their likelihood of 

occupancy or use. For example, a stand may have adequate average tree size and canopy cover, but may 

be even-aged and lack large (potential nest) trees or multi-layered canopy conditions. The 1st 48 Project

was designed to maintain current characteristics of nesting/roosting and foraging habitat but, more 

importantly, to create the habitat characteristics that are currently lacking.

The oak woodland treatments would restore black and white oak areas that are being encroached upon by 

dense brush and Douglas-fir saplings. None of the oak woodland treatments occur in suitable NSO 

nesting/roosting/foraging habitat.

The 1st 48 Project would treat 96 acres of moderate-quality nesting/roosting habitat, 194 acres low-quality 

nesting/roosting habitat and 221 acres of low-quality foraging habitat and 165 acres moderate-quality 

foraging habitat. The 290 acres of nesting/roosting habitat and 383 acres of foraging habitat would be 

modified through the creation of a shaded fuelbreak and HFR treatments (plus an additional 3 acres of low-
Chapter 3. Environmental Consequences

72 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

quality foraging habitat removed for landings). The remaining acres are considered non-habitat for spotted 

owls and are primarily fuels treatments within hazardous fuels stands within the fire scar of the Ruth Fire.

There are 13,686 acres of nesting/roosting habitat and 8,648 of foraging habitat in the action area. It is 

expected that current habitat function would be maintained in all treatment areas immediately post-project 

(as was seen in the post-treatment Level 1 Team review of other SRNF habitat restoration projects); 

however, approximately 97 percent of the nesting/roosting/foraging habitat in the action area would not 

have any treatment. Therefore, “adequate alternative habitat” as suggested by Forsman et al. (2011) is 

being left untreated.

Approximately 88 acres of moderate-quality nesting/roosting habitat, 140 acres of low-quality 

nesting/roosting habitat and approximately 101 of moderate foraging habitat and 134 acres of low-quality 

foraging habitat would be thinned for the construction of the shaded fuelbreak. Approximately 8 acres of 

moderate-quality and 54 acres of low-quality nesting/roosting and 64 acres of moderate-quality and 87

acres of low-quality foraging will be treated through hazardous fuels reduction (HFR).

The 1st 48 Project is a low-intensity TFB that would not remove any pre-dominant or dominant trees and 

canopy closure would be maintained at 60 percent or greater in all nesting/roosting/foraging habitat. No 

treatments would occur in spotted owl nest groves or high-quality nesting/roosting habitat. Adequate 

alternative habitat (98% nesting/roosting/foraging habitat untreated) exists in the action area.

This project has protected all high-quality habitat, all spotted owl territories (not just high priority sites, 

RA 10) and is designed to restore and accelerate important habitat characteristic for the spotted owl (RA 

6) and protect existing suitable habitat from stand replacing fire. Such long-term restoration and 

protection of owl habitat is consistent with the recommendations in the Recovery Plan. This project and 

the type of habitat proposed for treatment meets the recommendations of and are consistent with the 

Critical Habitat Rule (and Recovery Plan).

Nesting/Roosting Habitat – Nesting/Roosting Habitat Removal: No nesting/roosting habitat would be 

removed by the 1st 48 Project.

Nesting/Roosting Habitat – Maintenance: The 1st 48 Project would treat 96 acres of moderate-quality 

nesting/roosting habitat and 194 acres low-quality nesting/roosting habitat. Of the 290 acres of 

nesting/roosting habitat being treated, 88 acres of moderate-quality nesting/roosting habitat and 140 acres 

of low-quality nesting/roosting habitat would be modified through the creation of a shaded fuelbreak and 

8 acres of moderate-quality nesting/roosting habitat and 37 acres of low-quality nesting/roosting habitat 

would be modified through hazardous fuel reduction.

The total acreage for fuelbreak construction units is 461 acres; 228 acres of that is considered low- and 

moderate-quality nesting/roosting habitat. No high-quality nesting/roosting habitat would be treated 

within the 1st 48 Project. Since sections of this area of fuelbreak occur in younger stands, 228 acres 

overestimates the amount of nesting/roosting habitat being treated.

Thin from below would reduce the stand density of trees to improve growth, enhance stand health, and 

reduce potential tree mortality. Thin from below while maintaining a minimum of 60 percent or greater 

canopy cover is the best management prescription to maintain and recruit the habitat variables critical to 

nesting/roosting habitat (e.g., large old trees and co-dominant and intermediate conifers with crown space 

in the canopy for crown development) while at the same time improving forest health and reducing risk to

wildfire and insects and disease. Removal of the co-dominant trees would only occur when stem densities 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 73

needs reduced for proper heath of another adjacent co-dominant tree or when culturing around resident 

black oak trees.

The stands within nesting/roosting habitat proposed for treatment are generally even-aged and lack the 

horizontal and vertical diversity components associated with late-mature stands. These stands have the 

potential to achieve rapid diameter and height growth with thinning. As these stands develop, the acres 

suitable for spotted owls and other late-successional associated species should increase. By treating 

currently unsuitable habitat adjacent to existing late-successional habitat, larger patches would develop. 

Silvicultural prescriptions can be applied to these stands in order to accelerate their development toward 

late seral conditions. These treatments can increase the amount of late seral vegetation quicker than would 

occur naturally. Treatments would change the stand structure and allow large trees to develop, promote 

development of an understory canopy, accelerating the development of functional late-successional 

habitat. Silvicultural prescriptions developed for the 1st 48 Project would ensure retention of existing 

stand structure, species composition, snags, and downed logs.

Thinning and fuels reduction activities may have a short-term reduction of stand density in suitable NSO 

nesting/roosting habitat; however, the habitat would remain suitable post project. Canopy closure would 

be maintained at 60 percent or greater in nesting/roosting habitat, no pre-dominant or dominant trees 

would be removed and large snags and downed wood would be maintained at the 80 to 100 percent level. 

All high-quality nesting/roosting habitat was excluded from thinning. Selected stands for thinning are 

considered low to moderate quality, with the potential to be improved through treatment.

The HFR prescriptions would treat 8 acres of moderate-quality nesting/roosting habitat and 54 acres of 

low-quality nesting/roosting habitat; however, all existing important habitat characteristics for nesting 

would be maintained and the stands would still function as nesting/roosting immediately post-project.

Of the 13,686 acres of nesting/roosting habitat within the action area, approximately 96 acres of 

moderate-quality nesting/roosting habitat and 194 acres of low-quality nesting/roosting habitat would be 

treated though both shaded fuelbreak and hazardous fuel reduction. The amount of nesting/roosting 

habitat within the planning area proposed for treatment would be approximately 2 percent (98% 

nesting/roosting in the action area would not receive any treatment).

Strategically located fuelbreaks would reduce the risk of human-caused fire ignitions along high-use 

forest and county roads and provide greater protection to existing late-successional habitat in the 1st 48 

Project area. Fuel reduction treatments are designed to protect existing habitat characteristics while 

reducing ground and ladder fuels and creating a defensible space to be used in defense of wildfires. 

Treatments include thinning existing stands to retain the best, healthiest trees that have a high canopy 

capacity (those with the strongest crown to bole ratio, have the highest needle or leaf cover and provide

the most shade to the forest floor), capable of maintaining those objectives for a long period of time 

within the buffer area. All pre-dominant and dominant trees would be retained, while removing 

suppressed, intermediate, and some co-dominant trees (under specific conditions), and large snags and 

downed wood would be maintained at the 80 to 100 percent level. Cut material in nesting/roosting habitat 

would be would be lopped and scattered, handpiled and burned, or jackpot burned. The habitat would 

remain suitable immediately post project.

The thinning units would be hand piled and burned with some units having a follow-up understory burn. 

All 290 acres of nesting/roosting habitat to be thinned may be jackpot burned, if conditions are within the 

required limits to maintain a low-intensity burn. The primary objective of burning is to reduce ground 

fuels within fuelbreaks. Once the initial treatment has been completed, maintenance burns or treatments 
Chapter 3. Environmental Consequences

74 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

would be implemented every 5 to 15 years or as need is determined. Because of its low intensity, the burn 

is not uniform in nature creating a mosaic pattern within the stand. Effects of jackpot burning would be 

limited because of this patchiness leaving interspaces of unburned forest floor. Foraging habitat would be

modified as some understory shrubs and some small saplings would be killed and some smaller downed 

logs would be consumed from the burning in portions of the stand; however, current habitat function 

would be maintained.

Jackpot burning is expected to reduce the quantity of downed woody material to various degrees 

regardless of the season of burning; however, snag and log numbers would be maintained at levels 

designated in the SRNF LRMP. Generally, the wetter the conditions during the burn, the less the impact 

would be to the surrounding habitat components. Jackpot burning is designed to produce the least damage 

to the boles of the trees in the unit and to prevent fire from getting into the crowns of the overstory. Tree 

mortality would be minimal and mainly in the smaller size classes. In some cases, lines would be 

scratched around snags and existing downed wood.

Fuels treatments are not intended to homogenize habitats. Jackpot burning would occur under specific 

weather and moisture conditions designed to minimize damage to the residual stand, maintain snags and 

large down logs, and maintain about 50 percent of the duff layer (USFS Region 5 Soil Quality S&Gs). 

Dead and down materials are usually of large enough diameters that the logs are not burned completely

and continue to provide key habitat features, such as refugia and escape cover. Fuel moistures and 

humidity are monitored to assure that the prescriptions are met. Burn prescriptions are designed to prevent 

severe burn levels.

Nesting/Roosting Habitat – Summary: Thinning and fuels reduction activities may modify 

nesting/roosting habitat through a short-term reduction of stand density; however, the habitat would 

remain suitable post project. Canopy closure would be maintained at 60 percent or greater, no predominant or dominant trees would be removed and large snags and downed wood would be maintained at 

the 80 to 100 percent level. Selected stands for thinning are considered low- to moderate-quality habitat, 

with the potential to be improved through treatment. Treatments would be beneficial in the long term by 

creating stand conditions that accelerate the development of high-quality habitat in a shorter timeframe 

than would occur without treatment. This restoration and maintenance of habitat would aid in bringing 

these stands along in a manner consistent with pre-fire suppression era growth.

No activities would occur in high-quality nesting/roosting habitat or in 100-plus-acre nest groves of any 

AC, and no activities would occur within 0.25 mile of any AC during the breeding season.

Foraging Habitat

Foraging habitat generally has attributes similar to that of nesting/roosting habitat, however does not 

contain the structural characteristics necessary to support successfully nesting pairs. The foraging habitat 

selected for treatment in the 1st 48 Project is lacking diversity of species and sizes as well as structural 

components such as multi-layered conditions, snags, downed wood and decadent structures such as large 

limbs, broken tops, and cavities.

There are 8,648 acres of foraging habitat in the action area. The 1st 48 Project would treat 221 acres of lowquality foraging habitat and 165 acres moderate-quality foraging habitat. Of the 383 acres of foraging 

habitat being treated (plus approximately 3 acres removed for landings), 131 acres of low-quality foraging 

habitat and 101 acres of moderate-quality foraging habitat would be modified through the creation of a 

shaded fuelbreak and 87 acres of low-quality foraging habitat and 64 acres moderate-quality foraging

habitat would be modified through hazardous fuel reduction. The prescriptions would maintain a minimum 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 75

of 60 percent canopy cover and would remain suitable foraging habitat immediately post project. 

Approximately 4 percent of the foraging habitat in the action area would receive treatment leaving 96 

percent of the foraging-only habitat in the action area untreated.

Northern spotted owl will also forage in nesting/roosting habitat. There are 13,686 acres of nesting/

roosting habitat and 8,648 of foraging habitat in the action area. It is expected that current habitat function 

would be maintained in all treatment areas immediately post-project (as was seen in the post-treatment 

Level 1 Team review of the Beaverslide Project on the Mad River RD treated in 2012, which 

implemented similar prescriptions); however, approximately 97 percent of the nesting/roosting/foraging 

habitat in the action area would not have any treatment. Therefore, “adequate alternative habitat” as 

suggested by Forsman et al. (2011) is being left untreated. The project would develop functional habitat 

that is currently lacking in the stands.

Foraging Habitat Removal: The only treatments that would remove habitat would be the construction of 

landings. Twenty (20) new landings would be constructed, 12 of which are in low-quality foraging 

habitat. Each landing would be up to 0.25 acres in size. Approximately 3 acres of low-quality foraging 

habitat would be removed through new landing construction. Removal of habitat for landings is limited to 

small areas and is considered insignificant because after treatment they would resemble small forest 

openings. Small openings can be beneficial in stands lacking structural diversity to “maximize individual 

tree development, encourage some understory vegetation development, and encourage the initiation of 

structural diversity” (Interagency REO memorandum 1996). Often the canopy above the roads still falls 

within the 40 percent retention guidelines, but is considered removed to evaluate the full potential of 

affects to any given AC.

The majority of landings that would be used for this project are existing openings that would only need 

minor expansion and brushing for safe operations; therefore, 3 acres of foraging habitat removed is an 

overestimate. A small number of trees may be removed along cable lines, in association with skyline 

landings within the unit boundaries, for safety reasons.

Nineteen out of the 20 new landings occur within four (4) ACs. All landings would occur within the outer 

1.3-mile radius of the affected ACs. The maximum amount of foraging habitat that would be removed in 

any one AC is 1 acre, 0.25 acre in any one area. Total removal by new landing construction would be 3 

acres of the 8,648 acres of foraging-only habitat in the action area. The loss of habitat in any one area 

would be negligible and would resemble natural assemblages and small forest openings.

The removal of these small patches (0.25 or less in any one area) of low-quality foraging habitat (totaling 

3 acres) would allow the shaded fuelbreak treatment of 221 acres of other low-quality stands of foraging 

habitat. In the long term, this would improve the stands that are currently not providing adequate habitat 

conditions due to high tree density and lack of structural diversity. In the short term, these small openings 

may be utilized by the owls for foraging (North et al. 1999, Carey 1995).

Foraging Habitat Maintenance – Shaded Fuelbreak Construction and Plantation Thinning:

Approximately 134 acres of low-quality foraging (3 acres of which would be removed for landings) and 101

moderate-quality foraging habitat would be thinned for fuelbreak construction. Fuelbreaks would be created 

along high-use roads to assist in firefighting efforts and to protect existing nesting/roosting/foraging habitat 

within NSO territories from human caused fires. These prescriptions are designed to reduce ground fuels 

and the lower understory vegetation that create ladders for fire to climb into the canopy. Although multilayered conditions contributing to foraging habitat would be slightly reduced by removing brush and 
Chapter 3. Environmental Consequences

76 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

understory trees, treatments would result in a greater assurance of long-term maintenance of suitable 

foraging habitat within the project area and reduce the risk that existing habitat would be lost due to fire.

Plantation thin treatments would occur in even-aged young stands that are in early seral stages of 

development. These stands of plantations lack the structure needed to be considered for NSO habitat, such 

as multiple canopy layers and structure within the stand. The project includes 108 acres of plantation 

thinning of mechanical TFB (60-plus percent crown closure) with 15- to 24-foot inter-tree crown spacing) 

in 30- to 45-year-old, even-age plantations to promote the development of shaded fuelbreak overstory, 

along with mechanical, manual and jackpot burning.

Individual trees with high potential for rapid growth would be widely spaced to accelerate diameter and 

height growth with the expectation of achieving vertical diversity. These trees are also expected to 

develop wide crowns and large limbs. No pre-dominant trees would be removed. Existing snags (20-inch 

dbh or greater) and downed logs (20-inch diameter or greater and 10-feet long) would be maintained 

unless they pose a safety hazard or reduce the effectiveness of the shaded fuelbreaks.

The low-quality foraging habitat and moderate-quality foraging habitat stands selected for treatment 

minimally met the definition of foraging habitat, but have a lower likelihood contributing to survivorship 

or reproduction. The stands have the tree diameter size and canopy cover of suitable habitat, but lack 

other important characteristics (such as multi-layered conditions that provide for prey species) that reduce 

their likelihood of use. Treatments were designed to accelerate the development of important habitat 

components currently lacking in the stands while retaining the existing structural elements, resulting in 

high restoration benefits. The project would improve habitat conditions and restore high-quality habitat 

for the spotted owl. Canopy closure would be reduced in the short-term, but would be maintained at a 

minimum of 60 percent. Foraging habitat would remain suitable immediately post project. In the long 

term, the treatments should improve habitat conditions by accelerating the development of stand attributes 

important to the NSO (e.g., multi-storied stands and large-diameter trees with large crowns) and 

contribute to the recovery of the species.

In the plantations and dense, overstocked, early-seral stands (not currently suitable foraging habitat), the 

benefit to the owl would be immediate. The treatments proposed would reduce the overstocked stems and 

ladder fuels that currently create a “safe haven” for woodrats since the owls cannot effectively forage in 

these dense stands. Treatments of these stands would create more acres of habitat on the landscape, 

helping reduce competitions between the spotted and barred owls for the same habitats.

The stands proposed for treatment are generally even-aged and lack the horizontal and vertical diversity 

components associated with late-mature stands. These young stands have the potential to achieve rapid 

diameter and height growth with commercial thinning. As these stands develop, the acres suitable for 

spotted owls and other late-successional associated species should increase. By treating currently 

unsuitable habitat adjacent to existing late-successional habitat, larger patches would develop. 

Silvicultural prescriptions can be applied to these stands in order to accelerate their development toward 

late seral conditions. These treatments can increase the amount of late seral vegetation quicker than would 

occur naturally. Treatments would change the stand structure and allow large trees to develop, promote 

development of an understory canopy, accelerating the development of functional late-successional 

habitat. Silvicultural prescriptions designed for the 1st 48 Project would ensure retention of existing stand 

structure, species composition, snags, and downed logs.

Thinning in currently lower-quality foraging habitat is the best prescription to maintain and recruit the 

habitat variables critical to NSO high-quality foraging and nesting/roosting habitat. Treatments would have 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 77

a positive impact on NSO foraging habitat since stand growth would be accelerated resulting in older seral 

stages earlier than if left unthinned. Reducing tree density within foraging habitat would improve the owl’s 

ability to forage within the stands as well as improve forest health and reduced fire risk. Thinning provides 

more sunlight to the forest floor for plant species used as food by key spotted owl prey species. Existing 

structural conditions would be maintained in order to support prey occurrence and abundance while 

allowing for rapid development of additional habitat parameters such as low shrub and forb growth. 

Current low-quality foraging habitat could develop into higher quality, more productive foraging habitat 

and even nesting/roosting habitat over time with the accelerated development of late successional 

characteristics (multi-layered conditions and large diameter trees with cavities and large limbs).

Fuels Reduction Treatments: Approximately 87 acres of low-quality and 64 acres of moderate-quality 

foraging habitat would be modified through fuels reduction treatments. Fuels treatment would occur on 

215 acres of strategic roadside and ridgetop units. These fuels treatments would reduce fuel loadings in 

order to create a defensible space for fire suppression resources, decrease the potential for detrimental 

wildfire effects to the overall project area adjacent to the community of Ruth, and enhance the treated 

stands resiliency to fire.

The HFR treatment areas are typically dominated by dead standing trees created by the 2011 Ruth Fire 

and areas of brush such as manzanita, where sufficient live overstory does not exist for the development 

of a shaded fuelbreak.

The thinning units would be hand piled and burned with some units having a follow-up jackpot burn. All 

383 acres of foraging habitat to be thinned may be jackpot burned if conditions are within the required 

limits to maintain a low-intensity burn. The primary objective of jackpot burning is to reduce ground fuels 

within fuelbreaks. Once the initial treatment has been completed, maintenance burns or treatments would 

be implemented every 5 to 15 years or as need is determined. Because of its low intensity, the burn is not 

uniform in nature creating a mosaic pattern within the stand. Effects of jackpot burning would be limited 

because of this patchiness leaving interspaces of unburned forest floor. Foraging habitat would be 

modified as some understory shrubs and some small saplings would be killed and some smaller downed 

logs would be consumed from the burning in portions of the stand; however, current habitat function 

would be maintained. The results would be a more complex understory and forest floor that would benefit 

key prey species for the spotted owl such as the dusky-footed woodrat, while breaking up the continuity 

of the fuels in the understory to reduce flame length and spread of wildfire.

Jackpot burning is expected to reduce the quantity of downed woody material to various degrees 

regardless of the season of burning; however, snag and log numbers would be maintained at levels 

designated in the Six Rivers LRMP. Generally, the wetter the conditions during the burn, the less the 

impact would be to the surrounding habitat components. Jackpot burning is designed to produce the least 

damage to the boles of the trees in the unit and to prevent fire from getting into the crowns of the 

overstory. Tree mortality would be minimal and mainly in the smaller size classes. In some cases, lines 

would be scratched around snags and existing downed wood.

Fuels treatments are not intended to homogenize habitats. Jackpot burning would occur under specific 

weather and moisture conditions designed to minimize damage to the residual stand, maintain snags and 

large down logs, and maintain about 50 percent of the duff layer (USFS Region 5 Soil Quality S&Gs). 

Dead and down materials are usually of large enough diameters that the logs are not burned completely 

and continue to provide key habitat features, such as refugia and escape cover. Fuel moistures and 
Chapter 3. Environmental Consequences

78 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

humidity are monitored to assure that the prescriptions are met. Burn prescriptions are designed to prevent 

severe burn levels.

Burning could reduce prey species habitat temporarily in the immediate area, but is expected to be shortterm leading to an overall increase of post-treatment prey habitat. In addition, owls are known to forage 

within the burned areas once the understory vegetation begins to grow again (USDA Forest Service 1985, 

Clark 2007, Bond et al. 2009). Fuels reduction along high-use roads is expected to result in the protection 

and long-term maintenance of adjacent late-successional habitat by creating more fire resilient and fireresistant forests.

Foraging Habitat Summary: Thinning and fuels reduction activities may modify foraging habitat 

through a short-term reduction of stand density; however, the habitat would remain suitable post project. 

Canopy closure would be maintained at 60 percent or greater, no pre-dominant or dominant trees would 

be removed and large snags and downed wood would be maintained at the 80 to 100 percent level. 

Selected stands for thinning are considered low to moderate-quality habitat, with the potential to be 

improved through treatment. Treatments would be beneficial in the long term by creating stand conditions 

that benefit prey and accelerate the development of higher quality habitat in a shorter timeframe than 

would occur without treatment. This restoration and maintenance of habitat would aid in bringing these 

stands along in a manner consistent with pre-fire suppression era growth.

Northern Spotted Owl Activity Center Summary

Direct, indirect and cumulative effects were analyzed for nesting/roosting and foraging habitat. The 

USFWS considers that the most activity occurs within 0.5 miles of the nest tree. Northern spotted owl 

territories with at least 400 acres of suitable habitat within 0.5 miles and 1,336 acres within 1.3 miles of 

the nest tree are generally thought to be more likely to be reproductively successful (USDI Fish and 

Wildlife Service 2009).

Habitat Guidelines: The USFWS has determined minimum habitat guidelines, or the minimum amount 

of nesting/roosting/foraging habitat, that must be maintained in a territory within a specific distance from 

the core area of use in order for an NSO pair to persist at the site. Habitat removal below these minimum 

guidelines may be considered “take” under the ESA. These habitat guidelines are also used to assess the 

relative condition of the AC. The SRNF also uses the relative condition of an AC to evaluate the level of 

impact from habitat treatments (manipulating the habitat but maintaining habitat function) even though no 

take would occur.

The guideline for the home range is to maintain a minimum of 1336 acres of nesting/roosting/foraging 

habitat within 1.3 miles, 400 acres within 0.5 miles and 936 between 0.5 and 1.3 miles of the AC. The 0.5 

miles is the core for nesting and the outer area, out to 1.3 mile, provides other elements critical to their 

life histories such as foraging. The USFWS has determined that the proportion and types of habitat to be 

maintained within the core area is very important in predicting NSO presence. The USFWS found that the 

highest use areas were within 0.5 miles of the nest and contained a combination of 48 percent nesting/ 

roosting and 28 percent foraging habitat (USDI Fish and Wildlife Service 2009). Applying these 

percentages rounded up to the 0.5-mile scale, results in the guidelines of 250 acres of nesting/roosting 

habitat and 150 acres of foraging habitat. Between 0.5 and 1.3 miles of the AC, the SRNF/USFWS Arcata 

office Level 1 Consultation Team determined that the 936 acres should consist of a minimum of 300 acres 

of nesting/roosting habitat and 636 acres of foraging habitat. It is important to recognize the difference 

between habitat use guidelines in the determination of take under ESA versus descriptions of desired 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 79

habitat conditions for conservation of NSO. Table 11 displays the current amount of nesting/roosting/

foraging habitat within the 1st 48 Project ACs.

One mapped NSO AC affecting this project occurs near FSR 2S48, where a nest tree is located 

approximately 75 feet outside the treatment unit. Although no NSO detections have been recorded since 

1992, in order to protect the nest tree and maintain the effectiveness of the fuelbreak, fuel treatments 

would occur within 50 feet of the road, following the standard fuelbreak prescription described above. In 

affected areas remaining, 40 to 50 percent of existing brush would be maintained for wildlife cover. 

Overstocked trees less than 8-inch dbh would still be reduced and pruning of residual trees would still be 

allowed in these areas.

Table 11. Current northern spotted owl (NSO) nesting/roosting and foraging habitat by activity center (AC).

AC #10 AC Name

N/R11 habitat 

within 0.5 miles of 

AC

F12 habitat within 

0.5 miles of AC

N/R habitat within 

1.3 miles of AC

F habitat within 1.3 

miles of AC

290 Slide Creek 209 147 1,307 850

237 Anada Creek 212 135 1,300 1,146

347 Jonathan Creek 85 150 1,005 905

251 Littlefield Creek 168 199 771 1,127

239 Long Glade 206 69 720 861

236* South Fork 42 118 428 772

387 Maple Flat 115 192 749 1,368

252 Ruth Airport 179 217 774 1,489

Although the ACs listed above are deficit in nesting/roosting and/or foraging habitat at 0.5 miles and/or 

1.3 miles, two ACs have been severely impacted by fire. Both AC 236 and AC 347 have been greatly 

impacted by fire, AC 236 by the Journey Fire in 2015 and AC 347 by the Ruth Fire in 2011. Both of these 

owl sites are now deficit because of the impacts of those fires.

Nineteen (19) of the 20 landings occur within four (4) ACs. No landings within the ACs fall within 

nesting/roosting habitat. All new landing construction would occur within the outer 1.3-mile radius of the 

affected ACs. Twelve (12) out of the 20 ACs fall within low-quality foraging habitat. The maximum 

amount of foraging habitat that would be removed in any one AC is 1 acre, with a maximum of 0.25 acre 

in any one area. The loss of habitat in any one area would be negligible and would resemble natural 

assemblages and small forest openings.

The total treatments within any one AC would vary from 0 to 19 percent of the available nesting/roosting 

habitat within 0.5 miles and 1 percent to 11 percent within 1.3 miles of the center (treatment acres/

percentages within 1.3 miles include the acres within 0.5 miles; Table 12. No nesting/roosting habitat 

would be lost due to new landing construction.

No AC would have thinning or fuelbreak treatments over 19 percent of the nesting/roosting habitat within 

any one AC. Thinning may modify nesting/roosting habitat but would maintain current habitat function 

immediately post-project. The project is expected to have beneficial effects by accelerating the 

 10 Activity Centers (ACs) 347 and AC 236 have both been burned by high severity fires, which is why those numbers show 

severe deficit within the 0.5-mile core. Activity Center 347 is within the Ruth Fire scar and AC 236 is within the Journey Fire. 11 N/R = nesting/roosting. 12 F = foraging.
Chapter 3. Environmental Consequences

80 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

development of forest structure to mature conditions more quickly than if left untreated, as well as 

reducing the risk of stand-replacing wild fire.

The total treatments within any one AC would vary from 0 to 25 percent of the available foraging habitat 

within 0.5 mile and 0.4 to 13 percent within 1.3 miles of the AC (treatment acres/percentages within 1.3 

miles include the acres within 0.5 miles). Only small amounts of foraging habitat would be lost due to 

new landing construction. A total of 3 acres foraging habitat removed within the action area, 1-acre 

maximum in any one AC. This loss would be negligible in any one given area and would resemble small 

forest openings after the roads and landings have been decommissioned.

No AC would have thinning or fuelbreak treatments over 25 percent of the foraging habitat within any 

one AC. Thinning may modify foraging habitat but would maintain current habitat function immediately 

post-project. The project is expected to have beneficial effects by accelerating the development of forest 

structure to mature conditions more quickly than if left untreated, as well as reducing the risk of standreplacing wildfire.

Table 12. Proposed treatments by activity center (AC).

Activity

Centers

Habitat 

Type

Thin from 

Below

Hazardous 

Fuels 

Reduction

Landing 

Construction

Total 

Treatment 

Acres

Percent 

Total 

Treatment

Total 

Treatment 

Acres

% Total 

treatment

0.5 mi 

acres

1.3 mi 

acres

0.5 mi 

acres

1.3 mi 

acres

0.5 mi 

acres

1.3 mi 

acres 0.5 mi acres 0.5 mi 1.3 mi acres 1.3 mi

290 NR 48 49 3.8

F 12 82 1 12 8 83 10

NON 1 1

237 NR 12 64 17 12 6 81 6

F 30 148 10 0.75 30 22 158.75 14

NON 9 31 30 0.75 9 61.75

347 NR 42 13 19 15 18 63 6

F 73 38 22 0.25 38 25 95.25 11

NON 9 25

251 NR 25 52 7 19 32 19 71 10

F 11 11 3 30 14 7 41 4

NON 16 44 16 44

239 NR 3 24 1 3 4 2 27 4

F 12 23 35 4

NON 7 25 7 25

236 NR 11 12 3

F 12 0.25 12.25 2

NON

387 NR 9 6 15 2

F 10 18 28 2

NON 10 10

252 NR 3 3 1

F 11 11 1

NON
Chapter 3. Environmental Consequences

Final Environmental Assessment – 81

All treated habitat would remain functional immediately post project. In addition, treatment of capable but 

currently unsuitable stands within the ACs would improve habitat conditions for the owls.

Northern Spotted Owl Critical Habitat

Direct and Indirect Effects: Approximately 28,413 acres of the action area occur within the Unit 11, 

ICCS 1 and 2 of the Critical Habitat Rule. There are 16 units to be treated for hazardous fuel reduction 

(215 acres), four (4) units to be oak woodland restoration (37 acres), eight (8) units of plantation thins 

(108 acres) and 61 units (461 acres) of fuelbreak construction that would occur in NSO CHU. A total of 

786 acres of NSO nesting/roosting/foraging/dispersal habitat and 37 acres non-habitat would be treated 

between the two subunits of CHU. In ICCS 1, fuelbreak construction would occur in 39 acres of lowquality foraging habitat. In ICCS 2, hazardous fuel reduction would occur in 54 acres of low-quality 

nesting/roosting habitat, eight (8) acres of moderate-quality nesting/roosting habitat, 64 acres of 

moderate-quality foraging habitat, and 87 acres of low-quality foraging habitat. Plantation thins would 

occur on 108 acres of dispersal-only habitat. Fuelbreak construction would occur in approximately 88 

acres of moderate-quality nesting/roosting habitat, 140 acres of low-quality nesting/roosting habitat, 101 

acres of moderate-quality foraging habitat, and 95 acres of low-quality foraging habitat would be 

modified, but would maintain current habitat function within NSO CHU.

Approximately, 290 acres (2%) of PCE 2, 386 acres (4%) of PCE 3, and 108 acres (2%) of PCE 4 will be 

treated of the 28,413 acres of NSO CHU within the Action Area. The 1st 48 Project would leave 98 

percent of PCE 2, 96 percent of PCE 3, and 98 percent of PCE 4 untreated within CHU. The project will 

maintain all habitat and will be suitable directly after treatment.

All Primary Constituent Elements (PCE) occur in concert with PCE 1, which is coniferous forest types 

that support the NSO:

o Nesting/Roosting Habitat (PCE 2): Suitable nesting/roosting NSO habitat, as defined by the 

Forest Service, is composed of mature timbered stands having multi-layered conditions, a canopy 

closure of 60 percent or greater, and obvious decadence (i.e., large, live coniferous trees with 

deformities such as cavities, broken tops, and dwarf-mistletoe infections). Overstory should be 

comprised of conifer trees 21 inches or greater dbh and at least 40 percent of the total canopy 

closure. The forest’s local definition of nesting/roosting habitat also includes stands with 

overstory canopy closure of at least 40 percent because these stands typically have a hardwood 

understory which increases total canopy closure to 60 percent or greater.

Potential treatment units were selected by a silviculturist from a vegetative database and then 

field verified as to density and stand structure. Field verification was completed by the 

silviculturist and wildlife biologist. All stands classified as late mature or old growth were 

excluded from treatment. Mid-mature stands with pre-dominant trees were ground verified as to 

whether they contained stand structure characteristics that would be classified as high-quality 

nesting/roosting habitat.

All high-quality nesting/roosting habitat stands (mid-mature stands with mature forest 

characteristics and all mature and old growth) were dropped from treatment.

Of the 28,413 acres of CHU within the action area, 13,686 acres are suitable nesting/roosting 

habitat (PCE 2). Approximately 290 acres (2%) of PCE 2 is proposed for fuels reduction 

treatments. The treatments would maintain all components of PCE 2.

There would be no removal of PCE 2 due to thinning or fuels reduction activities.
Chapter 3. Environmental Consequences

82 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Thin from below is a silvicultural method that involves removal of trees from lower canopy 

positions (overtopped, intermediate, and sometimes co-dominant), retaining the largest and most 

vigorous trees with the best-developed crowns. This type of thinning closely mimics the natural 

course of stand development as it eliminates the trees least likely to grow into the dominant or codominant crown classes. Thinning reduces the stand density of trees to improve growth and yield, 

enhance stand health, and reduce potential tree mortality. Thin from below while maintaining a 

minimum of 60 percent or greater canopy cover is the best management prescription to maintain 

and recruit the habitat variables critical to nesting/roosting habitat (e.g., large old trees and codominant and intermediate conifers with crown space in the canopy for crown development) while 

at the same time improving forest health and reducing risk to wildfire and insects and disease.

Fuel reduction treatments are designed to reduce ground fuels and the lower understory 

vegetation that create ladders for fire to climb into the canopy. Treatments are limited to pruning 

lower branches of larger trees and removal of brush and small diameter trees 8 inches in diameter 

or less. No pre-dominant or dominant trees would be removed, canopy closure would be 

maintained at 60 percent or greater, and snags and downed logs (20-inch dbh or greater) would be 

maintained unless they pose a safety hazard. The habitat would remain suitable post-project.

Fuel treatments are designed to reduce the risk of fire disturbance on a large scale. Although 

multi-layered conditions contributing to PCE 2 would be reduced by removing brush and 

understory trees within 150 feet of a road, treatments would result in a greater assurance of longterm maintenance of existing late-successional habitat within the action area. Fuel treatments in 

strategic areas along high-use roads would reduce the risk of fire ignitions along high use roads 

and provide greater protection to adjacent late-successional habitat. This would protect and 

enhance owl critical habitat in the end.

Fuelbreak construction would modify 228 acres of low to moderate quality PCE 2 and 62 acres of

low- to moderate-quality PCE 2 will be treated through HFR; however, the habitat would be 

maintained as nesting/ roosting habitat post-project. No PCEs would be removed through 

thinning or fuels treatments except for negligible amounts for landing construction.

Fuels reduction activities may modify suitable NSO nesting/roosting habitat PCE; however, the 

habitat would remain suitable post project. Even though the treatment areas would remain 

suitable immediately post-treatment, 13,365 acres (98%) of PCE 2 in the action area would 

remain untreated in this project.

o Foraging Habitat (PCE 3): The Critical Habitat Rule describes foraging habitat in the Klamath 

and Northern California Interior Coast Ranges Zone as having “very vegetative diversity” and 

that foraging-only habitat “for this zone showed greater divergence from nesting habitat, with 

much lower canopy cover and tree size.” The Rule states that “habitats used for foraging northern 

spotted owls are much more variable than in northern portions of the species’ range” and that 

“northern spotted owls would forage in younger stands and brushy openings with high prey 

densities and access to prey (Carey et al. 1992, Rosenberg and Anthony 1992, Thome et al. 1999,

Irwin et al. 2012). Throughout much of the owl’s range, the same habitat that provides for nesting 

and roosting also provides for foraging, although northern spotted owls have greater flexibility in 

utilizing a variety of habitats for foraging than they do for nesting and roosting.”

Foraging habitat often has attributes similar to that of nesting/ roosting habitat, but such habitat 

lacks specific nesting structures necessary to support successfully nesting pairs. It is often the 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 83

younger stands that provide habitat for those early and mid-successional associated prey species 

that nesting/roosting habitat do not offer. Foraging habitat is identified in the SRNF vegetation 

GIS layer, which uses the 11-inch dbh/40 percent canopy closure of the California Wildlife 

Habitat Relationship (CWHR) classification to define the lower end of this habitat type. Due to 

this, many acres of conifer-dominated stands are shown here as foraging habitat rather than as 

dispersal habitat.

Of the 8,648 acres of potential PCE 3 within critical habitat in the action area, approximately 383 

acres of foraging PCE would be treated either through shaded fuelbreak construction (232 acres) 

or through fuels reduction treatments (151 acres). An additional 3 acres will be removed for 

landings (12 landings total). The treatments would maintain all components of foraging habitat. 

No PCE 3 will be removed except on the 3 acres for landing construction, which will resemble 

small forest openings. No more than 0.25 acres would be removed in any one area. These 

thinning treatments would accelerate the development of late-successional characteristics that 

favor NSOs and protect existing suitable habitat The loss of PCE in any one area would be 

negligible. All associated landings would be decommissioned after project activities are complete.

The stands within foraging habitat proposed for treatment are even-aged and lack the horizontal 

and vertical diversity components associated with late-mature stands. These young stands have 

the potential to achieve rapid diameter and height growth with commercial thinning. Silvicultural 

prescriptions would ensure retention of existing stand structure, species composition, snags, and 

downed logs. Treatment would maintain functional habitat conditions within all currently suitable 

foraging, and is expected to improve conditions within the stands treated in the long term.

Thinning would have a positive impact to NSO foraging PCE since growth would be accelerated 

resulting in multi-layered, older seral stages earlier than if left unthinned. Reducing tree density 

within foraging habitat would improve forest health and a reduced risk from fire. Existing 

structural conditions would be maintained in order to support prey occurrence and abundance 

while allowing for rapid development of replacement habitat. Replacement habitat could develop

into nesting/roosting habitat over time. Some stands would be immediately improved upon 

completion of the treatment by allowing increased access to prey by the owl in the dense stands 

formerly refugia for the wood rat.

Jackpot burning may be used within the fuelbreaks and the fuels reduction treatment units 

including the 383 acres of foraging habitat. The primary objective of jackpot burning is to reduce 

ground fuels within fuelbreaks. Because of its low intensity, the burn is not uniform in nature 

creating a mosaic pattern within the stand. Effects of jackpot burning would be limited because of 

this patchiness leaving interspaces of unburned forest floor. Foraging habitat would be modified as 

some understory shrubs and some small saplings would be killed and some smaller downed logs 

would be consumed from the burning in portions of the stand; however, current habitat function 

would be maintained. The results would be a more complex understory and forest floor that would 

benefit key prey species for the spotted owl such as the dusky-footed woodrat, while breaking up 

the continuity of the fuels in the understory to reduce flame length and spread of wildfire.

Burning would occur under specific weather and moisture conditions designed to minimize 

damage to the residual stand, maintain large woody debris and maintain about 50 percent of the 

duff layer. Burning could reduce prey species temporarily in the immediate area, but is expected 

to be a short-term effect.
Chapter 3. Environmental Consequences

84 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Dead and down material are usually of large enough diameters that the logs are not burned 

completely and continue to provide key habitat features, such as refugia and escape cover. In 

some areas, fuel treatments may be beneficial to the NSO in potential foraging habitat in CHU by 

opening thick sub-canopy vegetation, allowing increased access to prey. In addition, owls are 

known to forage within the burned areas once the understory vegetation begins to grow again.

Fuel corridors would be created along major roads, mainly along ridge tops, to create a defensible 

space and safe access to assist in firefighting efforts and to protect existing nesting/roosting/foraging 

habitat from human-caused fires. Fuel reduction treatments are designed to reduce ground fuels and 

the lower understory vegetation that create ladders for fire to climb into the canopy. Although multilayered conditions contributing to foraging habitat would be slightly reduced by removing brush 

and understory trees treatments would result in a greater assurance of long-term maintenance of 

suitable foraging and foraging PCE within the planning area.

The project would modify approximately 383 acres (plus an additional 3 acres removed for 

landings) of low- to moderate-quality foraging habitat PCE in fuels and thinning; however the 

habitat would be maintained as foraging habitat immediately post project.

Removal of PCE 3 for new landing construction would be minimal in any one area (0.25 acres or 

less). No PCEs would be removed through thinning or fuels treatments. The project design would 

ensure retention of existing stand structure, species composition, snags, and downed logs. Canopy 

closure would be reduced in the short term, but would be maintained at a minimum of 60 percent 

closure. Foraging habitat function would be maintained immediately post-project. Treatment 

would maintain functional PCE conditions within all currently suitable foraging habitats and is 

expected to improve conditions within the stands treated in the long term. These treatments would 

accelerate the development of late-successional characteristics that favor NSOs.

o Dispersal Habitat (PCE 4): The survivorship of NSOs is likely greatest when dispersal habitat 

most closely resembles nesting, roosting, and foraging habitat, but owls may use other types of 

habitat for dispersal on a short-term basis. Dispersal habitat, at a minimum, consists of stands 

with adequate tree size and canopy cover to provide protection from avian predators and at least 

minimal foraging opportunities. The minimum requirement for dispersal-only habitat is forests 

composed of at least 50 percent of trees with 11-inch dbh or greater and a minimum 40 percent 

canopy cover. Although NSO use nesting/roosting/foraging habitat as dispersal habitat, here we 

define dispersal-only as conifer forest types that fall below the definition of foraging but still 

meet the criteria for dispersal.

Of the 6,505 acres of dispersal-only habitat within the project action area, approximately 108

acres would be treated (2% of the dispersal-only habitat in the action area). These units are very

low-quality dispersal habitat because they are densely stocked with little space for an owl to fly 

through. Thinning would reduce stand density; however, post-treatment canopy cover would be 

maintained at 60 percent or greater. These stands would be immediately improved as posttreatment dispersal habitat.

Even though all treatment areas would maintain their current habitat function and maintain a 

minimum of 60 percent canopy closure, approximately 98 percent of the dispersal-only habitat in 

the action area would not have any treatment. Since the NSO use nesting/roosting/ foraging 

habitat for dispersal as well, of the 28,839 acres of nesting/roosting/foraging/ dispersal habitat in 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 85

the action area approximately 99 percent of habitat suitable for dispersal would be left untreated 

in the action area.

o ICCS 1 and 2: Approximately 195,097 acres of Unit 11, ICCS 1 and 2 occurs on the SRNF with 

179,758 acres on the Mad River RD and 17,885 acres within the 1st 48 Project action area.

Noise and Smoke: Noise and smoke-generating activities that occur within or adjacent to suitable NSO 

habitat has the potential to disturb nesting owls. To avoid disturbance, design features and limited operating 

periods (LOPs) would be implemented as described in the PDFs. The LOP from February 1 through July 

31 within 0.25 miles of known ACs would avoid impacts the NSO during the breeding season.

Direct Injury or Death: The 1st 48 Project area has eight (8) historic ACs identified. No treatments would 

occur within the 100-plus-acre nest groves established around each known AC and no activities would 

occur in high-quality nesting/roosting habitat anywhere in the project area. Surveys to the most current, 

USFWS approved-protocol have been conducted throughout the project area. Limited operating periods 

have been established for all activities within 0.25 miles of each AC. Updated surveys would be 

maintained throughout the life of the project or additional LOPs would be implemented on activities within 

0.25 miles of nesting/roosting habitat without up-to-date surveys. If no surveys are conducted, then a 

September 15 LOP would be used for either occupied (breeding pair) or unsurveyed nesting/roosting 

habitat. There is a low likelihood that direct injury or death could occur to an individual NSO during the 

implementation of the management activities.

The forest conducted informal consultation on the 1st 48 Project with the USFWS. The informal 

consultation process on the SRNF is conducted under the Level 1 Consultation process. The Level 1 

process requires biologists from the US Forest Service and the USFWS to work together to identify 

potential impacts to listed species and, where possible, to propose mitigation measures that would 

minimize impacts to those species. The Forest Service has worked extensively with the USFWS to ensure 

that the 1st 48 Project was designed to protect listed species and their critical habitat.

The Six Rivers’ Level 1 Team determined that the 1st 48 Project may affect but is not likely to adversely 

affect the NSO, and it may affect but is not likely to adversely affect NSO critical habitat. The Level 1 

Team determined that the proposed prescriptions would improve conditions within the treated areas and 

would be beneficial to the NSO.

Forest Service Sensitive Species

No Action Alternative

Under the No Action Alternative, no thinning, shaded fuelbreak construction, or fuel treatments would 

occur. The No Action Alternative would not change the current conditions. No suitable habitat for any 

Forest Service Sensitive species would be degraded through thinning or shaded fuelbreak construction. 

However, the No Action Alternative would not accelerate development of late-successional conditions in 

younger stands throughout the project area. The No Action Alternative would also not reduce the fuels 

build-up in the project area or protect existing late successional habitat.

Proposed Action Alternative

Direct and Indirect Effects

All Forest Service Sensitive wildlife species known or thought to occur in the project area (based on 

habitat and range), were evaluated for this project. It was determined that the project would have no 

impact on certain Forest Service Sensitive species, based on either the lack of habitat, lack of detections 
Chapter 3. Environmental Consequences

86 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

during surveys, or the fact that habitat would not be impacted. Species that would not be affected by this 

project include the bald eagle (Haliaeetus leucocephalus), Townsend’s big-eared bat (Corynorthinus 

townsendii), fringed myotis (Myotis thysanodes), California wolverine (Gulo gulo luteus), Humboldt 

marten (Martes caurina), pallid bat (Antrozous pallidus), western bumblebee (Bombus occidentalis), 

western pond turtle (Clemmys marmorata), southern torrent salamander (Rhyacotriton variegatus), and 

northern red-legged frog (Rana aurora aurora). The following environmental consequences section 

focuses on those Forest Service Sensitive species and/or habitat that may be impacted by this project.

Pacific Fisher (Martes pennanti pacifica, also a Federal Candidate Species)

In northern California, fishers occupy mid-elevation, multi-storied mature and old growth conifer, mixed 

conifer and mixed-conifer hardwood forests with contiguous canopy cover. Closed canopies (>50%) are 

typically selected but fishers would use areas of low to moderate canopy cover (25 to 40%) if there is 

sufficient understory (Lofroth et al. 2010). They do not occur in high-elevation alpine or subalpine habitats.

Foraging habitat varies with primary prey species. Since fishers in California prey primarily on small to 

medium-sized mammals (woodrats, squirrels, etc.), they would use forests with hardwood components 

which provide mast for prey, structurally complex structures near the forest floor (brushy understories) 

and high abundance of downed, woody debris (Lofroth et al. 2010).

Rest sites are strongly associated with moderate to dense forest canopy and elements of late-successional 

forests (Lofroth et al. 2010). Rest sites in northern California typically have greater than 50 percent canopy 

cover and an average dbh of 30 to 45 inches for the five (5) largest trees in the immediate area. These areas 

would often have a higher density of snags and large downed wood. Due to high temperatures, rest sites in 

this region often occur in the bottom of drainages or within 100 meters of water. Cavities, mistletoe 

blooms, branch deformities and platforms in live trees and snags (conifers and hardwoods) are used for rest 

sites as well as logs, rock areas, brush piles and concentrations of downed woody debris.

Cavities in live trees and snags are critical for reproduction. Females use cavities in a variety of tree 

species (e.g., Douglas-fir, Ponderosa pine, black oak, etc.), but live hardwoods appear to be particularly 

important in northern California. Most cavities used as natal and weaning dens are formed from 

heartwood decay and are in large (average 36-inch dbh) trees and snags. These trees are often much older 

than those available with Douglas-fir averaging 177 years (Lofroth et al. 2010).

Thompson et al. (2007) determined that based on data from a 1994 to 1995 soot track plate study, a 1996 

to 1997 telemetry study, and a 2002 to 2003 mark-site study, fishers appear to be abundant and well 

distributed across “the managed forests of extreme northwest California”. An exact population estimate 

and distribution for the Forest are still unknown.

Systematic surveys across the forest in 1999 (Carroll et al 1999) show the highest probability of detections 

centered on the Trinity River, with detection probability decreasing the farther north and south you go.

Surveys were conducted in the 1st 48 Project area in 2016 using camera stations. Fisher were detected in 

three areas. No dens sites have been found.

Direct and Indirect Effects

Characteristics for denning would be maintained and the stands would still function as denning habitat 

immediately post-project. All riparian reserves would be buffered on both sides of stream channels (nonfish bearing buffers are 160 feet, fish-bearing buffers are 320 feet or two site potential tree heights), 

unless intersecting with road networks. In the case of Littlefield Creek, the no-cut buffer (“inner riparian 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 87

reserves”) south of the stream would extend to the edge of the road, which is less than 160 feet in many 

areas, but this buffer is still considered adequate to prevent impacts to the stream because the area is so 

flat. Canopy closure in the outer riparian reserve buffers would be maintained at 60 percent or greater.

No tree removal is permitted within the inner riparian reserve buffers. Exceptions include hand-cut trees less 

than 6-inch dbh within 25 feet where riparian reserves intersect roads. Thinning and release work within 

riparian reserves would be accomplished with small gas powered hand tools (e.g., chainsaws, brush cutters). 

Ignition may occur within riparian reserves only when necessary to minimize prescribed fire behavior 

intensity and/or the potential for burning material to roll down into a riparian reserve. No fire line (scraped 

to mineral soil) would be constructed within riparian reserves; however, a hand-cut brush-only control line 

would be allowed for holding purposes on prescribed fires. Hand piling and pile burning may only occur 

within a riparian reserve if the hand piles are 6 feet or less in diameter, and less than 6 feet in height.

Little to no true riparian habitat exists within the units given the lack of riparian vegetation associated 

ephemeral and intermittent stream courses within the project area. However, in the long-term project 

implementation has the potential to improve riparian habitat conditions through the release of conifer and 

hardwoods/shrubs from thinning, generating a secondary canopy. The project would maintain high levels 

of coniferous canopy closure within the project area adjacent to riparian reserves. Project activities would 

not occur within riparian habitat. Implementation of the project would maintain and improve riparian 

habitat conditions.

Of the 13,686 acres of fisher denning habitat within the action area, approximately 290 acres of low and 

moderate-quality denning habitat would be treated. No high-quality habitat would be treated. The amount 

of fisher denning habitat within the action area proposed for treatment would be approximately 2 percent 

(98% of the denning habitat in the action area would not receive any treatment).

Strategically located fuelbreaks would reduce the risk of human-caused fire ignitions along high-use 

County roads and provide greater protection to existing late-successional habitat in the 1st 48 Project area. 

Fuel reduction treatments are designed to protect existing habitat characteristics while reducing ground 

and ladder fuels and creating a defensible space to be used in defense of wildfires. No dominant or codominant trees would be removed, canopy would be maintained at 60 percent or greater, and large snags 

and downed wood would be maintained at the 80 to 100 percent level. The habitat would remain suitable 

immediately post project.

Noise and Smoke: Noise and smoke-generating activities that occur within or adjacent to occupied fisher 

denning habitat has the potential to disturb fisher. Surveys were conducted in the 1st 48 Project area in 

2016 using camera stations. Fisher were detected in three areas. Although no den sites have been located, 

LOPs have been imposed for all noise and smoke generating activities within 0.25 miles of fisher suitable 

habitat around the detection sites.

The project may impact individual fisher but would not cause a trend towards listing.

Northern Goshawk (Accipiter gentilis)

Goshawks are known to use mature forest habitats for nesting and foraging. Nesting stands are typically 

in dense pockets of large trees, often on north-facing, bench slopes near water. Foraging habitats are often 

more open to allow for the aerial ambush foraging strategy of the goshawk.
Chapter 3. Environmental Consequences

88 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Goshawks occupy similar habitat to that of the NSO. There are approximately 13,686 acres of suitable 

goshawk habitat in the 1st 48 Project area. Surveys were conducted in the 1st 48 Project area in 2017. No 

goshawks were detected.

Direct and Indirect Effects

Suitable habitat for the goshawk occurs in the planning area. No pre-dominant trees (potential nest trees) 

or dominant trees would be removed. Current canopy closure would be maintained. Removal of 

understory vegetation may improve foraging conditions for the goshawk. If nesting goshawks were 

subsequently found within 0.25 miles of any treatment units, LOPs would be imposed. The project may 

impact individual northern goshawk but would not cause a trend towards listing.

Foothill Yellow-Legged Frog (Rana boylii)

The foothill yellow-legged frog is found in or near rocky streams or rivers in a variety of habitats. In 

California, breeding and egg laying usually wait until the end of spring flooding, and may commence 

anytime from mid-March to mid-June, depending on the occurrence of spring rains. Foothill yellowlegged frogs are diurnal with adults often basking on exposed rock surfaces near streams. When 

disturbed, they dive into the water and take refuge under submerged rocks or sediments.

Direct and Indirect Effects

Suitable habitat for foothill yellow-legged occurs in the planning area. In August 2017, tadpoles and adult 

frogs were observed in Littlefield Creek at the low water crossing on at milepost 0.4 on FSR 2S53 (K. 

Kenfield personal observation). If water is not present during operations, commercial log hauling may 

proceed. If water is present, a temporary low water crossing would be required. Currently noncommercial 

vehicles drive through the low water ford. Installation of the temporary vented ford (two (2) or more 36-

inch pipes laid over geotextile cloth on the streambed with fill on top) would cause disturbance to an 

approximate 30-foot by 10-foot reach of stream. The installation of the vented ford would eliminate 

vehicles entering the water while it is installed. The project may impact individuals but would not cause a 

trend towards listing.

Management Indicator Species and Migratory Bird Species

Direct, indirect and cumulative effects to MIS and MBS are disclosed in the MIS and MBS reports (Smith 

2017) located in the project file with the results are summarized here. Management indicator species and 

MBS were addressed based on their potential to occur within the project area based on habitat suitability, 

survey results, or incidental sighting records. Habitat suitability evaluations were made using the 

California Wildlife Habitat Relationships System, Version 8.0 software, developed by the California 

Department of Fish and Game. In addition, habitat evaluations were made utilizing SRNF Wildlife 

Sighting Database, SRNF Vegetation Layer, field reviews, and forest GIS vegetation layers.

No Action Alternative

Under the No Action Alternative, no thinning, shaded fuelbreak construction, or fuel treatments would 

occur. The No Action Alternative would not change the current conditions. No suitable habitat for any 

MIS or MBS species would be degraded through thinning or shaded fuelbreak construction. However, the 

No Action Alternative would not accelerate development of late-successional conditions in younger 

stands throughout the project area. The No Action Alternative would also not reduce the fuels build-up in 

the project area or protect existing late successional habitat.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 89

Proposed Action Alternative

Management Indicator Species

Under the National Forest Management Act (NFMA), the Forest Service is directed to “provide for diversity 

of plant and animal communities based on the suitability and capability of the specific land area in order to 

meet overall multiple-use objectives” (PL 94-588 §6 (g)(3)(B)). The 1982 regulations implementing NFMA 

require that “Fish and wildlife habitat shall be managed to maintain viable populations of existing native and 

desired non-native vertebrate species in the planning area.” (36 CFR 219.19) Management indicator species 

is a concept used by the agency to serve as a barometer for species viability at the forest level. Population 

changes of MIS are believed to indicate the effects of management activities.

The SRNF LRMP uses MIS to assess potential effects of project activities on the various habitats and 

habitat assemblages with which these species are associated. Forty-one (41) fish and wildlife species have 

been selected as MIS or assemblages for a variety of habitats that are potentially affected by resource 

management activities on the Forest (LRMP IV-97).

The potential impacts to MIS were analyzed and the results are summarized here. The full report is

located in the project file.

Seral stages in the project area range from shrub to mid-mature stands with small patches of late-mature 

and old growth. The project is designed to improve habitat conditions through the acceleration of latesuccessional habitat characteristics, while still maintaining current functional habitat. Canopy closure 

would be maintained in late-successional habitats, vegetation species diversity and composition would be 

maintained, and retention of snags and downed logs would be retained at 80 to 100 percent of the average 

numbers found within mature and old growth stands within the Forest.

This project would treat a total of 142 acres of early seral stage habitat due to fuelbreak construction and 

thinning in early seral stands (shrub through early mature). For species that utilize early seral habitat 

(such as the lazuli bunting), this represents 3 percent of the early seral stage habitat in the project area.

Shaded fuelbreak construction would occur in late-successional habitat along the main roads. Fuel 

treatments would occur in approximately 290 acres that are considered suitable for late successional 

associated species. Fuel treatments would degrade approximately 2 percent of the suitable habitat for 

these species available in the project area. The shaded fuelbreak would be approximately 150-feet wide 

on either side of the road. No pre-dominant or dominant trees would be removed. All exiting snags and 

downed wood would be retained, unless the former poses a safety hazard. There would be minor habitat 

degradation for understory species such as the Pacific wren and ruffed grouse within the project areas 

through the removal of brush and understory trees; however, in the long term, reduction of fuel ladders in 

these areas would improve adjacent habitat areas resilience to fire disturbance. Overstory canopy closure 

would be maintained at 60 percent or greater, ground disturbance would be limited to existing roads and 

skid trails, vegetation species diversity and composition would be maintained, and retention of snags and 

downed logs would be retained at 80 to 100 percent of the average numbers found within mature and old 

growth stands within the forest.

All riparian reserves would be buffered on both sides of stream channels (non-fish bearing buffers are 160 

feet, fish-bearing buffers are 320 feet or two site potential tree heights), unless intersecting with road 

networks. In the case of Littlefield Creek, the no-cut buffer (“inner riparian reserves”) south of the stream 

would extend to the edge of the road, which is less than 160 feet in many areas, but this buffer is still 
Chapter 3. Environmental Consequences

90 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

considered adequate to prevent impacts to the stream because the area is so flat. Canopy closure in the 

outer riparian reserve buffers would be maintained at 60 percent or greater.

The crossing of Littlefield Creek by FSR 2S02 is thought to be perennial due to increased flow from the 

Ruth Fire (from reduced transpiration due to canopy removal). Resident rainbow trout and foothill yellow 

legged frog are found in the stream at the crossing. If the stream is flowing at the time needed for 

commercial haul, a temporary pipe array will be installed consisting of two or more culverts, geotextile 

fabric, and clean gravel (i.e., no fine sediments). Installation of the temporary vented ford (two or more 

36-inch pipes laid over geotextile cloth on the streambed with fill on top) would cause disturbance to an 

approximate 30 foot by 10 feet reach of stream. The installation of the vented ford would eliminate 

vehicles entering the water while it is installed.

No tree removal is permitted within the inner riparian reserve buffers. Exceptions include hand-cut trees 

less than 6-inch dbh within 25 feet where riparian reserves intersect roads. Thinning and release work 

within riparian reserves would be accomplished with small gas powered hand tools (e.g., chainsaws, 

brush cutters). Ignition may occur within riparian reserves only when necessary to minimize prescribed 

fire behavior intensity and/or the potential for burning material to roll down into a riparian reserve. No 

fire line (scraped to mineral soil) would be constructed within riparian reserves; however, a hand-cut 

brush-only control line would be allowed for holding purposes on prescribed fires. Hand piling and pile 

burning may only occur within a riparian reserve if the hand piles are 6 feet or less in diameter, and less 

than 6 feet in height.

Little to no true riparian habitat exists within the units given the lack of riparian vegetation associated 

ephemeral and intermittent stream courses within the project area. However, in the long term, project 

implementation has the potential to improve riparian habitat conditions through the release of conifer and 

hardwoods/shrubs from thinning, generating a secondary canopy. The project would maintain high levels 

of coniferous canopy closure within the project area adjacent to riparian reserves. Project activities would 

not occur within riparian habitat. Implementation of the project would maintain and improve riparian 

habitat conditions.

Jackpot burning may also cause short-term habitat degradation through the loss of small woody debris; 

however, burning would occur under specific weather and moisture condition designed to minimize 

damage to the residual stand, maintain large woody debris, and maintain at least 50 percent of the duff 

layer. Some minor local increases in fuels may occur from project-generated slash, but due to proposed 

post-harvest fuel treatments, fuel loading would not be a threat to the treated areas. In the long term, 

reduction of fuel ladders would improve stand resilience to fire disturbance.

Jackpot burning the special habitat areas (oak woodlands) would reduce encroachment and protect the 

habitat in the long term. Management indicator species such as the black-tailed deer would benefit from 

burning these areas.

The 1st 48 Project would not adversely impact MIS. Although shaded fuelbreak construction would 

degrade habitat for species such as the Pacific wren and ruffed grouse, the majority of the project would 

improve/restore habitat conditions for all MIS by thinning young, homogenous stands, accelerating the 

development of multi-storied conditions and other late successional habitat characteristics. In addition, 

development of strategic fuelbreaks would help protect existing habitat from stand replacing fire.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 91

Migratory Bird Species

The potential impacts to MBS were analyzed and the results are summarized here. The full report is located 

in the project file. The project would not adversely impact migratory species or their associated habitats.

Project design standards would minimize potential impacts to migratory species. The project is designed 

to improve habitat conditions through the acceleration of late-successional habitat characteristics, while 

still maintaining current functional habitat. Although there would be minor habitat degradation for 

understory species through the removal of brush and understory trees, in the long term the reduction of 

fuel ladders in these areas would improve adjacent habitat areas resilience to fire disturbance. Overstory 

canopy closure would be maintained at 60 percent or greater, ground disturbance would be limited to 

existing roads and skid trails, vegetation species diversity and composition would be maintained, and 

retention of snags and downed logs would be retained at 80 to 100 percent of the average numbers found 

within mature and old growth stands within the Forest.

Survey and Manage Wildlife Species

No wildlife S&M species occur within the 1st 48 Project; therefore, no pre-project surveys are required. 

This project is in compliance with the Record of Decision for amendments to the survey and manage, 

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

Land Management planning documents within the range of the northern spotted owl (USDA and USDI 

2001), the April 25, 2013 9th Circuit Court Order in Conservation Northwest (and others) v. Sherman 

(No. 11-35729), and the February 18, 2014 District Court Order in Conservation Northwest (and others)

v. Robert Bonnie (and others) (W. WA No. C08-1067-JCC).

Cumulative Effects to TES, MIS, MBS, and other Wildlife Species

Regarding all the past impacts from land uses (i.e., mining, timber harvest, and road constructions), the 1st

48 Project would facilitate restoration by thinning plantations and young natural stands. The beneficial 

cumulative effects include the reduction of habitat fragmentation and the development of late-seral 

conditions.

Timber Harvest

Timber harvest activities and the suppression of wildfire in Mad River RD have led to changes in seral 

stages and increases in fuels. This shift in seral stage distribution is highest in the tanoak and Douglas-fir 

series, due to harvest of commercially valuable old growth Douglas-fir stands that began in the late 1950s. 

There has been a reduction in old-growth forests and an increase in shrub, pole, and early mature forests.

Currently three (3) timber sales occur within the UMRW on the Mad River RD: Little Doe/Little Gulch, 

Kelsey Peak and Beaverslide. The action area for Beaverslide overlaps with the 1st 48 Project, but no 

treatments overlap or occur within any AC associated with the 1st 48 Project. The Shasta Trinity Salvage 

Project also overlaps with the 1st 48 Project, but no treatments overlap or occur within any affected AC. 

Therefore, these projects would not be discussed any further.

The action areas for the 1st 48 and Kelsey Peak projects overlap. No timber sale units for Kelsey Peak are 

within the overlap; however, 638 acres of the Kelsey Peak fuels corridor overlaps into the 1st 48 Project. 

This fuels corridor connects directly into the 1st 48 Project shaded fuelbreak creating an extended 

fuelbreak near the town of Ruth.

The Kelsey Peak Project has proposed treatments in 414 acres and 2,175 acres of nesting/roosting and 

foraging respectively. This equates to 3 percent nesting/roosting habitat being treated and 10 percent 

foraging habitat combined for the two projects being treated within the UMRW. All acres of these 
Chapter 3. Environmental Consequences

92 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

treatments would maintain its current habitat function except for a negligible amount removed for 

landings that resemble small forest openings and would be decommissioned post-project. This leaves 97 

percent and 90 percent of the available nesting/roosting and foraging habitat untreated and available as 

alternative habitat for the use by spotted owls.

Because the effects of thinning and fuel treatments are primarily beneficial to NSO, similar projects 

(Beaverslide) in the area should be considered to have achieved the desired conditions and provided positive 

cumulative effects to the area, as recommended by the Recovery Plan and the Critical Habitat Rule.

Within or overlapping the boundaries of the UMRW, there are over 85 NSO ACs. Since the two projects 

are immediately adjacent to each other, four (4) ACs overlap the Kelsey Peak and 1st 48 projects (Table 13

and Table 14).

Habitats

Four (4) of the eight (8) ACs in the 1st 48 Project area also overlap the Kelsey Peak Project planning area. 

Incorporating the entire home ranges for these four (4) NSO ACs has defined the action area and has been 

evaluated throughout this document. The combined effects of the 1st 48 and Kelsey Peak projects are 

displayed in Table 13 and Table 14 below.

Table 13. Combined treatments for 1st 48 (48) and Kelsey Peak (KP) projects in foraging habitat by activity 

centers (AC) that overlap both projects.

AC#

Acre Total for 48 Acre Total for KP Acre Total for Both Acre Total Forage 

Habitat Avail % Habitat Impact

0.5 miles 1.3 miles 0.5 miles 1.3 miles 0.5 miles 1.3 miles 0.5 miles 1.3 miles 0.5 miles 1.3 miles

239 0 35 0 246.5 0 281.5 69 861 0 33

251 14 41 54 294 68 335 199 1,127 34 30

387 0 28 69 495 69 523 192 1,368 36 38

252 0 11 42 444 42 455 217 1,489 19 31

Table 14. Combined treatments for 1st 48 (48) and Kelsey Peak (KP) projects in nesting/roosting habitat by 

activity centers (AC) that overlap both projects.

AC#

Acre Total for 48 Acre Total for KP Acre Total for Both Acre Total N/R Habitat 

Avail % Habitat Impact

0.5 

miles

1.3 

miles 0.5 miles 1.3 miles 0.5 miles 1.3 miles 0.5 miles 1.3 miles 0.5 miles 1.3 miles

239 4 27 10 27 14 54 206 720 7 8

251 32 71 0 27 32 98 168 771 19 13

387 0 15 9 40 9 55 115 749 8 7

252 0 3 21 5 21 8 179 774 12 1

The only treatment occurring in these four (4) ACs for both projects is fuelbreak construction along high 

use roads. No pre-dominant or dominant trees were or would be removed and existing canopy was or 

would be maintained. Snags and downed logs were and would be maintained at the 80 to 100 percent 

level. All treated acres in both project is or would remain suitable immediately post project.

The maximum amount of acres treated within an AC for the two project combined is 19 percent of 

nesting/roosting and 36 percent of foraging. Although current habitat function has been or would be 

maintained in all treated areas, approximately 98 percent of the available nesting/roosting and 90 percent 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 93

foraging within the UMRW would be left untreated and available as alternative habitat for the use by 

spotted owls.

All treatment areas in the action areas would remain suitable immediately post project. Treatments were 

designed to maintain and restore habitat function in low- to moderate-quality habitat in all project areas.

Post treatment monitoring was conducted by the Level 1 Team on the Kelsey Peak Project, as well as on 

similar projects elsewhere on the Forest. All the units exceeded canopy closure requirements, and 

protected pre-dominant trees, snags, and downed logs. The units are still functional habitat and should 

respond well to the treatments. It was agreed by the Level 1 Team these types of treatments would have a 

beneficial effect on the future habitat conditions of the area and creating more alternative habitats for owls 

to use as additional treatments occur on the landscape.

Timber Harvest Plans

A search of the CalFire Timber Harvest Plan (THP) database showed that there was one private timberland THP within the 1st 48 Project area. Timber harvest plan 1-17-100TRI is located in T2S, R7E, Sec. 11 

and 12. The project will harvest 62 acres using a group selection method. The age of the stand is between 

40 and 75 years old, and was identified in the THP as low-quality foraging habitat. The project allows for 

openings up to 2.5 acres in size, in no more than 20 percent of the stand. Average canopy closure posttreatment will be 50 percent. No new roads will be constructed and landings will be a half-acre or less.

The THP occurs within the home range of AC 290, in the outer 1.3-mile radius. This home range is not 

deficit in foraging habitat (or nesting/roosting habitat) within 1.3 miles, and the harvest plan is expected 

to maintain foraging habitat post-project. There will be no cumulative impacts from the THP that would 

cause adverse effects or change the determination for the 1st 48 Project.

Fire

Historical records and fire evidence show that fires regularly occurred in this area with a variety of fire 

frequencies and intensities. Both wildfires and their exclusion through aggressive suppression affect plant 

and animal habitat, including stand structure, number of standing snags, amount of large woody debris, 

soil organic matter content, nutrient availability, and erosion hazard.

The dramatic reduction in wildfire burn acreages over the last 80 years appears to have resulted in 

unnatural fuel profiles that are more continuous, both horizontally and vertically. Given this increased 

conifer density, future wildfires could become larger and more destructive than in the past.

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

and grasslands have undergone significant changes in species composition and structure. Intermediate 

canopy layers and higher ground fuel loadings have developed which allow ground fires to reach the 

crown more easily, making fires more difficult to control. Young plantations now occupy most of the 

harvested old-growth sites within the project area. Early and mid-seral stages of Douglas-fir are more 

susceptible to mortality by wildfire than older late seral stands. Thick, corky bark on the lower bole and 

roots of older trees protects the cambium from heat damage. In addition, the tall trees have their foliage 

concentrated on the upper bole, which makes it difficult for fire to reach the crown; however, trees are 

typically not free of lower branches until they are more than 100 years old (Hermann et al. 1990). Stands 

selected for treatment in project area are predominantly 80 years old or less.

The high stem densities in plantations and younger stands also results in greater fire risk. Fire suppression 

activities have significantly reduced the amount of fire over the past 50 years leaving high fuel loads in 
Chapter 3. Environmental Consequences

94 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

places, which threaten the resiliency of the upland and riparian habitats in the event of a wildfire. In 

addition to these past activities, road building has cut across numerous riparian reserves and fragmented 

habitat in multiple locations throughout the project area, which has the potential to alter the sediment 

routing within the riparian reserve.

Within the 1st 48 Project area, there are two (2) large fire scars: the 2011 Ruth Fire that burned 1,608 

acres, and the 2015 Journey Fire, which burned 1,010 acres, partially re-burning forest scorched in the 

2001 Trinity Fire.

Illegal Marijuana Cultivation

A current issues arising in the scientific community is the effect of illegal marijuana gardens on public 

and private lands. The use of rodenticide has been linked to death in the Pacific fisher and the NSO. The 

project area has had gardens in the past, and some may exist on private lands as well, although there has 

been less of this type of activity on the district than other areas of the forest due to steep terrain and 

brushy conditions. It is uncertain how much cumulative impacts this would have on the owl at this time, 

but ongoing research has shown that there is greater risk to foraging Pacific fisher because of its 

scavenging activities during parts of the year. The data on these impacts is just starting to be generated. 

Whether rodenticide use is impacting the population of fisher or owls is still to be determined.

Marijuana cultivation on Forest Service land is an illegal activity and therefore is beyond the Forest 

Service control. The Forest Service law enforcement actively searches for and removes any grow-sites 

found; however, it is unknown how many sites exist in the Forest. It is hoped that by treating these lowquality stands and plantations that are not currently habitat that owls, fisher, and other species would have 

increased areas for foraging, and possibly help limit their exposure to the toxins that may be found in the 

forest from illegal activities.

Due to the scope, size, and intent of this project, there are no concerns of negative cumulative effects for 

TES, MIS, MBS, or other wildlife species. This proposed project is designed to attain Recovery Plan, 

Critical Habitat Rule, and LSR objectives and contains implicit measures to reverse cumulative watershed 

effects over the long term in the treated area.

Watershed Resources

Introduction

This section presents the predicted effects of the Proposed Action as compared to the No Action 

Alternative on watershed resources.

Environmental Consequences

Methodology

Cumulative watershed effects were analyzed at the 6th-field watershed scale. The watersheds are Ruth 

Lake-Mad River (180101020203) and Barry Creek-Mad River (180101020202). All units were field 

visited to validate presence and condition of riparian reserves and to determine existing and potential 

sediment sources.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 95

To quantify cumulative watershed effects the Region 5 Equivalent Roaded Acre (ERA) method was used 

to determine if these watershed are near the threshold of concern (TOC). Landscape treatments are 

considered to have no effect to water quality after 30 years, but all activities in the watersheds from 1988 

to the present were considered, both public and private. Effects from previous treatments were assumed to 

recover linearly.

Alternative 1 – No Action

Direct Effects

There are no direct effects of choosing Alternative 1 – No Action Alternative.

Indirect Effects

Because no vegetation would be cut, there would be no indirect effects to stream shading from canopy 

reduction, although not treating the fuels would make it more likely that the canopy is reduced or 

removed by wildfire.

Roads are the largest source of controllable sediment sources. Without this project, most of the roads in 

the project area would not be maintained for years to come. This project provides the funds needed to 

maintain roads in this area. In addition, FSR 2S54 would still be at risk from culverts being plugged and 

failing, which could introduce large amounts of sediment to Littlefield Creek, which is fish bearing.

Cumulative Effects

Vegetation and debris would continue to accumulate on the forest floor. This could lead to hotter, more 

intense fires and a decrease in the ability to suppress them.

Roads would continue to deteriorate and contribute small amounts of sediment to the watershed, which is 

the total maximum daily load (TMDL) listed for sediment. The watershed is well below the threshold of 

concern (TOC) for sediment, but untreated sediment sources push the watershed closer to that limit.

Alternative 2 – Proposed Action

Direct Effects

The Proposed Action would limit equipment entry into riparian reserves. For the project as a whole, there 

are 141 acres of riparian reserves deemed equipment exclusion zones. Of this, 90 acres are “inner” 

riparian reserves, (within 80 feet of the stream) which will only have fuel treatments by hand. There are 

51 acres of “outer” riparian reserves, which are equipment exclusion zones, but trees maybe yarded out 

using a cable. There are 3.7 miles of intermittent streams and one mile of perennial streams within the 

project units. The streams coming off South Fork Mountain are high gradient, steeply incised, with mostly 

stable banks and little true riparian vegetation. The project also includes areas near Littlefield Creek and 

Jonathan Creek. These streams are low gradient, with substantial floodplains or terraces, have less stable 

banks and more true riparian vegetation (primarily willow). Streams were not evaluated for seasonality of 

flow. If they were dry at the time they were inventoried in the field, they were clearly intermittent, but if 

they were flowing at the time of inventory, they were assumed to be perennial.

The project would not reduce the forest canopy below 60 percent, and even this would be temporary as 

the trees that are left behind are expected to grow faster and close gaps in the canopy. There would be no 

logging and associated ground disturbing activities within 80 feet of any watercourse (160 feet for fishbearing) although there will be fuels treatment by hand. There would be no effect on stream shading and 

stream temperatures would not be elevated due to project activities. Between 80 and 160 feet from 
Chapter 3. Environmental Consequences

96 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

watercourses (160 to 320 feet for fish-bearing) equipment would be excluded, although manual fuels 

treatments and logging would be permitted so long as canopy cover remains at or above 60 percent. These 

buffer widths are slightly greater than those called for in the NWFP.

Roads in the project area would be maintained and in some cases repaired prior to project activities. This 

would cause a slight reduction in sediment production from these roads. When the project no longer needs 

these roads, they would be maintained again (bladed, culverts cleaned, waterbars constructed) and left in a 

better condition than before the project.

All 1.95 miles of FSR 2S54 would be decommissioned and removed from the transportation system. This 

involves removal of all culverts and associated fill, constructing permanent dips or waterbars to control 

drainage, and blocking the road with a barrier. Decommissioning may introduce a small amount of sediment 

during earthmoving and possibly the first winter following, but would be diminimus and short-lived.

The Van Horn Allotment overlaps a southern portion of the project area. Cattle are known to “hang out” in 

riparian areas where it is cooler, and livestock impacts to the streambed, stream banks, and riparian 

vegetation have been documented in localized areas within the Van Horn Allotment (North Fork Eel EIS 

Grazing Allotment Analysis 2010). Reducing localized impacts to streams from grazing activities is outlined 

in the annual operation instructions to the permittee. The forest implements range monitoring per the terms 

and conditions of the North Coast Water Quality Waiver.

Livestock have access throughout the 1st 48 Project area; however, there were no readily obvious rangerelated impacts observed during field review within the project area, including riparian areas. The riparian 

areas within the project area are typically upslope, forested locations with steep draws where livestock 

utilization is very limited.

Indirect Effects

Project treatments would reduce the likelihood of catastrophic fire and improve the ability of firefighters 

to control unwanted wildfires. This reduces the risk that fire could remove the forest canopy, which would 

lead to increased sunlight and possibly elevated stream temperature levels. Loss of canopy and fine fuels 

could also lead to an increase in sediment delivered to the streams in the project area.

The installation and removal of culverts on Littlefield Creek (at FSRs 2S02 and 2S53) would cause some 

minor disturbance to the streambed and banks. Installation and removal will occur during the low-flow 

time of year when the stream is nearly dry. Effects to water quality and aquatic habitat should be shortterm and diminimus. If a temporary bridge is used instead, there will be no effect to water quality or 

aquatic habitat.

After FSR 2S54 is decommissioned, there would be no need for maintenance and no risk of culverts 

plugging and failing.

Cumulative Effects

To analyze cumulative watershed effects, the ERA model was used to quantify the effects of past projects, 

roads and trails, burned areas, recent firelines, timbers sales on private property, grazing allotments, this 

projects, and foreseeable future projects (Table 15).
Chapter 3. Environmental Consequences

Final Environmental Assessment – 97

Table 15. Equivalent Roaded Acres (ERA) and percentage of watersheds.

Watershed Ruth Lake – Mad River

(acres) % ERAs Barry Creek – Mad River(acres) % ERAs

Drainage Area 20,247 27,880

Past Projects 34 0.2% 407 1.5%

Roads and Trails 727 3.6% 1,016 3.6%

Burned Areas 802 4.0% 113 0.4%

Firelines 31 0.2% 2 0.0%

Private Timber Sales 189 0.9% 8 0.0%

Grazing 486 2.4% 1,155 2.4%

Total Existing 2,269 11.2% 2,701 9.7%

1st 48 86 0.4% 114 0.4%

Future (Beaverslide and Kelsey) 0 65 0.2%

Total ALL 2,354 11.6% 2,880 10.3%

Threshold of Concern 12.8 12.8

This project treats a very small percentage of the watersheds in which it is proposed to occur. For the Ruth 

Lake-Mad River watershed, the ERA model indicates that the existing condition is 11.2 percent; this 

project would add 0.4 percent for a total of 11.2 percent. The threshold of concern (TOC) for Ruth LakeMad River is 12.8 percent. There are no foreseeable future projects. This project would not lead to 

adverse cumulative watershed effects in the Ruth Lake-Mad River watershed.

For the Barry Creek-Mad River watershed, the ERA model indicates that the existing condition is 9.7 

percent; this project would add 0.4 percent for a total of 10.1 percent. This watershed does have 

foreseeable future actions (primarily remaining units from the Beaverslide and Kelsey Peak timber sales). 

Assuming that all the remaining units are treated in 2018, the ERA would increase to 10.3 percent. The 

TOC for Barry Creek-Mad River is 12.8, so this watershed would remain under threshold. This project 

would not lead to cumulative watershed effects in the Barry Creek-Mad River watershed.

The entire Mad River watershed is listed as impaired due to excess sediment and temperature under 

§303(d) of the Clean Water Act. Due to limited project activities in riparian reserves and 60-plus percent 

canopy outside of riparian reserves, stream temperature would not be affected. Some small amount of 

sediment may be generated by road maintenance and decommissioning activities during project 

implementation, but these activities are expected to reduce sediment production in the long term.

Total Maximum Daily Load and 303(d) Listing

In accordance with §303(d) of the Clean Water Act, the State of California periodically identifies “those 

waters within its boundaries for which the effluent limitations... are not stringent enough to implement 

any water quality standard applicable to such waters.” In 1992, US Environmental Protection Agency 

(EPA) added the Mad River to California’s 303(d) impaired water list due to elevated 

sedimentation/siltation and turbidity, as part of listing the entire Mad River basin. The North Coast 

Regional Water Quality Control Board (Regional Board) has continued to identify the Mad River as 

impaired in subsequent listing cycles, the latest in 2012. The 2006 303(d) listing identifies temperature as 

an additional impairment to the watershed. The EPA finished the Mad River TMDL for sediment and 

turbidity in December 2007. The temperature TMDL will be developed by the State of California in the 

future. In the Mad River basin, turbidity levels are closely linked with suspended sediment load. Thus, the 

TMDL focuses on total sediment load as well as suspended sediment load, which are the pollutants 

associated with excess sediment and turbidity that violate water quality standards.
Chapter 3. Environmental Consequences

98 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

The Upper Mad subarea (comparable to the Upper Mad River 5th-field watershed) produces only six 

percent of the sediment within the larger Mad River Watershed. For the UMRW, the total sediment is 

estimated at 234 tons per square mile per year with an average of 38 percent being from management 

related sources. The TMDL target for sediment in the UMRW subarea was set at 173 tons. This would 

mean a reduction of 26 percent for the Upper Mad watershed. The EPA specified that in order to meet a 

26 percent reduction in total sediment within the UMRW, management-related sediment must be reduced 

by 68 percent over time. Activities within the proposed project are designed to minimize and in some 

areas reduce management related sediment and move towards meeting the EPA sediment load allocation.

Due to limited project activities in riparian reserves and 60-plus percent canopy retention, stream 

temperature would not be affected. The primary management-related sources of sediment are attributed to 

current road conditions. Some small amount of sediment may be generated by proposed road maintenance 

and decommissioning activities during project implementation, but these activities are expected to reduce 

sediment production in the long term. Road maintenance and road decommissioning activities proposed 

in this project implement the road-related sediment reductions required by the Mad River TMDL and 

described in the Upper Mad River Watershed Restoration Action Plan. This project will result in a low risk 

of added cumulative effects and no adverse cumulative watershed effects are likely to occur.

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

of best management practices (BMPs) and adhering to the terms and conditions of the Waiver of Waste 

Discharge Requirements for Nonpoint Source Discharges Related to Certain Federal Land Management 

Activities on National Forest System Lands in the North Coast Region (The Waiver; Order No. R1-2015-

0021). Enrollment in The Waiver under Category B must be granted before project activities commence.

The direct, indirect, and cumulative watershed effects of the proposed action will not result in any 

significant impacts to water quality, as directed in the terms and conditions of The Waiver.

Watershed Restoration Action Plan

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

Project area) were identified as Priority Watersheds under the Watershed Condition Framework. As such, 

these watersheds had developed watershed restoration action plans (WRAPs). The primary strategies for 

restoring these watersheds are fuels reduction projects and road maintenance, stormproofing, and 

decommissioning. Although this project was not anticipated when the WRAP was created, it meets the

goals and intent of the WRAP.

Aquatic Conservation Strategy

The Aquatic Conservation Strategy (ACS) is intended as a means to restore and maintain the ecological 

health of watersheds and aquatic ecosystems contained within them on public lands. The strategy would 

protect salmon and steelhead habitat on federal lands managed by the Forest Service and BLM within the 

range of the NSO.

In order to make the finding that an action “meets” or “does not prevent attainment” of the objectives, the 

analysis must include a description of the existing condition, a description of the properly functioning 

range of natural variability of the important physical and biological components of a given watershed, and 

how the proposed project or management action maintains the existing condition or moves it toward the 

properly functioning range of natural variability. Management actions that do not maintain the existing 

condition or contribute to improved conditions in the long term would not meet the intent of the ACS and 

thus, should not be implemented.

Under the ACS, riparian reserves are designed to:
Chapter 3. Environmental Consequences

Final Environmental Assessment – 99

o Maintain and restore riparian structures and functions of intermittent streams.

o Provide benefits to riparian-dependent and associated species other than fish.

o Enhance habitat conservation for organisms that are dependent on the transition zone between 

upslope and riparian areas.

o Improve travel and dispersal corridors for many terrestrial animals and plants, and provide for 

greater connectivity of the watershed. The riparian reserves will also serve as connectivity corridors 

among LSRs (LRMP IV-44, 45). Riparian reserves along streams and unstable areas are designated 

riparian reserve land allocation per the SRNF LRMP Management Area 9. The land management 

emphasis for riparian reserves is to achieve the goals of the ACS (LRMP IV-106-108).

Alternative 2 would contribute to the attainment of the ACS, as it was designed to fulfill the nine objectives 

associated with the following stream classifications within the project area:

o Fish-bearing streams: Riparian reserves consist of the stream and the area on each side of the 

stream extending from the edges of the active stream channel to the top of the inner gorge, or to 

the outer edges of the 100-year floodplain, or to the outer edges of riparian vegetation; or to a 

distance equal to the height of two site-potential trees, or 300-foot slope distance (600 feet total, 

including both sides of the stream channel), whichever is greatest.

o Permanently flowing nonfish-bearing streams: Riparian reserves consist of the stream and the 

area on each side of the stream extending from the edge of the active stream channel to the top of 

the inner gorge, to the outer edges of the 100-year floodplain, to the outer edges of riparian 

vegetation, to a distance equal to the height of one site potential tree, or 150 feet slope distance 

(300 feet total, including both sides of the stream channel), whichever is greatest.

o Seasonally flowing or intermittent streams, wetlands less than 1 acre, and unstable and 

potentially unstable areas: This category applies to features with high variability in size and sitespecific characteristics. At a minimum, the riparian reserves must include the extent of unstable 

and potentially unstable areas (including earthflows) and extend from the edges of the stream 

channel to a distance equal to the height of one site-potential tree, or 100-foot slope distance, 

whichever is greatest. A site potential tree height is the average maximum height of the tallest 

dominant trees (200 years or older) for a given site class.

Intermittent streams are defined as any non-permanent flowing drainage feature having a 

definable channel and evidence of annual scour or deposition. This includes what are sometimes 

referred to as ephemeral streams if they meet these two physical criteria.

This project is consistent with the ACS, as unique design features and mitigations measures are 

incorporated to ensure proposed activities would contribute to maintaining or restoring both the condition 

of the project area and, through these actions, watershed condition as a whole over the long term with only 

minor, unavoidable short-term impacts. Project design criteria would fully protect aquatic resources and 

allow treatments within riparian reserves only when and where they would maintain or improve conditions.

While minor, short-term increases in sediment could occur during tree removal operations (skidding and 

log hauling, road maintenance (grading), and road decommissioning (during removal of drainage 

structures and re-establishing natural drainage patterns), in the long term, road improvements would be 

expected to lower chronic fine sediment inputs from compacted surfaces to promote a more natural 

watershed sediment regime. Overall, the Proposed Action would have long-term positive effects for 

aquatic habitats within the project area and for the watershed as a whole:
Chapter 3. Environmental Consequences

100 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

1. Maintain and restore the distribution, diversity, and complexity of watershed and landscape-scale 

features to ensure protection of the aquatic systems to which species, populations and communities 

are uniquely adapted.

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

designated a Priority Watershed under watershed condition framework (WCF). The Proposed Action is 

small in acreage and widely dispersed across the landscape alongside open roads in narrow 300-foot 

strips, existing roadside plantations and an oak woodland stand. Thinning to establish shaded fuelbreaks 

would retain forest overstory canopies at 60-plus percent, functioning to provide sufficient shade from 

solar radiation to prevent increases in water temperature.

Alternative 2 incorporates design features to retain large woody debris and avoids thinning of trees 

greater than 6-inch dbh within inner riparian reserve buffers to also ensure future down wood recruitment 

is sufficient to maintain suitable stream habitat conditions.

Events such as the Ruth Fire in 2011, consumed forest vegetation leaving soils barren and vulnerable to 

erosion and displacement resulting in substantial disruptions to the watershed conditions and hydrological 

function. Alternative 2 would contribute to the attainment of this ACS objective, as roadside fuelbreak 

treatments are designed to aid wildfire containment and control to decrease the probability for large-scale, 

high-intensity fire behavior to protect water temperature, sediment loads, and nutrient cycling at levels 

that provide for productive riparian and aquatic ecosystems in the long term.

The 1st 48 Project proposes to decommission FSR 2S54, an ML 2 road that is 1.95-miles long, and has 

four low-water crossings and three culverted stream crossings; featuring a large landslide near milepost 

0.65 that encompasses the entire road prism. Although the landslide would not be treated since it is now 

stabilized, decommissioning of the access segment from the intersection of FSR 2S02 would include 

barricading the entrance to prevent motorized travel to promote passive restoration of the travelway, 

removal of drainage structures to re-establish natural drainage patterns, and restoring maintenance-free 

conditions for the long term. The combination of barricading and water dispersion treatments are 

designed to stop water from concentrating on the travelway surface, reduce the potential for stream 

diversions (i.e., prevent water from flowing down the road or trail), and reduce the potential for off-site 

sediment delivery to water resources.

2. Maintain and restore spatial and temporal connectivity within and between watersheds. Lateral, 

longitudinal, and drainage network connections include floodplains, wetlands, upslope areas, 

headwater tributaries, and intact refugia. These network connections must provide chemically and 

physically unobstructed routes to areas critical for fulfilling life history requirements of aquatic and 

riparian-dependent species.

Under Alternative 2, there is no provision for equipment use within riparian reserves. The Proposed 

Action limits HFR treatments to low-intensity manual pruning and cutting of small trees less than 8-inch 

dbh, while retaining all hardwood trees. Newly excavated stream channel banks and fill disposal sites 

would be mulched to reduce surface erosion in the short-term. Mulch shall consist of locally available 

slash, wood chips, wood straw, or certified weed-free rice or barley straw. As such, it is likely there would 

be no negative effects to stream channel banks or stream connectivity.

The project area lies within the UMRW, which encompasses 120 square miles (24% of the basin) from the 

headwaters of the Mad River to Robert Matthews Dam, which impounds runoff from the upper watershed 

in Ruth Lake Reservoir (the only existing impoundment on the Mad River), built in 1961 by the Humboldt 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 101

Bay Municipal Water District (HBMWD). The reservoir has a storage capacity of about 48,030 acre-feet 

and was designed to provide a safe yield of 75 million gallons per day (mgd; 230 acre-feet per day), 

approximately 8 percent of the total annual runoff for the watershed.

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

Creek were intermittent. At the former US Geological Survey (USGS) gage near Forest Glen (No. 

11480500, located approximately 9 miles downstream of Matthews Dam), mean daily flow for the month 

of August from 1953 to 1961 ranged from 2 to 8 cubic feet per second (cfs), with an average of 4 cfs. 

Currently the HBMWD manages the release of water from Ruth Reservoir to meet domestic and 

industrial water needs as well as instream flow requirements for the protection of listed fish species 

(HBMWD 2004). Because of these releases, mean daily flow at USGS gage near Forest Glen for the 

month of August from 1962 to 1994 ranged from 73 to 97 cfs and averaged 85 cfs (HBMWD 2004).

3. Maintain and restore the physical integrity of the aquatic system, including shorelines, banks, and 

bottom configurations.

The physical integrity of riparian reserves would be maintained, as the Proposed Action is designed to 

avoid use of equipment (tractor/masticator) within the full 160 and 320-foot-wide equipment exclusion 

zones, and only manual treatment would occur with the inner 80- and 160-foot buffers. As such, there 

would likely be no impact to stream channel banks or stream bottom configurations. There are no 

wetlands, ponds or lakes within the project area for no effect to aquatic systems.

4. Maintain and restore water quality necessary to support healthy riparian, aquatic, and wetland 

ecosystems. Water quality must remain within the range that maintains the biological, physical, and 

chemical integrity of the system and benefits survival, growth, reproduction, and migration of 

individuals composing aquatic and riparian communities.

All landings and existing temporary roads required for access are outside of riparian reserve buffers. Thin 

from below would only occur in the outer riparian reserve buffers with only limited manual HFR. 

Ground-based equipment would be excluded from full buffers to avoid disturbance to soils, organisms 

and potential for chemical contamination (diesel or oil leaks or spills). As such, there would likely be no 

impact to water quality and chemical integrity.

5. Maintain and restore the sediment regime under which aquatic ecosystems evolved. Elements of the 

sediment regime include the timing, volume, rate, and character of sediment input, storage, and 

transport.

This project is small in acreage, spread out across the landscape, and will not reduce canopy below 60 

percent. The full 160-foot and 320-foot riparian reserve buffers would be designated an equipment 

exclusion zones. The inner riparian reserve buffer fuels treatments would be limited to manual and 

jackpot burning only away from stream channels. Although there may be minor amounts of sediment 

production in the short-term, primarily from road maintenance and decommissioning, the amount of 

increase at any single location would be undetectable and diminimus.

6. Maintain and restore in-stream flows sufficient to create and sustain riparian, aquatic, and wetland 

habitats and to retain patterns of sediment, nutrient, and wood routing. The timing, magnitude, 

duration, and spatial distribution of peak, high, and low flows must be protected.

The extent, duration and intensity of proposed activities under Alternative 2 are not sufficient to adversely 

affect in-stream flows. Evapotranspiration rates would not be further altered, nor would sufficient ground 
Chapter 3. Environmental Consequences

102 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

compaction occur to alter rates of surface runoff. The proposed treatments would not result in changes to 

spatial and temporal hydrology both due to the limited magnitude of the treatments and the very small and 

localized spatial extent of the treatments. Therefore, the timing, magnitude, and duration of flows would 

not be altered. Instream flows and fluvial processes would continue to occur at the rates under which the 

stream system evolved. Habitat diversity, channel stability, and water quality would continue to be 

moderate to high.

7. Maintain and restore the timing, variability, and duration of floodplain inundation and water table 

elevation in meadows and wetlands.

There are no wet meadows or wetlands near the project.

8. Maintain and restore the species composition and structural diversity of plant communities in 

riparian areas and wetlands to provide adequate summer and winter thermal regulation, nutrient 

filtering, appropriate rates of surface erosion, bank erosion, and channel migration and to supply 

amounts and distribution of CWD sufficient to sustain physical complexity and stability.

The project will not alter species composition, structural diversity, thermal regulation, nutrient filtering, 

rates of surface or bank erosion, channel migration, or large woody debris recruitment in riparian 

reserves, as equipment exclusion buffers and low-intensity TFB and HFR treatments are spatially limited 

to 130 acres or 16 percent of the project area units.

9. Maintain and restore habitat to support well distributed populations of native plant, invertebrate, and 

vertebrate riparian-dependent species.

As the Proposed Action is designed to maintain forest canopy closure at 60-plus percent providing shade 

with diverse multi-storied structure, riparian reserve conditions would maintain microclimate in the 

reserve corridors. In some drainages, these reserve corridors would extend to ridgeline saddles and 

connect with the corridors of other sub-watersheds to provide for travel and dispersal of animals and 

maintain habitat connectivity across the landscape. This would provide sufficient well-distributed habitats 

for terrestrial and aquatic species such as fish, mollusks, amphibians, lichens, fungi, bryophytes, vascular 

plants, and retention of adequate habitat conditions for dispersal of NSOs.

Geologic Resources

Introduction

The geologic effected environment consists of unstable lands that have potential to impact streams. The 

SRNF LRMP requires addressing the potential for increased mass movement for proposed timber harvest 

or building of roads and landings by development of landslide hazard maps and risk assessment (USDA 

Forest Service 1995 p. IV-71). Unstable and potentially unstable lands (including earthflows) are included 

in riparian reserves as directed by the ACS objectives, which direct management activities to result in 

non-degradation and restoration of aquatic and riparian ecosystems (USDA Forest Service 1995 pp. IV44-45). This is because landslides are a key component of the riparian system, supplying and metering 

sediment and large wood that are essential habitat elements of Pacific Northwest river systems. Unstable 

lands are defined as lands prone to mass failure under natural conditions and where human activities, such 

as road building and harvest, are likely to increase landslide distribution and frequency to the point likely 

to modify geomorphic and hydrologic processes. They include active landslides and those that exhibit 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 103

sound evidence of movement in the past 400 years, inner gorges, and lands identified as unstable by 

geologic investigation (USDA Forest Service 1994).

In order to meet ACS objectives, vegetation management activities follow several sets of guidelines 

including LRMP S&Gs, BMPs (USDA 2010) and PDFs. These guidelines are incorporated into project 

analyses and design, and provide a set of practices, which, during project implementation, allow for both 

accomplishment of project objectives, and maintenance and restoration of riparian function and condition. 

Because of these prescriptive methods, vegetation management within all unstable lands meet ACS 

objectives as project activities do not accelerate mass movement above background rates. This is largely 

achieved by restricting mechanical vegetation management to outside of unstable lands.

The forest plan also requires compliance with federal regulations for airborne asbestos (USDA Forest 

Service 1995 p. IV-116).

Environmental Consequences

Methodology

Resources used to identify unstable and potentially unstable lands were bedrock geology and geomorphic 

maps verified by field investigations. The bedrock geology GIS database was derived from published 

geologic maps. The original published geologic map was also used as a reference (McLaughlin 2000). 

GIS databases for geomorphology and active landslides were derived from air photo analysis performed 

by forest service geologists. Active landslides and geomorphic landforms were verified in field. Active 

landslides adjacent to streams with evidence of activity within the past 400 years were mapped 

individually within a single GIS database and were included as riparian reserves. All inner gorges were 

encompassed by stream riparian reserve buffer distances so were not mapped individually.

Alternative 1 – No Action

Direct Effects

Eight active landslides were identified in the project area including two deep-seated earthflows. No 

ultramafic bedrock and therefore, no naturally occurring asbestos occur in the project area.

There are no direct effects of choosing the No Action Alternative.

Indirect Effects

A major mitigating factor in reducing the risks of accelerating landslide activity is the prevention of highintensity fire itself through the proposed actions of fuels reduction and prescribed burning (Levitan 2014, 

Rolof et al. 2005). The low burn intensities and retention of trees associated with the proposed fuels 

treatments minimize the longer-term risks associated with high-intensity burns such as decreased 

infiltration from hydrophobicity, and loss of root strength with vegetation clearing (Iverson 2000, Roering 

and Jackson 2009, Wondzell and King 2003, Ziemer 1981, de la Fuente et al. 2002).

While there are areas of concern where project effects, such as mechanical ground-based yarding, might 

have short-term deleterious effects, such as locally triggering slope instability if not performed according 

to appropriate design features, the consequences of no action might be more significant from a slope 

stability perspective. Notably, reactivation of deep-seated landslides has been observed in a number of 

high severity burned areas (Mikulovsky et al. 2012). Common factors among these reactivations include 

stand-replacing (high or complete tree mortality) fire in late seral or old growth stands, and deep-seated 
Chapter 3. Environmental Consequences

104 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

landslides (earthflows, block sides, rotational/translational complexes, etc.) on highly sheared or 

unconsolidated geologic types. In the Coast Ranges, Franciscan rock types that were mélanges were 

involved and mélanges exist within the project area and contain existing earthflows. Because the project 

area has been fire-excluded for a lengthy period, it is likely that wildfire in the area would spread rapidly 

and extensively, and would burn at high severity in areas that resemble those with the described reactivated landslides. It is reasonable to assume then, that treatments such as those proposed, if they prove 

effective at reducing fire risk, will provide safer access for firefighters to contain fire starts, reduce the 

overall pattern of high burn severity on the landscape, and be effective in helping maintain hillslope 

stability and landslide activity rates within their range of historic variability, and meet the desired 

condition under SRNF LRMP.

Cumulative Effects

There are no cumulative effects associated with the No Action Alternative.

Alternative 2 – Proposed Action

Direct Effects

There are no direct effects to geological resources.

Indirect Effects

The activities that pose some, but minimal risk to unstable lands are commercial ground and cable 

mechanical harvest, and prescribed burning. Because all mechanical harvest or operation of machinery 

within unstable lands is prohibited, the risk and effects are indirect. The risk is that disturbed ground 

adjacent to unstable lands may trigger mass movement at a rate and distribution greater than average rates 

without human disturbance. The disturbances that pose the risk are skid trails that can concentrate flow to 

active scarps and landslide masses, and compaction that can alter groundwater patterns and, to an 

unpredictable degree, potentially increase subsurface water flow to active scarps and landslide masses. 

Disturbance of ground is restricted to 15 percent or less as per LRMP S&G 1-2 (USDA Forest Service 

1995 p. IV-71). This limits both the number of skid trails and area of ground compacted, thereby limiting 

potential effects and risk. Standards and guidelines require remediation of skid trails including installation 

of water bars, which eliminate risk of increased concentrated flow to unstable lands.

Risk of increased landslide activity due alteration of deeper subsurface flow patterns due to compaction 

poses minimal risk. Compaction by heavy machinery has a greater impact to the soil at the surface and 

causes more increased surface runoff and erosion than it does to alter deeper subsurface flow patterns (Reid 

2010). Although there is a potential for changes to deeper subsurface flow patterns due to compaction, with 

the limit of ground compaction to less than 15 percent, it is unlikely that increased subsurface flow to 

unstable lands will occur, minimizing risk of increased landslide activity, due to compaction.

Increased subsurface water to landslide masses has been shown to increase mass movement activity 

(Ziemer 1981, Reid 2010, Roering and Jackson 2009, Roering et al. 2003).), however, increased subsurface 

water that triggered landslides was typically from lack of tree evapotranspiration after total vegetation loss 

due to harvest or fire (Ziemer 1981, Reid 2010, Roering and Jackson 2009, Roering et al. 2003). The 

project retains at minimum 40 percent of canopy cover, and leaves all pre-dominant and dominant trees, so 

land adjacent to unstable lands will not provide increased subsurface water by loss of vegetation.

The proposed actions for prescribed burning plan to maintain low to moderate intensity, thereby retaining 

live trees and root strength. At low and moderate intensities, surface duff cover is restored rapidly and 

poses minimal risk to increased runoff to unstable lands. Risk of debris flows exists where soil burn 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 105

intensities reach moderately high to high levels, but these are typically short-term risks during the one to 

two winter seasons post burn (Wondzell and King 2003). The project designs include multiple strategies 

for controlling burn intensities such as implementation within strict moisture regimes and limits on spatial 

extent and fuel types. By following project designs, the risk of generating moderately high to high burn 

intensities is greatly reduced.

Further, all risk of landslide activity is by intense storms. This trigger is unpredictable. Though, on 

average, 10- to 15-year magnitude storms are the most likely to produce mass movement (Spittler 1989, 

Wondzell and King 2003), actual storm intensities that can trigger landslides depend on antecedent and 

subsurface infiltration conditions (Iverson 2000, Roering and Jackson 2009). However, a major mitigating 

factor in reducing the risk of landslide activity is the prevention of high-intensity fire itself through the 

proposed actions of fuels reduction and prescribed burning (Levitan 2014, Rolof et al. 2005). The low 

burn intensities and retention of trees associated with the proposed fuels treatments minimize the longerterm risks associated with high-intensity burns such as decreased infiltration from hydrophobicity, and 

loss of root strength with vegetation clearing (Iverson 2000, Roering and Jackson 2009, Wondzell and 

King 2003, Ziemer 1981, de la Fuente et al. 2002, Bosch and Hewlett 1982).

Cumulative Effects

Surveys identified eight active landslides within the project area. There are no other Forest Service or 

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

increased rate of landslide activity. Landslide activity has been shown to increase about 10 years after all 

vegetation has been removed by fire or harvest due to loss of root strength. The project would not remove 

all vegetation, thereby preserving root strength in the long term and will not increase landslide activity. 

Concentrated flow from skid trails would not occur due to application of skid trial remediation as per 

S&Gs and pose no long-term risk. If S&Gs, BMPs, and PDFs are followed, negative effects to slope 

stability should be minimal or absent as compared to the likelihood that extensive landslide reactivation 

would be in the event of stand-replacing fire across much of the landscape.

Soil Resources

Introduction

This section presents an assessment of current soil conditions and the analysis of potential effects of 

proposed treatments to short-term and long-term soil quality and productivity in the project area.

Environmental Consequences

Methodology

Forest Service Manual 2550 – Soil Management (Nov. 2010)

Forest Service Manual (FSM) 2550 provides a national directive to maintain or restore soil quality on 

NFS lands, and establishes the management framework for sustaining soil quality and hydrologic function 

while providing goods and ecosystem services outlined in forest and grassland LRMPs. The FSM defines 

soil productivity and soil quality, and describes soil functions that may be used in evaluating soil quality.
Chapter 3. Environmental Consequences

106 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

The FSM outlines programmatic requirements for assessments, analyses, and monitoring pursuant to 

management activities, and outlines general requirements that S&Gs be developed and implemented at 

regional and forest levels.

Standards and guidelines are intended to prevent substantial and permanent damage or degradation that 

affects inherent ecosystem processes. Substantial and permanent soil impairment is defined as detrimental 

changes in soil properties (physical, chemical, biological) that result in the loss of the inherent ecological 

capacity or hydrologic function of the soil resource, over the midterm (substantial, beyond the duration of 

the project) to long term (permanent, beyond a land management planning period), respectively.

Forest Service Region 5 FSM Supplement – Soil Quality Management (R5-2500-2017-1)

Soil management direction is applied to lands dedicated to growing vegetation; it is not applied to areas 

dedicated to other uses, such as roads, trails, administrative and recreation sites, etc. The Supplement 

specifies three (3) key soil functions to be used in R5 for assessment and analysis of soil quality: support 

for plant growth function, soil hydrologic function, and filtering-buffering function. Indicators and 

desired conditions for indicators are outlined for each soil function. Soil condition is rated as good, fair, or 

poor for each indicator relative to the desired condition. This approach is intended to help determine the 

status and trend of soil management, determine whether ecosystem health and long-term soil productivity 

is being maintained, and better determine needs and priorities for restoration activities.

The R5 Soil Quality Management Supplement (SQMS) uses the following indicators to evaluate 

management effects on key soil functions:

Support for Plant Growth Function (Soil Productivity)

o Soil stability: maintain adequate soil cover to prevent accelerated erosion.

o Surface organic matter: maintain adequate soil cover to provide for support of soil biology and 

nutrient cycling (maintain soil inputs of organic matter).

o Soil Organic Matter (SOM): maintain the topsoil in place (avoid excessive displacement). An 

area is considered displaced if more than one-half (0.50) or four (4) inches (whichever is less) is 

removed from a contiguous area larger than 100 square feet.

o Soil strength: maintain a favorable rooting environment (avoid excessive compaction).

o Soil moisture regime: maintain the inherent soil moisture regime, especially in wet meadows and 

fens.

Soil Hydrologic Function

o Soil stability: maintain adequate soil cover to prevent accelerated erosion.

o Soil structure and macro-porosity: maintain sufficient structure and macro-porosity in most of the 

area to provide for water infiltration and permeability (avoid excessive compaction, displacement, 

puddling, or severe burning).

Filtering-Buffering Function

For projects involving chemical or nutrient applications to the soil, an analysis is completed to maintain 

soil chemistry and capacity to filter and buffer foreign compounds. Another provision of the supplement 

is considerable direction on the process of conducting assessments and analyses. The activity area is no 

longer defined necessarily as individual harvest units, and it is not considered always necessary to field 

review every unit. For large projects (such as this), a prioritization approach is recommended, utilizing 

various soil risk ratings and interpretations to focus field review on areas with the higher risks to soils:
Chapter 3. Environmental Consequences

Final Environmental Assessment – 107

o “Assessments can be conducted on individual treatment units, entire activity areas, or specially 

designated land management areas. The area bounded by the assessment would be described or 

defined.”

o “Existing soil condition must be determined in the field, and field work needs to be focused 

where risks are greatest. Generally, it is not feasible or practical to field visit all proposed 

management areas, so priority sites must be chosen. Highest priority areas to field review are 

where soil condition may have been adversely affected by past management, and where proposed 

activities have the greatest potential to cause adverse effects to soil functions.”

Various types of soil disturbance (compaction, displacement, severe burning, etc.) may affect key soil 

functions in different ways on different soils and sites. Both degree and extent of disturbance are 

important considerations that must be evaluated together to assess potential adverse impacts on soil 

functions for the activity area. Quantitative measures or thresholds/limits for various types of soil 

disturbance are generally not provided in the Supplement, recognizing that one-size-fits-all ‘standards’ are 

often inappropriate for particular or differing soil types, and recognizing that disturbances need to be 

evaluated in a site and soil specific manner during assessments and analyses. The objective is to avoid or 

minimize disturbances that may impair key soil functions for the activity area, as that is defined. Areas 

rated in a poor condition should be considered for restoration activities.

Specific measures, indicators, and thresholds are established at the project scale in assessing soil 

condition, and for evaluating the effects of the proposed project on the soil resource: what gets looked at, 

why, and interpretation of what it means to soil quality and site productivity. This is described for this 

project in the methods and analysis sections below.

Soils information for the project area was obtained from two sources. The SRNF Soil Survey (USDA 

Forest Service 1993) was primarily used for soil mapping coverage and various soil interpretations (e.g., 

susceptibility to burning damage). The Natural Resource Conservation Service (NRCS) Web Soil 

Survey13 has publicly available soil mapping, map unit descriptions, information on soil physical, 

chemical, and engineering properties, along with additional NRCS soil interpretations. This was used to 

obtain official series descriptions, updated taxonomy information, and lab information (such as clay and 

organic matter content), realizing that such properties likely differ from the site-specific soils being 

assessed, but useful to rate soils on a relative basis for general sensitivity to various kinds of disturbance. 

Ultimately, soil resource information was field-verified to assure accuracy of soil properties and 

interpretations at the site/project scale.

Soil Erosion Rating

The Region 5 Soil Erosion Hazard Rating (EHR) System (FSH) 2509.20-50) was used to rate the risk of 

soil erosion for all soils in the project area. This system uses various physical soil properties along with 

climate and site-specific factors to rate soils for hazard of sheet and rill erosion. This system can also be 

used to determine the amount of surface cover necessary post-activity to avoid raising the erosion hazard 

rating to a higher risk level, and to determine the slope gradient at which EHR becomes higher with other 

site factors held constant. Hazards of gully erosion or mass wasting are not addressed with this procedure; 

these are evaluated on site during site visits, specifically looking for past problem areas that could also be 

future problems.

 13 See http://websoilsurvey.nrcs.usda.gov/app/HomePage.htm
Chapter 3. Environmental Consequences

108 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Field Observations

The purpose of the field investigations were to: 1) validate soil mapping coverage; 2) gather information 

on site-specific soil properties; 3) assess current soil conditions as affected by past management activities; 

4) develop predictions on soil response to the proposed activities.

Field surveys were largely ocular, meaning emphasis was given to traversing a large portion of unit areas 

and visually observing the range of conditions and kinds and amounts of disturbance from past activities, 

with soil pits along the way to document soil types and condition. Most soil pits were relatively shallow 

(1 to 2 feet deep) as physical soil impacts are largely confined to this surficial layer. Profile horizonation, 

texture, structure, rock content, and color were used to distinguish and identify different soils for mapping 

validation, as well as evaluating resistance and resilience of soils to physical impacts, for example 

susceptibility to compaction. Other site-specific data was collected for the analysis portion below, mainly 

site and topography data such as slope gradient, soil cover amount and components including rock cover, 

and LWM concentrations.

Current soil conditions in undisturbed state were observed, as well as altered states resulting from past 

management effects. Most of the mechanical units have some level of management history using groundbased equipment, as detailed below. Old features such as skid trails, landings, and former temporary roads 

were inspected for degree and extent of detrimental soil conditions, in particular erosion features, 

compaction, and soil displacement. No soil-related legacy problems were identified to be brought forward 

to the IDT as restoration opportunities to consider with the project.

Analysis Methods and Assumptions

Analysis first requires an assessment of the existing or baseline condition and then a prediction of the 

effects from the proposed activities. Existing current conditions were determined in the field. Soil impacts 

from proposed activities consider the types of activities, types of equipment and manner of operations 

expected, potential for detrimental disturbances, including where and to what extent, and further how long 

impacts are expected to persist considering expected rates of natural recovery or revegetation.

Information sources include the silvicultural prescriptions, including treatment methods, aerial 

photography, NRCS- and USGS-certified data, forest GIS layers, the Forest Soil Survey (USDA Forest 

Service 1993), custom GIS products generated for this project, field notes from site visits, and other 

interdisciplinary specialists’ input (particularly geology, hydrology, silviculture and fuels).

Regarding silvicultural prescriptions and mechanical operations: some unit prescriptions have optional 

methods to be used for the fuel reduction component of activities, namely through hand piling, mechanical 

piling, mastication, and/or understory burns. This is intended to confer flexibility for implementation as 

site-specific conditions warrant at the time; however, different activities carry different consequences for 

analysis purposes. It thus must be assumed for analysis that the more disturbing of alternate practices will 

be used (i.e., “conservatively” estimating more rather than less soil-disturbing methods will take place). 

For example, many of the units involve pile burning, with piling accomplished by hand and/or machine 

piling; for analysis, it is assumed machine piling is the more impactful option. Some of the PDFs are 

prescribed with this in mind, which risk being overly restrictive where less-disturbing activities wind up 

being chosen. This is necessary to address the range of soil disturbing activities that may be expected to 

occur and ensure compliance with LRMP standards. Mechanical treatments are expected to be restricted to 

allowable slope gradients as specified in the LRMP. Units are further assumed to be treated in designated 

portions over approximately 10 to 15 years, so impacts will be spread out over time, not all at once or in a 

couple years like the scope of a conventional commercial timber sale.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 109

Spatial and Temporal Bounding of the Effects Analysis

For soil resource analysis, the analysis area for direct effects is bounded spatially by the entire “footprint” 

of the project activity units, as this is the full extent of direct soil disturbing activities. The R5 Supplement 

and the forest plan indicate that the activity area is an appropriate scale to analyze project effects on the 

soil resource. Forest plan soil quality standards (SQS) are intended to be used at this scale to determine 

project effects on key soil functions, focusing here upon soil productivity and soil hydrologic function.

For indirect and cumulative effects, the analysis area is likewise the same as the proposed project area 

(unit areas only). Although surface runoff egressing the project units could possibly affect adjacent 

downhill slopes, it is only relevant where 1) runoff may be expected to occur, and 2) site-specific 

topography indicates runoff could pose additional off-site scouring, erosion, or water quality concerns. It 

is an assumption that runoff and erosion concerns are expected to be controlled on-site through effective 

BMPs and drainage controls. Thus, the analysis area for direct and indirect effects is the same, the 

proposed project area units.

The analysis is further bounded in time by the foreseeable future period during which effects of this 

project could persist as detectable, significant effects. Some soil impacts, such as cover reductions, can 

naturally recover quite quickly from needlecast and other organic debris deposited on the forest floor. 

Others, such as compaction and effects of displacement, can persist for decades. In general, expectation 

for temporal longevity of effects is discussed as short-term (<5 years), mid-term (5 to 20 years), or longterm (>20 years) effects. For cumulative effects, the analysis is bounded in time by past, present, and 

reasonably foreseeable future projects.

By adhering to SQS for limiting detrimental effects such as erosion, compaction, displacement, and loss 

of organic matter components, key soil functions described above are assumed to be maintained, in both 

space and time. A further level of analysis and discussion is warranted where SQS are expected to be 

exceeded in significant portions of the unit area. Greater than 15 percent of the area has conventionally 

been used for this extent threshold of concern for soils, though it is only technically specified for 

compaction and coincidental area in tractor skid trails.

Analysis Indicators

The effects of individual management activities on the soil resource, pertaining to soil productivity and 

soil ecological function, is guided using the regulatory framework outlined above, with particular 

emphasis on the most specific guidance: Six Rivers LRMP S&Gs and SQS (Appendix L).

Three indicators were chosen that best address relevant soil issues in the project and measure compliance 

with LRMP S&Gs. The indicators include soil stability (soil cover for erosion prevention), soil organic 

matter (conservation of), and soil structure & porosity (limiting aerial extent of compaction and 

displacement). The unit measures for each indictor are percentage area (acres) not meeting desired 

conditions, as set forth from applicable LRMP S&Gs and/or SQS.

Soil Resource Inventory

The Order 3 soil survey was judged as having good accuracy and utility for project planning based upon 

field review. No areas were found that had substantially different soil types, which would change 

interpretations and conclusions regarding environmental effects of proposed activities. This project area has 

an unusual variety of soil types, not one or a few dominant soils based on relative acreage; however, most 

soils are fairly similar in certain key respects such as surface texture and depth. In all, there are 10 soil map 

units with 20 family-phases in various combinations and component proportions (Table 16 and Table 17).
Chapter 3. Environmental Consequences

110 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Map phases are most commonly based upon slope class and perhaps depth class. Here Clallam is an 

example having 3 phases differentiated by rock fragment content and aspect (“dry” occurring on south 

aspects). Riverwash bridges alluvial and dry-floodplain and stream terrace environs. All but one (1) soil 

map unit are associations, meaning the components occur in a predictable and repeatable pattern such that 

they could be mapped at Order 2 survey intensity (1:24,000). This was not necessary here since most of 

the soils have similar manageability characteristics relative to this kind of project, as described below, so 

there would be no added benefit from the effort.

Soil maps are in Appendix A of the Soils Report, with Table 16 serving as the soil map unit legend. Select 

properties and risk ratings including EHR for the dominant soils are displayed in Table 17 and Table 18.

Table 16. Soil map units, acreage, and GIS-derived slope stats from a USGS 10-meter DEM (Digital Elevation 

Model).

Soil Map Unit Map Unit Name MU 

Type Acres GIS Slope %

Min. Mean Max.

100 Typic Xerofluvents-Riverwash, 2-10% slopes Assoc. 16 1 30 105

250 Oxalis-Hecker-Doty, deep, 25-70% slopes Family 1.1 27 31 34

256 Hecker deep, 35-70% slopes Assoc. 32 0 45 114

257 Dins deep-Nanny deep-Woodseye, 5-35% slopes Assoc. 8.4 0 14 31

258 Albus-Race, deep, 35-70% slopes Assoc. 119 12 30 66

259 Nanny deep-Woodseye-Bins deep, 35-70 slopes Assoc. 151 0 15 76

260 Skalan-Kistirn-Holland, deep, 35-70% slopes Assoc. 278 0 36 134

265 Clallam-Hugo-Holland, deep, dry, 35-70% slopes Assoc. 103 0 33 83

266 Clallam-Hugo-Holland, deep, 30-50% slopes Assoc. 26 13 50 107

281 Clallam deep, e.g. Deadwood, 35-70% slopes Assoc. 88 0 38 142

Totals 823 0 33 142

Table 17. Soil families in descending extent, including select properties and interpretations. Acreage is 

prorated from map unit components, less inclusions. Abbreviations are standard soil science.

Most of the soils within the project area are deep, well drained, with gravelly to very gravelly loam surface 

textures; several soils have finer-textured subsoils, sometimes fairly shallow and sometimes at depth. 

Woodseye and Deadwood are the only shallow soils, and only Deadwood has a soil hydrologic group D.

Soil Family/Phase Rel. Acres Rel. Acres A Texture Depth Tex. Δ Sub. Texture Depth RFC (top 12") HydroGroup Compaction BurnDamage SiteClass Part. Class Taxonomy

Skalan deep 83.5 13.4% vgL 12 vgCL 56 55 B-C moderate low 3-4 L-skel Ultic Haploxeralf

Holland deep 69.6 11.1% vgL 6 gL 40-60 40 C moderate low-mod 3 fine-L Ultic Haploxeralf

Kistirn deep 60.9 9.7% vgL 8 vcCL 53-79 40 C high moderate 3-4 L-skel Typic Haploxerult

Albus deep 53.6 8.6% gL 14 gCL 44-60 15 B-C moderate moderate 3-4 L-skel Ultic Haploxeralf

Nanny deep 47.5 7.6% gL 10 egL 40-60 20-45 B-C moderate moderate 3-4 L-skel Typic Xerumbrept

Woodseye [shallow] 46.7 7.5% gL 8 egL 14 20-60 C moderate moderate 4-5 L-skel Lithic Xerumbrept

Race deep 41.7 6.7% gL 16 cCL 40-60 20 C moderate moderate 3 fine-L Dystric Xerochrept

Clallam deep eg 39.5 6.3% egL 42 R 42 60-80 B moderate high 5 L-skel Dystric Xerochrept

Clallam deep dry 36.0 5.8% vgL 13 egCL 53 35 B moderate high 4-5 L-skel Dystric Xerochrept

Bins deep 33.2 5.3% L 10 gL 58 0-15 B-C moderate low-mod 3 fine-L Typic Xerumbrept

Deadwood [shallow] 26.4 4.2% gL 14 vgL 18 15 D moderate high 5-6 L-skel Dys-Lithic Xerochrept

Holland deep dry 20.6 3.3% vgL 6 gL 40-60 40 C moderate high 3 fine-L Ultic Haploxeralf

Hugo deep dry 20.6 3.3% gL 7 SiL 40-60 15 B high high 3 fine-L Dystric Xerochrept

Hecker deep 19.2 3.1% gL 6 vglCL 40-60 15 B-C high mod-low 4 L-skel Mollic Haploxeralf

Clallam deep 7.8 1.3% vgL 13 egCL 53 35 B-C moderate moderate 4 L-skel Dystric Xerochrept

Typic Xerofluvents 6.6 1.1% gSL 10-30 vgLS 40-60+ > 35 A low low n/a S-skel Typic Xerofluvents

Hugo deep 6.5 1.0% gL 7 SiL 40-60 15 C high moderate 3 fine-L Dystric Xerochrept

Riverwash 4.9 0.8% egS 10-30 cS 60+ > 35 A low low n/a S-skel Riverwash

Oxalis deep 0.4 0.1% SiL 8 SiC 40-60 0-10 C high moderate non-com fine-L Vertic Xerochrept

Doty deep 0.2 0.0% L 7 CL 40-60 5 B high low 4 fine-L Pachic Xerumbrept

Risk Ratings
Chapter 3. Environmental Consequences

Final Environmental Assessment – 111

Soil hydrologic groups (Table 17) indicate the potential of a soil to produce runoff from long duration 

storms, when soils are already thoroughly wet and are not protected by vegetation. Groups range from A, 

indicating very low runoff potential, to D, indicating prone to flashy runoff with erosion consequences. 

Soils here are mostly B or C. Group C soils indicate moderate runoff potential due to their less permeable 

subsoil, shallower profile depth, or both.

Compaction risk rating in Table 17 follows Roath (2006). Relatively high rock fragment content (RFC) and 

organic matter content are both beneficial in making topsoils moderately resistant and resilient to 

compaction from ground based machinery. Most soils have a moderate compaction risk because of loam 

surface textures. Soils with a high rating have a finer-textured subsoil (clay loam or silt loam) within 12 

inches of the surface. These shallow-occurring fine textures are susceptible to compaction, and have a 

higher risk of exposing less-permeable subsoil from incidental displacement with mechanical ground-based 

yarding. This is the sort of risk identification that may drive development of unit-specific PDFs after field 

review; compaction risk is usually best dealt with by limiting the extent (% area) of mechanical operations.

Burn damage risk rating (Table 17) indicates the susceptibility of heat to penetrate the soil during a fire, 

volatilize SOM, and kill soil microorganisms. While this is primarily determined by fire intensity, soil 

properties such as texture, rock content, parent material, and organic matter content can influence heat 

penetration to some degree. Long-term burn damage is mainly related to the loss of SOM, which requires 

long timeframes to accumulate within the soil. Soil moisture status at the time of burning also has a 

profound influence on heat penetration (Busse et al. 2010), but is not a factor in this rating system due to 

its transient nature. Clallam, Deadwood, and dry-phase soils have a high burn damage susceptibility 

rating because of lower levels of SOM in the topsoil. Soils with a moderate rating and not severely burned 

are expected to naturally recover in the short term. That said, prescribed burning activities still carry a risk 

of erosion if too much soil cover is removed, particularly on steeper slopes and soils with high EHR.

Erosion hazard rating results in Table 18 are calculated for project specific conditions and local climate. 

These are based upon the dominant soil component in each map unit. Often an approach rating the “most 

limiting” component is taken or rating components separately, if they are drastically different. Soil map units 

here do not generally have strongly contrasting soil components that might otherwise necessitate this.

Table 18. Erosion hazard ratings for soil map units (calculations may be seen in Appendix C of the Soils Report).

None of the soils have a high EHR with 50 to 70 percent soil cover on their respective average slope 

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

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

soils will reach a high EHR at some point of steepness with 50 percent or less soil cover, or even with 50 

GIS Hydrologic High EHR

Erosion Hazard Rating (EHR) summary table mean Soil limit

Soil MU Map Unit Name % slope Group Current Post-Treatment Bare % slope

100 Typic Xerofluvents-Riverwash, 2-10% slopes 30 A L M M 94**

250 Oxalis-Hecker-Doty, deep, 25-70% slopes 31 C-B L M H 37**

256 Hecker deep, 35-70% slopes 45 B-C L M H 53

257 Bins deep-Nanny deep-Woodseye, 5-35% slopes 14 B-C L L M 57**

258 Albus-Race, deep, 35-70% slopes 30 B-C L M M 57

259 Nanny deep-Woodseye-Bins deep, 35-70% slopes 15 B-C L L M 57

260 Skalan-Kistirn-Holland, deep, 35-70% slopes 36 B-C L M M 73

265 Clallam-Hugo-Holland, deep, dry, 35-70% slopes 33 B-C L M M 86**

266 Clallam-Hugo-Holland, deep, 30-50% slopes 50 B-C L M H 86

281 Clallam deep eg, Deadwood, 35-70% slopes 38 C L M M 86

Note: "current" condition assumes 95% ground cover, "post-project" assumes > 50% ground cover, "bare" includes only overstory canopy and rock cover.

Erosion Hazard Rating

Soil Cover Levels
Chapter 3. Environmental Consequences

112 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

to 70 percent cover for most soils. The EHR slope limit in Table 18 is the slope gradient at which EHR 

becomes high with assumed 50 to 70 percent soil cover post-project; this would indicate a need for soil 

cover additions above this limit to maintain a moderate or lower EHR (**denotes these soils do not 

actually occur on slopes this steep (e.g., Bins)). The soils that do have a high EHR when bare are 

relatively minor in extent (<60 acres total), but would warrant caution where they occur to not create large 

bare areas, particularly on slopes greater than 50 percent as a general practice for all soils here.

Thus, from a manageability perspective, considering texture, depth, and interpretive ratings, these soils 

fall into three groups: 1) soils which are more susceptible to compaction and displacement impacts 

because of fine-textured subsoils shallow beneath the surface (Kistirn, Hugo, Hecker, Oxalis, Doty); 2) 

soils susceptible to burn damage because of low OM content (Clallam, Deadwood, and dry-phase soils on 

south aspects); 3) other soils which are generally more resistant/resilient to management related impacts.

Oxalis is repeatedly noted as different. This is a somewhat unique soil found in the “glades” that supports 

mixed grassland-oak woodland; it has finer textures (SiL overlying SiC) than any of the other soils (Table 

17), and is considered “non-commercial”—it does not support productive forest. Silty clay is a very unusual 

texture on NFS lands. Also notable, Oxalis is vertic meaning it has shrink-swell clays that form cracks 

seasonally when dry; thus, infiltration and permeability function differently in this soil, and natural recovery 

of compaction is relatively fast. Oxalis only occurs in tiny portions (0.5 to 0.6 acres) of two units (416 and 

613), both oak woodland restoration units where actual ground impacts are expected to be quite minimal.

All of these management risk ratings collectively indicate the general sensitivity or resistance and resilience 

of different soil types to different kinds of disturbances or impacts. They were also used as a pre-field filter 

to help identify and prioritize emphasis areas for more detailed field review, to ensure that soils types, which 

are generally more sensitive to management related impacts, receive more attention and thorough review, 

given the management activities proposed. Units are routinely dropped during the field review phase for 

various resource concerns, including slope stability and soils concerns when they pose higher risks. Again, 

these are the sort of risk factors that may drive development of unit-specific PDFs after field review.

Alternative 1 – No Action

Direct Effects

Direct effects of the No Action Alternative would be of no immediate effect at all on the soils, as new soil 

disturbing activities would not take place. Soil cover for erosion protection would not change. Present 

compaction levels would remain the same in the short-term, with very slow long-term natural recovery. 

Surface organic matter components would continue to accumulate faster than decomposition. Soil organic 

matter would be unaffected. Soil hydrologic function would be unaffected.

Indirect Effects

Indirect effects of the No Action Alternative would be the increased accumulation of organic matter in 

terms of surface and ladder fuels, with a corresponding continual increase in fire hazard. Fire hazard is 

not the probability of a fire ignition, but that a fire ignition (human or lightning caused) would result in a 

successful fire start and spread, and fire behavior would be more severe. Fire hazard already represents an 

unacceptable threat to values at risk in proximity to the project area due to present vegetation 

composition. The No Action Alternative would do nothing to alleviate the hazard, and would do nothing 

to provide for a more manageable firefighting scenario in the eventual case of another fire.

These fuelbreaks also provide opportunities for compartmentalizing fires when they do occur, as a matter 

of when, not if. To the extent that management activities can reduce the eventual size of high severity 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 113

fires, soil resources benefit in the long term. Low to moderate severity fire is not usually considered a 

serious threat to soil resources, but high soil burn severity can have long-term consequences to soils. High 

severity fire may have other resource benefits, depending on scale, but not for soils as an essentially nonrenewable and irreplaceable resource in human timeframes.

Cumulative Effects

There would be no additional impacts to soils with the No Action Alternative, so there would be no 

additive effects of other past, present and reasonably foreseeable future actions, and therefore by 

definition no cumulative effects. Soils would continue to have natural ecological function and soil 

productivity would be unaffected relative to the current existing condition. It can certainly be argued that 

there are ecological cumulative effects of the No Action Alternative, in terms of wildfire effects to soils, 

watersheds, and TE fish and wildlife habitats, but wildfires are not Forest Service actions, so they are not 

usually discussed in this NEPA context of cumulative effects.

Alternative 2 – Proposed Action

The environmental effects were analyzed with the intent and assumption that BMPs and the following PDFs 

are effectively applied to the Proposed Action, meaning they are implemented and achieve the intended 

results on the ground. Best management practices are intended to manage water quality consistent with the 

Federal Water Quality Act (WCA) and State of California water quality programs. Best management 

practices are not repeated here; see the project hydrologist’s report for specifics. Notable here is that many 

of the BMPs concurrently address soils concerns to the extent they are intended to prevent or minimize 

surface erosion and sediment movement. Appendix C of this EA discloses a list of applicable BMPs.

Direct Effects

Direct effects are generally analyzed in the context of activity types and where they are expected to occur 

(i.e., what “footprint features” would be left behind and what are the soil impacts there). The direct effects 

of these activities are very largely predictable based upon expected methods of operations and location of 

activities in terms of topography and soils and vegetation composition, the latter indicating types and 

amounts of removals or general treatment intensity (Table 19). The effects of these different activities on 

the soil resources are well understood from years of experience planning and monitoring the effects of 

such activities on a wide variety of soils.

New temporary roads and landings are the most impactful features associated with activities, in particular 

ground-based (tractor) operations. No new temporary roads are proposed with this project, in agreement 

with the Collaborative. The majority of landings are old landings to be reutilized, but a number of new 

landings would also be created. These would have severe compaction, and thus have reduced infiltration 

and be prone to producing runoff; drainage features are required to control runoff and avoid adverse 

impacts (BMPs). Being “temporary” means that they will need to be rehabilitated once their use is 

finished. Project design features herein stipulate that rehabilitation will include de-compaction via ripping 

(furrowing using conventional rock-rippers common on logging equipment) or “dibbling” meaning 

working the ground with an excavator bucket (common method in other areas, also called “potato patch”). 

This would be followed by re-contouring to the approximate original terrain in cases where the feature 

was “constructed” by blading topsoil to create a favorable grade or bench (constructed using cut and fill).
Chapter 3. Environmental Consequences

114 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Table 19. Soil map unit acres by logging system method (Alternative 2).

The proposed landings are mostly roadside on gentle grade, so little blading should be necessary to make 

them usable, and thus little to no recontouring is expected to be necessary; however, some form of 

decompaction would be necessary. These areas would also be rendered bare, so some form of soil cover 

may be required to prevent erosion, either organic mulch, slash, and/or seeding to establish vegetation. In 

most cases, old access roads and landings are in favorable locations to be re-utilized, which will minimize 

new disturbance and cumulative effects. Even with rehabilitation measures, new and reutilized temporary 

roads and landings would still have long-term effects left to slowly recover naturally over time.

Skid trails would be created as necessary to operate the mechanical ground-based units. These would also 

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

“detrimental” levels of compaction, depending on traffic intensity. A few passes with a tracked grappleskidder will generally not produce a detrimental degree of compaction if soils are dry. Most soils have a 

moderate compaction risk (Table 19), but some have a high compaction risk, namely Kistirn (SMU 260), 

Hugo (SMU 265-266) and Hecker (SMU 250-256); these intersect with many of the ground-based units 

(Appendix C). Thus, it is conservatively assumed that skid trail compaction will be detrimental, and these 

equipment trails in combination with temporary roads and landings should not exceed 15 percent of the 

unit area as part of the layout plan to ensure this aerial extent is not exceeded (PDF). If equipment trails 

are deeply rutted, they should also be decompacted by ripping and allowed to naturally revegetate.

Mastication uses specialized equipment to “chew up” or create wood chips from standing surface and 

ladder fuels (shrubs and saplings) and redistribute them on the soil surface. This creates increased surface 

fuels for some time, while reducing potential for crown fire. Chips are more or less directionally propelled 

during operations, which leaves a somewhat clumpy distribution of chips. If chips build up around tree 

boles, there is the potential for tree mortality from cambial scorch during broadcast burns. On the positive 

side, chips decompose over the course of 5 to 10 years, benefitting buildup of SOM. Burns can be safely 

accomplished after a lag time for chips to decompose. Thick chip layers can also inhibit germination of 

some understory species for some time, which there is little scientific information about (i.e., what species 

are more sensitive, in what settings, can it also inhibit invasive species?). Finally, large additions of 

carbon (C) to the soil can potentially immobilize nitrogen (N) through microbial metabolism for some 

time and affect C:N ratios for plants. This effect was not seen on two intensively studied long-term 

research experiments by PSW Research Station, Redding, despite great effort to document it (Zhang et al. 

[ACRES]

Soil MU Hand Cable Ground w/ Endline Ground Total

100 3.6 13 16

250 1.1 1.1

256 24 7.7 32

257 8.4 8.4

258 25 94 119

259 151 151

260 5.7 110 0.1 162 278

265 4.4 28 7.8 62 103

266 19 7.3 26

281 21 67 88

Total 10.1 231 7.9 574 823

Logging System
Chapter 3. Environmental Consequences

Final Environmental Assessment – 115

2016). That said, mastication effects on fire hazard and understory development are temporary, which 

may or may not fit with other short-term management objectives.

There is a great variety of equipment used to accomplish mastication, which is usually smaller and lighter 

ground pressure than conventional harvest equipment, but not a given depending on specific equipment 

used, which is not necessarily known beforehand to estimate soil impacts. It is conventionally thought 

that operating upon a fresh masticated chip layer helps to protect soils from compaction effects, but to 

what degree likely depends on several factors.

Tractor piling of fuels for later burning is one the more controversial practices regarding soil impacts. In 

the past, this was usually conducted with fixed-blade D-6 type tractors, resulting in much topsoil 

displacement into piles, and much maneuvering and many passes with resulting compaction effects, 

especially if soils were moist. Today, this practice often utilizes smaller tractors with six-way blades and a 

brush rake attachment, which is nimble and much more effective in piling fuels without the associated 

displacement or severe compaction impacts. This project proposes using primarily smaller excavators 

(Type 3) to pile fuels, which is lower ground-pressure on the soils, and can reach out to operate a larger 

swath in fewer passes, usually single-pass. This kind of operation does not typically produce soil 

displacement or detrimental levels of soil compaction or unless operating in truly adverse weather on 

saturated soils (Rust 2009).

Most units are proposed to have some form of manual treatment, hand pile burn, or prescribed burn 

activities, discussed here collectively as “hand-treatments.” This is often a follow-up or maintenance 

treatment sometime after initial treatments are completed. Hand treatments are generally low impact, 

rarely creating impacts of a degree or extent that would be considered detrimental for soils, only foot 

traffic and potential burning effects for possible soil impacts.

Pile burning creates severe heating of soils under the piles, but these occupy a relatively small portion of 

unit area, and are surrounded by duff-covered soils to provide a filter strip to prevent sediment movement. 

Soil heating is reduced if burning is conducted when soils are moist to wet (Busse et al. 2010, 2013), 

shortening soil recovery time as well. Prescribed (broadcast) burning, conducted as desired, usually 

should not burn all the duff to bare mineral soil, or only in patches. However, this practice does have more 

potential to remove more duff from more of the area than may be desirable for soil cover and erosion 

prevention. Burn plans will need to be conservative, and explicitly take measures to retain soil cover 

levels specified in PDFs.

There are steep areas not suitable for mechanical operations (>35%) in many of the ground-based units 

that will need to be avoided or only treated by hand. Steep areas should not be traversed with heavy 

equipment. Flexibility is usually granted for tracked equipment to strategically operate on short pitches 

less than 100 feet and less than 40 percent slope, in which case equipment should go straight up and down 

slope with no turning; any such instances should be identified for installation of waterbars at close 

spacing and addition of soil cover (e.g., slash) if bare soil results. Thus, minor flexibility is allowed, but it 

carries additional mitigations.

It is expected there would be areas of bare soils after ground-based operations are complete, typically less 

than 10 percent of unit area. Bare areas are typically small and dispersed; larger bare areas in one portion 

of a unit would pose a concern for erosion and sediment production. Any such areas rendered bare on 

greater than one-fifth of an acre would be monitored for vegetation recovery, and would be actively 

mulched and/or seeded if any evidence of significant erosion is discovered, and/or if natural revegetation 

is not timely (PDF).
Chapter 3. Environmental Consequences

116 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Cable and road-based mechanical treatments are generally lower impact on soils, especially with full 

suspension cable. Road-based cable generally only achieves single-end suspension, with some resulting 

soil gouging. With either system, a PDF specifies at least one-end suspension of the butt-end of the tree, 

which will greatly help reduce gouging. Where gouging does expose bare soils, hand waterbars and 

raking cover back onto the corridor shall be done to mitigate water routing and potential for gullying 

since these activities are by necessity on steeper slopes.

All of these foreseeable direct impacts would not occur all at once; rather they would be spread out over 

the next 15 years (estimated). Best management practices and PDFs would be kept concurrent with 

operations. Thus, the acreage extent of impacts would be annually variable over the life of the project.

Given the activity-centric context described above, effects below will now be discussed relative to the 

analysis indicators used to address Forest Plan requirements, and where appropriate relative to specific 

activity type or specific units.

Soil Cover for Erosion Prevention

Reduction of soil cover to varying degrees is a given by-product of proposed activity types. This is 

acceptable given that residual soil cover still meets requirements for erosion prevention, generally greater 

than 50 percent on slopes less than 50 percent and greater than 70 percent on slopes greater than 

50percent, as indicated by EHR analysis.

Site-specific EHR development (Appendix C) indicates that greater than 50 percent cover is adequate to 

avoid a high erosion hazard for all soils present here, at least upon average (GIS-derived) slope gradients 

for those soils. But even with greater than 50 percent cover, most soils will still reach a high EHR at some 

point of steepness, ranging from 53 to 86 percent slope for soils that actually occur on slopes that steep 

(Table 18). Thus, it is conservatively recommended that on slopes exceeding 50 percent, more residual 

soil cover is required at greater than 70 percent, which is easy to achieve for cable operations but not 

necessarily for broadcast burns.

All other areas have loam surface textures, and greater than 50 percent soil cover in the form of duff and 

litter is estimated as sufficient to avoid a high erosion hazard. Only prescribed (broadcast) burning 

activities have potential to exceed 50 percent cover losses, and then only if the burns are much hotter than 

planned. It is expected that burns will be conducted with target residual cover levels in the prescription, 

and all units should accordingly meet this requirement at unit-scale post-activity.

Soil Porosity (Compaction)

The Six Rivers LRMP defines detrimental compaction is a 10 percent reduction in total soil porosity, and 

this condition cannot occupy greater than 15 percent area of an activity unit. All units surveyed currently 

meet this standard. For proposed activities, this would practically apply only to units with mechanical 

ground-based activities. One PDF specifies limiting temporary roads and landings and skid trails 

collectively to less than 15 percent unit area, and this is a conventional standard that sale administration 

staff is accustomed to implementing and achieving. It is thus expected that all units will meet this 

standard post-activity.

Soil Organic Matter

Soil organic matter (SOM) is organic matter and humus within the topsoil, which is crucial for nutrient 

and water holding capacity and long-term soil productivity. In Mediterranean climates, it is produced 

mainly from annual fine-root turnover, and to a lesser extent from fine surface organic matter additions; 

these are long-term processes, and long timeframes are necessary to accumulate SOM. The SOM is 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 117

principally vulnerable to loss from erosion (export), severe burning effects (volatilization), and 

displacement (redistribution, but still generally on-site).

Forest SQS include a standard of retaining 85 percent of total SOM in the top 12 inches of soil. Though 

not stated, this standard is aimed at avoiding excessive soil displacement; notably it is non-implementable 

because even an experienced soil scientist cannot objectively determine compliance, or lack of. That said, 

soil displacement effects are a lesser concern for SOM loss, because the displaced soil is still on-site 

unless eroded, so the nutrient capital is still accessible by plant roots. This was a much greater concern 

historically when large brushfields were “reclaimed” for conifer plantations by “topsoil windrowing” to 

remove root-crowns of sprouting species that would be aggressive competition for resources, along with 

removing nutrient and SOM rich topsoil. It came to light that this practice was degrading to long-term soil 

productivity, particularly when windrows were spaced far apart and then many tree roots could not reach 

the enriched soil; such practices have not been conducted for several decades now. Displacement here will 

be incidental and very small in scale of movement, very unlike the old practices that became a concern for 

degraded soil productivity. Soil displacement in this context is not a concern with this project.

Erosion is explicitly part of the project design to prevent and avoid. Therefore, severe burning has the 

greatest potential to cause some loss of SOM and nutrients in the top several inches of soil, precisely 

where they are most concentrated (DeBano et al. 1998). Fire effects are specifically a concern in the event 

that proposed burning activity is much hotter and hotter over larger areas than planned. Burn prescriptions 

that aim to preserve greater than 50 percent duff cover for erosion prevention should certainly not be hot 

enough to significantly degrade SOM in the surface soil, except perhaps in small patches, as with pile 

burning where residence time is longer. Broadcast burning prescriptions as practiced usually produce low 

to moderate soil burn severity (SBS), as opposed to 5 to 15 percent high SBS plus 30 to 40 percent 

moderate SBS typical for wildfires in this vicinity (BAER records, on file with author). In either case, soil 

heating will be reduced if burns are conducted when soils are moist (Busse et al., ibid).

Proposed activities, including burning activities, are fully expected to result in all units meeting applicable 

standards for SOM post-activity.

Surface Organic Matter – Duff and Fine Litter

Surface organic matter here is for nutrient cycling, as opposed to aforementioned erosion prevention, 

which may or may not coincide as the same cover levels. The LRMP specifies at least 50 percent cover of 

duff and fine litter for soil productivity (with perhaps more needed for erosion prevention, as determined 

for the project). As already stated, it is expected that this level of soil cover will be met for all project 

units post-activity.

Furthermore, these are not clearcuts. A living forest canopy that continually adds litterfall to the forest 

floor will compensate in the short-term to cover small areas that may have burned hot or otherwise 

inadvertently removed more cover than desired. A healthy productive forest is the best case for selfmaintaining favorable nutrient cycling, particularly on the more developed soils (Ultisols and Alfisols).

The portion of the burn scar area that burned at high fire severity lacks a productive overstory, so surface 

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

been aggressive, so current cover levels are adequate in extent (>50%). Fuels reduction activities will set 

this recovery back slightly, but it is still expected that this standard will be met post activity.
Chapter 3. Environmental Consequences

118 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Large Woody Material

Large woody material contributes to SOM and habitat for arthropods that masticate fine organic matter 

into smaller particles that soil microbes can then utilize as food. Large woody material becoming SOM is 

an even longer-term process than for duff and litter, and in a fire-prone setting, most LWM probably never 

makes it to this state, but is consumed by fire sometime at higher levels of decomposition class. That said, 

the habitat value of LWM for arthropods, bacteria, and fungi is ecologically important.

As stated above, LWM is generally deficient in most of the project area, attributed to roadside firewood 

scavenging by the nearby community. This is not a problem, nor undesirable here. These roadside units 

are proposed as fuelbreak units, and LWM requirements are explicitly waived in strategic fuelbreak areas, 

so this is a non-issue here.

This leaves plantations and oak woodland units where the retention standard would perhaps apply. These 

are both also deficient in LWM. The oak woodlands are an ecological type that would not be expected 

capable of producing and maintaining LWM standards. The plantations do not currently have much LWD 

because of past management practices, particularly site prep for planting that would have removed or 

burned most of this material. The stands are relatively immature, so there will not be large trees on site to 

contribute such materials for some time into the future. Such forested areas where LWM does not 

currently occur are not expected to meet the retention standard with current activities.

As with duff and fine litter, burning activities and especially broadcast burns have the most potential of 

consuming what LWM does exist here. Since plantations do not have adequate size class of trees for 

LWM recruitment, the only practical management option is to protect existing LWM in non-plantations 

from mechanical disturbance and more importantly burning. Burn plans will need specific provisions to 

protect this resource (PDF). It is thus estimated in good faith that LWM will be protected to the extent 

practical, and LWM levels will increase over time, on average project-wide and eventually within 

plantations in the long term.

Infiltration and Permeability (Soil Hydrologic Function)

The Six Rivers Plan specifies that infiltration and permeability would not be reduced to a rating of 6 or 8

under the EHR system. Furthermore, the area in detrimental condition should not be of a size or extent 

that would result in a significant change in production potential for the activity area; this is not specified 

for this criterion, but is conventionally assumed to be 15 percent of the area, as with other criteria.

The primary impact to soil hydrologic function is compaction by ground-based equipment, which usually 

only affects surface infiltration, not permeability as this is based upon subsurface water movement that is 

typically below compaction depth. Notably, the EHR system was developed primarily for agricultural 

soils; forest soils nearly always have rapid to moderate infiltration rates, being naturally more porous than 

equivalent Ag soils. Reducing infiltration from rapid to moderate still produces a water movement rating 

of 3 to 4 for almost all of these soils. The water movement rating becomes a 6 if infiltration is reduced 

from rapid to moderate on a shallow soil (e.g., Woodseye), or an 8 if infiltration is reduced to slow (<0.6 

in/hr.) on any soil. A reduction of infiltration to 0.6 inches per hour would be unusually severe 

compaction, such as with a temporary road or severely compacted landing.

Soil hydrologic function is currently in good condition except in the limited areas, namely old landings 

and just a few main skid trails close to landings, comprising about 5 percent area in previous mechanical 

units and less than 2 percent of the project area as a whole.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 119

For proposed activities, this function is potentially compromised where severe compaction from groundbased equipment is expected, specifically landings if not rehabilitated and any reutilized temporary roads 

or landing spurs. Heavy equipment traffic (including temporary roads and landings and skid trails) is 

limited to less than 15 percent area (PDF) to satisfy the porosity/compaction standard. Even most 

compaction that would qualify as detrimental would NOT be compacted severely enough to reduce 

infiltration to less than 0.6 inches per hour. Thus, the PDF that limits detrimental compaction is expected 

to more than satisfy the soil hydrologic standard also. All units are expected to comply with this standard 

post activity. Project design features also specify rehabilitation of any temporary roads and landings that 

are used, so this condition is expected to be actually improved on net-balance post-activity.

Unit-Specific Mitigations

Often differing soil types or differing levels of current legacy soil impacts drive the need for additional 

unit-specific requirements beyond project-wide PDFs, necessary to ensure compliance with LRMP 

standards. No such measures were identified as necessary for this project during field review or analysis 

phases of the soil assessment for this project.

Indirect Effects

Indirect effects of the Proposed Action relative to soils within the bounding area include changes to the soil 

environment, reallocation of soil resources (water and nutrients) to fewer plants, changes in the distribution 

of organic matter upon and within the soil, and changes in potential soil damage from future wildfires.

The Proposed Action would create short- to mid-term changes in the soil environment. Soil temperatures 

would be elevated due to opening the canopy and increased solar exposure of the soils. This would stimulate 

soil microbial and fungal activity and increase decomposition of soil organic matter and CO2 efflux from the 

soils. This would also synergistically stimulate root activity of vegetation, also increasing CO2 efflux but as 

importantly, increasing annual fine-root turnover, which is a primary input to soil C and organic matter. On 

balance, soil C attrition in CO2 efflux would probably exceed accrual in root turnover for the first several 

years, then stabilize once revegetation and canopy expansion proceeds to shade the soil, then perhaps 

becoming a C sink from increased tree growth and vigor. This is all largely speculative, as current science 

has not yet formed reliable principles on effects of such practices, particularly belowground. Regardless, 

these effects would be temporary as the overstory canopy closes, understory fills in, and forest floor layers 

increase in depth over several years. Thus, such effects are expected to be short- to mid-term, minor, and not 

relevant to long-term soil productivity. The scale of the proposed activities is not large enough to make net 

carbon sink or source estimates relevant to local or larger scale climate effects.

With thinning as a silvicultural practice, residual stocking of trees is supposed to be high enough to fully 

occupy the site, so finite soil moisture and nutrient resources are still fully utilized, just reallocated to 

fewer individual trees. Therefore thinning should have little effect on soil moisture or nutrient status. 

Trees will increase growth rates, expand crown and root systems, and would generally be healthier and 

more resistant to drought and insect attack with more available water and xylem flow.

Increased organic matter mineralization rates, as mentioned above, can provide short term benefits to 

microbial activity and soil nutrient status, but as that nutrient capital is ‘used up’ more rapidly, it can also 

possibly lead to nutrient deficits later. Conservation of surface organic matter as proposed with these 

activities is intended to maintain adequate nutrient cycling and prevent nutrient deficits. Often 

overlooked, the root systems of trees and vegetation that are removed remain in the soil, and slowly 

decompose to provide organic matter inputs directly within the soil, as well as provide readily available 

growth pathways for new roots through compacted soil. This is currently thought by investigators to be 
Chapter 3. Environmental Consequences

120 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

the probable explanation for a general lack of negative effects on tree growth with extreme experimental 

compaction in the Long-Term Soil Productivity study (Powers et al. 2005, Ponder Jr. et al. 2012, Zhang et 

al. 2017, Busse et al. 2017). This experiment also tested effects of complete organic matter removals on 

soil nutrient status and tree growth, with no negative effects overall in the first 20 years to date. Thus, 

short-term pulse changes in organic matter presence and distribution upon the soil are not expected to 

significantly affect soil productivity.

Given direct localized impacts described above, mainly associated with ground-based operations, this 

should be balanced against a reduced potential for future wildfires to damage the soil in a more harmful 

fashion. On a Regional basis, fire is considered a much larger threat to soil productivity than active 

management activities, because the cumulative annual ‘footprint’ of fire is dramatically larger, and it 

causes much more erosion, which represents the most irreversible and irretrievable kind of soil damage. 

However, it is also unknown with what severity a future wildfire would burn on these particular areas, 

depending not just on fuels, but topography and weather conditions at the time as they influence fire 

behavior. It is reasonable to assume that fuel reduction activities should help moderate future fire 

behavior, and therefore benefit soil resources, at a cost of management impacts today. This is considered 

acceptable, as long as management related impacts are minor in scale. Soil impacts associated with 

proposed activities are expected to be mostly minor in severity, and ultimately minor in scale.

In summary, indirect effects of proposed activities upon the soil resource are generally neutral or 

beneficial, are short-term in nature, and no adverse or long-term indirect effects are foreseen.

Cumulative Effects

Past timber harvest activities have occurred in approximately 40 percent of the project area (FACTS). 

There were past regeneration harvests followed by broadcast burning for site prep, replanting, and 

subsequent thinning about 20 years later. These old 1960s to 1970s clearcuts are today’s plantations. Soil 

impacts at the time for ground-based clearcuts were no doubt significant, considering size and volume of 

materials skidded and removed, and larger, heavier equipment conventionally used for skidding at the 

time (Table 20 and Table 21).

Most relevant for soil resources, regardless of past methods the remaining footprint of past activities can 

and was observed in the field, and current soil condition assessed accordingly. Where past impacts cannot 

be observed today, they were likely minor impacts that have naturally recovered and are not significant

today, or else they would still be apparent. This is bolstered by the finding that almost all of the lasting 

past impacts that were observed are not judged to be detrimental severity or significant in aerial extent 

today. There are no additional foreseen future projects within the bounded analysis area. Presumably there 

will be future management actions in the vicinity at some point, but it is unknowable at this time as to 

what those actions may consist of, where they would be located, or the management setting and 

operational environment (e.g., biomass harvest, restoration, post-wildfire, revised LRMP standards, etc.).
Chapter 3. Environmental Consequences

Final Environmental Assessment – 121

Table 20. FACTS database activities intersecting with project units.

Table 21. Ruth Timber Sale activities intersecting with project units.

The Proposed Action and connected activities are to take place over the next approximately 15 years; for 

analysis purposes, these are collectively considered the “present” action regardless of implementation 

timing. To reiterate, the cumulative effects assessment area for the soils resource is bounded in space 

within the proposed activity units, including area with connected actions such as road decommissioning 

and landing rehab treatments, because this is the full extent of where soil-disturbing activities are to take 

place. Effects analysis is bounded in time by Past, Present, and Reasonably Foreseeable Future Actions 

within this area, summarized below:

o Past: Effects of past management have almost entirely naturally recovered, with only a small 

portion of the old harvest footprint having soil disturbance that qualifies as detrimental under 

current soil management standards. Field review indicated that almost all of the previously 

managed stands have less than 5 percent of the area with detrimental disturbance currently.

o Present: Impacts of the Proposed Action will by design occupy less than 15 percent of the area of 

any individual unit, and will re-utilize old access roads, skid trails, and landings where possible, 

again to limit cumulative effects for individual units as a whole. “Where possible” is indefinite, 

sometimes reutilization of prior access routes and landings is not operationally pragmatic; it is 

expected from field review for this project that reutilization is entirely feasible. The direct and 

indirect effects of the Proposed Action are minimized to the degree possible, in severity and 

extent (considered in tandem), partly due to the application of integrated PDFs.

o Future: There are no known future planned activities that will have any foreseeable adverse 

effects intersecting with the current project’s analysis area.

Silvicultural Rx From To Acres

Commercial Thin 5.6

Sanitation 15.5

Shelterwood 34.7

Shelterwood Removal 25.9

Single Tree Selection 69.0

Clearcut 6.1

Total 1984 1987 157

Year

FACTS database -- Activity Type From To Acres

Commercial Thin 1983 1983 18

Sanitation Cut 1983 1983 16

Seed-tree Seed Cut (with and without leave trees) (EA/RH/NFH) 1982 1990 106

Shelterwood Removal Cut (EA/NRH/FH) 1983 1986 14

Single-tree Selection Cut (UA/RH/FH) 1974 1983 106

Stand Clearcut (EA/RH/FH) 1968 1982 77

Total 1968 1990 337

Fiscal Year
Chapter 3. Environmental Consequences

122 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Current existing detrimental effects of past actions are minimal in extent area. The Proposed Action 

alternative by itself would not produce significant amounts of adverse direct or indirect soil impacts, 

using 15 percent area in detrimental soil conditions collectively as the threshold used to determine if soil 

impacts are significant, per current management direction. There are no reasonably foreseeable future 

actions, which would produce significant impairment of soil quality or productivity. Thus there are no 

additive significant effects of past, present, and foreseeable future actions expected, and therefore by 

definition no significant cumulative effects for soil resources.

The Proposed Action is design consistent with the regulatory framework outlined above. Forest plan 

S&Gs and SQS are intended to comply with NFMA, maintaining soil productivity. Standards and 

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

of expected soil impacts, spatially and temporally. Implementing project-specific PDFs are intended to 

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

productivity is maintained within this project area.

Cultural Resources

Introduction

This section presents the predicted effects of the Proposed Action as compared to the No Action 

Alternative on cultural resources.

Environmental Consequences

Methodology

The Forest Service is directed to identify, evaluate, treat, protect, and manage historic properties by 

several laws. However, the National Historic Preservation Act of 1966, as amended (16 USC 470 et seq.; 

NHPA), provides comprehensive direction to federal agencies about their historic preservation 

responsibilities. Executive Order 11593 – Protection and Enhancement of the Cultural Environment (May 

13, 1971), also includes direction about the identification and consideration of historic properties in 

federal land management decisions.

The NHPA extends the policy in the Historic Sites Act of 1935 (49 Stat. 666; 16 USC 461-467) to include 

resources that are of state and local significance, expands the National Register of Historic Places 

(NRHP), and establishes the Advisory Council on Historic Preservation (ACHP) and State Historic 

Preservation Officers (SHPO). Section 106 of NHPA directs all federal agencies to take into account 

effects of their undertakings (actions, financial support, and authorizations) on properties included in or 

eligible for the National Register. The ACHP’s regulations (36 CFR 800) implements NHPA §106. 

Section 110 of NHPA sets inventory, nomination, protection, and preservation responsibilities for 

federally owned historic properties.

Section 106 of the NHPA and the ACHPs implementing regulations, Protection of Historic Properties (36 

CFR Part 800), require that federal agencies take into account the effect of their undertakings on historic 

properties, and that agencies provide the ACHP with an opportunity to comment on those undertakings. 

Programmatic agreements (36 CFR 800.14(b)) provide alternative procedures for complying with 36 CFR 

800. Region 5 has such an agreement: Programmatic Agreement among the USDA Forest Service, Pacific 

Southwest Region (Region 5), California State Historic Preservation Officer, Nevada State Historic 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 123

Preservation Officer, and the Advisory Council on Historic Preservation Regarding the Processes for 

Compliance with Section 106 of the National Historic Preservation Act for Management of Historic 

Properties by the National Forests of the Pacific Southwest Region (R5 PA; USDA Forest Service 2013b). 

The R5 PA was adhered to in order to comply with the §106 process.

Executive Order 11593 directs federal agencies to inventory cultural resources under their jurisdiction, to 

nominate to the NRHP all federally owned properties that meet the criteria, to use due caution until the 

inventory and nomination processes are completed, and to assure that federal plans and programs 

contribute to preservation and enhancement of non-Federally owned properties.

The forest’s LRMP cultural resource-specific S&Gs are outlined below:

o A cultural resources inventory would be completed for any proposed activity that could affect 

cultural resources. Results of these inventories would be documented in a project specific 

Cultural Resources Inventory Report (CRIR). A certified archaeological surveyor, archaeologist, 

or historian would conduct the cultural resource inventory.

o The significance of and effects on inventoried sites would be evaluated by an archaeologist or 

historian. Consultation with the California SHPO and the ACHP would take place as required.

o Identified cultural resources would be protected from disturbance and artifact theft through the 

implementation procedures outlined for the National Preservation Act and the Archaeological 

Resources Protection Act (ARPA).

o Proposed projects with potential to affect local Native American cultural values or contemporary 

uses, or in location known as traditional Native American spiritual use area, would be discussed 

with a cross section if the local Indian population and tribal governments. These discussions 

would take place in the early stages of planning and environmental analysis to identify possible 

mitigation opportunities or alternatives.

Alternative 1 – No Action

Direct Effects

There are no direct effects of choosing the No Action Alternative.

Indirect Effects

There are no indirect effects of choosing the No Action Alternative.

Cumulative Effects

There are no archaeological sites that would be impacted by Alternative 2 (Proposed Action); therefore, 

there would be no cumulative effects.

Alternative 2 – Proposed Action

Direct Indirect Effects

In order to comply with the regulatory framework regarding the protection of cultural resources, pre-field 

research was conducted consisting of examination of previous archaeological surveys in the planning 

area, site records, maps, and GIS data. This data indicated that seven of those surveys were conducted 

within the Area of Potential Effect (APE), defined as the project’s treatment units. These surveys have 

been carried out between 1978 and 2012.
Chapter 3. Environmental Consequences

124 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

The surveys resulted in the identification of 10 archaeological site, none of which is located within the 

APE. Archaeological surveys were conducted within the project’s APE between October 2016 and August 

2017 and recorded in a CRIR on file in the Heritage Department of the SRNF Supervisor’s Office. Two 

archaeological sites were identified because of the archaeological surveys.

Standard resource protection measures as defined in the R5 PA would be applied to fully protect 

archaeological sites within the APE.

Cumulative Effects

There are no cumulative effects associated with Alternative 2 – Proposed Action.

Threatened, Endangered, Sensitive Botanical Resources

Introduction

A BA/BE was prepared for this project and is included in the project file (McRae 2018). The objectives of 

this biological assessment/evaluation are (a) to determine the effects of the 1st 48 Project on any TES 

vascular plant, bryophyte, lichen, or fungi species and (b) to insure these species receive full consideration 

in the decision-making process to maintain species viability (USDA Forest Service 2005).

No federally listed plant species are known to occur, nor does suitable habitat exist in the project area.

Two Forest Service Sensitive botanical species were found to occur within the project planning area, the 

mountain lady’s slipper orchid and the waterfan lichen. Although both occur in the planning area, they 

have been buffered out of the project area (the units). Both species are also managed under S&M S&Gs 

and addressed in the S&M report developed for this project. A no-action buffer of approximately 0.5 acres 

was marked on the ground at the mountain lady’s slipper orchid site, most, if not all of which occurs in 

the riparian reserve associated with Dashield Creek. The buffer was delineated in the field to account not 

only for protection of the species but also to account for habitat elements associated with mountain lady’s 

slipper, specifically overstory shading and existing canopy layers, existing moisture conditions, 

maintenance of CWD, maintenance of existing tree, shrub and forb diversity, and adequate habitat around 

the existing plants for short-range dispersal of seeds and rhizome.

The waterfan lichen, a submerged aquatic lichen, also occurs within the riparian reserve associated with 

Dashield Creek. This is the only known occurrence for this species on the SRNF. This occurrence was not 

buffered in the field because of its location submerged in Dashield Creek.

Because both sites occur in riparian reserves, are outside the project area (the units) and the mountain 

lady’s slipper orchid site is within a no action buffer, there is no effect to either species under either 

Alternative 1 (No Action Alternative or Alternative 2 (Proposed Action).

The potential exists for the following Forest Service Sensitive fungi species to occur in the project area: 

Dendrocollybia racemosa, Sowerbyella rhenana, Phaeocollybia olivaceae, Boletus pulcherrimus and 

Tricholomopsis fulvescens. Silvicultural and fuels design, PDFs and LRMP S&Gs, as described below, 

reduce the level of negative direct and indirect impacts under Alternative 2 to sensitive fungi. 

Implementation of Alternatives 2 may affect individuals, but is not likely to result in a trend toward 

federal listing or loss of viability of Sensitive fungi species.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 125

Environmental Consequences

Methodology

A pre-field analysis was used to determine which units to survey within commercial timber, biomass, and 

shaded fuelbreaks, the spatial context for analysis where direct, indirect and cumulative effects are likely 

to occur over the life of the project. The analysis included review and consideration of 1) the Forest 

Sensitive species database and associated spatial layers of known occurrences relative to the project area, 

2) Geographic Information System (GIS) spatial layers of the vegetative subseries and stand age in which 

the project occurs, 3) elevation gradient of the project area, 4) land-use history, 5) aerial photo 

interpretation, and 6) professional knowledge of TES species habitat and distribution on the forest.

Average elevation in the planning area is approximately 4100 feet (range 2,800 to 5,400 feet). The 

vegetation associations in the project area where the shaded fuelbreak is proposed under Alternative 2 

include Black Oak-Douglas-fir, Black Oak-Greenleaf Manzanita, Black Oak-Ponderosa Pine, Black OakWhite Fir, Brewer Oak-White Fir, Chaparral-Whitethorn, Deerbrush Shrubland, Douglas-fir/Deerbrush, 

Douglas-fir/Greenleaf Manzanita, Douglas-fir-Bigleaf Maple, Douglas-fir-Black Oak, Douglas-firCanyon Live Oak, Douglas-fir-Herb, Douglas-fir-Incense Cedar, Douglas-fir-Oregon White Oak, 

Douglas-fir-Ponderosa Pine, Douglas-fir-White Fir, Grassland-Unknown, Gray Pine-White Oak, 

Mountain Meadow Unknown, Ponderosa Pine-Black Oak, Ponderosa Pine-Douglas-fir, Ponderosa PineIncense Cedar, Ponderosa Pine-White Fir, Ponderosa Pine-White Oak, White Fir-Black Oak, White FirBrewer Oak, White Fir-Douglas-fir, White Fir-Incense Cedar, White Fir-Ponderosa Pine, White Fir-Red 

Fir, White Fir-White Fir, White Fir-White Oak, White Oak-Black Oak, White Oak-Buckbrush, White 

Oak-Gray Pine, White Oak-White Fir, White Oak-White Oak. Seral stages range from grass/forb to old 

growth, with a majority of the project area composed of early seral conditions (Table 22).

Table 22. Seral stage composition in shaded fuelbreak.

Seral Stage % of Acreage in Fuelbreak

Grass/Forb 0.7

Shrub 5.6

Pole 8.9

Early mature 42.5

Mid-mature 29.1

Late-mature 09.3

Old-growth 3.0

As a result of potential habitat information garnered from review of the spatial coverages, air photo 

review, field reconnaissance, and intuitively controlled surveys in the stands, a total of 341 acres of the 

approximately 821 acres proposed for treatment were surveyed. Units or portions thereof not subject to 

survey were plantations, portions of natural stands characterized as even-aged early mature stands with 

little stand structure, riparian reserves since these areas are essentially protected from intensive activities, 

and units within vegetation types not considered suitable for sensitive species. An example of the latter 

could be the Douglas-fir-Canyon live oak subseries, which is characterized by high surface rock content, 

a characteristic not suitable for the target species.

Based upon pre-field analysis, including a query of the USFWS IPaC database (USDI Fish and Wildlife 

Service 2018) no federally listed or proposed plant species are known to occur within the 1st 48 Project

planning area nor is suitable habitat present. The non-fungal Sensitive species targeted for field surveys 
Chapter 3. Environmental Consequences

126 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

were mountain lady’s slipper (Cypripedium montanum), fascicled lady’s slipper, (Cypripedium 

fasciculatum), small-flowered calycadenia (Calycadenia micrantha), and the waterfan lichen (Peltigera 

gowardii) Surveys were conducted for Sensitive fungi species by a mycologist who focused on areas of 

suitable habitat. His report and survey field forms can be found in the project record (Davidson 2018). 

Targeted Sensitive fungi species included Boletus pulcherrimus, Dendrocollybia racemosa, 

Phaeocollybia olivaceae, Sowerbyella rhenana, and Tricholomopsis fulvescens.

Surveys for the 1st 48 Project for all Sensitive species in Table 23, except for the fungi species, occurred 

in July 2017 when they were identifiable. Approximately 58 percent of the proposed fuelbreak was 

considered unsuitable habitat for Sensitive species and therefore was not surveyed. Unsuitability related 

to seral stage and resultant stand conditions, specifically those units/areas in the shrub-harvest, poleharvest, early mature with harvest and early mature stands seral stages. Table 22 above displays the 

percentage of each seral stage within the fuelbreak. All mid mature, late mature and old growth within the 

fuelbreak was surveyed. In addition, dry, open rocky grassland and hillsides were surveyed for 

Calycadenia micrantha.

Table 23. Sensitive species considered in the project as a result of pre-field analysis.

Common Name Scientific Name Known (K) or 

Potential (P)

Taxonomic 

Group General Habitat/Substrate

Bryophyte

Bug-on-a-stick Bauxbaumia viridis P Bryophyte Late decay class down logs

Vascular Plants

Small-flowered 

calycadenia Calycadenia micrantha P Vascular plant Dry open rocky grassland and hillsides

Fascicled lady’s 

slipper Cypripedium fasciculatum P Vascular plant Mature forest

Mountain lady’s 

slipper Cypripedium montanum P Vascular plant Mature forest

Lichen

Waterfan lichen Peltigera gowardii K Aquatic Lichen Cool mountain streams that run 

year-round.

Fungi

N/A Boletus pulcherrimus P Fungus Mature forest/ectomycorrhizal

N/A Dendrocollybia racemosa P Fungus Mature forest/parasitic

N/A Phaeocollybia olivacea P Fungus Mature forest/ectomycorrhizal

N/A Sowerbyella rhenana P Fungus Wet mossy areas under 

conifers/saprobe on litter

N/A Tricholomopsis fulvescens P Fungus Mature forest/ectomycorrhizal

Because the Sensitive fungi species noted above are also managed under S&M S&Gs, surveys were 

conducted in November utilizing S&M survey equivalent effort survey protocols where applicable. 

Surveys for Sensitive fungi in stands that are not old growth are not required under S&M S&Gs. 

However, because commercial treatments are proposed in old-growth habitat within the fuelbreak, S&M 

protocols require equivalent effort surveys (strategic surveys; USDA and USDI 2001).

Survey Results

Table 24 summarizes the survey results relative to units within the Proposed Action.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 127

Table 24. Survey results, Sensitive species detected in the planning area.

Species Taxonomic Group Unit

Mountain lady’s slipper orchid (Cypripedium montanum) Vascular plant In inner gorge of Dashield Creek in riparian

reserve. Site buffered; flagged and painted.

Waterfan lichen (Peltigera gowardii) Lichen In Dashield Creek, south of Unit 418 and in 

riparian reserve adjacent to Units 412 and 421.

The following provides information on what is known or suspected about the biology and ecology of the 

species with relevance to the proposed activities and effects analysis that follows. Regarding Sensitive 

fungi, little if any information is known about management effects to a particular species, therefore, 

species will at times be addressed in the context of their particular habit or taxonomic group.

Mountain lady’s slipper orchid

The mountain lady’s slipper orchid was the only Sensitive species located are within the proposed 

fuelbreak. Project design features associated with activities within the fuelbreak units are disclosed in 

Chapter 2 of this EA.

Mountain lady’s slipper is found in a broad range of habitats throughout the western United States and 

Canada. In California, there are roughly 200 populations of mountain lady’s slipper; however, between 50 

to 70 percent have not been visited in the last five (5) years (Kaye and Cramer 2005). Including the one 

detection associated with this project, there are currently 17 extant populations of mountain lady’s slipper 

on SRNF ranging from the Orleans RD to Mad River RD.

Habitat attributes related to aspect (northerly), canopy cover ( greater than 60 percent) and seral stage 

(mid-mature and older), and the population sizes (fewer than 10 stems) in the project area are in keeping 

with those attributes ascribed the species by Kaye and Cramer (2005) in the Region 5 Forest Service 

Conservation Assessment for this species. Besides the aforementioned habitat attributes assigned 

mountain lady’s slipper, this species also requires the presence of a fungus in its early stage of 

development thus the presence of host trees and organic matter that favor fungal associations are also 

critical habitat element.

Conditions conducive for the health of existing mountain lady’s slipper populations are those that provide 

for partial canopy cover, native understory and forest floor species associates, host species for 

mycorrhizal fungi and organic matter cover on the forest floor that sustains the fungus, and suitable 

habitat surrounding the parent population for subsequent recruitment.

Waterfan lichen

The waterfan lichen is endemic to North America. It has been historically reported in all four (4) major 

mountain chains in the United States but has apparently been extirpated in most of the Appalachians 

(Dennis et al. 1981). The one known occurrence on SRNF occurs within the project area along Dashield 

Creek at the following locations.

The waterfan is an aquatic lichen and as such, its characteristic habitat is cool pollution free moving water 

in mountain streams where it occurs on submerged rocks. It is a good indicator of water quality.

Sensitive Fungi Species

Little if any information is known about management effects to a particular Sensitive fungus; therefore,

species will be addressed in the context of their particular habitat and ecological function. The three fungi 

species listed that may occur within the project area can be divided into three groups: saprobic, 
Chapter 3. Environmental Consequences

128 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

mycorrhizal, and parasitic. Sowerbyella rhenana is saprobic meaning that it is a decomposer, thriving on 

the litter and duff of the forest floor. Litter saprobes, such as this species, can extend over a large area, via 

mycelial networks. Relatively shady and moist to mesic mature stands with various sized litter (including 

some CWD) describe the habitat for saprobes. Phaeocollybia olivaceae, Boletus pulcherrimus and

Tricholomopsis fulvescens are mycorrhizal. Mycorrhizal fungi form interdependent relationships with their 

host tree, exchanging nutrients, minerals, and water. Dendrocollybia racemosa is parasitic on decaying 

fungi. Common to all of these fungal groups are habitat conditions characterized by shady, mid- to latemature stands with conifer or hardwood hosts and ample organic substrate (e.g., leaf, needle, woody 

debris). Networks of fungal hyphae or mycelia (the body of the fungus) group together into strands. These 

networks scavenge nutrients from the surrounding soils, acting as an extension to the root system. These 

hyphae can grow to infect nearby plant roots and can eventually connect neighboring plants. This network 

facilitates carbon transfer from the host to the fungus. Networks also facilitate water transfer (Bruns 1995).

Management that retains living trees (the host) and the important underground linkages for mycorrhizal 

fungi via the mycelial network will maintain habitat parameters for mycorrhizal species (Amaranthus and 

Perry 1994). Likewise, management that retains overstory canopy and the litter and CWD of the forest 

floor will maintain habitat parameters for saprobes (Norden et al. 2004). Factors considered when 

assessing risk to sensitive fungi were overstory shading, presence of host trees or shrubs, and presence of 

litter, duff and CWD. Issues to consider when evaluating effects to Sensitive fungi for the 1st 48 Project

pertain to activities occurring in mid-mature and older stands, which only includes fuels projects and the 

a) extent of understory vegetation removal, b) burn intensity and d) burn interval.

Cumulative Effects to Sensitive Botanical Species

Implementation of this project is not expected to result in any direct or indirect impact to either the 

mountain lady’s slipper orchid or the waterfan lichen; therefore, there would be no cumulative effects 

posed by this project to Sensitive Botanical species.

Sensitive Fungi

Implementation of this project may directly or indirectly impact sensitive fungi species. Cumulative effect 

activities and events relate to clearcutting (or similar cutting) in mid- and older seral stages and wildfire 

intensities.

As mentioned above in the introductory section, past logging methods in the planning area emphasized 

clearcutting, which removed habitat associated with sensitive fungi. While fungi can tolerate lowintensity fire, a wildfire that is stand replacing, like clearcuts, also removes habitat for sensitive fungi. The 

practice of clearcutting and past high-intensity wildfires have influenced the percentage of the planning 

area within a given seral stage; however, the current distribution of mature seral stages (habitat for 

sensitive fungi) is still within the Douglas-fir recommended management range thresholds for the 

planning area and within the white fir recommended management range thresholds within the south zone, 

which is the entire Mad River RD.

Silviculture prescriptions are no longer oriented toward clearcutting, but focus more on thinning. The 

scale and intensity of foreseeable future timber and fuels activities in logged stands on the Forest, along 

with PDFs, are not likely to significantly degrade habitat for sensitive fungi. Thinning prescriptions 

coupled with recommended management range guidelines for the mid-seral and older stands would 

further reduce the significance of concerns for retention of fungal habitat in the future. Foreseeable future 

wildfire in conifer stands is expected to be of mixed severity and as such is not likely to negatively impact 

sensitive fungi, and may actually benefit fungi by diversifying the structure of forest floor organics.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 129

While local extirpations may have occurred and may occur in the future, these losses would not constitute 

a trend toward federal listing or loss of viability as a result of cumulative effects in the planning area. 

Future extirpations would be limited by type of prescription, PDFs, and recommended management range 

guidelines. Other factors include a) the potential for sensitive fungi to occur underground or associated 

with stable substrates (logs) in undisturbed stands surrounding the affected area, b) the ability of spores to 

move into a disturbed area from the surrounding forest and persist as mycelia underground or in the 

substrate, and c) the geographic distribution of most of these species south (as far as the northern Sierras) 

of the project area and into the Pacific Northwest.

Alternative 1 – No Action

Direct Effects

There are no direct effects of choosing the No Action Alternative.

Indirect Effects

There are no indirect effects of choosing the No Action Alternative.

Cumulative Effects

There are no direct or indirect effects of choosing Alternative 1; therefore, there are no cumulative effects.

Alternative 2 – Proposed Action

Direct Effects

Mountain Lady’s Slipper Orchid

There are no direct effects to the mountain lady’s slipper orchid from implementing Alternative 2 based 

on the following:

o The site occurs in the riparian reserve and is afforded protection under this land allocation. 

Additionally, a no disturbance buffer was flagged in the field. No activities would occur in this 

buffer, which includes not felling trees in the buffer. Therefore, there would be no direct effects.

o Edge effects are reduced to a negligible level in light of the buffer size of 0.40 acres whose 

effectiveness is enhanced due to its proximity to a thinned stand (versus regenerated stand).

o In terms of indirect impacts, the buffers were delineated in the field to account not only for 

protection of the plants but to account for habitat elements associated with mountain lady’s 

slipper, specifically overstory shading and existing canopy layers, existing moisture conditions, 

maintenance of CWD, maintenance of existing tree, shrub and forb diversity, and adequate habitat 

around the existing plants for short-range dispersal of seeds and rhizome.

Waterfan Lichen

Due to the occurrence of the waterfan lichen in a riparian environment and its absence from the project 

area (the units), there are no direct effects to the waterfan lichen from implementing Alternative 2.

Sensitive Fungi

Effects to sensitive fungi are discussed in light of the magnitude of change in potentially suitable habitat 

as a result of project implementation. Effects are associated with activities occurring within the midmature and older stands slated for treatment. Direct effects associated with actions proposed under 

Alternative 2 pertain to removal or severance of mycelial components (which comprise the fungal 

organism) residing in the organic or topsoil layer for mycorrhizal fungi.
Chapter 3. Environmental Consequences

130 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Silviculture and fuels design, PDFs and LRMP S&Gs reduce the level of negative impacts to sensitive 

fungi. Silviculture and fuels design includes a) the nature of the silvicultural treatments (thinning from 

below, variable density, retention of existing species diversity) that allow for structural diversity, retention 

of host trees and partial shade to the forest floor, and b) the nature of the fuels treatment in the units which 

focus on thinning, pruning and piling of small diameter trees and shrubs within a limited space near roads. 

Project design features and LRMP guidelines oriented toward soils or wildlife that also benefit sensitive 

fungi and include:

o For each unit, soil porosity would be maintained to at least 90 percent of its natural condition over 

at least 85 percent of the unit area.

o Skid roads and trails would be limited to no more than 15 percent of the harvest area.

o At the end of project activities, a layer of litter and duff would occur over at least 50 percent of 

the activity area.

o In all treatment units, retain at least five logs per acre of existing CWD (at least 20 inches in 

diameter and 10 feet long) on the ground.

o All existing large snags (20 inches or greater in diameter) would be retained in units unless they 

pose a safety concern.

While not eliminating effects to fungi, it is assumed by managing for habitat elements in stands to be 

thinned, adverse effects to sensitive fungi species can be reduced. Effects of relatively small-scale 

activities are not likely to significantly reduce the fungal species diversity that was in place prior to the 

disturbance (Durall et al. 1999). In certain areas in a stand, meso-habitat features would be impacted by 

skidding, felling of canopy trees, yarding tops, end-lining or pile burning, but mycelial networks can 

extend several meters through the forest floor, so conceivably localized impacts may impact or sever part 

of the fungal individual but would not necessarily impact the entire body of the organism. Furthermore, if 

vegetative and soil conditions are retained in places within the unit, spores stored in the soil provide a 

propagule for development of fungi after the disturbance. These impacted areas would recover in time and 

along with it the development of fungal communities (Dahlberg and Stenlid 1995).

Based on the aforementioned, implementation of Alternatives 2 may affect individuals, but is not likely to 

result in a trend toward Federal listing or loss of viability of sensitive fungi species.

Indirect Effects

Mountain Lady’s Slipper Orchid and Waterfan Lichen

There are no indirect effects to the mountain lady’s slipper orchid or the waterfan lichen from 

implementing Alternative 2.

Sensitive Fungi

Indirect effects to Sensitive fungi associated with actions proposed under Alternative 2 pertain to 

reduction in canopy shade and organic forest floor cover, reduction in the abundance of host trees and 

refuge species to sustain inoculum through periods of successional change in the stand, removal or 

reduction of forest floor organics and CWD which form the primary micro-habitat for saprobic species, 

and breakdown of soil structure (e.g., compaction) which not only affects the mycelia therein but also 

damages fine root tips to which the mycelia attach. (Amaranthus et al. 1996). See the discussion under 

direct effects to Sensitive fungi species regarding how the management of habitat elements can reduce 

effects to these species.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 131

Cumulative Effects

Mountain Lady’s Slipper Orchid and Waterfan Lichen

There are no direct or indirect effects to the mountain lady’s slipper orchid or the waterfan lichen from 

implementing Alternative 2; therefore, there are no cumulative effects.

Sensitive Fungi

Implementation of this project may directly or indirectly impact sensitive fungi species. Cumulative effect 

activities and events relate to clearcutting (or similar cutting) in mid- and older seral stages and wildfire 

intensities. As mentioned above in the introductory section, past logging methods in the planning area 

emphasized clearcutting, which removed habitat associated with sensitive fungi. While fungi can tolerate 

low-intensity fire, a wildfire that is stand replacing, like clearcuts, also removes habitat for sensitive 

fungi. The practice of clearcutting and past high-intensity wildfires have influenced the percentage of the 

planning area within a given seral stage; however, the current distribution of mature seral stages (habitat 

for sensitive fungi) is still within the Douglas-fir recommended management range thresholds for the 

planning area and within the white fir recommended management range thresholds within the south zone, 

which is the entire Mad River RD.

Silvicultural prescriptions are no longer oriented toward clearcutting, but focus more on thinning. The scale 

and intensity of foreseeable timber (e.g., Cedar Gap, Kelsey Peak) and fuels activities in logged stands on 

the forest, along with PDFs, are not likely to significantly degrade habitat for sensitive fungi. Thinning 

prescriptions coupled with recommended management guidelines for the mid-seral and older stands would 

further reduce the significance of concerns for retention of fungal habitat in the future. Foreseeable future 

wildfire in conifer stands is expected to be of mixed severity, and as such, is not likely to negatively impact 

sensitive fungi, and may actually benefit fungi by diversifying the structure of forest floor organics.

While local extirpations may have occurred and may occur in the future, these losses would not constitute 

a trend toward federal listing or loss of viability as a result of cumulative effects in the planning area. 

Future extirpations would be limited by type of prescription, PDFs, and recommended management range 

guidelines. Other factors include a) the potential for sensitive fungi to occur underground or associated 

with stable substrates (logs) in undisturbed stands surrounding the affected area, b) the ability of spores to 

move into a disturbed area from the surrounding forest and persist as mycelia underground or in the 

substrate, and c) the geographic distribution of most of these species south (as far as the northern Sierras) 

of the project area and into the Pacific Northwest.

Determination

Based on the above it is my determination that the 1st 48 Project would not affect either the mountain 

lady’s slipper orchid (Cypripedium montanum) or the waterfan lichen (Peltigera gowardii).

With the aforementioned PDFs in place for Sensitive fungi species, the 1st 48 Project may affect individuals 

but is not likely to lead to a trend toward Federal listing or a loss of viability for Boletus pulcherrimus, 

Dendrocollybia racemosa, Phaeocollybia olivaceae, Sowerbyella rhenana , Tricholomopsis fulvescens.

Survey and Manage Plants

Introduction

This section presents the predicted effects of the Proposed Action as compared to the No Action 

Alternative on Survey and Manage (S&M) botanical resources.
Chapter 3. Environmental Consequences

132 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Environmental Consequences

Methodology

Survey and Manage Guidance 2018 – Six Rivers National Forest

This document is intended to provide a summary of the current S&M status and management direction to 

address those S&M vascular, non-vascular and fungi species that correspond to the 1st 48 Project area.

Forest Service Correspondence, File Code 1950 – Direction Regarding the Survey and Manage Standards 

and Guidelines, May 13, 2014 provides the current Forest Service direction for the S&M program. At this 

point in time, project work on SRNF will be considered under either option 2a or 2b, unless the project 

record can demonstrate that “Survey and Manage pre-disturbance survey(s) have been initiated (defined 

as “at least one occurrence of actual in-the-field surveying undertaken according to applicable protocol”) 

for the project.

Under Option 2, management direction is dependent on when the project was initiated. Initiated is defined 

in this context as “scoping [has been] initiated or the project is entered into the Schedule of Proposed 

Actions”. Districts can choose which direction to follow, if the project was initiated prior to April 30, 

2015, the project can follow the direction in (a) or (b) below. Projects initiated after April 30, 2015 must 

follow direction in (b):

a. “The January 2001 ROD standards and guidelines and the associated January 2001 species list, 

and/or the four categories of projects exempt from the Survey and Manage standards and 

guidelines as stipulated by Judge Pechman (October 11, 2006 Pechman exemptions). Same as 

previous June 12, 2013 Interim Direction.

b. The January 2001 ROD standards and guidelines and the December 2003 species list, except for 

the red tree vole which remains as Category C across its range, and/or the four categories of 

projects exempt from the Survey and Manage standards and guidelines.”

Exemptions

The four (4) categories of projects exempt under Option 2b for the S&M S&Gs, as stipulated by Judge 

Pechman (October 11, 2006, “Pechman exemptions”), are:

o Thinning projects in stands younger than 80 years old;

o Replacing culverts on roads that are in use and part of the road system, and removing culverts, if 

the road is temporary or to be decommissioned.

o Riparian and stream improvement projects where the riparian work is riparian planting, obtaining 

material for placing in-stream, and road and trail decommissioning; and where the stream 

improvement work is the placement of large wood, channel and floodplain reconstruction, or 

removal of channel diversions; and

o The portions of projects involving hazardous fuel treatments where prescribed fire is applied. Any 

portion of a hazardous fuel treatment project involving commercial logging will remain subject to 

the S&M requirements except for thinning of stands younger than 80 years old under 

subparagraph a of this paragraph.

Trigger and the need for survey of the proposed project area, three criteria must be evaluated:

o It must occur within the suspected range of a species covered by the appropriate protocol (by year 

and species).
Chapter 3. Environmental Consequences

Final Environmental Assessment – 133

o It must occur within suitable habitat for those target species.

o The proposed project must have the potential of being a habitat disturbing activity, which would 

cause significant negative effect on the species habitat or the persistence of the species at the site.

o The species must occur within the NWFP area, or occur close to the NWFP area and have 

potentially suitable habitat within the NWFP area. The species must be closely associated with 

late-successional or old-growth forest. The reserve system and other NWFP S&Gs do not appear 

to provide for a reasonable assurance of species persistence.

Survey and Manage Vascular Plants, Bryophytes and Fungi

Option 2b is applicable to the 1st 48 Project. This option references the December 2003 species list. The 

list includes numerous fungi species that could occur on the Forest and within the project area. Of the 

plant species, Table 25 below lists the species considered for this project by virtue of the species range 

and the presence of potentially suitable habitat in the project area. Beyond activities captured by the 

Pechman exemptions listed above, the trigger for pre-disturbance surveys is based upon the potential for 

the activity to be habitat disturbing and thus resulting in a “significant negative effect” to the persistence 

of species at the site. The following paragraphs elaborate on the definitions of “habitat disturbance” and 

“persistence at a site.”

Habitat disturbing activities (species habitat) include:

o Defined as those disturbances likely to have a significant negative impact on the species habitat, 

its life cycle, microclimate, or life support requirements.

o The evaluation of the scale, scope, and intensity of the anticipated negative impact of the project 

on habitat or life requirements should include an assessment of the type, timing, and intensity of 

the disturbing activity.

o “Habitat-disturbing” is not necessarily the same as “ground-disturbing”; helicopter logging or 

logging over snow-pack, for example, may not disturb the ground but might clearly affect 

microclimate or life cycle habitat factors.

Exemptions include:

o Routine maintenance of improvements and existing structures is not considered a habitatdisturbing activity. Examples include pulling ditches, clearing encroaching vegetation, managing 

existing seed orchards, and falling hazard trees.

o Pre-disturbance surveys are not required for wildland fires for benefits in designated wilderness. 

Wildland fires for resource benefits are prescribed fires that result from natural ignition, are 

consistent with the applicable LRMP, are addressed in a fire management plan, and are burning 

within prescription (see S&G pg. 22).

o Exemptions to pre-disturbance survey requirements may also be proposed for wildland fire for 

resource benefits in LSR if the LSRA addresses the potential presence and likely effect on S&M 

species, and REO review of that aspect of the Assessment concludes such fire(s) will not prevent 

achievement of the persistence objectives of these S&Gs.

o A line officer should seek a specialist’s recommendations to help determine the need for a survey 

based of site-specific information. The project may not require surveys if no suitable habitat 

exists within the project area, project is outside the range of the species/taxa, or if the project 

design can avoid habitat associated with a given species.

Persistence of the species at the site:
Chapter 3. Environmental Consequences

134 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

o Defined as whether the activity might cause a significant negative effect on the habitat or the 

persistence of the species at the site where the activity is being proposed. There is no reference 

in the S&M S&Gs to look at the watershed, district, or range-wide scales when making this 

determination. It really is not a question about the persistence of the actual species as a whole; 

instead, it is a question about the persistence of a (potential) site of a species.

Species requiring pre-disturbance surveys:

o Pre-disturbance surveys are conducted prior to signing NEPA decisions or decision documents for 

habitat disturbing activities. This applies to Category A and C species, as well as Category B 

fungi if proposed activities are occurring in late-succession forest stands and considered habitat 

disturbing.

o Surveys are conducted using protocols for each species or taxonomic group (e.g., fungi species).

Table 25 includes the S&M botanical species that are known or have the potential to occur in the project 

area and only refers to the list associated with option 2b—those projects initiated after April 30, 2015.

Table 25. List of Survey and Manage plant species that have the potential to, or are known to occur, in the 

project area.

Group Scientific Name S&M Category14 Known or Previously 

documented

Non-vascular plants/Bryophytes

Buxbaumia viridis E Potential

Ptilidium californicum A Potential

Non-vascular plants/Lichen Dendriscocaulon intricatulum E Previously documented

(one site)

Vascular plants Cypripedium fasciculatum C Potential

Cypripedium montanum C Potential

Fungi

Boletus pulcherrimus B Potential

Dendrocollybia racemosa B Potential

Phaeocollybia olivaceae E Potential

Sowerbyella rhenana B Potential

Tricholomopsis fulvescens B Potential

Survey and Manage Species Analysis

Known Sites of Survey and Manage Species

Review of NRIS and other datasets indicated there is one known sites of Dendriscocaulon intricatulum a 

Category E S&M lichen species within the project area in Unit 805. A 0.25-acre no-disturbance buffer has 

been established around this site.

Survey and Manage Species Further Analyzed

Category A and Category C species identified for pre-disturbance surveys were based upon species range 

relative to the project area, presence of suitable habitat in the project area and extent of habitat-disturbing 

activities therein, and current scientific information relative to species taxonomy. As a result of the 

analysis, pre-disturbance surveys were conducted for two vascular plants and one bryophyte. As a result 

of surveys, one new site of the vascular plant Cypripedium montanum (Category C) was detected and two 

new sites of the bryophyte species Ptilidium californicum (Category A).

 14 “2014 option 2b” Project initiated after April 30, 2015.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 135

Alternative 1 – No Action

Direct Effects

Review of NRIS and other datasets indicated there is one known sites of Dendriscocaulon intricatulum, a 

Category E S&M lichen species, within the project area. Category A and Category C species identified for 

pre-disturbance surveys were based upon species range relative to the project area, presence of suitable 

habitat in the project area and extent of habitat-disturbing activities therein, and current scientific 

information relative to species taxonomy. Because of the analysis, pre-disturbance surveys were conducted 

for two vascular plants and one bryophyte. As a result of surveys, one new site of the vascular plant 

Cypripedium montanum (Category C) was detected and two new sites of the bryophyte species Ptilidium 

californicum (Category A). There are no direct effects associated with the No Action Alternative.

Indirect Effects

There are no indirect effects associated with the No Action Alternative.

Cumulative Effects

There are no cumulative effects associated with the No Action Alternative.

Alternative 2 – Proposed Action

Direct and Indirect Effects

The following is an evaluation of habitat disturbing activities relative to the known and newly detected 

S&M species in the 1st 48 Project area. Only vascular plants and non-vascular botanical species would be 

further analyzed. The assessment considers the extent and significance of habitat disturbance, in particular, 

life cycles, microclimate or life support requirements, from actions proposed under Alternative 2.

Dendriscocaulon intriculatum (Manage Known Sites) – in Unit 805

Dendriscocaulon intricatulum is a lichen that grows on the bole and branches of oak trees. As a lichen, it 

exchanges water, gases through its “skin”, and thus is influenced by changes in atmospheric moisture. 

Lichens are most susceptible to changes in their environment when the thallus is hydrated. In this condition, 

lichens are most photosynthetically active, contrarily, no gas exchange occurs in air-dried lichens (Nash 

1996). Changes in atmospheric moisture and its effect on lichens are influenced by temperature. Lichens are 

well adapted to temperatures experienced in their microhabitat (Nash 1996), but tolerances to heat outside 

the natural range of variability can trigger a stress response in the lichen. In a dry state, lichens have a 

tremendous capacity to tolerate heat stress, but when hydrated that tolerance diminishes.

In light of these ecological variables associated with lichens, the 1st 48 Project includes design features 

that would reduce potential negative effects of heat and smoke as well as maintain residual substrate for 

Dendriscocaulon intricatulum. A 0.25-acre buffer (radius approximately 50 feet) was established at the 

detection in Unit 805. This buffer area is considered a no-disturbance buffer. Trees shall not be fallen into 

the buffered area.

Cypripedium montanum (Pre-disturbance Surveys and Site Management) – Adjacent to Unit 421

Potential habitat disturbing activities related to Cypripedium montanum known sites pertain to mechanical 

disturbance that removes plants, disrupts upper soil horizons, triggers a shift in associated species 

composition, and opens the canopy beyond the tolerance threshold of mountain lady’s slipper. Where new 

sites were detected, no-disturbance buffers were established in the field. Buffers were delineated in the 

field to account not only for protection of the plants but to account for habitat elements associated with 

mountain lady’s slipper, specifically overstory shading and existing canopy layers, existing moisture 
Chapter 3. Environmental Consequences

136 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

conditions, maintenance of CWD, maintenance of existing tree, shrub and forb diversity, and adequate 

habitat around the existing plants for short-range dispersal of seeds and rhizome. Trees shall not be fallen 

into the buffered area.

Edge effects were also taken into consideration. Edge effects include changes in air and soil temperature, 

wind velocity, and relative humidity from a given edge into an intact forest. To reduce the potential for edge 

effects to known sites, buffers, their size and dimension, were established with aspect, slope position, and 

proximity to riparian areas in mind. A 0.5-acre buffer was established around the occurrence in the riparian 

zone adjacent to Unit 421. Cypripedium montanum is not only an S&M species, but also Forest Sensitive 

species. A more detailed analysis of effects is included in the BE/BA for this project (McRae 2018).

Ptilidium californicum (Pre-disturbance Surveys and Site Management) – in Units 419 and 805

Potential habitat disturbing activities related to Ptilidium californicum pertain to extent of canopy opening 

and vegetation manipulation in the vicinity of the documented occurrence which could increase drying 

effects of solar radiation and wind, removal of mature trees around the occupied tree, which would 

remove sites for future dispersal opportunities, and broadcast burning that could result in torching the 

base of the occupied tree. Two occurrences of Ptilidium californicum were detected, one in Unit 419 and 

the other in Unit 805, both on the base of a 36-inch-diameter white fir in a mid-mature stands.

A no-disturbance buffer of approximately 0.5 acres was established around the occupied trees to ensure 

the retention of the existing vegetation and stand structure, which provides the shade to the forest floor 

surrounding the occupied tree. The buffer incorporated mature trees for future dispersal opportunities. 

Under the Proposed Action, the silviculture treatments surrounding the buffer would provide peripheral 

shade to the buffer, thereby reducing edge effects, and potentially suitable substrates by retaining predominant, healthy dominant and co-dominant conifers around the buffer. Trees shall not be fallen into the 

buffered area.

With the PDFs in place for Dendriscocaulon intricatulum, Cypripedium montanum, and Ptilidium 

californicum, measures have been provided for the persistence of the species at known sites; therefore, the 

project is consistent with the current S&M direction.

Equivalent Effort Fungi Surveys

Equivalent effort surveys were conducted for potential S&M plant species in July 2017. Survey efforts 

focused on potentially suitable habitat for these species, specifically stands in the mid-mature and older 

seral stages with the structure and canopy cover that defines the habitat. Surveys were performed by a 

mycologist who conducted a reconnaissance of all potential areas within the project area on October 14, 

2017. Approximately 194 acres of suitable fungi habitat were identified for survey. Following S&M 

protocols, the first fungi surveys were conducted from November 10, 2017 to November 12, 2017. There 

were 43 species of fungi, mostly wood rotting saprobes or pathogenic fungi recorded; however, no S&M 

species were detected.

The second survey was from November 28, 2017 to November 30, 2017. During this survey, Ramaria 

rubrievanescens was detected, a Category B S&M fungi requiring management of the known site. The 

site was flagged with a no disturbance buffer and the boundary of unit 402 was moved so that the buffered 

area is now outside of the unit. Trees shall not be fallen into the buffered area.

Ramaria rubrievanescens (Equivalent Effort Surveys and Site Management)

Potential habitat disturbing activities related to Ramaria rubrievanescens pertain to removal or severance 

of mycelial components (which comprise the fungal organism) residing in the organic or topsoil layer for 
Chapter 3. Environmental Consequences

Final Environmental Assessment – 137

mycorrhizal fungi, reduction in canopy shade and organic forest floor cover, reduction in the abundance 

of host trees and refuge species to sustain inoculum through periods of successional change in the stand, 

removal or reduction of forest floor organics and CWD which form the primary micro-habitat for 

saprobic species, and breakdown of soil structure (e.g., compaction) which not only affects the mycelia 

therein but also damages fine root tips to which the mycelia attach (Amaranthus et al. 1996).

Silvicultural and fuels design, PDFs and LRMP S&Gs reduce the level of negative direct and indirect 

impacts to sensitive fungi. Silvicultural and fuels design includes a) the nature of the silvicultural 

treatments (TFB and oak woodland maintenance to retain existing species diversity) that allows for 

structural diversity, retention of host trees and partial shade to the forest floor, and b) the nature of the 

fuels treatment in the units which focus on thinning, pruning and piling of small-diameter trees and shrubs 

within a limited space near roads. Project design features and LRMP guidelines oriented toward soils or 

wildlife that also benefit sensitive fungi include:

o For each unit, soil porosity would be maintained to at least 90 percent of its natural condition over 

at least 85 percent of the unit area. Skid roads and trails would be limited to no more than 15 

percent of the harvest area. At the end of project activities, a layer of litter and duff would occur 

over at least 50 percent of the activity area. In all treatment units, retain 80 to 100 percent of 

existing CWD (at least 20 inches in diameter and 10 feet long) on the ground.

o All existing large snags (20 inches or greater in diameter) would be retained in units unless they 

pose a safety concern.

While not eliminating effects to fungi, it is assumed by managing for habitat elements in stands to be 

thinned, adverse effects to sensitive fungi species can be reduced. Effects of relatively small-scale 

activities are not likely to significantly reduce the fungal species diversity that was in place prior to the 

disturbance (Durall et al. 1999). In certain areas in a stand, meso-habitat features would be impacted by 

skidding, felling of canopy trees, yarding tops, end-lining or pile burning, but mycelial networks can 

extend several meters through the forest floor, so conceivably localized impacts may impact or sever part 

of the fungal individual but would not necessarily impact the entire body of the organism. Furthermore, if 

vegetative and soil conditions are retained in places within the unit, spores stored in the soil provide a 

propagule for development of fungi after the disturbance. These impacted areas would recover in time and 

along with it the development of fungal communities (Dahlberg and Stenlid 1995).

Cumulative Effects

Impacts to known sites of S&M species are isolated and localized. There are no other Forest Service or 

private property projects occurring within the project area that could impact these known sites. Therefore, 

there are no cumulative effects associated with Alternative 2 (Proposed Action).

Provided PDFs described is this document are implemented, the Proposed Action adheres to the policy 

within the SRNF LRMP (USDA Forest Service 1995) and FSM 2900 Invasive species management and 

the Forest Service National Strategic Framework for Invasive Species Management (USDA Forest 

Service 2013a).

The Sensitive Botanical species effects analysis and the actions proposed under Alternative 2 adhere to 

the policy within the SRNF LRMP and FSM 2670.

By managing known S&M sites, based on pre-disturbance and equivalent effort surveys adhering to S&M 

S&Gs per the 2001 Record of Decision (ROD) and the SRNF LRMP, microsite conditions would be 

maintained to provide for the persistence of these species.
Chapter 3. Environmental Consequences

138 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Invasive Non-Native Plants

Introduction

Key to keeping invasive non-native plants at bay on SRNF is management of existing infestations and of 

the vectors that introduce and spread these plants on forest with particular emphasis on the management 

of satellite or leading edge occurrences. In regards to the latter, this is a rare opportunity to manage and 

possibly even eradicate occurrences before population numbers explode to a point of no return. The main 

emphasis of the Invasive Non-Native Plant section of this document is an evaluation of the risk of 

introduction and spread of invasive non-native plants from actions proposed under the action alternative, 

Alternative 2. The level of risk is used as a measurement indicator to compare environmental 

consequences between alternatives. The risk evaluation leads to PDFs that are designed to mitigate 

project effects by reducing the risk of introduction and spread of invasive non-native plants from the 

existing condition of high to the desired condition of low.

Environmental Consequences

Methodology

In accordance with the policy within FSM 2900 Invasive species management, the forest shall abide by 

the following as a component of project decision document:

o Determine the risk of introducing, establishing, or spreading invasive species associated with any 

proposed action, as an integral component of project planning and analysis, and where necessary 

provide for alternatives or mitigation measures to reduce or eliminate that risk prior to project 

approval.

o Ensure that all Forest Service management activities are designed to minimize or eliminate the 

possibility of establishment or spread of invasive species on the NFS, or to adjacent areas.

o Make every effort to prevent the accidental spread of invasive species carried by contaminated 

vehicles, equipment, personnel, or materials (including plants, wood, plant/wood products, water, 

soil, rock, sand, gravel, mulch, seeds, grain, hay, straw, or other materials).

o Monitor all management activities for potential spread or establishment of invasive species in 

aquatic and terrestrial areas of the NFS.

Evaluating Risk

Risk is evaluated in an assessment for this project based on five indicators: 1) presence of known invasive 

plant species in the project area, 2) habitat vulnerability, 3) non-project-dependent vectors such as 

grazing, existing roads or trails, adjacent private property, 4) habitat alteration expected as a result of 

project implementation, and 5) potential for increasing vectors as a result of project implementation.

Roads are vulnerable settings for the introduction and spread of invasive non-native plant species. 

Invasive plants are highly adapted to settings that are chronically disturbed and with little to no shade. 

Seeds of these plants can be inadvertently introduced to new areas on vehicles or equipment (the latter 

used in road maintenance), attached to domestic animals, or imported on rock/gravel/straw or other 

material used on roads or for erosion control. Once introduced, seed banks produced by yellow star thistle 

can last a decade or more and germinate when subjected to scarification (alteration of the seed coat) by 

mechanical or thermal means.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 139

An evaluation of the risk of introduction and spread from actions proposed under the action alternative, 

Alternative 2, follows. The risk evaluation leads to PDFs that are designed to mitigate effects noted above by 

reducing the risk of introduction and spread from the existing condition of high to the desired condition of 

low. Alternative 1 (No Action Alternative) would score a high risk under Factor 1 due to the presence of 

yellow star thistle. It would also score high risk for Factors 2 and 3. Actions proposed under Alternative 2, on 

the other hand, include actions that could greatly increase the risk of introduction and spread by adding the 

high risks associated with Factors 4 and 5 if the PDFs and mitigations are not implemented.

Factor 1. Presence of known non-native invasive plant species identified as a forest concern.

o HIGH Risk: Because of surveys conducted by SRNF botanists, yellow star thistle infestations 

were found to exist on edges of FSRs 02S50 and 02S48. Table 26 provides the location of these 

sites. Sites would be flagged in the field and identified by the INFESTATION ID. Note that 

UTMs are centroids of infestations. Mileposts were derived in ArcMap and are approximate.

Table 26. Yellow star thistle infestations and their location within the project area.

Infestation ID Acres NAD83X NAD83Y Road 

Number Milepost Notes

54CESO17TEC01 0.22 471,943 4,459,472 2S50 0.19

54CESO17JDM02 0.02 472,339 4,458,783 2S48 0.33 to 0.36

54CESO17JDM03 0.01 472,377 4,458,803 2S48 0.37 At Landing

54CESO17JDM04 0.01 472,586 4,458,776 2S48 0.51

54CESO17JDM05 0.01 472,550 4,458,772 2S48 0.48

54CESO17JDM06 0.01 472,666 4,458,954 2S48 0.81

54CESO17JDM07 0.01 472,778 4,458,933 2S48 0.88

54CESO17JDM08 0.01 472,777 4,459,022 2S48 0.97

54CESO17JDM09 0.03 472,860 4,459,071 2S48 1.07 Near Landing

54CES017JDM10 0.01 473,122 4,459,207 2S48 1.46

54CESO17JDM11 0.01 473,111 4,459,278 2S48 1.51 At Landing

54CESO17JDM12 1.30 473,435 4,459,203 2S48 1.76 to 2.00 At Landing

54CESO17JDM13 0.05 473,427 4,459,398 2S48 2.05

54CESO17JDM14 0.74 473,641 4,459,345 2S48 2.13 to 2.27

54CESO12JDM01 0.02 473,726 4,459,365 2S48 2.30 t0 2.34

Factor 2. Habitat vulnerability based on previous disturbance, plant cover, soil cover, shade, soil 

type, aspect/moisture.

o LOW Risk: Forested areas with high canopy cover.

o HIGH Risk: Oak woodlands, forested (harvested) areas with low canopy cover, early seral 

communities, road edges, and burned areas.

The project area possesses attributes that are conducive to yellow star thistle introduction and spread. 

These attributes include relatively open habitats including oak woodlands, areas of reduced canopy and 

overall vegetative cover, areas of ground disturbance due to past logging, road construction, road 

maintenance, and private land developments. There are also burned areas as a result of the 2008 Mad 

River Complex fires. Yellow star thistle is intolerant of shade and readily invades open and disturbed 

settings. A majority of the project area is forested, which is not considered a habitat type vulnerable to 

noxious weeds that might occur in the area.
Chapter 3. Environmental Consequences

140 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Factor 3. Non-project-dependent vectors such as existing roads and trails, traffic use, 

livestock/wildlife migrations, wind patterns, drainage flow directions.

o HIGH Risk: Roads, wind patterns, livestock grazing and wildlife movement

Roads are a primary vector for the introduction and spread of weeds (Gelbard and Harrison 2003). Use of 

roads associated with the project area, especially those adjacent to known occurrences of invasive species, 

can lead to a high risk of spread of invasive non-native plant species. Yellow star thistle is winddispersed, and as such can disperse over long distances.

Areas where livestock concentrate such as water troughs are subject to sometimes-intense ground 

disturbance, which creates a setting conducive for invasive plant establishment. Livestock can also serve 

as vectors for transport of yellow star thistle seed, via seeds embedded in mud attached to hoofs. The 1st

48 Project lies within the Van Horn grazing allotment, and as such is subject to spread of noxious weeds 

via livestock activities.

Factor 4. Habitat alteration expected as a result of the project such as logging prescriptions, road 

construction, fuels prescriptions, change in grazing management or recreation use, intensity and 

extent of disturbance.

o LOW Risk: Activities that maintain more than 60 percent canopy cover and remnant understory 

vegetation.

o MODERATE Risk: Activities that maintain 40 percent to 60 percent canopy cover and remnant 

understory vegetation.

o HIGH Risk: Activities resulting in less than 40 percent canopy cover and remnant understory 

vegetation.

In general, invasive non-native plant species establish and recruit in areas of ground disturbance, 

especially where forest canopy is diminished. Logging, temporary and permanent road construction, fuels 

prescriptions, and the machinery used to perform these activities can create disturbed soils, reductions in 

vegetative ground cover, and reductions in canopy. The conditions created are conducive to the 

introduction and spread of noxious weeds.

Where complete removal of vegetation is expected (e.g., shrub/vegetation removal in fuel corridors, or 

landing development), the risk of introduction and spread is considered to be HIGH. Where partial removal 

of vegetation in forested habitats results in a minimum 60 percent canopy closure, the risk of spread into 

the setting is low to moderate in the short-term. As the forest canopy fills in the gaps and understory 

vegetation and where canopy cover is greater than 60 percent, the risk is considered low.

Factor 5. Increased vectors as a result of project implementation such as road construction, 

facility construction, amount of project-related traffic.

o MODERATE Risk: Other areas of project.

o HIGH Risk: Increased traffic on 2S50 and 2S48 including the use of machinery associated with 

project implementation, and use of landings and turnouts along these roads.

Risk Determination

Given yellow star thistle’s ecology and roadside distribution within the project area, the evaluation of the 

5 factors above result in a moderate to high risk of introducing and spreading yellow star thistle within the 

project area. Hence, the following PDFs are designed to mitigation measures to reduce or eliminate that 

risk prior to project approval.
Chapter 3. Environmental Consequences

Final Environmental Assessment – 141

Alternative 1 – No Action

Direct Effects

If left unmanaged, invasive non-native plant species directly threaten ecosystems by displacing native 

species.

Indirect Effects

Indirectly, over time they can reduce species diversity, and degrade wildlife and fisheries habitat. Yellow 

star thistle has been shown to be toxic to horses, leading to injury or death, and as such can indirectly 

degrade rangelands and lower private property values (DiTomaso and Healy 2007). In addition to 

degrading rangelands and lowering property values, widespread infestation of yellow star thistle can 

indirectly lead to soil erosion and siltation in streams.

Cumulative Effects

Failure to take action now under the Proposed Action would lead to the spread of invasive non-native 

plants into currently un-infested areas over time, primarily along roadsides and forest and grassland 

openings. Cattle grazing would contribute to the increased risk of spread along roadsides and into 

grassland openings where the Van Horn allotment coincides with the project area. The rate of spread would 

accelerate over time, as the seed source increases and expands. Without the application of control 

treatments at this point, a threshold would be reached at some future time, where the feasibility of 

controlling the widespread distribution of these non-native plant populations would become cost 

prohibitive. The outcome would be that these non-native invasive plant species would become a permanent 

fixture on the landscape, causing subsequent loss of biodiversity and quality forage for open range.

Alternative 2 – Proposed Action

Direct Effects

Project design features described in Chapter 2 would reduce the risk of introduction and spread of 

invasive non-native plant species from a risk of high to a risk of low and, as such, direct effects under 

Alternative 2 are less than under Alternative 1. These design features include removing existing 

infestations and lessening the chance of spread via actions proposed to protect biodiversity and quality 

forage in forest openings and grasslands.

Indirect Effects

Project design features outlined above would reduce the risk of introduction and spread of invasive nonnative plant species from a risk of high to a risk of low and, as such, the risk of degrading wildlife and 

fisheries habitat, and degrading rangelands and property values are reduced. Hence, indirect effects under 

Alternative 2 are comparatively lower than under Alternative 1.

Cumulative Effects

Establishing the geographic scope for analysis of cumulative effects is difficult for species that disperse 

readily and long-distances on vehicles and equipment. The Van Horn Allotment introduces an additional 

vector where the movement of cattle serves to introduce and spread non-native invasive plants along 

roadsides and into forest openings and grasslands.

For recent past projects, invasive plant risk assessments were developed using similar criteria outlined 

above e.g. presence of known invasive plant species in the project area, habitat vulnerability. The 

temporal time span for this analysis would be the implementation time span of the project. The 

assessment considering vectors influencing risk cumulatively indicate over this timeframe, a low to 
Chapter 3. Environmental Consequences

142 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

moderate risk for introduction and spread associated with project implementation would occur with the 

application of project design features and monitoring. The existing infestations would be contained or 

eradicated, and mitigation would lower the risk of new introductions and spread from project activities,

resulting in a beneficial effect compared to existing conditions. 
Finding of No Significant Impact

Final Environmental Assessment – 143

Finding of No Significant Impact

As the responsible official, I am responsible for evaluating the effects of the project relative to the 

definition of significance established by the Council on Environmental Quality (CEQ) regulations (40 

CFR 1508.13). I have reviewed and considered the environmental assessment (EA) and documentation 

included in the project record, and I have determined the Proposed Action would not have a significant 

effect on the quality of the human environment. As a result, no environmental impact statement (EIS) 

would be prepared. My rationale for this finding is as follows, organized by sub-section of the CEQ 

definition of significance cited above.

Context

For the Proposed Action and the No Action Alternative, the context of the following disclosure of 

environmental effects is based on the environmental analysis completed in preparation of this EA, 

summarized below.

Intensity

Intensity is a measure of the severity, extent, or quantity of effects, and is based on information from the 

effects analysis of this EA and the references in the project record. The effects of this project have been 

appropriately and thoroughly considered with an analysis that is responsive to concerns and issues raised 

by the public. The agency has taken a hard look at the environmental effects using relevant scientific 

information and knowledge of site-specific conditions gained from field visits. My finding of no 

significant impact is based on the context of the project and intensity of effects using the following ten 

factors identified in 40 CFR 1508.27(b):

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

agency believes that on balance the effect would be beneficial.

Fire, Fuels and Vegetation. The Proposed Action would have a positive response to thinning from below 

from implementing the Proposed Action, since subordinate trees (suppressed, intermediate and select codominant trees) would be removed to allow trees of the upper canopy (dominant and pre-dominant trees 

with fully developed crowns) to utilize the additional growing space. Thinning from below would 

increase the residual size of trees left in a stand (Agee and Skinner 2005, Smith et al. 1997). Crowns 

would expand into the desired shaded fuelbreak condition (final EA pp. 56-57).

Reducing stand density at this time would also allow these stands to develop more resilience to 

disturbances such as wind, heavy snow and ice, bark beetles, and fire. Thinning, whether from below or 

throughout the diameter classes (with the exception of pre-dominant and dominant trees), would increase 

spacing between trees and reduce stand densities, resulting in less inter-tree competition. This is predicted 

to increase individual tree vigor, resulting in stands that are more resilient to insects, disease, wildland 

fire, and drought (Agee and Skinner 2005, Fettig et al. 2007, Hessburg et al. 2016, van Mantgem et al. 

2009, Vernon 2017; final EA p. 57).

The Proposed Action would reduce ladder fuels and increase canopy base heights. Thinning activities 

would lower canopy densities, and to a potentially noticeable extent, a reduction in fuel ladders would 

occur through the same activities. These, in combination, would help to reduce flame length, resistance to 

control and the potential for a ground fire to transition into a crown fire (Vernon 2017; final EA pp. 54-57).
Finding of No Significant Impact

144 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

One of the most threatened species is the California black oak (Quercus kelloggii), which is vulnerable to 

being overtopped and crowded out by Douglas-fir. One of the biggest deficits on the landscape is the old 

upland oak woodland (CR). Thinning around these remnant oak trees being over topped and shaded out 

by faster growing Douglas-fir, would enable them to receive more sunlight promoting the growth of fuller 

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

Invasive Plant Species. The policy, which guides the management of invasive species on National Forest 

System (NFS) lands, requires that land management activities not foster the introduction and spread of 

invasive species. Germane to the Proposed Action, the following policies from FSM 2900 (Invasive 

Species Management) apply. Project design features (PDFs) described in Chapter 2 of this EA are 

designed to reduce the risk of introduction and spread of invasive non-native plant species from a risk of 

high to a risk of low and, as such, direct effects under the Proposed Action (Alternative 2) are less (final 

EA pp. 138-142; Botany Weed Risk Assessment).

Soil Resources. The Proposed Action was designed to be consistent with the SRNF’s Land and Resource 

Management Plan (LRMP or forest plan) and associated standards and guidelines (S&G), including soil 

quality standards (SQS) maintaining soil productivity in compliance with the National Forest 

Management Act (NFMA). Implementing project-specific mitigation measures would minimize effects to 

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

productivity would be maintained within this project area.

Current existing detrimental effects of past actions are minimal in extent area. The Proposed Action by 

itself would not produce significant amounts of adverse direct or indirect soil impacts, using 15 percent of 

the area in detrimental soil conditions collectively as the threshold used to determine if soil impacts are 

significant, per current management direction. There are no reasonably foreseeable future actions, which 

would produce significant impairment of soil quality or productivity. Thus there are no additive 

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

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

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

Clean Air Act of 1970. The Clean Air Act of 1970 and its amendments provide for the protection and 

enhancement of the nation’s air resources. The implementation of the Proposed Action would not exceed 

the federal and state ambient air quality standards to protect public health. Jackpot burning and 

underburning in the oak woodlands would be implemented seasonally. As each entry may be implemented 

over several seasons and would small in size, and handpiles would be covered with Kraft waxed paper to 

minimize smoke production during burning, project design and mitigation measures would address public 

health and safety concerns. The project design incorporates operational provisions to ensure safe 

motorized access. Additionally, burn plan would be developed identifying specific tactics to reduce smoke 

emissions, including identifying sensitive smoke receptors and when favorable wind directions would 

promote smoke dispersal prior to scheduling burn ignition (final EA p. 45).

Clean Water Act. The protection of water quality and quantity is an important part of the mission of the 

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

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

the volume, timing, and quality of streamflow. The alternatives, as proposed, would comply with the Clean 

Water Act, Porter-Cologne Water Quality Control Act, applicable water quality control plans, and the North 

Coast Regional Water Quality Control Board (NCRWQCB) waiver of waste discharge requirements. A 

waiver application would be filed after the Decision Notice is signed (final EA pp. 13, 98).
Finding of No Significant Impact

Final Environmental Assessment – 145

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

other policies of the State Water Quality Control Board and the federal government, which are applicable 

to timber and fuel treatment projects. The water quality standards in the Basin Plan that most closely 

apply to this Proposed Action are sediment. The standard for sediment states that sediment load and 

suspended sediment discharge rate of surface waters shall not be altered in such a manner as to cause 

nuisance or adversely affect beneficial uses.

Due to limited project activities in riparian reserves and 60-plus percent canopy retention, stream 

temperature would not be affected. The Proposed Action avoids constructing new roads (and temporary 

roads). For the project as a whole, there are 141 acres of riparian reserves deemed equipment exclusion 

zones. Of this, 90 acres are “inner” riparian reserves, (within 80 feet of the stream) which will only have 

fuel treatments by hand. There are 51 acres of “outer” riparian reserves, which are equipment exclusion 

zones, but trees may be yarded out using a cable. There are 3.7 miles of intermittent streams and one mile 

of perennial streams within the project units. The streams coming off South Fork Mountain are high 

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

The 1st 48 Project lies within the Upper Mad subarea (comparable to the Upper Mad River 5th-field 

watershed), which produces only six percent of the sediment within the larger Mad River Watershed. For 

the Upper Mad River Watershed (UMRW), the total sediment is estimated at 234 tons per square mile per 

year with an average of 38 percent being from management related sources. The total maximum daily 

load (TMDL) target for sediment in the UMRW subarea was set at 173 tons. This would mean a reduction 

of 26 percent for the UMRW. The Environmental Protection Agency (EPA) specified that in order to meet 

a 26 percent reduction in total sediment within the UMRW, management-related sediment must be 

reduced by 68 percent over time. Activities within the proposed project are designed to minimize and in 

some areas reduce management related sediment and move towards meeting the EPA sediment load 

allocation (final EA pp. 95-98).

Wildland-Urban Interface. The reduction in fire hazards would enhance public safety for those living 

within the wildland-urban interface (WUI), as the Proposed Action was designed to allowing for efficient 

wildfire containment and control. Between 2006 and 2011, about 600 assessments were completed by the 

Forest Service on wildfires that burned into areas where hazardous fuels reduction treatments (HFR) had 

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

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

indicate that 90 percent of treatments reported in the database have helped to reduce wildfire intensity, 

allowing better control by firefighters. In most of these cases, as fires moved from untreated locations to 

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

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

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

shrubs, pine needles, and other flammable materials on the ground) (DellaSala et al. 2004, Stein et al. 

2013; final EA pp. 52-55).

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

parklands, prime farmlands, wetlands, wild and scenic rivers, or ecologically critical areas.

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

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

There are no known caves within the project area. Therefore, there would be no effect to this resource 

from implementing the Proposed Action (final EA pp. 102-104; Geology Report).
Finding of No Significant Impact

146 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Wetlands and Floodplains. No floodplains associated with Executive Order 11988 or wetlands per 

Executive Order 11990 exist within the project area. Therefore, there would be no effect to these 

resources from implementing the Proposed Action.

Parklands and Prime Farmlands. There are no parklands or prime farmlands within or immediately 

adjacent to the project area. Therefore, there would be no effect to these resources from implementing the 

Proposed Action.

Research Natural Areas. Research Natural Areas (RNA) are areas allocated for research, education and 

to protect biodiversity on NFS lands. There are no RNAs within the project area. Therefore, there would 

no effect to these resources.

Wilderness Areas. Wildernesses areas are managed according to the Wilderness Act of 1964, the 

California Wilderness Act of 1984, and regulations pursuant to those acts and the Forest Service Manual

(FSM). There are no wilderness area designated within the project area. Therefore, there would be no 

effect to these resources.

Wild and Scenic Rivers. There are no designated and/or recommended National Wild and Scenic Rivers 

or adjacent corridors of land classified as recreational (USDA Forest Service 1995) within the project area

per the National Wild and Scenic Rivers Act of 1968, designated by the Secretary of the Interior on 

January 19, 1981. Therefore, there would be no effect to these resources.

Northern Spotted Owl Critical Habitat. On December 4, 2012, the Northern Spotted Owl Critical Habitat 

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

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

encourage land managers to consider implementation of forest management practices recommended in the 

Revised Recovery Plan to restore natural ecological processes where they have been disrupted or suppressed 

(e.g., natural fire regimes), and application of ecological forestry management practices ....”. In the Critical 

Habitat Rule, the US Fish and Wildlife Service (USFWS) acknowledged that “Compared to other zones (in 

the Klamath and Northern California Interior Coast Ranges), additional foraging habitat for this zone 

showed greater divergence from nesting habitat, with much lower canopy cover and tree size.”

Approximately 36,267 acres of the action area occur within the Unit 11, the Interior California Coasts 

Subunits (ICCS) 1 and 2 of the Critical Habitat Rule. There are 12 units to be treated for hazardous fuel 

reduction (152 acres), 4 units to be oak woodland restoration (37 acres), 8 units of plantation thins (108 

acres) and 65 units (530 acres) of fuelbreak construction that would occur in northern spotted owl (NSO) 

critical habitat units (CHU). A total of 786 acres of NSO nesting/roosting/foraging/dispersal habitat and 

34 acres non-habitat would be treated between the two subunits of CHU. In ICCS 1, fuelbreak 

construction would occur in 39 acres of low-quality foraging habitat. In ICCS 2, hazardous fuel reduction 

would occur in 49 acres of low-quality nesting/roosting habitat, 28 acres of moderate-quality 

nesting/roosting habitat, 12 acres of moderate-quality foraging habitat, 41 acres of low-quality foraging 

habitat, and 37 acres of dispersal-only habitat. Oak woodland restoration would occur on approximately 

37 acres of dispersal-only habitat. Plantation thins would occur on 108 acres of dispersal-only habitat. 

Fuelbreak construction would occur in approximately 85 acres of moderate-quality nesting/roosting 

habitat, 159 acres of low-quality nesting/roosting habitat, 136 acres of moderate-quality foraging habitat, 

and 95 acres of low-quality foraging habitat would be modified, but would maintain current habitat 

function within NSO CHU.
Finding of No Significant Impact

Final Environmental Assessment – 147

Post treatment monitoring was conducted by the Level 1 Team on the Kelsey Peak Project, as well as on 

similar projects elsewhere on the forest. All the units exceeded canopy closure requirements, and 

protected pre-dominant trees, snags, and downed logs. The units are still functional habitat and should 

respond well to the treatments. It was agreed by the Level 1 Team these types of treatments would have a 

beneficial effect on the future habitat conditions of the area and creating more alternative habitats for owls 

to use as additional treatments occur on the landscape (final Biological Assessment).

Late Successional Reserve. A very small portion of the 1st 48 Project is located within the South Fork 

Late-Successional Reserve (LSR; RC-330). The entire South Fork LSR is 80,451 acres, with the majority 

located on the Shasta-Trinity National Forest (STNF). Of that, only 1,057 acres located on the Six Rivers 

National Forest (SRNF), and the 1st 48 Project affects only 73 acres located on the westernmost boundary 

of the entire LSR. The South Fork LSR is a land allocation established in the Northwest Forest Plan 

(NWFP), incorporated into both the SRNF and STNF LRMPs, allocated to be managed to protect and 

enhance late-successional forest ecosystems through prescribed understory fire, and thinning from below 

(TFB). General management direction for LSR lands is found in the SRNF LRMP (USDA Forest Service 

1995 pp. IV-34-39). The STNF included the South Fork LSR in the 1999 Forest-Wide Late-Successional 

Reserve Assessment (LRSA; USDA Forest Service 1999), which identified general current conditions, 

general desired conditions, and management recommendations that would move the LSRs, including the 

South Fork LSR, toward desired conditions. One of these desired conditions is the reduction of risk to 

large-scale disturbance.

In 2009, the STNF received a letter of clarification from the Regional Ecosystem Office (REO) related to 

hazard reduction thinning activities proposed in LSRs in order to reduce the risk of large-scale 

disturbance. The REO had reviewed the LRSA for the STNF and concluded that fuel treatments proposed 

in the LSRs that thin suppressed, intermediate and some co-dominant trees are consistent with the S&Gs 

under the NWFP (USDA and USDI 2009).

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

firefighters a good chance of keeping exterior wildfire from entering; or conversely interior wildfire from 

exiting the area. Under the LSRA and LRMP direction, proposed silvicultural activities are aimed at 

reducing risk (potential loss due to wildfire) in 59 acres of younger white fir stands adjacent to FSR 2S23 

along the ridgetop within the South Fork LSR.

Project objectives are to reduce the stand density with a TFB of primarily white fir to reduce fuel and add 

space between crowns. The trees targeted for removal in the early mature white fir stands have a diameter 

range of 14 to 24 inches, and are less than 120 to 150 years old. Some trees in this age class are larger 

than 24 inches dbh and may be removed to meet crown spacing objectives.

Additionally, there are approximately 14 acres of Douglas-fir or ponderosa pine-dominated stands within 

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

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

terms of age and diameter range. In the patches of mid-mature and remnant late-mature seral forest (Table 

9), trees range from 70 to 120 years old, with diameters ranging from 12- to 32-inch dbh. As the Proposed 

Action targets those trees with under-developed crowns, which are typically suppressed and/or 

intermediate trees less than 150 years old, and retains trees with the fullest crowns characteristic of codominant, dominant and pre-dominant trees. Late-seral characteristics would be maintained (final EA pp. 

57-58, 203-206).
Finding of No Significant Impact

148 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

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

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

management area and 234 acres within partial retention management area, while the remainder of the 

project area occurs within the Modification VQO category. The majority of the project area has 

experienced alterations in visual quality from road and log landing construction and even-age timber 

harvest management. The 1st 48 Project would retain variable forest canopy closure over 60 percent, 

limits new landing construction to existing flat openings and does not involve new road construction. The 

removal of boundary flagging and placing stump marks away from viewpoints would ensure the Proposed 

Action complies with forest plan) S&Gs. The proposed treatments would blend well with adjacent lands 

not proposed for treatment and would conserve the scenic quality and integrity of the project area.

Recreational Resources. Jeep Trail 8E20 (aka Wiregrass) is a special vehicle designation trail (i.e., fourwheel-drive non-highway legal vehicle wider than 50 inches/all-wheeled vehicles 50-inches wide or less) 

that is 1.29 miles long, located in T2S R8E. The Forest Service’s national resource management (NRM) 

database indicates this trail was added to the NFST (National Forest System trails) under Lower 

Trinity/Mad River Motorized Travel Management Record of Decision in April 2010. This trail is displayed 

on the revised motor vehicle use map (MVUM) for that area. The trail would be graded within its existing 

footprint and temporarily closed to public use during logging operations to ensure public safety. Other 

than the short-term disruption in public use, grading and constructing waterbars would be visually evident 

in the short-term, likely one season (final EA pp. 45-46).

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

controversial.

The project area lies within the UMRW, which encompasses 120 square miles (24% of the basin) from the 

headwaters of the Mad River to Robert Matthews Dam, which impounds runoff from the upper watershed 

in Ruth Lake Reservoir (the only existing impoundment on the Mad River), built in 1961 by the 

Humboldt Bay Municipal Water District (HBMWD). The reservoir has a storage capacity of about 48,030 

acre-feet and was designed to provide a safe yield of 75 million gallons per day (mgd; 230 acre-feet/day), 

approximately 8 percent of the total annual runoff for the watershed.

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

were intermittent. At the former US Geological Survey (USGS) gauge near Forest Glen (No. 11480500 

located approximately 9 miles downstream of the dam), mean daily flow for the month of August, from 1953 

to 1961, ranged from 2 to 8 cubic feet per second (cfs), with an average of 4 cfs. Currently the HBMWD 

manages the release of water from Ruth Reservoir to meet domestic and industrial water needs as well as 

instream flow requirements for the protection of listed fish species (HBMWD 2004)(final EA p. 101).

The extent, duration and intensity of proposed activities under Alternative 2 are not sufficient to adversely 

affect in-stream flows. Evapotranspiration rates would not be further altered, nor would sufficient ground 

compaction occur to alter rates of surface runoff. The proposed treatments would not result in changes to 

spatial and temporal hydrology both due to the limited magnitude of the treatments and the very small and 

localized spatial extent of the treatments. Therefore, the timing, magnitude, and duration of flows would 

not be altered. Instream flows and fluvial processes would continue to occur at the rates under which the 

stream system evolved. Habitat diversity, channel stability, and water quality would continue to be 

moderate to high (final EA p. 102).
Finding of No Significant Impact

Final Environmental Assessment – 149

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

unique or unknown risks.

Asbestos Airborne Toxic Control Measure (ATCM) for Surface Application. The ATCM rule was 

adopted by the California Air Resource Board (CARB) in 1990 and amended in 2000. The amendment 

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

surfacing applications subjected to vehicular, pedestrian or non-pedestrian use, such as cycling and 

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

percent without concern.

The SRNF has samples and tests for presence of Naturally Occurring Asbestos as close as 10 miles from 

the project area. Two of the 42 samples within a 20-mile radius from the project area contained asbestos at 

0.5 percent in small serpentenite outcrops. The project area contains no similar outcrops. No ultramafic 

bedrock and therefore, no naturally occurring asbestos occur in the project area. No groundwater 

resources would be developed or are existing within the project area. The Proposed Action applies lowintensity mechanical, manual and prescribed burning treatment methods. The treatment prescriptions and 

mitigation measures incorporated have been applied on numerous projects across the SRNF with 

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

Executive Order 12898, Environmental Justice. This federal order requires an assessment of whether 

there would be disproportionate effects to minority or low-income populations. Although there are 

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

the proposal.

Environmental Justice means that, to the greatest extent practicable and permitted by law, all populations 

are provided the opportunity to comment before decisions are rendered on, are allowed to share in the 

benefits of, are not excluded from, and are not affected in a disproportionately high and adverse manner, 

by government programs and activities affecting human health or the environment. There would be no 

discernable differences between the Proposed Action and No Action Alternatives regarding effects on 

minorities or the civil rights of any American citizen.

The Proposed Action does not have a disproportionately high and adverse human health effects, high or 

adverse environmental effects, substantial environmental hazard, or affects to differential patterns of 

consumption of natural resources. Extensive scoping did not reveal any issues or concerns associated with 

the principles of Environmental Justice. No mitigation measures to offset or ameliorate adverse effects to 

these populations have been identified (final EA pp. 14-15).

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

enhancement of long-term productivity. Short-term uses are expected to change the human 

environment during mechanical, manual, prescribed burning and logging/hauling operations. Long-term 

effects should not appreciably change the human environment after final entry fuel reduction operations 

have concluded, as proposal treatment prescriptions are low-intensity, and planned for phased entries to 

minimize disturbance to nearby neighbors and natural resources (final EA pp. 35-39).

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

community members rely on natural resources for substance food gathering and jobs. These communities 

are directly influenced by forest-management job opportunities and supply of natural resources from 

forest ecosystems. Implementation of the Proposed Action would cause no unavoidable or other indirect 

social/economic adverse effects.
Finding of No Significant Impact

150 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

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

represents a decision in principle about a future consideration.

Irreversible or Irretrievable Commitments of Resources. Irreversible commitment of resources refers 

to a loss of non-renewable resources, such as mineral extraction, heritage (cultural) resources, or to those 

factors, which are renewable only over long time spans, such as soil productivity. Under the No Action 

Alternative, there would be no irreversible or irretrievable commitment of resources.

Irretrievable commitment applies to losses that are temporary, such as use of renewable natural resources. 

The production lost would be irretrievable, but the action would not be irreversible. Vegetation removed 

as commodity byproducts under the Proposed Action is considered an irretrievable impact. Forest 

conditions would return, as tree growth over one or more decades would feature increased canopy closure 

and development of healthy, sustainable stand densities resilient to natural processes serving Endangered 

Species Act (ESA) wildlife habitat and soil resources (final EA pp. 56-57, 92, 113-122).

Vegetation. Tree removal authorized by my decision is considered an irretrievable impact, as it will 

“extract” timber, an outcome of thinning commercially valuable trees. However, forested conditions will 

return as tree growth accelerates over one or more decades, with increased diameter and canopy growth 

associated with higher commercial value. In the long term, the 1st 48 Project will also promote the 

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

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

Soils. Current existing detrimental effects of past actions are minimal in extent area. The Proposed Action 

by itself would not produce significant amounts of adverse direct or indirect soil impacts, using 15 

percent of the area in detrimental soil conditions collectively as the threshold used to determine if soil 

impacts are significant, per current management direction. There are no reasonably foreseeable future 

actions, which would produce significant impairment of soil quality or productivity. Thus there are no 

additive significant effects of past, present, and foreseeable future actions expected, and therefore by 

definition no significant cumulative effects for soil resources.

The Proposed Action is design consistent with the regulatory framework outlined above. Forest plan 

S&Gs and SQS are intended to comply with NFMA, maintaining soil productivity. Standards and 

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

of expected soil impacts, spatially and temporally. Implementing project-specific PDFs are intended to 

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

productivity is maintained within this project area (final EA pp. 117-120).

Adverse Environmental Effects that cannot be Avoided. The Proposed Action involves adverse 

environmental effects to soil resources that cannot be wholly avoided or mitigated. New temporary roads 

and landings are known to be the most impactful features associated with activities, in particular groundbased (tractor) operations. No new temporary roads are proposed with this project, in agreement with the 

Collaborative. The majority of landings are old landings to be reutilized, but a number of new landings 

would also be created. These would have severe compaction, and thus have reduced infiltration and be 

prone to producing runoff; drainage features are required to control runoff and avoid adverse impacts 

(BMPs). Being “temporary” means that they will need to be rehabilitated once their use is finished. 

Project design features herein stipulate that rehabilitation will include de-compaction via ripping 

(furrowing using conventional rock-rippers common on logging equipment) or “dibbling” meaning 

working the ground with an excavator bucket (common method in other areas, also called “potato patch”). 
Finding of No Significant Impact

Final Environmental Assessment – 151

This would be followed by re-contouring to the approximate original terrain in cases where the feature 

was “constructed” by blading topsoil to create a favorable grade or bench (constructed using cut and fill).

The proposed landings are mostly roadside on gentle grade, so little blading should be necessary to make 

them usable, and thus little to no recontouring is expected to be necessary; however, some form of 

decompaction would be necessary. These areas would also be rendered bare, so some form of soil cover 

may be required to prevent erosion, either organic mulch, slash, and/or seeding to establish vegetation. In 

most cases, old access roads and landings are in favorable locations to be re-utilized, which will minimize 

new disturbance and cumulative effects. Even with rehabilitation measures, new and reutilized temporary 

roads and landings would still have long-term effects left to slowly recover naturally over time.

Skid trails would be created as necessary to operate the mechanical ground-based units. These would also 

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

“detrimental” levels of compaction, depending on traffic intensity. A few passes with a tracked grappleskidder will generally not produce a detrimental degree of compaction if soils are dry. Most soils have a 

moderate compaction risk (110Table 17), but some have a high compaction risk, namely Kistirn (SMU 

260), Hugo (SMU 265-266), and Hecker (SMU 250-256); these intersect with many of the ground-based 

units (Appendix C). Thus, it is conservatively assumed that skid trail compaction would be detrimental, 

and these equipment trails, in combination with temporary roads and landings, limited to less than 15

percent of the unit area as part of the layout plan to ensure this aerial extent, is not exceeded. If equipment 

trails are deeply rutted, they may be decompacted by ripping if necessary to promote natural revegetation

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

Energy Requirements of Alternatives. Under the Proposed Action, various amounts of fossil fuels, and 

human labor would be expended. Fossil fuel energy would not be retrievable. None of them are in short 

supply and their use would not have an adverse effect upon continued availability of these resources.

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

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

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

breaking it down into small component parts.

Vegetation. The Proposed Action differs from past actions, in that historic timber harvest (pre-1990s)

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

The actions proposed here are to reduce hazardous fuels and to construct shaded fuelbreaks to promote 

resiliency of stands from fire effects. These treatments would not detract or stall these stands in 

development of structure to mid-mature/late-mature and understory re-initiation and would not alter the 

current distribution of seral or development stages (also called structural stages) within the analysis area.

Similar thinning projects are being carried out within this watershed. The 2009 Beaverslide and the 2013 

Kelsey Peak Timber Sale and Fuelbreak projects have portions recently implemented. Other foreseeable 

actions within the analysis area are additional hazardous fuel reduction projects and shaded fuelbreak 

construction and maintenance.

In terms of past, proposed, ongoing, and foreseeable actions, this project would have no cumulative 

effects to the vegetation structural stages within the south zone of the forest, which is the entire Mad 

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

older forest types, and by past wildfires. This project would improve the distribution of structural stages 

over the long term for species needing older forest habitat for part or all of their life cycle.
Finding of No Significant Impact

152 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

The Proposed Action would retain all dominant trees and pre-dominant trees, which includes those with 

defects. Most co-dominant trees would also be retained. The thinning from below prescription would not 

alter existing seral stage condition, and it would in fact, increase growth on the remaining trees to 

accelerate development of trees into late seral size classes. This would promote an increase in the amount 

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

Recommended Management Range (RMR) threshold (final EA pp. 56-58, 184-185, 206-207).

Fire and Fuels. The absence of recent mixed-severity fire has been a likely factor in the rather uniform, 

even-aged, single-layer structure of these Douglas-fir stands, as well as the continued loss of black oak 

through competition from Douglas-fir. Fire suppression since the early 1900s means that these sites have 

likely missed several fire events that would have created more horizontal and structural diversity in the 

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

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

Fire scar evidence indicates that these stands were historically maintained at low densities by frequent fire 

regimes. Many of these stands contain large, old specimens of both of these species. Stand densities and 

ladder fuels have increased to the point that there is a risk of losing them to a stand-replacing fire.

The Proposed Action would employ TFB (Tappeiner et al. 2007) in early and early/mid-mature Douglasfir/black oak stands ranging in age from 70 to 80 years, early mature white fir stands, and young Douglasfir or ponderosa pine plantations. These stands are generally single-layered and consist of even-aged 

patches of varying age. A positive response to thinning from below from implementing the Proposed 

Action is expected, since subordinate trees (suppressed, intermediate and select co-dominant trees) would 

be removed to allow trees of the upper canopy (which have more fully developed crowns) to utilize the 

additional growing space. Thinning from below increases the residual size of trees left in a stand (Agee 

and Skinner 2005, Smith et al. 1997). Crowns would expand into the desired shaded fuelbreak condition.

Reducing stand density at this time would allow these stands to develop more resilience to disturbances 

such as wind, heavy snow and ice, bark beetles, and fire. Thinning, whether from below or throughout the 

diameter classes (with the exception of pre-dominant and dominant trees), would increase the spacing 

between trees and would reduce stand densities. This would act to lessen inter-tree competition, which 

increases individual tree vigor, resulting in stands that are more resilient to insects, disease, wildland fire, 

and drought (Agee and Skinner 2005; Fettig et al. 2007; Hessburg et al. 2016; van Mantgem et al. 2009; 

Vernon 2017).

Similarly, retaining the trees with the largest crowns may initially stimulate growth response of some 

brush species. However, the resulting increase in crown growth would reduce available sunlight from 

reaching the forest floor within a few years, which would in turn, reduce understory vegetation growth, 

including brush species that might contribute to ladder fuel development (final EA pp. 56-57).

Watershed Resources. The 1st 48 Project area is not within a key watershed under the NWFP. Barry 

Creek-Mad River is designated a Priority Watershed under watershed condition framework (WCF). The 

Proposed Action is small in acreage and widely dispersed across the landscape alongside open roads in 

narrow 300-foot strips, existing roadside plantations and an oak woodland stand. Thinning to establish 

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

sufficient shade from solar radiation to prevent increases in water temperature.

Thinning of trees (ladder and crown fuels) prescriptions would be restricted to the outer portion of the 

riparian reserves to retain tree root systems that hold soil and stream channels in place, functioning to 
Finding of No Significant Impact

Final Environmental Assessment – 153

minimize soil erosion and potential for increased sedimentation to protect water quality. Alternative 2 

incorporates design features to retain large woody debris and avoids thinning of trees within inner riparian 

reserve buffers to ensure future down wood recruitment is sufficient to maintain suitable stream habitat 

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

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

Soil Resources. Current existing detrimental effects of past actions are minimal in extent area. The 

Proposed Action alternative by itself would not produce significant amounts of adverse direct or indirect 

soil impacts, using 15 percent of the area in detrimental soil conditions collectively as the threshold used 

to determine if soil impacts are significant, per current management direction. There are no reasonably 

foreseeable future actions, which would produce significant impairment of soil quality or productivity. 

Thus there are no additive significant effects of past, present, and foreseeable future actions expected, and 

therefore by definition no significant cumulative effects for soil resources.

The Proposed Action is design consistent with the regulatory framework outlined above. Forest Plan 

S&Gs and SQS are intended to comply with NFMA, maintaining soil productivity. Standards and 

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

of expected soil impacts, spatially and temporally. Implementing project-specific PDFs are intended to 

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

productivity is maintained within this project area (final EA p. 122).

Geologic Resources. Surveys identified eight active landslides within the project area. There are no other 

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

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

after all vegetation has been removed by fire or harvest due to loss of root strength. The project would not 

remove all vegetation, thereby preserving root strength in the long term and would not increase landslide 

activity. Concentrated flow from skid trails will not occur due to application of skid trial remediation as per 

S&Gs and pose no long-term risk. If S&Gs, BMPs and PDFs are followed, negative effects to slope stability 

should be minimal or absent as compared to the likelihood that extensive landslide reactivation would be in 

the event of stand-replacing fire across much of the landscape (final EA pp. 104-105).

Invasive Plant Species. Management of the direct and indirect effects to invasive plant species via the 

PDFs would mitigate effects by reducing the risk of introduction and spread, as Alternative 2 would 

remove the source of infestation and, hence, lead to beneficial cumulative effects (final EA pp. 138-142; 

Botany Weed Risk Assessment).

8. The degree to which the action may adversely affect districts, sites, highways, structures, or objects 

listed in or eligible for listing in the National Register of Historic Places or may cause loss or 

destruction of significant scientific, cultural, or historical resources.

In order to comply with the regulatory framework regarding the protection of cultural resources, pre-field 

research was conducted consisting of examination of previous archaeological surveys in the planning 

area, site records, maps, and GIS data. This data indicated that seven of those surveys were conducted 

within the area of potential effect (APE), defined as the project’s treatment units. These surveys have 

been carried out between 1978 and 2012.

The surveys resulted in the identification of 10 archaeological site, none of which is located within the 

APE. Archaeological surveys were conducted within the project’s APE between October 2016 and August 

2017 and recorded in a cultural resource inventory report (CRIR) on file in the Heritage Department of 
Finding of No Significant Impact

154 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

the SRNF Supervisor’s Office. Two archaeological sites were identified because of the archaeological 

surveys. Standard resource protection measures as defined in the R5 PA would fully protect 

archaeological sites within the APE (final EA pp. 122-124).

9. The degree to which the action may adversely affect an endangered or threatened species or its 

habitat that has been determined to be critical under the Endangered Species Act of 1973 (ESA).

The Endangered Species Act (ESA) of 1973 (16 USC 1531 et seq.) requires any action authorized by a 

federal agency to not jeopardize the continued existence of a threatened or endangered species, or result in 

the destruction or adverse modification of the critical habitat of such species. Section 7 of the ESA, as 

amended, requires the responsible federal agency to consult with the USFWS and the National Marine 

Fisheries Service (NMFS) concerning endangered and threatened species under their jurisdiction as follows:

Threatened and Endangered Wildlife Resources. Informal consultation with the USFWS was initiated 

through the interagency Level 1 Process. The 1st 48 Project was designed to ensure no adverse impacts to 

listed species would occur. The Level 1 team determined that the project was not likely to adversely affect 

NSO or designated NSO critical habitat. The USFWS concurred with this determination (final EA pp. 61-85; 

final Biological Assessment (BA)).

Threatened and Endangered Botanical Resources. No federally listed plant species are known to 

occur, nor does suitable habitat exist in the project area (final EA pp. 46, 124; Biological Assessment/

Biological Evaluation (BA/BE)).

Threatened and Endangered Aquatic Species. Three species of threatened and endangered (TE) 

salmonids are found in the Mad River watershed. Northern California steelhead trout (Oncorhynchus 

mykiss) are found in the mainstem Mad River up to Matthews Dam with critical habitat being designated 

up to County Line Creek. Chinook (California Coastal ESU; O. tshawytscha) and coho (Southern 

Oregon/Northern California ESU, O. kisutch) are found in the in mainstem Mad River up to “Bug Creek 

Falls” (approximately 27 miles downstream from Matthews Dam). As the proposed roadside treatment 

areas are located upstream of the Ruth Lake Dam, threatened, endangered and Forest Service Sensitive 

(TES) anadromous fish species cannot reach the project area and therefore the Proposed Action would 

have no effect on the anadromous TE species and their habitats (final EA pp. 46-47).

10. Whether the action threatens a violation of federal, state, or local law or requirements imposed for 

the protection of the environment.

Aquatic Conservation Strategy. The 1st 48 Project was developed in alignment with the Aquatic 

Conservation Strategy (ACS) reflected in the Record of Decision (ROD), and S&Gs of the Northwest 

Forest Plan (NWFP; USDA and USDI 1994) as incorporated into the SRNF LRMP (USDA Forest Service 

1995) and the KNF LRMP (USDA Forest Service 2010). The project is designed to fulfill specific 

objectives regarding the forest goals in the management of aquatic and riparian resources (SRNF IV-107), 

and to be consistent with the nine ACS objectives and the May 22, 2007 Memorandum. Implementation 

of the Proposed Action would not retard or prevent attainment of ACS objectives at the HUC (hydrologic 

unit code) 6th-level and larger scales in the short-term. Rather, it would promote attainment of ACS 

objectives in the long term. Cumulative watershed effects (CWE) would remain below threshold for 

adverse watershed effects (final EA pp. 98-102).

Forest Service Sensitive Wildlife Species. All Forest Service Sensitive wildlife species known or thought 

to occur in the project area, based on habitat and range, were evaluated for this project. It was determined 
Finding of No Significant Impact

Final Environmental Assessment – 155

that the project will not impact certain Forest Service Sensitive species, based on the lack of habitat, lack of 

detections during surveys, or the fact that habitat will not be impacted. Species that will not be affected by 

this project include the bald eagle (Haliaeetus leucocephalus), Townsend’s big-eared bat (Corynorthinus 

townsendii), fringed myotis (Myotis thysanodes), California wolverine (Gulo gulo luteus), Humboldt marten 

(Martes caurina), pallid bat (Antrozous pallidus), western bumblebee (Bombus occidentalis), western pond 

turtle (Clemmys marmorata), foothill yellow-legged frog (Rana boylii) southern torrent salamander 

(Rhyacotriton variegatus), and northern red-legged frog (Rana aurora aurora) (final EA pp. 86-89).

Pacific Fisher (Martes pennanti pacifica, also a Federal Candidate Species).

In northern California, fishers occupy mid-elevation, multi-storied mature and old-growth conifer, mixed 

conifer, and mixed-conifer hardwood forests with contiguous canopy cover. Fishers typically select closed 

canopies (>50%), but would use areas of low- to moderate-canopy cover (25 to 40%), if there is sufficient 

understory (Lofroth et al. 2010). They do not occur in high-elevation alpine or subalpine habitats.

My decision will maintain characteristics for denning, so habitats will continue to provide denning habitat 

immediately post-project. All riparian reserves will be buffered on both sides of stream channels and 

canopy closure will be maintained at 60 percent or greater. Little to no true riparian habitat exists within 

the units given the lack of riparian-vegetation-associated ephemeral and intermittent stream courses 

within the project area. However, in the long term, project implementation has the potential to improve 

riparian habitat conditions through the release of conifer and hardwoods/shrubs from thinning, generating 

a secondary canopy.

Of the 13,686 acres of fisher denning habitat within the action area, approximately 290 acres of low- and 

moderate-quality denning habitat will be treated. However, no high-quality habitat will be treated. 

Approximately 2 percent of the denning habitat within the action area will be treated (98% of the denning 

habitat in the action area will not receive any treatment).

In 2016, surveys were conducted in the 1st 48 Project area using camera stations. Fisher were detected in 

three (3) areas. Although no den sites have been located, limited operating periods (LOPs) will be 

imposed for all noise- and smoke-generating activities within 0.25 miles of fisher suitable habitat around 

the detection sites (final EA pp. 84-86).

Northern Goshawk (Accipiter gentilis).

Goshawks are known to use mature forest habitats for nesting and foraging. Nesting stands are typically 

in dense pockets of large trees, often on north-facing, bench slopes near water. Foraging habitats are often 

more open to allow for the aerial ambush foraging strategy of the goshawk. Goshawks occupy similar 

habitat to that of the NSO. There are approximately 13,686 acres of suitable goshawk habitat in the 1st 48 

Project area. Surveys were conducted in the 1st 48 Project area in 2017. No goshawks were detected.

Suitable habitat for the goshawk occurs in the planning area. No pre-dominant trees (potential nest trees) 

or dominant trees will be removed. Current canopy closure will be maintained. Removal of understory 

vegetation may improve foraging conditions for the goshawk. If nesting goshawks were subsequently 

found within 0.25 miles of any treatment units, LOPs will be imposed. The project may impact individual 

northern goshawk, but will not cause a trend towards listing (final EA pp. 88-94).

Foothill yellow-legged frog (Rana boylii).

The foothill yellow-legged frog is found in or near rocky streams or rivers in a variety of habitats. In 

California, breeding and egg laying usually wait until the end of spring flooding, and may commence 

anytime from mid-March to mid-June, depending on the occurrence of spring rains. These frogs are 
Finding of No Significant Impact

156 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

diurnal with adults often basking on exposed rock surfaces near streams. When disturbed, they dive into 

the water and take refuge under submerged rocks or sediments.

There is suitable habitat for foothill yellow-legged frogs in the planning area. In August 2017, tadpoles 

and adult frogs were observed in Littlefield Creek at the low-water crossing at milepost 0.4 on 2S53 (K. 

Kenfield personal observation). If water is not present during operations, commercial log hauling may 

proceed. If water is present, a temporary low-water crossing will be constructed. Currently noncommercial vehicles drive through the low-water ford. Installation of the temporary vented ford (two or 

more 36-inch pipes laid over geotextile cloth on the streambed with fill on top) will cause disturbance to 

an approximate 30-foot by 10-foot reach of stream. My decision will install a vented ford to eliminate 

vehicles entering the water during operations. The project may impact individuals, but will not cause a 

trend towards listing (final EA pp. 88-94).

Management Indicator Species and Migratory Bird Species. Under NFMA, the Forest Service is 

directed to “provide for diversity of plant and animal communities based on the suitability and capability 

of the specific land area in order to meet overall multiple-use objectives” (PL 94-588 §6 (g)(3)(B)). The 

1982 regulations implementing NFMA require that “Fish and wildlife habitat shall be managed to 

maintain viable populations of existing native and desired non-native vertebrate species in the planning 

area” (36 CFR 219.19). Management indicator species (MIS) is a concept used by the agency to serve as a 

barometer for species viability at the forest level. Population changes of MIS are believed to indicate the 

effects of management activities.

The SRNF LRMP uses MIS to assess potential effects of project activities on the various habitats and 

habitat assemblages with which these species are associated. Forty-one (41) fish and wildlife species have 

been selected as MIS or assemblages for a variety of habitats that are potentially affected by resource 

management activities on the Forest (USDA Forest Service 1995 p. IV-97).

Due to the scope, size, and intent of this project, there are no concerns of negative cumulative effects for 

MIS, migratory bird species (MBS), or other wildlife species. Direct, indirect and cumulative effects to 

MIS and MBS were addressed based on their potential to occur within the project area based on habitat 

suitability, survey results, or incidental sighting records.

The 1st 48 Project will not adversely impact MIS. Although shaded-fuelbreak construction will degrade 

habitat for species, such as the Pacific wren and ruffed grouse, through the removal of brush and 

understory trees, the majority of the project will improve/restore habitat conditions for all MIS by 

thinning young, homogeneous stands, accelerating the development of multi-storied conditions and other 

late-successional habitat characteristics. In addition, development of strategic fuelbreaks will help protect 

existing habitat from stand-replacing fire.

The crossing of Littlefield Creek by Forest Service road (FSR) 2S02 is thought to be perennial due to 

increased flow from the Ruth Fire (from reduced transpiration due to canopy removal). Resident rainbow 

trout and foothill yellow legged frog were found in the stream at the crossing. If the stream is flowing at 

the time needed for commercial haul, a temporary pipe array will be installed consisting of two (2) or 

more culverts, geotextile fabric, and clean gravel (i.e., no fine sediments). Installation of the temporary 

vented ford (two or more 36-inch pipes laid over geotextile cloth on the streambed with fill on top) will 

cause disturbance to an approximate 30 foot by 10 foot reach of stream (final EA pp. 88-94).

Survey and Manage Wildlife Species. No wildlife survey and manage (S&M) species occur within the 

1st 48 Project; therefore, no pre-project surveys were conducted. The 1st 48 Project will be in compliance 
Finding of No Significant Impact

Final Environmental Assessment – 157

with the Record of Decision for amendments to the survey and manage, protection buffer, and other 

mitigation measure standards and guidelines in Forest Service and Bureau of Land Management planning 

documents within the range of the northern spotted owl (USDA and USDI 2001), the April 25, 2013 9th 

Circuit Court Order in Conservation Northwest (and others) v. Sherman (No. 11-35729), and the February 

18, 2014 District Court Order in Conservation Northwest (and others) v. Robert Bonnie (and others) (W. 

WA No. C08-1067-JCC) (final EA pp. 91-94).
Finding of No Significant Impact

158 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

This page intentionally left blank.
Chapter 4. Consultation and Coordination

Final Environmental Assessment – 159

Chapter 4. Consultation and Coordination

Preparers and Contributors

Forest Service Interdisciplinary Team

The primary individuals involved in the development of the 1st 48 Roadside Fuelbreak Collaborative 

Project (1st 48 Project) environmental assessment (EA) are listed in Table 27.

Table 27. Interdisciplinary team (IDT) members.

Interdisciplinary Team Member Role or Resource Area

Merv L. George Jr. Responsible Official

Dan Dill Line Officer/Team Leader

Carol Spinos Environmental Planner, Writer/Editor

Krista Smith Wildlife

Brenda Devlin Wildlife

Bryan Yost Wildlife Consultation

Karen Kenfield Fisheries/Consultation/Editor

Adam Dresser Hydrology

Carolyn Cook Hydrology

Nancy Curran Fire and Fuels/ Air

Bridget Litten Public Affairs/Editor

John McRae Botany and Noxious Weeds

Doreen Hrivnak Heritage

Jennifer Dyer Heritage Consultation

Jennifer Peterson Geographic Information Systems (analysis and mapping)

Christy Prescott Recreation/Visuals

Kristen Lark Vegetation and Fuels

Jeff Jones Vegetation

Dave Young Soils

Natalie Cabrera Geology

Chase Bloom Transportation

Jeff Jones Vegetation/Range

Shirley Rech Forestry

Table 28 lists the members of the Trinity County Collaborative (TCC) working group who co-developed, 

participated in planning interdisciplinary meetings, and contributed to the preparation of the 1st 48 Project

draft and final EA.

Table 28. Trinity County Collaborative working group members.

TCC Members

Larry Glass

Tom Walz

Susan Bower

Dee Sanders

Arnold Whitridge

TCC Members

Bob Morris

Clarence Rose

Jerry Cousins

Alex Cousins
Chapter 4. Consultation and Coordination

160 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Federal, State, and Local Agencies

The Forest Service also consulted with the following federal, and state and local agencies during the 

development of this EA:

o National Marine Fisheries Service, California Coastal Branch

o US Fish and Wildlife Service

o State Historic Preservation Officer

o Environmental Protection Agency

o North Coast Regional Water Quality Control Board

Tribes

The Forest Service also consulted with the following local tribes during the development of this EA:

o Bear River Band of Rohnerville Rancheria

o Wiyot Tribe

o Round Valley Indian Tribes: A Sovereign Nation of Confederated Tribes

o Lassic Band of Wylacki-Wintoon Family Group Inc.
References

Final Environmental Assessment – 161

References

Forest Service Reports

Smith K. 2018. Biological Assessment and Evaluation for 1st 48 Roadside Fuelbreak Collaborative 

Project. On file at Six Rivers National Forest. Eureka, CA.

Smith, K. 2017. Management Indicator Species Report On file at Six Rivers National Forest. Eureka, CA.

Smith K. 2017. 1st 48 Roadside Fuelbreak Project – Migratory Birds. On file at Six Rivers National 

Forest. Eureka, CA.

McRae, J.D. 2018. Biological Assessment/Biological Evaluation for Threatened, Endangered, Sensitive 

Plant and Fungi Species. 1st 48 Roadside Fuelbreak Project, Mad River Ranger District, Six 

Rivers National Forest, January 15, 2018. On file Six Rivers National Forest, Eureka, CA.

Young, D. 2018. Soils Specialist Report for 1st 48 Roadside Fuelbreak Collaborative Project. On file at 

Six Rivers National Forest. Eureka, CA.

Literature Cited

Adams, S. and J. Sawyer. 1980. Past fire incidence in mixed evergreen forests of northwest California. 

Report on file Six Rivers National Forest. 22pp.

Agee, J.K. and Skinner, C.N., 2005. Basic principles of forest fuel reduction treatments. For. Ecol. 

Manag. 211:83-96. https://doi.org/10.1016/j.foreco.2005.01.034.

Amaranthus, M.P. and D. Page-Dumroese, A. Harvey, D. Cazares and L.F. Bednar. 1996. Soil compaction 

and organic matter removal affect conifer seedling nonmycorrhizal and ECM root tip abundance 

and diversity. USDA Forest Service PNW-RP-494, 12pp.

Amaranthus, M.P. and D.A. Perry. 1994. The functioning of ectomycorrhizal fungi in the field: linkages in 

space and time. Plant and soil 159:133-140.

Anthony, R.G. and F.F. Wagner. 1999. Reanalysis of northern spotted owl habitat use on the Miller 

Mountain Study Area. Unpublished report. Submitted to Bureau of Land Management, Medford 

District and Forest and Rangeland Ecosystem Science Center, Biological Resources Division, US 

Geological Survey. NO ELECTRONIC COPY AVAILABLE.

Bailey, J.D. and J.C. Tappeiner. 1998. Effects of thinning on structural development in 40- to 100-year-old 

Douglas-fir stands in western Oregon. For. Ecol. Manage. 108:99-113.

Baker, W. 2012. Implications of spatially extensive historical data from surveys for restoring dry forests 

of Oregon’s eastern Cascades. Ecosphere, March 2012, Volume 3(3), Article 23.

Barrows, C. 1980. Feeding ecology of the spotted owl in California. Raptor Research 14:73-78.

Bond, M.L., D.E. Lee, R.B. Siegel and J.P. Ward Jr. 2009. Habitat use and selection by California spotted 

owls in a postfire landscape. Journal of Wildlife Management 73:1116-1124.
References

162 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Bosch, J.M. and J.D. Hewlett. 1982. A review of catchment experiments to determine the effect of 

vegetation changes on water yield and evapotranspiration. J. Hydrol. 55:3-23.

Bruns, T.D. 1995. Thoughts on the processes that maintain local species diversity of ectomycorrhizal 

fungi. Plant and Soil. Kluwer Academic Publishers. Netherlands. 170:63-73.

Busse, M.D., G.O. Fiddler and C.J. Shestak. 2017. Conifer root proliferation after 20 years of soil 

compaction. Forest Science 63(2):147-150.

Busse, M.D., C.J. Shestak and K.R. Hubbert. 2013. Soil heating during burning of forest slash piles and 

wood piles. International Journal of Wildland Fire 22:786-796.

Busse, M. D., C.J. Shestak, K.R. Hubbert and E.E. Knapp. 2010. Soil Physical Properties Regulate Lethal 

Soil Heating during Burning of Woody Residues. Soil Science Society of America Journal 

74:947-955.

Carey, A.B. 2007. Aiming for Healthy Forests: active, intentional management for multiple values. 

General Technical Report PNW-GTR-721.

Carey, A.B. 1995. Sciurids in Pacific Northwest Managed and Old-Growth Forests. Ecological 

Applications 5(3):648-661.

Carey, A.B. and K.C. Peeler. 1995. Spotted owls: resource and space use in mosaic landscapes. Journal of 

Raptor Res. 29(4):223-239.

Carey, A.B., S.P. Horton and B.L. Biswell. 1992. Northern spotted owls: influence of prey base and 

landscape character. Ecological Monographs 62(2):223-250.

Carroll, C., W. Zielinski and R. Noss. 1999. Using presence-absence data to build and test spatial habitat 

models for the fisher in the Klamath Region, USA Conservation Biology 13:1344-1359.

Clark, D.A. 2007. Demography and Habitat Selection of Northern Spotted Owls in Post-fire Landscapes 

of Southwestern Oregon. Master’s Thesis submitted to Oregon State University, Corvallis, OR. 

201pp.

Dahlberg, A. and J. Stenlid. 1995. Spatiotemporal patterns in ectomycorrhizal populations. Canadian 

Journal of Botany 73 (Supplement) S1222-S1230.

de la Fuente, J., D. Elder and A. Miller. 2002. Does deforestation influence the activity of deep-seated 

landslides? Observations from the flood of 1997 in the central Klamath Mountains, northern 

California. Geologic Society of America 98th Annual Meeting Poster.

DeBano, L.F., D.G. Neary, P.F. Folliott. 1998. Fire’s Effects on Ecosystems. John Wiley & Sons, Inc. 

10158-0012.

DellaSala, D.A.; J.E. Williams; C.D. Williams and J.F. Franklin. 2004. Beyond smoke and mirrors: a 

synthesis of fire policy and science. Conservation Biology. 18:976-986.

Dennis, W.M., P.A. Collier, P. DePriest and E.L. Morgan. 1981. Habitat notes on the aquatic lichen 

Hydrothyria venosa J.L. Russel in Tennessee, Bryologist 84:402-403.
References

Final Environmental Assessment – 163

DiTomaso, J. and E. Healy. 2007. Weeds of California and Other Western States. University of California 

Agriculture and Natural Resources, Publication 3488:250-260.

Drever, C.R., G. Peterson, C. Messier, Y. Bergeron and M. Flannigan. 2006. Can forest management 

based on natural disturbances maintain ecological resilience? Canadian Journal of Forest 

Research 36:2285-2299.

Dugger, K.M., R.G. Anthony and L.S. Andrews. 2011. Transient dynamics of invasive competition: 

Barred Owls, Spotted Owls, habitat, and the demons of competition present. Ecological 

Applications, 21(7):2459-2468.

Durall, D.M., M.D. Jones, E.F. Wright, P. Kroeger and K.D. Coates. 1999. Species richness of 

ectomycorrhizal fungi in cutblocks of different sizes in the Interior Cedar-Hemlock forests of 

northwestern British Columbia: sporocarps and ectomycorrhizae. Canadian Journal of Forest 

Research. 29(9):1322-1332.

Fettig, C.J., K.D. Klepzig, R.F. Billings, A.S. Munson, T.E. Nebeker, J.F. Negrón and J.T. Nowak. 2007. 

The effectiveness of vegetation management practices for prevention and control of bark beetle 

infestations in coniferous forests of the western and southern United States. For. Ecol. Manag. 

238:24-53.

Forsman, E.D. 1975. A preliminary investigation of the spotted owl in Oregon. Thesis, Oregon State 

University, Corvallis. 145pp.

Forsman, E.D., E.C. Meslow and H.M. Wight. 1984. Distribution and biology of the spotted owl in 

Oregon. Wildlife Monographs 87:1-64.

Forsman, E.D., R.G. Anthony, E.C. Meslow and C.J. Zabel. 2004. Diets and foraging behavior of northern 

spotted owls in Oregon. Journal of Raptor Research 38:214-230.

Forsman, E.D., R.G. Anthony, K.M. Dugger, E.M. Glenn, A.B. Franklin, G.C. White, C.J. Schwarz, K.P. 

Burnham, D.R. Anderson, J.D. Nichols, J.E. Hines, J.B. Lint, R.J. Davis, S.H. Ackers, L.S. 

Andrews, B.L. Biswell, P.C. Carlson, L.V. Diller, S.A. Gremel, D.R. Herter, J.M. Higley, R.B. 

Horn, J.A. Reid, J. Rockweit, J. Schaberl, T.J. Snetsinger and S.G. Sovern. 2011. Population 

demography of northern spotted owls: 1985-2008. Studies in Avian Biology. Cooper 

Ornithological Society.

Franklin, J.F., D.R. Berg, A.B. Carey and R.A. Hardt. 2006. Chapter 5: Old-growth forests. Pages 97-121 

in D. Apostol and M. Sinclair (editors), Restoring the Pacific Northwest: The Art and Science of 

Ecological Restoration in Cascadia. Island Press, Washington, DC, 475 pp.

Franklin, J.F., R.J. Mitchell and B.J. Palik. 2007. Natural disturbance and stand development principles 

for ecological forestry. General Technical Report NRS-GTR-19, Northern Research Station, US

Department of Agriculture, Forest Service, Newtown Square, PA. BOOK.

Franklin, J.F., T.A. Spies, R. Van Pelt, A.B. Carey, D.A. Thornburgh, D.R. Berg, D.B. Lindenmayer, M.E. 

Harmon, W.S. Keeton, D.C. Shaw, K. Bible and J. Chen. 2002. Disturbances and structural 

development of natural forest ecosystems with silvicultural implications, using Douglas-fir 

forests as an example. Forest Ecology and Management 155:399-423.
References

164 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Gelbard, J.L. and S. Harrison. 2003. Roadless habitats as refuges for native grasslands: interactions with 

soil, aspect, and grazing. Ecological Applications 13:404-415.

Graham, R., A. Harvey, T. Jain and J. Tonn. 1999. Effects of thinning and similar stand treatments on fire 

behavior in western forests. USDA Forest Service, Pacific Northwest Research Station, General 

Technical Report PNW-GTR-463.

Graham, R.T., S. McCaffrey and T.B. Jain. 2004. Science Basis for Changing Forest Structure to Modify 

Wildfire Behavior and Severity. General Technical Report RMRS-GTR-120. USDA Forest 

Service, Rocky Mountain Forest and Range Experiment Station, Fort Collins, CO.

Gustafsson, L., S.C. Baker, J. Bauhus, W.J. Beese, A. Brodie, J. Kouki, D.B. Lindenmayer, A. Lõhmus, 

G.M. Pastur, C. Messier, M. Neyland, B. Palik, A. Sverdrup-Thygeson, W. Jan, A. Volney, A. 

Wayne and J.F. Franklin. 2012. Retention Forestry to Maintain Multifunctional Forests: A World 

Perspective, BioScience, 62(7):633-645.

Gutiérrez, R.J. 1996. Biology and distribution of the northern spotted owl. Studies in Avian Biology 17:2-5.

Hamer, T.E. 1988. Home range size of the Northern Barred Owl and Northern Spotted Owl in western 

Washington. M.Sc. thesis, Western Washington University, Bellingham, WA.

Hamer, T.E., E.D. Forsman and E.M Glenn. 2007. Home range attributes and habitat selection of barred 

owls and spotted owls in an area of sympatry. Condor 109:750-768.

Hansen, D.L. and M.J. Mazurek. 2010. Effects of forest thinning on northern spotted owls. Unpublished 

white paper.

Hanson, C.T., D.C. Odion, D.A. DellaSala and W.L. Baker. 2009. Overestimation of fire risk in the 

Northern Spotted Owl Recovery Plan. Conservation Biology 23:1314-1319.

Healey, S.P., W.B. Cohen, T.A. Spies, M. Moeur, D. Pflugmacher, M.G. Whitley and M. Lefsky. 2008. 

The Relative Impact of Harvest and Fire upon Landscape-Level Dynamics of Older Forests: 

Lessons from the Northwest Forest Plan. Ecosystems 11:1106-1119.

Helms, J.A. ed. 1998. The Dictionary of Forestry. Society of American Foresters, Bethesda, MD, 210pp.

Hermann, R.K. and D.P. Lavender. 1990. Pseudotsuga menziesii Mirb. Franco. Douglas-fir. In: Silvics of 

North America, Volume 1. Conifers. USDA For. Serv. Agric. Handbook. 654, Washington, DC, 

pp. 527-540.

Herter, D.R. and L.L. Hicks. 2000. Barred Owl and Spotted Owl populations and habitat in the central 

Cascade Range of Washington. Journal of Raptor Research 34:279-286.

Hessburg, P.F., R.B. Salter and K.M. James. 2007. Re-examining fire severity relations in premanagement era mixed conifer forests: inferences from landscape patterns of forest structure. 

Landscape Ecology 22.1:5-24.

Heyerdahl, E.K, A.G. McKenzie, L.D. Daniels, A.E. Hessl, J.S. Littell and N.J. Mantua. 2008. Climate 

drivers of regionally synchronous fires in the inland Northwest (1651-1900). International Journal 

of Wildland Fire, 17:40-49.
References

Final Environmental Assessment – 165

Humboldt Bay Municipal Water District. 2004. Habitat Conservation Plan for its Mad River Activities,

Final Approved HCP – April 2004, Eureka, CA. 168 pp.

Irwin, L.L., D.F. Rock and S.C. Rock. 2012. Habitat Selection by Northern Spotted Owls in MixedConiferous Forests. The Journal of Wildlife Management 76(1):200-213.

Irwin, L.L., L.A. Clark, D.F. Rock and S.L. Rock. 2007. Modeling Foraging Habitat of California Spotted 

Owls. Journal of Wildlife Management 71(4):1183-1191.

Iverson, R.M. 2000. Landslide triggering by rain infiltration. Water Resources Research 36(7):1897-1910.

Jenkins, M.J, W.G. Page, E.G. Hebertson and M.E. Alexander. 2012. Fuels and fire behavior dynamics in 

bark beetle-attacked forests in Western North America and implications for fire management. 

Forest Ecology and Management 275 (2012) 23-34.

Jimerson, T. M., E.A. McGee, D.W. Jones, R.J. Svilich, E. Hotalen, G. DeNitto, T. Laurent, J.D. Tenpas, 

M. Smith, K. Hefner-McClelland and J. Mattison. 1996. A Field Guide to the Tanoak and the 

Douglas-fir Plant Associations in Northwestern California. USDA Forest Service, Pacific 

Southwest Region. R5-ECOL-TP-009.

Kaye, T.N. and J.R. Cramer, Institute for Applied Ecology. 2005 Conservation Assessment for 

Cypripedium fasciculatum and Cypripedium montanum, Region 5-USDA Forest Service. On file 

Six Rivers National Forest, Eureka, CA.

Kelly, E.G., E.D. Forsman and R.G. Anthony. 2003. Are barred owls displacing spotted owls? Condor 

105:45-53.

Kennedy, R.S.H. and M.C. Wimberley. 2009. Historical fire and vegetation dynamics in dry forests of the 

interior Pacific Northwest, USA, and relationships to Northern Spotted Owl (Strix occidentalis 

caurina) habitat conservation. USDA Forest Service Pacific Northwest Research Station, Forestry 

Sciences Laboratory, 3200 Forest Ecology and Management 258:554-566.

Latta, G., H. Temesgen, D. Adams and T. Barrett. 2010. Analysis of potential impacts of climate change 

on forests of the United States Pacific Northwest. Forest Ecology and Management 259:720-729.

Levitan, F. 2014. Thoughts on high severity fire, deep-seated landslides, and fuels treatments in the Sims 

Fire restoration area. Six Rivers National Forest Sims Restoration project file. 1330 Bayshore 

Way, Eureka, CA.

Littell, J.S., D. McKenzie, D.L. Peterson and A.L. Westerling. 2009. Climate and wildfire area burned in 

western US ecoprovinces, 1916-2003. Ecological Applications, 19(4):1003-1021.

Littell, J.S., E.E. O’Neil, D. McKenzie, J.A. Hicke, J.A. Lutz, R.A. Norheim and M.M. Elsner. 2010. 

Forest ecosystems, disturbance, and climatic change in Washington State, USA. Climatic Change 

102:129-158.

Lofroth, E.C., C.M. Raley, J.M. Higley, R.L. Truex, J.S. Yaeger, J.C. Lewis, P.J. Happe, L.L. Finley, R.H. 

Naney, L.J. Hale, A.L. Krause, S.A. Livingston, A.M. Myers and R.N. Brown. 2010. 

Conservation of Fishers (Martes pennanti) in South-Central British Columbia, Western

Washington, Western Oregon, and California–Volume I: Conservation Assessment. USDI Bureau 

of Land Management, Denver, CO.
References

166 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Long, J.N. 2009. Emulating natural disturbance regimes as a basis for forest management: A North 

American view. Forest Ecology and Management 257:1868-1873.

Mad River Watershed Assessment. 2010. Final report. Prepared by Stillwater Sciences, Arcata, California 

in association with Redwood Community Action Agency, and Natural Resources Management 

Corp. Eureka, CA.

Marlon, J.R., P.J. Bartlein, D.G. Gavin, C.J. Long, R.S. Anderson, C.E. Briles, K.J. Brown, D. 

Colombaroli, D.J. Hallett, M.J. Power, E.A. Scharf and M.K. Walsh. 2012. Long-term perspective 

on wildfires in the western USA. Published online February 14, 2012 

www.pnas.org/cgi/doi/10.1073/pnas.1112839109.

McLaughlin, R.J., S.D. Ellen, M.C. Blake, A.S. Jayko, W.P. Irwin, K.R. Aalto, G.A. Carver and Clarke, 

S.H. 2000. Geology of the Cape Mendocino, Eureka, Garberville, and southwestern part of the 

Hayfork 30 x 60 minute quadrangles and adjacent offshore area, northern California. US 

Geological Survey, Miscellaneous Field Studies Map MF-2336. Retrieved from 

https://pubs.usgs.gov/mf/2000/2336/.

McNab, W. H. and P. E. Avers. 1994. Ecological subregions of the United States: section descriptions.

Mikulovsky, R.P., J.A. De la Fuente, A. Bell, M. Stevens and F. Levitan. 2012. Reactivation of DeepSeated Landslides in Northwestern California after Wildfires in 2006 and 2008. American 

Geophysical Union, fall 2012 meeting, San Francisco, CA.

Miller, C. and D.L. Urban. 2000. Modeling the effects of fire management alternatives on Sierra Nevada 

mixed-conifer forests. Ecol. Appl. 10:85-94.

Miller, J.D., C.N. Skinner, H.D. Safford, E.E. Knapp and C.M. Ramirez. 2012. Trends and causes of 

severity, size, and number of fires in northwestern California, USA. Ecological Applications, 

22(1):184-203.

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 12:16-32.

Nash III, T.H. 1996. Lichen Biology. Cambridge University Press, Cambridge, UK. 303pp.

Noon, B.R. and J.A. Blakesley. 2006. Conservation of the northern spotted owl under the Northwest 

Forest Plan. Conservation Biology 20:288-296.

Norden, B., M. Fyberg, F. Gotmark and B. Olausson. 2004. Relative importance of coarse and fine woody 

debris for the diversity of wood-inhabiting fungi in temperate broadleaf forests. Biological 

Conservation 117, pp. 1-10.

North, M.P., J.F. Franklin, A.B. Carey, E.D. Forsman and T. Hamer. 1999. Forest stand structure of the 

northern spotted owl's foraging habitat. Forest Science 45:520-527.

Oliver, C.D. and B.C. Larson. 1996. Forest stand dynamics: updated edition. John Wiley and sons.

Perry, D.A., P.F. Hessburg, C.N. Skinner, T.A. Spies, S.L. Stephens, A.H. Taylor, J.F. Franklin, B. 

McComb and G. Riegel. 2011. The ecology of mixed severity fire regimes in Washington, 

Oregon, and Northern California. Forest Ecology and Management 262 (2011) 703-717.
References

Final Environmental Assessment – 167

Ponder Jr., F., R.L. Fleming, S. Berch, M.D. Busse, J.D. Elioff, P.W. Hazlett, R.D. Kabzems, J.M. 

Kranabetter, D.M. Morris, D. Page-Dumroese, R.F. Powers, F.G. Sanchez, D.A. Scott, R.H. 

Stagg, D. Young, J. Zhang, D.W. McKenney, D.S. Mossa, P.T. Sanborn, D.M. Stone and R.A. 

Voldseth. 2012. Effects of organic matter removal, soil compaction, and vegetation control on 

10th-year biomass and foliar nutrition: LTSP continent-wide comparisons. Forest Ecology and 

Management 278:35-54.

Powers, R.F.D., A. Scott, F.G. Sanchez, R.A. Voldseth, D. Page-Dumroese, J.D. Elioff and D.M. Stone. 

2005. The North American Long-Term Soil Productivity Experiment: Findings from the first 

decade of research. Forest Ecology and Management 220:31-50.

Reid, L. 2010. Chapter 6. Cumulative effects of fuel treatments on channel erosion and mass wasting. In 

Cumulative Watershed Effects of Fuel Management in the Western United States. USDA Forest 

Service RMRS-GTR-231-125.

Roath, B. 2006. Detrimental Compaction Risk Rating Guide. Region 5 Version 1.

Roering, J.J., K.M. Schmidt, J.D. Stock, W.E. Dietrich and D.R. Montgomery. 2003. Shallow landsliding, 

root reinforcement, and the spatial distribution of trees in the Oregon Coast Range. Can. Geotech. 

J. 40:237-253.

Roering, J.J. and M. Jackson. 2009. Post-fire geomorphic response in steep, forested landscapes: Oregon 

Coast Range, USA. Quaternary Science Reviews 28:1131-1146.

Rolof, G.J., S.P. Mealey, C. Clay, J. Barry, C. Yanish and L. Neuenschwander. 2005. A process for 

modeling short- and long-term risk in the southern Oregon Cascades. Forest Ecology and 

Management 211:166-190.

Rosenberg, D.K. and R.G. Anthony. 1992. Characteristics of northern flying squirrel populations in young 

second- and old-growth forests in western Oregon. Canadian Journal of Zoology 70:161-166.

Rosenberg, D.K., C.J. Zabel, B.R. Noon and E.C. Meslow. 1994. Northern spotted owls: Influence of 

prey base–A comment. Ecology, 75(5):1512.

Rothermel, R.C. 1983. How to predict the spread and intensity of forest and range fires. Intermountain 

Forest and Range Experiment Station General Tech. Rep. INT-143, USDA Forest Service, 161 

pp.

Rust, B. 2009. Lakehead Mastication Soil Monitoring Report. On file with the Shasta-Trinity NF and the 

author of this report.

Safford H.D., D.A. Schmidt and C.H. Carlson. 2009. Effects of fuel treatments on fire severity in an area 

of wildland-urban interface, Angora Fire, Lake Tahoe Basin, California. Forest Ecol. Manage., 

258:773-787.

Sakai, H.F. and B.R. Noon. 1993. Dusky-footed woodrat abundance in different-aged forests in 

northwestern California. Journal of Wildlife Management 57:373-382.

Scott, J. and E. Reinhardt. 2001. Assessing crown fire potential by linking models of surface and crown 

fire behavior. Research Paper RMRS-RP-448 H-E.
References

168 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Skinner, C.N., M.W. Ritchie, T. Hamilton and J. Symons. 2004. Effects of prescribed fire and thinning on 

wildfire severity. In Cooper, S., editor, Proceedings 25th annual vegetation management 

conference, January 2004, Redding, California. University of California Cooperative Forestry 

Extension. Redding, CA, pp. 80-91.

Smith, D.M., B.C. Larson, M.J. Kelty and P.M.S. Ashton. 1997. The practice of silviculture: Applied 

forest ecology. John Wiley and Sons, Inc.

Solis, D.M. 1983. Summer habitat ecology of spotted owls in Northwestern California. Thesis, Humboldt 

State University, Arcata, CA.

Solis, D.M. and R.J. Gutiérrez. 1990. Summer habitat ecology of northern spotted owls in northwestern 

California. Condor 92:739-748.

Spies, T.A., J.D. Miller, J.B. Buchanan, J.F. Lehmkuhl, J.F. Franklin, S.P. Healey, P.F. Hessburg, H.D. 

Safford, W.B. Cohen, R.S.H. Kennedy, E.E. Knapp, J.K. Agee and M. Moeur. 2010. 

Underestimating risks to the northern spotted owl in fire-prone forests: response to Hanson et al. 

Conservation Biology 24:330-333.

Spittler, T. E. 1989. Controlled Burns on the Urban Fringe, Mount Tamalpais, Marin County, California. 

USDA Forest Service Gen. Tech. Rep. PSW-109:43-48.

Stein, S.M., J. Menakis, M.A. Carr, S.J. Comas, S.I. Stewart, H. Cleveland, L. Bramwell and V.C. Radeloff. 

2013. Wildfire, wildlands, and people: understanding and preparing for wildfire in the wildlandurban interface – A Forests on the Edge report. Gen. Tech. Rep. RMRS-GTR-299. Fort Collins, CO. 

US Department of Agriculture, Forest Service, Rocky Mountain Research Station. 36pp.

Stephens, S.L., J.D. McIver, R.E.J. Boerner, C.J. Fettig, J.B. Fontaine, B.R. Hartsough, P. Kennedy and 

D.W. Schwilk. 2012. Effects of forest fuel reduction treatments in the United States. BioScience 

62:549-560.

Sugihara, N.G., J.W. van Wagtendonk, K.E. Shaffer, J. FitesKaufman and A.E. Thode (eds). 2006. Fire in 

California’s Ecosystems. University of California Press. 596pp.

Swanson, M.E., J.F. Franklin, R.L. Beschta, C.M. Crisafulli, D.A. DellaSala, R.L. Hutto, D.B. Lindenmayer 

and F.J. Swanson. 2010. The forgotten stage of forest succession: early-successional ecosystems on 

forest sites. Frontiers in Ecology and the Environment. https://doi.org/10.1890/090157.

Syphard, A.D., R.M. Scheller, B.C. Ward, W.D. Spencer and J.R. Strittholt. 2011. Simulating landscapescale effects of fuels treatments in the Sierra Nevada, CA. International Journal of Wildland Fire 

20:364-383.

Tappeiner, J.C., D.A. Maguire and T.B. 2007. Silviculture and ecology of western US forests. Oregon 

State University Press. Book, No Electronic Copy.

Taylor, A.H. and C.N. Skinner. 2003. Spatial and temporal patterns of historic fire regimes and forest 

structure as a reference for restoration of fire in the Klamath Mountains. Journal of Arid Land 

Studies. 13:704-719.
References

Final Environmental Assessment – 169

Thomas, J.W., M.G. Raphael, R.G. Anthony, E.D. Forsman, A.G. Gunderson, R.S. Holthausen, B.G. 

Marcot, G.H. Reeves, J.R. Sedell and D.M. Solis. 1993. “SAT Report”. Viability assessments and 

management considerations for species associated with late-successional and old-growth forests 

of the Pacific Northwest. US Forest Service, Portland, OR.

Thome, D.M., C.J. Zabel and L.V. Diller. 1999. Forest Stand Characteristics and Reproduction of 

Northern Spotted Owls in Managed North-Coastal California Forests. The Journal of Wildlife 

Management 63(1):44-59.

Thompson, J., L. Diller, R. Golightly and R. Klug. 2007. Fisher (Martes pennanti) Use of a Managed 

Forest in Coastal Northwest California. USDA Forest Service General Technical Report PSWGTR-194. 2pp.

Trinity County Community Wildfire Protection Plan. 2010.

USDA and USDI. 2014. The National Strategy: The Final Phase in the Development of the National 

Cohesive Wildland Fires Management Strategy. April 2014.

USDA and USDI. 2001. Record of Decision for amendments to the survey and manage, protection buffer, 

and other mitigation measure standards and guidelines in Forest Service and Bureau of Land 

Management planning documents within the range of the northern spotted owl. US Department of 

Agriculture and US Department of the Interior. 160pp.

USDA and USDI. 1994a. Record of Decision for Management of Habitat for Late-Successional and OldGrowth Forest Related Species within the Range of the Northern Spotted Owl.

USDA and USDI. 1994b. Final Supplemental Environmental Impact Statement on Management of 

Habitat for Late-Successional and Old-Growth Forest Related Species Within the Range of the 

Northern Spotted Owl, Volume I.

USDA and USDI Interagency Regional Ecosystem Office. 2009. Memorandum. Forest-wide latesuccessional reserve management assessment. October 18, 2009.

USDA Forest Service. 2018. Biological Assessment/Evaluation, Forest-wide Reference Document. 

Unpublished report. Original publication 1997, last update 1/31/2018. Six Rivers National Forest. 

131pp.

USDA Forest Service. 2014. Six Rivers Best Management Practices: Invasive Plant and Aquatic Organisms. 

Signed April 18, 2014, Tyrone Kelley, Forest Supervisor. On file Six Rivers National Forest.

USDA Forest Service. 2013a. Forest Service National Strategic Framework for Invasive Species 

Management. FS-1017. August 2013. Washington, DC.

USDA Forest Service. 2013b. R5 Programmatic agreement among the USDA Forest Service, Pacific 

Southwest Region (Region 5), California State Historic Preservation Officer, Nevada State 

Historic Preservation Officer, and the Advisory Council on Historic Preservation regarding the 

processes for compliance with Section 106 of the National Historic Preservation Act for 

management of historic properties by the national forests of the Pacific Southwest Region. 

Vallejo, California. 124 pp.
References

170 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

USDA Forest Service. 2012. FS-990a: National Best Management Practices for Water Quality 

Management on National Forest System Lands.

USDA Forest Service. 1999. Forest-wide late-successional reserve management assessment. Shasta 

Trinity National Forests Aug 26, 1999.

USDA Forest Service. 1998. Upper Mad River Watershed Assessment. Six Rivers National Forest. 

Eureka, CA.

USDA Forest Service. 1995. Six Rivers National Forest Land and Resource Management Plan and 

Record of Decision. Six Rivers National Forest, Pacific Southwest Region, USDA Forest Service.

USDA Forest Service. 1994. Final environmental impact statement Shasta-Trinity National Forests land 

and resource management plan.

USDA Forest Service. 1993. Six Rivers National Forest Soil Survey. On file at Six Rivers National 

Forest, Eureka, CA.

USDA Forest Service. 1985. Ecology and Management of the Spotted Owl in the Pacific Northwest. 

Technical PNW-185.

USDI Fish and Wildlife Service. 2018. IPaC database.

USDI Fish and Wildlife Service. 2012. Letter from Paul Henson (USFWS) Steve Homer (American Bird 

Conservancy) dated April 30, 2012, regarding the 2012 proposed critical habitat rule, climate 

change, and spotted owl recovery. US Fish and Wildlife Service, Portland, OR.

USDI Fish and Wildlife Service. 2011. Revised recovery plan for the northern spotted owl (Strix 

occidentalis caurina). US Fish and Wildlife Service, Portland, OR.

USDI Fish and Wildlife Service. 2009. Regulatory and scientific basis for US Fish and Wildlife Service 

guidance for evaluation of take for northern spotted owls on private timberlands in California’s 

northern interior region. 78pp.

USDI Fish and Wildlife Service. 2008. Recovery plan for the northern spotted owl (Strix occidentalis 

caurina). Region 1, US Fish and Wildlife Service, Portland, OR.

van Mantgem, P.J., N.L. Stephenson, J.C. Byrne, L.D. Daniels, J.F. Franklin, P.Z. Fule, M.E. Harmon, 

A.J. Larson, J.M. Smith, A.H. Taylor and T.T. Veblen. 2009. Widespread Increase of Tree 

Mortality Rates in the Western United States. Science 323:521-524. 

https://doi.org/10.1126/science.1165000.

Vernon, M.J. 2017. In the face of drought: Do fuel treatments promote drought resistance in Whiskeytown 

National Recreation Area? Humboldt State University, Arcata, CA.

Ward Jr., J.P. 1990. Spotted owl reproduction, diet and prey abundance in northwest California. M.S. 

Thesis, Humboldt State Univ., Arcata, CA. 70pp.

Ward Jr., J.P., R.J. Gutierrez and B.R. Noon. 1998. Habitat selection by Northern Spotted Owls: the 

consequences of prey selection and distribution. Condor 100:79-92.
References

Final Environmental Assessment – 171

Waring R.H., N.C. Coops and S.W. Running. 2011. Predicting satellite-derived patterns of large-scale 

disturbances in forests of the Pacific Northwest Region in response to recent climatic variation. 

Remote Sensing of Environment 115:3554-3566.

Weaverville Community Forest Strategic Plan 2010-2015. A Collaborative effort of the Community and 

Trinity County Resource Conservation District, Bureau of Land Management – Redding Field

Office, and the US Forest Service – Shasta Trinity National Forest/Trinity River Management 

Unit. February 2010.

Weisberg, P.J. 2004. Importance of non-stand-replacing fire for the development of forest structure in the 

Pacific Northwest, USA. Forest Science 50:245.

White, K. 1996. Comparison of fledging success and sizes of prey consumed by spotted owls in 

northwestern California. Journal of Raptor Research 30: 234-236.

Williams, D.F., J. Verner, H.F. Sakai and J.R. Waters. 1992. General biology of the major prey species of 

the California spotted owl.in J. Verner, editor. The California Spotted Owl: A Technical 

Assessment of its Current Status. General Technical Report PSW-GTR-133. Pacific Southwest 

Research Station, Albany, CA.

Wondzell, S.M. and J.G. King. 2003. Postfire erosional processes in the Pacific Northwest and Rocky 

Mountain regions. Forest Ecology and Management 178:75-87.

Zabel, C.J., J.R. Dunk, H.B. Stauffer, L.M. Roberts, B.S. Mulder and A. Wright. 2003. Northern spotted 

owl habitat models for research and management application in California (USA). Ecological 

Applications, 13(4):1027-1040.

Zabel, C.J., K. McKelvey and J.P. Ward Jr. 1995. Influence of primary prey on home-ranges size and habitatuse patterns of Northern Spotted Owls (Strix occidentalis caurina). Can. J. Zool. 73:433-439.

Zabel, C.J., K. McKelvey, P.W.C. Paton, B.B. Bingham and B.R. Noon. 1993. Home range size and 

habitat use patterns of northern spotted owls in northwestern California and southwestern Oregon. 

Unpublished manuscript. NO ELECTRONIC COPY AVILABLE.

Zhang, J., M.D. Busse, D.H. Young, G.O. Fiddler, J.W. Sherlock and J.D. TenPas. 2017. Aboveground 

biomass responses to organic matter removal, soil compaction, and competing vegetation control 

on 20-year mixed conifer plantations in California. Forest Ecology and Management 401:341-353.

Zhang, J., J. Webster, D.H. Young and G.O. Fiddler. 2016. Effect of thinning and soil treatments on Pinus 

Ponderosa plantations: 15-year results. Forest Ecology and Management 368:123-132.

Ziemer, R. 1981. The role of vegetation in the stability of forested slopes. Proceedings of the International 

Union of Forestry Research Organizations, XVII World Congress. Kyoto, Japan. Vol. I, pp. 297-308.
References

172 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

This page intentionally left blank.
Appendix A. Response to Comments

Final Environmental Assessment – 173

Appendix A. Response to Comments

Scoping Period 

This section discloses the response to public comments received during the 30-day scoping period held 

between April 14 and May 5, 2017, in compliance with the National Environmental Policy Act (NEPA). 

On April 25, 2017, the US Forest Service (USFS or Forest Service) and a representative from the Trinity 

County Collaborative (TCC) jointly hosted a public meeting at the Ruth Community Center, in Mad 

River, California. The objective of the public meeting was to invite public participation in selecting key 

road systems to establish defensible space used to define the project area and refine treatment methods. 

Ten members of the local community attended the public meeting. 

Summary of Scoping Comments Received

In response to scoping notifications (letter, posting on the Six Rivers National Forest (SRNF or forest) 

website and email), the Responsible Official received written comments from one (1) agency, five (5) 

organizations, and two (2) individuals. Table 29 provides a compiled listing of the names and locations of 

the commenters, the organization or entity each commenter represents, and the type and date of the 

comment submitted. 

Table 29. Listing of the names and locations of the commenters, the organization or entity each commenter 

represents, and the type and date of the comment submitted. 

Comment ID 

Code Commenter Entity Location Type Date of Comment

1 Patsy Lewis Individual Mad River, CA

Meeting 

handout 

form

April 25, 2017

2 Kimberly Baker, Public 

Land Advocate

Environmental Protection 

Information Center (EPIC) Arcata, CA Email May 5, 2017

3 Dean Prat, Senior 

Engineering Geologist

North Coast Regional Water 

Quality Control Board (NCRWCB) 

Northern Nonpoint Source and 

Forestry Unit

Santa Rosa, CA Email May 9, 2017

4 John Elgin, Chairperson;

LWW Board of Directors

Lassic Band of Wylacki-Wintoon 

Family Group, Inc. (LWW) Mad River, CA Email April 27, 2017

5 Karen Wilson Individual Vallejo, CA Email May 5, 2017

6 Denise Boggs, Executive 

Director Conservation Congress (CC) Chico, CA Email May 1, 2017

7 Larry Glass,

Executive Director

Safe Alternatives for our Forest 

Environment (SAFE) Hayfork, CA Email May 5, 2017

8 

Gerard MJ van Hees, 

Northern California 

Representative

American Forest Resource Council 

(AFRC) Weed, CA Email May 4, 2017

Response to Scoping Comments

Introduction

The Council on Environmental Quality (CEQ) regulation 40 CFR 1503.4 states that an agency preparing an 

environmental assessment (EA) shall assess and consider comments both individually and collectively. The 
Appendix A. Response to Comments

174 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

following includes a narrative of public comment statements received, followed by the Forest Service 

responses, organized by resource topic in alphabetical order. The comment statement is taken from the 

written comments. Copies of the written comments received are available upon request, located in the project 

file at the SRNF’s Supervisor’s Office, 1330 Bayshore Way, Eureka, California 95501.

The discussion is organized by topic, presented in alphabetical order as follows:

o Aquatic Resources (AR)

o Botany Resources – Noxious Weeds (BRNW)

o Fire and Fuels (FF)

o General (G)

o Soil Resources (SR)

o Vegetative Resources (VR)

o Water Resources (WR)

o Wildlife Resources (WLH)

Aquatic Resources (AR)

1. Spring Chinook Salmon and Wild-Mad Rd—a dirt road that last year was used for extreme heavy loghauling in rain. Please inform me of road conditions on this road, as I expect the USFS to provide me 

with access when weather permits, and to not allow degradation of a refugia key 1 watershed. Just 

because it is far from Supervisors’ Offices and Ranger Stations, and falls within 2 different National 

Forests, it is a major responsibility to maintain the portion of this road that drains into the only cold 

waters on the South Fork Trinity River that can still support summering-over of Spring Chinook 

Salmon (Karen Wilson, Individual, p. 1).

Response: Given the location of the project, it is anticipated that hauling would occur on the ridgetop 

South Fork Mountain road (Route 23) or County Road 501, both of which connect to State Highway 36. 

Nonetheless, if circumstances arise where hauling does occur east over Route 30, wet weather standards 

on either the Six Rivers or the Shasta Trinity national forests would be followed. The Six Rivers National 

Forest (SRNF) wet weather operating standards (WWOS) guidance defines the wet weather operating 

season as typically ranging from October 16 and to around May 14, but wet weather conditions can 

happen anytime of the year (e.g., during summer thunderstorms). These WWOS meets national best 

management practices (BMPs) to reduce impacts to water quality in order to be in compliance with the 

Clean Water Act, therefore it is unlikely that spring Chinook in the South Fork Trinity would be affected.

2. Please provide more information on repairing roads 2S51 and 2S52. If they are causing sediment 

problems, which water bodies and/or fish species are being impacted? And to what degree? (Denise 

Boggs, Conservation Congress (CC), p. 3).

Response: Roads in the project area would be maintained and in some cases repaired prior to operations. 

This would cause a slight reduction in sediment production from these roads. When the project no longer 

needs these roads, they would be maintained again (bladed, culverts cleaned, waterbars constructed) and 

left in a better condition than before the project. The Proposed Action would implement road maintenance 

including grading and placement of waterbars, including Forest Service Road (FSR) 2S51, as a risk 

reduction to minimize future sedimentation, along with rectifying legacy sediment sources on FSRs 2S52 

and 2S53.
Appendix A. Response to Comments

Final Environmental Assessment – 175

Forest Service Road 2S54 would be decommissioned and removed from the transportation system. This 

involves removal of all culverts and associated fill, constructing permanent dips or waterbars to control 

drainage, and blocking the road with a barrier. Decommissioning may introduce a small amount of sediment 

during earthmoving and possibly the first winter following, but would be diminimus and short-lived.

Resident rainbow trout are found within the upper Mad River mainstem. Historic surveys of Littlefield 

Creek found no fish during the summer. In 2016, juvenile rainbow trout were spotted in the intermittent 

pools. It is unknown as to whether or not spawning occurs within Littlefield Creek or if the juvenile fish 

hatched in the mainstem Mad River and moved into the tributary only to be trapped when the flows went 

subsurface. It is unlikely that the amount of sediment entering the channel during the first winters flow 

would have an effect on the rainbow trout.

3. We are extremely concerned about logging and/or treatment activities within Riparian Reserves. This 

is a 303(d) listed watershed listed for sediment. The upcoming NEPA document should provide 

information on how many acres of treatment is proposed, where the RR’s are, what types of RR’s are 

proposed for treatment and the current condition of each RR to be treated. Please follow the 

recommended buffers within the Aquatic Conservation Strategy (ACS).

Management direction for wetlands and riparian areas is to insure high quality aquatic habitat and 

functioning riparian ecosystems now and in the future (LRMP III-4). Riparian areas create cooler 

microclimates. As acknowledged in the statements from the Upper Mad River Watershed Analysis (WA) 

logging, road construction, road density and a lack of road maintenance are severely impacting the 

aquatic health of watersheds in the planning area. The project could worsen the watershed condition 

requiring he need to follow the Clean Water Act, TMDL Plans and ACS. Riparian ecosystems are the 

interface between the aquatic and terrestrial ecosystems. Riparian areas provide habitat for a greater 

number of wildlife species than do any other habitat types. At least 250 wildlife species use riparian 

areas for breeding, feeding and resting and as travel lanes and connectors between habitat types. 

Riparian vegetation is important to fish habitat (LRMP III-4)(Kimberly Baker, EPIC, pp. 2 and 3).

Response: Between 80 and 160 feet of watercourses, equipment would be excluded, although fuels 

treatments would be permitted retaining canopy cover at or above 60 percent. These buffer widths are 

slightly greater than those called for in the Northwest Forest Plan (NWFP).

4. Riparian ecosystems are the interface between the aquatic and terrestrial ecosystems. Riparian areas 

provide habitat for a greater number of wildlife species than do any other habitat types. At least 250 

wildlife species use riparian areas for breeding, feeding and resting and as travel lanes and connectors 

between habitat types. Riparian vegetation is important to fish habitat (LRMP III-4). The forthcoming 

NEPA document should disclose impacts of RR treatments on wildlife (Kimberly Baker, EPIC, p. 3).

Response: The Proposed Action would treat limited acres within riparian reserves. For the project as a 

whole, there are 141 acres of riparian reserves spread out across multiple small tributaries. There are 3.7 

miles of intermittent streams and one mile of perennial streams within the project units. The streams 

coming off South Fork Mountain are high gradient, steeply incised, with mostly stable banks. The project 

also includes areas near Littlefield and Jonathan creeks. These streams are low gradient, with substantial 

floodplains or terraces, have less stable banks and more true riparian vegetation (primarily willow). The 

project would not reduce the forest canopy below 60 percent, and even this would be temporary as the 

trees that are left behind are expected to grow faster and close gaps in the canopy. There would be no 

logging and associated ground disturbing activities within 80 to 160 feet of any watercourse although 

there will be fuels treatment by hand. Within 80 to 160 feet of streams, canopy reduction would be even 
Appendix A. Response to Comments

176 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

less because only fuel treatment by hand would be allowed. There would be no effect on stream shading 

and stream temperatures would not be elevated due to project activities.

The project primarily follows existing roads within the project area. Little true riparian habitat exists within 

the units along both Littlefield and Jonathan creeks. However, in the long-term project implementation has 

the potential to slightly improve riparian habitat conditions through the release of conifer and 

hardwoods/shrubs from thinning, generating a secondary canopy. The project would maintain high levels 

of coniferous canopy closure within the project area adjacent to riparian reserves. Implementation of the 

project would maintain and improve riparian habitat conditions.

Resident rainbow trout are found within the upper Mad River main-stem. Previous surveys of Littlefield 

Creek found no fish during the summer. In 2016, juvenile rainbow trout were spotted in the intermittent 

pools in the Ruth fire burned area. The proposed fuel reduction action would reduce the likelihood of an 

additional fire burning on new streamside vegetation coming in after the fire.

Botany Resources – Noxious Weeds (BRNW)

5. Please disclose how proposed project activities will avoid the spread of invasive non-native species 

(Kimberly Baker, EPIC, p. 3).

Response: Risk of introduction and spread of invasive non-native plants is evaluated in an assessment 

for the 1st 48 Project based on five indicators: 1) presence of known invasive plant species in the project 

area, 2) habitat vulnerability, 3) non-project-dependent vectors such as existing roads or trails, adjacent 

private property, 4) habitat alteration expected as a result of project implementation, and 5) increased 

vectors as a result of project implementation. The risk evaluation leads to project design features that are 

designed to mitigated effects noted above by reducing the risk of introduction and spread from the 

existing condition of high due to proposed actions, to the desired condition of low risk. In keeping with 

Forest Service policy on Invasive Species Management (FSM 2900); the following project design features 

are identified to reduce the risk of introduction and spread from its current risk rating of high to a low 

risk. Priority areas for treatment along 2S50 and 2S48 would be flagged in the field prior to treatment.

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

shall be pressured washed prior to operating on the Forest.

o All mechanical equipment used in the project shall be washed after operating if moving from an 

infested to an un-infested area.

o Treatment of mechanical units shall follow a progression of work schedule, whereby treatment 

occurs first where invasive plants are limited to non-existent before moving to heavily infested 

areas (e.g. the lower infested stretch of 2S48). If progression of work is not feasible, equipment 

operating in infested road segments shall be cleaned before relocating. Progression of work 

applies to road maintenance associated with this project as well.

o Avoid yarding/skidding through yellow star thistle infestations.

o Immediately before using existing landings occupied by yellow star thistle, mechanically remove 

the plants to the edge of the landing, away from where equipment would be operating, pile and 

subsequently burn. Use native material to mulch landings following their use.

o Avoid masticating sections of 2S50 and 2S48 occupied yellow star thistle.
Appendix A. Response to Comments

Final Environmental Assessment – 177

o Where yellow star thistle infestations are present, surface blade 2S48 in such a way that bladed 

material in not reincorporated into the road travel way, but rather is push completely off the travel 

way to prevent it from re-establishment.

o In the Fall, following surface blading, manually pull or use tools to remove individual plants, 

removing as much of the roots as possible.

o Pile treated plants and burn where treated, or if plant numbers are few, incorporate plant material 

into a nearby burn pile.

o Include treated areas in the prescribed burn footprint.

o If practicable, stockpile wood chips generated on site to treat yellow star thistle sites.

Successful control of yellow star thistle would necessitate periodic monitoring and evaluation of 

treatment efficacy. If present after initial treatment, manually pull or use tools to remove individual plants 

in the late spring of the year (before fruiting/seeding) ensuring removal of the roots as much as possible. 

Pile treated plants and burn where treated, or if plant numbers are few, incorporate plant material into a 

nearby burn pile. Monitor annually and retreat as necessary and until no plants persist.

The following units occur in the vicinity of yellow star thistle infestations and as such should be treated last 

in order to reduce the risk of introduction and spread: 308, 401, 402, 403, 404, 405, 406, 407, 408, 409, 410, 

411, 418 and 421. If this progression of work cannot be implemented equipment shall be cleaned prior to 

operating in any of the units associated with the section of these road segments.

Fire and Fuels (FF)

6. Hoping you have a copy of a well-researched, comprehensive, and still up-to-date Report on a 

Literature Search Pertaining to Fuelbreaks and Fire Behavior, By Kenneth C. Baldwin for Trinity RCD 

Council. I suggest that an evaluation of fire behavior during the 2015 Trinity Fires, especially as it 

relates to existing fuelbreaks, be added to the literature on the subject. Since fire resilience is desired, 

please be aware of the recommendations made by Prof. James K. Agee, April 25, 2008 Klamath Fire 

Ecology Conference in Orleans, CA, that fuels treatments most likely to create fire resilience in the 

mixed-fire regime forests of the Klamath Mountains are in order (Karen Wilson, Individual, p. 2):

 Reduce surface fuels

 Increase canopy base height

 Keep the big trees

 Reduce canopy density

Response: Although the SRNF has yet not analyzed fire behavior of the 2015 Trinity Fires, 

representatives from the USFS, Northern Province Ecology program have been coordinating a rapid 

assessment team to assess fuel treatment effectiveness over the past 5 years across the northern region. 

Although the following study is not specific to the project area, the study methodology is robust and 

findings indicating general efficacy of fuel treatments in reducing fire severity and tree mortality is valid 

to this project area, according to the fuels forester at the Mad River Ranger District (RD).

“After the institution of fire suppression in the early 20th century (and the later 

development of Smokey-the-Bear educational efforts), fire became a comparatively rare 

phenomenon in California forests, reaching its nadir in the 1960s to early 1980s, when 

fire rotations in the Sierra Nevada and NW California ranged from 600–900+ years 
Appendix A. Response to Comments

178 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

(Miller et al., 2009, 2011). Since the mid-1980s however, drier mixed conifer and yellow 

pine forests across the western United States have experienced a notable increase in fire 

frequency, mean and maximum size, and annual burned area. Some regions have 

experienced proportional increases in fire severity and some have not, but the overall

area of high severity (stand-replacing) fire in these forest types is also rising (Miller et 

al., 2009, 2011; Dillon et al., 2011). In concert with these fire trends, numbers of firecaused human fatalities and destroyed and damaged homes are also mounting. This 

reversal in fire trends comes even as federal and state governments deploy tens-ofthousands of fire fighters and spend billions of dollars annually on fire management 

(Stephens and Ruth, 2005). Overall, our results support the central conclusions we made 

in an earlier paper that treated the Angora Fire on its own (Safford et al., 2009). These 

include the general efficacy of completed fuel treatments in reducing fire severity and tree 

mortality and the reduced loss of biomass/carbon from fire in treated areas” (H.D. 

Safford, J.T. Stevens, K. Merriam, M.D. Meyer, A.M. Latimer. 2012).

The attachment provided addressing research from 2005, predominantly addresses ponderosa pine forest 

types, not present in the 1st 48 Project area.

The Forest Service does not have a copy of recommendations stated by Prof. James K. Agee, at the April 

25, 2008 Klamath Fire Ecology Conference in Orleans, or his comments at the conference talk. If these 

notes are available, or copies are available and provided to the Forest Service during the 30-day comment 

period on this draft EA, the Forest Service will consider his recommendations.

7. We acknowledge the hysteria surrounding wildfire in the WUI but people who choose to live in these 

areas need to understand their responsibility in protecting their property. There are many papers out 

now speaking to the efficacy of fuel breaks and how they don’t work in general.

Attached is a recent study of fuel effectiveness. Beyond Fuel Treatment Effectiveness: Characterizing 

Interactions between Fire and Treatments in the USA. Fire scientists have been saying for a long 

time, one of the common assumptions of on-going fuel reduction projects like thinning and even 

prescribed burning is that it will reduce the spread of wildfires and make communities safe. However, 

there are many problems with fuel reductions. Thinning is not as effective as prescribed burning, but 

it is the most widely used method in the West (there is a lot of prescribed burning in the Southeast). 

Plus, thinning and/or prescribed burning effectiveness is relatively short lived—because shrubs, 

grasses, and small trees—the fine fuels that carry a fire—tend to regrow relatively quickly negating 

fuel reductions. Assuming the fuel reduction is even effective, especially as the time since treatment 

lengthens (an assumption that is questionable in many instances) the probability that a fire will 

actually encounter a fuel reduction is relatively low.

What they found is that only 6.8% of fuel reductions were ever encountered by a fire during the study 

period. And that of course does not mean that the fuel reduction had any influence on the fire for a 

host of reasons, including the largest blazes are driven by climate/weather conditions that overwhelm 

any fuel reduction effectiveness. So some subset of 6.8% can even be considered effective at all, and 

only under more moderate fire weather conditions. What this implies is that the vast majority of all 

fuel reductions are a waste of time and effort because most will never encounter a fire during their 

effective period—if they work at all. Again this paper makes the point that strategic reductions of 

fuels around homes and the edge of communities is the only strategy that makes any sense.
Appendix A. Response to Comments

Final Environmental Assessment – 179

We cannot predict where and when a fire will occur, but we can agree that we don’t want homes to 

burn down. So a focus on reducing fuels immediately adjacent to homes makes both economic and 

ecological sense. If we reduce the flammability of homes, we can allow fires to burn in much of the 

rest of the forest without having to suppress them. It would be encouraging if the Forest Service would 

hold fieldtrips and workshops to help people understand how to fire proof their homes using fire-wise 

principles developed by the Forest Service. The bottom line is wildfire is here to stay especially in a 

changing climate. People need to learn to live with fire instead of fearing it and fighting it. Fire 

proofing homes works as has been shown again and again. Fuel breaks don’t work in general as has 

been shown again and again. So what makes more sense to do? Protect your home or build more 

fuelbreaks? (Denise Boggs, CC, pp. 1 and 2).

Response: The Mad River RD has numerous recent examples of fuel reduction effectiveness; Mad Ridge 

Fuelbreak, which bisects a large portion of the district, and spans from the Dinsmore area to south of 

Ruth, has served local communities for over a decade since initial treatments were completed about 2006. 

During the lightning siege of 2008, two fires were started within or near the fuelbreak; one fire was less 

than 0.1 acre and the other less than 5 acres. In both cases, the fuelbreak slowed the fire progress, 

allowing for safe and effective suppression with minimum resources. In 2009, a lightning fire on Mad 

Ridge was held to 0.7 acres.

In the 2015 Mad River Complex and the 2017 Ruth Complex, Mad Ridge Fuelbreak served as an anchor 

point from which firefighting resources were able to construct fireline to stop the lateral spread of fire. A 

small-scale administrative fuel reduction project around the Ruth Guard Station and adjacent to the Ruth 

Community Church contributed to stopping the progress of the 2011 Ruth Fire from progressing north 

along County Road 501 toward the Ruth Store. Strategic fuelbreak placement in conjunction with home 

ownership fuel reduction best serves both communities and firefighters. The 1st 48 Project addresses 

concerns of many local homeowners in the Ruth community by creating primary lateral fuelbreaks from 

the top of South Fork Mountain down toward the valley floor.

8. When considering prescriptions for manual treatments please include limbing and pruning of brush 

species rather than complete removal, this includes Manzanita. Please consider species preference of 

more desirable fire resistant plants and trees so as to culture fire resilience into the future (Kimberly 

Baker, EPIC, pp. 3 and 4).

Response: Starting with the construction of the Mad Ridge Fuelbreak in 2003, and subsequent fuel 

reduction projects since then, older shrubs and/or shrub islands have been retained with brush treatment 

specifications incorporated into standard fuelbreak construction guidelines. Old growth manzanita is 

routinely targeted for retention, with lower limbs being pruned during lop and scatter operations.

9. Shaded Fuelbreaks need less maintenance, and are most effective. In severely burned areas, shade is 

not possible, so provide documentation for more frequent maintenance if not shaded. Unless 

maintained approximately every 5 years, any fuelbreaks have no effect. Please provide records for 

previous fuelbreak maintenance along ridgetop (Karen Wilson, Individual, p. 2).

Response: In severely burned areas, initial treatments would involve cutting, piling and burning slash 

and brush. First entry treatments would include retaining dominant sprouting hardwoods and conifers for 

future culturing. Mad Ridge Fuelbreak continues to be maintained either by mastication or lop and scatter 

operations since completion of initial treatments of thinning, piling and burning around 2006. There are 

areas within the Mad Ridge Fuelbreak that have been converted from an oak and manzanita brush field to 

an oak woodland with native grass understory. Forest Service appropriated funds, force-account personnel 
Appendix A. Response to Comments

180 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

and equipment, or external funding from various organizations and partners, such as the Trinity County 

Resource Advisory Committee (RAC), California Deer Association, and Joint Chiefs’ Landscape 

Restoration Project have all contributed to fuelbreak maintenance.

General (G)

10. I think it’s great that you’re including the community (Patsy Lewis, Individual, p. 2).

Response: The Forest Service’s mission is to care for the land and serve our communities. Thank you for 

your support.

11. The Forest Service roads listed in the scoping letter need to include their road classification. Are they 

Class 2 roads or Class 3 roads? How far away are they from the nearest communities and/or homes 

in the area? What types of vehicles traverse jeep trail 8E01 and how close is it to a community or 

home? (Denise Boggs, CC, p. 2).

Response: With exception of the units located along Route 23, the roads selected to establish a fuelbreak 

network defining the project area abut private lands and Ruth Lake.

The following roads are to be used at their existing maintenance levels:

o Maintenance Level (ML) 2

 2S02 MP 0.0-2.0

 2S02C MP 0.0-0.4

 2S47 MP 0.0-2.55

 2S48 MP 0.0-4.79

 2S48C MP 0.0-0.44

 2S49 MP 0.0-0.63

 2S50 MP 0.0-1.07

 2S51 MP 0.0-1.44

 2S52 MP 0.0-1.31

 2S53 MP 0.0-2.0

o Maintenance Level 1

 2S02B MP 0.0-0.2 would be maintained to ML 2 standards for access during operations, 

then returned to ML 1 status and closed when the project is completed.

12. We request additional information on the 147 acres of hazardous fuels reduction ... (Denise Boggs, 

CC, p. 3).

Response: The Forest Service hosted a field trip and public meetings during the development of the 

Proposed Action and during the Scoping period to help people understand fire-wise principles developed 

by the Forest Service and to encourage participation in project planning and monitoring. The observations 

associated with the effectiveness of fuelbreaks by those involved in fire suppression locally, indicate from 

first-hand experience, a change in fire behavior when forests are “pre-treated” allowing for more rapid 

containment.
Appendix A. Response to Comments

Final Environmental Assessment – 181

The Forest Service agrees a comprehensive “all-lands” approach is warranted, including strategic 

reductions of fuels around homes on private property and around the edge of communities. However, the 

1st 48 Project represents a “proof of concept” proposed by the TCC, whereby zones of agreement are to 

limit treatments alongside existing, open FSRs. Although the Forest Service recognizes and appreciates 

predicting where and when a wildfire will ignite is uncertain, the outcome to lives and our environment 

warrant a conservative approach, assuming probable ignition.

13. Safe Alternatives for our Forest Environment (SAFE) supports the 1st 48 Collaborative Shaded 

Roadside and Plantation Fuelbreak Project (1st 48). Through the Trinity Collaborative, SAFE has had 

extensive input into this project and we believe it is well-designed to achieve the outcome of reducing 

the risk of “high severity burns in forests where past management practices have increased risks related 

to wildfire.” It also supports “the economic vitality and safety of rural communities and ecological 

resilience of forest resources, ”SAFE believes this project will “provide residents and visitors travel 

zones that allow for safer evacuations during wildfires, allow for faster wild land firefighter response, 

and reduce the threat of roadside fire-starts resulting in the loss of high value forest resources.” SAFE 

also believes the project will create valuable control lines for wildfires and reintroduction of intentional 

fire to the forest. It has been a unique opportunity and pleasure to work so closely with Ranger Dill and 

his staff on this precedent-setting project. SAFE believes that the successful implementation of this 

project will, over the long run, benefit and protect the environment and ecosystems that we care so much 

about. Thank you for this great opportunity (Larry Glass, SAFE, p. 1).

Response: The Forest Service’s mission is to care for the land and serve our communities. Thank you for 

your support.

14. EPIC appreciates the collaborative nature of the project and the focus on roadside and plantations. 

We ask you to consider leaving all predominant and dominant trees on the landscape and to follow 

the ACS recommended buffer widths. Please limit landing construction and machine piling. Thank 

you for the consideration (Kimberly Baker, EPIC, p.4).

Response: The Proposed Action is designed to retain all pre-dominant trees and dominant trees, as their 

characteristics best respond to the purpose and need for maintaining adequate shade to deter brush 

response. The project is also designed to not retard or prevent attainment of ACS objectives, by protecting 

forest elements and avoiding equipment entry into riparian reserves. New landing construction is limited 

to existing forest openings on flat terrain, most exist but require expansion (up to 1⁄2-acre total across the 

project area).

15. Thank you for retaining all predominant trees. The scoping notice states, “Healthy vigorous trees 

with greatest crown potential will be retained”. However, large trees with defects are valuable 

habitat. Please consider retaining dominant trees, which are providing habitat elements that take a 

long time to develop. “The watershed is currently at or below the minimum. Recommended 

Management Range RMR) for the late mature seral stage, and below the minimum RMR for oldgrowth in the Douglas-fir series. Therefore, management actions in these seral stages will be limited 

in order to maintain the current acreage and increase acreage over time.” Upper Mad River 

Watershed Analysis (WA) pg. 35 (Kimberly Baker, EPIC, pp. 1 and 2).

Response: The majority of stands proposed for treatment are classified as early to mid-mature seral stages. 

The Proposed Action would retain all dominant trees and pre-dominant trees, which includes those with 

defects. Most co-dominant trees would also be retained. The thinning from below prescription would not 

alter existing seral stage condition, and it would in fact, increase growth on the remaining trees to accelerate 
Appendix A. Response to Comments

182 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

development of trees into late seral size classes. This would promote an increase in the amount (acres) of 

late seral stands as an incremental step toward achieving the minimum Douglas-fir RMR threshold.

16. Other projects within the area and coordination with Shasta-Trinity National Forest – I again ask to be 

kept informed of projects and activities affecting the Up-River portion of the South Fork Trinity River. 

This includes projects such as Kelsey and Cedar Gap because they are adjacent and affect roads. Who 

can I contact during any approved Winter Operating Periods? (Karen Wilson, Individual, p. 1).

Response: The Forest Service will contact you as a follow up so we can better understand your interests 

for notifications.

17. My concerns are all along the South Fork Mountain Ridge, generally south of Pickett Peak. Roadless 

Areas and RNA – recognize there is a significant Chinquapin Roadless Area just over the ridge-top. 

The disruption should be minimized (Karen Wilson, Individual, p. 1).

Response: The project area does not enter any research natural areas (RNAs) or roadless area 

management area allocations per the SRNF LRMP. Therefore, there would be no disruption to these 

important natural environments.

18. 8E20 – Does this project proposed to make this a “highway” and encourage travel on a trail that 

does not show up on Six River’s Visitor Map (Karen Wilson, Individual, p. 1).

Response: Jeep Trail 8E20 (aka Wiregrass) special vehicle designation trail (four-wheel-drive nonhighway legal vehicle wider than 50 inches/all-wheeled vehicles 50 inches wide or less) that is 1.29 miles 

long, located in T2S R8E.

The USFS national resource management (NRM) database indicates the trail was added to the NFST 

(National Forest System trails) under the Lower Trinity and Mad River Motorized Travel Management

Record of Decision (April 2010). As the forest visitor map predates the travel management decision, it has 

not been updated to reflect this change. This trail is displayed on the revised motor vehicle use map 

(MVUM) for that area, which does reflect the 2010 decision.

The trail would be graded within its existing footprint and temporarily closed to public use during logging 

operations to ensure public safety. Other than the short-term disruption in public use, grading and 

constructing waterbars would be visually evident in the short-term; likely one season. The Forest Service 

has no plans to improve the trail physically or to promote increased use.

19. There are many ways to design a timber sale that allows a purchaser the ability to deliver logs to 

their mill in an efficient manner, while also adhering to the necessary practices that are designed to 

protect the environmental resources present on Forest Service forestland. AFRC wants to go on 

record in support of the 1st 48 Project if it is economically feasible to remove commercial volume. 

Thank you for the opportunity to comment on the proposed project and please keep us informed on 

the progress of NEPA. We are also interested in any field trips that may be set up for this project 

(Gerard MJ van Hees, AFRC, p. 3).

Response: The Proposed Action is designed to be a break-even, economically feasible operation for 

units deemed commercially viable due to thin from below forest byproducts (sawlog volume equivalent to 

5 mbf/acre stand average). There is no requirement for costly road reconstruction or new construction. 

The units planned for hazardous fuels reduction (HFR) are a mix of break-even and below cost 
Appendix A. Response to Comments

Final Environmental Assessment – 183

treatments, depending on whether or not sufficient size/amount of pole material and firewood is present to 

carry a viable commercial forest products sale.

Soil Resources (SR)

20. Planning should consider the current problems with the road system. Please consider not using 

machine piling within the project area or analyze and disclose the amount and location where it 

would be considered. Limit or do not construct new landings. Landing construction has deleterious 

impacts and will degrade the hydrological, soil, terrestrial habitat and connectivity values of these 

lands. Overall, please provide details concerning how the proposed project activities will mitigate 

damage to the soils (Kimberly Baker, EPIC, p. 3).

Response: Proposed activities would necessarily create soil disturbance. Soil disturbance is not 

inherently good or bad. The types of soil disturbance that are of potential concern include compaction, 

displacement, and severe burning, which vary by type of activity and intensity of treatments. Each of 

these have severity and extent components that are evaluated in combination, to assess potential adverse 

impacts to soils of the activity area. The LRMP defines “detrimental” soil disturbance and extent 

thresholds of concern. When soil impacts are severe enough to constitute “detrimental” disturbance, they 

then should not occupy greater than 15 percent area, which is assumed to be a large enough area to 

potentially affect soil productivity. The LRMP has standards and guidelines pertaining to soils, as well as 

Soil Quality Standards to be implemented. Project specific design features (PDFs) were also developed to 

help ensure compliance with LRMP provisions.

Some detrimental soil disturbance is allowable per the LRMP. Detrimental compaction is expected in 

landings and some of the more highly trafficked skid trails near landings; decompaction treatments are 

recommended for rehabilitation to improve soil hydrologic function, but these specific areas left in 

detrimental condition would still satisfy LRMP soil requirements in terms of percent area. Machine piling 

methods proposed are not expected to create significant soil displacement or severe compaction effects, 

unlike historic practices.

Vegetation Resources (VR)

21. How old are the plantations proposed for thinning? How old are the natural stands proposed for 

thinning? Will a diameter limit be placed on the trees marked for removal (we encourage this and 

recommend 15′′ DBH)? What percentage of canopy cover will be left? (Denise Boggs, CC, p. 2).

Response: Plantations range from 30 to 45 years old. Natural stands range from 100 to 250 years old, 

with the older stands having dominant or pre-dominant trees that would be retained. There is no diameter 

limit proposed for the project, as the thin from below prescription already targets smaller tree diameters in 

order to meet the desired condition. In addition, a 15-inch dbh limit would fail to consider treating those 

trees that contribute to stand structural conditions that need to be treated, such as large height-to-crown 

ratios or overlapping crowns, in order to meet components of the Proposed Action that contribute to the 

“underlying need for increasing canopy base height of live crowns...and... separating intertwined tree 

crowns”. Residual canopy cover is an average of 60 percent across all treatment types.

22. Blown-down ridgetop and edges—important to recognize and evaluate the potential for the strong 

winds in storms to make edges and ridgetops more vulnerable. Southern exposure vs Northerngenerally the area under consideration has southern exposure and my perspective is from the side of 
Appendix A. Response to Comments

184 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

the ridge with northeastern exposure. At this elevation, there is quite a difference in snow retention 

and moisture, besides the fact that it is roadless (Karen Wilson, Individual, p. 1).

Response: The thinning intensity design of the thin from below prescription maintains an average of 60 

percent or greater canopy cover with a relatively uniform crown spacing, as these forest stands are 

exposed to prevailing winds. The proposed treatment would maintain the largest trees with best crowns, 

which are the most resilient to winds, snow and ice. Thinning would improve the ability of these stands to 

withstand the typical winter wind, ice, and heavy snow storms in the Coast Ranges and Klamath 

Mountains, although there may be a short-term increase in susceptibility to wind storms in the denser 

stands on exposed sites.

Over time, thinning promotes a lower height-to-diameter ratio, which improves the ability of a tree to 

withstand heavy snow and ice loads, especially if they are associated with dynamic loadings associated 

with high winds (Oliver and Larson 1996). However, some blow-down is still to be expected, and these 

events are expected to provide additional coarse woody debris and diversity to stands, while still 

maintaining an adequate growing stock for future management objectives, including wildlife habitat.

23. AFRC would like to see forest health thinning increased wherever possible. Please provide a table 

that includes all stands in the project area. For each stand, please provide the current and projected 

conditions including percent of maximum stand density index (see below). Also, please include the 

reason why stands are/are not proposed for treatment. When considering areas with restrictions on 

canopy reduction, long-term benefits to forest health should be weighed against any short-term 

reductions in canopy closure (Gerard MJ van Hees, AFRC, p. 2).

Response: Stands included for proposed treatment constitute a continuous linear feature along identified 

strategic roads and ridgetops. No stands in the continuous linear feature were dropped from treatment 

during the analysis, although the treatment prescription may have changed. During the planning process, 

consideration to forest health was weighed against the purpose and need to establish roadside shaded 

fuelbreaks for the long term, whereby reductions in canopy is sufficient to maintain healthy, live trees, but 

not lowered to the extent to cause a heavy brush response or trigger blowdown.

24. An important Regional objective is to reduce the probability of large-scale tree mortality by reducing 

high-stand densities. The forested area within the 2017 Waterman Project planning area have stand 

densities that exceed biological potential and are especially susceptible to tree mortality during 

drought conditions. Stand Density Index (SDI) is an excellent measure of stand stocking density and 

vigor and can be used to determine effective tree stocking densities over time to meet forest health 

objectives. To accomplish this, the project’s thinning should be designed to ensure that stocking 

density does not exceed an upper limit of 60% of maximum SDI for at least the next 20 years.

Example: Maximum SDI is 550. Current average SDI is 548. An SDI of 330 is 60 percent of maximum 

(550). Thin to tree stocking levels below SDI 220 that will ensure density does not exceed SDI 330 

(60% of SDImax) after twenty years of growth.

AFRC recommends and supports this silvicultural prescription based on one thinning entry every 20 

years. This would reduce the number of entries over time and provide added assurance against future 

drought. Heavier thinning would meet forest health objectives for a longer timeframe, create 

conditions more conducive to the establishment and growth of shade intolerant species, and provide 

sufficient value (saw timber) for economically efficient projects that can pay their way out of the 

woods. This approach has been widely used and was endorsed by former Regional Forester Jack 
Appendix A. Response to Comments

Final Environmental Assessment – 185

Blackwell. See attached Regional Forester letter “Conifer Forest Density Management for Multiple 

Objectives, 7/14/2004.” When considering areas with restrictions on canopy reduction, long-term 

benefits to forest health should be weighed against any short-term reductions in canopy closure 

(Gerard MJ van Hees, AFRC, p. 2).

Response: Prescriptions were designed through a collaborative process to result in an effective shaded 

fuelbreak and to reduce fuel loading of hazardous fuels, while meeting the project design features of the 

other affected resources. With this in mind, thinning prescriptions took into account many factors beyond 

only the existing stand density, to meet the objective of an effective shaded fuelbreak.

The maximum stand density index (SDI) value used for Douglas-fir was 547. Stand density indexes 

ranged from 139 to 707, averaging 349. A 60 percent SDI value is 328. Approximately 70 percent of the 

stands had an SDI that was over 60 percent. The maximum SDI value used for white fir was 759. A 60 

percent value is 455. Over 65 percent of the white fir stands in the planning area had SDI values greater 

than 60 percent, and 14 percent were just slightly lower than 60 percent maximum SDI. Proposed 

thinning prescriptions have a residual canopy cover at an average of 60 percent across all treatment types 

in order to maintain current characteristics of nesting/roosting and foraging habitat for the northern spotted 

owl (NSO) immediately post-project, and also to retard brush response and establishment and growth of 

shade intolerant species in the shaded fuelbreak.

25. Currently there are planned 107 acres of harvest of forest products in plantations. Economics need to 

be considered due to the small average diameter of these stands (Gerard MJ van Hees, AFRC, p. 2).

Response: Plantations proposed for treatment contribute to the development of the shaded fuelbreak. 

While some merchantable material, such as firewood and pole, would be generated from the plantations, 

economics was not a main factor in determining the need for treatment. Additionally, a variety of methods 

would be used to treat the proposed units other than the traditional timber sale, such as existing cooperator 

agreements that have an economic correlation to values other than directly to sawlog prices.

26. The analysis in the EA needs to display how long the treatments will be effective in meeting the 

designed purpose and need. In order to meet the desired condition for ecological restoration and fuels 

management the treatments will need to be intensive enough to be effective for a considerable period 

of time. Forest health is a major concern on the Six Rivers National Forest and forests throughout the 

West. Regional Forester priorities were stated in the August 10, 2016 letter “FY17 Priorities, 

Program Direction, Operating Budget, and Performance Contributions.” Regional response to tree 

mortality from insect and disease is the first priority listed. AFRC supports thinning over stocked 

stands to improve forest health. It makes sense to treat as many acres as possible when planning 

projects in the area (Gerard MJ van Hees, AFRC, p. 2).

Response: The project area was determined and the treatment prescriptions were designed through a 

collaborative process to result in an effective shaded fuelbreak and to reduce fuel loading of hazardous 

fuels, while meeting the project design features of the other affected resources. With this in mind, 

thinning prescriptions took into account many factors beyond only the existing stand density, to meet the 

objective of an effective shaded fuelbreak. In order to treat as many acres as possible, no stands in the 

continuous linear feature were dropped from treatment during the analysis, although the treatment 

prescription may have changed. Intensity of treatments were in part affected by maintaining residual 

canopy cover at an average of 60 percent across all treatment types in order to maintain current 

characteristics of nesting/roosting and foraging habitat for the NSO immediately post-project, and also to 

retard brush response in the shaded fuelbreak.
Appendix A. Response to Comments

186 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Water Resources

27. The project proposes to reduce road related sediment sources by repairing roads 2S51 and 2S52, and 

decommission road 2S54 (Gerard MJ van Hees, AFRC, p. 2).

Response: The Proposed Action would implement road maintenance including grading and placement of 

waterbars, including FSR 2S51, as a risk reduction to minimize future sedimentation, along with 

rectifying legacy sediment sources on FSR 2S52 and 2S53. The Proposed Action would also 

decommission FSR 2S54. This ML 2 road is 1.95-miles long, and has four low-water crossings and three 

culverted stream crossings. Two of the culverted crossings have small fills (150 and 318 cubic yards). 

One crossing is larger (800 cubic yards).

28. We are extremely concerned about logging and/or treatment activities within Riparian Reserves. This 

is a 303(d) listed watershed listed for sediment. The upcoming NEPA document should provide 

information on how many acres of treatment is proposed, where the RR’s are, what types of RR’s are 

proposed for treatment and the current condition of each RR to be treated. Please follow the 

recommended buffers within the Aquatic Conservation Strategy (ACS).Management direction for 

wetlands and riparian areas is to insure high quality aquatic habitat and functioning riparian 

ecosystems now and in the future (LRMP III-4). Riparian areas create cooler microclimates. As 

acknowledged in the statements from the Upper Mad River Watershed Analysis (WA) logging, road 

construction, road density and a lack of road maintenance are severely impacting the aquatic health 

of watersheds in the planning area. The project could worsen the watershed condition requiring the 

need to follow the Clean Water Act, TMDL Plans and ACS (Kimberly Baker, EPIC, pp. 2 and 3).

Response: This project would not worsen the condition of the watershed. Only 821 acres or 1.7 percent 

would be treated within the 48, 127-acre 6th-field watershed scale, used to determine cumulative effects to 

water resources. The forest canopy cover would remain at or above 60 percent. In addition, this project 

would decommission FSR 2S54. This decommissioned FSR would be left in a maintenance-free 

condition (i.e., drainage structures are removed and natural drainage patterns restored), and would cause 

localized sediment production to go down.

29. As background, state law assigns responsibility for protection of water quality within north coast 

watersheds to the Regional Water Board. The Regional Water Board implements and enforces the 

Porter-Cologne Water Quality Control Act (“Porter-Cologne Act,” California Water Code §13000 et 

seq.) and the Water Quality Control Plan for the North Coast Region (Basin Plan). All forest projects 

must comply with all substantive and procedural requirements of the Porter-Cologne Act and the 

Basin Plan. The Waiver waives certain activities conducted on NFS Lands from the waste discharge 

requirements of Article 4 (commencing with Section 13260) of Chapter 4, Division 7 of the California 

Water Code, except as provided within the Waiver. In order to receive coverage under the Waiver, the 

Project must meet specific eligibility criteria and conditions. A guidance document and pertinent 

forms are available for review and can be downloaded at the following web address: 

www.waterboards.ca.gov/northcoast/water_issues/programs/timber_operations/timber_waiver/. The 

Basin Plan contains water quality objectives, implementation plans for meeting those objectives, and 

other policies, including State Water Resources Control Board and federal policies, which are 

applicable to operations on NFS lands within California. The Project must be designed and 

implemented to meet the water quality standards outlined in the Basin Plan. Additionally, the Project 

must be in compliance with any total maximum daily load (TMDL) that has been developed for the 

watersheds in which the Project will occur. Please accept the following comments based on the 

information provided in the Project scoping letter (Dean Prat, NCRWCB, pp. 2 and 3).
Appendix A. Response to Comments

Final Environmental Assessment – 187

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

objectives, and other policies, including State Water Resources Control Board and federal 

policies, which are applicable to operations on NFS lands within California. The Project must be 

designed and implemented to meet the water quality standards outlined in the Basin Plan. 

Additionally, the Project must be in compliance with any total maximum daily load (TMDL) that 

has been developed for the watersheds in which the Project will occur.

o For project enrollment, the Waiver states that after project approval by the USFS and at least 30 

days prior to commencement of on-the-ground activities, a Notice of Intent (NOI) and Waiver 

Application shall be filed with the Regional Water Board. The NOI certifies that the USFS 

understands and intends to comply with the Waiver. A letter granting coverage must be received 

by the USFS prior to initiating activities.

o This Waiver requires that all active and potential legacy sediment sites be identified, inventoried, 

prioritized, scheduled, and implemented for treatment for all Category B projects and/or through 

the Watershed Restoration Action Plan (WRAP). If the USFS does not have a WRAP for the sixth 

field subwatershed where a Category B activity is proposed for coverage under this Waiver, the 

USFS must propose treatments of all existing legacy sediment sites within the Project area as part 

of the proposed Project. Grazing allotments are exempt from the requirement to identify and treat 

legacy sediment sites.

o The USFS shall include specific on-the-ground prescriptions designed to meet the USFS Best 

Management Practices (BMP) within the environmental document prepared pursuant to the 

National Environmental Policy Act (NEPA). The specific prescriptions shall also be included in 

all contracts, grazing permits, agreements, and other instruments used to direct the activities of 

contractors, grazing permittees, USFS personnel, volunteers, or any other third parties specified 

in this Waiver. The intent is to provide clarity and transparency in how the BMPs will be 

implemented and to facilitate the monitoring of BMP implementation.

o In addition to providing specific on-the-ground prescriptions, the USFS shall provide copies of 

this Waiver to contractors and grazing permittees, and USFS volunteers and any other third 

parties specified in this Waiver, and notify them of their responsibilities to comply with the Waiver.

o USFS shall manage and maintain designated riparian zones to ensure retention of adequate 

vegetative cover that results in natural shade conditions, within 300 feet slope distance on each 

side of fish-bearing streams, 150 feet slope distance on each side of perennial streams, and 100 

feet slope distance on each side of intermittent streams, or the site potential tree height distance 

on each side of the stream, whichever is greatest (per North West Forest Plan (NWFP) Aquatic 

Conservation Strategy (ACS)). Reference to the NWFP ACS includes any modifications to those 

documents during the life of this Waiver, so long as the modifications are equally or more 

protective of water quality, as determined by the Executive Officer. Timely implementation is 

necessary for sediment and temperature TMDL compliance. Site-specific potential effective shade 

is defined as the shade on a watercourse equivalent to that provided by topography and potential 

vegetation conditions at a site. Exceptions to this condition will be considered. In order for 

Regional Water Board staff to determine the adequacy of the justification for an exception, the 

justification must identify the proposed canopy reduction and expected recovery time, provide an 

estimate of the pre-and post-project shade or solar impacts, and explain how such an exception 

will result in a net long-term benefit to water quality and stream temperatures.
Appendix A. Response to Comments

188 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

o Measures to mitigate water quality impacts should be included in the design of the Project. The 

2015 Category B Waiver Application Procedures (page 29, item “i”) state that an application 

must contain:

“Copies of relevant portions of all environmental documents that set out the details of a project, 

especially on-the-ground prescriptions, including supporting documents that describe in detail 

the activities and management practices that will be taken to reduce potential water quality 

impacts to less than significant levels (e.g., NEPA documents, wet weather operations standards, 

technical reports, design criteria, assessments, watershed restoration plans).”

Response: This project is designed to be in full compliance with the terms and conditions of The Waiver 

of Waste Discharge Requirements for Nonpoint Source Discharges Related to Certain Federal Land 

Management Activities on National Forest System (NFS) lands in the North Coast Region (Order No. R1-

2015-0021). Meeting the terms and conditions of The Waiver, along with implementation of BMPs, are 

how the Forest Service shows compliance with the TMDL developed for the Mad River Watershed. Once 

the planning document is signed, the Forest Service will request coverage for the project under Category 

B of The Waiver.

There is a Watershed Restoration Action Plan (WRAP) for Barry Creek-Mad River (180101020202). 

Nevertheless, all legacy sediment sites in the project area would be treated. These include active erosion 

sources originating from NFS roads (2S52 and 2S53) which would be treated. In addition, all roads in the 

project area would receive road maintenance. While not large enough or concentrated enough to be 

considered legacy sediment sources, it is anticipated that sediment production would be decreased 

following maintenance.

The BMPs for this project are disclosed in Appendix C of this EA. These BMPs would be implemented to 

ensure 100 percent implementation in each unit. Effectiveness monitoring would be done after at least one 

winter as part of the Best Management Practices Evaluation Program (BMPEP).

Copies of The Waiver shall be given to the contractor prior to implementation.

This project has designated riparian reserves of 160 feet on each side of streams (320 feet for fish-bearing 

streams). In all cases, the inner 80 feet (80 feet on each side) will have only fuels treatment by hand. The 

riparian reserve boundary (160 feet on each side, 320 feet for fish-bearing) will function as an equipment 

exclusion zone. No equipment would be allowed to enter riparian reserves except on existing roads. 

Because only fuels treatment by hand would occur within the inner riparian reserve, and the outer riparian 

reserve would not be reduced below 60 percent canopy cover, there would be no effect on stream shading 

or temperature.

Along the south side of Littlefield Creek (which is considered fish bearing) there is a large, flat terrace,

which road 2S02 travels on. In this area, fuels treatment by hand would occur on the stream side of the 

road, and thinning would occur on the other side. In some cases, the road is closer than 160 feet to the 

stream but no sediment is expected to reach the stream due to the flatness of the terrain. This area was 

heavily burned by the Ruth Fire, removing the forest canopy, so there would be no effect on shade from 

project activities.

When the time comes to apply for enrollment under Category B of the Waiver the North Coast Regional 

Water Quality Board will be sent a copy of this NEPA document, relevant specialist reports, an erosion 

control plan, the wet weather operations plan, and the watershed restoration action plan.
Appendix A. Response to Comments

Final Environmental Assessment – 189

Between 80 and 160 feet of watercourses, equipment would be excluded, although fuels treatments would 

be permitted so long as canopy cover remains at or above 60 percent. These buffer widths are slightly 

greater than those called for in the NWFP and would maintain water quality and current stream temperature.

30. We don’t support logging in riparian areas in general and especially the “test harvest” within the 

interior 80 feet of Riparian Reserves. Logging in riparian areas will not make them more resilient to 

fire. If the Forest Service pursues this a lot more information will be needed and likely a LRMP 

amendment (Denise Boggs, CC, P. 2).

Response: The “test harvest” has been dropped from the Proposed Action. Only manual fuels treatment 

would occur within 80 feet of watercourses; limited to less than 6-inch dbh within 25 feet where riparian 

reserves intersect roads.

Wildlife Resources (WLR)

31. Thank you for retaining all predominant trees. The scoping notice states, “Healthy vigorous trees 

with greatest crown potential will be retained”. However, large trees with defects are valuable 

habitat. Please consider retaining dominant trees, which are providing habitat elements that take a 

long time to develop. We ask you to consider leaving all predominant and dominant trees on the 

landscape. (Kimberly Baker, EPIC, pp. 3 and 4).

Response: The project would not remove potential threatened, endangered, and sensitive species nest 

trees (pre-dominant trees) or affect the canopy around potential nest trees in suitable habitat. Directional

falling would be used to protect all pre-dominant trees. All pre-dominant trees would be retained. 

Thinning from below, while maintaining a minimum of 60 percent or greater canopy cover, is the best 

management prescription to maintain and recruit the habitat variables critical to nesting/roosting habitat 

(e.g., large old trees and co-dominant and intermediate conifers with crown space in the canopy for crown 

development) while at the same time improving forest health and reducing risk to wildfire and insects and 

disease. Removal of the co-dominant trees would only occur when stem densities needs reduced for 

proper heath of another adjacent co-dominant tree or when culturing around resident black oak trees.

32. The Upper Mad River Watershed Analysis at page 16 indicates that Northern Spotted Owls (NSO), 

Northern Goshawks, Western Pond Turtles and Pacific Fishers are present in the watershed and that 

Martens, Willow Flycatchers and Del Norte Salamanders are suspected in the planning area for this 

project (Kimberly Baker, EPIC, p. 3).

Response: All riparian reserves would be buffered on both sides of stream channels (non-fish bearing 

buffers are 160 feet, fish-bearing buffers are 320 feet or two site potential tree heights), unless intersecting 

with road networks. In the case of Littlefield Creek, the no-cut buffer (“inner riparian reserves”) south of 

the stream would extend to the edge of the road, which is less than 160 feet in many areas, but this buffer 

is still considered adequate to prevent impacts to the stream because the area is so flat. Canopy closure in 

the outer riparian reserve buffers would be maintained at 60 percent or greater. No tree removal is 

permitted within the inner riparian reserve buffers. Exceptions include hand-cut trees less than 6-inch dbh

within 25 feet where riparian reserves intersect roads.

Little to no true riparian habitat exists within the units within the project area. However, in the long term,

project implementation has the potential to improve riparian habitat conditions through the release of 

conifer and hardwoods/shrubs from thinning, generating a secondary canopy. The project would maintain 

high levels of coniferous canopy closure within the project area adjacent to riparian reserves. Project 
Appendix A. Response to Comments

190 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

activities would not occur within riparian habitat. Implementation of the project would maintain and 

improve riparian habitat conditions.

All Forest Service Sensitive wildlife species known or thought to occur in the project area (based on 

habitat and range), were evaluated for this project. It was determined that the project would have no 

impact on certain Forest Service Sensitive species, based on either the lack of habitat, lack of detections 

during surveys, or the fact that habitat would not be impacted. Surveys have been conducted for NSO, 

northern goshawks, and forest carnivores. Northern spotted owl and fisher have been detected and 

mitigation protection measures would be implemented.

Direct, indirect and cumulative effects to Management Indicator Species (MIS) and Migratory Bird 

Species (MBS) are disclosed in the MIS and MBS reports (Smith 2017; located in the project file). MIS 

and MBS were addressed based on their potential to occur within the project area based on habitat 

suitability, survey results, or incidental sighting records.

No wildlife Survey and Manage (S&M) species occur within the 1st 48 Project area; therefore no preproject surveys are required. This project is in compliance with the 2001 Record of Decision and 

Standards and Guidelines for Amendments to Survey and Manage, Protection Buffer, and other Mitigation 

Measure Standards and Guidelines (USDA and USDI 2001), the April 25, 2013 9th Circuit Court Order 

in Conservation Northwest (and others) v. Sherman (No. 11-35729), and the February 18, 2014 District 

Court Order in Conservation Northwest (and others) v. Robert Bonnie (and others) (W. WA No. C08-

1067-JCC).

Project design standards would minimize potential impacts to TES, MIS and MBS. The project is 

designed to improve habitat conditions through the acceleration of late-successional habitat 

characteristics, while still maintaining current functional habitat. Although there would be minor habitat 

degradation for understory species through the removal of brush and understory trees, in the long term the 

reduction of fuel ladders in these areas would improve adjacent habitat areas resilience to fire disturbance. 

Overstory canopy closure would be maintained at 60 percent or greater, ground disturbance would be 

limited to existing roads and skid trails, vegetation species diversity and composition would be 

maintained, and retention of snags and downed logs would be retained at 80 to 100 percent of the average 

numbers found within mature and old growth stands within the Forest.

33. Is any part of the project area in designated critical habitat for the NSO? Are there any NSO ACs in 

the project area? If so please provide us with the habitat suitability of each AC (N/R/F/D %), as well 

as occupancy status and whether or not 2012 protocol surveys have been conducted (Denise Boggs, 

CC, p. 2).

Response: The whole project is within critical habitat within the subunits ICCS 1 and ICCS 2. There are 

eight (8) identified NSO activity centers (AC) located within the 1st 48 planning area. Northern spotted 

owl protocol surveys were conducted in all suitable habitats for the 1st 48 Project in 2017, with the second 

year of surveys scheduled for 2018. In addition, NSO surveys were conducted within the planning area in 

the early and mid-1990s. Only one AC (347) was occupied during the 2017 surveys.

An analysis of habitat suitability has been conducted for each AC to determine the amount of 

nesting/roosting and foraging that is currently available and the percent proposed for treatment. Please 

note, dispersal habitat is not addressed at the AC level but for Critical habitat at the landscape level. 

Impacts to NSO ACs, suitable habitat, and Critical habitat were fully analyzed and displayed in the 

biological assessment (BA; Smith 2018).
Appendix A. Response to Comments

Final Environmental Assessment – 191

All pre-dominant and dominant trees would be retained. Suppressed, intermediate, and some co-dominant

trees (under specific conditions) would be removed. Large snags and downed wood would be maintained 

at the 80 to 100 percent level and canopy would be maintained at minimum of 60 percent in treated areas.

No suitable or Critical habitat removal or downgrading would occur under the 1st 48 Project except for 

landing construction. Nineteen landings, up to approximately 0.25 acres in size would be constructed in 

nesting/roosting/foraging habitat (CHU PCE 2 and PCE3) for a total of 5 acres, 3 acres of low-quality 

foraging habitat and 2 acres of low-quality nesting/roosting habitat, with negligible amounts of habitat 

reduction in any one area. The majority of landings that would be used for this project are existing 

openings that would only need minor expansion and brushing for safe operations; therefore, 5 acres of 

nesting/roosting/foraging habitat removed is an overestimate. All landings would occur within the outer 

1.3-mile radius of the affected ACs. The maximum amount of foraging habitat that would be removed in 

any one AC is 1 acre, 0.25 acres in any one area.

No AC would have treatments over 19 percent of the nesting/roosting habitat or over 25 percent of the 

foraging habitat. Thinning may modify nesting/roosting or foraging habitat but would maintain current 

habitat function immediately post-project. The project is expected to have beneficial effects by 

accelerating the development of forest structure to mature conditions more quickly than if left untreated, 

as well as reducing the risk of stand-replacing wildfire.

No activities would occur in high-quality nesting/roosting habitat or in 100-plus-acre nest groves of any 

AC, and no activities would occur within 0.25 mile of any AC during the breeding season.

No AC would have thinning or fuelbreak treatments over 19 percent of the nesting/roosting habitat within 

any one AC. Thinning may modify nesting/roosting habitat but would maintain current habitat function 

immediately post-project. The project is expected to have beneficial effects by accelerating the 

development of forest structure to mature conditions more quickly than if left untreated, as well as 

lowering risk of stand-replacing wild fire.

The total treatments within any one AC would vary from 0 to 25 percent of the available foraging habitat 

within 0.5 mile and 0.4 to 13 percent within 1.3 miles of the center (treatment acres/percentages within 

1.3 miles include the acres within 0.5 miles; Table 12). Only small amounts of foraging habitat would be 

lost due to new landing construction. A total of 3 acres foraging habitat removed within the action area, 1-

acre maximum in any one AC. This loss would be negligible in any one given area and would resemble 

small forest openings after the roads and landings have been decommissioned.

Treatments would result in a greater assurance of long-term maintenance of existing late-successional 

habitat within the action area. Fuel treatments in strategic areas along high-use roads would reduce the 

risk of fire ignitions along high use roads and provide greater protection to adjacent late-successional 

habitat. This will protect and enhance owl suitable and critical habitat in the long run.

34. “Project-level planning should consider connectivity between LSRs.” WA pg. 38 (Kimberly Baker, 

EPIC, p. 2).

Response: The project involves thinning stands to improve fire resilience. No habitat removal will 

occur; therefore, connectivity between LSRs will not be affected. The project is designed to improve 

habitat conditions through the acceleration of late-successional habitat characteristics, while still 

maintaining currently functional late-successional habitat. Although there would be minor habitat 
Appendix A. Response to Comments

192 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

degradation through the removal of brush and understory trees, in the long term the reduction of fuel 

ladders in these areas would improve adjacent habitat areas resilience to fire disturbance.

Overstory canopy closure would be maintained at 60 percent or greater, ground disturbance would be 

limited to existing roads and skid trails, vegetation species diversity and composition would be maintained, 

and retention of snags and downed logs would be retained at 80 to 100 percent of the average numbers 

found within mature and old growth stands within the Forest, providing for connectivity between LSRs.

35. “A rigorous timber program over the past 40 years has reduced the amount of late-successional 

habitat in the watershed, which has most likely reduced the amount of late-successional species.” WA 

pg. 50 (Kimberly Baker, EPIC, p. 2).

Response: Approximately 73 acres of the project occurs in a Late-Successional Reserve (LSR), 

specifically LSR 330. The STNF LSRA (1999) determined that this area of the LSR was deficient in latesuccessional habitat. Portions of the LSR were previously harvested; therefore, extensive stands of dense 

plantations exist that not only create a fuels hazard, they also do not provide suitable habitat for latesuccessional species such as NSO. Plantations and young natural stands are even-aged and lack the 

horizontal and vertical diversity components associated with late-mature stands. Young stands have the 

potential to achieve rapid diameter and height growth with thinning treatments. Silvicultural prescriptions 

can be applied to younger stands in order to accelerate their development toward late seral conditions. 

These treatments could increase the amount of late seral vegetation sooner than would occur naturally. 

The LSRA indicated the proposed area needs extensive fuels treatments to protect the LSR as well as 

extensive habitat restoration. The project would maintain and improve habitat conditions within the LSR.

Treatments would result in a greater assurance of long-term maintenance of existing late-successional 

habitat within the action area. Fuel treatments in strategic areas along high-use roads would reduce the 

risk of fire ignitions along high use roads and provide greater protection to adjacent late-successional 

habitat. Therefore, the project would maintain and improve habitat conditions within the LSR.

36. The Six Rivers Land Resource Management Plan (LRMP) at II-1 states, “The Forest will be managed 

to maintain ecosystem components, structure and processes. Both reserved and matrix areas perform 

an important role in maintaining biodiversity. Forests in the matrix function as connectivity between 

reserved areas and provide habitat for a variety of organisms associated with both late successional 

and younger forests.” South Fork Mountain provides important wildlife habitat connectivity. This 

reiterates the need to keep canopy and the largest trees (Kimberly Baker, EPIC, p. 2).

Response: The project involves thinning stands to improve fire resilience. No habitat removal would 

occur; therefore, habitat connectivity would not be affected. The project would provide both short and 

long-term benefits to wildlife by protecting current habitat and improving/restoring lower quality or nonhabitat. The 1st 48 Project will restore and accelerate development of important habitat characteristic for 

the spotted owl. This includes plantations and overstocked stands that, if treated, would increase the 

available habitats for the spotted owl and help reduce inter-specific competition between the barred owl 

and the spotted owl. Treatment of these stands would have an immediate benefit to the spotted owl. The 

project would maintain a canopy closure of 60 percent or greater.

37. Please survey the area to NSO protocol and consider Activity Center deficits in planning 

prescriptions. We are concerned about cumulative impacts from the Beaverslide and Kelsey projects. 

Please provide information on owl occupancy and reproductive status within project area and what is 

known in the Upper Mad River watershed (Kimberly Baker, EPIC, p. 2).
Appendix A. Response to Comments

Final Environmental Assessment – 193

Response: Northern spotted owl protocol surveys were conducted in all suitable habitats for the 1st 48 

Project in 2017, with the second year of surveys scheduled for 2018. In addition, NSO surveys were 

conducted within the planning area in the early and mid-1990s. Only one AC (347) was occupied during 

the 2017 surveys within the 1st 48 planning area.

Regarding all the past impacts from land uses (mining, timber harvest, and road constructions), the 1st 48 

Project would facilitate restoration by thinning plantations and young natural stands. The beneficial 

cumulative effects include the reduction of habitat fragmentation and the development of late-seral 

conditions.

The 1st 48 Project was designed to maintain current characteristics of nesting/roosting and foraging 

habitat but, more importantly, will create the currently lacking, critically important habitat characteristics 

for nesting/roosting and foraging habitat It is expected that current habitat function would be maintained 

in all treatment areas immediately post-project (as was seen in the post-treatment review of the 

Beaverslide Project); however, approximately 90 percent of the nesting/roosting/foraging habitat in the 

project action area would not have any treatment. Therefore, “adequate alternative habitat” as suggested 

by Forsman (2011) remains available in the action area for owl use. The project would develop functional 

habitat that is currently lacking in the stands.

The wildlife analysis area used for cumulative effects is the Upper Mad River Watershed (UMRW), which 

is a 5th-field watershed consisting of 102,926 acres. There are 25,178 acres of nesting/roosting and 24,762 

acres of foraging in the UMRW. Currently three (3) timber sales occur within the watershed on the Mad 

River District: Little Doe/Little Gulch, Kelsey Peak and Beaverslide. The Action Area for Beaverslide 

overlaps with the 1st 48 Project, but no treatments overlap or occur within any AC associated with the 1st

48 Project. The Shasta Trinity Salvage Project also overlaps with the 1st 48 Project, but no treatments 

overlap or occur within any affected AC.

The action areas for the 1st 48 Project and the Kelsey Peak Project overlap. No timber sale units for 

Kelsey Peak are within the overlap; however, 638 acres of the Kelsey Peak fuels corridor overlaps into 

the 1st 48 Project. This fuels corridor connects directly into the 1st 48 shaded fuelbreak creating an 

extended fuelbreak near the town of Ruth.

The Kelsey Peak Project has proposed treatments in 414 acres and 2,175 acres of nesting/roosting and 

foraging respectively. This equates to 3 percent nesting/roosting habitat being treated and 10 percent 

foraging habitat combined for the two projects being treated within the UMRW. All treated acres will 

maintain its current habitat function except for a negligible amount removed for landings that resemble 

small forest openings and will be decommissioned post-project. This leaves 97 percent and 90 percent of 

the available nesting/roosting and foraging habitat, respectively, untreated and available as alternative 

habitat for the use by spotted owls.

Within or overlapping the boundaries of the UMRW there are over 85 NSO ACs. Since the two projects 

are immediately adjacent to each other, four (4) ACs overlap Kelsey Peak and 1st 48 projects. The 

maximum combined percent treated of nesting/roosting habitat in any AC is 19 percent and 36 percent of 

foraging habitat. All treated areas would remain suitable post-treatment.

Because the effects of thinning and fuel treatments are primarily beneficial to NSO, similar projects 

(Beaverslide and Kelsey Peak) in the area should be considered to have achieved the desired conditions 

and provided positive cumulative effects to the area, as recommended by the Recovery Plan and the 2012 

Revised NSO Critical Habitat Rule (Critical Habitat Rule).
Appendix A. Response to Comments

194 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

38. NSO – Concerns about noise and other disruptions in habitat for Northern Spotted Owls, and other 

wildlife, especially rare, threatened and endangered (Karen Wilson, Individual, p. 1)

Response: Noise and smoke-generating activities that occur within or adjacent to suitable NSO habitat 

has the potential to disturb nesting owls. To avoid disturbance, design features and limited operating 

periods (LOPs) would be implemented as described in the project design features. The LOP from February 

1 through July 31 within 0.25 miles of known ACs will avoid impacts the NSO during the breeding season. 

Surveys to protocol would continue for the life of the project or additional seasonal restrictions would be 

imposed on any treatment in or within 0.25 miles of nesting/roosting habitat. A September 15 LOP would 

be used in occupied (breeding pair) or nesting/roosting habitat if no surveys are conducted.

39. The forthcoming NEPA document should address the effects of treatments on Sensitive, Management 

Indicator and Survey and Manage species (Kimberly Baker, EPIC, p. 3).

Response: Under the National Forest Management Act (NFMA), the Forest Service is directed to “provide 

for diversity of plant and animal communities based on the suitability and capability of the specific land area 

in order to meet overall multiple-use objectives” (PL 94-588§6(g)(3)(B)). The 1982 regulations 

implementing NFMA require that “Fish and wildlife habitat shall be managed to maintain viable populations 

of existing native and desired non-native vertebrate species in the planning area” (36 CFR 219.19).

Forest Service Sensitive (FSS) Species. All Forest Service Sensitive wildlife species known or thought 

to occur in the project area (based on habitat and range), were evaluated for this project. It was 

determined that the project would have no impact on certain Forest Service Sensitive species, based on 

either the lack of habitat, lack of detections during surveys, or the fact that habitat would not be impacted. 

Species that would not be affected by this project include the bald eagle (Haliaeetus leucocephalus), 

Townsend’s big-eared bat (Corynorthinus townsendii), fringed myotis (Myotis thysanodes), California 

wolverine (Gulo gulo luteus), Humboldt marten (Martes caurina), pallid bat (Antrozous pallidus), western 

bumblebee (Bombus occidentalis), western pond turtle (Clemmys marmorata), foothill yellow-legged frog 

(Rana boylii) southern torrent salamander (Rhyacotriton variegatus), and northern red-legged frog (Rana 

aurora aurora). Willow flycatcher was removed from the Sensitive species list for the Six Rivers as it was 

determined that the species did not breed on the forest.

o Pacific Fisher (Martes pennanti pacifica, also a Federal Candidate Species). Surveys for fisher 

were conducted and fisher were detected in the project area. Of the 13,686 acres of fisher denning 

habitat within the action area, approximately 290 acres of low- and moderate-quality denning 

habitat would be treated. No high-quality habitat would be treated. The amount of fisher denning 

habitat within the action area proposed for treatment would be approximately 2 percent (98% of 

the denning habitat in the action area would not receive any treatment). Characteristics for 

denning would be maintained and the stands would still function as denning habitat immediately 

post-project. Canopy closure in the outer riparian reserve buffers would be maintained at 60 

percent or greater.

o Northern Goshawk (Accipiter gentilis). Surveys were conducted in the 1st 48 Project area in 

2017. No goshawks were detected.

Management Indicator Species. Management Indicator Species is a concept used by the agency to serve 

as a barometer for species viability at the Forest level. Population changes of MIS are believed to indicate 

the effects of management activities. The SRNF LRMP uses MIS to assess potential effects of project 

activities on the various habitats and habitat assemblages with which these species are associated. The 1st

48 Project would not adversely impact MIS. Although shaded fuelbreak construction would degrade 
Appendix A. Response to Comments

Final Environmental Assessment – 195

habitat for species such as the Pacific wren and ruffed grouse, the majority of the project would 

improve/restore habitat conditions for all MIS by thinning young, homogenous stands, accelerating the 

development of multi-storied conditions and other late successional habitat characteristics.

Overstory canopy closure would be maintained at 60 percent or greater, ground disturbance would be 

limited to existing roads and skid trails, vegetation species diversity and composition would be 

maintained, and retention of snags and downed logs would be retained at 80 to 100 percent of the average 

numbers found within mature and old growth stands within the forest.

Little to no true riparian habitat exists within the units given the lack of riparian vegetation associated 

ephemeral and intermittent stream courses within the project area. However, in the long-term project 

implementation has the potential to improve riparian habitat conditions through the release of conifer and 

hardwoods/shrubs from thinning, generating a secondary canopy. The project would maintain high levels 

of coniferous canopy closure within the project area adjacent to riparian reserves. Project activities would 

not occur within riparian habitat. Implementation of the project would maintain and improve riparian 

habitat conditions.

Jackpot burning may also cause short-term habitat degradation through the loss of small woody debris; 

however, burning would occur under specific weather and moisture condition designed to minimize damage 

to the residual stand, maintain large woody debris, and maintain at least 50 percent of the duff layer.

Survey and Manage Wildlife Species. The 1st 48 Project is outside of the range of the Del Norte 

salamander. No wildlife S&M species occur within the 1st 48 Project; therefore, no pre-project surveys 

were conducted. This project is in compliance with the 2001 Record of Decision and Standards and 

Guidelines for Amendments to Survey and Manage, Protection Buffer, and other Mitigation Measure 

Standards and Guidelines (USDA and USDI 2001), the April 25, 2013 9th Circuit Court Order in 

Conservation Northwest (and others) v. Sherman (No. 11-35729), and the February 18, 2014 District Court 

Order in Conservation Northwest (and others) v. Robert Bonnie (and others) (W. WA No. C08-1067-JCC).

40. Wildlife Corridors where are these located in the Project area? (Karen Wilson, Individual, p. 1).

Response: The forest does not designate specific wildlife corridors, but rather facilitates wildlife 

dispersal through maintaining functional habitat in all treated areas. No habitat removal will occur; 

therefore, habitat connectivity would not be affected.

In addition, all riparian reserves have equipment exclusion buffers established from 160 to 320 feet within 

thin from below and hazardous fuels reduction units.

Comment Period on Draft Environmental Assessment

This section discloses the response to public comments received during the 30-day comment period on 

the 1st 48 Project draft EA, held between February 22 and May 26, 2018, in compliance with NEPA.

Summary of Comments Received

In response to comment period notifications (letter, posting on the SRNF website and email), the 

Responsible Official received written comments from one (1) agency and three (3) organizations. Table 30

provides a compiled listing of the names and locations of the commenters, the organization or entity each 

commenter represents, and the type and date of the comment submitted.
Appendix A. Response to Comments

196 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Table 30. Listing of the names and locations of the commenters, the organization or entity each commenter 

represents, and the type and date of the comment submitted.

Comment ID 

Code Commenter Entity Location Type Date of Comment

1 Kimberly Baker

Public Land Advocate

Environmental Protection 

Information Center (EPIC) Arcata, CA Email March 23, 2018

2 George Sexton

Conservation Director

Klamath Siskiyou Wildlands Center 

(KSWC) Ashland, OR Email March 23, 2018

3 Fred Blatt

Division Chief

North Coast Regional Water 

Quality Control Board (NCRWCB) 

Northern Nonpoint Source and 

Forestry Unit

Santa Rosa, CA Email March 21, 2018

4 Denise Boggs

Executive Director Conservation Congress (CC) Chico, CA Email March 19, 2018

Response to Comments

Introduction

The CEQ regulation 40 CFR 1503.4 states that an agency preparing an EA shall assess and consider 

comments both individually and collectively. The following includes a narrative of public comment 

statements received, followed by the Forest Service responses, organized by resource topic in alphabetical 

order. The comment statement is from the written comments. Copies of the written comments received are 

available upon request, located in the project file at the SRNF’s Supervisor’s Office, 1330 Bayshore Way, 

Eureka, California, 95501.

The discussions are organized by topic, presented in alphabetical order as follows:

o Botany Resources – Noxious Weeds (BRNW)

o Fire and Fuels (FF)

o General (G)

o Soil Resources (SR)

o Vegetative Resources (VR)

o Water Resources (WR)

o Wildlife Habitat Resources (WLH)

Botany Resources – Noxious Weeds (BRNW)

1. The moderate to high potential of the spread of invasive non-native plant species, primarily star 

thistle and spotted knapweed (we have heard that it is found on the allotment) is very concerning. We 

urge the district to by all means follow and implement the project design features and the Best 

Management Practices and if possible to limit cattle grazing in the area and complete surveys for 

invasive species throughout the Van Horn allotment. We would like to express our interest in the 

monitoring results and post implementation of manual treatments for these invasive species (Kimberly 

Baker, EPIC and George Sexton, KSWC, p. 3).

Response: The Forest Service considered the risk of introduction and spread of non-native invasive 

species during the planning process. The 1st 48 Project incorporates project design features and BMPs

essential for lowering the risk of introduction and spread. Completing surveys for invasive species 

throughout the Van Horn Allotment was deemed beyond the scope of the purpose and need.
Appendix A. Response to Comments

Final Environmental Assessment – 197

The Van Horn Allotment overlaps a southern portion of the 1st 48 Project area. For the environmental 

analysis, risk of introduction and spread of invasive plants was evaluated based on five indicators: 1) 

presence of known invasive plant species in the project area, 2) habitat vulnerability, 3) non-projectdependent vectors such as grazing, existing roads or trails, adjacent private property, 4) habitat alteration 

expected as a result of project implementation, and 5) potential for increasing vectors as a result of project 

implementation in compliance with FSM 2900 (Invasive species management).

1. The 1st 48 Project area features localized attributes that are conducive to yellow star thistle 

introduction and spread. Localized populations are visible alongside open FSRs being treated 

under the Proposed Action. See Table 26 (yellow star thistle infestations and their location within 

the project area).

2. The environmental conditions or attributes conducive to yellow star thistle introduction and 

spread, particular where there are barren soils in proximity to open FSRs (road cut banks, old fire 

lines, existing log landing sites, etc.). This invasive species is highly adapted to settings where 

this is full sunlight and soils are chronically disturbed. Yellow star thistle is intolerant of tree 

shaded, cooler riparian areas and forested settings with closed tree canopies.

3. Some operational activities including motor vehicle uses (administrative and public), and 

equipment uses (road maintenance; grading, ditch cleaning, etc.) can carry invasive plant seeds in 

soil and debris attached to tires and the undercarriages. Nearby private land development 

(driveway and road construction) and uses can provide additional vectors for introduction via 

seed dispersal in the wind and direct contact. Cattle act to introduce and spread non-native 

invasive plants along roadsides and into forest openings and grasslands via seeds embedded in 

mud attached to hoofs. Cattle are known to gather in riparian areas where it is cooler, and 

livestock impacts to the streambed, stream banks, and riparian vegetation have been documented 

in localized areas within the Van Horn Allotment.

4. The majority of the treatment units are densely forested with thick undergrowth. In select patches 

of grasses and forbs remaining in oak woodlands and where stimulated by wildfire, cattle grazing 

is currently limited. Transitory use along roadways is seasonal. The 1st 48 Project is designed to 

maintain a minimum of 60 percent canopy closure for all forest habitat types, specifically 

designed to retain sufficient tree shade to curb brush response representing a low risk. Treatment 

areas most vulnerable to attracting transitory grazing and associated risk of introduction and 

spread would be in the oak woodland treatment units planned for prescribed underburning, and in 

the areas that burned hot, where roadside mastication and jackpot burning of dead material may 

stimulate regeneration of grasses and forbs. In these areas, seeds of these plants can be 

inadvertently introduced to new areas on vehicles or equipment (the latter used in road 

maintenance), attached to domestic animals, or imported on rock/gravel/straw or other material 

used on roads or for erosion control).

5. The introduction and species invasive species and noxious weeds are influenced by multiple 

factors as aforementioned, including wind direction, animal migrations and drainage patterns. The 

final EA indicates the successful control of yellow star thistle would necessitate periodic 

monitoring and evaluation of treatment efficacy. As stated in Chapter 2, “If present after initial 

treatment, manually pull or use tools to remove individual plants in the late spring of the year 

(before fruiting/seeding) ensuring removal of the roots as much as possible. Pile treated plants 

and burn where treated, or if plant numbers are few, incorporate plant material into a nearby burn 

pile. Monitor annually and retreat as necessary until no plants persist. A complete listing of BMPs 

is included in Appendix C of this EA”.
Appendix A. Response to Comments

198 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Fire and Fuels (FF)

2. The SRNF is basing claims of high risk of stand replacing fire on the 1999 LSRA which is almost 20 

years old. Fire science has changed dramatically in the past 20 years. The EA lists the many benefits the 

project would have for fire suppression and mentions the fuel loads “could” result in high-intensity fire 

that “could” negatively impact suitable wildlife habitat. “Could” is a term that does not imply 

certainty. Many things “could” happen but we don’t manage for them (Denise Boggs, CC, pp. 6 and 7).

Response: The NFMA of 1976 (PL 94-588) reorganized, expanded and otherwise amended the Forest 

and Rangeland Renewable Resources Planning Act of 1974, which called for the management of 

renewable resources on national forest lands. The NFMA requires the Secretary of Agriculture to assess 

forest lands, develop a management program based on multiple-use, sustained-yield principles, and 

implement a resource management plan for each unit of the NFS. It is the primary statute governing the 

administration of national forests. The Forest Service has the responsibility and opportunity to assure a 

national natural resource conservation posture that will meet our citizens’ needs in perpetuity.

The Forest Service recognizes ecological systems and processes are highly complex. For this reason, the 

term “could” is deemed appropriate for the purposes of this analysis, as it reflects an accurate disclosure 

of the inherent level of uncertainty of stochastic fuel behavior modeling and predictions. However, the 

NFMA mandates the agency manage national, managing level of risk and take action as a precaution to 

conserve natural resources for the long term.

The final EA indicates a fire modeling assessment using the Fire and Fuels Extension (FFE) of the Forest 

Vegetation Simulator (FVS) was conducted to evaluate the existing potential of fireline intensity and 

relative hazard rating (expressed in flame length) and existing potential crown fire ratings for the 

proposed project area under severe and moderate fire conditions. Based on the fire modeling assessment, 

approximately 31 percent project (treatment) area currently could generate flame lengths over 4 feet 

making it necessary to utilize mechanized equipment, including aircraft, for suppression activities. There 

is evidence indicating past fires were a common occurrence from field observations where visible low 

intensity fire scars on pre-dominant trees was widespread. Tree ring and fire scar studies in the Douglasfir series on the SFNF found that the mean fire return intervals varied from 13 years in the south to 21 

years in the north (Adams and Sawyer 1980 In: Jimerson et al. 1996), with frequent lightning ignitions 

along South Fork Mountain. Stand-replacing fire events historically created large areas of young forest, 

during drought periods from 1860 to 1890 and 1915 to 1935 (MRWA; USDA Forest Service 1998).

3. The EA uses pejorative terms like “catastrophic” fire and talks about how fire is increasing. We are 

attaching two documents to these comments documenting acreage burned. The first is graph from the 

NIFC website showing the 80-year average is 14.1 million acres burned annually nationwide. The 

second document is from the USFS website. It shows an increase in acreage burned since 2003, that 

accounts for drought and climate change, but the annual acreage burned is well below 14.1 million 

acres. From 1998-2002 is was about 5 million acres burned and 2003-2007 it was about 8 million 

acres burned annually. In fact, the USFS (2017) states:

For burned area, the current period shows an increase over the reference period (table 

16-2); however, both of these periods are substantially less than the historic 5-year 

period maximum that occurred in the late 1920s, as illustrated in figure 16-1.

These graphs and documents should be read n entirety because they paint a much different 

picture than the propaganda the FS promotes in its “log to prevent wildfire” campaign.
Appendix A. Response to Comments

Final Environmental Assessment – 199

Response: The term catastrophic in the draft and final EAs is from the Recovery Plan, which identifies 

stand-replacing wildfire as one of the three top threats to the recovery of species stating, “Currently the 

primary source of habitat loss is catastrophic wildfire ....” The Recovery Plan further notes that wildfire 

size and frequency have been increasing in the western United States and that acres burned are expected 

to continue to increase due to climate changes and past land management practices. This overall increase 

in acres burned translates to a corresponding increase in the acres of spotted owl habitat lost to fire. The 

references described above have been reviewed, considered and included in the project record. However, 

local historic fire records such as the Ruth Fire in 2011, which resulted in loss of NSO habitats, are 

considered at-risk.

The EA acknowledges that there is a decrease in the average acres burned, but this is due to continued 

growth and effectiveness of suppression forces, along with improved access roads and aerial suppression 

and surveillance, has led to these decreases. The graph you reference does not address the increase in 

potential fire behavior. With the onset of effective fire suppression, fire frequency has declined, which has 

created changes in stand structure and fuel arrangement leading to greater potential of stand-replacing 

wildfire in the planning area.

4. WUIs: The best available science that came directly from the USFS states homeowners need to 

implement firewise practices on their own property within 100-300 feet from the structure. That will 

protect homes more than anything else. Creating defensible space occurs at the home site, not on NF 

lands.

Response: The purpose and need of this project is to provide rural communities and residents travel 

zones that allow for safer evacuation during wildfires; allow greater, faster wildland firefighter response 

and suppression; and reduce the risk of roadside fire starts traveling into high-value landscape-level forest 

resources. Given the level of fire frequency and risk, former Forest Service Chief Tom Tidwell 

emphasized in his 2014 letter of intent; “We do not accept unnecessary risk or transfer it to our partners or 

future generations. Enabling fire to be managed at an acceptable level of risk now would mitigate 

unacceptable consequences and reduce risk to future generations”. The Proposed Action is designed to 

meet this mandate.

Another consideration is that the State of California is concerned about the potential of high intensity 

wildfire, where they have invested in various defensible space programs, based on reasonable certainty 

that wildfire is a potential threat to wildland-urban interface (WUI) communities.

General (G)

5. Our initial comments have to do with process. This project came out the same day as the Somes Bar 

(WKRP) Project with the same due date for comments (March 26, 2018). Both projects are documented 

in an EA totaling over 600 pages, not counting specialist reports. It’s difficult to believe the SRNF wants 

substantive public comment when it releases two projects at the same time. My understanding is this 

happened to meet some timber targets in the fiscal year. (Denise Boggs, CC, p. 1).

Response: The Forest Service appreciates the commenter’s frustration, recognizing the bulk of the 

materials available for review. It was not our intention to schedule this overlap. The release of the Somes 

Bar Integrated Fires Management Project (Somes Bar Project) was originally scheduled to occur two 

weeks prior to offset the comment periods on the draft EAs. However, during the internal final review of 

the Somes Bar Project draft EA, content warranted revision prior to being released.
Appendix A. Response to Comments

200 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

The 1st 48 Project draft EA was listed in the SRNF’s schedule of proposed actions (SOPA) website since 

2017, indicating the release of the draft EA for public comment in February 2018. The SRNF received 

funding to accomplish the 1st 48 Project as a collaborative demonstration and adaptive learning 

opportunity. This project is one of the highest forest work priorities, as it demonstrates accountability to 

prior commitments made to the TCC (project was delayed in 2017), makes available easily accessible 

forest products responsive to repeated community requests for firewood and poles, as well as fulfilling 

regional accomplishments (timber, fuels reduction acres treated, miles of road decommissioning) to 

achieve our mission.

6. To make matters worse the specialist reports were not posted on the website, although we received 

some of them upon request. We did not receive the wildlife BE/BA and FWS consultation. These are 

the most important documents to CC and without them we can’t do the best job of relaying our 

concerns. The EA itself states in numerous places, as well as the response to comments, to refer to the 

BA. That document has never been made available to the public. According to the RO, the forest is 

required to make specialist reports available for public inspection during the comment period. There 

are also court cases stating they must be available during the comment period. Below is language 

from a successful lawsuit in 2014 regarding this very issue. It is pertinent to our complaint in the 1st

48 Project (Denise Boggs, CC, pp. 1 and 2).

Plaintiffs contend that the Forest Service was required to include certain Wildlife 

Specialist Reports in the appendices to its draft EIS and final EIS, yet failed to do so and 

also failed to disclose these reports during the comment period.

Defendants respond that the Forest Service permissibly incorporated the Specialist 

Reports by reference and that deliberative privilege permitted it not to disclose them 

during the comment period.

The Court finds that the Forest Service violated NEPA by failing to make the Specialist 

Reports accessible to the public. The Forest Service’s failure to include the Specialist 

Reports in the appendices of the draft EIS accompanied by its refusal to disclose during 

the comment period material on which it relied in the draft EIS is contrary to the spirit of 

NEPA and the letter of the CEQ regulations.

“The BA/BE contains the list of species considered, local population information, survey 

results, and suitable habitat descriptions on which effects of proposed projects are 

evaluated.” This document was not made available to the public for review and therefore 

this information can’t be accessed or reviewed. This is a NEPA violation (Denise Boggs, 

CC, p. 8).

Response: On February 22, 2018, the SRNF provided email, disc and/or hardcopy notifications of the 1st

48 Project draft EA, along with contact information if individuals needed additional material or had 

questions. On February 22, 2018, you requested specialist reports for review. On February 23, 2018, the 

Forest Service mailed (next day service) a thumb drive in response to your request including the following: 

S&M report, neo-tropical migratory bird report, MIS report, invasive plant risk assessment, soils report, 

and vegetative and watershed cumulative effects spreadsheets prepared for the draft EA. It was indicated 

that separate reports were not prepared for fuels, vegetation, range, visuals, recreation or hydrology.
Appendix A. Response to Comments

Final Environmental Assessment – 201

The validity and relevancy of court case lawsuits and determinations s in context of NEPA compliance for 

the 1st 48 Project regarding distribution of specialist reports and draft reports (draft BAs) during the 

comment period, may solely be determined by Office of General Counsel (OGC).

The SRNF did not release the draft Wildlife Biological Evaluation/Biological Assessment (BE/BA) as it 

was pending US Fish and Wildlife Service (USFWS) consultation under the streamline consultation 

procedures for §7 of the ESA (Forest Service and USFWS MOU, January 31, 2013). The objective of the 

streamline consultation process is to reduce the likelihood of conflicts between listed species or critical 

habitat and proposed actions, and is similar to “early consultation” described at 50 CFR 402.11. Using the 

best scientific and commercial data available, the USFS and the USFWS will independently make any 

factual determinations within their respective authorities, including final determinations concerning the 

content and findings. On the basis of early planning and Level 1 Team meetings, action agencies will 

prepare a draft BA. “At this point, the action agency will have identified its proposed action and the Level 

1 Team can assume the proposed action will not change in any way that materially changes the analysis in 

the draft BA” (MOU 2013). The Action agency (USFS) will submit the draft BA to the USFWS for 

review and comment. Level 1 Team members (USFS and USFWS) met on September 7, 2017, December 

13, 2017, and January 2, 2018 to clarify comments.

The information in the wildlife draft BA prepared per ESA was incorporated into the draft EA, with the 

exception the NSO methodology for the habitat analysis was separated under individual headings, tables 

displaying survey history and recent detection findings, acres per designated nest grove, acres of 

individual treatments by critical habitat subunits accounting for combined treatments proposed for the 1st

48 and the Kelsey Peak projects to foraging habitat, where overlapping with ACs were summarized in 

text, and AC habitat type maps were not included. Tables from the draft BA displaying current NSO 

nesting/roosting and foraging habitat by AC and proposed treatments by AC by habitat types within 0.5 

mile and 1.3 miles were incorporated in their entirety.

7. We requested the legal notice be withdrawn until the BE/BA was available and then begin the public 

comment process. I was told that in the future, requests for public comment would not be issued 

unless the specialist reports were available. While I appreciate that, it does me no good for this 

project (as well as Somes Bar). In addition, I was told the wildlife biologists didn’t want to release 

these documents because they were still working with the USFWS and changes would likely be made. 

This is very problematic because the forest is asking people to comment on a project without full 

knowledge, and in which changes may occur with no other opportunity to comment. The 218 regs 

forbid raising new issues during the Objection period, but CC reserves the right to raise new issues if 

an Objection is filed. While the regs don’t permit this, the SRNF has put everyone in an untenable 

position. We request the BE/BA/consultation be sent to us ASAP.

Finally, there is no substantive information on whether or not “take” will be authorized in this 

project. We can only assume there will be considering all 8 ACs are under minimum habitat 

thresholds; the project will log an additional 19-36% in four of the ACs that overlap with Kelsey; the 

other four are also under minimum habitat thresholds and will be logged an additional 2-25%; and 

the condition of the AC habitat threshold is used to determine take. More on that in these comments.

Response: The responsible official did not select to authorize an extension of the comment period. The 

1st 48 Project draft EA included the wildlife analysis with identical information from the draft BA 

prepared by the Forest Service, released for 30 day review and comment. The Forest Service mailed and 

emailed additional materials either same day or next day, in response to your requests.
Appendix A. Response to Comments

202 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

The regulations at 40 CFR 1500-1508 set forth specific requirements for implementing NEPA. The 

regulations establish procedures and rules governing environmental analysis and documentation; ensure 

that environmental information is available to public officials and the public and provide direction to 

assist public officials in making decisions based on an understanding of environmental consequences. 

Similar to other public comments received on the 1st 48 Project draft EA, revisions from USFWS review 

and comment during the Level 1 streamline consultation process on ESA listed species, prompted further 

clarifications and minor revision/supplemental information to the analysis disclosed in the final EA. 

These updates and rationale are described in the changes between draft and final EA section at the 

beginning of the final EA.

The Forest Service prepares an environment assessment (EA) to provide sufficient evidence and analysis, 

including the environmental impacts and alternative(s), to determine whether to prepare either an 

environmental impact statement (EIS) or finding of no significant impact (FONSI; 40 CFR 1508.9). If for 

any reason, during the Level 1 streamline consultation process there was a change in determination to ESA 

species in the final BA, the Forest Service may prompt a supplement and additional comment period, 

extend the comment period (36 CFR 220.5(f)(3)); or the responsible official could determine preparation 

on an EIS is warranted.

The release of the 1st 48 Project final EA and draft decision notice (draft DN) in compliance with 36 CFR 

220.5(h), 36 CFR 220.6(f), and 36 CFR 220.7(d)), along with the concurrent release of specialist reports 

on the SRNF website and the final BA for ESA listed species during the 45- day objection review period, 

provides another opportunity for the public to provide comments for consideration by the responsible 

official, prior to the decision. The pending federal decision document will document comments received 

during the objection period and how the responsible official addressed those comments.

Soils (SR)

8. LANDING CONSTRUCTION: Please avoid the construction of up to 20 new landings, as soil and 

habitat impacts last for decades and as stated above recent timber sales are adding to the habitat 

fragmentation in this watershed. Although there is an allowable percentage of soil damage associated 

with logging activities that does not mean it is desirable. We appreciate that the impacts would mostly 

be along roadsides however, we urge you to avoid new construction if at all possible to avoid removal 

of suitable habitat. (Kimberly Baker, EPIC, George Sexton, KSWC, p. 4).

Response: The Forest Service concurs in principle that soil impacts upon landings are not desirable. The 

soils report (p. 20) states “New temporary roads and landings can be the most impactful features 

associated with activities, in particular ground-based (tractor) operations. However, no new temp roads 

are proposed with this project, in agreement with the Collaborative.

Landings sites would be compacted by heavy equipment use with reduced infiltration. For this reason, 

drainage features would be required to control water runoff during and post operations. In alignment with 

the interests of the TCC, the majority of landings already exist and would be utilized to minimize further 

soil disturbance. Although the 1st 48 Project allows for constructing up to 20 new landings, the allowable 

landing sites would involve an expansion of existing areas that exhibit some previous ground disturbance 

located in natural openings within units, or widening roadside turnouts.

The Forest Service in collaboration with the TCC designed the 1st 48 Project along FSRs, whereby felled 

trees maybe decked along roads, and sorted and loaded into trucks where turnouts have been widened. 

Being almost exclusively roadside helps limit soil impacts and eliminates access road spurs. Recognizing 
Appendix A. Response to Comments

Final Environmental Assessment – 203

landing construction and use would result in unavoidable impacts to soils that would slowly recover 

naturally over time, they are included in the “allowable percentage of soil damage associated with logging 

activities” per the SRNF Land and Resource Management Plan (LRMP or forest plan).

9. GRAZING IMPACTS: It is not clear as to the extent of water quality or soil impacts currently 

occurring on the Van Horn Allotment and within the project area due to cattle grazing in addition to 

all other activities in this 5th field watershed. (Kimberly Baker, EPIC, George Sexton, KSWC, p. 3).

Response: The comment touches upon soil impacts on the Van Horn Allotment and elsewhere in the 5thfield watershed. Applicable to the soils part of the comment (excluding water quality and riparian 

concerns) it is noted in the soils report (p. 11) that the analysis area for soils for direct, indirect, and 

cumulative effects is restricted to “the entire “footprint” of the project activity units, as this is the full 

extent of direct soil disturbing activities. The R5 Supplement and the Forest Plan indicate that the activity 

area is an appropriate scale to analyze project effects on the soil resource. LRMP Soil Quality Standards 

are intended to be used at this scale to determine project effects on key soil functions, focusing here upon 

soil productivity and soil hydrologic function.” Note that for soils, the concern is with on-site soil quality 

and productivity.

Vegetation Resources (VR)

10. There also appears to be a lot of misleading information in the EA. The proposed action states 530 

acres are proposed for TFB in young natural stands and 108 acres of plantation thinning would 

occur. That sounds like one project. The rest of the EA includes exceptions for logging codominant 

trees; the charts included in the EA document logging trees over 100 years old and up to 150 years 

old and reducing the basal area between 44% and up to 80% in some units (Denise Boggs, CC, p. 3)

Response: While it is true co-dominants are part of the thinning prescription, the EA states, “First 

priority for removal would be the smaller suppressed and intermediate crown classes, as these smaller 

diameter trees have the poorest crown and tend to grow below the forest canopy. They are at the highest 

risk for tree mortality as a result of competition for light, water and nutrients. Some co-dominant trees 

would also be removed to improve the function of the fuelbreak, increase growth of adjacent trees and to 

meet the desired residual stand density. The following conditions for removal of co-dominant conifers 

include where:

o Co-dominant conifers do not have growing space in the canopy for further crown development, 

or removal of co-dominant trees is needed to reduce stand density to desired levels.

o Removal of co-dominant conifers adjacent to dominant and pre-dominant conifers and 

hardwoods, or pockets of smaller diameter hardwoods, would facilitate the survival of these 

trees.

A co-dominant is a tree’s position in tree canopy and has nothing to do with stand age. The final EA 

includes the definition of tree crown classes. It states a co-dominant tree is, “A tree whose crown helps 

form the general level of the main canopy in even-aged stands, or in uneven-age stands, the main canopy 

of the tree’s immediate neighbors, receiving full light from above and comparatively little from the 

sides.” Co-dominant trees can exist in young 40-year-old plantation or older stands. Thinning codominant trees is not restricted in the SRNF LRMP.

The draft EA (p. 48) states that most stands are between 80 to 120 years. The REO letter regarding the 

LSR exempts trees from 120 years, up to 150 years, in lieu of 20-inch diameter limit. The draft EA also 
Appendix A. Response to Comments

204 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

states that within the Douglas-fir/Black oak type, stands are between 70 to 80 years old (p. 53). Over 70

percent of the project area is within the vegetation type (p. 47). Tree data indicate that the larger tree 

components of the stands are indeed within the upper age range given, and no tree that had been aged was 

over 150 years (CSE data). In addition, when stand data was collected, including tree age data, trees were 

labeled assigned a “cut” or “leave” status that was based on the thin-from-below prescription-marking 

guide. All cut trees were aged. The largest cut tree measured was 25 inches and was 119 years old, which 

was the oldest cut tree aged. The oldest tree measured was 150 years old, but it was a 31-inch predominant Douglas-fir. The EA and treatment prescription states that no pre-dominant and dominant tree 

would be cut (draft EA pp. 39, 53, 68, 70-71, 73, 78, 84, 86, 89, 100, 138, 146-147).

There is nowhere in the EA that states or infers an 80 percent reduction in basal area. The final EA

includes existing basal areas (pp. 48-49, 53) and proposed basal area targets after thinning. No target basal 

area approaches an 80 percent reduction. One sentence (p. 49) within the final EA has two values that 

could be construed as an 80 percent reduction if used out of context, stating an existing basal area “ranged 

from 107 square feet per acre to 521 square feet per acre”. Tree data (CSE FVS) showed that basal areas 

reduction would range from 10 to 56 percent, with an average of 33 percent. The SRNF LRMP does not 

include arbitrary basal area thresholds within this range.

11. The project proposes to reduce the basal area anywhere from 42-80% depending on the seral stage. 

For EM/MM seral stage [about 42% of the project] which contain trees 70-120 years old, and have 

diameters of 16-32” the prescription is to reduce the basal area 60 – 80%. The next highest basal 

area removal is in units that are MM seral stage [29% of the project] which contain trees 100-120 

years old and have diameters of 24-32” DBH (Denise Boggs, CC, pp. 3 and 4).

Response: The prescription is based on a basal area target, depending on seral stage and existing 

conditions. Higher existing basal areas would have more basal area removed, and conversely, lower 

existing basal area conditions would have less basal areas removed. In areas where basal area is below 

prescription threshold, little to no trees would be removed.

This is not the next highest basal area removal. Mid-mature (MM) stands have higher basal areas, in 

general, than early mature (EM) by the fact they have larger trees. Basal area removal would still be 

dependent on existing conditions on the ground, while still following thin-from-below prescription 

retention guidelines.

The most basal area targeted for removal would be 56 percent, and the average would be 33 percent. 

Removing trees over 100 years does not violate the SRNF LRMP, or any other rule and regulation 

regarding tree age thresholds. Approximately 95 percent of the trees targeted proposed to be felled and

removed are less than 20-inch dbh, and the majority of these are less than 16-inch dbh.

12. The SRNF downplays the project area that is in LSR stating there are only 73 acres of LSR in the 

project. Then why not drop those 73 acres? The LSR RC-330 is mostly on the STNF and it has been 

logged to death. The FS likes to draw arbitrary lines and not consider the “rest of the picture.” The 

LSR should have been analyzed to see how it is functioning; the quality of the habitat; and what 

impacts further intrusion would cause. Instead, the SRNF cherry picked a “desired condition” to 

reduce the risk to large scale disturbance. What about all of the desired conditions to protect LSR 

habitat; not log any trees over 80 years of age; not to build roads in LSR; to manage them for the 

benefit of late-successional species. In fact, the LSRA states projects in this management area are not 

to be developed for economic purposes (Denise Boggs, CC, p. 4 and 5).
Appendix A. Response to Comments

Final Environmental Assessment – 205

Response. The Shasta-Trinity LSRA (USDA 1999), states “There is currently a substantial amount of late 

successional habitat within LSR. Also, of the 85, 917 acres that comprises the LSR, 83% is in late to midmature stands, and 13% is in plantations”. The portion of the LSR on the SRNF includes a few acres of 

plantations. The remaining portion has experience past management (logging), primarily along the 

existing road structure, which is nearly all close to the outer perimeter of the LSR (except for portions of 

1S23, which are well within the LSR). The 1st 48 Project would apply TFB on 49 acres retaining a 

minimum of 60 percent canopy closure, all pre-dominant, dominant and 98 percent of the co-dominant 

trees, out of the total 73 acres proposed for treatment within the LSR. Historic fire records indicate South 

Fork Mountain experiences frequent, seasonal lightning strikes. The FSR 23 lies along this north-south 

mountain ridgeline representing the boundary between the SRNF and the STNF to the east. As the FSR 

23 provides strategic access for fire suppressions crews, the 1st 48 Project includes these roadside 

fuelbreak treatments. No new road construction or reconstruction are proposed in the LSR. Existing 

temporary roads would be re-opened and closed after operations.

13. The SRNF claims removing all this habitat will not result in significant impacts to NSO or its habitat.

The problem is active management in the 1st 48 project will not “maintain or restore habitat”. In fact, 

it will log trees over 100 years old; remove up to 80% of the basal area in some units (Denise Boggs, 

CC, p. 5).

The SRNF is relying on a 2009 letter of clarification from the REO to the STNF permitting hazard 

reduction thinning activities to reduce the risk of large-scale disturbance and allow the logging of 

codominant trees. First, this letter is to the STNF not the SRNF. Second, it is 9 years old and 

outdated. Third, conditions of owl habitat and populations have changed dramatically in the past 5 

years alone, not to mention 9 years. We do not support logging codominant trees in this LSR that has 

already been logged and is not in accordance with the LSRA.

The EA also states the NWFP S&Gs for risk reduction treatments do not limit the size of trees that 

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

treatments within LSRs. The “LSR work group” concurred with an upper 150-year age limit on trees 

removed, as opposed to a 20-inch diameter limit. First, the fact the SRNF feels the need to make 

excuses for logging old growth trees in 73 acres of LSR to “benefit” the owl speaks volumes – and 

those volumes are in board feet. Trees targeted for removal in the LSR are larger diameter 24”+ and 

“may be removed to meet crown spacing objectives.” This appears to us to be a classic case of 

cherry picking large, old trees for volume and has nothing to do with improving owl habitat. This 

appears especially true when the EA states there are extensive stands of dense plantations in the LSR 

yet those plantations aren’t targeted for logging; the old growth trees are. If this project is intended 

to be beneficial to owl habitat, then plantations 80 years old and younger should be thinned; not 

natural trees 120-150 years old.

The LSR work group has no legal authority. If the SRNF intends to rely on some meeting notes, then 

it must include them in the final EA and be prepared to defend them. The whole premise of logging to 

reduce wildfire has been debunked for a decade. Again, the SRNF cherry picked a S&G when there 

are many others that speak to protecting owl habitat, the importance of old trees to owls, and 

allowing natural processes to occur. The SRNF has not even attempted to take a balanced approach 

in this project. This is a commercial timber sale to benefit industry. If implemented it will only harm 

the NSO and its habitat. We request the SRNF disclose how much old growth is being maintained in 

the 5th field watershed as required by the NWFP. If it is deficient, the FS should not be logging any 

120-150- year old trees, well on their way to old growth status (Denise Boggs, CC, pp. 4 and 5).

Response: Standards and Guidelines (S&Gs) in the Record of Decision for Amendments to Forest 

Service and Bureau of Land Management Planning Documents within the Range of the Northern Spotted 
Appendix A. Response to Comments

206 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Owl (NWFP ROD) provide that silvicultural activities, treatments to reduce risks of large-scale 

disturbances, and salvage within Late-Successional Reserves (LSRs) and Managed Late-Successional 

Areas (MLSAs) [collectively referred to as LSRs] are subject to review by the Regional Ecosystem Office 

(REO) (NWFP ROD pp. C-12, 13 and 26). In addition, other activities deemed to have potentially adverse 

effects on LSR objectives are subject to REO review (NWFP ROD p. C-19). The LSR Workgroup is a 

subgroup of the REO, which reviews treatments to provide concurrence that projects are consistent with 

the NWFP.

The S&Gs also state the REO may develop criteria that would exempt some activities within LSRs and 

managed late-successional areas from review. Exemption criteria for silvicultural projects have already 

been developed and were issued April 20, 1995, for young stand thinning, release, and reforestation and 

revegetation; and July 9 and September 30, 1996, for commercial thinning activities 

(www.reo.gov/library/policy/exemptions.htm).

On July 30, 2017, during the planning process, the SRNF contacted the LSR Workgroup, REO, 

responsible for LSR project-level consistency reviews. The REO considered stand types, stand history 

and location, and the proposed treatment for those stands in detail and confirmed the guideline of an 

upper age limit of 150 years as stated in the STNF LSR, as opposed to a 20’ dbh limit for removal of the 

encroaching white fir cohort.

The Proposed Action for this project is to thin-from-below, while maintaining the largest, healthiest trees 

within the stand, maintaining adequate stocking levels and maintaining canopy closures above 60 percent. 

Of all the data plots collected (CSE FVS), the highest basal reduction was 56 percent, and that was only 

one plot in a location with a basal area around 544 ft2

/acre. The average was 33 percent. Total basal area 

ranged from 71 ft2

/acre to 545 ft2/acre, averaging 293 ft2/acre. The prescription is designed to thin stands 

based on existing conditions, while maintaining adequate basal area and canopy closure. Residual basal 

area guidelines listed in the EA are average ranges. Areas with the highest basal area would likely have 

more trees removed, while still retaining all pre-dominant, dominant and most co-dominant trees, and 

would often result in exceeding the average basal area retention guidelines at that location, which still 

results in residual basal areas over 180 ft2

/acre.

Plot data demonstrates that on average, there is about one (1) snag per acre greater or equal to 20 inches

across the project area. This does not include areas within the Ruth Fire perimeter. Almost all of these 

snags have been dead for more than 5 years and no economic value. Felling snags will be primarily based 

on local conditions pertaining to safety and effects to fire outside the old Ruth fire perimeter. Within the 

fire perimeter, these snags have no commercial value, and felling operations are for other treatment 

purposes, primarily fuels reduction and safety. No snag within the fire perimeter are being cut for 

economic reasons.

The final EA defines Old Growth (OG) as generally open to dense stands, with multiple layers and trees 

of various size classes, the top layer of which is generally larger than 30-inch dbh. The current seral stage 

distribution across all species occurrence within the planning area is shrub/forb (6%), pole (9%), earlymature (43%), mid-mature (29%), late mature (3%) and old growth (2%). There are no treatments 

proposed within old growth stands. The watershed is currently at or below the minimum Recommended 

Management Range (RMR) for the late mature seral stage, and below the minimum RMR for old-growth 

in the Douglas-fir series. The Proposed Action would retain all dominant trees and pre-dominant trees, 

which includes those with defects. Most co-dominant trees would also be retained. The thinning from 

below prescription would not alter existing seral stage condition, and it would in fact, increase growth on 
Appendix A. Response to Comments

Final Environmental Assessment – 207

the remaining trees to accelerate development of trees into late seral size classes. This would promote an 

increase in the amount (acres) of late seral stands as an incremental step toward achieving the minimum 

Douglas-fir RMR OG threshold. No old growth trees are being targeted. All trees with old growth and late 

seral characteristics would be retained. The oldest tree within the LSR was 127 years old, and this was a 

26-inch tree. There are 17,250 acres of late seral within the 5th-field watershed.

Canopy closure prescriptions would retain 60 percent canopy closure as a minimum, not the average. In 

many cases, average stand canopy closure will be higher than 60 percent after treatment, and will exceed 

70 percent even after treatment, based on implementation monitoring of the Kelsey Peak Project and the 

Little Doe/Low Gulch Project (applied similar prescriptions).

14. The EA also cites to the “dry forests of the CA Klamath Province” for management actions that result 

in fire resilient and fire resistant forests. The SRNF is not even in this zone. It is within the Moist 

Forest Zone of the NSO range as delineated in the RRP. (Denise Boggs, CC, p. 7).

Response: The Recovery Plan was informed by Forsman et al. (2011) and Dugger et al. (in press at the 

time, but subsequently published in 2011). The Recovery Plan states, “The continued decline of the 

spotted owl populations and low occupancy rates in large habitat reserves, and the growing negative 

impact from barred owl invasions of spotted owl habitats (Forsman et al. 2011, Dugger et al. in press), 

which is greater than anticipated in the NWFP. In view of the increasing risk posed to NSO habitat by 

wildland fire in the dry forests of the California Klamath Province, the Recovery Plan calls for 

management actions that result in forests that are more fire resilient and fire-resistant.” The 1st 48 Project 

is located within the Northern California Interior Coast Ranges Region (ICC) modeling zone, as identified 

in the USFWS Revised Recovery Plan (2011) for NSO.

This region consists of the Northern California Coast Ranges ecological Section M261B (McNab and 

Avers 1994), and differs markedly from the adjacent redwood coast region. Marine air moderates winter 

climate, but precipitation is limited by rain shadow effects from steep elevational gradients (100 to 2,400 

meters) along a series of north-south trending mountain ridges. Forest communities in this modeling zone 

tend to be relatively dry mixed conifer, blue and Oregon white oak, and the Douglas-fir tanoak series 

(USFW 2011). The 1st 48 Project draft and final EAs state, “The SRNF is within the Moist Forest zone of 

the spotted owl’s range as delineated in the Recovery Plan.

However, the area’s dry, hot summers and extreme departure from its historic fire return interval mean that 

owl habitat within many areas of the forest is at risk of being lost to, or significantly degraded by, severe fire. 

The 1999 Megram Fire (120,000 acres), 2002 Biscuit Fire (500,000 acres), the 2008 Lightning Complex 

(45,000), the 2013 Butler (14,600 acres), the 2013 Coral fire (12,500 acres), the 2015 lightning fires (100,000 

acres forest-wide), the 2017 lightning fires (54,387 acres forest-wide) and many other smaller fires including 

the 2011 Ruth Fire (1,414 acres), all removed suitable NSO habitat on the SRNF, and demonstrates that the 

fire risk on the Forest is genuine. Active management to reduce the fire hazard and increase resilience, as well 

as to accelerate the development of higher-quality NSO habitat, should contribute to the spotted owl’s 

persistence and recovery. Such long-term protection of owl habitat is consistent with the recommendations in 

Forsman (2011), as well as the Recovery Plan and Critical Habitat Rule.

15. The EA states there are extensive areas of 40-plus year old plantations and young natural stands 

throughout the planning area. Yet this project only includes 108 acres of plantation thinning and the 

other units are in natural stands targeting old trees. In fact, 30% of this project targets large diameter, 

old trees. The EA also states the species of shrubs involved in the project are not known to be 

particularly volatile during a fire and opening up these stands would increase potential wind speeds, 
Appendix A. Response to Comments

208 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

which contribute to flame lengths. Blow down is expected to occur post treatment. These issues are 

mentioned but not analyzed in regards to (additional lost habitat see WLH), and increased risk of fire. 

(Denise Boggs, CC, p.7)

Response: In 2013, the TCC brought forward a “proof of concept” proposal, seeking collaboration with 

SRNF leadership, to establish a network of linear, roadside shaded fuelbreaks on national forest lands to 

facilitate safe evacuation, firefighter access and landscape fire management. The final EA indicates the 

placement of the proposed treatments would occur at varying widths, from a minimum of 25 feet on one side 

of a road, up to 275 on the other, not exceeding a total 300-foot-width. Fuelbreaks would be established along 

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

motorized trail (Jeep Trail 8E20); irrelevant if the stand was typed as a young natural stand or plantation.

The final EA indicates the 1st 48 Project would thin trees growing in plantations and oak woodlands 

bordering roadways, beyond the 275-foot maximum on one side of FSRs. Additionally, along the outer 

perimeter of the plantations, hazardous fuels reduction (HFR) treatments would be implemented to 

establish a 150-foot flank or buffer intersecting with the roadway. This design is responsive to higher risk 

for “volatile” conditions during a wildfire in even-age, overstocked plantations.

While there are always tradeoffs to stand manipulations in terms of fire behavior, it is expected that in the 

long term (10 years and beyond) the thinning conducted in this project would lead to reduced propensity 

towards crown fires and stand-replacing fire events. This conclusion is based on the expected rapid 

recovery of the upper canopy that would inhibit continued growth of tall shrubs that could contribute to 

extreme fire behavior. The final EA does indicate the species of shrubs involved are not known for being 

particularly volatile during a fire. However, this is discussion is pertinent to the white fir dominated 

stands located along South Fork Mountain only. The final EA states, “Opening up these stands would 

increase potential wind speeds, which contribute to flame lengths, but this effect should be negated by the 

reductions in surface and canopy fuels” (Graham et al. 2004, Agee and Skinner 2005).

The environmental analysis cannot quantify the extent of blowdown. However, the Forest Service 

acknowledges that opening up stands would increase potential wind speeds and contribute to flame 

lengths, but this effect should be negated by the reduction in surface and canopy fuels (Graham et al.2004, 

Agee and Skinner 2005). The final EA states, “Over time, thinning promotes a lower height-to-diameter 

ratio, which improves the ability of a tree to withstand heavy snow and ice loads, especially if they are 

associated with dynamic loadings associated with high winds” (Oliver and Larson 1990).

The thin from below (TFB) treatment prescription would retain residual basal area from 140 square feet 

per acre to 180 square feet per acre, with variable crown spacing and a minimum 60 percent canopy 

closure. The thinning treatment would retain a slightly higher target residual basal area square feet per 

acre, compared to lower elevation Douglas-fir dominated areas less prone to high winds. The higher basal 

area retention, along with retaining all pre-dominant and dominant trees above the main forest canopy 

most resistant to blowdown, and co-dominate trees composing the main canopy, is predicted to minimize 

blowdown and associated loss of forest structure.

The Upper Mad River Watershed Analysis (USDA 1998) found several trends thought to be related to the 

effects of fire suppression. Permanent forest inventory plots revealed a continuing increase in stand 

densities over the previous 30 years. This finding is consistent with recently collected stand data from the 

project area. The final EA indicates an absence of recent mixed-severity fire has been a likely factor in the 

rather uniform, even-aged, single-layer structure of these Douglas-fir stands, as well as the continued loss 

of black oak through competition from Douglas-fir. Historic fire record indicate since the early 1900s 
Appendix A. Response to Comments

Final Environmental Assessment – 209

with the fire suppression era, this lack of disturbance has lowered horizontal and structural diversity in the 

early- and mid-mature stands (Weisberg 2004, Taylor and Skinner 2003). The findings from the analysis 

indicates stand structure and fuel arrangement is now such that stand-replacing fire would be expected to 

be a substantial, if not the dominant, type of fire severity during wildfires in the planning area.

The Forest Service acknowledges the initial thinning treatments may stimulate growth response of some 

brush species, but the resulting crown growth would increase shade within a few years to once again inhibit 

brush growth. In addition, maintenance of fuelbreaks would treat brush response post initial treatment.

Water Resources (WR)

16. “The Upper Mad River Watershed is a heavily roaded watershed, which contributes additional 

fragmentation to a landscape that is already fragmented by natural conditions and previous timber 

harvest units. Fragmentation reduces habitat for species that require large home ranges with 

continuous habitats, and species that use interior, non-edge influenced late-successional habitats. -

Upper Mad River Watershed Analysis p 72.” (Kimberly Baker, EPIC and George Sexton, KSWC, p. 2)

Response: As disclosed in the Upper Mad River WA, the Forest Service is aware new road construction, 

historic clearcutting and other even-age management practices (particularly near streams) and infrequent 

road maintenance can contribute to elevated sedimentation/siltation and turbidity, increase water 

temperatures and fragmentation of wildlife habitats. In recognition the US Environmental Protection 

Agency (EPA) added the Mad River to California’s Clean Water Act §303(d) impaired water in 1992, and 

the North Coast Regional Water Quality Control Board (NCRWQCB) identified water temperature as an 

additional impairment to the watershed in 2006, the 1st 48 Project does not include new road construction or 

reconstruction. Rather, it would decommission (remove) 1.95 miles of road (FSR 2S54. The FSRs used for 

access and hauling would be maintained (bladed, culverts cleaned, waterbars constructed), prior to, during 

and post operations) for a slight reduction in current sediment production rates. Legacy sediment sources on 

FSR 2S52 and 2S53 would be rectified. Within the inner riparian reserve buffer, trees greater than 8-inch 

dbh would be retained to provide forest shade to maintain water temperatures during the summer. See WLH 

for discussion on habitat fragmentation and late-successional habitats.

17. “It is unclear in the draft EA how much of the 1.95 mile road segment will be treated and how many 

of the seven legacy sediment sites are beyond the landslide. Please clarify in the final EA how many 

crossings will be removed and how much of the 1.95-mile long road segment will be 

decommissioned.” (North Coast Regional Water Quality Control Board (NCRWQCB), p. 3)

Response: The entire 1.95-mile-long road would be decommissioned and removed from the road 

system. The landslide is at approximately mile 0.65. All seven legacy sediment sites and/or culverts are 

on the accessible side of the slide and would be treated. Beyond the slide, the road is primarily along a 

ridge and has no stream crossings, cross-drains or legacy sediment sites (EA pp. 29, 91).

18. “The draft EA identifies the use of existing skids trails and newly constructed skid trails to facilitate 

ground based operations. From our review of the Draft EA, we could not determine if use of existing 

or proposed skid trails is proposed within riparian reserves. Please incorporate in the final EA the 

specific on-the-ground prescriptions or the project design features designed to meet the USFS best 

management practices, and provide protection measures for skid trail watercourse crossings. 

Additionally, please provide a map of designated skid trail locations proposed for use within riparian 

reserves in the final EA or Waiver application.” (Fred Blatt, NCRWQCB, pp. 3-4)
Appendix A. Response to Comments

210 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Response: The entire riparian reserve would be designated an equipment exclusion zone. No equipment 

would be allowed on the ground within riparian reserves, whether there are pre-existing skid trails or not. 

There would be no skid trail watercourse crossings. The only place equipment would be permitted within 

riparian reserves is on existing FSR.

19. “The Draft EA identifies that existing skid trails are proposed for use within the Project area. Please 

identify in the final EA or Waiver application if the Project area has been evaluated for the presence 

of legacy sediment sites associated with any existing skid trail watercourse crossings. If there are 

legacy sediment sites associated with existing skid trail watercourse crossings within the Project area, 

please include the sites in the legacy sediment site treatment plan in the Waiver application.” (Fred 

Blatt, NCRWQCB, p. 4)

Response: There are no known existing skid trail watercourse crossings within the project area, and as such, 

no legacy sediment sites associated with pre-existing skid trails. This will be further clarified in the EA.

20. “Grazing by livestock in riparian areas has the potential to generate the discharge of nutrients and 

pathogens from animal waste, and to remove riparian shade. Grazing in riparian zones can also 

cause increased sediment loads to surface waters and physical compaction of the streambed. 

Disturbance and overgrazing of streambanks can cause decreased bank stability, increased erosion, 

and reduced riparian and instream vegetation to trap sediment. Please include discussion of these 

impacts and any monitoring performed on this allotment in the final EA and provide them via the 

project webpage.” (Kimberly Baker, EPIC, and George Sexton, KSWC, p. 3)

Response: Thank you for your comment. Grazing is known to have impacts to riparian areas and water 

quality. The impacts to grazing are incidental and transitory with limited to no observable impacts within 

the proposed project area. The Van Horn Allotment overlaps a southern portion of the project area. Cattle 

are known to gather in riparian areas where it is cooler, and livestock impacts to the streambed, stream 

banks, and riparian vegetation have been documented in localized areas within the Van Horn Allotment 

(USDA Forest Service 2010).

As canopy cover in forested areas would remain high, secondary range condition would experience minor 

improvement. Cattle would continue to use the area to travel through, but probably not stay since 

available forage is minimal. In oak woodland areas that would be enhanced from thinning release and 

prescribed burning, secondary range would be improved and cattle grazing would expect to occur in 

slightly higher frequency than before implementation. Plantations with thinning would have a brief 

improvement in secondary range, but improved growth would shade out forbs and grass in less than 5 

years. Conditions in the white fir stand would be similar to those occurring in the lower elevation 

Douglas-fir dominated forested stands, considered too dense to support much of an increase in secondary 

range conditions. Reducing localized impacts to streams from grazing activities is outlined in the annual 

operation instructions to the permittee. The forest implements range monitoring per the terms and 

conditions of the North Coast Water Quality Waiver.

Wildlife Resources (WLH)

21. We did not receive the wildlife BE/BA and FWS consultation. These are the most important documents 

to CC and without them we can’t do the best job of relaying our concerns. The EA itself states in 

numerous places, as well as the response to comments, to refer to the BA. That document has never 

been made available to the public. According to the RO, the forest is required to make specialist 
Appendix A. Response to Comments

Final Environmental Assessment – 211

reports available for public inspection during the comment period. There are also court cases stating 

they must be available during the comment period.) (Denise Boggs, CC, p. 1).

Response: Consultation direction is included under the Endangered Species Act (ESA), not NEPA. A 

federal agency must prepare a BA, which analyzes the potential effects of the project on listed species and 

critical habitat and justifies a particular “effects determination.” A BA was drafted and includes the 

threatened and endangered species analysis found in the draft EA. The Forest is in full compliance with 

the ESA. The complete threatened and endangered species effects analysis was included in the draft EA 

for public comment. See comment #7.

22. I was told the wildlife biologists didn’t want to release these documents because they were still 

working with the USFWS and changes would likely be made. This is very problematic because the 

forest is asking people to comment on a project without full knowledge, and in which changes may 

occur with no other opportunity to comment. (Denise Boggs, CC, p. 2).

Response: The consultation process on the SRNF is conducted under the Level 1 Consultation process. 

The role of the Level 1 Team is to reach consensus on determinations for projects and to ensure that all 

the required information is included in BAs before being sent to USFWS for consultation. The Level 1 

Team is also responsible for proposing mitigations that would minimize impacts to listed species. This 

requires that the team be fully informed of what is included in the project. The Level 1 Team consists of 

wildlife biologists from the USFWS and the Forest Service, each with extensive experience with the NSO 

and consultation.

The Level 1 Team conducted informal consultation on the 1st 48 Project on December 13, 2017 and 

February 7, 2018, with a field visit on June 13, 2016. The Level 1 Team provided management 

recommendations that would minimize impacts to the NSO, and agreed that the project “may affect, but is 

not likely to adversely affect” the NSO or NSO Critical Habitat.

The Level 1 Team is fully versed in the project description and the potential impacts to listed species. 

Review of the BA involves adding clarification or additional details. At this stage in a project, no 

substantive changes are made to the documents that would change the level of effects or the 

determination. If such changes did occur, the NEPA document and timelines would have to be modified.

23. There is no substantive information on whether or not “take” will be authorized in this project. We 

can only assume there will be considering all 8 ACs are under minimum habitat thresholds; the 

project will log an additional 19-36% in four of the ACs that overlap with Kelsey; the other four are 

also under minimum habitat thresholds and will be logged an additional 2-25%; and the condition of 

the AC habitat threshold is used to determine take. (Denise Boggs, CC, p. 3).

Response: The USFWS (Level 1 team) determined that the project was “not likely to adversely affect” 

the NSO or NSO Critical habitat. No take occurs under a “may affect, not likely to adversely affect” 

determination. No nesting/roosting or foraging habitat will be removed or downgraded, beyond three 

acres of low-quality foraging habitat removed for landings. Please note, no nesting/roosting habitat will 

be removed for landings as previously reported in the draft EA.

Each landing would be 0.25 acres or less in any one area, all in the outer 1.3 miles of any affected home 

range. A total of one acre is the maximum amount removed in any one AC. The USFWS has considers 

this amount of habitat loss to be insignificant when considered with the project design features. The 

USFWS considers that effects to spotted owl habitats around ACs will be minimized if there are no 
Appendix A. Response to Comments

212 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

treatments or removal in the 70-plus acre nest groves, no high-quality habitat is being treated, posttreatment canopy closure will be maintained at 60 percent or greater in all treated areas, no pre-dominant

or dominant trees will be removed, and all large logs and snags 20-inch dbh or greater will be retained 

(unless they pose a safety hazard). Large snags felled for safety reasons will be left on site. The project is 

not likely to affect the NSO or Critical Habitat.

24. There is an inherent conflict between an economically viable commercial timber sale and a project that 

would improve NSO habitat. Both goals can’t be achieved in one project. (Denise Boggs, CC, p. 3).

Response: The design of the 1st 48 Project is similar to the Little Doe/Low Gulch, Beaverslide, and 

Kelsey projects, all which the USFWS has determined to maintain current habitat function, and were “not 

likely to adversely affect” the NSO or NSO Critical Habitat. The USFWS defines “habitat maintenance” 

as a reduction in stand density, but the current habitat function would be maintained immediately post 

project with the purpose of improving its quality for the species over time.

The Level 1 team conducted a post-treatment habitat monitoring of the Beaverslide Project, as well as the 

Little Doe/Low Gulch Project. The level 1 team found that all the units exceeded canopy closure 

requirements, and protected pre-dominant trees, snags, and downed logs. The Level 1 team agreed that: 1) 

the prescriptions had been met, 2) that the units are still functional habitat as expected, and 3) the units 

should respond well to the treatments. The Level 1 Team agreed the treatments will have a beneficial 

effect on the future habitat conditions of the area.

25. The project states the best owl habitat was dropped from the project, and the habitat in the project is 

not as preferred by NSO as if that somehow makes it better. The RRP states to protect ALL suitable 

habitat. Obviously the habitat in the project is suitable because it’s critical habitat designated as 

N/R/F/D.

Next, the EA goes to great lengths to claim there will not be any habitat removal. This is simply not 

true. The EA states 2 acres of N/R habitat will be removed; 3 acres of foraging habitat will be 

removed; and 8 acres of dispersal habitat will be removed for landings, for a total of 13 acres of 

habitat removal. To put that in a visual perspective, it’s about 16 football fields cleared of vegetation 

throughout the project area. That is a significant loss of suitable habitat and should have been 

treated as such. (Denise Boggs, CC, p. 3).

Response: The 2011 Recovery Plan does not state that ALL suitable habitat must be protected. Rather the 

Recovery Plan states the agencies should maintain or restore “older and more structurally complex multilayered conifer forests... while allowing for other threats, such as fire and insects, to be addressed by 

restoration management actions. These high-quality spotted owl habitat stands are characterized as having 

large diameter trees, high amounts of canopy cover, and decadence components such as broken-topped 

live trees, mistletoe, cavities, large snags, and fallen trees” (Recovery Action 32).

There would be no high quality habitat is being treated under the 1st 48 Project. Although the Recovery 

Plan does not require all suitable habitat be protected, the 1st 48 Project is designed to maintain or 

improve all suitable habitat conditions within the project area. Please be advised that Critical Habitat, as 

defined by the USFWS, does not equate to “suitable” habitat for the NSO. Critical Habitat is a land 

designation or a specific area on a map. “Suitable habitat” is what the NSO actually uses. Not all areas of 

Critical Habitat are suitable for the NSO. However, the 1st 48 Project was designed to maintain or 

improve all suitable habitat, regardless of land allocation.
Appendix A. Response to Comments

Final Environmental Assessment – 213

The stands selected for treatment minimally met the definition of suitable nesting/roosting/ foraging 

habitat, but had a lower likelihood contributing to survivorship or reproduction. The stands had one or 

more features of suitable habitat, but lacked other important characteristics that reduce their likelihood of 

occupancy or use. For example, a stand may have an average tree size of 21-inch dbh and 60 percent 

canopy cover, but lack large nest trees and multi-layered canopy conditions. The 1st 48 Project was 

designed to maintain current characteristics of nesting/roosting and foraging habitat but, more 

importantly, would create the currently lacking, critically important habitat characteristics for 

nesting/roosting and foraging habitat. It is expected that current habitat function would be maintained in 

all treatment areas immediately post-project (as was seen in the post-treatment review of the Beaverslide 

Project; however, approximately 96 percent of the nesting/roosting/foraging habitat in the action area 

would not have any treatment. Therefore, “adequate alternative habitat” as suggested by Forsman (2011) 

remains available in the action area for owl use. The project would develop functional habitat that is 

currently lacking in the stands.

This project has protected all high-quality habitat, all spotted owl home ranges (not just high priority 

sites, RA 10) and would restore and accelerate important habitat characteristic for the spotted owl (RA 6) 

in young overstocked stands. Such long-term protection of owl habitat is consistent with the 

recommendations in the Recovery Plan.

Each landing would be 0.25 acres or less in any one area, all in the outer 1.3 miles of any affected home 

range. A total of one (1) acre is the maximum amount removed in any one AC. Small openings can be 

beneficial in stands lacking structural diversity to “maximize individual tree development, encourage 

some understory vegetation development, and encourage the initiation of structural diversity” 

(Interagency REO memorandum 1996). In addition, the USFWS has considered this amount of habitat 

loss to be insignificant when considered with the project design features.

The majority of landings that would be used for this project are existing openings that would only need 

minor expansion and brushing for safe operations; therefore, three acres of foraging habitat removed is an 

overestimate.

The USFWS considers that effects to spotted owl habitats around ACs will be minimized if there are no 

treatments or removal in the 70-plus acre nest groves, no high quality habitat is being treated, posttreatment canopy closure will be maintained at 60 percent or greater in all treated areas, no pre-dominant

or dominant trees will be removed, and all large logs and snags 20-inchdbh or greater will be retained 

(unless they pose a safety hazard). Large snags felled for safety reasons will be left on site. The project is 

not likely to affect the NSO or Critical Habitat.

26. The project proposes to reduce the basal area anywhere from 42-80% depending on the seral stage. 

For EM/MM seral stage [about 42% of the project] which contain trees 70-120 years old, and have 

diameters of 16-32” the prescription is to reduce the basal area 60 – 80%. The next highest basal 

area removal is in units that are MM seral stage [29% of the project] which contain trees 100-120 

years old and have diameters of 24-32” DBH. The SRNF claims removing all this habitat will not 

result in significant impacts to NSO or its habitat; and the habitat will still function as its designation 

of N/R/F. It is simply impossible to reduce that amount of older tree habitat and have the area 

function the same. NSO prefer a BA of 180 ft2/acre for foraging and 210+ft2/acre for high quality 

nesting/roosting habitat. This project will not maintain those values; is managing for minimums and 

in some case not even meeting minimums; and therefore this project will not be beneficial to NSOs or 

their habitat. (Denise Boggs, CC, p. 4).
Appendix A. Response to Comments

214 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Response: The amount of basal area being removed is dependent on stand density, which varies by stand 

and will require site-specific design to meet other project requirements. The project will maintain the 

largest trees in the stand with the best crowns, all pre-dominant and dominant trees, and a minimum of 60 

percent canopy closure.

The minimum standards described are not the objective or goal of the treatments, but the lowest a stand 

can be taken in any one area. Canopy closure is expected to be maintained at 10 to 20 percent higher than 

the minimums. The largest, oldest trees in the stands will be maintained. Primarily suppressed and 

intermediate trees will be removed, with co-dominant trees only being removed under specific conditions 

(to improve growing conditions for a larger conifer or large dimeter hardwood). Suitable NSO habitat will 

be maintained in all areas.

27. The project also promises to maintain 60% canopy cover in each unit, but owls prefer 70-90% canopy 

for N/R habitat. The EA never addresses NSO preferences for N/R habitat; it simply speaks to bare 

minimum requirements. We are led to believe 60% canopy is sufficient. That number is below even the 

lowest level of 70% owls prefer for nesting. While owls will use stands with canopy cover of 60% is 

not as secure and not what is needed in order for the owl to recover. NSO are using all kinds of 

habitat to nest in because of fragmentation from logging and barred owl invasion, therefore more 

habitat should be retained. That is why the RRP requires protecting all suitable owl habitat. This 

entire project is in suitable habitat, as well as critical habitat. (Denise Boggs, CC, p. 4).

Response: The EA discusses the habitat requirements for the NSO in detail, including N/R habitat, and, 

as stated above, the Recovery Plan does not require all suitable habitat be protected, although the 1st 48 

Project is designed to maintain or improve all suitable habitat conditions within the project area.

As stated above, the minimum standards described are not the objective or goal of the treatments, but the 

lowest a stand can be taken in any one area. Canopy closure is expected to be maintained at 10 to 20 

percent higher than the minimums. The largest, oldest trees in the stands will be maintained. Primarily 

suppressed and intermediate trees will be removed, with co-dominant trees only being removed under 

specific conditions (to improve growing conditions for a larger conifer or large dimeter hardwood). 

Suitable NSO habitat will be maintained in all areas.

28. The problem is active management in the 1st 48 project will not “maintain or restore habitat”. In fact, 

it will log trees over 100 years old; remove up to 80% of the basal area in some units; continue 

logging ACs that are already under minimum habitat thresholds; and overall continue to chip away at 

designated critical habitat and LSR at the expense of spotted owls. (Denise Boggs, CC, pp. 5-6).

Response: Thinning and fuels reduction activities may have a short-term reduction of stand density in 

suitable NSO nesting/roosting habitat; however, the habitat will remain suitable post project. Canopy 

closure will be maintained at 60 percent or greater in all treated areas, no pre-dominant or dominant trees 

will be removed and large snags and downed wood would be maintained at the 80 to 100 percent level. 

Co-dominant trees will only be removed if under specific conditions that will improve the growth of an 

adjacent larger conifer or large hardwood. All high-quality nesting/roosting habitat consisting of old 

growth late mature, and some mid mature stands were excluded from commercial harvest. Selected stands 

for thinning are considered low to moderate quality, with the potential to be improved through treatment.

As stated above, the USFWS considers that effects to spotted owl habitats around ACs will be minimized 

with the design features above. The project will maintain and restore habitat conditions within the project 

area.
Appendix A. Response to Comments

Final Environmental Assessment – 215

29. Under RA 32 the EA states the definition of NSO N/R habitat used for this project was based on the 

definition found in the LRMP, which is about 20 years old. It goes on to say the LRMP definition was 

based on extensive published literature and represents the best available science. That is not true any 

longer. The RRP represents the BAS; not a 20-year old definition based on outdated information. The 

RRP states “All suitable habitat” should be considered N/R/F habitat. (Denise Boggs, CC, p. 6).

To meet RA 32 the EA claims no habitat will be removed. That is not true. Five acres of N/R/F habitat 

and 8 acres of dispersal habitat will be removed for landings, and 12 of these landings will be in 

Activity Centers. The EA attempts to brush this off and fails. Removal is removal. Using an outdated 

definition of N/R habitat and habitat removal does not meet the intent of RA 32 and this project fails 

to comply with the RRP. (Denise Boggs, CC, p. 6).

Response: The LRMP definition was based on the best available science at the time, but more 

importantly, is a very conservative description of potential habitat. NSO on the SRNF have been found 

nesting in habitat meeting this definition (which represents the best available science no matter the age of 

the definition). It is important to note that LRMP definition does not limit the description of 

nesting/roosting habitat but is the starting point. To limit the definition to high-quality habitat only would 

greatly underestimate the amount of habitat available to the NSO.

The Recovery Plan states, “Because the characteristics of the stands or patches targeted by this recovery 

action vary widely across the range of the species, the Service believes implementation and/or mapping of 

this recovery action is best left to interagency teams with localized expertise.” The Level 1 team has 

reviewed and approved the definitions of suitable habitat the SRNF uses.

To clarify, all suitable habitat was considered nesting/roosting/foraging habitat, and was discussed at 

length in the EA. Please note, no nesting/roosting habitat would be removed for landings, as previously 

reported in the draft EA.

As stated above, each landing would be 0.25 acres or less of low-quality foraging habitat in any one area, 

all in the outer 1.3 miles of any affected home range. A total of one acre is the maximum amount removed 

in any one AC. Small openings can be beneficial in stands lacking structural diversity to “maximize 

individual tree development, encourage some understory vegetation development, and encourage the 

initiation of structural diversity” (Interagency Regional Ecosystem Office memorandum 1996). In 

addition, the USFWS has considered this amount of habitat loss to be insignificant in past consultations 

when considered with similar project design features. The USFWS considers that effects to spotted owl 

habitats around ACs will be minimized if there are no treatments or removal in the 70-plus acre nest 

groves, no high quality habitat is being treated, post-treatment canopy closure will be maintained at 60 

percent or greater in all treated areas, no pre-dominant or dominant trees will be removed, and all large 

logs and snags 20-inchdbh or greater will be retained (unless they pose a safety hazard). Large snags 

felled for safety reasons will be left on site. The project meets the objectives of the Recovery Plan.

30. RA 10 requires conserving spotted owl sites and high value habitat to provide additional 

demographic support; and to prioritize known historic owl sites for conservation and/or maintenance 

of existing levels of habitat. Neither of these criteria have been met. The EA is silent on the LSR’s 

direction for demographic support; and nowhere else in the document is demographic support even 

mentioned. The 1st 48 project proposes to log N/R/F habitat in all 8 historic ACs that are already 

under minimum habitat thresholds. This is not conserving or maintaining existing levels of habitat. It 

is further reducing habitat in these ACs. RA 10 will not be met in this project.
Appendix A. Response to Comments

216 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Response: No habitat removal would occur in any AC beyond negligible amounts of low-quality 

foraging habitat. Habitat will be maintained in all treated areas. Because the SRNF strives towards 

recovery of the spotted owl, all ACs receive the same level of protection and are not prioritized with some 

ACs getting lower levels of protection as allowed by the Recovery Plan. This goes beyond the 

requirement of the RA 10 of the 2011 Recovery Plan. In addition, the USFWS requires a 70-acre nest 

grove protection zone. In this project we exceeded 70 acres around each known AC (each AC has a 

minimum of 100 acres delineated for nest grove protection), which was incorporated into the project 

design (see the BA for the project for specific information relating to nest groves). No activities would 

occur within the nest groves.

This project has protected all high-quality habitat, all spotted owl home ranges (not just high priority 

sites, RA 10) and would restore and accelerate important habitat characteristic for the spotted owl (RA 6) 

in young overstocked stands. Such long-term protection of owl habitat is consistent with the 

recommendations in the Recovery Plan.

31. RA 6 states projects in spotted owl habitat should occur in plantations, overstocked stands, and 

modified younger stands. This RA will not be met. This leads back to the proposed action as described 

under Alt. 2 in the EA as thinning young seral stage stands and 108 acres of plantations; and the rest 

of the document that has exceptions for logging codominant trees; trees up to 150 years old; etc. to 

make a timber sale that is economically viable. This is the inherent conflict we mentioned previously. 

RA 6 does not permit or suggest logging codominant trees. (Denise Boggs, CC, p. 6).

Response: As stated in the Proposed Action for the project, 108 acres of plantation will be thinned 

within the fuelbreak area (150 feet each side of the high-use roads). Recovery Action 6 does not limited 

all treatment to plantations, but rather specifically addresses treatments “in plantations, overstocked 

stands and modified younger stands to accelerate the development of structural complexity and biological 

diversity that will benefit spotted owl recovery”. The project meets the objectives of RA 6 and the 

Recovery Plan.

32. The project The SRNF also fails to acknowledge that spotted owls evolved with western forests that 

had wildfires much larger than today; burning far more acres; as well as insect and disease 

epidemics. Spotted owls managed just fine before the USFS was ever created. Logging to prevent 

wildfire is a fool’s game and it certainly does not improve the habitat for spotted owls – not as 

proposed and carried out by the FS in general or proposed in this project. Fire is not “catastrophic” 

in late-successional habitat when owls evolved with it. (Denise Boggs, CC, p. 7).

Response: The SRNF lies within the Moist Forest zone of the spotted owl’s range as delineated in the 

Recovery Plan. However, the area’s dry, hot summers and extreme departure from its historic fire return 

interval mean that owl habitat within many areas of the Forest is at risk of being lost to, or significantly 

degraded by, severe fire. The 1999 Megram Fire (120,000 acres), 2002 Biscuit Fire (500,000 acres), 2008 

Lightning Complex (45,000), 2013 Butler Fire (14,600 acres), 2013 Coral Fire (12,500 acres), 2015 

lightning fires (100,000 acres forest-wide), 2017 lightning fires (54,387 acres forest-wide), and many 

other smaller fires, including the 2011 Ruth Fire (1,414 acres), all removed suitable NSO habitat on the 

SRNF, and demonstrates that the fire risk on the forest is genuine. Active management to reduce the fire 

hazard and increase resilience, as well as to accelerate the development of higher quality NSO habitat, 

should contribute to the spotted owl’s persistence and recovery. Such long-term protection of owl habitat 

is consistent with the recommendations in Forsman (2011) as well as the Recovery Plan and Critical 

Habitat Rule.
Appendix A. Response to Comments

Final Environmental Assessment – 217

The 1st 48 Project includes the footprint of the 2011 Ruth Fire, which burned 688 acres of nesting/roosting 

foraging habitat (386 acres of nesting roosting habitat and 302 acres of foraging habitat) at high severity, 

including in already deficit ACs. The proposed action will not only protect the WUI area form uncontrolled 

wildfire, but also help protect exiting late-successional habitat from human cause fires along high-use 

roads and from uncontrolled fires originating on private land.

33. What is certain is the NSO population is precipitously declining in northern CA; and every 

commercial timber sale planned on the SRNF is in designated critical habitat/LSR. There are 

implications to this management strategy the SRNF continuously fails to address. Timber sales impact 

owls now. Long term means little to an extinct species. The SRNF also fails to acknowledge that 

spotted owls evolved with western forests that had wildfires much larger than today; burning far more 

acres; as well as insect and disease epidemics. Spotted owls managed just fine before the USFS was 

ever created. Logging to prevent wildfire is a fool’s game and it certainly does not improve the 

habitat for spotted owls – not as proposed and carried out by the FS in general or proposed in this 

project. Fire is not “catastrophic” in late-successional habitat when owls evolved with it. It is only 

catastrophic to the timber industry that wants board feet/volume from NF lands at tax payer/wildlife 

expense. (Denise Boggs, CC, p. 7)

Response: On December 4, 2012, the Critical Habitat Rule was published (77 Fed. Reg. 71876-72068). 

Critical habitat consists of those areas which have “physical or biological features (I) essential to the 

conservation of the species and (II) which may require special management considerations or protection” 

(16 USC 1532(5)(A)). In total, approximately 9,577,969 acres (3,876,064 hectares (ha)) in 11 units and 60 

subunits in California, Oregon, and Washington fall within the boundaries of the Critical Habitat 

designation Federal agencies are required to consult on any project that may affect newly designated 

Critical Habitat under the ESA. The rule became effective on January 3, 2013. Out of the 280,259 acres of 

national forest land administered by the Mad River RD, there are 180,319 acres designated as Critical 

Habitat or 64 percent of the land base. As a consequence, past and current proposals many times occur 

within designated critical habitat.

34. Blow down is expected to occur post treatment. These issues are mentioned but not analyzed in 

regards to additional lost habitat (Denise Boggs, CC, p. 7).

Response: The proposed action for the 1st48 Project is to create a shaded fuelbreak that relies on thinfrom-below treatment. The silviculture prescription is to retain the trees with the largest crowns, while 

still maintaining high enough stocking levels to maintain over a 60 percent crown closure and relatively 

high basal area retention. A tree’s susceptibility to blow down depends on several external factors, but the 

major risk factor associated with tree blowdown after thinning is the tree itself. Trees with smaller 

diameters relative to the trees’ height are much more susceptible to blowdown. These types of trees 

typically have smaller crowns. Basically, tall, skinny trees with small crowns are more susceptible to 

blowdown than larger diameter trees (with similar heights), with larger crowns. The 1st 48 prescription is 

to maintain the trees with the largest diameters and largest crowns, which are those trees that are least 

susceptible to blowdown. In addition, the prescription would be similar to other projects in the area 

(Beaverslide, Kelsey Peak and Little Doe/Low Gulch), that have not incurred significant blowdown after 

implementation. The probability of blowdown decreases each successive year after implementation, 

because of increased diameter growth and increased root growth, relative to increased height.

35. The EA states similar thinning projects are being carried out in this watershed including Beaverslide, 

Kelsey and other “foreseeable” actions [not listed] within the analysis area that include hazardous 
Appendix A. Response to Comments

218 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

fuel reduction projects and shaded fuelbreak construction and maintenance. The FS did not include 

the Little Doe/Low Gulch project that is also occurring in this watershed. There is no analysis of how 

all these timber related projects are impacting owl habitat and populations. (Denise Boggs, CC, p. 8).

Response: The EA discusses Little Doe/Low Gulch, Beaverslide and Kelsey projects. As stated in the 

EA, only the Kelsey Peak Project overlaps NSO ACs affected by the 1st 48 Project.

The design of the 1st 48 Project is similar to the Little Doe/Low Gulch Project, the Beaverslide Project, 

and the Kelsey Project, all of which the USFWS has determined to maintain current habitat function, and 

were “not likely to adversely affect” the NSO or NSO Critical Habitat. The USFWS defines “habitat 

maintenance” as a reduction in stand density, but the current habitat function would be maintained 

immediately post project with the purpose of improving its quality for the species over time. No habitat 

was removed in the previous projects nor will be by the 1st 48 Project, except for negligible amounts for 

landing construction; therefore, there were no changes to the habitat baseline from any of these projects. 

Cumulative impacts to the NSO affected by the 1st 48 and Kelsey projects were addressed in the EA.

36. In fact, the SRNF largely blows off this issue claiming in terms of past, proposed, ongoing and 

foreseeable actions, “the 1st 48 project would have no cumulative effects to vegetation structural stages 

within the South Zone. The current distribution has been molded by past activities, which removed 

older forest types, and by past wildfires.” Structural stages aside, what about cumulative effects to 

NSO and their suitable habitat? The entire headwaters of the Upper Mad River Watershed (5th field) 

has multiple timber sales occurring simultaneously. They are all in designated critical habitat (same 

unit); they all include LSR lands; they all include NSO ACs; they all involve smoke and noise; and 

none of them have been legitimately surveyed to the 2012 protocol.... (Denise Boggs, CC, p. 8).

Response: Please see response to comment #26 above.

37. The EA is relying on RA 32 and RA 10 to meet mitigation requirements for Barred owls. We have 

already shown neither of those RAs will be met. The EA also claims “Maintaining all historic ACs is 

a standard SRNF protection measure.” The 1st 48 project will not maintain historic ACs; not even the 

minimum habitat contained in each. (Denise Boggs, CC, p. 8).

Response: As described in responses above, both RA 32 and RA 10 would be met. The 1st 48 Project has 

protected all high-quality habitats (not just old growth), all spotted owl territories (not just high priority 

sites) and would restore, maintain, and accelerate important habitat characteristic for the spotted owl. 

“Maintaining or restoring these forests should allow time to determine both the competitive effects of 

barred owls on spotted owls and the effectiveness of barred owl removal measures” (II-67 of the 

Recovery Plan). Protecting these forests should provide spotted owls high-quality refugia habitat from the 

negative interactions with barred owls that are likely occurring where the two species’ home ranges 

overlap. The 1st 48 Project would not exacerbate competitive interactions between the two species. 

Without the implementing the additional protection measures and recovery actions of the Recovery Plan, 

the barred owl may be successful in out-competing the spotted owl. It is imperative to the spotted owl’s 

recovery to take such actions. The 1st 48 Project is meeting the objectives of the Recovery Plan.

The 1st 48 Project area has eight historic ACs identified. No treatments would occur within the 100-plusacre nest groves established around each known AC and no activities would occur in high-quality 

nesting/roosting habitat anywhere in the project area. Treatments in lower-quality habitat will maintain 

current habitat function. Surveys to the most current, USFWS approved-protocol have been conducted 

throughout the project area. Limited operating periods have been established for all activities within 0.25 
Appendix A. Response to Comments

Final Environmental Assessment – 219

miles of each AC. Updated surveys would be maintained throughout the life of the project or additional 

LOPs would be implemented on activities within 0.25 miles of nesting/roosting habitat without up-to-date 

surveys. The project will protect and maintain all NSO ACs.

38. The EA states surveys will be conducted in 2018 and throughout the life of the project. Based on one 

year of survey data the SRNF determined 7 of the 8 ACs were not occupied. It can’t make this 

assumption. The 2012 protocol requires 3 years of survey data to determine occupancy because owls 

can use different nest sites or are forced out by Barred owls to take up some place else. Protocol 

surveys on the Mendocino NF have found new ACs because of this very reason. The SRNF has not 

made an attempt to find NSO outside historic ACs, unless this information is in the BA that was 

withheld from the public. Survey results are important because they affect when LOPs will be 

implemented. If the SRNF only has one year of reliable survey data, then a Sept. 15th LOP should be 

used for all ACs. We would also like to know how many NSO were found in the 4 ACs that overlap the 

Kelsey project at the time of that analysis. (Denise Boggs, CC, pp. 8-9).

Response: The 2012 USFWS NSO survey protocol requires two years of surveys to determine occupancy, 

not three. The second year of surveys will be conducted in the 2018 season, before project implementation 

will occur. As stated in the EA, a LOP of February 1 through July 31 will be imposed for all known 

(previously documented) ACs per LRMP requirements; however, a February 1 through September 15 will 

be imposed for actions in occupied (by breeding birds) or unsurveyed nesting/roosting habitat. A single 

season of surveys or not continuing surveys in the future is considered “unsurveyed”. If surveys discover 

new ACs or find an AC location has moved, consultation with the USFWS will be reinitiated and the project 

will be modified if necessary to maintain a “not likely to adversely affect” determination.

Of the four “overlap” NSO ACs, at the time of the Kelsey Project analysis, one was not detected during 

project analysis but has since been detected, one was detected during the project analysis but has no 

detections since 2012, and the remaining two were detected during the project analysis and after (2014 

and 2015).

39. The EA includes a definition for N/R habitat, as defined by the FS, comprised of mature timbered 

stands, average canopy cover of 60% or greater; overstory should be comprised of conifer trees 21” 

dbh or greater; conifer canopy closure should be 40% or greater. “This habitat is used primarily for 

nesting/roosting.” It is important to note this is a FS definition – it is not in any way a USFWS 

definition. The FS is much weaker and is not based on the best available scientific information. 

(Denise Boggs, CC, p. 9).

Response: Please see response to comment #10 and #11 above.

40. The FS definition for N/R is based on bare minimums and is for “suitable” habitat versus “high quality” 

habitat. We also note the vast difference in basal area. High quality N/R requires 210+ sq/ft. The project 

won’t maintain anywhere near that in the vast majority of the project. (Denise Boggs, CC, p. 9).

Response: Please see responses to comments #10, #11, #25 and #27 above concerning habitat 

maintenance, minimum standards and basal area.

41. The SRNF is relying on an unpublished white paper that, that is almost 10 years old and has never 

been peer-reviewed to rely on a definition of low quality foraging habitat as having 40% canopy 

cover and 11” dbh trees. Again, this is a definition to maintain minimum foraging habitat not high 

quality foraging habitat. Regardless, the RRP has its own definitions which are the BAS information 
Appendix A. Response to Comments

220 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

that were developed by the USFWS – the agency that listed the species as ‘threatened’ under the ESA. 

The FS is required to use the BAS information and not create its own weaker definitions or rely on 

unpublished white papers. While it has some latitude to use “localized expertise” it’s clear it is 

relying on the white paper, which in no way is the BAS. Since it did, the entire analysis done for the 1st

48 project is suspect and not based on the BAS information. The SRNF has not demonstrated why the 

White Paper is the best available scientific information. Considering the vast peer-reviewed papers 

that have been published since 2009 on NSO and their habitat requirements, including those used in 

the RRP, many from N CA; we don’t believe the SRNF can justify use of this paper for anything. 

(Denise Boggs, CC, p. 10).

Response: The Forest did not base the entire analysis for the project on the white paper, or solely rely on 

the document for habitat definitions. The white paper is only one of many references used. The same 

literature cited in the white paper was used in developing the Recovery Plan and the Critical Habitat Rule. 

The white paper was developed by the USFWS within the Klamath Province and had specific relevance 

to the 1st 48 Project because some of the published literature discussed had been conducted on the SRNF 

(and Mad River District). The White Paper was not intended for publication but was a synthesis of the 

published literature specific to the analysis and effects of forest management on the NSO. The issue that 

the white paper was not published is moot because the literature it cited was published, and was 

incorporated into the Recovery Plan and the Critical Habitat Rule.

42. The EA also states that after logging and burning woodrats may be scarce in the project area and 

claims it will be a short-term impact but short-term isn’t defined. Owls have to eat and if they have to 

leave a secure area to hunt they are exposed to avian predators. This issue is brushed off as a shortterm impact with no mitigation. (Denise Boggs, CC, p. 10).

Response: The EA does not state that “woodrats may be scarce”. Potential effects to prey species are 

discussed in EA. Short-term effects were discussed. Proposed “jackpot” burning involves burning 

concentrations of fuels rather than broadcast burning, which will break up the continuity of the fuels in 

the understory to reduce flame length and spread of wildfire. This type of burn leaves a mosaic of 

unburned material on the forest floor, and promotes an increased vegetative complexity for understory 

species such as the dusky-footed woodrat.

Effects of jackpot burning would be limited because of this patchiness leaving interspaces of unburned 

forest floor. Foraging habitat will be modified as some understory shrubs and some small saplings would 

be killed and some smaller downed logs would be consumed from the jackpot burning; however, current 

habitat function will be maintained. The results will be a more complex understory and forest floor that 

will benefit key prey species for the spotted owl such as the dusky-footed woodrat.

Burn prescriptions are designed to prevent severe burn levels and retain large down woody material, and 

snags. In the short term, these small openings may be utilized by the owls for foraging as the prey leave 

the untreated forested areas adjacent to project units (North et al 1999, Carey 1995). In contrast to an 

unplanned wildfire, prescribed burning will be conducted under conditions where the flame length and 

intensity will be low. Dead and down materials are usually large enough in diameter that the logs are not 

burned completely and continue to provide key habitat features such as refugia and escape cover. Some of 

these stands once treated will be immediately improved for foraging by owls. In addition, owls are known 

to forage within the burned areas once the understory vegetation begins to grow again (USDA Forest 

Service 1985, Clark 2007).
Appendix A. Response to Comments

Final Environmental Assessment – 221

43. The EA quotes the 2012 CHU Rule that speaks to recommended forest management practices that 

speaks to the application of “ecological forestry practices” and using ecological forestry practices 

that are compatible with both the goals of NSO recovery and the S&Gs of the NWFP. The 1st 48 project 

does neither. Ecological forestry practices would not use exemptions to log 150-year old trees to make 

an economically viable timber sale. Ecological forestry practices would not continue to log ACs below 

minimum habitat thresholds because that further delays recovery. (Denise Boggs, CC, pp. 10-11).

Response: Trees that are 150 years old would not be removed. Canopy closure would be maintained at 

60 percent or greater in all treated areas, no pre-dominant or dominant trees will be removed and large 

snags and downed wood would be maintained at the 80 to 100 percent level. Co-dominant trees would 

only be removed if under specific conditions that would improve the growth of an adjacent larger conifer 

or large hardwood. All high quality nesting/roosting habitat consisting of old growth late mature, and 

some mid mature stands were excluded from commercial harvest. Selected stands for thinning are 

considered low to moderate quality, with the potential to be improved through treatment.

There is research support for improving habitat conditions for the NSO in deficit ACs. In the Recovery 

Plan, “Dugger et al. (2005) found that apparent survival and reproduction was positively associated with 

the proportion of older forest near the territory center (within 730 meters),” approximately 0.5 miles. 

Additionally, the Recovery Plan stated that Dugger et al. (“in press” was published later in 2011) found an 

inverse relationship between the amount of old forest within the core area and spotted owl extinction rates 

from territories” when barred owls were present (Dugger et al. in press). The Recovery Plan also states 

due to the “growing negative impact from barred owl invasions of spotted owl habitats (Forsman et al. 

2011, Dugger et al. in press)”..., we recommend increased conservation and restoration of spotted owl 

sites and high-value spotted owl habitat to help ameliorate this impact (emphasis added). In other words, 

without treatment of lower quality habitats in deficit core areas we may lose these sites to barred owls. 

The Recovery Strategy of the 2011 Recovery Plan supports “active forest management” and states that 

“In addition to describing specific actions to address the barred owl threat, this Revised Recovery Plan 

continues to recognize the importance of maintaining and restoring high value habitat for the recovery 

and long-term survival of the spotted owl”. The 1st 48 treatments within owl territories including core 

areas will maintain and improve habitat conditions for the spotted owl, while protecting existing habitat 

from wildfire.

44. This 5th field watershed has experienced widespread disturbance, this includes the more recent 

Beaverslide and Kelsey projects (with nearly 4,000 acres of commercial logging and over 6 miles of 

new road construction and over 7 miles of reconstruction) as well as recent wildfires and subsequent 

fire suppression and logging activities. Most notable are the concurrent impacts and fragmentation of 

Critical Habitat. (Kimberly Baker, EPIC, and George Sexton, KSWild, p.2)

Kelsey logged 2,175 acres of N/R/F habitat. It would be helpful for the SRNF to inform the public on 

how much of the CHU (179,758 acres) on the Mad River RD was also logged in past projects, 

including LDLG, BS, and proposed in the upcoming unnamed projects. This would present a more 

accurate reflection of how the unit is functioning on the SRNF. (Denise Boggs, CC, p. 11).

Response: As stated above, the design of the 1st 48 Project is similar to the Little Doe/Low Gulch, 

Beaverslide, and Kelsey projects, all of which the USFWS has determined to maintain current habitat 

function, and were “not likely to adversely affect” the NSO or NSO Critical Habitat (Table 31). The 

USFWS defines “habitat maintenance” as a reduction in stand density, but the current habitat function 

would be maintained immediately post project with the purpose of improving its quality for the species 

over time. No habitat was removed in the previous projects nor will be by the 1st 48 Project except for 
Appendix A. Response to Comments

222 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

negligible amounts for landing construction; therefore, there were no changes to the habitat baseline 

within Critical Habitat from any of these projects.

Table 31. Total treated acres in NSO Critical Habitat, Subunits ICC1 and ICC2. PCE= primary constituent 

element; PCE2=nesting roosting habitat; PCE3=foraging habitat; PCE4= dispersal habitat; CT=commercial 

thin from below; FR= fuels reduction, understory only; L/R acres removed for landings and roads.

Project PCE2

CT

PCE2

FR L/R PCE3CT

PCE3

FR L/R PCE4CT

PCE4

FR L/R

Little Doe / Low Gulch – 2007 54 48 0 127 142 0 156 112 0

Beaverslide – 2009 397 454 0.8 1,717 445 4.6 21 0 0

Kelsey Peak – 2013 62 352 2.7 1,225 946 13.2 192 0 0

1st 48 – 2018 228 62 0 196 151 3 108 0 0

Total acres in ICC1 subunit 39

Total acres in ICC2 subunit 741 877 3.5 3,265 1,684 20.8 477 112 0

When project planning was completed on Little Doe/Low Gulch and Beaverslide, the projects did not 

occur in NSO Critical Habitat (either the1992 or 2008 designations). Northern spotted owl Critical 

Habitat was revised in 2012, and both projects were within the newly designated areas. Consultation with 

USFWS was reinitiated for these to address the new information. The USFWS found that the projects 

would modify but maintain current habitat function in all units and habitat removal for landings or roads 

were negligible amounts in any one area. The USFWS determined these projects were not likely to 

adversely affect Critical Habitat.

Subunit ICC1: ICC1 is 43,663 acres in size, 1,774 acres of which is on the SRNF. Total treated in the 

subunit is 39 acres of PCE3 (foraging) habitat. There are 3,473 acres of PCE3 within the subunit, and 210 

acres on the SRNF. Total treated in the subunit represents 1 percent of PCE3 in the subunit, and 18 

percent of PCE3 on the SRNF.

Subunit ICC1: Subunit ICC2 is 224,777 acres in size. All but 425 acres occur on the SRNF. Of this, 92,359 

acres occur in nesting/roosting habitat, 59,443 acres in foraging, and 9,428 acres in dispersal-only habitat.

o Total PCE2 treated but maintained in ICC2 = 1,618 acres or 2%

o Total PCE2 removed in ICC2 = 3.5 acres or 0.003%

o Total PCE3 treated but maintained in ICC2 = 4,949 acres or 8%

o Total PCE3 removed = 20.8 acres or 0.03%

o Total PCE4 treated but maintained = 589 acres or 6% 

o Total PCE4 removed in ICC2 = 0.

45. All 8 ACs are well below minimum habitat thresholds and therefore “take” has already occurred; and 

the 1st 48 project will further reduce habitat in all 8 ACs by 189 acres. The reduction is anywhere 

from 2 to 25% depending on the AC. Combined with the Kelsey project, 4 of the ACs will be reduced 

further between 19% additional N/R habitat loss and 36% additional foraging habitat loss. Twelve 

landings totaling 3 acres will be removed from the ACs. Five of the landings are in N/R habitat and 7 

are in foraging habitat. We assume the FWS is authorizing take in the 1st 48 project – it really has no 

other choice. (Denise Boggs, CC, p. 11).

Response: Thinning and fuels reduction activities may have a short-term reduction of stand density in 

suitable NSO nesting/roosting habitat; however, the habitat will remain suitable post project. Canopy 
Appendix A. Response to Comments

Final Environmental Assessment – 223

closure will be maintained at 60 percent or greater in all treated areas, no pre-dominant or dominant trees 

will be removed and large snags and downed wood would be maintained at the 80 to 100 percent level. 

Co-dominant trees will only be removed if under specific conditions that will improve the growth of an 

adjacent larger conifer or large hardwood. All high quality nesting/roosting habitat consisting of old 

growth late mature, and some mid mature stands were excluded from commercial harvest. Selected stands 

for thinning are considered low to moderate quality, with the potential to be improved through treatment.

As stated above, the USFWS considers that effects to spotted owl habitats around ACs will be minimized 

with the design features above. The project will maintain and restore habitat conditions within the project 

area.

The Level 1 Team conducted informal consultation on the 1st 48 Project on December 13, 2017 and 

February 7, 2018, with a field visit on June 13, 2016. The Level 1 Team provided management 

recommendations that would minimize impacts to the NSO, and agreed that the project “may affect, but is 

not likely to adversely affect” the NSO or NSO Critical Habitat. No “take” will occur.

46. The SRNF has the gall to claim thinning and fuels reduction may have a short-term reduction of stand 

density in suitable NSO N/R habitat, but the habitat would remain suitable post project. If the ACs are 

already below minimum habitat thresholds; the proposed project combined with Kelsey will remove 

an additional 19-38% of the habitat in the ACs; how on earth does the SRNF claim they remain 

suitable post project? They aren’t currently suitable and this project sets back any opportunity to 

allow them to become suitable. (Denise Boggs, CC, p. 11).

Response: Please see responses to comments #10, #11, #25 and #27 24 above.

47. Since the SRNF relied on bare minimum FS habitat definitions, the analyses to consider impacts to 

PCEs is flawed. For example, for N/R habitat (PCE 2) it used conifers 21” dbh and 40% canopy 

cover. That is nowhere near the USFWS definition of 210+ sq/ft basal area; 8 trees 26” DBH or 

greater per acre; and 60% canopy cover. The same is true for foraging habitat (PCE 3) where the 

SRNF relied on the white paper versus the FWS recommendations which are stricter and require 

higher quality habitat. Dispersal habitat (PCE 4) is only mentioned once in the EA stating 145 acres 

would be logged and 8 acres would be removed for landings. Dispersal habitat is important for owl 

dispersal and requires security and connectivity in order to function. There is no information in the 

EA on this issue. (Denise Boggs, CC, p. 12).

Response: Please see responses to comments #10, #11, #13, #14, #23, #25 and #26 above.

As stated in the EA, NSO will use nesting/roosting and foraging habitat for dispersal, as well as 

“dispersal-only” stands. Dispersal-only habitat are defined as trees with 11-inch dbh or greater and a 

minimum 40 percent canopy cover. The units defined as dispersal-only habitat are very low quality 

because they are densely stocked with little space for an owl to fly through. Thinning would reduce stand 

density; however, post-treatment canopy cover would be maintained at 60 percent or greater. These stands 

would be immediately improved as post-treatment dispersal habitat.

48. The LOP from Feb 1- July 31 within 0.25 miles of each AC is not adequate. First, the LOPs should be 

within 0.5 miles of each AC according to the FWS, and we believe a Sept. 15th date (versus July 31) 

is called for considering the SRNF really has no idea how many NSO are in the project area..

Response: Please see response to comment #38 above. Also, the USFWS does not use 0.5 miles from 

ACs to impose LOPs, but rather 0.25 miles.
Appendix A. Response to Comments

224 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

49. The EA states the SRNF worked with the FWS on the BA during the consultation process. The BA could 

change after the public comment period ends – and if so that’s a NEPA violation. This project is 

documented in an EA and therefore a FONSI is required. The determination in the EA for NSO and CHU 

is MANLAA. Neither of these determinations can be substantiated based on the information in the EA. 

First of all, all 8 ACs are already at ‘take” level; and this project will continue reduce N/R/F habitat in 

each AC further reducing use by owls. Under the FWS own rules it will have to authorize “take” in this 

project, and if so, a MANLAA and FONSI cannot be supported. (Denise Boggs, CC, p. 12).

Response: Please see responses to comments #6, #7 and #23 above.

50. The EA states most dens are formed in large (average 36” DBH) trees and snags, and these trees are 

often much older than those available with Douglas-fir averaging 177 years. Does the project area 

have so many 150-year old trees that it can afford to log them, if Fisher require trees older than 177 

years for denning? We request a breakdown of how many trees will be logged by species, age and 

diameter class in this project. Table 9 has generic information on this issue but not specific 

information. While the proposed alternative makes it sounds as if a few codominant trees will be 

logged; the rest of the EA presents a different story. To resolve that it would be helpful to know how 

many trees 24” dbh and greater will be logged in this project. Since the SRNF is attempting to use the 

exemption the STNF received from the REO 9 years ago to log 150-year old trees; how many 150-

year old trees will be logged in this project? We believe a diameter limit and LOPs should be imposed 

within 0.5 miles of the three areas fisher were found. This would protect den sites the SRNF did not 

find (Denise Boggs, CC, p. 12).

Response: The project, as designed, will protect all pre-dominant and dominant trees, large logs, and 

large diameter snags (20-inch dbh or greater) unless they pose an imminent safety hazard. Large snags 

felled for safety reasons would be left on site.

The LRMP requirement for LOPs for fisher is to protect “active dens”. The SRNF is conservatively 

imposing LOPs on potential dens sites.

Approximately 95 percent of the tree targeted for removal are less than 20 inches in diameter, and the 

majority of these are less than 16-inch dbh. Table 32 provides a breakdown for species by diameter class 

anticipated to be thinned. Age does not correlate to tree diameter, as suppressed trees with stunted growth 

in the understory may be the same age or older than intermediate and co-dominant trees. The core

samples taken indicate the range in ages for trees that would be thinned was 75 years to 119 years. Based 

on CSE FVS in the Douglas-fir stands, approximately 28,600 trees total were modeled to be thinned. The 

predicted estimate is 530 Douglas-fir trees 24-inch dbh and greater would be cut, representing 1.8 percent 

of the trees. In the white fir stand, approximately 18,570 trees total were modeled to be thinning; of these 

186 white fir trees 24-inch dbh and greater would be cut, representing 1.0 percent. An estimated 95

percent of the tree targeted for removal are less than 20 inches in diameter, and the majority of these are 

less than 16-inch dbh.
Appendix A. Response to Comments

Final Environmental Assessment – 225

Table 32. Predicted tree species, age and diameter classes proposed for removal.

DBH grouping 2"-DBH class Estimated number of trees modeled to be cut by species, based on plot data

DF WF PP IC

9" – 10" 10" 11,890 6,128 0 0

11" – 12" 12" 7,100 3,343 0 0

13" – 14" 14" 3,905 2,693 93 278

15" – 16" 16" 2,310 2,878 186 186

17" – 18" 18" 1,420 1,764 0 0

19" – 20" 20" 710 836 93 0

21" – 22" 22" 710 650 0 0

23" – 24" 24" 355 278 0 0

25" – 26" 26" 177 0 0 0

51. It was disturbing to read that no goshawks were found in the project area. These raptors use similar 

habitat as NSO. What has happened to the goshawk population in the Mad River headwaters? Are 

timber sales impacting this species to a degree they have been extirpated? (Denise Boggs, CC, p. 13).

Response: The goshawk is an uncommon species that does not occupy all potential habitat. Goshawks 

are not extirpated from the Mad River District, on the contrary, many active nests have been documented 

on the District.

52. We further request that implementation only be allowed after NSO surveys have been completed to 

protocol and do not show a change from what is analyzed in the EA. (Kimberly Baker, EPIC, and 

George Sexton, KSWC, p.2)

Response: Please see response to comment #38 above.
Appendix A. Response to Comments

226 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

This page intentionally left blank.
Appendix B. Proposed Activities

Final Environmental Assessment – 227

Appendix B. Proposed Activities

Table 33 through Table 36 display the 36 units (up to 395 acres total) with sufficient tree sizes and 

quantity of forest by-products to support an economically viable commercial sale of timber and poles. 

This opportunity would generate revenue to offset hazard fuel reduction (HFR) and other manual, 

prescribed burning and fuelbreak maintenance activities. There are ten additional units with limited 

commercial opportunity requiring further evaluation to determine economic viability as part of a 

commercial sale package; ground based units 111, 311, and 614 (11 acres total), and cable units 112, 205, 

206, 312, 408, 422, and 423 (34 acres total).

Logging systems are based on site conditions and existing road infrastructure. Ground or cable based 

systems would be used where units are accessible from either National Forest System (NFS) roads or 

existing skid roads off system roads. Ground-based yarding systems would be used to remove whole trees 

on slopes up to 35 percent, using either tracked or rubber-tired skidders. Cable yarding systems would be 

used to remove whole trees on steeper ground (slopes greater than 35 percent). There is no new temporary 

road construction. Existing non-system roads are generally old Jeep roads or temporary roads constructed 

for past harvest activities. These roads require re-opening and blading prior to use. Road reconstruction, 

as defined by Forest Service Manual (FSM) 7700, would not be required.

Landings would be needed to log the proposed units based on intensive field reconnaissance. Actual locations 

for new landings may vary slightly and are subject to agreement by the Forest Service and timber purchaser 

under the Timber Sale Contract or other agreements. All landings would comply with best management 

practices (BMPs) and project design features. Existing landings and skid trails would be used to the fullest 

extent possible. New landings may be constructed where necessary to facilitate logging operations.

Table 33. Summary of the proposed shaded fuelbreak activities by unit – Cable/Leave Tree Mark.

Unit Estimated Acres to 

Mark and Cruise Potential Utilization Logging System Tree Designation

103 2 Saw log Cable Leave Tree Mark

104 7 Saw log Cable Leave Tree Mark

107 1 Saw log Cable Leave Tree Mark

108 3 Saw log Cable Leave Tree Mark

201 3 Saw log Cable Leave Tree Mark

204 2 Saw log Cable Leave Tree Mark

302 3 Saw log Cable Leave Tree Mark

305 1 Saw log Cable Leave Tree Mark

307 1 Saw log Cable Leave Tree Mark

403 7 Saw log Cable Leave Tree Mark

501 6 Saw log Cable Leave Tree Mark

503 3 Saw log Cable Leave Tree Mark

504 4 Saw log Cable Leave Tree Mark

Total Acres 43
Appendix B. Proposed Activities

228 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Table 34. Summary of the proposed shaded fuelbreak activities by unit – Ground/Leave Tree Mark.

Unit Estimated Acres to 

Mark and Cruise Potential Utilization Logging System Tree Designation

101 3 Saw log Ground Leave Tree Mark

102 4 Saw log Ground Leave Tree Mark

105 5 Saw log Ground Leave Tree Mark

106 8 Saw log Ground Leave Tree Mark

109 11 Saw log Ground Leave Tree Mark

202 1 Saw log Ground Leave Tree Mark

203 2 Saw log Ground Leave Tree Mark

301 4 Saw log Ground Leave Tree Mark

303 1 Saw log Ground Leave Tree Mark

304 1 Saw log Ground Leave Tree Mark

306 13 Saw log Ground Leave Tree Mark

401 19 Saw log Ground Leave Tree Mark

402 15 Saw log Ground Leave Tree Mark

407 16 Saw log Ground Leave Tree Mark

411 16 Saw log Ground Leave Tree Mark

502 5 Saw log Ground Leave Tree Mark

505 1 Saw log Ground Leave Tree Mark

801 15 Saw log Ground Leave Tree Mark

802 37 Saw log Ground Leave Tree Mark

803 10 Saw log Ground Leave Tree Mark

804 7 Saw log Ground Leave Tree Mark

805 23 Saw log Ground Leave Tree Mark

Total Acres 217

Table 35. Summary of the proposed shaded fuelbreak activities by unit – Cable/Cut Tree Mark.

Table 36. Summary of the proposed shaded fuelbreak activities by unit – Ground/Cut Tree Mark.

Unit Estimated Acres to 

Mark and Cruise Potential Utilization Logging System Tree Designation

405 12 Sawlog Ground Cut Tree Mark

406 4 Saw log Ground Cut Tree Mark

421 2 Saw log Ground Cut Tree Mark

424 4 Saw log Ground Cut Tree Mark

605 41 Saw log Ground Cut Tree Mark

611 8 Saw log Ground Cut Tree Mark

616 8 Saw log Ground Cut Tree Mark

Total Acres 79

Unit Estimated Acres to 

Mark and Cruise Potential Utilization Logging System Tree Designation

100 3 Saw log Cable Cut Tree Mark

410 9 Saw log Cable Cut Tree Mark

412 24 Saw log Cable Cut Tree Mark

509 13 Saw log Cable Cut Tree Mark

617 7 Saw log Cable Cut Tree Mark

Total Acres 56
Appendix C. Best Management Practices

Final Environmental Assessment – 229

Appendix C. Best Management Practices

Prevention – Terrestrial Invasive Plants (USDA/USFS 2014)

GP5. Actions conducted or authorized by written permit by the Forest Service operating on and outside 

the road prism (including public works, special-uses, and service contracts) will require cleaning of all 

heavy equipment (bulldozers, skidders, graders, backhoes, dump trucks, etc.) prior to entering National 

Forest System (NFS) lands).

GP6. Each unit shall identify sites for Forest Service vehicle cleaning and equip the sites sufficiently 

(i.e., high-pressure hose) to ensure mud or vegetative material trapped in tires or on the carriage of the 

vehicle can be effectively removed.

GP7. If there is a moderate to high risk of spreading invasives from an infested area to an uninfested 

area during operations and alternate project design features are not feasible to reduce risk of spread, 

equipment/machinery shall be cleaned prior to leaving the infested area and operating elsewhere.

GP8. When needed to control soil erosion, use mulch from chipped or masticated material or mulch 

native material or certified weed-free straw (see www.cal-ipc.org/ip/prevention for a weed-free forage and 

straw supplier list).

GP9. Rock, sand or other material to be used for projects conducted or authorized by the Forest Service 

shall originate from a weed-free source. Rock source shall be inspected by staff trained in invasive plant 

identification or if source is off-forest, contractor shall provide documentation that material is weed-free.

GP10. Material excavated at a project site that is contaminated with invasive plants can be a. reused at 

the site, b. stockpiled on site or c. relocated to an area that is already contaminated. During transport of 

contaminated soil or sand, cover material with an impervious material.

GP15. Locate activity boundaries or areas of concentrated use to exclude areas infested with invasive 

plants. Activity boundaries include staging areas, parking areas, trailheads, river access points, roadside 

pullouts, and timber harvest landings.

Timber and Fuels

TF1. In planning fuel treatment projects proximal to settings with invasive plants (e.g., road edges), 

consider the risk of invasive plants spreading into the treatment area. Where the risk of spread into the 

treatment area is moderate to high (e.g., invasive plant cover is relatively high along the road edge where 

treatment is planned to occur), incorporate design features to reduce the spread of invasives. For example:

o For manual/hand-removal treatments or mechanical treatments, remove only enough vegetation 

and ground cover in the treatment area to accomplish fuel management/resource objectives; retain 

patches of shrubs and ground cover.

TF2. Prior to implementation of timber operations, where the risk of spread is moderate to high, via 

contractor or force account, treat invasive plant-infested road medians, landings, processing areas or other 

clearings used in the course of project implementation proximal in time before the start of operations. 

Treatment may include machine removal, weed whacking, or hand treatments. Invasive plants or shrubs 
Appendix C. Best Management Practices

230 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

removed shall be located on the edge of the clearing out of the way of operations to avoid retrieval on 

equipment.

TF4. Where the risk of invasive plant spread and establishment is moderate to high in association, with 

landings, processing or staging areas... after their use, employ one of the following measures to cover the 

disturbed area:

o Distribute masticated material or mulch native plant material/wood straw to a depth of 

approximately 3 to 5 inches,

o Distribute logging-related slash (e.g., tops, bark, limbs) that is crushed/condensed in such a manner 

that this material is close to the ground providing moderate to high shade to the ground, and

o If feasible/practicable, decompact/rip and revegetate area with suitable native planting stock that 

optimizes resistance to invasive plant establishment (e.g., tree stock, earlysuccessional/disturbance tolerant shrubs).

TF5. If applicable, implement timber as well as subsequent fuels activities according to a progression 

of work, which prioritizes operating in relatively invasive plant-free sections of the planning area before 

moving equipment and general operations to areas of the project where invasive plants are present. As an 

example, along a given primary Forest Service route, first conduct work in those units located in the 

upper watershed where invasive plant cover is lower before operating machinery in units off the portion 

of the road in the lower watershed position where invasive plants are more common.

Roads

RD5. Incorporate, where applicable, the following into Forest road decommissioning projects to reduce 

the risk of an existing invasive plants occurrence from spreading occurrence to unoccupied areas as a 

result of project implementation:

o Where there is a risk of spread of invasive plants from an existing occurrence on or along the road 

to be decommissioned into unoccupied wildland settings (e.g., in settings where the vegetative 

ground and canopy cover in the adjacent habitat is minimal), remove entire plant (including roots) 

mechanically or manually prior to decommissioning,

o Mechanically or manually remove any invasive plant occurrence (remove entire plant) at the 

intersection of the decommissioned road and Forest system road.

 Apply ground cover in the form of native mulch/finely masticated material or mulch 

material spread to depth of 6 inches over the area where plants were removed, or ,

 If feasible, decompact/rip and revegetate area with suitable native planting stock that 

optimizes resistance to invasive plant establishment (e.g., tree stock, earlysuccessional/disturbance tolerant shrubs).

Soils

Various types of soil disturbance (compaction, displacement, severe burning, etc.) may affect key soil 

functions in different ways on different soils and sites. Both degree and extent of disturbance are 

important considerations that must be evaluated together to assess potential adverse impacts on soil 

functions for the activity area.
Appendix C. Best Management Practices

Final Environmental Assessment – 231

Soil Quality Standards (LRMP, Appendix L)

SQS provide threshold values to identify when changes in soil properties or conditions become 

detrimental. Areas of detrimental soil disturbance should not be of a size or extent that would result in a 

significant change in production potential for the activity area, generally assumed to be 15 percent of the 

area. Some standards are qualitative and some are quantitative. Six Rivers’ SQS use the following soil 

properties, conditions, and threshold values to evaluate management effects on the key soil functions of 

soil productivity and hydrologic function:

1. Soil cover for erosion prevention is sufficient to prevent the rate of accelerated soil erosion from 

exceeding the rate of soil formation (which is unknown and unknowable; number 2 is assumed to 

meet this objective unless stated otherwise for particular sites).

2. The kind, amount and distribution of soil cover necessary to avoid detrimental accelerated soil 

erosion is guided by the Region 5 Erosion Hazard Rating system (R5 FSH 2509.22) and locally 

adapted standard erosion models and measurements.

3. Soil porosity is at least 90 percent of the total porosity found under undisturbed or natural conditions. 

Porosity is evaluated between 4 and 8 inches below the surface. (compaction standard, 10% reduction 

in total porosity is “detrimental”).

4. Organic matter is present in sufficient amounts to prevent significant short or long-term nutrient cycle 

deficits, and to help avoid adverse physical soil characteristics (kinds and amounts of organic matter 

follow).

5. Soil organic matter in the upper 12 inches of soil is at least 85 percent of the total soil organic matter 

found under undisturbed conditions for the same or similar soils. (displacement standard; notably this 

is highly uncertain in measuring or implementing).

6. Litter and duff occurs over at least 50 percent of the activity area. Use the presence of living 

vegetation that could contribute significant annual litterfall to compensate for conditions when postdisturbance litter and duff coverage is less than 50 percent.

7. Large woody material, when occurring in forested areas, is at least five (5) logs per acre in contact 

with the soil surface. Desired logs are about 20 inches in diameter, about 10 feet long, and represent 

the range of decomposition classes [as defined]. Attempt to protect logs in decomposition classes 3 to 

5 from burning and mechanical disturbance. Large woody material requirements may be waived in 

strategic fuelbreak areas.

8. Infiltration and permeability are not reduced to ratings of 6 or 8 as defined in the R5 EHR system. 

(soil hydrologic function standard; “water movement” rating in EHR).

9. Soil reaction class, buffering or exchange capacities, or biological populations are not altered to the 

degree that significantly affects soil productivity, soil hydrologic function, or the health of humans 

and animals [soil chemical and biological standard; this is another unknowable and nonimplementable standard; notably the language this was taken from in the old R5 Supplement tied this 

to “materials added to the soil” will not have this effect, originally intended for fertilizer or herbicide 

applications].
Appendix C. Best Management Practices

232 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Water Quality

(USDA Forest Service. April 2012. Best Management Practices for Management on National Forest 

System Lands. From: National Volume 1: National Core BMP Technical Guide. FS-990a.)

Plan-2. Project Planning and Analysis (incorporates BMPs into project design and implementation).

Fire-1. Wildland Fire Management Planning (incorporates BMPs into project burn plans).

Fire-2. Use of Prescribed Fire (details methods to reduce impacts to soil and water from fire).

Fire-3. Wildland Fire Control and Suppression (details methods to reduce impacts to soil and water from 

suppression activities such as fireline construction).

Fire-4. Wildland Fire Suppression Damage Rehabilitation (details methods to repair or rehabilitate fire 

suppression activities such as fireline construction).

Road-4. Road Operations and Maintenance (details methods to avoid or minimize effects to water quality 

from road use. Includes wet weather operations).

Road-6. Road Storage and decommissioning (techniques to close a road and place in a free-draining, 

more natural, maintenance-free condition)

Road-7. Stream Crossings (techniques to mitigate effects to soil and water from constructing or 

reconstructing waterbody crossings).

Road-9. Parking and Staging Areas (methods to minimize effects from parking or staging areas such as 

landings).

Road-10. Equipment Refueling and servicing (guidelines to avoid soil or water contamination from fuel 

or other chemicals associated with maintenance of heavy equipment).

Veg-1. Vegetation Management Planning (incorporates BMPs into vegetation management projects).

Veg-2. Erosion Prevention and Control (techniques to avoid or minimize effects to soil and water from 

mechanical vegetation treatments).

Veg-3. Aquatic Management Zones (methods to avoid or minimize effects to soil and water in Riparian 

Reserves).

Veg-4. Ground-Based Skidding and Yarding Operations (techniques to minimize site disturbance and 

avoid or minimize sediment production from ground-based operations).

Veg-5. Cable and Aerial Yarding Operations (techniques to minimize site disturbance and avoid or 

minimize sediment production from skyline operations).

Veg-6. Landings (techniques to avoid or minimize effects to soil and water specific to the construction 

and use of log landings).

Veg-8. Mechanical Site Treatment (techniques to minimize site disturbance and avoid or minimize 

sediment production from mechanical thinning and fuel treatments).

Water Uses-3. Administrative Water Developments (techniques to avoid or minimize effects to water 

quality when drafting from streams or ponds).